MASTER AGREEMENT FOR 
 
PROVISION OF PERSONNEL SERVICES
 
 
BP TRINIDAD AND TOBAGO LLC
 
AND
 
Hydrocarbon Outsource Limited
 
 
CONTRACT NUMBER: XX-S-XX (AGR-XXX/11)
 
SECTION 4
HEALTH, SAFETY, SECURITY AND ENVIROMENT REQUIREMENTS

TABLE OF CONTENTS
 
 
1.   INTRODUCTION……………………………………………………….3
 
2.   HSSE MANAGEMENT SYSTEM……………………………………..3
 
3.   COMPLIANCE…………………………………………………………..5
 
4.   RISK……………………………………………………………………...5
 
5.   PROCEDURES…………………………………………………………6
 
6.   WORKING CONDITIONS……………………………………………..8
 
7.   WASTE DISPOSAL AND ENVIRONMENTAL SAFEGUARDS…...8
 
8.   SUBSTANCE ABUSE POLICY……………………………………….8
 
9.   METRICS, REPORTING AND INCIDENT MANAGEMENT……….9
 
10. ASSESSMENT AND AUDIT…………………………………………..10
 
11. EXHIBITS……………………………………………………………….11

 
INTRODUCTION
The following sections outline minimum requirements COMPANY expects CONTRACTOR to work to in support of COMPANY’s HSSE goals. COMPANY will work with CONTRACTOR to ensure that all of these expectations and CONTRACTOR’s role in delivering against these expectations are clearly understood. Compliance with the requirements set out in this Section is compulsory for WORK performed at COMPANY controlled premises or where COMPANY has control of operations.  The CONTRACTOR shall be required to work to an approved HSSE Management System (HSSE-MS). COMPANY emphasises that it shall continually verify, monitor and frequently audit the CONTRACTOR to ensure that CONTRACTOR is performing the WORK in accordance with the approved HSSE Plan and in accordance with COMPANY requirements and expectations as defined within this Section IV HSSE Requirements and Expectations document or any other COMPANY approved documents and/ or requirements that may be notified to the CONTRACTOR during the performance of the WORK.
 
 
1.0 OPERATING MANAGEMENT SYSTEM (OMS)

1.1 COMPANY is committed to deliver safe, reliable, and efficient operations wherever it operates. To ensure that these objectives continue to be met, COMPANY has adopted the Operating Management System (OMS) which sets out the requirements by COMPANY for managing risks and performance improvement.
1.2 While COMPANY does not expect CONTRACTOR to adopt OMS, it is the responsibility of CONTRACTOR to adopt and operate whatever management system and standards are appropriate for its business and activities. In practice, when CONTRACTOR is working at any LOCATION for any COMPANY entity that is operating on OMS, the WORK is governed by the Local Operating Management System (LOMS) as it applies at the WORKSITE as may be amended from time to time. The LOMS incorporates the requirements of OMS.
1.3 CONTRACTOR is expected at all times to follow and in be in full compliance of the HSSE policies of COMPANY once performing the WORK

2.0  HSSE MANAGEMENT SYSTEM

2.1        The HSSE Management System consists of the Health, Safety, Security, and Environmental HSSE) Requirements for CONTRACTOR and any SUBCONTRACTOR performing the WORK at any WORKSITE (where COMPANY is the operator) and/or on COMPANY Project Sites (where the WORK is performed exclusively for COMPANY). COMPANY’S HSSE Requirements encompass compliance with all applicable federal, state/provincial, maritime, and local statutes, regulations, enforceable agreements, agency orders, permits, and CONTRACT documents. The HSSE Requirements also include specific COMPANY Requirements as disclosed below and any LOCATION or site specific requirements not specified below. CONTRACTOR shall ensure that any SUBCONTRACTOR it employs meets these HSSE Requirements. CONTRACTOR will take any additional precautions necessary to prevent harm to personnel or damage to the environment, property, or COMPANY’S reputation.
 
 
2.2        The HSSE management system of CONTRACTOR shall, where relevant interfaces exist, be
compatible with the HSSE management system of COMPANY.  CONTRACTOR shall liaise with COMPANY REPRESENTATIVE to ensure that the roles and responsibilities in both systems are clearly defined and allocated and are clearly understood by all parties involved in the WORK and associated operations.
2.3        Within the framework of its HSSE management system, CONTRACTOR shall perform the WORK to HSSE performance standards which are compatible with those in the HSSE Management System of COMPANY.
 
2.4        Where applicable, CONTRACTOR shall ensure that similar standards apply to the HSSE management systems used by any SUBCONTRACTOR.
 
2.5        CONTRACTOR’S HSSE Management System shall be adequately documented, shall be shown to be effective in implementing the aims and objectives of its HSSE policy and shall include provisions for auditing the effectiveness of such HSSE Management System.
 
2.6        CONTRACTOR shall have in place and be actively using a formal HSSE Management System which demonstrates commitment to continuous improvement and excellence in HSSE risk management.
 
2.7        CONTRACTOR’S Leadership shall:

1. demonstrate management commitment to compliance with legal and regulatory requirements, and to conformance with COMPANY and CONTRACTOR Requirements;
2. model behaviours by personal examples that reinforce continuous risk reduction and performance improvement;
3. actively communicate HSSE expectations and COMPANY and CONTRACTOR Requirements, routinely monitor HSSE performance, develop action plans for continuous improvement, and actively take ownership of HSSE;
4. ensure that CONTRACTOR PERSONNEL understand and comply with COMPANY HSSE expectations and COMPANY and CONTRACTOR Requirements;
5. not tolerate retaliatory action against any member of their workforce for reporting in good faith, to line management or in confidence via any available COMPANY process, operating concerns or concerns relating to legal compliance or conformance to COMPANY and CONTRACTOR Requirements;

 
2.8        CONTRACTOR shall review its HSSE Management System at least annually and update it as necessary. In addition, the HSSE bridging document shall also be revised to reflect the changes.
 
2.9        CONTRACTOR shall demonstrate that the system for the pre-qualification and selection of any SUBCONTRACTOR ensures the compatibility and effectiveness of each SUBCONTRACTOR HSSE management system

 
3.0        COMPLIANCE3.1        In addition to the requirements of Article 3, CONTRACTOR shall observe and comply with relevant and current statutory requirements on HSSE matters.
 
3.2        CONTRACTOR shall ensure that all PERSONNEL comply with relevant HSSE legislation and that they are:

1. fully conversant with the working conditions at each LOCATION, the hazards and risks associated with the WORK and the roles and standards relating to the environment including the handling of waste and hazardous materials;
2. fully aware that they are expected to bring to the immediate notice of their supervisor any health, safety and environmental risks which they believe not to be under adequate control, so that action may be taken to prevent potential injuries or other losses and provide a safe and healthy workplace;
3. familiar with the site specific HSSE requirements and any other safety and working instructions applicable in the WORKSITE; and
4. available at all times for periodic drills, instructions on survival, life saving and fire fighting as requested and conducted by COMPANY and shall, prior to or on the day of arrival at a COMPANY location (offshore, onshore, office) attend a safety induction course conducted by COMPANY.

3.3        If in the opinion of COMPANY REPRESENTATIVE, CONTRACTOR is working in a manner which contravenes any requirement of these HSSE provisions, COMPANY shall stop all work that it deems unsafe and serve notice on CONTRACTOR to this effect and CONTRACTOR shall immediately comply with the requirements as outlined in COMPANY’S Control of Work policy
 
3.4        CONTRACTOR shall ensure that required regulatory training has been identified and completed. Required competencies must be demonstrated at all times, and where applicable, prior to commencement of the WORK. COMPANY reserves the right to require reasonable additional site-specific training and documentation.
 
4.0 Risk

4.1 CONTRACTOR shall develop a risk register which considers hazards and risks relating to operating performance (refer to Appendix 1 Attachment 1 for examples of Task Hazard Checklists). The risk register shall include the assessed impact and probability for each identified level risk and identify plant, process, people and performance risk reduction measures that are in place to manage and/or mitigate those risks. CONTRACTOR shall review and update the risk register at periodic intervals as defined by COMPANY.

4.2  Certain activities pose a higher risk to the safety of personnel, property and the environment.  Higher risk activities will accordingly demand a higher level of HSSE management from CONTRACTOR.  Where the use of a SUBCONTRACTOR involves the importation of higher risk activity, CONTRACTOR shall ensure and demonstrate the appropriate level of HSSE management.

4.3   Risk may vary from one LOCATION to another and, where the WORK is being provided at more than one LOCATION, CONTRACTOR may be required to provide different levels of HSSE management at each LOCATION.
4.4        CONTRACTOR shall utilize the behavioural-based safety program of COMPANY with performance targets as set out by the annual key performance indicators. CONTRACTOR shall communicate to PERSONNEL the expectation that everyone has an obligation to stop WORK that is unsafe.
4.5        CONTRACTOR shall identify, provide, maintain and train PERSONNEL in Personal Protective Equipment (PPE) requirements against the WORK environment based on the type and duration of exposures. CONTRACTOR PPE program must comply with all legal requirements and aligned to bpTT’s PPE policies at a minimum so as to protect PERSONNEL from chemical, physical, biological, or other hazards that may be present at any WORKSITE. CONTRACTOR shall ensure PERSONNEL have proper personal protective equipment (PPE) before WORK begins, and that PPE is worn as required. CONTRACTOR shall obtain and comply with individual site PPE requirements in accordance with the PPE policy of COMPANY.
Unless expressly stated otherwise in this Section or elsewhere in the CONTRACT, provision of all necessary PPE for all PERSONNEL shall be the sole responsibility of CONTRACTOR, and shall not be reimbursed by COMPANY.
 
4.6        CONTRACTOR shall conduct or take part in regularly scheduled on-site or off-site HSSE meetings discussing among other topics, facility and job hazards, incidents, near-misses, site-specific safety and health rules, and site-specific procedures.
 
5.0  Procedures

5.1     CONTRACTOR shall immediately following the CONTRACT COMMENCEMENT DATE but prior to mobilisation to WORKSITE, complete a detailed gap analysis between: -

1. CONTRACTOR’S and COMPANY’S procedures in operation at the WORKSITE, using the HSSE Bridging Document to identify the respective procedures applicable/ available;

1. the capabilities and requirements of CONTRACTOR’S HSSE Requirements and COMPANY’S HSSE Requirements of this Section 2.0 as they apply at the relevant WORKSITE(S);

1. the HSSE practices and capabilities of SUBCONTRACTORS (including suppliers of EQUIPMENT) and CONTRACTOR’S HSSE Requirements and the HSSE Requirements of this Section 2.0;

1. COMPANY and CONTRACTOR shall agree on the HSSE Bridging Document and the HSSE Bridging Document in conjunction with COMPANY’S HSSE Plan will govern the conduct of the WORK

 
5.2     CONTRACTOR shall at all times follow and comply with the hazard identification and risk assessment process and procedure of COMPANY once performing the WORK. The hazard identification and risk assessment process and procedure of COMPANY shall include but not limited to a process for completing daily Job Safety Analysis (JSA) / Job Safety Environmental Analysis (JSEA) to facilitate the daily task hazard analysis.
5.3     CONTRACTOR shall ensure Material Safety Data Sheets (MSDS) are updated and available at any  LOCATION and/or COMPANY Project Sites for all chemicals provided by CONTRACTOR and that the MSDS are reviewed as part of the JSA/toolbox discussions.
 
5.4     CONTRACTOR shall have a preventive maintenance program that includes, at a minimum, the      identification and prioritization of maintenance for safety and/or environmental critical items, safety critical equipment and protective systems
 
5.5     CONTRACTOR shall evaluate and manage road transportation risks appropriate to the WORKSITE, and where applicable to prevent injury to people and/or loss or damage to EQUIPMENT or property. CONTRACTOR shall systematically identify transport hazards, assess risk, and implement and maintain risk reduction measures identified as necessary to manage the risk. All CONTRACTORS who drive in service of conducting bp business are required to meet the requirements outlined in the COMPANY Driving Safety Standard which includes possession of a valid defensive driving certificate.
 
 
5.6     CONTRACTOR shall implement and maintain a Control of Work (COW) process to plan work, identify hazards, assess risk and put in place risk reduction measures to allow work tasks to be completed safely and without unplanned loss of containment causing environmental damage or damage to community assets.
 
CONTRACTOR shall have a documented and functioning Control of Work set of procedures that meet COMPANY COW practice requirements and include as a minimum: -
 
Plan the work

1. A written procedure shall exist describing the Control of Work process.
2. All identified roles within the Control of Work procedure shall have defined accountabilities.
3. All persons involved in the Control of Work process shall be appropriately trained and competent to carry out their roles.
4. Planning and scheduling of work shall identify individual tasks and their interaction.

Assess and manage the risk

1. Tasks shall not be conducted without being risk assessed.
2. Before conducting work that involves confined space entry, work on energy systems, ground disturbance, hot work in potentially explosive environments or other hazardous activities, a permit shall be obtained.
3. The scope, hazards, controls and mitigations shall be communicated in writing and signed off by all involved in the task.

Control the work

1. All ongoing work requiring a permit shall be regularly monitored and managed by a responsible person.
2. The WORKSITE shall be left in a safe condition on completion or interruption of the work.

Capture the learning

1. The Control of Work process shall include a program of regular auditing.
2. Internal and external lessons learned that impact the Control of Work process shall be captured, incorporated and shared.

Stop unsafe work

1. The Control of Work procedure shall make it clear to everyone that they have an obligation to stop unsafe work.

 
 
Certification Requirements
COMPANY has identified certain WORK positions which are especially responsible for ensuring safety during work or who are otherwise assigned on specific hazardous or safety critical tasks. PERSONNEL who hold these positions must not only possess the necessary competencies and capabilities relevant to their assigned tasks but their skills and competencies must be regularly assessed and certified by an independent party. These positions include: -

• Permit-to-Work Issuers and Receivers
• Isolation Authorities
• Authorized Gas Testers
• Safety Watch
• Fire Watch
• Confined Space Attendant
• Scaffolders and Scaffolding  Foremen
• Crane Operators, Riggers, Signalmen,
• Cherry Picker Operators
• Side boom Operators
• Rigging Supervisors

 
6.0 WORKING CONDITIONS

1. CONTRACTOR shall formally advise COMPANY REPRESENTATIVE of any known medical disability or condition of any PERSONNEL, which may adversely affect their own health and safety, or the health and safety of others.
2. CONTRACTOR shall ensure that all PERSONNEL shall keep WORKSITES as clean and tidy as is reasonably practicable under the circumstances, to minimise the risk of causing injury to persons, damage to property or delays in completing the WORK.

 
7.0        WASTE DISPOSAL AND ENVIRONMENTAL SAFEGUARDS

1. In the performance of the WORK, CONTRACTOR shall at all times:

1. observe and comply with laws and regulations and/or COMPANY requirements or policies concerning the production, carrying, keeping, treating and/or disposal of waste;
2. act to minimise the quantity of wastes;
3. comply with the environmental management system as it affects their operations within the WORKSITE

8.0        SUBSTANCE ABUSE POLICY

1. COMPANY is committed to providing a safe and healthy working environment for employees, visitors and THIRD PARTIES impacted by its operations.  This includes an environment free from the hazards caused by the abuse of substances including alcohol.  The policy equally applies in all aspects to both onshore and offshore staff both of COMPANY, CONTRACTOR or any OTHER CONTRACTOR and at each WORKSITE where the WORK is performed on behalf of COMPANY.
2. Smoking is prohibited on all offshore and onshore COMPANY facilities, with the exception of designated areas at the office locations. In addition, COMPANY specific requirements related to applicable law and the WORKSITE may require additional considerations to be appropriately managed by CONTRACTOR.

 
9.0   Metrics, Reporting and INCIDENT MANAGEMENT CONTRACTOR shall sustain performance by the use of leading and lagging indicators to monitor and measure progress against objectives and targets in the COMPANY’s HSSE Plan.

• CONTRACTOR to report HSSE performance data in accordance with COMPANY requirements electronically on the 10th business day of each and every month.

 
9.1       The core HSSE KPIs CONTRACTOR is required to report shall include but not be exclusively limited to the following: -

• Manhours

• Leading:

Near misses
HSSE Training hours
Leadership site visits
Number behaviour based safety conversations (eg STOPs, SOCs)
% Short service contractor personnel
Number Drills
Number hours- HSSE awareness meetings
% Audits (JSA/permits)
% Timely closure of actions

• Lagging:

First Aids
Total Recordable injury rate
Total Vehicle accident rate
Days away from work cases
High Potential Incidents
Fatalities
Environmental incidents
Any other event reportable to any AUTHORITY
 
CONTRACTOR shall assess at defined intervals the results of KPIs to identify trends, emerging risks, identify improvement opportunities and report results to COMPANY at quarterly performance review meetings.
 
9.2  CONTRACTOR shall immediately notify COMPANY of all CONTRACTOR or SUBCONTRACTOR incidents resulting in personal injury, spills or releases, security issues, loss or damage to property, or near-misses. COMPANY shall report and investigate incidents to identify immediate and system causes. COMPANY retains the right to participate or conduct its own incident investigation. For all incident investigations, CONTRACTOR will provide a written investigation report to COMPANY. The investigation report shall identify possible root causes associated with the incident as well as proposals for corrective actions. When requested, CONTRACTOR shall furnish COMPANY with a copy of reports which are not the subject of legal privilege, and which are made by or on behalf of CONTRACTOR concerning an incident, including any non-privileged statements or other similar investigative material.
 
CONTRACTOR shall develop and maintain an incident reporting response capability such that any incident, including Near Misses occurring during the WORK or at WORKSITES (whether involving COMPANY employees, CONTRACTOR employees or the general public) shall be reported using the COMPANY Incident Investigation and Reporting Procedure. 
 
10.0   Assessment and AuditCONTRACTOR shall perform assessments and audits of HSSE performance and management processes to assure compliance with legal and HSSE Plan requirements, and thus drive risk reduction as well as contributing to performance improvement.

• CONTRACTOR shall implement and maintain a risk based internal self assessment program to monitor that operating activities are being carried out in accordance with CONTRACTOR’S HSSE Plan
• CONTRACTOR shall plan and prepare for HSSE audits by COMPANY;
• CONTRACTOR shall identify and implement corrective actions with due dates for completion to address the findings of these self-assessments and audit, and track each to completion;

CONTRACTOR shall assess at defined intervals the results from self assessments and audits to identify trends, emerging risks, opportunities to improve risk reduction measures and identify improvement opportunities and report results to COMPANY at quarterly HSSE performance reviews.
 
11.0      REFERENCE DOCUMENTSIn the performance of the WORK, CONTRACTOR shall, as appropriate, refer to the following reference documents attached hereto:

• BP Operating Management System (OMS) –  (Exhibit A to Section IV – HSSE    Requirements)
• Task Hazard Checklist - (Exhibit B to Section IV – HSSE Requirements)
• WORKSITE Specific HSSE Standards – (Exhibit C to Section IV – HSSE Requirements)

EXHIBIT A – BP OPERATING MANAGEMENT SYSTEM (OMS)

Appendix 1 – bp operating management system (OMS)OMS is a comprehensive operating management system that integrates and improves existing management systems. It provides the framework to achieve safe and reliable operations day-in and day-out. OMS helps manage every element of operating, from basic compliance to excellence in performance.
In the short term, OMS helps BP meet the minimum requirements set by the law, BP Group and E&P Segment. In the longer term, effective OMS implementation will position BP to take and maintain the lead in operating excellence while building a supporting culture that learns and drives continuouss improvement.
 
Every site and business within BP E&P already uses a management system to set priorities and manage risk. The OMS Framework, illustrated in Figure 1, functions by applying the Performance Improvement Cycle (PIC) to local business processes. These processes deliver the outcomes defined in the BP Group Essentials, categorized within the Elements of Operating. In turn, assessments against the Group Essentials inform the risk assessment and prioritization step of the PIC. 
 
Local Business Processes
Each business defines a local OMS which describes how it delivers operating activities. The LOMS is developed, implemented and sustained locally. The local OMS translates business needs, relevant legal and regulatory requirements and OMS requirements into practical plans to reduce risk and deliver safe, sustainable performance.
 
Elements of Operating and Gap Assessment
The Elements of Operating describe eight dimensions of how people, process, plant and performance operate within BP.  Each of the eight interdependent Elements of Operating is divided into sub-elements (Figure 2), which need to be selectively and systematically managed to improve performance. Group and Segment Essentials corresponding to the sub-elements outline specific requirements covering risk mitigation, legal and regulatory compliance and conformance with BP requirements. A gap assessment against the Essentials is a necessary part of the risk assessment and prioritization step of the PIC.

Figure 2 BP OMS Elements and Sub-Elements

 

 

More details about BP OMS can be found in BP E&P OMS Manual Version 2.0. These materials are proprietary of BP and therefore should only be used, by BP International Limited, its affiliates and contractors that provides service for BP.

 

 

 

1. LEADERSHIP

Our operating leaders are competent, exhibit visible, purposeful and systematic leadership and are respected by the organizations they lead.

 

OPERATING LEADERS:

BP operating leaders provide clear direction to the people in their organization and then act in accordance with it.

 

Requirements:

·          Define and then annually review and communicate to the workforce an entity vision that includes details of how the application of OMS will enable continuous risk reduction and performance improvement and safe, responsible and reliable operating.

·          Demonstrate management commitment to compliance with legal and regulatory requirements, to the application of OMS and to conformance with BP Requirements.

o    Conduct periodic and planned leadership site reviews.

·          Model behaviors by personal example that reinforce continuous risk reduction and performance improvement.

o    Verify that operations integrity risks are systematically identified, understood, and managed.

§   Verify understanding of risks with key stakeholders.

§   Review risk mitigation plans periodically, know the key elements, and communicate to stakeholders as needed.

·          Seek feedback on their leadership behavior, and reflect it in their personal development.

 

OPERATING STRATEGY

BP leaders integrate operating activities into business strategies and objectives to deliver continuous risk reduction and performance improvement.

 

Requirements:

·          Incorporate a strategy for continuous risk reduction and operating performance improvement into the entity business strategy.

·          Maintain and communicate to the workforce a local operating policy consistent with the entity vision and OMS, and that includes the BP Commitment to Health, Safety and Environmental Performance.

·          Develop and annually review a statement of intent aligned to the entity vision and operating policy, explaining the objectives and scope of the local OMS.

·          Monitor the external environment and update the strategy for continuous risk reduction and performance improvement in response to changing business needs.

 

PLANNING AND CONTROLS

BP leaders formulate annual plans aligned to the local operating policy to address risks, performance delivery and performance improvement opportunities, and establish controls to deliver intended outcomes.

 

Requirements:

·          Identify and document risks and opportunities to be addressed in a prioritized way through the local OMS and include them in the annual planning process.

·          Incorporate objectives, targets, actions and accountabilities into the annual plan to manage operating risk, to deliver the requirements of OMS, and to close gaps against the Group Essentials.

·          Establish control mechanisms to address risks to the delivery of the annual plan and assess performance against the plan.

 

RESOURCE AND IMPLEMENTATION

BP leaders provide sufficient resources to manage risks and deliver performance improvement, and apply control mechanisms to identify and correct deviations from the annual plan.

 

Requirements:

·          Appoint Engineering and Marine Authorities.

·          Work with their Segment and/or SPU Engineering, Marine and Operating Authorities to support the delivery of safe, responsible and reliable operating activities.

·          Assign accountabilities and delegations to deliver BP Requirements.

·          Provide BP employees with clearly defined and documented accountabilities. Set performance standards, goals and objectives which are aligned with their performance contracts and reward mechanisms.

o    Document and communicate the local progressive disciplinary policy and apply it consistently across the organization, including a description of consequences for:

§   Non-compliance with legal and regulatory requirements.

§   Unsanctioned deviations from local operating procedures and policies.

 

ACCOUNTABILITY

BP operating leaders create and support clear delegation and accountability consistent with BP Requirements.

 

Requirements:

·          Appoint Engineering and Marine Authorities.

·          Work with their Segment and/or SPU Engineering, Marine and Operating Authorities to support the delivery of safe, responsible and reliable operating activities.

·          Assign accountabilities and delegations to deliver BP Requirements.

·          Provide BP employees with clearly defined and documented accountabilities. Set performance standards, goals and objectives which are aligned with their performance contracts and reward  mechanisms.

o    Document and communicate the local progressive disciplinary policy and apply it consistently across the organization, including a description of consequences for:

§   Non-compliance with legal and regulatory requirements.

§   Unsanctioned deviations from local operating procedures and policies.

 

 

 

 

 

 

COMMUNICATION AND ENGAGEMENT

BP leaders, through their actions and behaviors, create an environment in which the workforce are informed, involved and enabled to do their jobs.

 

Requirements:

·          Communicate business context and plans for risk reduction and performance improvement to the workforce.

·          Communicate to BP employees the process that enables them to report, in confidence, operating concerns and concerns relating to legal compliance or conformance with BP Requirements.

·          Apply reward and disciplinary programs to reinforce and reward behaviors consistent with legal and regulatory requirements and BP Requirements.

·          Not tolerate retaliatory action against any member of the workforce for reporting in good faith, to line management or in confidence via any available BP process, operating concerns or concerns relating to legal compliance or conformance to BP Requirements.

·          Implement and maintain a process to consult with the workforce to identify continuous risk reduction and performance improvement opportunities.

·          Develop a Local Operating Management System Handbook and communicate the contents to the workforce.

·          Require leaders to seek feedback at defined intervals on their communication and engagement activities and modify them as needed.

 

CULTURE

BP leaders take action to develop and maintain a culture and behaviors that enable safe, responsible and reliable operating.

 

Requirements:

·          Define and communicate the desired operating culture and behaviors to the workforce; address behaviors that are inconsistent with the desired culture, and encourage and recognize behaviors that support it.

·          Assess the operating culture and behaviors at defined intervals and develop improvement plans as needed.

 

 

2. ORGANIZATION

We have fit for purpose and agile organizations staffed with competent people and teams.

 

ORGANIZATION STRUCTURE

BP entities establish organizations that allow them to deliver their planned business objectives effectively and efficiently through the deployment of competent people and adequate resources.

 

Requirements:

·          Document and implement an organization structure aligned to manage entity business and operating processes.

·          Establish clear line reporting relationships ensuring leaders have a manageable span of control, and BP employees have a clear understanding of their roles, accountabilities and objectives.

·          Allow functional experts access to entity leaders and independent access to their functional leadership to discuss operating risk concerns.

·          Identify activities to be carried out by contractors and other parties and provide BP resources to manage the interfaces.

 

PEOPLE AND COMPETENCE

BP entities deploy and maintain competent employees with appropriate qualifications, skills and knowledge for roles that impact integrity and operating performance and to meet current and future business needs.

 

Requirements:

·          Implement and maintain a people resourcing strategy to meet the current and anticipated needs of the business and which assigns accountabilities for recruitment, selection and retention of personnel.

·          Define required competencies and training for roles to be filled by BP employees, including any legally required training.

o    Base training offers on recommended curricula from the function and involve the team leader in defining specific additional training necessary to achieve required competency and proficiency levels.

·          Perform induction training covering HSSE and emergency procedures for new or transferred BP employees, contractor employees and visitors.

o    Include the local OMS as part of new employee orientation.

·          Maintain training materials and records, evaluate training effectiveness at defined intervals, and implement identified improvements as needed.

o    Implement CMAS-ican when migrating or upgrading the local business to an electronic competency assurance system.

·          Implement and maintain performance management and career development processes to monitor and improve individual performance and enhance contribution.

 

OPERATING DISCIPLINE

BP entity leaders hold the workforce accountable for performing their work in accordance with operating procedures and practices.

 

Requirements:

·          Require members of the workforce to stop work that they consider unsafe or likely to cause loss of containment causing damage to the environment.

o    Implement a local policy which defines the expectations to stop work that is unsafe, non-compliant with environmental regulations or not conforming to BP Requirements.

·          Define and communicate to the workforce the consequences of noncompliance with legal and regulatory requirements, BP Requirements and local operating procedures and practices.

·          Monitor workforce understanding and observance of legal and regulatory requirements, BP Requirements and local operating procedures and practices. Apply defined consequences for noncompliance.

 

 

 

 

 

 

 

ORGANIZATIONAL LEARNING

BP entities continuously improve their local OMS, both sharing and incorporating learnings from within and outside the entity or BP Group.

 

Requirements:

·          Share high value learnings and other lessons learned from incident or other local operating investigations and good operating practices with other members of BP Group.

·          Benchmark good operating practices from across the BP Group and/or external sources to identify opportunities for risk reduction and operating performance improvement.

·          Prioritize and incorporate into the local OMS specific improvement opportunities identified through self-assessments, audits, annual management reviews, project reviews, internal and external incident investigations, high value learnings and benchmarked good practice.

 

WORKING WITH CONTRACTORS

BP entities systematically assure that goods, equipment and services provided by suppliers, contractors and other parties meet contractual and BP Requirements.

 

Requirements:

·          Designate BP employee and contractor employee roles which have accountability for the management of contracts, the safety of the contractor employees and the safety of their work activity.

·          Implement a process to screen and select contractors based on a combination of their capability, contractor employee competency, financial viability and HSSE performance, taking into account the technical, commercial and HSSE risks of the specific work.

·          Define contractually and inform contractors of the entity’s HSSE requirements for the services and equipment to be provided, the scope of work of the contract and identified boundary conditions.

·          Contractually require contractors to communicate the entity’s HSSE requirements to their employees and subcontractors and demonstrate that they follow them

o    Confirm that contractor and subcontractor personnel receive a site or project-specific induction that highlights BP’s HSSE expectations, site hazards, and compliance tasks to be accomplished by them.

·          Contractually require contractors to confirm at defined intervals that their employees are competent and their equipment is fit for service, and their work is carried out in compliance with entity requirements.

·          Evaluate contractor performance at defined intervals to provide feedback, lessons learned and a basis for improving future contractor selection and performance

 

3. RISK

The workforce at all levels of our organization understands and manages operating risk to prevent accidents and harm to people, to reduce damage to the environment and to achieve competitive performance.

 

 

 

 

 

 

RISK ASSESSMENT AND MANAGEMENT

BP entities assess, prioritize and manage operating risks consistent with BP Requirements.

 

Requirements:

·          Develop and then update at least annually an entity level risk register which considers hazards and risks relating to operating performance. The risk register shall include the assessed impact and probability for each identified entity level risk and identify plant, process, people and performance risk reduction measures that are in place to manage those risks.

o    Document and implement a major hazards risk management policy.

·          At least annually communicate the importance of the risk reduction measures put in place to manage the identified entity level risks, and the reasons for them, to those members of the workforce who apply them and to those members of the workforce who may be affected by the identified entity level risks.

·          At least annually update a gap assessment of the entity’s operating activities against the Group Essentials, GDPs and Segment, SPU and entity requirements. The gap assessment against the Group Essentials requires a full assessment with a facilitator who is external to the entity when first transitioning to OMS and thereafter every 3 years.

·          Use the gap assessment results to identify and prioritize opportunities for risk reduction and performance improvement that can be delivered through improvements to both the specification and application of the plant, process, people and performance risk reduction measures that constitute the local OMS.

·          Identify and apply tools to assess operating risks commensurate with the particular types of risk presented.

·          Document risk assessments and risk management control measures and include them in project approval documentation.

o    Document and manage residual risk throughout the project cycle.

§   Record and communicate residual risk carried from one stage gate to another.

·          Assign accountabilities for recording and communicating residual risks at each stage gate.

·          Confirm that projects document and communicate hazards, residual risks and safeguards to be managed by operations in the Operate stage of a project, prior to handover to operations.

 

PERSONAL SAFETY

BP entities provide a safe working environment by systematically identifying and assessing safety hazards and mitigating potential risks to people.

 

Requirements:

·          Systematically identify personal safety hazards, assess risk, and implement and maintain plant, process, people and performance risk reduction measures identified as necessary to manage the risk, and use as an input to the entity risk register. Personal safety hazards include but are not limited to breaking containment, working at heights, confined space entry, energy isolation, ground disturbance, power tools, electrocution, cranes and other lifting devices.

o    Engage the workforce in the identification, assessment and mitigation of safety-related hazards through a documented process.

·          Assess the engagement process at a frequency set by the local business and implement corrective actions as appropriate.

·          Implement and maintain a behavior-based safety process to continually improve operating behaviors through observation, recording and coaching.

o    Implement the Safety Observations & Conversations (SOC) program.

 

PROCESS SAFETY

BP entities manage the integrity of hazardous operating systems and processes by applying good design principles, engineering and operating practices which prevent and control incidents that have the potential to release hazardous materials or energy. Such incidents can cause toxic effects, fire or explosion and could ultimately result in serious injuries, environmental impact, property damage and lost production.

 

Requirements:

·          Systematically identify process safety hazards, assess risk, and implement and maintain plant, process, people and performance risk reduction measures identified as necessary to manage the risk, and use as an input to the entity risk register. Process safety hazards include but are not limited to sources of ignition, explosions, fires, and uncontrolled releases of hydrocarbons, toxic chemicals, high or low temperature materials and stored energy.

·          Identify whether there is a potential for a major accident, and if so, complete an assessment of the major accident risks; use identified major accident risks as input to the entity level risk register.

·          Define, based on entity risks, the level of process safety and operating integrity expertise needed to design, construct and operate safely. Provide BP employees with access to this expertise through available internal or external resources.

HEALTH AND INDUSTRIAL HYGIENE

BP entities manage their business to prevent harm to the health of employees, contractors, visitors and neighbors in local communities.

 

Requirements:

·          Systematically identify hazards including human factors in the work environment that could harm health. These include chemical, physical, biological, ergonomic hazards and psychosocial factors.

o    Assign Industrial Hygiene (IH) competent personnel to conduct hazard identification within the local business.

o    Document and regularly review hazards under normal operating conditions and for emergency scenarios.

·          Assess exposures and risks from identified health hazards, and implement and maintain plant, process, people and performance risk reduction measures identified as necessary to manage them. Use this as an input to the entity risk register.

o    Document applicable occupational exposure limits (OELs) for identified IH hazards.

o    Conduct quantitative workplace monitoring where potential exposure levels are uncertain relative to occupational exposure limits for identified IH hazards.

o    Assess exposure for compliance and maintain records in accordance with local business standards and the Group Reporting Practice.

o    Document and implement IH hazard control programs when there is the potential for exposures above applicable exposure limits.

o    Report actual or potential exposures in excess of established exposure limits in accordance with local business reporting procedures.

·          Conduct a management review upon identification of actual or potential exposures in excess of established limits.

·          Involve medical staff in evaluating the need for medical surveillance in the event of actual or potential exposures in excess of established limits.

o    Communicate via local leadership the results of monitoring, and applicable related recommendations, to those that are potentially impacted.

·          Implement and maintain exposure assessment programs to monitor the effectiveness of risk reduction measures to eliminate or manage exposures to identified health hazards.

·          Define fitness for task requirements for identified tasks where fitness is needed for the safety and health of the individual or to deliver safety and production critical operating activity. Assess BP employees against the fitness for task requirements for their role, record assessments, identify any gaps, and take action to close them.

·          Implement and maintain risk based programs to promote and monitor that individual performance of members of the workforce is not impaired by drugs and alcohol.

·          Implement and maintain health surveillance programs to monitor the health of BP employees who may be exposed to known workplace health risks.

·          Develop expertise in conjunction with Group Health that provides ready access to BP employees to health and industrial hygiene advice and support required to effectively manage risk and promote health and wellness

 

SECURITY

BP entities put processes in place to maintain the security of the workforce, premises, facilities, equipment and information.

 

Requirements:

·          Systematically identify security hazards, assess risk, and implement and maintain plant, process, people and performance risk reduction measures identified as necessary to manage the risk, and use as an input to the entity risk register. Security hazards include but are not limited to criminal conduct, intimidation, violence, sabotage, unauthorized access or damage to BP property, and unauthorized access to, alteration, use or disclosure of information.

 

·          Develop, implement and update at least annually a security management plan based on the results of the hazard evaluation and risk assessment. Develop internal security expertise in conjunction with Group Security and designate individuals as subject matter experts and security advisors to entity management.

·          Implement and maintain processes for the workforce to securely handle valuable and sensitive information in all forms, including Confidential and Secret information.

·          Design and operate IT and digital process control systems to manage risk to system and information integrity, availability and confidentiality.

 

ENVIRONMENT

BP entities identify and systematically manage the impact of their activities on the environment and integrate environmental requirements into the local Operating Management System.

 

Requirements:

·          Systematically identify environmental hazards, assess risks and opportunities to minimize environmental impact, and implement and maintain plant, process, people and performance risk reduction measures identified as necessary to manage the risks and use as an input to the entity risk register. Environmental risks include but are not limited to emissions to air, discharges to water and land and the handling and disposal of waste.

·          Identify the potential environmental, health and social impacts of projects, designing them to avoid or mitigate adverse impacts and reduce use of natural resources.

·          At Major operating sites, maintain external ISO14001 certification and produce an externally verified environmental statement at least every three years.

 

TRANSPORTATION

BP entities evaluate and manage transportation risks covering land, sea and air travel to prevent injury to people.

 

Requirements:

·          Systematically identify transportation hazards, assess risk, and implement and maintain plant, process, people and performance risk reduction measures identified as necessary to manage the risk, and use as an input to the entity risk register. Transportation hazards include but are not limited to road vehicle, bicycles, rail, ship, fixedwing aircraft and helicopter travel.

·          Require that all vehicles operated by members of the workforce while on BP business are operated and maintained to a defined standard, have fully functional seat belts installed, and that the seat belts are worn by all occupants at all times whenever the vehicle is in motion.

·          Require that members of the workforce while operating a vehicle on BP business do not use mobile phones or other two-way communication devices.

·          Require that motorcycles are not used on BP business unless a documented risk assessment is completed to support the advantages of their use rather than automobiles.

·          Require that in higher risk countries journey risk management plans must be in place.

·          Require that members of the workforce driving on BP business be appropriately assessed, licensed, trained and fit to operate the vehicle, be rested and alert, and do not operate any vehicle when fatigued.

·          Verify that all aircraft contracted or chartered to move the workforce for BP purposes, are operated and maintained to a defined standard, and that their use is in accordance with BP Requirements.

·          Implement and maintain a process to deliver safe, secure, timely and cost-effective BP employee business travel.

 

4. PROCEDURE

We document and rigorously follow procedures for safe, responsible and reliable operating.

 

PROCEDURES AND PRACTICES

BP entities document, maintain and follow practices and procedures for the safety of their workforce and the safe, responsible and reliable operation of their assets, facilities, floating structures and transport equipment.

 

Requirements:

·          Develop, implement and maintain local OMS procedures and practices for human resources, HSSE, engineering, operations, maintenance, inspection and projects. Require that operations
procedures cover normal operating conditions as well as startup, shutdown, upset and emergency conditions.

o    Specify guidelines for developing and using temporary operating and maintenance procedures.

·          Define which procedures and practices are applicable to identified BP employees or contractors, and make these procedures and practices available to them. Require contractors to follow these procedures or practices unless they have their own comparable procedures and practices.

·          Monitor that entity procedures and practices are up-to-date, understood and consistently followed, and take corrective action when gaps are identified.

·          Review and update entity procedures and practices at defined intervals, confirming that they are sufficient to control the related risks.

·          After each update, communicate any changes or additions to entity procedures and practices to the affected BP employees and contractors.

 

MANAGEMENT OF CHANGE

BP entities employ a formal, systematic process to document, evaluate, approve and communicate temporary and permanent changes that could impact safe, responsible and reliable operating activity.

 

Requirements:

·          Implement and maintain a Management of Change (MoC) process for temporary and permanent changes.

o    Adopt eMOC when migrating the local business to an electronic MoC system.

·          Monitor legal and regulatory requirements and BP Requirements so as to be aware of changes in these that might necessitate changes to the entity operating activity.

·          Specify criteria for determining which proposed changes to entity operating activity require application of the MoC process, paying particular attention to those affecting plant, material, equipment, technology, process, products, services, procedures, practices, people and organization.

o    Define criteria for determining the applicable MoC type (i.e. technical, organizational or administrative).

 

·          Include in the MoC process: risk assessment, identification and application of risk reduction measures; the required level of management approval; application of a review prior to implementing the change to verify that identified risk reduction measures are in place and identified training completed; and updating of relevant documents.

·          Communicate the details of the proposed change to affected members of the workforce.

·          Track MoC actions to closure.

·          Verify that the original scope and duration of temporary changes are not exceeded without review and approval.

 

INFORMATION MANAGEMENT AND DOCUMENT CONTROL

BP entities develop, review and maintain secure and readily available the necessary and appropriate information, documents and records.

 

Requirements:

·          Define and implement an information management and document control process to control the approval, publication, transmission, storage, change, retention and disposal of controlled documents.

o    Identify document owners for controlled documents.

·          Specify the types of information, documents and records that are to be controlled documents, and maintain formal registers of these controlled documents.

o    As a minimum, include the following as controlled documents:

§   Local OMS

§   Drawings

§   Policies

§   Internal standards

§   Procedures and practices (i.e. operating and maintenance procedures)

§   Regulatory compliance records

§   Design data

§   Training records

·          Provide ready and secure access to controlled documents, removing obsolete information and documentation from circulation.

·          Maintain and retain BP employee health and medical records as medical confidential and occupational exposure records as confidential.

 

INCIDENT MANAGEMENT

BP entities report and investigate incidents; determine immediate and system causes and implement appropriate corrective actions; and share the learnings to reduce the likelihood of recurrence and improve operating performance.

 

Requirements:

·          Develop and maintain an incident response capability.

·          Report and investigate incidents to establish immediate and system causes. Identify action plans to address identified causes with due dates for completion and track to completion.

o    Implement systems, processes and procedures to report, investigate, and analyze HSSE incidents, non-conformances to BP requirements and regulatory non-compliances, based on risks faced by the local business.

o    Use the E&P Segment incident reporting tool (Tr@ction) to record incidents.

 

o    Investigate HSE incidents and non-conformances per Table 4.4.2.3, using the more severe of the actual and potential outcome classifications.

·          Analyze collective results of incident investigations at defined intervals to identify trends in immediate and system causes. Develop action plans to address identified trends with due dates for completion and track to completion.

 

CONTROL OF WORK

BP entities employ a formal Control of Work process to provide a work environment that will allow tasks to be completed safely and without unplanned loss of containment causing environmental damage.

 

Requirements:

·          Implement and maintain a process to plan work, identify hazards, assess risk and put in place risk reduction measures to allow work tasks to be completed safely and without unplanned loss of containment causing environmental damage.

o    Define types of hazardous work that require a work permit.

o    Document and communicate the roles, responsibilities and accountabilities within the permit to work (PTW) system, including any that are specific to hazardous work.

§   Assign roles and responsibilities as set out in Table 4.5.1.2.

§   Check that individuals assuming the roles know their responsibilities.

§   Assign the roles of Performing Authority and Issuing Authority (or other roles responsible for issuing the permit) to different individuals for any given permit.

§   Define criteria and circumstances under which individuals can perform multiple roles without compromising the integrity of the PTW system.

§   Identify and document those roles in the PTW system that are exclusive to BP employees.

o    Execute the PTW process described in the requirements listed in Table 4.5.1.3.

 

CRISIS AND CONTINUITY MANAGEMENT AND EMERGENCY RESPONSE

BP entities prepare for and respond promptly to crisis and emergency events threatening harm to BP employees and contractors, company assets, and neighboring communities and interruption in business operations.

 

Requirements:

·          Identify crisis and continuity management scenarios utilizing the entity risk register, the output of the entity’s Major Accident Risk assessment and other information.

·          Implement and maintain crisis and continuity management plans to manage the scenarios identified. These will include procedures from initiation to response and recovery. At site level these plans shall include arrangements for evacuation and, where needed, for initial shelter-in-place.

 

·          Validate the plans through exercising them at defined intervals. Review the plans at least annually to reflect changes in hazards, risks, organization or contact details, and implement identified improvements.

·          Provide access to trained personnel, resources, medical emergency and other facilities needed to implement and execute the crisis and continuity management plans.

·          Implement, maintain and exercise a documented process for accounting for personnel during and after an emergency evacuation.

 

5. ASSETS

Our plants, facilities, assets and floating systems are fit for purpose throughout the lifecycle of the operation.

 

PROJECT MANAGEMENT

BP entities manage projects for design and construction of new or modified plant, facilities, assets and floating structures to prevent injury to people, damage to the environment and achieve competitive performance over the lifecycle.

 

Requirements:

·          Implement and maintain a documented system for managing projects which provides for five stages of project development (Appraise, Select, Define, Execute and Operate) with approval at each stage gate by an identified gatekeeper.

·          Identify legal and regulatory and BP Requirements applicable to the design, procurement, construction, commissioning, startup and handover of the project facilities.

·          Document the project objectives in a statement of requirements and have them agreed by the identified gatekeeper.

·          Develop and implement a documented project execution plan which covers concept selection through to handover.

·          Implement and maintain a comprehensive Quality Assurance/Quality Control process for project design, procurement, construction, commissioning, startup and handover.

·          Integrate operations, maintenance, HSSE and, where applicable, marine expertise during concept selection, definition of engineering scope, and design, construction, commissioning and handover of facilities.

·          Identify and assess the risks associated with the project interfaces to existing operations and implement plans to manage the identified risks.

·          Conduct documented HSSE reviews, pre-startup safety reviews and operational readiness reviews for projects, including projects on existing facilities, and close-out agreed actions.

·          Conduct documented post-project reviews to identify lessons for future projects.

 

DESIGN AND CONSTRUCTION

BP entities design, construct, modify plant, assets, facilities and floating structures to prevent injury to people, damage to the environment and achieve competitive performance over the lifecycle.

 

Requirements:

·          Establish the basis of design following BP Requirements and considering new technology, business requirements, performance improvement, normal and abnormal operating conditions, startup, shutdown, ramp-up, turndown and decommissioning.

·          Design plant, assets, facilities and floating structures (including engineered systems, marine systems, structures and protective systems) in accordance with inherently safer design principles and BP Requirements.

·          Procure and construct plant, assets, facilities and floating structures in accordance with the design.

·          Develop and maintain a Marine Assurance Plan, to encompass the specification, design, construction and commissioning of the marine structure and systems of all floating production and storage units, in conjunction with BP Shipping and the Segment Marine Authority.

·          Delegate the supervision of the specification, design, construction and commissioning of all Marine Vessels to BP Shipping.

·          Manage and control deviations from design standards, entity practices and procedures through a deviation process. Manage subsequent changes through the MoC process.

·          Identify safety and production critical equipment and systems. Define and set safe operating envelopes, alarm parameters and required levels of inspection and maintenance.

·          Develop and implement a commissioning, startup, handover and operating plan including a post startup review to confirm that construction is in accordance with design, all required verification testing is complete and all deviation and MoC actions are complete.

o    Develop full lifecycle asset integrity strategies and supporting implementation plans in conformance with ETPs as appropriate, and hand over to Operations on completion of projects and drilling programs.

 

ASSET OPERATION

BP entities operate plant, assets, facilities, floating structures and transport equipment to prevent injury to people, damage to the environment and achieve competitive performance over the lifecycle.

 

Requirements:

·          Operate plant, assets, facilities, floating structures and transport equipment within defined safe operating envelopes, in accordance with documented operating procedures and taking due account of manufacturers’ recommendations.

o    Define safe operating limits (SOL) and operating envelope for equipment covered by operating procedures or inspection plans.

§   Identify critical operating parameters (e.g. pressure, temperature, flow, level, vibration) that, if exceeded, may compromise equipment integrity (see Figure 5.3.1.1).

§   Specify upper and lower limits within which the equipment/process/system can operate safely.

 

 

 

o    Establish accountabilities for defining and updating equipment safe operating limits, including but not limited to the following:
Table 5.3.1.2 Roles and Accountabilities for defining and maintaining equipment Safe Operating Limits

·          Monitor, investigate and document excursions outside safe operating envelopes and unexpected failures of structures, materials and equipment. Identify and implement corrective actions.

·          At defined intervals, review safety and production critical equipment and upgrade them as necessary to continue to achieve safe, responsible and reliable operation and competitive performance.

·          Verify both the adequacy and accuracy of production metering instrumentation at defined intervals.

·          Measure, report and investigate performance shortfall, and develop a prioritized plan to reduce such shortfall and address identified immediate and system causes.

 

INSPECTION AND MAINTENANCE

BP entities inspect and maintain plant, assets, facilities, floating structures and transport equipment to prevent injury to people, damage to the environment and achieve competitive performance over the lifecycle.

 

Requirements:

·          Develop and implement an inspection, maintenance and turnaround strategy to manage identified risks and deliver availability in line with the entity business strategy. Include inspection, maintenance and turnaround actions in the annual plan.

o    Implement a risk-based inspection, maintenance and reliability management system with tools developed and outputs documented.

o    Apply the Capital Value Process for Turnarounds (CVP-TAR) for full facility outages and for major TAR.

·          Implement and maintain an inspection program to determine the condition of safety and production critical equipment and systems, and verify and document they are fit for service. Verify that deficiencies identified from the inspection program are investigated and corrected on a timely basis.

o    Track critical equipment failures and apply appropriate defect elimination techniques.

·          Implement and maintain a maintenance management system to plan, schedule, resource and record the results of inspection and maintenance work. Maintain engineering data and related process safety information for equipment requiring inspection.

o    Adopt Maximo when upgrading the local business electronic work management system.

·          Evaluate inspection program results and maintenance regimes, and modify the programs to take account of the risk of equipment and system failure.

o    Assess, evaluate and utilize inspection and condition monitoring data when making risk-based decisions on scope of equipment repair and program optimization.

·          Implement and maintain a process to verify that equipment replacement or modification maintains operating integrity.

 

 

 

 

·          Verify equipment that has been out of service is fit for service prior to use.

o    Develop and utilize quality assurance/quality control processes, performance acceptance criteria and/or certified testing prior to putting equipment back into service after repair.

o    Confirm that operating parameters of equipment returned to service remain valid.

DECOMMISSIONING AND REMEDIATION

BP entities plan for and manage the decommissioning or abandonment of plant, asset, facilities and floating structures and the remediation of the resulting HSSE impacts and risk.

 

Requirements:

·          Identify and consider decommissioning and remediation needs during project concept selection and design approval, updating them as needed over the lifecycle of the asset.

o    Incorporate regulatory and BP requirements for local businesses pertaining to decommissioning and remediation activities.

§   Include the requirements for addressing soil and groundwater contamination and waste.

·          Develop a risk-based plan prior to decommissioning, long-term shutdown, demolition or remediation and implement when required.

·          Identify and manage HSSE impacts of decommissioning and remediation on existing operations, neighbors and the local community.

 

MARINE OPERATIONS

All marine activity in the BP Group is carried out in such a way as to prevent injury to people, damage to the environment and to achieve competitive performance over the lifecycle of the asset.

 

Requirements:

·          Recognize BP Shipping’s sole accountability for marine activity related to the transportation of cargo by bulk, with particular reference to the execution of the chartering, purchasing, leasing, selling and recycling of cargo carrying marine vessels and the provision of manning and technical management, voyage operation (including non-customer-facing scheduling), and vetting services for all cargo carrying marine vessels.

·          Procure, charter, select, contract, operate and maintain marine vessels used in exploration, development and production to a defined standard.

·          Conduct the scheduling of customer-facing hydrocarbon transportation to a defined standard.

·          Operate and maintain Marine Terminals to a defined standard. Implement and maintain procedures that specify the requirements of a ship/shore interface.

·          Require that any marine vessel contracted for use by the BP entity meets a defined standard, fit for purpose and is vetted and approved by a defined process.

·          Produce an annual marine report on the scale of marine activity within the entity identifying associated marine risks.

 

 

6. OPTIMIZATION

Our operations are continuously optimized to improve performance and delivery from our assets.

 

PLANT OPTIMIZATION

BP entities identify, evaluate and capture opportunities to improve operating unit performance.

 

Requirements:

·          Identify and evaluate operating improvements and put prioritized plans in place to implement them.

·          Analyze production variances and put prioritized plans in place to reduce them.

·          Monitor the impact of changes to feedstocks and operating conditions on maintenance and inspection activities.

 

ENERGY

BP entities employ energy strategies to improve energy usage.

 

Requirements:

·          Include energy usage in the entity business strategy and annual plan.

·          Assess, prioritize and implement technologies and other systems for improving energy usage.

 

FEEDSTOCK AND PRODUCT SCHEDULING AND INVENTORY

BP entities manage feedstock inventories and schedule operations to meet production requirements that satisfy business and customer needs.

 

Requirements:

·          Develop and implement a logistics, inventory and production scheduling process to meet business needs.

·          Review the effectiveness of this scheduling process at defined intervals and implement identified improvements.

 

QUALITY ASSURANCE

BP entities assure the quality of their materials, operating activities, products and services.

 

Requirements:

·          Establish feedstock, intermediates and product specifications based on customer and business needs and operational considerations.

·          Implement and maintain quality assurance programs to assure BP, contractor or supplier activities that are material to operating performance.

·          Monitor that products sold by BP meet product specifications. Respond to variances, identify immediate and system causes and take corrective action.

 

TECHNOLOGY

BP entities identify and implement technology to improve operating performance.

 

Requirements:

·          Identify opportunities for application of new or existing technologies consistent with the business entity strategy.

·          Evaluate, select and apply preferred technologies.

 

 

 

 

 

 

 

PROCUREMENT

BP entities purchase feedstocks, materials and services to meet specifications, standards, delivery, and operating requirements which address lifecycle cost.

 

Requirements:

·          Implement and maintain a procurement process for materials and services that defines specifications and standards; establishes a supplier selection process based on criteria that include HSSE considerations; meets delivery requirements; considers lifecycle cost; and provides clear procedures for changes to suppliers, materials and services.

·          Review the effectiveness of the procurement process at defined intervals and implement identified improvements.

 

MATERIALS MANAGEMENT

BP entities manage materials to provide the required quality and availability to deliver operating performance.

 

Requirements:

·          Identify and maintain the material inventories required to deliver operating performance.

·          For stored materials, implement and maintain a system to identify, inspect and protect them from deterioration, paying particular attention to those that form part of safety and production critical equipment.

·          Review materials management performance at defined intervals and implement identified improvements.

 

CONTINUOUS IMPROVEMENT

BP entities develop a culture in the workforce to improve operating performance through defect identification, measurement and elimination.

 

Requirements:

·          Engage the workforce to build continuous improvement (CI) culture and behaviors.

·          Systematically identify defects in the plant, process, people and performance elements of the entity’s operating activity and implement improvements utilizing continuous improvement methodologies and tools.

o    Identify gaps and build plans to act on specific opportunities for eliminating defects in the local business in a systematic manner.

o    Include resources for local CI activities in the annual business plan, including process evaluation and standardization, implementation of lessons learned/best practices, and capability development.

·          Implement and maintain a process to capture learnings and sustain performance improvements in the local OMS.

 

 

 

 

 

 

 

 

 

 

 

7. PRIVILEDGE TO OPERATE
We deliver what is promised and address issues raised by our key stakeholders.

 

REGULATORY COMPLIANCE

BP entities comply with applicable legal and regulatory requirements.

 

Requirements:

·          Identify applicable legal and regulatory HSSE requirements, determining how these apply to the entity’s projects, operations, maintenance, inspection, marine, decommissioning and remediation activities, and products and services.

o    Develop and maintain a compliance matrix of HSSE regulatory and other legal HSSE requirements applicable to the local business.

§   List obligations for HSSE permits and authorizations associated with the local business.

§   Assign specific accountability for the development and management of the local HSSE compliance matrix.

§   Make the HSSE compliance matrix readily available across the organization.

·          Put a process in place to identify and where necessary implement an MoC for changes to applicable legal and regulatory HSSE requirements.

·          Identify and document specific compliance tasks to meet applicable legal and regulatory HSSE requirements.

·          Establish and implement operational controls needed to accomplish the identified compliance tasks to meet applicable legal and regulatory HSSE requirements.

·          Assign and document accountabilities for the identified compliance tasks to meet applicable legal and regulatory HSSE requirements, and communicate these to the accountable individuals.

·          Verify completion of the identified compliance tasks to meet applicable legal and regulatory HSSE requirements, report and investigate instances of non-compliance and take action to prevent recurrence.

·          Implement and maintain a program for verifying compliance with other (non-HSSE) legal and regulatory requirements.

·          Communicate to the workforce the existence and importance of these compliance programs.

 

COMMUNITY AND STAKEHOLDER RELATIONSHIPS

BP entities act to enhance their reputation with key stakeholders as a neighbor, partner, employer and investment of choice, and engage key stakeholders on the issues that affect them.

 

Requirements:

·          Identify key communities and stakeholders involved in or affected by its operating activities and designate accountabilities for managing the relationships with them.

·          Build relationships with identified key communities and stakeholders through early engagement, listening and responding to their expectations and concerns about its operations, projects and products.

·          Record external commitments made by the entity to the identified key communities and stakeholders and take action with respect to these commitments.

·          Establish and implement a process to receive communications from key communities and stakeholders and document responses.

·          Identify and manage the environmental, health and social impacts of changes to operating activities on key communities and stakeholders.

 

SOCIAL RESPONSIBILITY

BP entities deliver responsible operations conforming to BP Requirements and seek to have a positive influence on the communities in which they operate.

 

Requirement:

·          Identify whether there are social responsibility issues associated with their operating activities, and manage the associated impacts.

 

CUSTOMER FOCUS

BP entities develop and maintain transparent, sustainable BP customer relationships.

 

Requirements:

·          Manage BP customer relationships consistent with the entity business strategy and annual plan.

·          Implement and maintain a process to make relevant members of the workforce aware of the importance of maintaining BP customer relationships.

·          Implement and maintain a process to receive and respond to BP customer feedback on HSSE, service and quality issues.

·          Implement and maintain a process for managing or assuring all BP supervised activities involved in the safe transportation, storage and delivery of products to BP customers.

 

PRODUCT STEWARDSHIP

BP entities manage products throughout their lifecycle to satisfy legal and regulatory requirements and communicate potential HSSE impacts of products.

 

Requirements:

·          Maintain a register of products, and systematically assess them for HSSE hazards and risks and the legal and regulatory HSSE requirements applicable to BP in relation to the products from
development through to end-user for anticipated conditions of storage and use, and reassess when changes occur.

·          Inform the workforce, BP’s customers and other identified stakeholders about the relevant identified HSSE hazards and risks relating to products through the provision of material safety data sheets, warning labels or other communication media.

·          Implement and maintain a process to record, investigate and learn from product related HSSE effects and incidents reported to BP by other parties.

·          Implement and maintain a product recall procedure and emergency response procedure for product-related HSSE effects and incidents reported to BP by other parties. Exercise the procedures at defined intervals.

·          At defined intervals assess, document, and implement opportunities that are consistent with the entity business strategy, to replace chemical constituents or products that may present a significant risk to health or the environment, with chemical constituents or products that may present a lesser risk.

 

 

 

 

8. RESULTS

Measurement is used to understand and sustain performance.

 

METRICS AND REPORTING

BP entities establish metrics to monitor and report delivery of business and operating targets and to promote continuous improvement.

 

Requirements:

·          Use leading and lagging indicators to monitor progress against the objectives and targets in the annual plan.

·          Provide employee access to performance indicator information to support delivery of the annual plan.

·          Report operating performance data in accordance with BP.

 

ASSESSMENT AND AUDIT

BP entities perform assessments and audits of operating performance and management processes to assure compliance with legal and BP Requirements, and drive risk reduction and performance improvement.

 

Requirements:

·          Implement and maintain a risk-based internal self-assessment program to monitor that operating activities are being carried out in accordance with the local OMS; this shall include auditing of procedures and processes to validate they are operating as intended.

o    Include leaders in the monitoring of operating activities through systematic self-verification, and in the follow-up of corrective actions.

o    Define and document the key competencies required for team members participating in self-assessments, according to the type of self-assessment.

·          Plan and prepare for audits by Group S&O as per the S&O audit program.

·          Identify and implement corrective actions with due dates for completion to address the findings of these self-assessments and audits, and track to completion.

·          Assess at defined intervals the results from self-assessments and audits to identify trends, emerging risks, opportunities to improve risk reduction measures and identify local OMS improvement opportunities.

 

PERFORMANCE REVIEW

BP entities use the results of assessments and audits, as well as inputs from other internal learning activities, to periodically review the continued adequacy and appropriateness of the existing local OMS and drive systematic improvements in performance.

 

Requirements:

·          Conduct formal documented Management Reviews at least annually of the local OMS to determine its effectiveness in delivering continuous risk reduction and performance improvement across the Elements of Operating.

·          Implement and maintain a process to revise the local OMS with learnings identified at Management Reviews and in response to updates to Group, Segment and SPU requirements.

·          Track to completion improvement action items resulting from Management Reviews, reporting overdue action items to entity management at defined intervals.

 

 

 

 

BUDGET MANAGEMENT

BP entities operate safely and profitably, planning and managing financial and human resources consistent with the annual plan, and to deliver operating performance.

 

Requirements:

·          Develop the annual budget to provide resources to deliver the activities in the annual plan.

·          Monitor and control costs and record reasons for any variances against the annual budget. Report to the budget approver new or changing risks which may cause significant variances.

 

 

EXHIBIT B – TASK HAZARD CHECKLISTS

 Task Hazard Checklists

 

During a Hazard Identification and Task Risk Assessment (HITRA) process, the identification of hazards is integral to risk reduction surrounding activities.  The identification should include a list of all significant hazards and a review to determine what foreseeable effects they could cause if not eliminated or controlled. To aid in the process, the following checklist provides a listing of type of hazards, the type of harm they could result in, and examples of those hazards.

 

EXHIBIT C- CONTRACT AREA SPECIFIC HSSE STANDARDS

 

The following standards are required due to CONTRACT AREA specific requirements and shall be applied in conjunction with the other HSSE Requirements specified in this Section 6.

 

OMS Reference	Document Type	Document Title
GDP 3.1-0001v1	BP Group Defined Practice	Assessment, Prioritisation and Management of Risk-Ver 1
GDP 4.5-001	BP Group Defined Practice	Control of Work Standard
GDP 5.0-001	BP Group Defined Practice	Integrity Management Standard
GRP 3.7-0002	BP Group Recommended Practice	Driving Safety Standard
STP	BPTT Site Technical Practice	Site Technical Practice - Management of Lifting Operations
NA	BPTT Guidance Manual	Safe Work Practices Manual
TRD 2161	BPTT Practice	HSSE Incident Notification, Reporting, Investigation and Lessons Learned Procedure
	BPTT Policy	Personal protective equipment policy
	BPTT Policy	Protective footwear policy
TTHSSE-36-733	BPTT Policy	Flame Resistant Clothing policy
	BPTT Policy	Fit for Work Policy

 

 

 

 

 

 

 

 

 

 

 

BP TRINIDAD AND TOBAGO POLICIES

TITLE

Exhibit 1 – Contractor Substance Abuse Policy

Exhibit 2 ‑ Smoking Policy

Exhibit 3 ‑ Hearing Conservation Programme

Exhibit 4 ‑ Contractor Identification Policy

Exhibit 5 ‑ Non-Harassment Policy

Exhibit 6 - Fire Resistant Clothing Policy

Exhibit 7 – Policy on PPE during Helicopters Flights Offshore

Exhibit 8 - Young Persons at Work Policy

Exhibit 9 - Employees’ Right to Refuse Work Policy

Exhibit 10 - Driving Safety Standard

 

 

EXHIBIT 1

 

CONTRACTOR SUBSTANCE ABUSE POLICY

 

 

BP Trinidad and Tobago LLC (“COMPANY”) has a strong commitment to provide a safe work place for its employees and other persons working or visiting on its premises.  In order to assist in maintaining a safe working environment and to protect COMPANY property, this policy concerning substance abuse is established.

 

Contractors, who perform services on COMPANY's premises, must have and administer a formal substance abuse policy.  Policies for Contractors and Sub-contractors must include substance testing of Contractors' employees entering COMPANY premises.

 

The failure of a Contractor to comply with the provisions of this policy constitutes cause for termination of contract.

 

SECTION I-POLICY STATEMENT

 

The use, sale, possession, distribution or promotion of Prohibited Substances, as defined later herein, is strictly prohibited on COMPANY's premises, including all property owned, operated, leased by, or under the control of COMPANY.  Additionally,  Contractors' employees shall be in breach of this policy if a Prohibited Substance is determined by testing to be present in their body system at or above the levels set out in this policy at section B.4 of Section II and shall be prohibited from COMPANY's premises.

 

The Manager, Security in consultation with a COMPANY designated physician, reserves the right to make the final determination on any question concerning substances that fall within the meaning of a Prohibited Substance as used in this policy.

 

Contractors shall submit a copy of their policy and program to the Manager, Security.  Such policy must provide for Substance Testing, as defined herein, of employees and must meet the minimum standards as set forth in Section II below.  COMPANY's Management reserves the right to withhold solicitation of bids or to deny entry to COMPANY's premises of any Contractor who fails to present a written policy that meets COMPANY's minimum standards, or who fails to administer an acceptable policy.

 

A violation of this policy will subject the offending Contractor's employee to denial of entry to COMPANY's premises and projects.  Reinstatement of the access privilege may be made only after a  minimum of ninety (90) days after starting a chemical dependency program at a recognised institution and upon request of the employing Contractor.  A request may be granted only upon receipt of a certificate in the from of Appendix I Form 1 certifying that the Contractor’s employee has begun a chemical dependency programme and has started the out-patient portion of the programme since testing positive and has successfully passed a substance screen within 30 days of the request.  The above mentioned certificate must be issued by a rehabilitation centre which meets all of the minimum standards listed in Section II B 8 of this policy.

 

SECTION II - TESTING

 

A.   DEFINITIONS

 

For the purpose of this policy:

 

1.   "Substance Testing" means the analysis of urine and blood specimens for the presence of Prohibited Substances.  However, at times circumstances may warrant additional testing methods.

 

2.   "Contractor" includes Subcontractor, Independent Contractor and Vendor

 

3.   "Chain of Custody" means that combination of procedures and documentation which provides a faithful and accurate written record of the process of chain of custody transfer of a biological specimen from the time of initial collection of a specimen up to the time of final testing.

 

4.   "Witnessed Collection" means the collection of a specimen which is voided in the presence of another person whose positioning is discreet but sufficiently present to minimize attempts at substitution or contamination of that specimen.

 

5.   "Negative test result" means a laboratory conclusion that the presence of a substance was not detected in a specimen at or above the levels set out in Section B.4 of this Section II.

 

6.   "Presumptive Positive Result" means a laboratory conclusion that a specimen was found to contain the presence of a substance based on one or more analytical procedures which did not include gas chromatography/mass spectrometry (GC/MS).

 

7.   "Confirmed Positive Result" means a laboratory conclusion that a specimen was found to contain the presence of a substance based on two or more analytical procedures which did include gas chromatography/mass spectrometry (GC/MS).

 

8.   "Prohibited Substance" or "Prohibited Substances" means (a) any alcoholic beverage (b) any substance which an individual may not sell, possess, use, or distribute under the laws of the Republic of Trinidad and Tobago (c) any other legal, but unlawfully used substance.

B.   LABORATORY SPECIMEN COLLECTION AND REHABILITATION CENTRE/INSTITUTION STANDARDS

 

The following laboratory standards apply:

 

1.      Contractors shall take all necessary precautions, up to and including Witnessed Collection of the specimen, to ensure that substitutes or contaminated specimens are not submitted for testing.

 

2.      Contractors must use a laboratory which is capable of carrying out the substance tests in a consistent and professional manner.

 

3.      Chain of Custody procedures must be strictly adhered to.

 

4.      Contractors should establish confirmation levels no greater than those specified below.

 

DRUG	EMIT Screen	GC/MS Confirmation Levels
Amphetamines	1000 mg	500 mg
Marijuana	50 mg	15 mg
Cocaine	300 mg	500 mg
Opiates	300 mg	300 mg
Phencyclidine	25 mg	25 mg
Alcohol	.02 BAC	.02 BAC

 

5.      The specimens of applicants and current employees will be tested using an enzyme immunoassay (such as EMIT) and/or a radio immunoassay.  In this form of testing, a positive finding is called a Presumptive Positive Result.  All Presumptive Positives Results will be further tested using GC/MS.  In this  form of testing, a positive finding is called a Confirmed Positive Result.

 

6.      A blood alcohol test is considered positive (for the purpose of the policy) if the alcohol level is confirmed to be at or above .02% by volume.  This test must be run by a laboratory qualified to perform blood analysis work.

 

7.   A list of suggested laboratories, licensed physicians and rehabilitation centers which may be used for the collection and testing of specimens and the treatment and rehabilitation of Contractor Employees (who test positive) is contained in Appendix II of this policy.  COMPANY assumes no responsibility or liability for the ultimate choice of laboratory or physician and it shall be the sole obligation of the Contractor to ensure that the physician or laboratory utilized meets the standards and requirements of this policy.

 

8.   The following are the minimum standards which must be met by the Certifying Rehabilitation Centre/Institution:

 

1.   All counselors used in the program have been certified and have a minimum of 2 years clinical supervision in chemical dependency.

 

2.    The in-patient program has, as a minimum, consisted of daily clinical group therapy session to include video/lectures/discussions.

 

3.    Family education, separate and apart from the patient’s has been provided.

 

4.    The out-patient portion of the program will provide for a period no less than 6 weeks of weekly assessment and evaluation.

 

5.    The out-patient portion of the program will have a long-range    component which will provide, for a period of no less than one year, intensive follow-up addressing the patient’s medical, physical, self-esteem and spiritually needs.

 

C.       CONFIDENTIALITY

 

When a Contractor conducts drug testing of its employees for the purpose of establishing eligibility to enter COMPANY's premises, such substance testing results which are positive will not be disclosed to COMPANY.  COMPANY will require, however, that Contractors certify that each employee assigned to work on COMPANY's premises has passed a substance test that meets the standards of this policy.  Contractors must maintain records of Prohibited Substance tests including the names of employees who are tested, the date of the test and the result of the test  which are subject to audit by COMPANY (See Section IV and VI).

 

The results of Prohibited Substance tests performed for cause or accident/incident investigations as outlined below must be disclosed to COMPANY management upon request.

 

D.         TESTING

 

1.      Contractors will conduct Substance Testing in these situations:

 

a)      Before a Contractor's employee enters COMPANY's premises for the first time or where a Contractor's employee is regaining access after an absence in excess of 90 days.  This requirement may be waived by COMPANY's management in appropriate circumstances.

 

b)     A continuously employed contract worker must be tested for Prohibited Substances at least once every 12 months with no more than 24 hours notice prior to testing.  The various other situations that require testing will not satisfy this requirement.

 

c)      Where COMPANY or the Contractor reasonably suspects or has cause to believe that a Contractor employee on COMPANY's premises is under the influence of or has consumed any substance prohibited by this policy or has been charged with or convicted of a drug related offense.

 

d)     When required by COMPANY's management, immediately following any accident or dangerous occurrence including a recordable bodily injury, fatality or damage to COMPANY or Contractor-owned property.

 

2.      COMPANY will recognize a Prohibited Substance test conducted on a Contractor employee while that employee worked for a another Contractor provided that (1) the test was conducted within the 90-day period required by this policy;  (2) the laboratory and sampling procedures meet the standards set forth in this policy.

 

3.      Contractors will assume all costs associated with testing.

 

4.      The refusal of a Contractor's employee to sign a consent form or submit to any testing will result in revocation of that person's access privileges.

E.     EXCEPTIONS

 

  The following exceptions may be granted at the discretion of COMPANY's Management:

 

1.      Contractors and Contractors' employees who are contracted or hired on short notice may be permitted to begin work with the concurrence of the Department Head responsible for the work in, consultation with the Manager Security; pending receipt of the results of pre-access substance testing.  This permission will not extend beyond ten (10) calendar days from the first date after work starts by the Contractor.

 

Any person working under this provision must be removed from the work site immediately upon receipt of a positive test result, or at the end of ten (10) calendar days if test results have not been reported.

 

This provision is to allow work to begin in emergency or short notice situations only.  Testing must be done as soon as reasonably feasible and results must be available within the ten (10) calendar days allotted.  This provision covers only employees needed for initial staffing and does not extend to those hired with sufficient time for pre-access testing.

 

2.      Contractors whose need for site access is infrequent or whose presence poses a minimal safety risk may be exempted by the relevant Department Head in consultation with the Manager, Security from pre-access substance testing.

 

SECTION III - SEARCHES AND INSPECTIONS

 

COMPANY reserves the right at all times to conduct unannounced Substance Tests, searches and inspections of Contractors, Contractors' employees and other persons on its premises.  Searches and inspections may include but are not limited to their personal effects, lockers, baggage, tool boxes, clothing and vehicles.  The purpose of such tests, searches and inspections is to ensure compliance with this policy.

 

Any substances or items prohibited by this policy, or any materials, the possession of which is illegal, which are found during searches and inspections will be confiscated by COMPANY and may be destroyed or turned over to the appropriate law enforcement agency.

 

The refusal of a Contractor's employee to submit to a test, search or inspection will result in the revocation of that person's access privileges.

 

SECTION IV- COMPLIANCE AUDITS

 

COMPANY reserves the right to periodically audit a Contractor's records to the extent necessary to verify compliance with this policy in so far as it relates to Contractor employees deployed in COMPANY's operations.  Such verification will include, but is not limited to:

 

1.      Examination of the Contractor's substance abuse policy and its implementing directives and procedures.

 

2.      A determination that Prohibited Substance testing is being conducted in those situations which require it and that the testing meets the standards of this policy.

 

3.      Examination of Chain of Custody procedures which ensure integrity of collected specimens.

 

4.      Evaluation of laboratory services.

 

Audit results will be treated as confidential so as to protect the privacy of tested persons.

 

 

 

 

SECTION V - SUBCONTRACTORS

 

In all cases where a Contractor is permitted to employ a Subcontractor, the Contractor is responsible for insuring that the Subcontractor and Subcontractor's employees are in compliance with this policy.  Contracts between Contractors and Subcontractors must stipulate that COMPANY reserves the right to audit Subcontractors substance abuse programs.

 

SECTION VI - CONSENT FORMS

 

The Contractor must obtain a signed consent demonstrating each employee's agreement to be tested for substance abuse and to release to Contractor and COMPANY the results of any Substance Tests performed.

 

COMPANY will look at substance test results only during occasional compliance audits as described in Section IV, or when testing is required by COMPANY as described in Section II.

 

SECTION VII - NOTICE

 

The Contractor must ensure that all of its employees and all employees of its Subcontractors are informed of the provisions of COMPANY's Contractor Substance Abuse Policy and of the Contractor's own Substance Abuse Policy.  Notice will include the consequences of failure to comply and such notice should be given prior to entering COMPANY premises.

 

SECTION VIII - CONCLUSION

 

Consideration for work on COMPANY's premises will be conditioned upon implementation by the Contractor of a policy that, in COMPANY's sole judgment, conforms to the minimum standards expressed in this policy. Program development and implementation are the responsibility of the Contractor.  The central goal of this policy is to provide a safe and efficient working environment for all persons on COMPANY's premises.  Cooperation is vitally important to the achievement of this important goal.

Appendix I

FORM 1

 

Notice of Certification to BP Trinidad and Tobago LLC

 

Pursuant to a request by    (Insert the name of the Contractor)    and    (Insert Name of Patient)    this is to certify that    (Insert Full Name of Patient)    has begun a chemical dependency rehabilitation programme at    (Insert Full Name of Institution)   ,     (Insert Address of Institution)   .  The in-patient portion of the programme began on    (Insert the Date)    and the patient was referred for out-patient care beginning    (Insert Date)   .

 

________________________                                          _________________________

                        Name                                                                            Signature

 

________________________                                          _________________________

                        Title                                                                              Date

Please note that by signing this certificate you represent to BP Trinidad and Tobago LLC that your chemical dependency programme meets all of the below listed minimum standards :

1.   All counselors used in the programme have been certified and have a minimum of 2 years clinical supervision in chemical dependency.

2.   The in-patient programme has, as a minimum, consisted of daily clinical group therapy session to include video/lectures/discussions.

3.   Family education, separate and apart from the patient’s, has been provided.

4.   The out-patient portion of the programme will provide for a period of no less than 6 weeks of weekly assessment and evaluation.

5.   The out-patient portion of the programme will have a long-range component which will provide, for a period of no less than one year, intensive follow-up addressing the patient’s medical, physical, self-esteem and spiritually needs.

Please note any  standard which your  programme does not meet on this form.

BP Trinidad and Tobago LLC reserves the right to reject or accept this certificate.

 

 

Appendix II

 

List of Rehabilitation Centers  Recommended

 

 

New Life Ministries                                            Mount St Benedict.

                                                                        St. John's Road,

                                                                        Tunapuna.

                                                                        662 0707,  662 1797

 

Heal Centre                                                       Rienzi Complex,

                                                                        Couva.

 

Re Birth House                                                  Apt # 005, Charford Court, 

                                                                        Charlotte Street, Port of Spain.

                                                                        623 0952 / 623 4872  ( George "Tambi" Maximin )

 

Re Birth House                                                  # 29 Dundonald Street,

                                                                        Port of Spain.

                                                                        627 8894

 

Re Birth House                                                  Chaguaramas.

                                                                        627 8894

                                                                        623 0952 / 623 4872

 

Re Birth House                                                  School Street,

                                                                        Carenage.

                                                                        627 8894

                                                                        623 0952 / 623 4872

 

Re Birth House                                                  Sanora Park,

                                                                        Carenage.

                                                                        627 8894

                                                                        623 0952 / 623 4872

 

Caura Rehab Center                                           Caura Hospital,

                                                                        Caura.

                                                                        662 2211

 

San Fernando General Hospital                          Ward 2.

                                                                        San Fernando General Hospital.

                                                                        652 3581/6       

 

Faith Revival Ministries                                      P.O. Box 189,

                                                                                    Port of Spain.

                                                                                    645 2845  ( Pastor Eric St Cyr )

 

Friends Forever,  La Brea                                   c/o S. D. A.  Church,                      

                                                                        Point  Sable,

                                                                        Pt. D'or,

                                                                        La Brea.

                                                                        648 7383   ( Pastor Reynold Thomas )

Marabella Friends Forever                                  c/o S. D. A.  Church,

                                                                        Amar Singh Street,

                                                                        Marabella.

                                                                        658 4504 / 679 3147  ( Terrence Boissiere )

 

AIRI - B Nursing Home                                       Hubert Street

(Private and under                                             St Clair

  Pro. Beaubrun's care)                                      Port of Spain

                                                                        622 6453

 

Suggested list of laboratories

 

 

Vic - Lab Ltd.                                                    9 - 13 Archibald Street,

                                                                        Vistabella,

                                                                        San Fernando.

                                                                        652 4583 / 652 4579

 

Vic - Lab Ltd.                                                    # 64 Pembroke Street,

                                                                        Port of Spain.

                                                                        625 8493

 

Forensic Science Centre                                    Barbados Road,

                                                                        Federation Park,

                                                                        Port of Spain.

                                                                        622 2167  /  622 1011  /  6224170

 

St. Augustine Medical Lab. Ltd.                         MIK - ARL Building,

            (Dr. Bal Ramsaran)                                #143 Eastern Main Road,

                                                                        St. Agustine.

                                                                        663 2387

 

Arima Medical Lab.                                            Behind Bhagan's Drug Store,

                                                                        # 48C Broadway,

                                                                        Arima.

                                                                        667 3907

 

San Fernando Medical Lab.                               # 10A Chancery Lane,

                                                                        San Fernando.

                                                                        657 5251

 

St. Clair Medical Centre Lab.                              St. Clair,

                                                                        Port of Spain.

                                                                        628 1451/2

 

Spectrum Diagnostic Laboratories                     #44 Eastern Main Road.

            (Caribbean) Ltd.                                    St. Augustine.

                                                                        663 2621

 

Sangre Grande Medical Laboratory                    Super Care Building,

                                                                        #8 Eastern Main Road,

                                                                        Sangre Grande.                        

                                                                        668 0960

O'Neal Laboratory                                             Devenish Street,

                                                                        Arima.

                                                                        667 2371

 

Southern Medical Clinic Laboratory                    Southern Medical Clinic,

                                                                        # 26 - 34 Quenca & St. Vincent Streets,  

                                                                        San Fernando.

                                                                        652 2078  /  652 2064

EXHIBIT 2

 

SMOKING POLICY

 

Notice re: Tobacco Control Act

 

• The Minister of Health has advised that the Tobacco Control Act will come into force on Ash Wednesday (17^th February 2010)
• This law makes it an offence, punishable by a fine of TT$ 10,000 and imprisonment for 6 months, to smoke in any enclosed public place, enclosed workplace or public conveyance.
• The law prohibits smoking in the following areas:

 

(a)        public transportation terminals               (b)        workplaces

(c)        retail establishments including bars,      

            Restaurants and shopping malls                        (d)        clubs,

(e)        Cinemas                                               (f)         concert halls

(g)        sport facilities                                       (h)        pool and bingo halls

(i)         publicly owned facilities                         (j)         any other facilities that are                     rented out for events                                                accessible to the public

 

• Smoking is no longer allowed on offshore platforms (including smoke rooms), under the roof on the steps outside QPP Plaza and Beachfield or in company vehicles (pool vehicles or MVP vehicles used for BPTT business.
• Smoking will be allowed on the open air (outside) balconies at QPP Plaza and Albion Plaza and in the open air outside the Isthmus Court Compound, the Beachfield Compound, QPP Plaza and Albion Plaza.

 

 

EXHIBIT 3

 

HEARING CONSERVATION PROGRAMME

 

 

BP Trinidad and Tobago LLC’s (“COMPANY”) Hearing Conservation Programme is aimed at protecting all personnel who work for or at COMPANY’s premises from exposure to high levels of occupational noise.

 

COMPANY has had an ongoing programme geared towards sensitizing all personnel, whether employees or Contractors personnel, to the areas of its operations considered to be high level noise areas and to the need for and use of appropriate hearing protection.

 

COMPANY requires of Contractor and its employees the same adherence to COMPANY's guidelines and policy relating to the wearing of hearing protective devices as it does of its employees.  In this regard COMPANY has indicated by the use of warning signs and the like on all of its property and facilities the areas where it is mandatory that appropriate hearing protection be used.   In addition COMPANY recommends that its Contractors consider expanding their programmes to include audiometric testing and evaluation of their employees.  Should you wish to discuss any aspect of BP Trinidad and Tobago LLC's Hearing Conservation Programme, you may do so with our Safety Department at Galeota Point.

 

We expect you to inform your employees of our guidelines listed below as they apply to them and further expect each Contractor's full co-operation in enforcing those guidelines.

 

1.   Contractor must protect its employees from occupational noise exposure.

 

2.   Contractor's employees who enter areas where levels are 85 DBA or greater must wear prescribed hearing protection regardless of the length of time spent there.

 

3.   Contractor's employees must also wear prescribed hearing protection when working on a job activity that   requires exposure to suspected elevated noise levels which have not been measured and the job is not a recurring one (temporary use of the air hammer, explosive guns, generator tests, etc.).

 

4.   The adequacy of hearing protectors must be re-evaluated whenever employee exposure increases to the extent that the hearing protectors provided may no longer provide adequate attenuation.

 

5.   Contractor's employees may be given the option of utilizing hearing protectors that are most comfortable as long as the adequacy of attenuation is not compromised.

 

6.   All areas that require hearing protection to be worn by employees shall have a sign stating CAUTION - HIGH - NOISE - AREA HEARING PROTECTION REQUIRED.   Contractor is required to familiarize itself with these areas.

EXHIBIT 4

 

Article  .1.1.1.A.1.1          CONTRACTOR IDENTIFICATION POLICY

 

 

BP Trinidad and Tobago LLC ("COMPANY") requires all contractors to provide the Safety and Security Superintendent at COMPANY Galeota Point office with a listing, on a weekly basis, of all its personnel working for COMPANY who may enter COMPANY’s premises.  This list is to be provided not later than 3.00 p.m. on the first working day of the week.  Any changes to the listing during the course of the week should be brought to the attention of COMPANY in writing as soon as practicable after the change is made.

 

COMPANY will implement a procedure whereby all contractor personnel will be photographed and provided with special identification cards in order to strengthen its security and ensure the safety of those who work on its premises onshore and offshore.  You will be notified of this procedure in due course.

 

EXHIBIT 5

 

NON-HARASSMENT POLICY

 

BP Trinidad and Tobago LLC (“COMPANY”) has a strong commitment to provide a working environment for all employees that is free of harassment of any kind.  Consistent with this objective, a Non-Harassment Policy has been formalized.  It is against COMPANY policy for any of our employees, and non-employees on COMPANY 's premises, to harass any COMPANY’s employee or non-employee on the basis of race, creed, sex, sexual orientation or disability.

 

Personnel at all levels of the COMPANY have the responsibility to avoid any act or actions, implied or explicit, that may suggest harassment in any form.

 

Sexual harassment by employees and non-employees is also prohibited.  Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature and will be considered harassment when:

 

A.         Submission to such conduct is made either explicitly or implicitly a term of condition of an individual's employment.

 

 B.        Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual, or

 

C.         Such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile, or offensive working environment.

 

COMPANY is committed to a work environment free of harassment and will strictly enforce these guidelines.   Harassing conduct will result in disciplinary action up to and including discharge and/or other appropriate action.   Any person who believes that harassment has occurred should immediately notify his/her supervisor or the appropriate Human Resources personnel.  Any supervisor or manager who receives a complaint alleging harassment must follow the established complaint procedure.

 

 

 

 

 

 

 

EXHIBIT 6

 

Fire Resistant Clothing Programme

 

 

In accordance with BP Trinidad and Tobago LLC’s (“COMPANY”) Standard of Care, all personnel working at COMPANY controlled sites who have foreseeable exposure to flashburn injuries due to the characteristics of their working environment, are required to wear Fire Resistant Clothing.

 

All contractors are expected to comply with the requirements, as outlined below.

 

Please note that these requirements fall within the minimum requirements and expectations referred to in Exhibit 2 (Contractor Safety, Health and Environmental Policy) to the Agreement between our respective companies.

 

PERFORMANCE REQUIREMENTS

 

Objective:

The objective of these performance requirements is to provide an added degree of protection to personnel working at COMPANY controlled sites who have foreseeable exposure to flash burn injuries due to the characteristics of their working environment by requiring the proper wearing of fire resistant clothing/coveralls.

 

NOTE:  COMPANY controlled sites are Galeota Point area, as well as all offshore platforms and rigs.

 

Scope:

These performance requirements apply to all personnel, including contractors working at COMPANY controlled sites.

 

It is recognized that full, orderly implementation may require that this be accomplished in phases.  In such cases, first priority for implementation of these performance requirements should be given to formulation, start-up, and debugging of fire resistant clothing programmes for COMPANY employees with foreseeable exposure.

 

Standard Type:

These Fire Resistant Clothing (FRC) Programme performance requirements shall be performance requirements for all COMPANY controlled sites.  In addition, the attached HSE Practice No. 1 - PPE is provided to describe the standard of FRC required. 

 

Programme Elements:

Every COMPANY work location shall adhere to the following minimum performance requirements:

 

Each operating section/department shall review its operations and identify all jobs and/or areas with foreseeable exposure to flash burn injuries due to the characteristics of the work environment.  Factors to consider in making such evaluations include, but are not limited to, the following:

 

1.  Characteristics of material if released from containment.

2.  Area affected by such release.

3.  Likelihood of personnel exposure if such release occurs.

Personnel who perform jobs or enter areas with foreseeable exposure to flash burn injuries shall be required to wear fire resistant clothing which provides full body protection.  Full body protection is defined as coveralls, with sleeves extending to cover the wrists and trouser legs extending to cover the ankles.

 

Note: This applies to visitors as well.

 

At a minimum, fire resistant clothing shall be of a standard described in HSE Practice No. 1. Where other hazard exists, such as corrosive or toxic materials, appropriate personal protective equipment should be worn over the fire resistant clothing/coveralls.

 

Proper Wearing:

Personnel shall be required to wear fire resistant clothing/coveralls properly, i.e. with the sleeves rolled down and fastened at the wrist; with the front closure buttoned, snapped or zipped to the throat.  Legs must be kept rolled down to the ankle.

 

Fire resistant clothing/coveralls shall not be modified by the addition of decals or other decorations that could degrade the fire resistant characteristics of the clothing or by cutting off sleeves or legs or cutting additional opening other than those provided by the manufacturer of the clothing/coveralls.

 

Maintenance:

Fire resistant clothing/coveralls shall be kept in good repair, reasonably clean, and free of flammable or combustible materials that could degrade the fire resistant characteristics of the clothing/coveralls.

 

Training:

Personnel shall be educated regarding the capabilities and limitations of any fire resistant clothing that they are required to wear.  In addition, personnel should be made aware that their normal, non-fire resistant clothing can possibly increase the extent of burn injuries due to the tendency of many fabrics to continue to burn after the source of heat is removed and/or to melt and adhere to the skin.

 

Areas requiring Fire Resistant Clothing (FRC):

It is mandatory to wear FRC on ALL offshore platforms, including   Drilling Rigs and in the Tank Farm and Process Areas of the Galeota Terminal.  The listed remaining areas onshore at Galeota Point will require the wearing of FRC based on specific job functions as identified by Department Heads/Managers.

 

                                                Laboratory

                                                Maintenance Work Shop

                                                Chemical Storage

                                                Marine

                                                Construction Yard

HSE PRACTICE NO. 1

Personal Protective Equipment

 

Are systems in place to ensure: EXHIBIT 7 -  CHECKLIST					0				1				2				3
				Please enter '1' in the relevant box
1	That the use of Personal Protective Equipment is only ever considered as a "last resort" - that is after all collective and procedural methods have been utilized to eliminate or mitigate the risks to health and safety ?
2	A formal assessment is made to determine if the intended PPE is appropriate to the risks involved and the findings recorded ?
3	All PPE used complies with COMPANY requirements and meets local manufacture standards
4	All PPE used takes account of ergonomic requirements and the workers state of health, and fits the wearer correctly once adjusted?
5	Where the presence of more than one risk to health and safety requires a worker to use simultaneous more than one type of PPE, such equipment is compatible and continues to be effective against those risks ?
6	Any PPE is maintained (including replaced or cleaned as appropriate) in an effective state, effective working order and in good repair?
7	Are people provided with sufficient information, instruction & training to enable them to know the risks involved with the use of PPE, and to correctly use, adjust, and where necessary clean and inspect - the items of PPE they are required to wear?
8	Workers/and or their representatives are consulted about changes to your PPE program.
	NB: This checklist reflects some of the key aspects but is not an exhaustive list of requirements in the Directive.

 

EXHIBIT 7

 

POLICY ON PPE DURING HELICOPTER FLIGHTS OFFSHORE

 

 

Personnel traveling to an offshore location where they can go directly from the helicopter to a change area/living accommodation and who do not pass through any area where operations are in progress, are not required to wear fire resistant coveralls, safety boots/shoes or hard hats.

 

They are still required, however, to wear hearing protection and the approved floatation device. Appropriate street clothes including closed toe footwear, long pants and shirts must be worn as described below

 

EXCEPTIONS

 

Personnel traveling to an offshore location where they have to pass through a work area, no matter how small, are required to wear full PPE. Examples are, but not limited to, work over operations where a helipad is not on top of the living quarters and personnel have to walk from the helipad to the temporary living quarters. 

It is the responsibility of the Senior Supervisor at each site to evaluate each case and enforce this.

 

HELICOPTER MINIMUM FOOTWEAR/ CLOTHING POLICY

 

All personnel traveling offshore shall wear the following:

 

1.         Footwear

 

Covered shoes , for instance Track shoes, loafers etc. are allowed but absolutely no open toe footwear , sandals , slippers etc.

 

2.         Clothing

 

Long trousers / pants are allowed, absolutely no shorts

 

Short sleeved sports type shirt or similar are allowed, absolutely no sleeveless type shirts / vests etc.

 

The minimum clothing policy will be enforced rigorously and any personnel found not conforming will not be allowed to fly either inbound or out bound.

 

 

 

 

EXHIBIT 8

 

YOUNG PERSONS AT WORK POLICY

 

            In this Policy:

"Young Person" means a child of the age of sixteen years and under the age of eighteen years.

     

                        Core Elements of the Policy

Ø  Young persons shall only be employed on a temporary basis and for internships.           

Ø  bpTT shall not permit any young person to work at a machine on any bpTT premises, unless he has been fully instructed as to the dangers arising in connection with its operation, and the precautions to be observed, and--

      (a)  has received sufficient training in work at the machine; or

      (b) is under adequate supervision by a person who has special knowledge and experience in the operation of the machine.

Ø  This section applies to such machines as may be prescribed under the OSH Act which are of such a dangerous character that a young person ought not to work at them unless the requirements of 2.1 are complied with.

Ø  No young person shall be employed to work for a period of three months or more unless--

      (a) a medical practitioner, on the application of the young person or his parent, has examined the young person and ascertained his fitness for work in bpTT; and

      (b) a document signed by bpTT to the effect that the young person will be employed at BPTT is submitted to the medical practitioner no later than at the commencement of the medical examination.

      (c) In cases where a contractor has reasons to have a young person work on any bpTT premises for more than three months, the contractor shall:

I.    Ensure that a medical practitioner, on the application of the young person or his parent, has examined the young person and ascertained his fitness for work in the contractor’s work on bpTT’s premises; and

II.    Have a document signed by the contractor to the effect that the young person will be employed to work on a bpTT’s premises is submitted to the medical practitioner no later than at the commencement of the medical examination.

III.   Provide documentary proof to bpTT that (I) and (II ) has been complied with.

 

Ø  After an examination, the medical practitioner may grant to the young            person, in the form prescribed in the OSH Act, or may renew--

      (a) a certificate of fitness to work if he is satisfied that the young person has attained the prescribed physical standard and that he is fit for such work; or

      (b) a certificate of fitness to work as an adult, if he is satisfied that the young person has attained the age of sixteen years and that he is fit for a full day’s work in an industrial establishment.

(c) unless the examining physician has personal knowledge of the place where the young person proposes to work and of the process in which he will be employed, he shall not grant or renew a certificate.

(d) a certificate of fitness

(i) shall be valid for a period of twelve months from the date thereof; and

(ii) may be issued subject to conditions regarding the nature of work in which the young person may be employed, or conditions requiring a medical re-examination of the young person before the expiry of the period of twelve months.

Ø  Where a certificate is granted or renewed subject to such conditions as are referred to in       subsection 2.4 (d)(ii), the young person shall not be required to work on any BPTT premises except in accordance with those conditions.

 

Ø  Except as provided for by section 90(2) of the Children Act (Chap. 46:01), no young             person shall be employed--

(a) between the hours of 10.00 p.m. and 7.00 a.m.;

(b) during the period of twelve consecutive hours immediately following the end of the period during which he last worked; or

(c) for more than eight hours a day.

 

Ø  The hours of employment shall include a rest period of at least one hour.

Ø  No young person shall be required to work more than forty-eight hours in any week.

Ø  No young person whether employed by bpTT or through a contractor working on any bpTT premises shall be permitted to work on the site unless he presents a copy of the certificate to bpTT.

Ø  No contactor shall permit or otherwise allow any young person to come onto any of bpTT premises for the purposes of work without first declaring his intention to do so to bpTT and only after getting in writing from bpTT authorization to do so. Any authorization from bpTT must specify the duration for which approval has been granted and specify what job functions the young person is permitted to engage in whilst on bpTT premises.

 

 

EXHIBIT 9

 

EMPLOYEES’ RIGHT TO REFUSE WORK POLICY

 

Employee shall mean anyone who is employed by BPTT or employed by any contractor, agent or other third party to perform work on BPTT premises for and on behalf of BPTT.

 

This Policy shall apply to all employees working on BPTT’s premises.  BPTT’s operating philosophy is that all work related tasks and/or work activities shall be risk assessed and appropriate risk mitigation measures put in place before they are attempted.

All employees shall have a responsibility to identify workplace risks and to alert fellow employees/ workers and supervisory personnel on any concerns they may have on workplace risk identification and mitigation on all BPTT’s premises.

Refusal:

An employee may refuse to work or do particular work where he has sufficient reason to believe that--

(a   there is serious and imminent danger to himself or unusual circumstances have arisen which are hazardous or injurious to his health or life;

(b)  any machine, plant, device or thing he/she is to use or operate is likely to endanger himself or another employee;

(c   the physical condition of the workplace or the part thereof in which he works or is to work is likely to endanger himself;

(d)  any machine, plant, device or thing he/she is to use or operate or the physical condition of the BPTT LLC premises in which he works or is to work is in contravention of the OSH Act or the Regulations made under it and such contravention is likely to endanger himself or another employee

 

Report of refusal

(1)     Upon refusing to work or do particular work the employee shall immediately report the circumstances of the refusal or intended refusal to his/her supervisor, or other Management representative and a HSSE representative.

(2)     The relevant Supervisor or other Management Representative shall inform the Chairman of the Health and Safety Committee in the functional areas where the refusal is reported and request the Committee to immediately investigate the report in the presence of the employee and in the presence of a person who has sufficient knowledge, experience and training in relation to the particular matter and in the presence of a representative of BPTT.

(3)     Where there is no Safety and Health Committee the employee, upon refusing to work or do particular work, shall report the circumstance of the intended refusal to the relevant supervisor or appropriate Management representative and the Chief Inspector under the OSH Act.

 

 

The policy further details how BPTTLLC will treat with the following:

Ø Refusal to work following investigation

Ø Grievances following the investigation

Ø Employee at work and payment during investigation

Ø Fear of reprisal and  dismissal

 

EXHIBIT 10

 

DRIVING SAFETY STANDARD

 

 

The intent of this Standard is to ensure a formal approach to managing driving risk for BP employees and for BP Companies in respect of BP vehicles.

 

The further intent is to recommend that a comprehensive driving standard be adopted by non-BP Companies whose employees are members of the workforce.

This standard superseded the Golden safety rule, Driving.

 

The Group Standard – Personal Safety – Driving Safety requires compliance with the following 10 Elements:

 

Vehicle Requirements:

1. The vehicle shall be fit for the purpose, and shall be maintained in safe working order, with seatbelts installed and functional.

 

2. The number of passengers shall not exceed the manufacturer's specification

for the vehicle.

 

3. Loads shall be secure and shall not exceed the manufacturer’s specification

and legal limits for the vehicle.

 

BP Driver and Passenger Requirements:

4. Drivers shall be appropriately assessed, licensed, trained, and medically fit

to operate the vehicle.

 

5. Drivers shall be appropriately rested and alert.

 

6. Drivers shall not use a mobile phone or other two-way communication

device while operating the vehicle.

 

7. In specific higher-risk countries risks of the journey shall be assessed and

journey risk management policy & plans in place.

 

8. Seatbelts shall be worn by all occupants at all times whenever a vehicle is in

motion.

 

9. Drivers shall not be under the influence of alcohol or drugs, or any other

substance or medication that could impair their ability to drive.

 

10. Safety helmets shall be worn by rider and passengers of motorcycles, all

terrain vehicles (ATVs), snowmobiles and similar types of vehicle