1 SCOPE

This document provides the general rules for reporting incidents.

2 REFERENCES

3 DEFINITIONS

A recordable incident (injury related)
Recordable incidents are those which result in a fatality, an injury requiring time off work or a restriction in the work performed, or an injury requiring medical treatment.

An occupational injury
Is any injury such as a cut, fracture, sprain, amputation, etc., which results from a work related activity or from an exposure involving a single incident in the work environment, such as deafness from explosion, one-time chemical exposure, back disorder from a slip/trip, insect or snake bite. Report Forms 1 and 2 should be used to report injury related incidents and fatalities.

An occupational illness
Is any abnormal condition or disorder, other than one resulting from an occupational injury, caused by exposure to environmental factors associated with employment? Occupational illness may be caused by inhalation, absorption, ingestion of or direct contact with the hazard, as well as exposure to physical and psychological hazards. It will generally result from prolonged or repeated exposure. Report Forms 4 should be used to report illness related incidents and fatalities.

A Significant incident
Is defined to be incidents which cause or have the potential to cause serious injury and/or fatality, or significant structural damage (which may place personnel at risk).or substantial damage to the environment The description of the incident should be sufficiently detailed to allow other subsidiaries to share important safety learning arising from the incident. Subsidiaries are requested to limit the number of significant incident descriptions submitted to those which have high learning value on a broad basis.

A Company employee
Is a person employed by and on the payroll of the reporting Company, including corporate and management personnel specifically involved. Persons employed under short-service contracts are included as Company employees provided they are paid directly by the Company.

A Contractor employee
Is a person employed by a Contractor or Contractor’s Sub-Contractor(s) who is directly involved in execution of prescribed work under a contract with the reporting Company.

Work Related Activity

All incidents that occur in work-related activities are reportable and are to be included in reports especially if the incident results in an occupational injury or illness that is more serious than requiring basic first aid.

A work-related activity is an activity in a work environment, which is subject to management controls. Injuries incurred on Company or Contractor premises whilst off-duty are not classed as occupational injuries and should not be reported since they are not work-related. The exception is when the injury is directly linked to the activities of other personnel who are at work. The following Company and Contractor activities are considered work-related since they should be subject to management control.

Company work-related activities

All work by Company personnel, including attendance at courses, conferences and Company-organized events, business travel, field visits or any other activity or presence expected by the employer.
All work activities done by Contractor personnel:

  • Contractor work-related activities on Company premises, and
  • On non-Company premises which are or ought to be subject to Company management controls applied through contractual terms, and including the same activities as listed above if they are executed on behalf of the Company.

The second category would include, for example, fabrication by a Contractor of an assembly or construction under a specific contract where fabrication takes place in a designated area set aside for that work.

Exceptions to the second category will typically be where Contractor services are not dedicated to the Company, e.g.

  • factory manufacture of components together with components for others;
  • construction at Contractor’s fabrication site shared by others;
  • Delivery of purchased goods from a supplier to Company locations by a Contractor other than purpose-built assemblies and plants.

Incident severity

It is a measure of the consequences of an incident (human injury and/or environment damage and/or material loss) with five levels.

Real indicates the consequences that have occurred. "Potential" indicates the consequences that could have been a “reasonably likely outcome”, incidents with real severity of 1 and potential severity of 2 or more are also qualified as
near misses.

4 INCIDENT REPORTING

4.1 WHAT INCIDENTS TO REPORT

1. All recordable incidents and significant incidents (including near misses) shall be reported to the head of Well Operations department.

2. All fatalities, occupational injuries, occupational illness and significant incidents of severity of 2 or more and/or potential severity of 3 or more shall be reported to GDF SUEZ EPI headquarters.

3. The requirement to report incidents applies to all personnel whether employed by COMPANY or contracted directly or indirectly to COMPANY. The basis for reporting will be the standard OGP report form:

  1. Occupational injuries (Report 1)
  2. Fatal incidents (Report 2)
  3. Significant incidents (Report 3)
  4. Occupational illnesses (Report 4)

4.2 INCIDENT INVESTIGATION

1. The COMPANY Well Operations Supervisor on-site shall be responsible for timely investigation and reporting of incidents.

2. The COMPANY Well Operations Supervisor shall appraise the incident with the person reporting the situation. After discussion, the COMPANY Well Operations Manager or Field Manager will decide if further appraisal is needed.

3. Further action by an investigation team is generally required in the case of:

  1. Fatalities, occupational injuries with permanent disability or more than 30 workdays loss
  2. Serious incident with a real severity of 3 or more or potential severity rated 4 or more.

4.3 CONTRACTOR REPORTING

1. Contractors shall report all incidents and accidents to the GDF SUEZ EPI Well Operations
Supervisor in addition to reporting via their own system.

4.4 REPORTING INCIDENT TO PARIS HEADQUARTER

1. Fatalities, Occupational injury and serious incident with real severity of 3 or more or potential severity of 4 or more shall be reported to COMPANY by telephone within 4 hours of the incident occurring. Otherwise, reports by fax, telex or e-mail should be within 24 hours of the incident occurring.

2. The Incident Report shall provide at least the following:

  1. Details of injury to personnel
  2. Details of damage to property, equipment or the environment
  3. A description of the incident
  4. An analysis of the incident including working conditions, contributing factors etc
  5. A classification of the seriousness and probability of re-occurrence
  6. Preventive action, responsibility for action and time-scale
  7. Any other comments and sign-off.

3. Incidents shall be discussed at regular HSE meetings.

4.5 INCIDENT RECORDS AND FILING

1. The Well Operations department shall maintain an Incident file which shall contain all associated
reports, e-mails and forms.