Defining the Purpose of an Occupational Health and Safety Agreement

Defining the Purpose of an Occupational Health and Safety Agreement

Essential Actions

Define the purpose of the occupational health and safety agreement in consultation with the contractor to ensure long-term support of the agreement.

Tip: The agreement should provide the operator and contractor the opportunity to declare that they will work together to provide a safe and healthful workplace.

Consider occupational health and safety priorities in relation to contractual requirements for technical and financial performance to determine where they fit in.

Tip: It may be appropriate and advantageous to coordinate occupational health and safety with other priorities within the contract (e.g., including occupational health and safety goals with other performance goals associated with bonuses or other recognition or reward plans).

Determine if the occupational health and safety agreement will form a separate agreement or become part of the overall project contract.

Tip: In some cases, a separate agreement helps emphasize occupational health and safety requirements while a single consolidated agreement helps integrate occupational health and safety into the overall project commitments.

Determine how the occupational health and safety requirements established within the agreement will be managed, monitored and audited.

Determine how authority and responsibilities assigned to contractors under agreements fit with the operator's overall management of occupational health and safety.

Tip: It is essential to understand how assignments of authority and responsibility to contractors might impact the operator's overall occupational health and safety management approach. For example, authority to spend money on safety equipment or ergonomic design assigned to one contractor should be considered in the operator's overall plan for these areas to ensure consistency and compliance with operator standards.

Defining the Contents of the Agreement

Essential Actions

Define the scope of the occupational health and safety agreement to include the following elements.

Description of the work to be executed and known hazards.

Operator and contractor expectations and responsibilities.

See also: 3.3.1 Guidance for Defining Responsibilities in an Occupational Health and Safety Agreement.

Risk management (e.g., hazard identification and mitigation).

Requirements for contractor occupational health and safety programs or compliance with operator programs (including health and safety rules, practices and site-specific procedures).

Insurance requirements and account status (e.g., general liability and worker compensation insurance).

Personal protective and safety equipment requirements (e.g., provision, maintenance and use).

First aid facilities and supplies.

Occupational health monitoring.

Specific procedures and contingency plans for hazardous materials and critical tasks.

Occupational health and safety communications (e.g., orientations, pre-job meetings, tailgate meetings and regular safety meetings).

See also: Element 9 Health and Safety Communications in the 8.0 Model Occupational Health and Safety Program for Contractors for definitions of meeting types.

Incident management, reporting and investigation.

See also: 3.3.2 Guidance for Defining Incident Management Requirements.

Monitoring, audit and inspection requirements.

Tip: It is essential that contractors participate in any audits or inspections of their occupational health and safety programs and worksites. This requirement should be included in the agreement.

Routine occupational health and safety reporting requirements.

Compliance with regulations and operator requirements.

Due diligence.

Worker competence, based on occupational health and safety training (including access to occupational health and safety training records).

Occupational health and safety committees.

Ensure the wording in the agreement is clear and understood by the contractor.

Review the occupational health and safety agreement in a pre-job meeting with the contractor to ensure both parties clearly understand their respective duties and responsibilities, and to review the occupational health and safety programs and requirements of the job.

Identify a supervisor, either from the operator or contractor staff, who will be responsible and accountable for ensuring compliance with all the occupational health and safety requirements.

Tip: In some companies, responsibility for ensuring compliance with health and safety requirements is assigned to both the contractor's general or project manager and the operator's manager with overall responsibility for managing the contract. This level of assignment ensures the management of health and safety requirements is fully integrated with the management of other contractual requirements.

Ensure that good two-way communication is established between the contractor and the operator.

Tip: This can be established through joint safety committees, joint safety meetings or team inspections and audits.

3.3.1 Guidance for Defining Responsibilities in an Occupational Health and Safety Agreement

Define key operator responsibilities to include:

providing safe work standards and practices that meet or surpass current legislation

promoting safe and healthful work practices

providing a safe and healthful work place

reviewing and evaluating the contractors occupational health and safety program and performance record prior to hiring

ensuring contractors are aware of and meet their responsibilities under applicable state and regional government legislation

ensuring everyone on the operators worksites is adequately trained and competent

ensuring everyone on the operators worksites follows safe work practices and works safely

assigning an operations representative to be responsible for all aspects of each project

assigning an occupational health and safety representative for each project

ensuring that subcontractors hired by the contractor to work on a project are qualified and trained to manage occupational health and safety issues with the same capability as the contractor

ensuring that the operators representative responsible for administrating the contract is also responsible for all occupational health and safety aspects of the contract

Define key contractor responsibilities to include:

providing safe work standards and practices that meet or exceed current legislation and the operators requirements

promoting safe and healthful work practices

ensuring employees and subcontractors are aware of and meet their responsibilities under applicable state and regional government legislation

ensuring employees and subcontractors are adequately trained and competent

ensuring employees and subcontractors follow safe work practices and work safely

assigning an occupational health and safety representative for each projectTip: The assignment of occupational health and safety representatives will vary depending on the number of workers on the worksite, the level of hazards present and local regulatory requirements.

3.3.2 Guidance for Defining Incident Management Requirements

Require contractors to have incident management plans or follow the operators plans.

Ensure plans include:

training, exercises and drills

risk-specific and worksite-specific response plans (e.g., fire, fatality, missing person)

incident reporting, investigation and follow-up

Require contractors to immediately report all incidents to the operators designate and cooperate and participate in all investigations and follow-up activities (e.g., action plans).

3.4 Background

Occupational health and safety agreements provide opportunities at the beginning of a project for both the operator and contractor to very clearly state their expectations and specific requirements. Through the negotiation process, the parties also have the opportunity to build a positive relationship and a means for communicating that can provide benefits throughout the project. The agreement itself provides very clear statements of how each party is to behave and can be used very effectively to monitor compliance and identify concerns before incidents happen.

All agreements should be prepared with legal counsel. Contractors, particularly smaller ones that rely on the operator to create the agreement, should obtain legal advice to ensure their expectations, requirements and interests are effectively addressed.

Once agreements are signed, contractors must ensure all their employees and subcontractors are prepared to meet their commitments. The operator can assist in this process but is not directly responsible for the competence of its contractors.

Model Occupational Health and Safety Program for Contractors8.1 Introduction

Effective occupational health and safety programs reduce injuries and loss, save time and money, improve production over the long term and contribute to a better working environment. Because contractors play such a large role in the oil and gas industry and typically experience many more injuries and fatalities than operators, it is essential they:

maintain effective occupational health and safety programs

provide their services in a manner that meets regulatory requirements and the requirements of the occupational health and safety programs of the larger companies for which they work

conduct reviews and audits of their programs and performance

assist operators in their reviews and audits of the contractor's programs and performance

The following model illustrates the key elements and topics that should be included within a contractor's occupational health and safety program. Oil and gas companies can use this model program as a baseline measure against which contractor occupational health and safety programs can be compared for contract awards. Where contractor programs are inadequate, operators can also give this model program to their contractors to use in developing or upgrading their occupational health and safety programs. Used in conjunction with assistance from operators, this model program can offer contractors an effective and efficient approach to improving safety performance. It also suggests tools for effectively managing occupational health and safety over the long term.

8.2 Program Elements

Element 1: Management and Leadership

Demonstrate the company's commitment to providing a safe work environment and ensuring workers meet minimum safety requirements by developing:

Statement of Commitment. Prepare a statement that presents the occupational health and safety goals and values of your company.

Occupational Health and Safety Policy. Develop an Occupational Health and Safety Policy that presents your company's intentions related to planning, compliance, responsibility, communication, training and performance. The policy should illustrate how these components are structured and implemented.

Occupational Health and Safety Responsibilities. Define the key occupational health and safety responsibilities of all levels of management within your company. Include the board of directors, president, various levels of management and field employees.

Management Visibility. Ensure company management is visibly committed to promoting occupational health and safety principles by including references to occupational health and safety in speeches, and communications and by visiting field locations to observe health and safety activities and provide feedback and input.

Advanced Safety Audits. Institute a program of advanced safety audits and ensure results of audits are continuously provided to employees and management.

Element 2: Hazard Identification and Control

Design a process for hazard identification and control to identify all workplace hazards and eliminate or reduce them to an acceptable level. Ensure the process includes assignment of responsibilities, identification and assessment of hazards, hazard severity ranking, training, an assessment of current hazard controls and plans for eliminating or reducing hazards. The process should also include verification of hazards already identified by the operator as well as any control measures planned or implemented to address them.

Element 3: Compliance with Existing Regulations and Operator Standards

Ensure that your company understands and is in compliance with all occupational health and safety regulatory requirements for the jurisdiction in which you work. Develop a process for keeping abreast of regulatory requirements, for disseminating requirements to company employees and subcontractors and for ensuring compliance with these requirements. Also ensure a process for defining communicating and enforcing standards set by your company that may go beyond regulatory requirements.

Element 4: Personal Protection Equipment

Provide, maintain and require the use of personal protective equipment in accordance with the hazards at the worksite and the operator's requirements.

To do this effectively:

identify all hazards that cannot be eliminated or reduced to an acceptable level

classify remaining hazards based on their potential impacts

select the most appropriate personal protective equipment and ensure:

all employees are trained in the use and maintenance of personal protective equipment

personal protective equipment is kept in good working order

personal protective equipment is used where appropriate

requirements are understood and enforced

Element 5: Occupational Health and Industrial Hygiene

Ensure measures are in place to implement industrial and occupational hygiene practices for long-term health. Establish appropriate practices based on an assessment of immediate hazards and long-term risk. Include surveys and inspections to identify and monitor hazards, training appropriate to the identified hazards, appropriate personal protective equipment, information related to the potential hazards and if possible methods for substituting hazardous chemicals with chemicals that are less hazardous.

Element 6: Inspections and Reports

Develop a program to record unsafe and unhealthful practices and to conduct routine and ongoing inspections of worksites to identify and locate areas that are sources for potential incidents. Through regular inspections and reporting, worksites can be closely monitored for hazards. Ensure the inspections and reports cover all known hazards and are:

specific to the worksite

specific to work activities relative to the potential risk to the contractors health and safety

specific to certain work groups, considering their exposure to occupational risks (physical, chemical, biological, ergonomic, etc.)

routine and ongoing

conducted by trained employees

Include in the program procedures for assisting the operator in any inspections it conducts while monitoring the contractor's occupational health and safety performance or program.

Element 7: Emergency Response

Describe your company's approach to emergency response planning and provide references to specific contingency plans that exist within your company. Ensure emergency response plans provide:

information on initial actions (i.e., First-hour Response)

risks covered by the plans

written procedures for all potential incidents (e.g., oil spills, bomb threats, explosions or fires, hydrogen sulphide or sweet gas release)

current lists of all company employees and external emergency contacts

procedures for reporting

a process for maintaining plans

a process for integrating your company's emergency response programs with the operator's and other contractors on site

Element 8: Competence and Training

Develop an occupational health and safety training program aimed at reducing injury and property damage. Ensure your training program is designed to increase the qualifications and skills of all employees and subcontractors working for your company. Be sure to include requirements for orientation for all new employees and subcontractors, responsibilities of particular tasks beyond general occupational health and safety regulations, a system to log and track training, and a review process to ensure consistent performance.

Element 9: Health and Safety Communications

Ensure your occupational health and safety program is clearly communicated to all employees through the most effective method to efficiently convey the message. Consider the use of:

regular occupational health and safety meetings that include all employees involved (e.g., operator employees as well as contractors and their employees and subcontractors)

pre-job meetings to review the details of each particular job with employees and subcontractors before the job starts

daily tailgate meetings to review particular safety issues for the coming shift

field safety meetings

newsletters, performance reviews and pay envelope inserts

At a minimum, hold regular safety meetings to review facility and job hazards, incidents, near misses, site-specific rules and procedures and applicable policies.

Element 10: Incident Prevention, Reporting and Investigation

Ensure your company has a system for preventing, accurately reporting and investigating occupational diseases, incidents, near misses and spills and investigating incidents to identify root causes and facilitate actions to prevent recurrence.

Element 11: Safe Work Practices and Procedures

Ensure your company has a system to create, maintain and effectively communicate safe work practices and procedures. Used effectively, practices and procedures allow employees to complete operational tasks without incurring personal injury or property damage. Make practices and procedures specific to required tasks (e.g., confined space entry) and identify the potential hazards that may be present. Include information on how workers are to conduct the work in a safe and healthful way, what skills or training they need to be properly qualified to conduct the work, and how they are to control risks they cannot eliminate. Ensure this information is posted and distributed in a practical and readily available format.

Element 12: Subcontractor Management

Ensure that there is a program for subcontractor management that is consistent with, or adopts, the operator's occupational health and safety rules and requirements. Often there is little or no distinction between contractor employees and operator employees so it is expected that contractor and subcontractor employees will conduct themselves in a safe and professional manner consistent with the operator's employees. Ensure your employees and subcontractors understand the rules of conduct and are familiar with the working environment.

Element 13: Administration and Management of Change

Facilities, operations and systems are subject to continual change and improvement. Management of Change is a process for ensuring the overall impacts to operating systems are understood and result in the appropriate controls being implemented to protect company people and assets. Ensure there is a process for managing changes to facilities, operations and systems as well as for all new projects and that the process must be followed consistently.

Element 14: Safe Work Permits

Introduce a process of safe work permits to control, coordinate and communicate work activities that are classified as hazardous non-routine tasks. Ensure employees and subcontractors complete permits for all tasks considered non-routine. Where work is not completed by the expiration time, ensure the permit is renewed. Return the permit upon completion of the job. In addition, ensure this element contains specific instructions for the responsibilities of operators and contractors with respect to safe work permits when both parties have work permits.

Element 15: Simultaneous Operations

Ensure your system contains specific guidance on ensuring that health and safety requirements are met during situations where simultaneous operations are occurring (e.g., drilling w/rigging). When simultaneous operations are underway, the level of risk can be elevated and it is imperative that extra precautions are instituted to deal with increased number of hazards and the elevated levels of risk.

Guidance for Defining Occupational Health and Safety Qualification Criteria

Define requirements for general occupational health and safety qualification criteria including:

overall occupational health and safety experience and history (e.g., health and injury history of workers)

financial capacity (e.g., ability to meet liabilities resulting from potential incidents)

necessary occupational health and safety equipment to complete the work safely

preventive maintenance for all equipment

available staff and subcontractors and their respective qualifications

required licenses

lines of authority

occupational health and safety plans and procedures

programs for identifying, monitoring and managing potential causes of occupational health impacts and diseases

programs for identifying and monitoring non-occupational disease indicators (e.g., smoking, drug and alcohol abuse) and their impacts on the workplace

commitment and programs for encouraging healthy lifestyles (e.g., employee fitness and assistance programs) at and away from work

general liability and worker insurance information (e.g., coverage, status and statistics)

human resource skills

logistics necessary for the job

reporting of past fines and penalties

reporting of past safety records (e.g., incident statistics and documentation)

reporting of past health records (e.g., statistics and frequency indicators of absences due to health issues)

Define minimum training and certification requirements for contractor employees and subcontractors, including:

first aid and cardio-pulmonary resuscitation

prevention of endemic and regional diseases

fire prevention and control

confined space entry

prevention of specific risks (hydrogen sulphide, high-voltage works, high-pressure works)

extreme weather survival

defensive driving

ground disturbance (i.e., prevention of contact with underground utilities)

ergonomic design and evaluation of work processes and workplaces

Establish the level of emergency preparedness, response and recovery necessary, including:

overall emergency response capabilities (e.g., training, exercises, response plans and access to equipment)

specific incident response plans for preventing further deterioration once an incident occurs (e.g., stabilization actions that help to prevent the incident from escalating)

specific mitigation plans for eliminating the risk once the situation has been stabilized

specific recovery plans to reduce the long-term risk and return to normal operations

2.2.2 Guidance for Developing Effective Questionnaires

Ensure questionnaires focus on evaluating the occupational health and safety performance of potential contactors.

Cover all occupational health and safety concerns and activities that may be relevant, not only those on specific worksites.

Have a responsible individual, preferably a line manager, validate the questionnaire before sending it out.

Ask respondents to provide detailed answers and supporting documents as appropriate to validate their responses.

Encourage contractors to identify where they surpass your company standards and areas where they do not meet the required standards.

If necessary, contact respondents to clarify any questions arising from their answers to the questionnaire.

Define a scoring mechanism to ensure consistency in assessment of respondent answers.

Tip: ARPEL has already developed a detailed questionnaire and scoring mechanism for evaluating contractor performance. These can be used as a base for developing a more specific questionnaire for use as part of a pre-qualification process in the selection of contractors.

See also: Figure 3: Questionnaire for Contractor Occupational Health and Safety Pre-Qualification, and ARPEL Report on "Safety Issues for Contractors in the Upstream and Downstream Sectors of the Oil and Gas Industry", 2000, Appendix A Evaluation of Contractors.

Figure 3: Questionnaire for Contractor Occupational Health and Safety Pre-Qualification

Section

Questions

Yes

No

Comments

Management and LeadershipAre senior managers personally involved in OHS management through OHS activities, objective setting and monitoring? How?

Can you provide evidence of commitment to OHS at all levels in your organization?

Do you promote a positive culture towards OHS issues? How?

Does your company have an OHS policy? (please attach)

Is there a senior manager responsible for OHS in your organization? Who? (name, position)

Is your policy statement made available to all employees? How?

Do you advise employees and subcontractors of changes in the policy? How?

Do all levels within your company have specific OHS responsibilities?

Do you set and enforce OHS performance standards?

Hazard Identification and ControlDo you have techniques within your company for identifying, assessing and controlling hazards? Please describe.

Do you have systems in place to monitor the exposure of your employees and subcontractors to chemicals or physical agents?

Do you advise employees and subcontractors of hazards related to chemicals, noise, radiation etc.? How?

Regulatory ComplianceDoes your company have a system for understanding and ensuring compliance with applicable regulatory requirements?

Do you identify new industry or regulatory standards that are applicable to your operations?

Occupational Health and Safety RulesDoes your company have a set of occupational health and safety rules?

Do you have a drug and alcohol policy in your company?

Is there a process for enforcing rules?

Personal Protective Equipment (PPE)Does your company have a policy for use of personal protective equipment (PPE)?

Are all employees and subcontractors trained in the use and maintenance of PPE?

Is the PPE in your company properly maintained and in good working order?

Are requirements for use of PPE understood and enforced?

Industrial and Occupational HygieneDoes your company have measures in place to protect the long-term health of employees and subcontractors?

Does your company have a process for identifying and reducing long-term health and hygiene risks?

Are your employees provided with PPE related to health and hygiene risks?

Occupational Health and Safety Inspections and ReportsDoes your company have a program for conducting routine and ongoing inspections of worksites?

Do you have trained employees to conduct these inspections?

Does your company have a process for monitoring performance of employees and subcontractors?

Do you maintain records of incidents and OHS performance?

Are the results of inspections made available to employees and subcontractors? How?

Emergency ResponseDoes your company have emergency response plans?

Are the plans specific to the risks faced in your operations?

Are employees and subcontractors trained to respond to emergencies?

Are emergency plans tested and upgraded through tabletop and field exercises?

Competence and TrainingHave senior managers received OHS training related to their responsibilities?

Does your company have a process for ensuring new employees have the necessary OHS training?

Does your company provide orientations to train new employees or subcontractors?

Is there a program to ensure that existing employees and subcontractors maintain their expertise through training?

Is specialized training provided to employees or subcontractors who deal with specific hazards not covered in routine training?

Health and Safety CommunicationsDoes your company have an OHS Committee at the senior level of management?

Does your company have processes for communicating OHS information?

Do you hold regular OHS meetings with all employees and subcontractors?

Do you hold pre-job meetings to review details of each particular job?

Do you hold field safety meetings?

Do you have other methods for communicating OHS information? Please describe.

Incident Reporting and InvestigationDo you have a requirement for reporting and investigating incidents?

Are near misses reported?

Are findings of investigations used to correct problems?

Are findings of investigations communicated to employees and subcontractors? How?

Who is responsible for conducting incident investigations?

Safe Work Practices and ProceduresDoes your company have an OHS manual that describes approved work practices and procedures? If yes, please provide copy.

Do you have a process in place to ensure that company practices and procedures are followed? Please describe.

Does your company have practices or procedures for preventing road or vehicle incidents?

Please provide any additional information or comments.

2.3 Evaluating Occupational Health and Safety in the Bidding Process

Essential Actions

Define a method for evaluating occupational health and safety criteria that:

can be documented

provides measurable results

is consistent with evaluation methods used to assess technical capability and price

establishes priorities for the various criteria

See also: 2.3.1 Guidance for Evaluating Occupational Health and Safety Program Documentation.

Consider using a points system to evaluate occupational health and safety criteria.

See also: 2.3.2 Guidance for Measuring Quality in Occupational Health and Safety Criteria and Figure 4: Sample Evaluation Matrix.

Pay particular attention to:

quality of contractor occupational health and safety programs

knowledge of risks and remedial actions

historical records of the contractor's occupational health and safety performance (e.g., incident statistics)

how the contractor plans to manage the interaction between your company's occupational health and safety management system and the contractors occupational health and safety management program

If a contractor doesn't have a documented occupational health and safety plan, ask the contractor to provide a description and outline of a plan it would be able to develop and implement if it were awarded the project.

See also: 8.0 Model Occupational Health and Safety Program for Contractors.

For those contractors who have previously been used by your company, assess their performance through the use of closeout reports and other historical records.

2.3.1 Guidance for Evaluating Occupational Health and Safety Program Documentation

When reviewing contractor occupational health and safety programs, look for documentation that describes information about:

current occupational health and safety goals and objectives as well as progress toward them

overall occupational health and safety management system components (e.g., policies, site-specific procedures, training, professional qualification, hazard identification and control, incident management) and how they are interrelated

objectives of occupational health and safety plans developed for past jobs as well as descriptions of any associated hazards and the controls used

current contracting procedures and management processes for interacting with operators

past and current compliance with legal, normative and contractual issues

strategies for supervision

past interactions with operator plans and programs (e.g., emergency response plans)

types and schedules of past occupational health and safety training programs as well as descriptions of past operator and contractor training requirements

Involve the contractor directly in the review of the documentation to provide clarifications as necessary.

2.3.2 Guidance for Measuring Quality in Occupational Health and Safety Criteria

Assign a numeric value to each item in your occupational health and safety criteria (e.g., 5, 10 or 15).

Prioritize criteria according to the assigned numeric value (e.g., criteria worth 15 points are more important in the evaluation process than criteria worth fewer points).

Chart the criteria in order of priority in a matrix.

Provide columns for each of the bidding contractors.

Apply a score to each criterion for each contractor to the maximum of the assigned value for the criterion.

Evaluate the scores to determine which contractors scored highest in the areas of greatest priority.

Add the scores and analysis into the overall bid analysis (e.g., price and technical capability).

See also: Figure 4: Sample Evaluation Matrix.

Figure 4: Sample Evaluation Matrix

OHS CriteriaMaximum Potential ScoreContractors

ABCDEFCurrent OHS goal

10

Progress towards goals

15

OHS management system

15

Plans for interacting with operators management

5

Past and current compliance issues

10

Reactive indicators

10

Proactive indicators

15

Strategies for supervision

5

Past interaction with operator plans and programs

15

Training programs

Etc.

Etc.

Total

Ranking6

3

5

1

4

2

*Note: Maximum score reflects the importance of the criteria. These can be adjusted based on the operators view of the importance of each criterion. In addition, criteria can be added or deleted from the list based on the operators assessment of their importance in the evaluation process.

2.4 Applying the Results to Contractor Qualification, Re-Qualification and Selection

Essential Actions

Consider the results of your evaluation of occupational health and safety criteria in conjunction with:

technical competence

ability to meet schedule

cost

overall financial capacity to provide the resources necessary to complete the job and meet occupational health and safety liabilities

documented appraisal from previous work with the company

Tip: Relative weighting of occupational health and safety criteria will vary from operator to operator.

Meet with the contractor(s) that achieve the highest ratings to:

verify their results

review any areas of concern and determine how the contractor can resolve them

Make a final selection based on the results of the analysis and the outcome of any followup meetings or discussions.

If you select a contractor that does not have its own occupational health and safety program, either provide them a copy of relevant components from your companys program or assist them in developing their own program.

See also: 8.0 Model Occupational Health and Safety Program for Contractors.

If there are gaps between the your company's program and the contractor's program, fill those gaps by creating a Bridging Document.

See also: 2.4.1 Guidance for Creating a Bridging Document.

Give those evaluated contractors who did not reach the minimum qualification feedback as to why they did not qualify and provide information to show how, by correcting these deficiencies, they may qualify for future work.

2.4.1 Guidance for Creating a Bridging Document

Create a document that recognizes the strengths in both your health and safety program and the program of the contractor.

Specify areas where further communication is needed between the two organizations, including:

a statement describing the services to be provided by the contractor

the contractor's health and safety policy statement

a section defining the scope of the Bridging Document

description of the contractor's occupational health and safety management system including:

additional roles and responsibilities resulting from the interaction between the operator and the contractor

a description of procedures that will be used to complete work and how the operator's and contractor's procedures will integrate

specific practices for risk assessment, vehicle safety, management of change, worksite inspections, audits and incident reporting and investigation

a description of the contractor's occupational health programs

a description of the operator's training and competency requirements that the contractor is expected to meet.

key performance indicators that the contractor is expected to use to report safety performance

reporting requirements for all aspects of health and safety performance

emergency procedures that will be used by the contractor to respond to incidents on the operator's worksite

a description of document management procedures and activities designed to minimize the amount and type of documentation to be reviewed by either party

management review procedures that clearly define the management review system that will be used during the contract

2.5 Background

Through effective evaluation of contractor occupational health and safety performance and programs, oil and gas companies can significantly increase the safety and productivity of their worksites while improving industry performance overall. By allowing occupational health and safety performance to play a significant role in the selection of contractors, operators have the ability to directly support positive performance through their hiring decisions. They can also use the selection process to asses the financial capacity of contractors to cover liabilities resulting from poor occupational health and safety performance or unexpected incidents.

Screening for occupational health and safety criteria at the pre-qualification stage helps to ensure that bidding contractors share your company's commitments to providing a safe workplace. Scoring systems similar to those used to evaluate technical capabilities can be used to evaluate the results of the occupational health and safety screening process, and contribute to the selection of contractors that will be invited to provide a formal bid.

Questionnaires that describe detailed and measurable occupational health and safety criteria are very useful both in communicating your requirements to potential contractors and in providing a baseline for assessing results. The scores drawn from the results of the questionnaires can be added to the scores from evaluations of technical capabilities and price to provide an overall score for your selection process.

The most important criteria to measure are the quality of the contractor's occupational health and safety program and the contractor's knowledge of potential risks involved in the work. However, in some cases, a contractor may not have its own documented program in place and still have a very good performance record because it has followed the programs of the operators for whom it has worked. This approach provides an acceptable alternative to requiring a contractor to develop a program, provided the operator's program meets reasonable criteria.

Work Ethic Employees are expected to perform their duties to the maximum of their ability and deliver acceptable objectives to the company.

Safety Employees are expected follow health and safety guidelines and procedures and to be aware of and report any potential hazards.

Confidentiality Unauthorised disclosure of company information regarding both the company and its employees is prohibited.

Personal Conduct Employees are expected to act in a courteous, respectful manner at all times when dealing with fellow employees, suppliers, contractors, customers and the general public. Employees are expected to adhere to dress and presentation standards in accordance with the company guidelines.

Fair Business Employees are expected to behave honestly and openly and with integrity in their dealings with the company. Employees must not mislead or defraud fellow employees, customers, suppliers, contractors or Seven in general.

Working Environment Everyone at Seven has a legal obligation not to discriminate or harass any employee, agent, contract worker, supplier or visitor.Employees are not permitted to smoke on company premises, except in designated smoking areas.

Gifts, Conflict of Interest and Ethical ConductOther than in the course of routine business, employees must not to accept cash, gifts or gratuities from a supplier, agent, customer or contractor for any reason. Employees must not put themselves in a position where their interests conflict with those of the company.

Obligation to Disclose Relevant Information Employees are obliged to inform the company of any change in their circumstances that may affect their ability to perform their normal duties.

Use of Company Assets Employees must not deliberately misuse or damage company property in their possession, care or custody and must not use company assets, intellectual property or the services of other employees (including contractors) for private use or gain.

Change The company expects employees to remain open-mined about change in the work place and to collaboratively support and embrace new ideas and programs.

Environment Employees are responsible for maintaining and protecting the environment. Employees are expected to consider the impact of their actions on the environment and local community, including in relation to the disposal of waste, use and storage of chemicals and use of natural resources.

Business Conduct Guidelines for Employees and Officers

0. Compliance with the Law and Respect for Human Rights

Employees should comply with all applicable laws and regulations, whether domestic or foreign, and should conduct themselves in an ethical and responsible manner in the communities in which they perform their duties for the Company.

Employees should respect the cultures, customs and history of every country to which they are brought into contact while performing their duties for the Company.

Employees should respect human rights and should not discriminate between persons based on reasons of race, creed, sex, social status, religion, nationality, age or physical or mental disability.

1. Office Environment and Sexual Harassment

In order that Employees, with individuality and diversity, perform their duties for the Company to the best of their ability, the Employees should respect the character and individuality of one another and make every effort to ensure that the office is an open and comfortable environment in which to work.

The Employees should not engage in any sexual harassment or any other behavior which may appear to be sexual harassment.

Employees should not disturb the sound discipline, environment and good order of the office by conduct which is contrary to public order and good moral standards.

2. Compliance with Antitrust Law, etc.

Employees should not conduct themselves in their dealings with the Company's competitors in a manner which results in an illegal restraint of trade, such as collusion with a view to the fixing of price levels or levels of production or supply or the division of markets.

Employees should not collude with the Company's competitors in any tender such as determining a successful bidder or contract price.

Employees should not engage in unfair trade practices, such as boycotts, resale price maintenance or tie-in agreements.

Employees should not unreasonably damage the interests of sub-contractors of the Company through the unjustified demand to reduce purchase prices, rejection to receive goods, return of goods or delay of payment of purchase prices.

Employees should promote fair, transparent and free competition, and carry out appropriate business transactions.

3. Conflicts of Interest between Employees and the Company

Employees should not participate in any activity which creates or appears to create a conflict between his or her personal interest and the Company's business interest, such as working for the competitors or the customers of the Company or dealing with the Company for their own behalf.

Employees should not use the Company's property, assets or information system for any purpose other than that of the Company's business.

Employees should not, without the prior consent of the Company, be engaged in any other occupation.

Employees should not, without the prior consent of the Company, acquire any stock of the customers of the Company or the companies to which the Company makes, or is expected to make, investment where such stock is not listed in any securities exchange.

4. Gift and Favor

Employees should not render public officials or persons in a similar position any economic favor such as money, gift or other favor in return for performance of their duties.

Employees should not render public officials or persons in a similar position of a foreign country any economic favor such as money, gift or other favor for the purpose of securing any improper advantage.

Employees should not pay any agent, advisor or consultant any commission which they have reason to know will be used for influencing public officials or persons in a similar position in an unlawful manner.

Employees should not render employees or officers of customers of the Company any economic favor such as money, gift or other favor, the value of which is greater than a generally accepted commercial level at the relevant locale, nor should they receive such economic favor from officers of customers of the Company.

5. Treatment of the Company's Information

Employees should hold any secret information of the Company, customer information and personal information as strictly confidential and should not divulge such information to any third party, nor should they use the same for any purpose other than that of the business of the Company.

Employees should treat any secret information divulged by a third party as in the same manner as they treat the secret information of the Company.

Employees should not infringe the intellectual property rights of any third party, including the copying of computer software, without express permission of such third party.

Employees should actively and appropriately disclose in a timely manner any information of the Company in accordance with any laws and regulations protecting the interests of investors including the rules of any relevant stock exchanges.

If Employees become acquainted with any information of the Company or its customers which may materially influence the judgment of investors in the Company or in such customers, they should not sell or purchase any stock of the Company or stock of such customers unless and until such information becomes public and in any event Employees should comply with all relevant insider dealing laws.

Employees should not illegally acquire or use any secret business information of a third party.

6. Compliance with Procedures for Export and Import and Other Applicable Laws

Employees should comply with the procedures for export and import and should not import prohibited goods.

For the purpose of securing the international peace and security, Employees should comply with not only applicable laws and regulations but also internal rules of the Company for the international security trade control when they export goods to any foreign country.

Employees should be aware of laws and regulations applicable to the business of goods or services in which they are engaged.

7. Company Fund and Financial Reporting

Employees should properly manage the assets and funds of the Company and use them only for appropriate business related purposes. Employees shall not establish or maintain undisclosed or unrecorded assets or funds.

Employees should make timely and appropriate accounting reports, ensuring the accuracy of the reports, and should not make any false or misleading entries in the Company's books and records.

8. Political Donation and Other Contributions

Employees should comply with applicable laws and regulations in the event that they make political donations and other contributions to various entities.

9. Social Contribution

As good corporate citizens, Employees should make every effort to establish relationships of trust with all stakeholders of the Company with whom they have dealings for the continued improvement of corporate value, while carrying out their duties for the Company and further should try, where possible, to make a positive contribution to the communities in which they perform such duties to work toward building a sustainable society.

Employee responsibilities should extend beyond economic contributions, and Employees need to be globally active on a consolidated base in different fields, with emphasis on international exchange (regional contribution), education (cultivation of human resources), and the environment.

10. Protection of Environment

Employees should comply with all laws and regulations relating to the protection of the environment and strive to reduce the burden on the environment by paying maximum attention to the efficient use of resources and energy.

Employees should strive to develop the procedures for evaluating the environmental impact of new business and to achieve the optimum balance between economic benefit / return and environmental protection.

Employees should contribute to the development and spread of environmentally friendly technology and always take into consideration issues of safety.

11. Action against Antisocial Group

In the situation where an antisocial group makes unreasonable demands on the Company, Employees should firmly refuse such demands and should not resort to an easy monetary settlement.

Employees should never deal with any antisocial group or any entity that is connected with such antisocial group.

12. Report and Sanction

If an Employee finds evidence of violation of these guidelines, he or she should inform the Administrative Division concerned, Compliance Department of Legal Div. (the secretariat of the Compliance Committee), a Compliance Officer of Business Unit, Chief Compliance Officer of Regional Business Unit, a person in charge of Compliance of each Div. or Branch, or any other of his or her superiors.

If an Employee desires to inform anonymously, he or she may do so to the outside lawyers or a third-party hotline.

Employees should cooperate in any investigation of such alleged violation. If, as a result of the investigation, it becomes clear that there was a violation of these guidelines, sanctions will be imposed on the violator or his or her superiors in accordance with the regulations of the Company.

The Company ensures that no retaliatory action will be taken against an Employee for informing of such violation or cooperating in such investigation and makes every effort to prevent such informant and any Employees cooperating in such investigation from suffering any disadvantage at his or her office.

DOs

1). Maintain absolute integrity at all times.

2). Maintain absolute devotion to duty at all times

3). Those holding responsible posts shall maintain independence and impartiality in the discharge of his duties.

4). Maintain a responsible and decent standard of conduct in private life.

5). Render prompt and courteous service to the public.

6). Observe proper decorum during lunch break. Avoid moving out of CIPET premises during lunch break. Any accident to employees outside CIPET premises during lunch break is at their own risk.

7). Report to superiors the fact of your arrest or conviction in a Criminal Court and the circumstances connected therewith, as soon as it is possible to do so.

8). Keep away from demonstrations organized by political parties in the vicinity / neighbourhood of your offices.

9). Maintain political neutrality.

10). Manage private affairs in such a way as to avoid habitual indebtedness or insolvency.

11). If any legal proceedings are instituted for the recovery of any debt due from you or for adjudging you as an insolvent, report the full facts of such proceedings to the Competent Authority.

12). Act in accordance with CIPET policies, orders, rules, regulations, guidelines etc. applicable from time to time.

13). In performance of duties in good faith, communicate information to a person in accordance with the Right to Information Act, 2005 and the rules made thereunder.

14). Report to the Personnel department about change in status w.r.t. marriage, conversion to other religions, name and addition / deletion of family members.

15). Report details in various declaration forms (Home town etc.) with accuracy.

16). Ensure that all medical claims are submitted for reimbursement within 3 months of completion of treatment.

17). File your income tax returns in time.

18). Apply for leave of any type well in advance as per applicable rules.

19). Report to the Personnel department if your spouse is employed in Central / State Govt. / PSU / Autonomous Bodies / any other government service.

20). File all your nominations with accuracy (P.F., Gratuity, E.L., EDLI etc.)

21). When seeking employment in other Government organizations, forward your applications thru proper channel.

22). Apply / Renew for passports thru proper channel after obtaining No Objection Certificate from CIPET.

DONTs

1). Do not make joint representations in matters of common interest.

2). Do not be discourteous, dishonest and partial.

3). Do not practise untouchability.

4). Do not associate yourself with any banned organizations.

5). Do not join any association or demonstration whose objects or activities are prejudicial to the interest of the sovereignty and integrity of India, public order or morality.

6). Do not give expression to views on Indian or foreign affairs, while visiting foreign countries.

7). Do not get involved in unauthorized communication of any official document or any part thereof or classified information to any persons to whom you are not authorized to communicate such document or classified information.

8). Do not join or support any illegal strike.

9). Do not enter into any private correspondence with foreign embassies or Missions / High Commissions.

10). Do not accept lavish or frequent hospitality from any individual, industrial or commercial firms, organizations either foreign or Indian having official dealings with you.

11). Do not give or take or abet giving or taking dowry or demand any dowry directly or indirectly from the parent or guardian of a bride or bridegroom.

12). Do not lend money to or borrow money from or deposit money as a member agent, with any person, firm or private company with whom you are likely to have official dealings. Do not otherwise place yourself under pecuniary obligation with such person, firm or private company.

13). Do not approach your subordinates for standing surety for loans taken from private sources either by you / your relations / friends.

14). Do not undertake private consultancy work.

15). Do not speculate in any stock, share or other investment.

16). Do not bring any political influence in matters pertaining to your service.

17). Do not consume any intoxicating drinks or drugs while on duty.

18). Do not indulge in any act of sexual harassment of any woman at her work place.

19). Do not employ children below 14 years of age.

20). Do not indulge in habitual absence without permission and overstaying leave.

21).Do not speak or take active or prominent part in organizing or conducting meetings of any political party.

22). Do not indulge in acts which violate the provisions of the Personal Marriage laws applicable to the employee.

23). Do not unauthorizedly indulge in subletting of quarters, erects any unauthorized structure in any part of the residence allotted to you.

24). Do not claim leave as a matter of right.

25). Do not submit and claim false medical bills.

26). Do not use Staff cars for non-duty journeys.

27). Do not misuse LTC facilities.

28). Do not communicate with the press, TV, Radio or any form of media until authorized to do so.