SERIOUS SERVICES Serious Services LLC Health, Safety & Environment System The controlled version of this document is C Drive: HSEMS Version 0 Custodian SS – 2/8/2016 Paper copies are uncontrolled 1 SERIOUS SERVICES HEALTH, SAFETY AND ENVIRONMENT MANAGEMENT SYSTEM 1. SCOPE: ........................................................................................................................................... 9 2. DEFINITIONS: ................................................................................................................................ 9 3. HSE MANAGEMENT: ................................................................................................................... 16 3.1. POLICY: ................................................................................................................................... 16 3.1.1. Health, Safety And Environment (HSE) Policy: ......................................................................... 16 3.1.2. Policy on Environmental Protection: ...................................................................................... 17 3.1.3. Policy on Employee and Facility Safety and Occupational Health: ............................................... 18 3.1.4. Policy on Product Safety Stewardship: .................................................................................... 18 3.1.5. Policy on Minimisation of Emissions, Effluents and Wastes: ........................................................ 19 3.1.6. HSE Vision, Mission, Values: ................................................................................................ 20 3.2. REQUIREMENTS: ........................................................................................................................ 21 3.3. ROLES AND RESPONSIBILITIES: ..................................................................................................... 24 3.4. ESTABLISHING HSE OBJECTIVES AND TARGETS: .............................................................................. 25 3.5. IMPLEMENTING HSE PLANS: ........................................................................................................ 26 3.6. IMPROVEMENT INCENTIVES: ......................................................................................................... 26 3.7. HSE MANAGEMENT SYSTEM AUDITS: ............................................................................................ 27 3.8. MANAGEMENT REVIEW: .............................................................................................................. 28 3.9. COMMUNICATIONS AND INFORMATION SHARING: ............................................................................ 28 4. LEADERSHIP AND COMMITMENT: ............................................................................................ 32 5. POLICY AND STRATEGIC OBJECTIVES: .................................................................................... 33 6. ORGANISATION, RESOURCES AND DOCUMENTATION: ............................................................ 34 6.1. ORGANISATIONAL STRUCTURE AND RESPONSIBILITIES:...................................................................... 34 6.2. MANAGEMENT REPRESENTATIVE(S): .............................................................................................. 35 6.3. RESOURCES: ............................................................................................................................. 35 6.4. COMPETENCE: ........................................................................................................................... 35 6.4.1. General:............................................................................................................................ 35 6.4.2. Training: ........................................................................................................................... 36 6.5. CONTRACTORS: ......................................................................................................................... 37 6.6. COMMUNICATION: ...................................................................................................................... 37 6.7. DOCUMENTATION AND ITS CONTROL: ............................................................................................. 38 6.7.1. HSEMS Documentation:....................................................................................................... 38 6.7.2. Document Control:.............................................................................................................. 38 7. EVALUATION AND RISK MANAGEMENT: .................................................................................. 40 7.1. 7.2. 7.3. 7.4. 7.5. 7.6. 7.7. 7.8. HAZARD MANAGEMENT: ............................................................................................................. 40 IDENTIFICATION OF HAZARDS AND EFFECTS: .................................................................................... 41 EVALUATION:............................................................................................................................ 42 RECORDING OF HAZARDS AND EFFECTS: .......................................................................................... 43 STRATEGY REQUIREMENTS: ......................................................................................................... 43 OBJECTIVES AND PERFORMANCE CRITERIA:..................................................................................... 43 RISK REDUCTION MEASURES: ....................................................................................................... 43 IMPLEMENTATION: ..................................................................................................................... 44 The controlled version of this document is C Drive: HSEMS Version 0 Custodian SS – 2/8/2016 Paper copies are uncontrolled 2 SERIOUS SERVICES PLANNING: .................................................................................................................................. 45 8. 8.1. 8.2. 8.3. GENERAL: ................................................................................................................................ 45 ASSET INTEGRITY:...................................................................................................................... 45 PROCEDURES AND WORK INSTRUCTIONS:........................................................................................ 46 8.3.1. Developing Procedures: ....................................................................................................... 46 8.3.2. Issuing Work Instructions: .................................................................................................... 46 8.4. MANAGEMENT OF CHANGE: ......................................................................................................... 46 8.5. CONTINGENCY AND EMERGENCY PLANNING: ................................................................................... 47 IMPLEMENTATION: .................................................................................................................... 49 9. 9.1. 9.2. 9.3. 9.4. 9.5. 9.6. ACTIVITIES AND TASKS: .............................................................................................................. 49 MONITORING:............................................................................................................................ 50 RECORDS:................................................................................................................................. 50 NON-COMPLIANCE AND CORRECTIVE ACTION: ................................................................................. 51 INCIDENT REPORTING: ................................................................................................................ 51 INCIDENT FOLLOW-UP: ................................................................................................................ 52 AUDIT AND REVIEW: ............................................................................................................ 53 10. 10.1. 10.2. AUDIT: ................................................................................................................................. 53 REVIEW: ............................................................................................................................... 54 POLICY ON ENVIRONMENTAL PROTECTION: ................................................................................. 56 POLICY ON EMPLOYEE AND FACILITY SAFETY AND OCCUPATIONAL HEALTH: ........................ 57 POLICY ON PRODUCT SAFETY STEWARDSHIP: ............................................................................... 58 POLICY ON MINIMISATION OF EMISSIONS, EFFLUENTS AND WASTES: ........................................ 59 The controlled version of this document is C Drive: HSEMS Version 0 Custodian SS – 2/8/2016 Paper copies are uncontrolled 3 MANAGEMENT SYSTEM HEALTH, SAFETY AND ENVIRONMENT Serious Services LLC (SERIOUS SERVICES) believes it to be in the best interest of The Company to have a comprehensive Policy and Guidelines for Health, Safety and Environmental programs. SERIOUS SERVICES further believes that by working together, each of the Company will have a stronger, more efficient and cost effective program. Costs can be reduced and efficiencies improved by shifting our approach on Health, Safety and Environmental (HSE) issues to one that aligns and builds systematic processes for continuous improvement in business and HSE performance. A Health Safety and Environmental Management System (HSEMS) approach based on Total Quality Management principles will provide this. The goal of this HSEMS is to develop and implement business processes that will help line management to: Prevent incidents resulting in injuries, environmental damages, business interruptions or loss of assets Reduce operating costs Reduce instances of non-compliance with Group HSE Guidelines Continuously improve HSE performance Maintain The SERIOUS SERVICES reputation This HSEMS will enable SERIOUS SERVICES through its Group Company, Principals and Chief Operating Officers (GM) to drive the HSE Management processes throughout all operations. SERIOUS SERVICES has policies to help ensure that business is conducted with full concern for preserving the Environment and the Health and Safety of our workforce, neighbouring community and customers. To carry out these policies, the traditional approach has been based on an array of directives, controls and programs for compliance with emerging regulations, standards, rules and procedures. Our performance has been very good, and this approach served SERIOUS SERVICES and the Group Companies well in the past; but it cannot easily keep pace with the current speed or complexity of our changing business, technical and organisational needs or the increase in laws, regulations, and international standards. Major international companies have recognised this need and are developing systematic approaches for addressing HSE issues and compliance. We must do likewise if we are to remain competitive in the world market and be perceived as a good environmental citizen. This HSEMS must and will be a tool to improve our business and our HSE performance. The controlled version of this document is C Drive: HSEMS Version 0 Custodian SS – 2/8/2016 Paper copies are uncontrolled 4 The HSEMS will provide the following: HSE goals and targets will be clarified. Business process analysis techniques will be used to identify important HSE processes associated with supporting and improving key activities and business performance. Targeted are the HSE processes and activities that, if done well, will help us consistently meet our business goals, objectives and legal requirements at less cost, and with greater efficiency. This process will highlight which HSE related processes and activities should be emphasised for continuous improvement. Roles, responsibilities and expectations will be clarified. This will be accomplished through a systematic process to identify who, at each level of the organisation, is responsible for implementation and improvement of each relevant HSE related process and activity. Innovation will be fostered. This will be accomplished by providing a high degree of flexibility in how key HSE related processes and activities are implemented to deliver improved business performance, improved risk exposure and liability management, and cost effective regulatory compliance. Improved measurement and feedback mechanisms will be provided. This will help management better assess individual, departmental, organisational, and Group Company progress and to initiate appropriate action to achieve desired results. It will facilitate more consistent recognition for improvement of results. Participation and mobilisation of our leaders and workforce will be improved. This improvement will be gained by providing clarity regarding which HSE related processes and activities to emphasise and who is responsible for maintaining or improving each of those processes or activities. This will provide a clearer link between personal HSE related responsibilities and the business. Teamwork in HSE related activities will be enhanced. This enhancement will come from establishing a systematic framework for better defining expectations, priorities, key processes and technologies. This will also strengthen support for decision-making through improved analysis of HSE risks, exposures, liabilities, costs and benefits. The controlled version of this document is C Drive: HSEMS Version 0 Custodian SS – 2/8/2016 Paper copies are uncontrolled 5 HEALTH, SAFETY AND ENVIRONMENT (HSE) POLICY The controlled version of this document is C Drive: HSEMS Version 0 Custodian SS – 2/8/2016 Paper copies are uncontrolled 6 SERIOUS SERVICES LLC HEALTH, SAFETY AND ENVIRONMENT (HSE) POLICY It is Serious Services LLC (SERIOUS SERVICES) and Power Appliances Co. SAOC Policy to conduct activities in a manner designed to minimise HSE risks, protect the health and safety of employees, contractors, customers, the community at large and the environment in which the Company activities are conducted. SERIOUS SERVICES believes that good HSE performance will contribute and determine the success of the business and will treat HSE as an integral part of the business and with the same importance as other business goals. Serious Services LLC Will: Comply with all applicable laws and regulations and apply internationally recognised standards where local laws and regulations do not exist. Hold all levels of line management accountable for HSE issues. Require contractors to apply same or similar HSE standards, practices and procedures. Undertake appropriate reviews and evaluations to measure HSE performance against defined standards and to ensure compliance with this policy. Provide appropriate HSE training to employees. Develop and maintain HSE emergency procedures. Manage all risks to a level, which is ‘As Low As Reasonably Practicable’ (ALARP) Openly report HSE performance and ensure Lessons are learned. Control and manage all chemical, physical, biological, mechanical and psychosocial factors, which contribute to health risks. Strive to protect and promote the health of all employees and contractors. Progressively reduce emissions, effluents and wastes and improve efficient use of natural resources and energy. Minimise the impact of SERIOUS SERVICES activities on the environment. Signed: ????????…………………………Date:………………. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 7 SERIOUS SERVICES LLC SERIOUS SERVICES LLC HEALTH, SAFETY AND ENVIRONMENT MANAGEMENT SYSTEM The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 8 SERIOUS SERVICES LLC SERIOUS SERVICES HEALTH, SAFETY AND ENVIRONMENTMANAGEMENT SYSTEM INTRODUCTION The SERIOUS SERVICES HSE Management System (HSEMS) is a quality-based, structured, process for managing HSE activities. Through this process, SERIOUS SERVICES management wishes to clearly communicate the minimum level of HSE performance it expects Group Companies to meet, and its desire for continuous improvement of HSE performance. Personnel are to establish objectives and targets to meet or exceed these minimum levels of HSE performance, implement plans to achieve those objectives and targets, periodically measure their progress, and then readjust the objectives and targets accordingly to provide continuous improvement. SERIOUS SERVICES HSE policies (Section 3.1) provide the foundation for the HSEMS. To these are added HSE Vision, Mission and Value Statements (Section 3.1) to provide the philosophical cornerstone for the HSEMS by articulating where we are going as an organisation what we believe and how we conduct our business regarding HSE. In addition, the HSE Values provide a code of conduct to guide employees as they assume greater responsibility and accountability in the conduct of business. SERIOUS SERVICES Management states its minimum levels of HSE performance as a set of Expectations (Section 3.2), which are to be used by the Group Companies to translate SERIOUS SERVICES HSE Policies, Vision, Mission and Values into Systems, Programs and Procedures. These Expectations are grouped into eleven HSE areas called Elements. The Expectations focus on maximising the effectiveness of SERIOUS SERVICES Company Management and Staff to achieve desired HSE performance and improve the return from our assets. While the Expectations indicate WHAT level of HSE performance is required, people at each of the Group Companies locations are empowered to determine HOW to meet or exceed that level of performance. They are expected to develop the Systems, Programs and Procedures best suited to their needs, after considering operating conditions and requirements, best practices, experience of other Group Companies, major international companies and international standards. A Library of HSE Systems, Programs and Procedures will be maintained by SERIOUS SERVICES head office. This will allow for effective sharing of best practices and will assist in this process. Nevertheless, each Company will be free to achieve the HSEMS Expectations as it chooses. This HSE Management System includes a description of roles and responsibilities for implementing and maintaining the system (Section 3.3), procedures for establishing HSE objectives and targets (Section 3.4) and for implementing HSE programs (Section 3.5). After the initial implementation of the HSEMS, SERIOUS SERVICES goal is to establish a continuous improvement process to ensure that the HSEMS will be an integral part of each business (Section 3.6). The HSEMS includes HSE audit (Section 3.7) and management review (Section 3.8) procedures. Finally, the success of the HSEMS depends on there being clear, two-way communications and information exchange among and between all levels of SERIOUS SERVICES Group Companies (Section 3.9). 1. SCOPE: The HSEMS has been developed to provide direction to the SERIOUS SERVICES companies and to ensure that the management of HSE throughout the organisation is aligned with SERIOUS SERVICES HSE Policy, Vision, Mission and Values. The HSEMS should also be considered for all contractors. 2. DEFINITIONS: For the purposes of these HSEMS Guidelines, the following definitions apply: Accident: See ‘Incident’ SERIOUS SERVICES The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 9 SERIOUS SERVICES LLC Refers to SERIOUS SERVICES and its Principal and Chief Operating Officers responsible for Policies and Guidelines for the operating entities described as ‘Company’ below. As Low As Reasonably Practicable (ALARP): To reduce a risk to a level which is ‘as low as reasonably practicable’ involves balancing reduction in risk against the time, trouble, difficulty and cost of achieving it. This level represents the point, objectively assessed, at which the time, trouble, difficulty and cost of further reduction measures become unreasonably disproportionate to the additional risk reduction obtained. Audit Finding: An Audit Finding is the identification of a situation, which either does not satisfy applicable legal requirements or does not conform to the HSEMS. Company: Means SERIOUS SERVICES Group Companies and may also include contractors, facilities and entities responsible to the Principal Crisis: A Crisis is an incident or series of incidents that affect, or could affect, people, property, or the environment, and pose a serious threat to the company's ability to conduct business. Crisis Management: Crisis Management is a system of plans and procedures, which prepares the organisation to respond to and recover from crisis situations. Discharges: Discharges include releases to the air, surface water, groundwater, or land of any material which can have an adverse effect on human health or the environment, be it of gaseous, liquid, or solid nature or a combination thereof. Any discharges fall into one of three categories: Emission a discharge into the atmosphere Effluent a discharge of liquid Waste any other type of discharge Element: An Element is a part of the HSEMS system and represents a grouping of actions and/or expectations on key HSE focus areas, e.g., Safety, Risk Management, Training, etc. Environment: The surroundings and conditions in which a company operates and upon which it may have an effect. This includes non-living systems (air, water, earth) and living systems (human, plant and animal) and social/cultural systems. Environmental Effect: A direct or indirect impingement of the activities, products and services of a company upon the environment, whether adverse or beneficial. Environmental Effects Evaluation: The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 10 SERIOUS SERVICES LLC A documented evaluation of the environmental significance of the effects of a company's activities, products and services, both existing and planned. (This may also be termed an "Environmental Impact Assessment" or EIA.) The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 11 SERIOUS SERVICES LLC Expectation: An Expectation is a statement of the minimum level for HSE performance expected for any element of the HSEMS. Explanatory Notes: Explanatory Notes provide additional information about the Expectations, but do not add to their requirements. While they may discuss how the Expectation should be met, they do not require a specific approach to meet the Expectation. Gap: A Gap is a finding that an Expectation is not being met. Gap Analysis: A process that identifies a Gap, i.e., those areas of the HSE Management system that can or need to be improved. This “Gap Analysis” becomes part of the initial evaluation or subsequent audit report and consequently part of the cycle of planning and implementation for continuous improvement. Hazard: This includes anything with the potential to cause harm, ill health or injury, damage to property, plant, products or the environment, production losses or increased liabilities. Hazards may be physical, chemical or biological. Health Protection: Health Protection encompasses the practices, procedures, equipment and training necessary for the prediction of health risk and protection of the health of persons working at company facilities. Providing health protection requires recognition, evaluation, control and management of the physical, chemical, biological and ergonomic hazards associated with processes and operations. Health, Safety and Environmental Critical - (HSE Critical): Designates activities, personnel or measures that have been identified as vital to ensure asset integrity, prevent incidents and/or to mitigate adverse HSE effects. Health, Safety and Environmental (HSE) Management Audit: An independent, systematic and documented process of objectively obtaining and evaluating verifiable evidence to determine: Whether the HSEMS and its results conform to the audit criteria Whether the system is implemented effectively Whether the system is suitable to achieve the health, safety and environmental policy and objectives Health, Safety and Environmental (HSE) Management: Those aspects of the overall management function (including planning) that develop implement and maintain the HSE policy. Health, Safety and Environmental (HSE) Policy: A statement endorsed by the Principal or GM of SERIOUS SERVICES of the intentions and principles of actions regarding the health, safety and environmental effects and which gives rise to strategic and detailed objectives. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 12 SERIOUS SERVICES LLC Health, Safety and Environmental (HSE) Management Documentation: The documentation describing the overall health, safety and environmental management system, which makes reference to the systems and procedures for implementing the health, safety and environmental management plan. Health, Safety, and Environmental (HSE) Management Plan: A description of the means of achieving health, safety and environmental objectives. Health, Safety and Environmental (HSE) Management Review: The formal review by senior management of the status and adequacy of the health, safety and environmental management system and its implementation in relation to health, safety and environmental issues, policy, legal requirements, Codes of Practice and new objectives resulting from changing circumstances. Health, Safety and Environmental Management System (HSEMS): The structure, responsibilities, guidelines, practices, procedures, processes, systems and resources for implementing HSE management. Health, Safety and Environmental (HSE) Strategic Objectives: The broad goals, arising from the HSE policy that a company sets for itself to achieve. These should be quantified wherever practicable. Incident: An event or chain of events, which has caused or could have caused injury, illness and/or damage (loss) to assets, the environment or third parties. (The word ‘accident’ is used by some writers and organisations to denote an incident, which has caused injury, illness and/or damage, but the term also has connotations of ‘bad luck’ in common speech, and is therefore avoided by others. In these Guidelines, only the term ‘Incident’ has been used, which in the above sense embraces the concept of ‘accident’.) Incident Reporting and Investigation: Incident Reporting and Investigation are procedures undertaken to communicate the occurrence and to understand the root cause(s) of an incident. Legal Requirement: Legal refers to Local Laws, Regulations, Decrees and any Guidelines or Codes of Practice adopted by SERIOUS SERVICES under or because of these laws, regulations or decrees. It also refers to any international standards or treaties to which the Sultanate of Oman or is a signatory, or under which they have agreed in principle to operate. Maintain (Procedures): The term ‘Maintain’ as used in these Guidelines should be understood to mean ‘establish and maintain’ if the procedure, which is to be maintained, does not yet exist. Monitoring Activities: All inspection, test and monitoring work related to health, safety and environmental management. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 13 SERIOUS SERVICES LLC Performance Criteria: Performance criteria describe the measurable standards set by management to which an activity or system element is to perform. (You may also think of performance criteria as ‘goals’ or ‘targets’.) Practice: Accepted methods or means of accomplishing stated tasks. Procedure: A Procedure is a written description of how a specific task should be accomplished. Product Safety: Product Safety is the recognition, evaluation, control and communication of the potential health hazards of products and the materials used in their production. Program: A Program is a management tool for meeting an established objective, which is less comprehensive than a System. It is composed of two steps: plan and implement. It usually addresses issues that have either limited scope or limited time frame. Risk: This is the product of the chance that a specified undesired event will occur and the severity of the consequences of the event. Risk Management: Risk Management is the systematic process of: Identifying potential hazardous events and their potential consequences (hazard analysis) Assessing the probability of the hazardous event occurring (risk analysis) Reducing the risk by reducing the probability of a hazardous event occurring or mitigating its potential consequences. Safety: Safety encompasses the Systems, Programs, Procedures and Practices required for the prevention of incidents. Screening Criteria: These are the values or standards against which the significance of the identified hazard or effect can be judged. They should be based on sound scientific and technical information and may be developed by Renaissance, Standards Organisations, Industry Associations or Government Agencies. Self-Assessment: A Self-Assessment is a process whereby a check is carried out by a unit or facility to determine how well its programs and procedures satisfy legal requirements and conform to the Expectations of the HSEMS. System: A System is a management tool for meeting an established objective made up of four steps: plan, implement, measure and adjust. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 14 SERIOUS SERVICES LLC Training: Training encompasses the steps necessary to ensure that employees and contractors have the knowledge, skills and values necessary to fulfil their environmental, health and safety responsibilities. Waste Management: Waste Management encompasses the assessment and disposal of wastes generated by facilities, with the goal of minimising and preventing the generation of waste. When reference is made for actions to be taken, the intent of the following words is: Shall, Will, Must means that an action is compulsory Should, Would If possible means that an action is not compulsory but is recommended May means that an action is optional and no recommendation is made as to whether or not it is carried out. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 15 SERIOUS SERVICES LLC 3. HSE MANAGEMENT: 3.1. Policy: SERIOUS SERVICES has adopted the following Policies covering Health, Safety and Environmental activities. The Expectations of SERIOUS SERVICES HSEMS state these standards for all Group Company operations. 3.1.1. Health, Safety And Environment (HSE) Policy: It is SERIOUS SERVICES Policy to conduct activities in a manner designed to minimise HSE risks, protect health and safety of employees, contractors, customers, the community at large and the environment in which the Group activities are conducted. SERIOUS SERVICES through active participation of all employees and contractors, will strive to manage HSE risks with the goal of preventing accidents, injuries and occupational illnesses, progressively minimising environmental impact by reducing discharges and using energy efficiently, and producing safe, quality products. SERIOUS SERVICES Companies believe that good HSE performance will contribute/determine the success of the business and will treat HSE issues on par with all other primary business objectives. On General HSE Issues, SERIOUS SERVICES will: Commit to meet defined, measurable HSE targets. Comply with all applicable laws and regulations and apply internationally recognised standards where local laws and regulations do not exist. Hold all levels of line management accountable for HSE issues and for the development of positive attitudes in themselves and those whom they supervise. Require contractors to apply same or similar HSE standards, practices and procedures. Undertake appropriate reviews and evaluations to measure HSE performance against defined standards and to ensure compliance with this policy. Provide appropriate HSE training to employees and contractors. Develop and maintain HSE emergency procedures. Periodically audit and review application of process control and management measures to ensure compliance with the HSE Guidelines. Manage all risks to a level, which is ‘As Low As Reasonably Practicable’ (ALARP). Openly report HSE performance (good and bad). On Health Issues, SERIOUS SERVICES Will: Control and manage all chemical, physical biological, mechanical and psychosocial factors, which contribute to health risks, based on established guidelines and standards, applying best available technology consistent with good industry practice. Strive to protect and promote the health of all employees and contractors. Operate a NO Smoking Policy in all work areas. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 16 SERIOUS SERVICES LLC On Safety Issues, SERIOUS SERVICES Will: Design facilities, establish procedures, provide training and conduct operations in a manner that minimises risks and hazards to workers, property and the community at large, applying best available technology consistent with good industry practice. Ensure all operations are conducted with the safety of the employee and community as a primary objective. Practice good product stewardship to ensure products are properly evaluated and provide As Low As Reasonably Practicable (ALARP) impacts to the environment and can be used safely by customers. On Environment Issues, SERIOUS SERVICES Will: Progressively reduce emissions, effluents and wastes and improve efficient use of natural resources and energy. Minimise the impact of SERIOUS SERVICES activities on the environment and protect endemic fauna and flora at all sites of operations. Provide products and services supported with practical documented advice which, when used and practiced in accordance with this advice, will not cause undue effects on the environment. Preserve and protect all locations of archaeological, historical and natural interest in the areas of operation. SERIOUS SERVICES Companies will, through a documented Health, Safety and Environment Management System, implement this policy and ensure contractors apply similar systems. All employees and contractors are required to be committed and perform their duties according to this general HSE Policy and the individual policies on Environmental Protection, Employee and Facility Safety and Occupational Health, Product Safety Stewardship and Minimisation of Emissions, Effluents and Wastes. 3.1.2. Policy on Environmental Protection: It is the policy of SERIOUS SERVICES to ensure that the activities of its operations are conducted with full concern for safeguarding employee and public health, for protection of the physical environment and to comply with relevant environmental laws and regulations. SERIOUS SERVICES policy is to establish and implement effective compliance programs, including systems and procedures, for informing employees of the policy and their continuing obligation to conduct all activities in compliance with this policy and all applicable legal requirements. Where SERIOUS SERVICES becomes aware of a hazard representing a risk not covered by existing laws or regulations, where appropriate, SERIOUS SERVICES will develop its own environmental standards and practices to provide for adequate protection of employees, public health and the environment. In establishing timing, priorities, and levels of control, careful consideration will be given to benefits in relation to costs and technological feasibility. Particular attention will be given to achieving a reasonable balance between environmental goals and those for energy, jobs and the economy. Environmental laws and regulations will be periodically reviewed to comprehend changes in laws and regulations, national goals, new scientific and technical information and resource availability. SERIOUS SERVICES will co-operate with industry and government in identifying environmental goals and in developing effective, reasonable and equitable control programs. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 17 SERIOUS SERVICES LLC It is the responsibility of Group Company Managers and Supervisors to ensure adherence to SERIOUS SERVICES environmental policy. Further, all employees are expected to be guided by this policy in forming plans, setting objectives and conducting their day-to-day activities. Contractors are to be made aware of, and are expected to comply with, environmental policy and standards. 3.1.3. Policy on Employee and Facility Safety and Occupational Health: It is the Policy of SERIOUS SERVICES to ensure that the activities of its Group Companies are conducted with full concern for the safety of its facilities in order to protect the safety and health of employees, communities adjacent to our operations and the general public. SERIOUS SERVICES will comply with all applicable legal requirements pertaining to occupational safety, health, process safety and fire protection. SERIOUS SERVICES Guidelines, based upon scientific knowledge, established engineering practice and appropriate industry standards will be developed when existing laws and regulations do not provide for adequate protection. SERIOUS SERVICES will carry out the objective of this policy by developing and maintaining safety management systems and procedures, which ensure that work process, and employee safety and health considerations receive priority in design, operation, maintenance and decommissioning of facilities. SERIOUS SERVICES also will require appropriate safety and health training and will require strict adherence to safety rules and procedures. SERIOUS SERVICES will hold each Manager, Supervisor, and Employee accountable for the safe performance of their job and will measure their achievement in preventing occupational injuries, illness and accidental losses. SERIOUS SERVICES will provide qualified safety and health staff and appropriate equipment to support management in carrying out their objectives and goals in these areas. The same high standards are expected of contractors. SERIOUS SERVICES specifically operate a No Smoking Policy in all work areas. SERIOUS SERVICES recognise the harmful effects of first and second hand smoke and encourage all personnel to reduce or restrict the smoking habit. 3.1.4. Policy on Product Safety Stewardship: SERIOUS SERVICES will comply with applicable laws, regulations and international standards on product safety. In addition, SERIOUS SERVICES will: evaluate its products; identify reasonably foreseeable potential hazards to health and the environment; provide procedures and controls to avoid unreasonable risk; and assess the product safety compliance of its operations. Also, where appropriate, SERIOUS SERVICES will inform employees, customers, users, government agencies and the public concerning product safety. SERIOUS SERVICES will work with government and trade associations to develop and implement product safety regulations that protect employees, transportation personnel, customers and the public, taking into account scientific, economic and social factors. SERIOUS SERVICES are responsible for the development, manufacture and marketing of products in a manner consistent with applicable laws and company's high standards of safety, health, and environmental protection. In the absence of adequate local government requirements, SERIOUS SERVICES will maintain standards of safety and health protection that consider scientific knowledge, international standards and established practices in more developed countries. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 18 SERIOUS SERVICES LLC All hazardous purchased products transiting, stored or used on Company properties will be accompanied by a material safety data sheet (MSDS) or its equivalent. Appropriate management, employees and contractors will be made aware of the product and proper precautions on transport, storage, use and disposal. 3.1.5. Policy on Minimisation of Emissions, Effluents and Wastes: SERIOUS SERVICES, in addition to complying with all applicable environmental laws and regulations, is committed to reduce overall discharges (emissions to air, effluents to surface water, ground water and surface and solid waste) from its operations wherever technically and economically feasible. This is part of Company's commitment to safeguarding and protecting the physical environment. Although proper management of wastes, including environmentally sound treatment, storage and disposal, is important in protecting the physical environment, eliminating their generation through source reduction and recycling is encouraged. Source reduction can be accomplished in many ways, including input substitution, product reformulation, process modification, and operational changes and improved housekeeping. Recycling includes the use, reuse, and reclamation of residues both on-site and off-site. SERIOUS SERVICES will be responsible for developing, implementing and maintaining programs at their facilities aimed at minimising and preventing the generation of emissions, effluents and wastes. These programs will include the establishment of goals, encouragement of technology development and transfer and review of accomplishments. SERIOUS SERVICES employees and contractors will be informed of this policy and directed to strive for the minimisation and prevention of emissions, effluents and wastes in formulating plans, setting objectives and conducting their daily activities. 6 The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 19 SERIOUS SERVICES LLC 3.1.6. HSE Vision, Mission, Values: SERIOUS SERVICES HSE Vision: SERIOUS SERVICES will strive to be recognised as responsible, costeffective and innovative in our approach to health, safety and the environment. Our performance will be a source of pride to our employees, SERIOUS SERVICES, the Sultanate of Oman and the Region. SERIOUS SERVICES HSE Mission: SERIOUS SERVICES will identify the needs of the Sultanate of Oman, our customers, our employees and the physical environment. We will strive to deliver the highest quality of service and products while protecting the environment, employees and public health. SERIOUS SERVICES HSE Values: SERIOUS SERVICES values the health and well being of our employees, contractors, neighbouring communities, customers and the natural environment. SERIOUS SERVICES believes that: All accidents and incidents are preventable Line management is responsible for HSE performance Every employee and contractor is responsible for working safely and in an environmentally responsible manner Leadership and commitment of all employees and contractors is vital to successful HSE performance Demonstrating innovative and competent HSE management is a prime tool for gaining and retaining employee, community, public and customer preference Measuring and communicating performance is key to achieving continuous improvement Profitability and reputation will be enhanced by continuously improving HSE performance Proper HSE management will protect employees our neighbours, our operations and facilities SERIOUS SERVICES is committed to: Conducting our business with full concern for protecting the environment and the health and well-being of our employees, contractors, customers and the communities in which we operate Integrating environmental, health and safety priorities into our business activities Managing HSE risks of our business and being prepared to respond to emergency situations Seeking opportunities to cost-effectively and continuously improve our HSE performance Working with customers, suppliers, contractors, trade associations and government, to address HSE concerns and participate in the development of legal requirements, standards and Codes of Practice Involving our employees in the development and achievement of HSE goals and objectives The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 20 SERIOUS SERVICES LLC Enhancing our HSE reputation Conducting our business in compliance with legal requirements, standards and codes of practice 3.2. Requirements: The requirements of the HSEMS are defined by the system 'Elements and Expectations'. For each of these elements either a specific document or system must be in place to ensure the Expectation is met. These are listed below. Element 1: Policy, Leadership and Responsibility: 1.1. Policies are established, communicated, and periodically updated. 1.2. Business Units establish and implement HSE Management Systems that are consistent with HSEMS. 1.3. Clarity, definition and documentation of HSE roles and responsibility assignments for relevant employees and contractors are provided. 1.4. Managers demonstrate commitment to improved HSE performance through leadership and active, visible HSE participation. 1.5. Employees are encouraged to communicate opportunities for improved HSE performance. 1.6. Managers plan for the future by reviewing operations, evaluating risks/opportunities, setting measurable objectives, developing action plans and reporting annual achievements. 1.7. HSE performance indicators are established and measured. 1.8. Individual and team contributions to HSE performance are recognised and considered during employee performance reviews. 1.9. Procedures exist at all levels to encourage the transfer of good HSE systems, programs, procedures, practices and technology. 1.10. Contractor selection includes review of contractor HSEMS and HSE performance. 1.11. Management reviews HSE success and incorporates improvements to the HSEMS. Element 2: Safety: 2.1. 2.2. 2.3. 2.4. 2.5. 2.6. 2.7. 2.8. General Safety rules and a where appropriate a Permit-to-Work system is in place, communicated, documented, and enforced for each site to address identified hazards. Safety rules and procedures are in place, communicated, documented and enforced for off-site work-related activities, including vehicle operation. A self-audit ensures the adequacy and enforcement of the facility's safety rules and procedures. A procedure to ensure that facilities, vehicles, and equipment are maintained in a safe and operable condition. Purchasing and warehousing procedures consider HSE requirements. Ensure that appropriate safety equipment and hardware are provided and properly inspected and maintained. Ensure that the safety implications of operation and facility change both temporary and permanent are assessed, documented, communicated to employees and contractors, and properly managed. (This is often called a “Management of Change” system.) Ensure that contractors manage HSE issues in a manner compatible with the SERIOUS SERVICES HSE Management System. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 21 SERIOUS SERVICES LLC 2.9. 2.10. 2.11. 2.12. 2.13. Employees are involved in the development and implementation of safety systems. Identify and communicate personal protective equipment (PPE) requirements and train personnel to ensure that the PPE requirements are properly implemented and enforced. Ensure that design data, drawings and operating manuals are up-to-date and available. Purchasing and warehousing procedures and contracts include HSE requirements. Ensure safety and environmental control equipment and systems are tested and maintained. Element 3: Occupational Health Protection: 3.1. Protect the occupational health and well being of employees and contractors. 3.2. Ensure for camps, housing, food supply and sanitation the health protection of employees and contractors from infectious disease. 3.3. Evaluate and improve workplace ergonomic factors during design and implementation. 3.4. Ensure employees and contractors are fit for duty. 3.5. Identify, assure and manage occupational health risks. 3.6. Ensure adequate communication to employees and contractors of the hazards associated with jobs. Element 4: Product Safety: 4.1. Product safety information is appropriate, accurate and available. 4.2. Ensure that a proper, qualified professional prior to commercialisation evaluates the product safety aspects of new and reformulated products. Element 5: Environmental Protection: 5.1. Ensure that all discharges generated at facilities are managed to control their potential impacts on human health, the local environment, business operations and costs. 5.2. Definitions of hazardous and toxic waste are established and the disposal of hazardous and toxic waste is documented. 5.3. Continually reduce discharges whenever technically and economically feasible and beneficial to the environment. 5.4. Ensure that the control and the minimisation of discharges are evaluated in the design, operation and maintenance of facilities. 5.5. Systems are implemented to prevent and deal with spills and leaks. 5.6. Identify and manage instances of soil, ground water or surface water contamination resulting from facility operation. 5.7. Efficient use of energy and natural resources is a key consideration in the design, development and optimisation of field operations, plants and products. Element 6: Risk Management: 6.1. Identify hazardous activities and events and their potential consequences as part of on-going business operations. 6.2. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 22 SERIOUS SERVICES LLC 6.3. Assess and prioritise risks, manage them in a cost-effective manner, and document and communicate risk management decisions. 6.4. Ensure that the design of new and modified facilities incorporates appropriate environmental, health and safety protection measures. (This is often called a “HAZOP” review.) Ensure that appropriate HSE assessments are conducted as part of the acquisition or disposal of assets. Manage HSE hazards as part of equipment or facility decommissioning. 6.5. 6.6. Element 7: Crisis Management: 7.1. Ensure that assessments of potential emergency situations, including transportation accidents, and their potential impacts are periodically conducted. 7.2. Ensure that emergency response and crisis management plans are in place for each facility, are kept up-to-date and are understood by those who may be affected and those who will respond. 7.3. Ensure that the resources necessary to respond to emergency situations are defined, available, ready to use and periodically tested. 7.4. Exercises are conducted to ensure applicability of the emergency response plan and the readiness of resources. 7.5. The relative roles, responsibilities and capabilities of SERIOUS SERVICES contractors and emergency response agencies are understood and incorporated into emergency response plans. Element 8: Incident Reporting and Investigation: 8.1. An incident reporting system is in place, which, at a minimum, includes the types of incidents to be reported, the level of management to be informed and the time frame for reporting. 8.2. Ensure that incidents are investigated to determine root causes, costs and the corrective actions necessary to prevent their recurrence. 8.3. Ensure that corrective actions are implemented, documented and periodically assessed. 8.4. Ensure lessons learned are shared. Element 9: Training and Competency: 9.1. Procedures ensure that HSE training and experience pre-requisites for relevant assignments are defined and documented. 9.2. Provide training to meet HSE job requirements. 9.3. A competency evaluation system is implemented to evaluate staff in HSE critical assignments. Element 10: Community and Public Relations: 10.1. A procedure for maintaining community contact and addressing concerns is established and maintained. 10.2. Contact with appropriate local HSE authorities is established and maintained. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 23 SERIOUS SERVICES LLC 10.3. 10.4. Public Relations are knowledgeable of HSE in relation to operations, projects, incidents and crisis management and ensure the facts are appropriately communicated to concerned parties, government agencies and the media. Local concerns about or its business units should be identified and addressed. Element 11: Legal Requirements: 11.1. Ensure that all applicable HSE legal requirements are known and compliance is incorporated into relevant programs. 11.2. Monitor emerging HSE legal requirements and international standards development. 11.3. Identify opportunities for participating in the development of new legal requirements, where appropriate. 3.3. Roles and Responsibilities: Responsibilities for implementation of the HSEMS are as follows: 1) The SERIOUS SERVICES Company Principals are responsible for the implementation of the HSEMS within their group and accountable for achieving the Expectations 2) The SERIOUS SERVICES Company Principals are responsible for adopting the HSEMS, establishing Procedures for its implementation within their companies, and for achieving the Expectations 3) The Senior Line Manger in each business is responsible for ensuring that the HSEMS is implemented in their company and that appropriate resources and training are made available to understand the HSEMS and to achieve its Expectations 4) SERIOUS SERVICES HSE Staff are responsible for providing support to Line Management in implementing and overseeing the HSEMS. This function can be accomplished by developing, reviewing and periodically updating the necessary HSE Systems, Programs and Procedures, and by assisting Line Management in implementing appropriate self-assessment and audit systems 5) The SERIOUS SERVICES HSE Manager is responsible for: Maintaining and enhancing the HSEMS, including development of Procedures to facilitate comments and advice from the field on suggested revisions to the system, and for obtaining the necessary Line Management approval for any proposed changes Maintaining an HSE audit function to assure Line Management that the operations are in compliance with legal requirements, Codes of Practice and in conformance with the Expectations of the Group Company HSEMS Co-ordinating, on an annual basis, the development of a report summarising HSE performance for submission to the SERIOUS SERVICES Manager’s Committee who shall provide a combined HSE performance report of all Group Company actions to SERIOUS SERVICES Management Establishing and maintaining with SERIOUS SERVICES HSE function a “Library” to facilitate sharing HSE “Best Practices” and Systems, Programs and Procedures needed to meet the Expectations of the HSEMS. Participating in a network for transferring HSE technology and “lessons learned” as an aid to continuous improvement The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 24 SERIOUS SERVICES LLC 3.4. Establishing a document control system for communicating and distributing the HSEMS and associated HSE Systems, Programs and Procedures. The document control system includes a process for issuing all HSEMS information through line channels, a mechanism to acknowledge receipt of documents, and reports to users highlighting any changes in Expectations along with a description of the reasons for the changes Establishing HSE Objectives and Targets: Diagram 1 is a depiction of the HSE Management System process, as it would function at the Group Company or facility level. The term “facility” can refer to either a single facility, such as a worksite or a production unit; gas plant, port or it can refer to a set of similar facilities, aggregated together. CONTINUOUS IMPROVEMENT CYCLE Policy Visions, Missions, Values Elements and expectations Laws, regulations Codes & Practice Management review set HSE business objectives Audits Measure results Self Assess Continuous Improvement Share best practice Develop Plans Allocate resources Implement plans Develop Procedures Diagram 1 As shown at the top of Diagram 1, HSE policies provide the basic input for the HSE Vision, Mission and Values statement and for the Elements and Expectations of the HSEMS. Legal requirements define the regulatory boundaries in which the Group Companies operates. Facility management reviews its HSE performance and the requirements of the HSEMS and develops a set of HSE Business Objectives to improve HSE performance, which should be integrated with the overall business objective process. To facilitate this process, the business planning cycle should incorporate guidelines requesting a brief discussion of the overall HSE strategy and HSE objectives. Once HSE Business Objectives have been set, a Self-Assessment should be conducted. Since compliance with legal requirements, Guidelines and Codes of Practice are a critical part of the HSEMS; the Self-Assessment should include a careful review of these requirements and whether they are being met by the facility. The review should also examine the Systems in place to ensure that such requirements are identified and kept upto-date. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 25 SERIOUS SERVICES LLC Any Expectation, which is not being met by existing Systems, Programs and Procedures, constitutes a Gap. In evaluating whether a Gap exists, it is important to consider the documentation and review requirements in the HSEMS. Clear assignment of responsibility, provision of adequate resources and documentation are required for all Systems, Programs and Procedures. In addition, Systems must include provisions for measuring results and for management review. At the completion of the Self-Assessment, the facility may have a list of Gaps, which require filling. These Gaps should be prioritised, with Gaps which represent a threat to health, safety or the environment, or non-compliance with laws, regulations and Codes of Practice, having immediate priority, while Gaps which are caused by lack of proper documentation or management review have lower priority. Line Management should then develop its HSE plans, taking into account and establishing a balance between the following three considerations: 3.5. Filling Gaps in priority order Seeking opportunities to reduce HSE cost without compromising HSE performance Capturing operations, production and marketing opportunities created by improved HSE performance Implementing HSE Plans: Once the HSE Business Objectives have been established, Management personnel should develop specific plans including targets and timetables to achieve those objectives. As part of this process, Key Performance Indicators (KPI's) can be identified to help the facility track its performance. Resources should then be allocated, Systems, Programs and Procedures developed, and the plans implemented. Periodically operations personnel should measure the results of HSE programs and compare them with the targets set for those programs. Management should then review: The results of these measurements Findings of self assessments and independent audits of the HSEMS (discussed in section 3.7) Any other pertinent information, such as changes in HSE laws, regulations and codes of practice, business conditions or incentives for exceeding the expectations of the HSEMS HSE targets should be adjusted as necessary. Any capital requirements generated by these new targets are to be integrated into the business objectives for that facility. The adjustment of HSE targets ends one continuous improvement cycle and begins the next. 3.6. Improvement Incentives: Evaluation of the incentives to improve HSE should be an on-going process. These incentives can include: Reduced accidents Reduced emissions, effluents and waste Lower cost Improved reliability Reduced potential liability Improved reputation with regulators, the public and customers Enhancement of employee pride The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 26 SERIOUS SERVICES LLC In some cases it may be possible to quantify an economic incentive for exceeding the Expectations of the HSEMS by comparing The Price Of non-conformance (PONC) with the Price Of Conformance (POC). Examples of PONC include the costs of cleaning up spills, repairing the damage caused by accidents, carrying out incident investigations, dealing with the greater regulatory or public scrutiny which results from a poor performance record, etc. Examples of POC include the costs of additional control equipment, additional staff, additional training, etc. If PONC is greater than POC, an economic incentive may exist for exceeding Expectations. As part of its consideration of continuous improvement, management should evaluate incentives for obtaining ISO 9000 and ISO14000 and/or similar certifications. If such incentives exist, the facility will be required to implement a document control system and other appropriate procedures to meet certification requirements. Facilities, which do not find incentives for ISO standards or similar certifications, should consider whether there are incentives for establishing document control systems independent of certification. 3.7. HSE Management System Audits: SERIOUS SERVICES shall establish and maintain an HSE Audit Program to determine the effectiveness of the HSEMS in fulfilling Company HSE policies and overall business objectives. HSE performance, assessed by this Audit Program, will be reviewed with Group Company Management. Conducting HSEMS Audits will be the responsibility of the SERIOUS SERVICES HSE focal point, who will report annually to Senior Management on HSEMS performance. A fundamental principle of Company's approach to HSE auditing is recognition of the prime importance of periodic HSE Self-Assessments at the facility or business unit level. Such Self-Assessment is an essential tool for setting objectives and sustaining continuous improvement in HSE processes, HSE results and business performance and should be conducted on a regular schedule. Any finding of non-compliance with legal requirements or non-conformance with the Expectations of the HSEMS should be documented, and Action Plans developed to correct the situation. A business unit should carry out a Self-Assessment prior to an independent audit directed by SERIOUS SERVICES or Company Internal Auditors. Independent HSE audits will be conducted on a periodic basis as directed by SERIOUS SERVICES Management Committee and/or Internal Audit staff to verify compliance with applicable legal requirements, to ensure conformance with the Expectations of the HSEMS and to confirm the effectiveness of the facility or business unit's Self-Assessments Group Companies will develop and maintain a written HSE audit protocol based on selfassessment, and consistent with state-of-the-art criteria for use in carrying out independent HSE audits. These audit protocols will be document-controlled and may serve as guidance for the development of self-assessments and audit protocols for use by facility staff. SERIOUS SERVICES management Committee will ensure that directed auditors use the HSE audit protocol to develop an understanding of Group Company HSEMS. The audit team will also assess the effectiveness of the Management System by reviewing relevant documentation, inspecting operating sites and facilities, and interviewing employees and contractors. Audits will be scheduled on the basis of the strategic importance of the business activity concerned, considering such factors as risk, environmental sensitivity, the results of previous HSE audits, and the HSE performance of the facility or business unit. Audit findings will be recorded and reviewed with local Line Management at the conclusion of the audit. Subsequently, audit findings and recommendations must be documented and reported to those Senior Line Managers responsible for the activity and/or area audited. The responsible Line Managers must develop an Action Plan to address audit findings and The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 27 SERIOUS SERVICES LLC recommendations. For self-audits, the Senior Line Manager will be responsible to communicate annually a summary of the audit results and the success of the corrective Action Plan implementation through line channels to the SERIOUS SERVICES Management Committee/ appointed Audit Manager. The Group Companies will develop and maintain an HSE audit system to track the status of HSE audit findings and recommendations to ensure that timely follow-up action is implemented and to facilitate and document the follow-up process. The SERIOUS SERVICES Committee will maintain through Internal Audit an HSE audit database to track the status of HSE audit findings, recommendations and implementation. The SERIOUS SERVICES Committee appointed Audit Manager shall, in conjunction with SERIOUS SERVICES, ensure that independent HSE audits are led by personnel who: Have professional experience and a thorough understanding of the activity, area and business sector being audited Have been trained in quality auditing principles with a particular focus on HSE systems, programs and procedures Personnel to serve on the SERIOUS SERVICES audit teams will be drawn on an ad hoc basis from various departments within the Organisation as needed to meet audit objectives and provide HSE training opportunities for Group Company staff. Contractors may also be used to staff audit teams. 3.8. Management Review: Group Company Management will review the HSEMS at least biennially to ensure its continuing suitability and effectiveness. The review shall be documented. Management Review must address the HSE performance of facilities, the commitment to continuous improvement in HSE performance and the status of HSE audit findings. The Management Review must also address the potential need for change in SERIOUS SERVICES HSE policies or in Group Company HSE Systems and Objectives in light of emerging HSE trends and changes in the business. 3.9. Communications AND Information Sharing: Communications and information sharing are critical to the success of the HSEMS. Communication is specifically required: With employees, government agencies, customers, communities, and the public Between facilities and units at the same level within a Group Company and with their counterparts in the rest of the organisation 7 The Expectations of the HSEMS address the first type of communication and information sharing. The requirements for communication between various levels of the management on HSE matters are the same as the communication requirements for other aspects of our business. However, the HSEMS creates new opportunities and new incentives to communicate and share information horizontally throughout the Group Companies. By creating a common set The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 28 SERIOUS SERVICES LLC of requirements for operations, the HSEMS facilitates the sharing of HSE Systems, Programs and Procedures. The emphasis that the HSEMS places on continuous improvements should create an even greater incentive for this information sharing. SERIOUS SERVICES will maintain a “Library” of HSE Systems, Programs and Procedures, to facilitate sharing of “Best Practices” across all of SERIOUS SERVICES. DEVELOPMENT AND APPLICATION GUIDELINES Author: These Guidelines have been styled by HSE Partenaire in line with Health and Safety Executive document HS (G) 65 and after those principles proposed by the E&P Forum. We acknowledge the work performed by the OGP companies especially those represented in The E&P Forum Safety, Health and Personnel Competence and Environmental Quality Committees. This same basic structure has been adopted by the International Standards Organisation for the Environmental Management System (EMS) Standard Series 14000 (ISO 14000) and was used for the ISO 9000 standard services setting forth the Safety Management System (SMS) INTRODUCTION 1. BACKGROUND: There is wide recognition of the benefits of objective or goal-setting approaches to safety. This is a fundamental principle of British Standard 5750 (BS 5750) and the SMS approach which draws on the management principles of the International Standard on Quality Systems, ISO 9000. Similarly, environmental aspects are subject to extensive regulation and Environmental Management Systems (EMS) (BS 7750 and ISO 14000) are used to control and manage environmental impacts. Further, BS 8800, ISO 18000 Occupational Health and Safety Management System, has been implemented to include occupational health into this overall management scheme. Although there are differences in the detailed handling of Health, Safety and Environmental Issues, safety and environmental management are converging towards the systems model of ISO 9000. It is upon the ISO 9000 system that ISO 14000 builds Environmental Management Systems and 18000 for Occupational Health and Safety. The requirements of health, safety and environmental protection are not always in harmony. For example, measures necessary to safeguard personnel in emergencies may have adverse environmental effects, and vice versa. However, joint consideration of health and safety and environmental matters provides a framework within which such issues can be resolved, and an appropriate balance struck. 2. PURPOSE AND SCOPE: These Health, Safety and Environmental Management System Guidelines are designed to: Cover relevant Health, Safety and Environment (HSE) issues in a single document Be adaptable to different types of operations Recognise, and be applicable to, the role of contractors and sub-contractors Facilitate operation within the framework of statutory requirements Facilitate evaluation of operations to international standards These Guidelines describe the main elements necessary to develop, implement and maintain a Health, Safety and Environmental Management System (HSEMS). They do not dictate specific The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 29 SERIOUS SERVICES LLC performance requirements, but instead allow each Group Company to set Policies and Objectives taking into account information about the significant health and safety hazards and environmental effects of their operations. The Guidelines are templates for ourselves and our contractors that help assure us and others (such as government agencies, neighbours, partners, clients, insurers and the public) of compliance with stated HSE policies within an objective-setting management system. Furthermore, the guidelines are intended to build upon existing sound, workable and effective company systems and practices. The HSE criticality of a given operation or situation dictates whether it warrants a formally documented and controlled procedure. In many instances the existing company practices will be less formal but nevertheless fully acceptable. Assuring the suitability of all aspects of the HSEMS remains the responsibility of each Group Company and facility. These Guidelines should be read in the context and spirit of self-regulation. 3. The Health Safety and Environmental Management System Model The model Health, Safety and Environmental Management System that forms the basis of these Guidelines is shown schematically in Diagram 2. Although this indicates a sequence of the HSEMS elements, many of the stages will in practice be addressed at the same time or revisited at different times. Likewise, this is only one depiction of the interrelation of these elements. The HSEMS is not intended to be a stand-alone exercise. It is to be merged into and become an integral part of the overall management system. THE MODEL Leadership & Commitment Policy & Strategic Objectives Organisation & Resources Audit & Review Hazard & Risk Management Planning Implementation Diagram 2 The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 30 SERIOUS SERVICES LLC 4. STRUCTURE OF THE DOCUMENT: The SERIOUS SERVICES HSEMS GUIDE has two main sections: ‘Guidelines’ and ‘Supplementary Information’. The Guidelines describe the elements of the HSEMS model and their interrelationships. These elements may also be thought of as ‘performance standards’. [This term should not however, be confused with ‘performance criteria’, which are lower-level specifications for the performance of operations.] The Supplementary section contains additional advisory material under the same headings, including examples of the manner in which the Guidelines may be applied. The sections are numbered as in the Guidelines, but with the prefix ‘S’. 5. TERMINOLOGY: Particular attention should be paid to the definition and usage in these Guidelines of the terms ‘risk’, ‘hazard’, ‘performance criteria’, ‘audit’ and ‘review’. References in the Guidelines to a ‘Company’ may be taken to refer to the Renaissance, Group Companies, facilities, contractors, and other operations under the purview of Renaissance. EXECUTIVE SUMMARY OF THE HSEMS MODEL KEY ELEMENTS OF THE HSEMS MODEL: The Guidelines describe a management system, shown in Diagram 2 of this section, for setting and implementing Company Policy and Objectives on Health, Safety and the Environment. Key elements of the HSEMS are shown in the table below. HSEMS Element Addressing Leadership and commitment Top-down commitment and culture, essential to the success of the system. Policy and strategic objectives Company intentions, principles of action and aspirations with respect to health, safety and environment. Organisation, resources and documentation Organisation of people, resources and documentation for sound HSE performance. Evaluation and risk management Identification and evaluation of HSE risks, for activities, products and services, and development of risk reduction measures. Planning Planning the conduct of work activities, including planning for changes and emergency response. Implementation and monitoring Performance and monitoring of activities, and how corrective action is to be taken when necessary. Auditing and reviewing Periodic assessments of system performance, effectiveness and fundamental suitability. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 31 SERIOUS SERVICES LLC 4. LEADERSHIP AND COMMITMENT: This section addresses the top - down commitment and culture necessary for the success of an HSEMS system Leadership & Commitment Policy & Strategic Objectives Organisation & Resources Audit & Review Hazard & Risk Management Planning Diagram 3 Implementation Senior Management must provide strong, visible leadership and commitment, and ensure that this commitment is translated into the necessary resources to develop, operate and maintain the HSEMS and to attain the Policy and Strategic Objectives. Management should ensure that full account is taken of HSE Policy requirements and should provide support for local actions taken to protect health, safety and the environment. SERIOUS SERVICES must create and sustain a culture that supports the HSEMS, based on: Belief in the company desire to improve HSE performance Motivation to improve personal HSE performance Acceptance of individual responsibility and accountability for HSE performance Participation and involvement at all levels in HSEMS development Commitment to an effective HSEMS Employees of both SERIOUS SERVICES and its contractors must be involved in the creation and maintenance of a culture that supports HSEMS. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 32 SERIOUS SERVICES LLC 5. POLICY AND STRATEGIC OBJECTIVES: This section addresses Company intentions, principles of action and aspirations with respect to health, safety and environment and the aim of improved HSE performance Leadership & Commitment Policy & Objectives Strategic Organisation & Resources Audit & Review Hazard & Risk Management Planning Implementation Diagram 4 Company management will define and document its HSE Policies and Strategic Objectives and ensure that they: Are consistent with those of SERIOUS SERVICES Are relevant to its activities, products and services, and their effects on HSE Are consistent with other policies Have equal importance with other policies and objectives Are implemented and maintained at all organisational levels Are available to SERIOUS SERVICES, government agencies and the public Commit the company to meet or exceed all relevant regulatory and legislative requirements Apply responsible standards of its own where laws and regulations do not exist Commit to reduce the risks and hazards to health, safety and the environment of activities, products and services to levels which are as low as reasonably practicable Provide for the setting of HSE objectives that commit continuous efforts to improve HSE performance Strategic HSE Objectives will be established and periodically reviewed. Such objectives will be consistent with both SERIOUS SERVICES and the company's policy and reflect the activities, relevant HSE hazards and effects, operational and business requirements, regulations and the views of employees, contractors and customers. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 33 SERIOUS SERVICES LLC 6. ORGANISATION, RESOURCES AND DOCUMENTATION: This section addresses the organisation of people, resources and documentation for sound HSE performance Leadership & Commitment Policy & Objectives Strategic Organisation & Resources Audit & Review Hazard & Risk Management Planning Implementation Diagram 5 6.1. Organisational Structure and Responsibilities: Successful handling of HSE matters is a line responsibility, requiring the active participation of all levels of management and supervision; this should be reflected in the organisational structure and allocation of resources. The company will define, document and communicate - with the aid of organisational diagrams where appropriate - the roles, responsibilities, authorities, accountabilities and inter-relations necessary to implement the HSEMS, including but not limited to: Provision of resources and personnel for HSEMS development and implementation Initiation of action to ensure compliance with HSE Policy Acquisition, interpretation and provision of information on HSE matters Identification and recording of corrective actions and opportunities to improve HSE performance Recommendation, initiation or provision of mechanisms for improvement, and verification of their implementation Control of activities while corrective actions are being implemented Control of emergency situations It will be stressed to all employees their individual and collective responsibility for HSE performance. The company will also ensure that personnel are competent (see section 6.4) and have the necessary authority and resources to perform their duties effectively. The organisational structure and allocation of responsibilities will reflect the responsibility of line managers at all levels for developing, implementing and maintaining the HSEMS in their particular areas. The structure should describe the relationships between: Different operating units or facilities The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 34 SERIOUS SERVICES LLC Operating and supporting services (whether the services are provided on the same facility or from a larger corporate organisation) Employees and contractors Partners in joint activities 6.2. Management Representative(s): Management representative(s) will be assigned responsibility, authority and accountability for co-ordinating implementation and maintenance of the HSEMS. The representative(s) will be accountable to senior Group Company, management. However, the appointment(s) should not reduce the responsibility of individual line managers for implementing the HSEMS in their particular areas. 6.3. Resources: Senior management will allocate sufficient resources to ensure the effective operation of the HSEMS, taking account of advice from the management representative(s), line management and HSE specialists. Resource allocation should be reviewed regularly as part of the review of the HSEMS (see section 7.2), of management of change (see section 5.4) and of risk management (See section 4). 6.4. Competence: 6.4.1. General: Procedures will be maintained for ensuring that personnel performing specific assigned HSE-critical activities and tasks are competent on the basis of appropriate: Personal abilities Skills developed through experience Acquired knowledge Systems for competence assurance should apply both to initial recruitment and to selection for new activities, and to both staff and contractors. The continuing competence of personnel to perform their duties should be regularly reviewed and assessed, including appropriate consideration of personal development and training required to achieve competence for changing activities and technologies (see section 3.4.2). Procedures for competence assurance include, among others: Systematic analysis of requirements for tasks Assessment of individuals' performance against defined criteria Documented evidence of individual competence Programs for periodic re-assessment The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 35 SERIOUS SERVICES LLC Identify manner in which tasks are to be performed Identify competencies (abilities/skills/knowledge) Select appropriate staff Provide training if necessary Review performance Diagram 6 6.4.2. Training: The company will maintain procedures to ensure and increase competence through identification of training needs and provision of appropriate training for all personnel. Training must be sufficient to ensure achievement of the company's policy and objectives, and meet or exceed that required by legislation and regulations. Appropriate records of training should be maintained (see section 6.3) and refresher training scheduled as required. Diagram 7 Consider tasks and individuals Identify type/extent/frequency of training needed Prepare training course/material Record training conducted Obtain participants feedback Evaluate effectiveness The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 36 SERIOUS SERVICES LLC Systems to monitor the effectiveness of training programs and to introduce improvements where necessary should be developed. 6.5. 6.6. Contractors: Procedures must be developed to ensure contractors operate a management system that is consistent with the requirements and provisions of Policy and are compatible with the HSEMS of the company to which it is providing services. Procedures should facilitate interfacing of contractors' activities with those of the company and with those of other contractors, as appropriate. [This may be achieved by means of a specific interface document between company and contractor so that any differences may be resolved, and procedures agreed, before work commences]. Particular attention should be paid to the following: Selection of contractors, including (among other considerations) specific assessment of their HSE policy, practices and performance and the adequacy of their HSEMS, commensurate with the risks associated with the services to be provided Effective communication (see section 3.6) of the key elements of the company's HSEMS, and of the standards of worker and environmental protection expected from the contractor, including agreed HSE objectives and performance criteria Sharing by company and contractor of relevant information which may impact on the HSE performance of either The requirement that each contractor has an effective and relevant training program which includes records and procedures for assessing the suitability of staff or a particular individual and the need for further training Definition of methods for monitoring and assessing contractor performance against agreed HSE objectives and performance criteria Communication: Procedures are to be developed to ensure that company employees and those of contractors and partners, at all levels, are aware of the: Importance of compliance with the HSE Policy and Objectives, and their individual roles and responsibilities in achieving it HSE risks and hazards of their work activities and the preventative and mitigation measures (see section 4) and emergency response procedures that have been established (see section 5.5) Potential consequences of departure from agreed operating procedures Mechanisms for suggesting to management improvements in the procedures by which they and others operate Maintaining means of external communication in times of emergency is especially important and special contingency arrangements should be in place (see section 5.5). The company should maintain procedures for communication of HSE information, consistent with its policy and with applicable legal requirements. The company should, while protecting confidential information, make available its HSE experience to employees, contractors, customers and other companies engaged in similar activities to facilitate improvements in industry HSE performance. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 37 SERIOUS SERVICES LLC Customers Regulators Shareholders Media Banks C O M PANY Neighbours Management representatives Insurers All employees Interest Groups Emergency Services Renaissance Diagram 8 Suppliers Contractors Procedures should be developed for receiving and responding to communications from employees, contractors, customers, government agencies and the public concerning HSE performance and management. Community awareness and consultation programs will be maintained where appropriate. Methods to measure the effectiveness of these communication procedures should be developed. 6.7. Documentation and its control: 6.7.1. HSEMS Documentation: The Company will maintain controlled documentation to: Record the HSE policy, objectives and plans Record and communicate key roles and responsibilities Describe HSEMS elements and their interactions Cross-reference related documentation and describe links with other aspects of the overall management system Record the results of HSE evaluation and risk management Record relevant legal requirements Record, where necessary, procedures and work instructions for key activities and tasks Describe emergency plans and responsibilities, and the means of responding to incidents and potential emergency situations Such documentation will cover: 6.7.2. SERIOUS SERVICES Individual functions and operations Contractors and partners Document Control: Procedures for controlling HSEMS documents will ensure that: They can be identified with the appropriate company, unit or activity They are periodically reviewed, revised as necessary and approved for adequacy by authorised personnel prior to issue Current versions are available at those locations where they are needed When obsolete, they are promptly removed from all points of issue and points of use The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 38 SERIOUS SERVICES LLC Documentation will be legible, (with dates of revision), readily identifiable, numbered (with a version number), maintained in an orderly manner and retained for a specified period. Policies and responsibilities will be established for the modification of documents, and their availability to employees, contractors, government agencies and the public. Documentation may be made available on electronic media but at least one printed copy shall be available and easily accessible at major facilities. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 39 SERIOUS SERVICES LLC 7. EVALUATION AND RISK MANAGEMENT: Risk is present in all human endeavours. This section addresses the identification of HSE hazards and evaluation of HSE risks, for all activities, products and services, and development of measures to reduce these risks. The essential steps of Hazard Management are shown in diagram 10 Leadership & Commitment Policy & Strategic Objectives Organisation & Resources Audit & Review Hazard & Risk Management Planning Implementation Diagram 9 7.1. Hazard Management: Risk reduction is related to the reduction of hazards and is itself a TQM process as depicted below. Hazards must be identified and their possible effects evaluated. This allows the proper operations precautions or engineering design out steps to be taken to prevent hazards. However, when an incident does occur damage mitigation and recovery must be addressed through pre-planned procedures The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 40 SERIOUS SERVICES LLC THE ESSENTIAL STEPS OF HAZARD MANAGEMENT Evaluate Identify Prevent Recover Diagram 10 Mitigate 7.2. Identification of hazards and effects: Procedures will be developed to identify systematically the hazards and effects, which may affect or arise from operations and activities, and from the materials, which are used or encountered in them. The scope of the identification should cover activities from project inception through to abandonment and restoration of sites. The concept being to “design out” HSE possible problems from day one. Identify hazards and effects Establish screening criteria Identify applicable statutory requirements Establish hazards and effects significant hazards and effects and statutory requirements Set detailed objectives and performance criteria Identify and evaluate risk reduction measures Diagram 11 Implement selected risk reduction measures The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 41 SERIOUS SERVICES LLC This includes consideration of: Planning, construction and commissioning (i.e., asset acquisition, development and improvement activities) Routine and non-routine operating conditions, including shut-down, maintenance and start-up Incidents and potential emergency situations, including those arising from: Product/material failures Structural failure Climatic, geophysical and other external natural events Human factors including breakdowns in the HSEMS Decommissioning, abandonment, dismantling, disposal and restoration Potential hazards and effects associated with past activities Personnel at all organisational levels should be appropriately involved in the identification of hazards and effects. 7.3. Evaluation: Procedures will be developed to evaluate (assess) risks and effects from identified hazards against screening criteria, taking account of probabilities of occurrence and severity of consequences for: People Environment Assets Reputation It should be noted that any evaluation technique provides results which themselves may be subject to a range of uncertainties. Therefore, formal risk evaluation techniques will be used in conjunction with the judgement of experienced personnel. Where appropriate, advice of regulators and surrounding community should also be considered. Risk evaluation should: Include effects of activities, products and services Address effects and risks arising from both human and hardware factors Solicit input from personnel directly involved with the risk area Be conducted by qualified and competent personnel Be conducted according to appropriate and documented methods Be updated at specified intervals Evaluation of health and safety risks and effects should include, where appropriate, consideration of: Fire and explosion Impacts and collisions Drowning, asphyxiation and electrocution Chronic and acute exposure to chemical, physical and biological agents Ergonomic factors Evaluation of acute and chronic environmental effects should include, where appropriate, consideration of: The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 42 SERIOUS SERVICES LLC Controlled and uncontrolled emissions of matter and energy to land, water and the atmosphere Generation and disposal of solid and other wastes Use of land, water, fuels and energy, and other natural resources Noise, odour, dust, vibration Effects on specific parts of the environment including ecosystems Effects on archaeological and cultural sites and artefacts, natural and conservation areas and sensitive marine areas. 7.4. Recording of hazards and effects: The company will maintain procedures to document those hazards and effects (chronic and acute) identified as significant in relation to health, safety and the environment, outlining the measures in place to reduce them (see sections 4.6) and identifying the relevant HSE critical systems and procedures. 7.5. Strategy Requirements: The company should maintain procedures to record statutory requirements and codes applicable to the HSE aspects of its operations, products and services and to ensure compliance with such requirements. 7.6. Objectives and Performance Criteria: The company will maintain procedures to establish detailed HSE objectives and performance criteria at relevant levels. Such objective and performance criteria should be developed in the light of policy, strategic HSE objectives, HSE risks, and operational and business needs. They should be quantified, wherever practicable and identified with defined time scales while being realistic and achievable. As a follow-up to risk evaluation (see section 4.3), the company should develop procedures to set performance criteria for HSE - critical activities and tasks, which stipulate in writing the acceptable standard for their performance. It should also, at specified intervals, review the continuing relevance and suitability of the criteria. 7.7. Risk Reduction Measures: The company will have procedures to select, evaluate and implement measures to reduce risks and effects. Risk reduction measures include both those to prevent incidents (i.e., reducing the probability of occurrence) and to mitigate chronic and acute effects (i.e., reducing the consequences). Preventive measures such as ensuring asset integrity (see section 5.2) should be emphasised wherever practicable. Mitigation measures should include steps to prevent escalation of developing abnormal situations, lessen adverse HSE effects and ensure emergency response measures for recovery (see section 5.5). Effective risk reduction measures and follow-up require visible commitment of management and onsite supervision, as well as the understanding and ownership of operations personnel. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 43 SERIOUS SERVICES LLC 7.8. Implementation: In all cases consideration will be given to reducing risk to a level deemed ‘As Low As Reasonably Practicable’ (ALARP) reflecting among other factors, local conditions and circumstances, the balance of cost and benefits and the current state of scientific and technical knowledge. Procedures are needed to: Identify prevention and mitigation measures for particular activities, products and services which pose potential HSE risks Re-appraise activities to ensure that the measures proposed do reduce risks, or enable relevant objectives to be met Implement, document and communicate to key personnel interim and permanent risk reduction measures, and monitor their activities Develop relevant measures such as plans for emergency response (section 5.5) to recover from incidents and mitigate their effects Identify hazards arising from risk prevention and mitigation and recovery measures Evaluate the tolerability of consequent risks and effects against the company screening criteria The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 44 SERIOUS SERVICES LLC 8. PLANNING: This section addresses the firm planning of work activities, including the risk reduction measures (selected through the evaluation and risk management process). This includes planning for existing operations, managing change and developing emergency response measures Leadership & Commitment Policy & Strategic Objectives Organisation & Resources Audit & Review Hazard & Risk Management Planning Implementation Diagram 12 8.1. General: There must be within overall work programs, plans for achieving HSE objectives and performance criteria. These plans should include: 8.2. A clear description of the objectives Designation of responsibility for setting and achieving objectives and performance criteria at each relevant function and level of the organisation The means by which they are to be achieved Resource requirements Time scales for implementation Programs for motivating and encouraging personnel toward a suitable HSE culture Mechanisms to provide feedback to personnel on HSE performance Processes to recognise good personal and team HSE performance (e.g., safety award schemes) Mechanism for evaluation and follow-up Asset Integrity: Procedures must be in place to ensure that HSE - critical facilities and equipment that the company designs, constructs, procures, operates, maintains and/or inspects are suitable for the required purpose and comply with defined criteria. Pre-procurement and preconstruction assessment of new facilities and equipment must include explicit assessment of appropriateness to meet HSE requirements and should emphasise design as the best preventive measures to reduce risk and adverse HSE effects. Procedures and systems for ensuring asset integrity must address (among other factors) structural integrity, process containment, ignition control and systems for detection, The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 45 SERIOUS SERVICES LLC shutdown, emergency response, life saving, exposure reduction and environmental protection. Deviation from approved design practices and standards are permitted only after review and approval by designated personnel and/or authorities (as appropriate). The rationale for the deviation should be documented. 8.3. Procedures and Work Instructions: 8.3.1. Developing Procedures: Activities for which the absence of written procedures could result in infringement of HSE policy, breaches of legal requirements, performance criteria, Guidelines, or Codes of Practice should be identified. Documented procedures or standards should be prepared for such activities, defining how they are to be conducted whether by the company's own employees, or by others acting on its behalf - to ensure technical integrity and to transfer knowledge effectively. State written procedures simply, unambiguously and understandably, and indicate the person's responsible, methods to be used and, where appropriate, performance standards and criteria to be satisfied. Procedures are required for procurement and contracted activities, to ensure that suppliers and those acting on the company's behalf comply with the company's policy requirements that relate to them. 8.3.2. 8.4. Issuing Work Instructions: Work instructions define the manner of conducting tasks at the work-site level, whether conducted by our own employees or by others acting on our behalf. In the case of HSE - critical tasks, which have the potential for adverse HSE consequences if incorrectly performed, these work instructions should be documented and communicated to relevant personnel. Management of Change: Procedures must be in place for planning and controlling changes, both permanent and temporary, in people, plant, processes and procedures, to avoid adverse HSE consequences. 9 The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 46 SERIOUS SERVICES LLC The procedures must be suitable to address the HSE issues involved, according to the nature of the changes and their potential consequences, and should address: Identification and documentation of the proposed change and its implementation Responsibility for reviewing and recording the potential HSE hazards from the change or its implementation Documentation of the agreed change and implementation procedure, including: Measures to identify HSE hazards and to assess and reduce risks and effects Communication and training requirements Time limits, if any Verification and monitoring requirements Acceptance criteria and action to be taken if breached Authority for approval to implement the proposed change Procedures will include how new, amended or revised legal requirements will be assessed and incorporated in the HSEMS. Separate plans should be established for the HSE management of new operations (relating, for example, to acquisitions, developments, divestments, products, services or processes), or of modified operations where the modification introduces significantly different HSE concerns. These separate plans should define at least: 8.5. HSE objectives to be attained Mechanisms for their achievement Resource requirements to achieve HSE objectives Procedures for dealing with changes and modifications as projects proceed Corrective mechanisms to be employed should the need arise, how they will be activated and how their adequacy can be measured Contingency and Emergency Planning: Procedures will be devised to identify foreseeable emergencies by systematic review and analysis. A record of such identified potential emergencies should be made, and updated at appropriate intervals in order to ensure effective response to them. The company should develop, document and maintain plans for responding to these potential emergencies, and communicate such plans to: Command and control personnel Employees and contractors who may be affected Emergency services Local government units Others likely to be impacted 10 The emergency plans should cover: Organisation, responsibilities, authorities and procedures for emergency response and diLLCter control, including the maintenance of internal and external communications Systems and procedures for providing personnel refuge, evacuation, rescue and medical treatment Systems and procedures for preventing, mitigating and monitoring environmental effects of emergency actions Procedures for communicating with authorities, relatives and other relevant parties Systems and procedures for mobilising company equipment, facilities and personnel The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 47 SERIOUS SERVICES LLC Arrangements and procedures for mobilising third party resources for emergency support Arrangements for training response teams and for testing the emergency systems and procedures To assess the effectiveness of response plans, procedures must be maintained to test emergency plans by scenario drills and other suitable means, at appropriate intervals, and to revise the response plans as necessary in the light of the experience gained. Procedures must be in place for the periodic assessment of emergency equipment needs and the maintenance of such equipment in a ready state. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 48 SERIOUS SERVICES LLC 9. IMPLEMENTATION: This section addresses how activities are to be performed and monitored and how corrective action is to be taken when necessary. Leadership & Commitment Policy & Strategic Objectives Organisation & Resources Audit & Review Hazard & Risk Management Planning Implementation Diagram 13 9.1. Activities and Tasks: Activities and tasks should be conducted according to procedures and work instructions developed at the planning stage or earlier, in accordance with HSE policy: At senior management level, the development of strategic objectives and high level planning activities are to be conducted with due regard for the HSE policy. At supervisory and management level, written directions regarding activities (which typically involve many tasks) will normally take the form of plans and procedures. At the work-site level, written directions regarding tasks will normally be in the form of work instructions, issued in accordance with defined safe systems of work (e.g., permits to work, simultaneous operations procedures, lock-off and tag-out procedures, manuals of permitted operations, etc.). The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 49 SERIOUS SERVICES LLC Management is to ensure, and be responsible for, the conduct and verification of activities and tasks according to relevant procedures. This responsibility and commitment of management to the implementation of policies and plans includes, among other duties, ensuring that HSE objectives are met and that performance criteria and control limits are not breached. Management will ensure the continuing adequacy of the HSE performance of the company through monitoring and review activities (see section 6.2). 9.2. Monitoring: Procedures are to be in place for monitoring relevant aspects of HSE performance and for establishing and maintaining records of the results. For each relevant activity or area, at least: Identify and document the monitoring information to be obtained, and specify the accuracy required of results Specify and document monitoring procedures, locations and frequencies of measurement Establish, document and maintain measurement quality control procedures Establish and document procedures for data handling and interpretation Establish and document actions to be taken when results breach performance criteria (see sections 4.4, 4.5 and 6.4) Assess and document the validity of affected data when monitoring systems are found to be malfunctioning and/or sampling procedures are not conducted properly Safeguard measurement systems from unauthorised adjustments, damage or tampering Procedures are required for both active and reactive monitoring. Active monitoring provides information in the absence of any incident, ill health or damage to the receiving environment. It includes checking that HSEMS requirements (e.g., procedures) are being complied with, and that objectives and performance criteria are met. Reactive monitoring provides information on incidents (including near-miss incidents, ill health or environmental damage) that has occurred and provides insights into the means of preventing similar incidents in the future. These insights become inputs to HSE planning. 9.3. Records: A system of records should be maintained in order to demonstrate the extent of compliance with HSE policy and its requirements, and to record the extent to which planned objectives and performance criteria have been met. There must be procedures to ensure the integrity, accessibility and control of such records. This includes relevant contractor and procurement records, the results of audits and reviews (see section 7), training records (see section 3.4.2) and employee medical records. The retention times of records should be established and recorded, and procedures must be maintained regarding their availability and confidentiality. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 50 SERIOUS SERVICES LLC 9.4. Non-compliance and Corrective Action: Responsibility and authority will be defined for initiating investigation and corrective action in the event of non-compliance with specified requirements relating to the HSEMS, its operation or its results. Situations of non-compliance may be identified by the monitoring program, through communications from employees, contractors, customers, government agencies or the public, or from investigations of incidents (see section 6.5 and 6.6). Procedures will be developed for investigation and corrective action. The procedure should: Notify the relevant parties Determine the causation sequence and likely root cause Establish a plan of action or an improvement plan Initiate preventive actions commensurate with the nature of the non-compliance Apply controls to ensure that any preventive actions taken are effective Revise procedures to incorporate actions to prevent recurrence, communicate changes to relevant personnel and implement them Determine the causes Plan action Initiate preventive actions Apply controls Diagram 14 Revise procedures and communicate changes 9.5. Inci dent Reporting: Procedures will be maintained for the internal recording and reporting of incidents which affected, or could have affected, HSE performance, so that the relevant lessons can be learned and appropriate actions taken (see section 6.6). There should be a defined mechanism for the reporting of incidents to government agencies to the extent required by law or to such greater extent as the policy of the company on external communication may require. Likewise, mechanisms should be maintained for communication to employees, partners, the media and public. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 51 SERIOUS SERVICES LLC 9.6. Incident Follow-up: Both the immediate circumstances of the incident and the underlying HSEMS weaknesses, which caused it, should be identified to enable judgements to be made by those responsible for authorising the necessary follow-up action. The mechanism and responsibilities for follow-up of incidents must be clearly defined. The mechanism should be broadly similar to the procedures for implementing corrective action in cases of non-compliance with the HSEMS (see section 6.4). The defined responsibilities for follow-up of an incident should be appropriate to the severity of its real or potential consequences. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 52 SERIOUS SERVICES LLC 10. AUDIT AND REVIEW: This section addresses the periodic assessment of system performance, effectiveness and inherent suitability Leadership & Commitment Policy & Strategic Objectives Organisation & Resources Audit & Review Hazard & Risk Management Planning Implementation Diagram 15 10.1. Audit: Audits will be performed as a normal part of business control in order to determine: Whether or not HSEMS Elements and activities conform to planned arrangements, and are implemented effectively The effective functioning of the HSEMS in fulfilling HSE Policy, Objectives, Guidelines and Performance criteria Compliance with relevant legal requirements Identification of areas for improvement, leading to progressively better HSE management (HSEMS Gap Analysis) The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 53 SERIOUS SERVICES LLC For this purpose, the audit plan will include at least the following elements: Specific activities and areas to be audited. Audits should cover the operation of the HSEMS and the extent of its integration into the activities, and should specifically address the following elements of the HSEMS model: Organisation, resources and documentation Evaluation and risk management Planning Implementation and monitoring Frequency of auditing specific activities/areas. Audits should be scheduled on the basis of the contribution or potential contribution of the activity concerned to HSE performance, and the results of previous audits Responsibilities for auditing specific activities/areas Audit protocols and procedures will be established and maintained. At a minimum, the following points should be covered: 10.2. Allocation of resources to the auditing process Personnel requirements, and specifically that the audit team has Adequate independence from activities audited to enable objective and impartial judgement The necessary expertise in relevant disciplines Support, if necessary, from a wider range of specialists Methodologies for conducting and documenting the audits, which may involve the use of questionnaires, checklists, interviews, measurements and direct observations, depending on the nature of the function being audited Procedures for reporting audit findings in a controlled manner to those responsible for the activity/area audited, who should take timely action on reported corrective actions and opportunities for improvement (see section 6.6). Reporting should address: Conformity or nonconformity of the HSEMS elements with specified requirements Effectiveness of the implemented HSEMS in enabling objectives and performance criteria to be met Implementation and effectiveness of corrective actions from previous audits Conclusions and recommendations System for auditing and tracking implementation status of audit recommendations Distribution and control of audit reports Review: The company's senior management should, at appropriate intervals, review the HSEMS and its performance, to ensure its continuing suitability and effectiveness. The review should specifically, but not exclusively, address: The possible need for changes to the Policy and Objectives, in the light of changing circumstances and the commitment to strive for continual improvement The success of the system in integrating HSE Guidelines, Procedures and Performance criteria into the line function Resource allocation for HSEMS implementation and maintenance Are operations and/or sites truly being evaluated on the basis of hazards, risks and emergency planning Reviews are used to reinforce continuous efforts to improve HSE performance. The review process must be documented, and its results recorded, to facilitate implementation of consequent changes. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 54 SERIOUS SERVICES LLC Appendix The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 55 SERIOUS SERVICES LLC POLICY ON ENVIRONMENTAL PROTECTION: It is the policy of SERIOUS SERVICES to ensure that the activities of The Company are conducted with full concern for safeguarding employee and public health, for protection of the physical environment and to comply with relevant environmental laws and regulations. SERIOUS SERVICES policy is to establish and implement effective compliance programs, including systems and procedures, for informing employees of the policy and their continuing obligation to conduct all activities in compliance with this policy and all applicable legal requirements. Where SERIOUS SERVICES becomes aware of a hazard representing a risk not covered by existing laws or regulations, where appropriate, SERIOUS SERVICES will develop its own environmental standards and practices to provide for adequate protection of employees, public health and the environment. In establishing timing, priorities, and levels of control, careful consideration will be given to benefits in relation to costs and technological feasibility. Particular attention will be given to achieving a reasonable balance between environmental goals and those for energy, jobs and the economy. Environmental laws and regulations will be periodically reviewed to comprehend changes in laws and regulations, national goals, new scientific and technical information and resource availability. SERIOUS SERVICES will co-operate with industry and government in identifying environmental goals and in developing effective, reasonable and equitable control programs. It is the responsibility of SERIOUS SERVICES Managers and Supervisors to ensure adherence to SERIOUS SERVICES environmental policy. Further, all employees are expected to be guided by this policy in forming plans, setting objectives and conducting their day-to-day activities. Contractors are to be made aware, of and are expected to comply with, SERIOUS SERVICES environmental policy and standards. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 56 SERIOUS SERVICES LLC POLICY ON EMPLOYEE AND FACILITY SAFETY AND OCCUPATIONAL HEALTH: It is the Policy of SERIOUS SERVICES to ensure that the activities of its Group Companies are conducted with full concern for the safety of its facilities in order to protect the safety and health of employees, communities adjacent to our operations and the general public. SERIOUS SERVICES will comply with all applicable legal requirements pertaining to occupational safety, health, and process safety and fire protection. SERIOUS SERVICES Guidelines, based upon scientific knowledge, established engineering practice and appropriate industry standards will be developed when existing laws and regulations do not provide for adequate protection. SERIOUS SERVICES will carry out the objective of this policy by developing and maintaining safety management systems and procedures, which ensure that process, and employee safety and health considerations receive priority in design, operation, maintenance and decommissioning of facilities. SERIOUS SERVICES also will require appropriate safety and health training and will require strict adherence to safety rules and procedures. SERIOUS SERVICES will hold each Manager, Supervisor and Employee accountable or the safe performance of their job and will measure their achievement in preventing occupational injuries, illness and accidental losses. SERIOUS SERVICES will provide qualified safety and health staff and appropriate equipment to support management in carrying out their objectives and goals in these areas. The same high standards are expected of contractors. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 57 SERIOUS SERVICES LLC POLICY ON PRODUCT SAFETY STEWARDSHIP: SERIOUS SERVICES will comply with applicable laws, regulations and international standards on product safety. In addition, SERIOUS SERVICES will: evaluate its products; identify reasonably foreseeable potential hazards to health and the environment; provide procedures and controls to avoid unreasonable risk; and assess the product safety compliance of its operations. Also, where appropriate, SERIOUS SERVICES will inform employees, customers, users, government agencies and the public concerning product safety. SERIOUS SERVICES will work with government and trade associations to develop and implement product safety regulations that protect employees, transportation personnel, customers and the public, taking into account scientific, economic and social factors. SERIOUS SERVICES are responsible for the development, manufacture and marketing of products in a manner consistent with applicable laws and the company’s high standards of safety, health, and environmental protection. In the absence of adequate local government requirements, SERIOUS SERVICES will maintain standards of safety and health protection that consider scientific knowledge, international standards and established practices in more developed countries. All hazardous purchased products transiting; stored or used on SERIOUS SERVICES properties will be accompanied by a material safety data sheet (MSDS) or its equivalent. Appropriate management, employees and contractors will be made aware of the product and proper precautions on transport, storage, use and disposal. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 58 SERIOUS SERVICES LLC POLICY ON MINIMISATION OF EMISSIONS, EFFLUENTS AND WASTES: SERIOUS SERVICES in addition to complying with all applicable environmental laws and regulations is committed to reduce overall discharges (emissions to air, effluents to surface water, ground water and land surface and solid waste) from its operations wherever technically and economically feasible. This is part of the company's commitment to safeguarding and protecting the physical environment. Although proper management of wastes, including environmentally sound treatment, storage and disposal, is important in protecting the physical environment, eliminating their generation through source reduction and recycling is encouraged. Source reduction can be accomplished in many ways, including input substitution, product reformulation, process modification, and operational changes and improved housekeeping. Recycling includes the use, reuse, and reclamation of residues both on-site and off-site. SERIOUS SERVICES will be responsible for developing, implementing and maintaining programs at their facilities aimed at minimising and preventing the generation of emissions, effluents and wastes. These programs will include the establishment of goals, encouragement of technology development and transfer and review of accomplishments. SERIOUS SERVICES employees and contractors will be informed of this policy and directed to strive for the minimisation and prevention of emissions, effluents and wastes in formulating plans, setting objectives and conducting their daily activities. The controlled version of this document is C Drive: HSEMS Version 0 Custodian 2/8/2016 Paper copies are uncontrolled 59