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Tullow safety rules - The Group

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<strong>Tullow</strong> Oil plc<br />

SAFETY RULES


<strong>Tullow</strong> Safety Rules<br />

TABLE OF CONTENTS<br />

SECTION 1. OVERVIEW<br />

SECTION 2. VISION<br />

SECTION 3. SCOPE AND APPLICATION<br />

SECTION 4. ROLES AND RESPONSIBILITIES<br />

4.1 Regional Business Manager<br />

4.2 Country Manager<br />

4.3 <strong>Group</strong> EHS Manager<br />

4.4 All Personnel<br />

SECTION 5. COMMITMENT AND EXPECTATION<br />

5.1 <strong>Tullow</strong>’s Commitment<br />

5.2 <strong>Tullow</strong>’s Expectations<br />

SECTION 6. FOUNDATION FOR OPERATIONS<br />

SECTION 7. VARIANCE<br />

SECTION 8. AUDITING AND COMPLIANCE<br />

8.1 Intent<br />

8.2 Self-Assessment<br />

8.3 Findings and Action Management<br />

SECTION 9. DOCUMENT CONTROL AND REVIEW<br />

SECTION 10. DEFINITIONS<br />

SECTION 11. TULLOW SAFETY RULES<br />

Rule 1: Permit to Work<br />

Rule 2: Energy Isolation<br />

Rule 3: Working at Height<br />

Rule 4: Lifting Operations<br />

Rule 5: Excavation Work<br />

Rule 6: Confined Space Entry<br />

Rule 7: Process Safety<br />

Rule 8: Management of Change<br />

Rule 9: Driving Safety<br />

Rule 10: Hazardous Materials<br />

Rule 11: Contractor Management<br />

Rule 12: Environmental Management<br />

Rule 13: Health and Hygiene<br />

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Page 1


<strong>Tullow</strong> Safety Rules<br />

SECTION 1<br />

OVERVIEW<br />

<strong>The</strong> <strong>Tullow</strong> Safety Rules are a set of requirements designed to manage high risk activities that have the potential to<br />

adversely effect our personnel, the environment and surrounding communities.<br />

<strong>The</strong>se <strong>rules</strong> are established using industry practices, guidelines and standards and are intended to reinforce, but do not<br />

replace, <strong>Tullow</strong>’s standards or applicable host country regulatory commitments.<br />

Effective implementation of these <strong>rules</strong> will steer our company to our commitment of eliminating harm to our personnel,<br />

the environment and surrounding communities during the execution of our operations.<br />

<strong>Tullow</strong> is committed to supporting the effective implementation of these <strong>rules</strong>. Likewise, <strong>Tullow</strong> expects that everyone give<br />

their own commitment to adhering to these requirements in their work.<br />

Page 2


SECTION 2<br />

VISIONS<br />

<strong>Tullow</strong> is fully committed to supporting these <strong>rules</strong>.<br />

In order for the <strong>rules</strong> to be effective we all must adhere to the following fundamentals:<br />

• We must take accountability for our own <strong>safety</strong> and for the <strong>safety</strong> of others.<br />

• We must plan and subsequently execute our work to minimize the risks associated to our personnel, the environment<br />

and our surrounding community.<br />

• We must continually learn from others and our experiences so that we may evolve into a learning organisation.<br />

• We must engage with our contractors to enable them to implement the intent of these <strong>rules</strong> when engaged in activities<br />

not controlled by <strong>Tullow</strong>’s management systems.<br />

• We must all stop the job whenever we feel the protection of our personnel, the environment and surrounding<br />

communities are compromised.<br />

Page 3


<strong>Tullow</strong> Safety Rules<br />

SECTION 3<br />

SCOPE AND APPLICABILITY<br />

<strong>Tullow</strong> Safety Rules apply to all parts of <strong>Tullow</strong>’s operations and to all employees and contractors, involved in those<br />

activities. <strong>Tullow</strong>’s Businesses are required to manage EHS risks by developing and implementing procedures that define<br />

the relevant standards and processes intended to support the implementation of these <strong>rules</strong>.<br />

Contractors working under the <strong>Tullow</strong> management system must comply with these <strong>Tullow</strong> Safety Rules.<br />

Contractors working under their own management system should be encouraged to implement the intent of these <strong>rules</strong>.<br />

Where conflict exists between these <strong>rules</strong> and the applicable host country regulatory requirements, the more stringent<br />

will apply.<br />

Page 4


SECTION 4<br />

ROLES AND RESPONSIBILITIESS<br />

Everyone has an individual responsibility for their own <strong>safety</strong> and the <strong>safety</strong> of the people around them. <strong>The</strong> roles and<br />

responsibilities listed below cascade throughout the organisation.<br />

4.1 Regional Business Manager<br />

• Responsible for supporting the Country Manager’s implementation of the <strong>Tullow</strong> Safety Rules.<br />

• Responsible for assessing, evaluating and approving any variance from these <strong>rules</strong>.<br />

4.2 Country Manager<br />

• Accountable for the execution of <strong>Tullow</strong>’s operations in accordance with these <strong>rules</strong>.<br />

• Accountable for ensuring that all individuals fully understand these <strong>rules</strong> as they apply to their specific roles.<br />

• Accountable for demonstrating compliance with these <strong>rules</strong>.<br />

• Accountable for identifying, reporting and addressing any circumstances of non-compliance.<br />

• Responsible for ensuring that the self-assessment is carried out every two years.<br />

• Approval of self-assessment and associated action plan.<br />

4.3 <strong>Group</strong> EHS Manager<br />

• Accountable for developing and maintaining the <strong>Tullow</strong> Safety Rules.<br />

• Accountable for communicating these <strong>rules</strong> to the Business Units.<br />

• Accountable for revising these <strong>rules</strong> based on the performance, industry practice and regulatory requirements.<br />

• Accountable for supporting the Business Units in understanding and implementing these <strong>rules</strong>.<br />

• Responsible for collating, reviewing, trending and reporting the degree of compliance across <strong>Tullow</strong>’s operations.<br />

• Responsible for reviewing and endorsing any variances submitted by the Business.<br />

4.4 All Personnel<br />

• Responsible for understanding these <strong>rules</strong>.<br />

• Responsible for executing specific roles and responsibilities in accordance with these <strong>rules</strong>.<br />

• Responsible for reporting any circumstances of non-compliance.<br />

• Responsible for stopping the job in circumstances where the <strong>safety</strong> of people, the environment and surrounding<br />

communities are compromised.<br />

Page 5


<strong>Tullow</strong> Safety Rules<br />

SECTION 5<br />

COMMITMENT AND EXPECTATION<br />

5.1 <strong>Tullow</strong>’s Commitment<br />

<strong>Tullow</strong> is committed to the <strong>safety</strong> and wellbeing of its people, the environment and surrounding communities:<br />

In delivering this commitment <strong>Tullow</strong> will:<br />

• Identify risks associated with the execution of <strong>Tullow</strong>’s business.<br />

• Develop a set of mandatory <strong>rules</strong> that must be applied.<br />

• Communicate <strong>Tullow</strong>’s expectations and requirements to everyone engaged in the execution of <strong>Tullow</strong>’s business.<br />

• Allocate sufficient competent resources to support the effective implementation of these <strong>rules</strong>.<br />

• Require everyone to comply with these <strong>rules</strong>.<br />

• Require everyone to report any variances and/or violations.<br />

• Undertake assurance activities.<br />

5.2 <strong>Tullow</strong>’s Expectations<br />

<strong>Tullow</strong> expects each employee and contractor is able to return home at<br />

the end of the working day without having suffered or caused harm in any<br />

way to themselves, others, the environment or surrounding communities.<br />

In delivering this individual commitment <strong>Tullow</strong> expects:<br />

• <strong>The</strong> <strong>Tullow</strong> Safety Rules form part of induction processes.<br />

• All employees and contractors are conversant with the <strong>Tullow</strong><br />

Safety Rules.<br />

• Employees and contractors will only undertake work for which they<br />

have been trained and deemed competent.<br />

• All employees and contractors are personally accountable for the<br />

implementation of these <strong>Tullow</strong> Safety Rules as they apply to their<br />

specific role.<br />

• Any variance and/or violation is immediately reported.<br />

• All employees and contractors to intervene and stop work for<br />

instances where these <strong>Tullow</strong> Safety Rules are not adequately<br />

managing the risks.<br />

Page 6


SECTION 6<br />

FOUNDATION FOR OPERATIONS<br />

Fundamental requirements which are the foundation for EHS aspects of operations include:<br />

• Work will not be conducted without a task risk assessment and a <strong>safety</strong> discussion appropriate to that level of risk.<br />

• People will be trained, competent and fit to conduct the activity.<br />

• Personal Protection Equipment (PPE) will be worn as detailed in the risk assessment and minimum site requirements.<br />

• All equipment to be utilised must be fit-for-purpose. Equipment found to be damaged or defective is removed<br />

from service.<br />

• Rescue, recovery and emergency response plans and specified equipment, developed from a review of potential<br />

emergency scenarios, is in place before commencement of the activity.<br />

• Everyone has an obligation to stop work that is unsafe.<br />

SECTION 7<br />

VARIANCE<br />

A decision by a <strong>Tullow</strong> operation to deviate from any part of these <strong>rules</strong> must be based on a formal documented risk<br />

assessment and justification. <strong>The</strong> justification must be reviewed and approved by the respective <strong>Tullow</strong> Regional Business<br />

Manager and endorsed by the <strong>Group</strong> EHS Manager prior to the execution of the activity.<br />

Any authorisation of a deviation under this process must be reviewed as part of the self-assessment every two years.<br />

Page 7


<strong>Tullow</strong> Safety Rules<br />

SECTION 8<br />

AUDITING AND COMPLIANCE<br />

<strong>The</strong> Regional Business Units are responsible for demonstrating and reporting compliance with these <strong>rules</strong>.<br />

Demonstration and compliance reporting must be performed in accordance with the self-assessment process every<br />

two years.<br />

8.1 Intent<br />

Each Business Unit must perform a self-assessment against these <strong>rules</strong>, with the intent of:<br />

• Providing assurance that controls are in place and effective in managing risks associated with these activities.<br />

• Demonstrating overall compliance with these <strong>rules</strong> by assessing whether systems are adequately documented,<br />

understood by personnel and effectively implemented.<br />

• Providing a compliance reporting structure whereby any lessons learned can be identified, communicated and<br />

implemented.<br />

8.2 Self-Assessment<br />

Compliance to these <strong>rules</strong> must be demonstrated every two years by using the <strong>Tullow</strong> Safety Rules Self-Assessment Toolkit.<br />

EHS Functional <strong>Group</strong> is responsible for the development, maintenance and issue of the toolkit at least three months prior<br />

to the submission deadline, which will be agreed with the <strong>Group</strong> EHS Manager.<br />

<strong>The</strong>se <strong>rules</strong> are mandatory and as such must be fully implemented to manage all <strong>Tullow</strong>’s operations. <strong>The</strong> level of<br />

compliance is based on a simple comply / not comply principle as the mandatory nature of these <strong>rules</strong> will not support<br />

partial implementation.<br />

<strong>The</strong> self-assessment team must collate evidence in order to demonstrate compliance / non-compliance with the<br />

relevant rule. <strong>The</strong> following items may be used as a form of evidence.<br />

• Documentation – demonstration that written standards, processes or procedures exist and are adequate in supporting<br />

the implementation of these <strong>rules</strong>.<br />

• Interviews – demonstration that specific individuals have an understanding of their roles and responsibilities.<br />

• Observations – demonstration that activities are performed in accordance with defined standards, processes<br />

and procedures. Observations provide evidence, regardless of an individual’s knowledge of <strong>rules</strong>, of whether activities<br />

are collectively performed as per the defined requirements.<br />

• Any approved and endorsed variances.<br />

8.3 Findings and Action Management<br />

All actions must be assigned a responsible party, appropriate completion date, managed in an action management system<br />

and be retained for reference in future audits.<br />

<strong>The</strong> relevant Country Manager will approve the self-assessment and associated action plan.<br />

Page 8


SECTION 9<br />

DOCUMENT CONTROL AND REVIEW<br />

<strong>The</strong> <strong>Group</strong> EHS Manager is responsible for the development, maintenance and revision of these <strong>rules</strong>.<br />

<strong>The</strong>se <strong>rules</strong> must be subject to review. <strong>The</strong> reviews should be based on:<br />

• Corporate objectives and targets.<br />

• EHS performance e.g. incidents, self-assessment findings etc.<br />

• Regulatory requirements.<br />

• Industry practice.<br />

Page 9


<strong>Tullow</strong> Safety Rules<br />

SECTION 10<br />

DEFINITIONS<br />

Permit to Work<br />

A controlled document identifying hazards and setting measures to manage risks associated with the actual task and any<br />

potential interfacing tasks. A permit to work is required for, but not limited to, confined space entry, excavation work,<br />

work on energised systems (electrical, mechanical, hydraulic, thermal), hot work, heavy lifts, working at heights,<br />

work with hazardous materials (including radioactive sources) and any non-routine activities. Local procedures may<br />

require a PTW for additional activities.<br />

Excavation Work<br />

Work to form a cut, cavity, trench or depression in the earth’s surface by earth removal or by other ground disturbance.<br />

Confined Space<br />

An enclosed or partially enclosed space:<br />

• Not intended or designated primarily as a place of work.<br />

• With restricted means for entry and exit.<br />

• At atmospheric pressure when occupied.<br />

Which may at any time:<br />

• Have a potentially harmful atmosphere.<br />

• Have an oxygen deficiency or excess.<br />

• Cause engulfment.<br />

Hazardous Material<br />

A solid, liquid, or vapour (gas) that when released into the environment could cause illness, injury, or death to people<br />

or destruction of the environment if improperly treated, stored, handled, transported, or discarded. Substances are<br />

considered hazardous if they are:<br />

• Ignitable.<br />

• Corrosive.<br />

• Reactive.<br />

• Toxic.<br />

Mixtures, residues, or materials containing hazardous wastes are also considered hazardous materials.<br />

Contractor<br />

Any person(s) or company contracted by <strong>Tullow</strong> to provide services in support of the execution of <strong>Tullow</strong>’s business.<br />

Competent Person<br />

A competent person is someone who has sufficient training, experience and/or knowledge to undertake the task being<br />

asked of them.<br />

Page 10


Working at Height<br />

All personnel, when engaged in work 2 metres (or 6 feet) or more above a working surface or where a fall could result in a<br />

significant injury e.g. water; should be protected at all times from falling by guardrail systems, fixed platforms or personal<br />

fall arrest systems. Note: Risk of significant injuries may occur from heights less than 2 metres (or 6 feet), as such,<br />

appropriate controls and mitigation measures must be in place to manage such risks.<br />

Management of Change<br />

A process for the identification, evaluation and approval of change that ensures risks associated with specific changes are<br />

managed prior to the execution of the change and commencement and/or continuation of activities.<br />

Lifting Operations<br />

Lifting operations are defined as activities associated with the lifting and lowering of a load i.e. includes movement,<br />

which may include both horizontal and vertical, of the supported load.<br />

Risk Assessment<br />

A process by which hazards are identified and evaluated for a specific activity, and control and mitigation measures<br />

implemented to prevent and mitigate potential hazards that have the potential to adversely impact the protection of people,<br />

the environment and surrounding communities.<br />

Non-routine activity<br />

An activity that is being performed sufficiently infrequently that could potentially lead to the inadequate identification of<br />

hazards and ineffective implementation of controls.<br />

Safety Critical Equipment<br />

Safety Critical Equipment can prevent, control or mitigate major accident events and the failure of which could cause or<br />

contribute substantially to a major accident event.<br />

HAZOP<br />

A Hazard and Operability (HAZOP) study is a structured and systematic examination of a process or operation in order to<br />

identify and evaluate hazards that may represent risks to personnel or equipment, or prevent efficient operation.<br />

Major Accident Event<br />

An accident involving loss of life on a site / facility of five or more people resulting in damage to equipment leading to<br />

stoppage of process or adverse effects to the environment.<br />

Zero Energy State<br />

<strong>The</strong> dissipated energy state whereby no stored energy can be released and all electrical sources are grounded.<br />

Page 11


<strong>Tullow</strong> Safety Rules<br />

SECTION 11<br />

TULLOW SAFETY RULES<br />

<strong>The</strong> <strong>Tullow</strong> Safety Rules cover the following activities:<br />

Rule 1:<br />

Rule 2:<br />

Rule 3:<br />

Rule 4:<br />

Rule 5:<br />

Rule 6:<br />

Rule 7:<br />

Rule 8:<br />

Rule 9:<br />

Rule 10:<br />

Rule 11:<br />

Rule 12:<br />

Rule 13:<br />

Permit to Work<br />

Energy Isolation<br />

Working at Heights<br />

Lifting Operations<br />

Excavation Work<br />

Confined Space Entry<br />

Process Safety<br />

Management of Change<br />

Driving Safety<br />

Hazardous Materials<br />

Contractor Management<br />

Environmental Management<br />

Health and Hygiene<br />

Page 12


Rule 1<br />

Permit to work<br />

Intent<br />

To provide a standard for the management of high risk activities and ensure that permit to work procedures are<br />

implemented by the business and that they are adequate, communicated and formally controlled.<br />

Requirements<br />

• A formal written work permit must be obtained prior to the<br />

commencement of work involving confined space entry, work<br />

on energised systems (electrical, mechanical, hydraulic, thermal),<br />

hot work, heavy lifts, working at heights, work with hazardous<br />

materials (including radioactive sources) and non-routine activities.<br />

• A task risk assessment must be conducted with all personnel<br />

involved in or impacted by the permitted work.<br />

• <strong>The</strong> work permit documentation must ensure:<br />

- <strong>The</strong>re is a clearly defined scope, location of work and validity<br />

period.<br />

- All hazards associated with the work have been identified and risk<br />

assessed.<br />

- All controls identified to manage the risks associated with the<br />

hazards are communicated to all involved in the work,<br />

implemented and verified.<br />

- A responsible person for the specific work location must authorise the work.<br />

--<strong>The</strong> responsible person must verify that the controls are adequate and in place prior to authorization and<br />

commencement of the work.<br />

--Any electrical and/or mechanical isolations are referenced on the permit, in place and verified as such.<br />

--No conflicting work activities exist that could potentially adversely effect the controls or introduce additional hazards.<br />

--Personnel conducting the work acknowledge the risks and agree to the controls identified to manage such risks.<br />

--Those accountable and responsible persons authorise, monitor and revalidate the work permit.<br />

--Relevant risk assessment and/or associated certificates are referenced on the work permit.<br />

• All work permits must be displayed at the work site and central site/facility control centre.<br />

• All work permits must be managed from a central location on the site or facility.<br />

• A competent person must be appointed to manage the permit to work system.<br />

• A system for the management, authorisation and communication of work permits that extend beyond the validity period<br />

must be in place.<br />

Page 13


<strong>Tullow</strong> Safety Rules<br />

Rule 2<br />

ENERGY ISOLATION<br />

Intent<br />

To provide a standard for the management of risks associated with work requiring energy (process, mechanical, electrical,<br />

instrument, hydraulic) isolations, such that energy sources are identified, isolated, tested and communicated to appropriate<br />

personnel before work shall proceed.<br />

Requirements<br />

• A written work permit must be obtained prior to the<br />

commencement of any work on a system requiring energy<br />

isolation.<br />

• Personnel involved in isolations will be trained and competent.<br />

• A task risk assessment must be conducted with all personnel<br />

involved in or impacted by the permitted work.<br />

• A system for the use of locks, tags or physical removal or<br />

separation of components to isolate energy sources must be<br />

developed and in place to ensure positive protection is provided.<br />

• Locks used in the isolation of energy sources must be adequately<br />

designed to prevent any inadvertent or malicious de-isolation<br />

of a source.<br />

• All isolated energy sources must be tested and verified to ensure<br />

that the source is effectively isolated.<br />

• Isolation effectiveness must be periodically tested and verified.<br />

• Isolations and/or de-isolations must be conducted, tested and<br />

verified by a competent person.<br />

• A test procedure must be in place for the verification of a<br />

positive isolation.<br />

• <strong>The</strong> duration of an isolation must be defined on the written<br />

work permit and a system must be developed and in place that<br />

manages the:<br />

- Hand-over of an isolation to another responsible person, and<br />

- Removal of isolation by an alternate responsible person not<br />

initially identified on the written work permit.<br />

• A system must be developed and in place that manages<br />

circumstances where any one of the following is not achievable:<br />

--A zero energy state,<br />

--A test/try of isolation, or<br />

--Use of a locking device.<br />

Page 14


Rule 3<br />

WORKING AT HEIGHT<br />

Intent<br />

To provide a standard for the management of risks associated with working at height and ensure that the procedures<br />

established by the Business considers the identification and control of working at height activities. Working at height<br />

is defined as work at 2 metres (or 6 feet) or more above a working surface or any height whereby there in potential for<br />

significant injury if you fall.<br />

Note: Risk of significant injuries may occur from heights less than 2 metres (or 6 feet), as such, appropriate controls and<br />

mitigation measures must be in place to manage such risks.<br />

Requirements<br />

• Working at height activities must only be conducted after alternatives, which avoid working at height have been<br />

considered, evaluated and discounted.<br />

• Where possible a fixed platform with guards, handrails and kick plates should be used. Such platforms or scaffold<br />

erections must be initially checked and signed off by a Competent Person prior to initial use.<br />

• A task risk assessment must be conducted for all working at height activities with all personnel involved in or impacted<br />

by the activity. Consideration should be given to the work environment (rotating machinery, lifting operations etc.)<br />

and the most appropriate form of controls.<br />

• Working at height activities must only be performed by trained and competent individuals.<br />

• Working at height activities must never be performed alone.<br />

• Ensure that the area below is cordoned off and that appropriate notifications are communicated and posted.<br />

• Ensure that all tools used at height are always secured from free fall and removed from height upon temporary<br />

suspension or completion of the activity.<br />

• All working at height activities must be performed using a personal fall arrest system, consisting of a full body harness,<br />

shock absorber and lanyard which limits the fall to 2 metres (or 6 feet) or less.<br />

• <strong>The</strong> personal fall arrest system and associated equipment must be visually inspected prior to use and immediately<br />

removed from service if any defects exist.<br />

• Individuals working at height must remain attached to a suitable anchor point at all times. Where movement at height<br />

is necessary a double lanyard will be used.<br />

• A suitable anchor point preferably overhead must be selected to reduce the overall potential fall distance.<br />

• All anchor points must be sufficiently designed to withstand the potential shock load of an individual falling from height.<br />

• A rescue plan and associated equipment must be in place prior to the commencement and/or continuation of an<br />

activity at height.<br />

• A preventative maintenance system must be in place to ensure that all fall arrest equipment is maintained and in a<br />

serviceable condition.<br />

Page 15


<strong>Tullow</strong> Safety Rules<br />

Rule 4<br />

LIFTING OPERATIONS<br />

Intent<br />

To provide a standard for the management of risks associated with lifting operations (which involve cranes, hoists, chain<br />

blocks or other mechanical lifting devices) and ensure that the procedures established by the Business considers the<br />

identification and control of lifting activities.<br />

Requirements<br />

• Cranes must be subject to daily visual inspections of wire ropes, sheaves, hoses and general condition and include<br />

tests to confirm the correct operation of all limit switches, shutdowns, load indicators, alarms and other<br />

<strong>safety</strong> devices.<br />

• <strong>The</strong> Safe Working Load (SWL) must be clearly identified and marked on all cranes and relevant lifting equipment and<br />

must not be exceeded by static or dynamic loads.<br />

• Suitably qualified, certified and competent person(s) must be involved in the planning, supervision and execution of<br />

lifting operations.<br />

• Man-riding operations using work baskets (or similar) will only be permitted following specific risk assessment.<br />

All equipment used for man-riding operations must be specifically designed, certified and identified as suitable<br />

for such operations.<br />

• Clear lines of communications between all person(s) involved in the lifting operations must be established and<br />

maintained.<br />

• A dedicated signalman must be appointed to all lifting operations and must ensure that the lines of communications<br />

are established with the crane operator.<br />

• Lifting operations must only be performed within the manufacturers recommended adverse weather limits.<br />

• Lifting operations must be performed in a manner that eliminates person(s) under the load or between a suspended<br />

load and fixed object.<br />

• Lifting operations when lifting near or over unprotected plant, equipment or services, including live process plant or<br />

hydrocarbon processes must be risk assessed to identify hazards, controls and mitigations measures designed to<br />

eliminate or minimise risks.<br />

• Lifting equipment must be fit-for-purpose, certified, managed and maintained in accordance with a site / facility lifting<br />

equipment register.<br />

• A preventative maintenance system must be in place to ensure that all cranes and lifting equipment are maintained<br />

and in a serviceable condition.<br />

• All lifting equipment is subject to a visual inspection by a competent person prior to every lift.<br />

• Safety devices are operable for every lifting operation.<br />

• Any modification to cranes and lifting equipment must be subject to the original equipment manufacturer’s approval<br />

and managed in accordance with the management of change process.<br />

Page 16


Rule 5<br />

EXCAVATION WORK<br />

Intent<br />

To provide a standard for the management of risks associated with excavation work and ensure that the procedures<br />

established by the Business considers the identification and control of these activities.<br />

Requirements<br />

• A written work permit must be in place and a risk assessment must be conducted for all excavation related activities<br />

with all personnel involved in or impacted by the work.<br />

• <strong>The</strong> risk assessment must consider underground services and utilities, other operations in the vicinity, isolation<br />

requirements, any confined space activities, access and egress requirements.<br />

• A rescue plan and associated equipment must be in place and communicated to personnel prior to the commencement<br />

and/or continuation of excavation work.<br />

• Excavation work must only be performed by trained and competent individuals.<br />

• No mechanical digging equipment must be used within 0.5metres of a below ground service; hand digging only.<br />

• All sources of energy affecting the excavation must be eliminated or isolated.<br />

• Initial and periodic atmospheric testing must be conducted.<br />

• Atmospheric testing equipment must be calibrated and inspected in accordance with the manufacturer’s<br />

recommendations or host country regulatory requirements, whichever is the higher standard.<br />

• Where applicable shoring of excavations must be in place.<br />

• Signs and barricades must be used to identify and warn personnel of on-going excavation activities.<br />

• Excavation spoil must be stored in such a way to avoid it falling back into the excavation.<br />

• Ground and environmental conditions must be monitored for change.<br />

• Waste management of any pumped water and excavated materials must be managed in accordance with the risk<br />

assessment and specific site <strong>rules</strong>.<br />

Page 17


<strong>Tullow</strong> Safety Rules<br />

Rule 6<br />

CONFINED SPACE ENTRY<br />

Intent<br />

To provide a standard for the management of risks associated with confined space entry and ensure that the procedures<br />

established by the Business considers the identification and control of these activities.<br />

Requirements<br />

• Confined space entry must only be conducted after alternatives,<br />

which avoid confined space entry have been considered, evaluated<br />

and discounted.<br />

• Identify and suitably mark/label all permanent confined spaces to<br />

prevent inadvertent or unauthorised access to those spaces<br />

by site personnel.<br />

• A written work permit must be in place and a risk assessment<br />

must be conducted for all confined space entries with all<br />

personnel involved in or impacted by the work.<br />

• A rescue plan and associated equipment must be in place and<br />

communicated to personnel prior to the commencement<br />

and/or continuation of a confined space entry.<br />

• Confined space entries must only be performed by trained and<br />

competent individuals.<br />

• All sources of energy affecting the space must be eliminated<br />

or isolated.<br />

• Initial and periodic atmospheric testing must be conducted before<br />

and during work activities in the space.<br />

• Atmospheric testing equipment must be calibrated and inspected<br />

in accordance with the manufacturer’s recommendations or host<br />

country regulatory requirements, whichever is the higher standard.<br />

• Adequate ventilation must be provided to ensure a safe<br />

atmosphere at all times, from initial entry until the work is<br />

completed and the space is evacuated.<br />

• A dedicated stand-by person must be continually stationed at the<br />

entrance to the space to prevent unauthorised entry and initiate<br />

any rescue response.<br />

• <strong>The</strong>re must be a reliable means of communication established<br />

with the individual(s) in the confined space.<br />

Page 18


Rule 7<br />

PROCESS SAFETY<br />

Intent<br />

To provide a standard for the management of risks associated with operating hydrocarbon processes and ensure that the<br />

procedures established by the Business considers major accident event prevention by assuring the on-going integrity of<br />

process plant and equipment.<br />

Requirements<br />

• Process plant and equipment must be appropriately designed for the intended service and risks demonstrated as<br />

being ALARP.<br />

• A HAZOP must be performed on all process systems prior to the commencement of hydrocarbon handling and<br />

processing.<br />

• Process plant and equipment is operated within approved safe limits.<br />

• Safety Critical Equipment must be identified, inspected, tested and maintained in accordance with an approved<br />

maintenance schedule.<br />

• Process plant and equipment repairs and replacements are completed within specified timeframes.<br />

• Changes to <strong>safety</strong> critical equipment must include consultation with the equipment manufacturer and managed in<br />

accordance with a specific management of change procedure.<br />

• All hydrocarbon releases are reported, quantified, investigated and rectified.<br />

• A documented system must be in place for managing inhibits & overrides.<br />

• A hand-over process must be in place to ensure communication of process conditions and status between process<br />

operators.<br />

• Process operators must be adequately trained and competent to perform their intended duties at the specific site /<br />

facility.<br />

Page 19


<strong>Tullow</strong> Safety Rules<br />

Rule 8<br />

MANAGEMENT OF CHANGE<br />

Intent<br />

To provide a formal standard for the management of organisational, equipment and procedural changes and ensure<br />

that management of change procedures implemented by the business consider the identification, initiation, evaluation,<br />

approval and implementation of change.<br />

Requirements<br />

• Where change, permanent or temporary, occurs to equipment, operating processes, procedures or personnel or<br />

where the potential for EHS impact from change exists, assessment of the change must be conducted, including formal<br />

justification and approval of the change and implementation of effective change management.<br />

• All hazards associated with the potential change must be formally identified and risk assessed.<br />

• All controls identified to manage risks associated with the change must be communicated to all involved stakeholders,<br />

implemented and verified prior to the commencement and/or continuation of work.<br />

• Prior to final approval and implementation all changes must be reviewed to ensure that:<br />

--<strong>The</strong> risk assessment adequately identifies and evaluates potential impacts of the change, and<br />

--<strong>The</strong> implementation plan is adequate to address revision of relevant procedures, equipment specifications and<br />

highlight those controls that must be implemented prior to commencement and/or continuation of work.<br />

• Managers must ensure that risks from a proposed change have<br />

been formally assessed and reviewed by competent technical and<br />

operational personnel.<br />

• An authorisation framework for the approval of the change must<br />

be established commensurate with the potential risks associated<br />

with the implementation of the change.<br />

• Prior to the commencement and/or continuation of work the<br />

responsible person for the site or facility must verify that the<br />

controls are adequate and in place.<br />

• Where extension to approved durations for a temporary change<br />

is required, a formal review must be undertaken and approval<br />

obtained.<br />

• Circumstances where the <strong>Tullow</strong> and Contractor’s management<br />

of change system both apply an interface review and document<br />

must be established to clearly identify jurisdiction of each system.<br />

Page 20


Rule 9<br />

DRIVING SAFETY<br />

Intent<br />

To provide a standard for the management of risks associated with driving and ensure that the procedures established by<br />

the Business considers the identification and control of people and equipment transported by vehicles.<br />

Requirements<br />

• Vehicle and journey selection must be based on a risk assessment taking account of tasks, application and<br />

environmental conditions.<br />

• Daily and pre-use checks must be performed on all <strong>Tullow</strong> owned and leased vehicles prior to their use.<br />

• A formal inspection and preventative maintenance system must be in place to ensure that vehicles are maintained in a<br />

safe and roadworthy condition, and as a minimum serviced in line with the vehicle manufacturer’s service schedule.<br />

• Drivers and passengers must always wear a three point seatbelt while the vehicle is in motion.<br />

• Vehicles used off-road must have roll-over bars/protection.<br />

• All 4x4 and other heavy vehicles must be fitted with reverse alarms and warning lights.<br />

• For light vehicles (i.e. not lorries or trucks) drivers airbags, and where available as a manufacturers fitted item,<br />

passengers airbags must be fitted.<br />

• Mobile phones, whether hands free or not, must only be used by the driver of a vehicle whilst the vehicle is stationary<br />

and in a safe location.<br />

• Drivers must obey speed limits and comply with applicable host country and site road <strong>rules</strong>.<br />

• Drivers must be appropriately licensed, trained and medically fit to operate the specific vehicle.<br />

• Drivers must adjust their speed to account for prevailing weather conditions. If adverse weather conditions persist and<br />

it is deemed unsafe to continue to drive, the driver must cease driving, pullover to a safe location until weather<br />

conditions improve.<br />

• No night driving outside of city limits is allowed unless in an emergency or with prior risk assessment and approval by<br />

the Country Manager or nominated Incident Responsible Person.<br />

• Drivers must not operate a vehicle while under the influence of drugs, alcohol or medication that could effect their<br />

ability to drive.<br />

• Drivers must not operate vehicles when fatigued or for excessive hours without sufficient rest, as defined by the <strong>Tullow</strong><br />

and/or site specific requirements.<br />

• Material and/or equipment must be adequately secured or physically separated from the vehicle occupants.<br />

• Loads must be physically secured and must not exceed manufacture design specification or legal limits for the vehicle.<br />

• Individuals must not approach a vehicle without establishing visual contact or communication with the vehicle operator<br />

to establish it is safe to approach.<br />

Page 21


<strong>Tullow</strong> Safety Rules<br />

Rule 10<br />

HAZARDOUS MATERIALS<br />

Intent<br />

To provide a standard for the management of risks associated with hazardous materials and ensure that the procedures<br />

established by the Business considers the identification and control of processing, storage, handling, transportation<br />

and disposal of hazardous materials.<br />

Requirements<br />

• An inherently safe approach to the use of hazardous materials<br />

must be adopted, where by the use, transportation and storage<br />

of hazardous materials should be eliminated or substituted for<br />

less hazardous materials, where appropriate.<br />

• A register of hazardous materials at a site/facility must be<br />

maintained and must at least include material names,<br />

type, volumes and Material Safety Data Sheet (MSDS).<br />

• <strong>The</strong> use of hazardous material on a site / facility must be<br />

performed under a written work permit and by competent<br />

person(s).<br />

• A task risk assessment must be conducted for the use of<br />

hazardous materials with all personnel involved in or potentially<br />

impacted by the work.<br />

• First aid and material provisions must be adequate and in place<br />

for mitigating any potential hazardous material spills.<br />

• Hazardous materials must be stored, transported, handled and<br />

disposed of correctly and in accordance with the manufacturer’s<br />

recommendations.<br />

• Hazardous materials must be segregated from and not come into<br />

contact with incompatible materials.<br />

• Labelling must be in place on all storage areas, vessels,<br />

containers and tanks, as per appropriate national or<br />

international standards.<br />

• A process must be in place to ensure that up-to-date MSDS<br />

are readily available to all personnel involved in the<br />

transportation, storage, handling, use and disposal of hazardous<br />

materials on the site / facility.<br />

• Appropriate PPE provisions must be available as defined by the<br />

relevant MSDS and must be fitted to the specific user, stored in a<br />

clean area, and maintained and inspected on a regular basis.<br />

• Access to areas where hazardous materials are stored and<br />

handled must be controlled and monitored, including process areas where hazardous materials may be released under<br />

certain operational circumstances.<br />

• Storage and handling of hazardous materials and execution of activities must consider the site / facility hazardous area<br />

classification layout (including ventilation).<br />

Page 22


Rule 11<br />

CONTRACTOR MANAGEMENT<br />

Intent<br />

To ensure the Business defines procedures that clearly describe the work scope, and evaluate, select and manage<br />

contractor services prior, during, and upon completion of the contracted work. This process will include identification of<br />

hazards and assessment of risk associated with the contract scope.<br />

Requirements<br />

• A clearly defined work scope must be developed, documented and communicated to the Contractor.<br />

• <strong>The</strong> hazards and risk associated with the work must be assessed.<br />

• Prior to selection of a Contractor, their EHS capabilities must be assessed and evaluated to provide assurance that the<br />

contractor is suitable to perform the work safely and in accordance with <strong>Tullow</strong>’s objectives.<br />

• <strong>The</strong> EHS capability evaluation must consider:<br />

--EHS management systems in place to manage and mitigate risks.<br />

--EHS record.<br />

--Training and competency of personnel assigned to perform the work.<br />

--Ability to demonstrate a positive EHS reporting system and culture.<br />

--Degree of autonomy in executing the work scope.<br />

• <strong>The</strong> <strong>Tullow</strong> contract owner is responsible for ensuring that the Contractor executes the work in accordance with the<br />

requirements defined in the scope, contract and relevant procedures.<br />

• Prior to the execution of work, the <strong>Tullow</strong> contract owner must ensure that Contractor personnel are:<br />

--Aware of the scope of work and associated hazards.<br />

--Adequately trained and competent to safely execute the work.<br />

--Aware of the <strong>Tullow</strong> EHS Policies and Procedure and the <strong>Tullow</strong> Safety Rules and agree to the execution of the<br />

work in accordance with these <strong>rules</strong>.<br />

--Aware of the system for reporting incidents, near misses and hazards.<br />

--Supervised on site.<br />

• <strong>The</strong> management system or its relevant components to be used to manage a scope of work must be identified and<br />

understood by both parties. This may require bridging procedures between <strong>Tullow</strong> and the Contractor.<br />

• Contractor performance must be periodically evaluated during the execution and upon completion of the contracted<br />

scope of work.<br />

• Areas of inadequate performance must be addressed during the execution of the contracted work scope and any future<br />

contractor evaluations.<br />

Page 23


<strong>Tullow</strong> Safety Rules<br />

Rule 12<br />

ENVIRONMENTAL MANAGEMENT<br />

Intent<br />

To ensure that processes and procedures are implemented by the Business that eliminates and/or minimises potential<br />

environmental harm, while satisfying, as a minimum, applicable host country regulatory environmental requirements and<br />

commitments made in <strong>Tullow</strong> Oil’s Environmental Standards (toes).<br />

Requirements<br />

• Environmental impacts resulting from the execution of work must be identified and fully understood by all relevant<br />

stakeholders.<br />

• All incidents that have the potential to impact the environment must be immediately reported in accordance with the<br />

company incident reporting process.<br />

• A waste management plan must be developed to ensure that all waste streams resulting from the execution of work<br />

are identified and managed.<br />

• A discharge plan must be developed to ensure that all discharges resulting from the execution of work are identified<br />

and managed in accordance with the applicable host country regulatory requirements.<br />

• Equipment designed for the monitoring of discharges must be calibrated and inspected in accordance with the<br />

manufacturer’s recommendations or applicable host country regulatory requirements, whichever is the higher standard.<br />

• All sites / facilities must maintain up to date oil spill response plans that identify and evaluate credible foreseeable<br />

scenarios that could potentially result in significant environmental damage.<br />

• All sites / facilities must have sufficient competent resources and equipment allocated to:<br />

--Contain potential spills at source and eliminate or mitigate escalation.<br />

--Clean and dispose of spills immediately at the primary and secondary containment points.<br />

--Clean-up, dispose and mitigate spills immediately that have inadvertently entered the eco-system.<br />

• Foreseeable environmental accident scenarios must form part of the overall site / facility drills and exercise schedule.<br />

• <strong>The</strong> Business procedures must clearly identify and communicate the appropriate host country regulatory permit<br />

requirements and the associated roles and responsibilities to meet these permit conditions.<br />

Page 24


Rule 13<br />

HEALTH AND HYGIENE<br />

Intent<br />

To ensure that procedures are implemented by the Business that identifies, evaluates, and eliminates and minimises<br />

potential health and hygiene risks, while satisfying, as a minimum, applicable relevant host country regulatory health and<br />

hygiene requirements.<br />

Requirements<br />

• Health and hygiene risks associated with physical, chemical,<br />

biological and ergonomic exposures must be identified, risk<br />

assessed and fully understood by relevant stakeholders.<br />

• All incidents that have the potential to impact the health<br />

and hygiene of individuals must be immediately reported in<br />

accordance with the company incident reporting process.<br />

• Medical assessments must be undertaken for all employees<br />

and contractors prior to the execution of specific site / facility<br />

activities.<br />

• Appropriate PPE must be provided where specific health<br />

hazards e.g. noise, respiratory etc.; cannot be eliminated or<br />

minimised to tolerable levels.<br />

• All sites / facilities must allocate sufficient resources to<br />

support emergency medical facilities and trained and<br />

competent individuals commensurate with the risk associated<br />

with the work being performed.<br />

• Supervisors responsible for creating and implementing work<br />

/ shift schedules must review and adjust schedules to ensure<br />

that individuals do not work excessive hours without providing<br />

sufficient rest periods.<br />

• Fatigue management must be considered when extended<br />

working hours are anticipated.<br />

• An individual must not work in excess of 16hrs within a 24hr<br />

period without sufficient rest, as defined by the <strong>Tullow</strong> and/or<br />

specific site requirements.<br />

• Malaria risk must be assessed for every country of operation<br />

and management plans must be in place where there is<br />

significant risk.<br />

• All personnel performing work on behalf of the Company and/<br />

or on a Company site must not do so while under the influence<br />

of drugs and alcohol and all personnel must comply with the<br />

local Intoxicant and Substance Abuse Policy.<br />

Page 25


<strong>Tullow</strong> Oil plc<br />

9 Chiswick Park<br />

566 Chiswick High Road<br />

London<br />

W4 5XT<br />

United Kingdom<br />

Email: info@tullowoil.com<br />

Tel: +44 (0) 20 3249 9000<br />

Fax: +44 (0) 20 3249 8801 T-EHS-STD-001 Revision 2

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