Registration document 2011 - tota - Total.com

2.2. Management and monitoring of industrial and environmental risks
2.2.1. TOTAL policies regarding health,
safety and the environment
TOTAL has developed a “Health Safety Environment Quality
Charter” (see point 2 of Chapter 12) which sets out the basic
principles applicable within the Group regarding the protection of
people, property and the environment. This charter is rolled out at
several levels within the Group by means of management systems.
Along these lines, TOTAL has developed efficient organizations as
well as safety, environmental and quality management systems,
which it makes every effort to have certified or assessed (standards
such as the International Safety Rating System, ISO 14001 and
ISO 9001). For example, in 2010, TOTAL received ISO 9001
certification for “development and management of the database
of technical businesses” in Exploration and Production.
In most countries, TOTAL’s operations are subject to government
regulations concerning environmental protection and industrial
safety. The main regulations are:
1) In Europe: IPPC- Large Combustion Plants Directives
(recasted by IED Directive), SEVESO Directive, Pressure
Equipment Directive, Water Framework Directive, Waste
Directive, ETS Directive (CO 2 quotas), Fuel Directive, REACH
and CLP Regulations.
2) In France: the legislation on natural and technological risks
also applies to several sites.
3) In the United States: several activities are subject to the
Occupational Safety and Health Administration (“OSHA”)
Process Safety Management of Highly Hazardous Materials
and the Superfund Act.
2.2.2. Assessment
As part of its policy, TOTAL systematically assesses risks and
impacts in the areas of industrial safety (particularly technological
risks), the environment and the protection of workers and local
residents:
– prior to approving new projects, investments, acquisitions and
disposals;
– periodically during operations (safety studies, environmental
impact studies, health impact studies and risk prevention plan in
France as part of the 2003 legislation on the prevention of major
technological risks);
– prior to introducing new substances to the market (toxicological
and ecotoxicological studies and life cycle analyses); and
– based on the regulatory requirements of the countries where
these activities are carried out and generally accepted standards.
In countries where prior administrative authorization and supervision
is required, projects are not undertaken without the authorization of
the relevant authorities and are developed according to the studies
provided to the authorities.
In particular, TOTAL has developed common methodologies for
analyzing technological risks which must gradually be applied to all
activities carried out by the Group’s companies.
2.2.3. Management
Risk factors 4
Industrial and environmental risks
TOTAL develops risk management measures based on risk and
impact assessments. These measures involve facility and structure
design, the reinforcement of safety devices and remedies of
environmental degradations.
In addition to developing organizations and management systems
as described above, TOTAL strives to minimize industrial and
environmental risks inherent in its operations by conducting
thorough inspections and audits, training personnel and raising
awareness among all those involved, and implementing an active
investment policy.
In addition, performance indicators (in the areas of HSE) and risk
monitoring have been put in place, objectives have been set and
action plans have been implemented to achieve these objectives.
Although the emphasis is on preventing risks, TOTAL takes regular
steps to prepare for crisis management based on the risk scenarios
identified.
In particular, TOTAL has developed emergency plans and
procedures to respond to an oil spill or leak. These plans and
procedures are specific to each TOTAL affiliate and adapted to its
organization, activities and environment, and are consistent with
the Group plan. They are reviewed regularly and tested through
exercises.
At the Group level, TOTAL has set up the alert scheme PARAPOL
(Plan to Mobilize Resources Against Pollution) to facilitate crisis
management and provide assistance by mobilizing both internal
and external resources in the event of pollution of marine, coastal
or inland waters, without geographical restriction. The PARAPOL
procedure is made available to TOTAL affiliates and its main goal
is to facilitate access to internal experts and physical response
resources.
Furthermore, TOTAL and its affiliates are currently members
of certain oil spill cooperatives that are able to provide expertise,
resources and equipment in all geographic areas where TOTAL has
operations, including in particular Oil Spill Response, CEDRE
(Center of documentation, research and experimentation on
accidental water pollution) and Clean Caribbean and Americas.
Following the blow-out on the Macondo well in the Gulf of Mexico
in 2010 (concerning which the Group was not involved), TOTAL
created three Task Forces in order to analyze risks and provide
recommendations.
In Exploration & Production, Task Force No. 1 reviewed the safety
aspects of deep offshore drilling operations (wells architecture,
design of blow-out preventers, training of personnel based on
lessons learned from the serious accidents that occurred recently
in the industry). Its efforts have led to the implementation of even
more stringent controls and audits on drilling operations.
Task Force No. 2, coordinated with the Global Industry Response
Group (GIRG) created by the OGP (International Association of Oil
and Gas Producers), is studying deep offshore oil capture and
containment operations in case of a pollution event in deep waters.
In the short term, capture devices will be available in several regions
of the world where TOTAL has a strong presence in explorationproduction
(North Sea, Gulf of Guinea).
Registration Document 2011. TOTAL 79