HEALTH SAFETY AND … HSE Plan.pdf · prepared by rigsafe inc. lrsi hse plan-2011.doc little red...

Little Red Services Inc. Page 1 of 16 Revised 10/15/2011

Prepared by RigSafe Inc. LRSI HSE Plan-2011.doc

LITTLE RED SERVICES INC.LITTLE RED SERVICES INC.LITTLE RED SERVICES INC.LITTLE RED SERVICES INC.

HEALTH SAFETY AND HEALTH SAFETY AND HEALTH SAFETY AND HEALTH SAFETY AND

ENVIRONMENTALENVIRONMENTALENVIRONMENTALENVIRONMENTAL

PLANPLANPLANPLAN

Originally Prepared By

RigSafe Inc.RigSafe Inc.RigSafe Inc.RigSafe Inc. Anchorage, Alaska



Little Red Services, Inc. (LRSI) HSE Plan

Table of Contents HEALTH, SAFETY, AND ENVIRONMENTAL POLICY........................4

Introduction .........................................................................................5

1.0 Management Commitment and Accountability .........................5 1.1 Statement of Management Commitment ..............................................................................................5 1.2 Management Structure..........................................................................................................................6 1.3 Roles and Responsibilities....................................................................................................................6 1.4 Goals and Performance Measures ........................................................................................................7 1.5 Safety and Environmental Processes ....................................................................................................8

2.0 Risk Assessment and Management ...........................................8 2.1 Risk Management Process....................................................................................................................8 2.2 Workplace Risk Assessment.................................................................................................................8

3.0 Equipment Design and Construction.........................................8 3.1 Design Standards ..................................................................................................................................8 3.2 Technical Authorities ...........................................................................................................................9

4.0 Operations and Maintenance......................................................9 4.1 Recommended Practices and SOPs ......................................................................................................9

4.1.1 LRSI Standard Procedures............................................................................................................9 4.1.3 North Slope Safety Handbook ......................................................................................................9 4.1.4 North Slope Environmental Handbook.........................................................................................9

4.2 Pre-job Meetings...................................................................................................................................9 4.3 Customer Interface ...............................................................................................................................9 4.4 Sim-ops...............................................................................................................................................10 4.5 Health and Industrial Hygiene ............................................................................................................10 4.6 Hydrogen Sulfide................................................................................................................................10 4.7 Equipment Maintenance and Testing .................................................................................................10

5.0 Management of Change ............................................................10 5.1 LRSI MOC Process ............................................................................................................................10 5.2 Changes To Company Owned Equipment..........................................................................................10 5.3 Changes To Company SOPs...............................................................................................................11 5.4 Changes To Customer Equipment ......................................................................................................11

6.0 Resources and Documentation ................................................11 6.1 LRSI Policies and Procedures ............................................................................................................11 6.2 Customer Policies and Procedures......................................................................................................11 6.3 Local, State, and Federal Regulations ................................................................................................11 6.4 Waste Transfer and Disposal ..............................................................................................................11 6.5 Material Safety Data Sheets................................................................................................................12 6.6 Confidential Records ..........................................................................................................................12 6.7 Document List ....................................................................................................................................12

7.0 Personnel and Training.............................................................12 7.1 Employee Selection and Evaluation ...................................................................................................12 7.2 Drug and Alcohol Policy ....................................................................................................................12 7.3 Training and Employee Development ................................................................................................13 7.4 Training Requirements .......................................................................................................................13

7.4.1 LRSI orientation .........................................................................................................................14 7.5 LRSI Progressive Disciplinary System...............................................................................................14

8.0 Third Party Services ..................................................................14 8.1 Selection of Contractors and Service Providers..................................................................................14



9.0 Incident Investigation and Follow Up.......................................14 9.1 Incident Reporting and Investigation Protocol ...................................................................................14 9.2 Follow Up and Sharing Lessons Learned ...........................................................................................15

10.0 Emergency Preparedness.........................................................15 10.1 Emergency Response Plans ................................................................................................................15

10.1.1 Field Plans ..................................................................................................................................15 10.1.2 Facility Plan................................................................................................................................15

10.2 Agency Reporting and Public Communications.................................................................................15

11.0 Operations Assessment and Improvement ...........................15 11.01 Audits and Inspections....................................................................................................................15 11.02 Action Items and Follow-up ...........................................................................................................15



LITTLE RED SERVICES INC.

HEALTH, SAFETY, AND ENVIRONMENTAL POLICY This policy covers all of the operations of Little Red Services in Alaska. We are fully committed to our

corporate goals: no accidents, no harm to people and no damage to the environment. In meeting with this

policy LRSI will:

• Expect all personnel to demonstrate commitment and leadership in health, safety and environmental (HSE) protection. Managers at all levels will consider safety and environmental issues as the primary focus when making business decisions which may impact these critical areas.

• Respond to the concerns of employees, customers, neighbors, government agencies and the public of relevant HSE aspects of our operations. Openly listen, and respond to their concerns.

• Meet or exceed compliance obligations of applicable HSE legislation and regulations and customer requirements.

• Provide employees with a safe place to work, clear expectations regarding HSE requirements and the necessary training to perform their jobs.

• Work closely with our customers to contribute effectively to their HSE programs and compliance efforts.

• Require those directly supporting our operations to meet or exceed applicable legislation, regulations and industry standards, in addition to LRSI requirements.

• Maintain a commitment to incident and pollution prevention and to continual improvement in HSE performance.

• Set annual HSE objectives and targets and openly report our performance to our employees, customers, and other interested parties.

• Audit compliance with this policy and take corrective action where appropriate.

• Make available appropriate resources to implement this policy.

Doug Smith, President and CEO Greg Johnson, Vice President- Operations Joe Curgus, Vice President- Operations



Introduction

The purpose of the Little Red Services Inc., Health Safety and Environmental Plan is to identify the

overall objective for the successful management of HSE issues that pertain to the conduct of our

business. By clearly describing the methods and the tools the company will use to ensure optimum

HSE performance, we hope to more clearly define the company strategy for continuous improvement

in this critical area of our business. All LRSI employees should understand how the company plans

to achieve the goals set forth in this document and how the existing programs will be used to reach

that end. We ask that our employees join in this effort to ensure a solid progressive future, for

themselves, and for the company. A future based on world class HSE performance that we all can

participate in and be proud of.

1.0 Management Commitment and Accountability

1.1 Statement of Management Commitment

The Management of LRSI is committed to conducting all operations in a safe and environmentally

sound manner. We believe that it is critical to the survival of the company that we take no action that

will endanger our employees, our customer’s employees, the general public, or the environment. We

intend to manage our business in a manner that places Health, Safety and Environmental integrity as

the primary operational objective of the company.

LRSI management demonstrates HSE commitment through their participation in a number of

scheduled meetings to keep abreast of operations. Management personnel have established schedules

for North Slope visits relative to position. Scheduled meetings include the following:

Table 1: Meeting Schedule

LRSI SCHEDULED MEETINGS PURPOSE

Morning meetings

(Telephone Conference)

Review daily operations with field

managers

Weekly Mgmt Meeting (Anchorage Managers, HR,

Staff)

HSE, Operations, Planning, Personnel

Weekly Contractors HSE Meeting BP (Slope

Managers)

HSE update and lessons learned

Weekly North Slope Safety and Training session

(Field Managers, Operators, Employees.)

HSE topics, Action items,

Update training

Forum for lessons learned

Bimonthly operations meeting

(Anchorage)

Review HSE performance,

operations,

Forward plan

Materials, logistics,

Handover for field managers

Monthly Safety Leadership Team

ConocoPhillips Management (Anchorage)

Customer Issues, Lessons learned,

HSE activities

Quarterly Performance Reviews LRSI HSE, Performance Review

Semi-annual Performance Reviews with BP HSE, Performance review



1.2 Management Structure

The HSE Plan of Little Red Services, Inc. (LRSI) is based on,

1. The safe, environmentally sound, maintenance and operation of its equipment and facility,

2. Operational support and performance,

3. Waste management, and

4. Monitoring operations for safety and environmental compliance.

5. Continual improvement of HSE processes and systems.

The HSE Plan includes managing all operations in a way that protects the environment, health and

safety of all employees, customers, and the public. Compliance with our Safety and Environmental

program is a condition of employment. LRSI supervisors have first-line responsibility to operate their

facility and field operations in a safe and environmentally sound manner.

Figure 1: Little Red Services, Organization Chart

1.3 Roles and Responsibilities

The President & CEO of LRSI will monitor the performance of HSE efforts through timely

communications with the NS Field Managers. He will measure progress made toward the goals set

forth in the HSE Plan.

President & C.E.O. Doug Smith

Vice President- Operations Greg Johnson & Joe Curgus

Field Supervisors Prudhoe Bay

Steve Nickles & Steve Leonard

Health, Safety & Environmental

Chris Warner

Field Supervisors Kuparuk

Steve Hitchcock & Jerry Webre



(Roles and Responsibilities continued)

Vice-President of Operations will be responsible for the oversight and implementation of LRSI’s HSE

program. The Vice-President, Operations will be report to the President. Duties will include:

1. Overall analysis of potential job-related HSE concerns before operations begin,

2. Ensure training of all LRSI employees on HSE issues prior to actual field work, and

3. On-going safety/environmental education through weekly meetings and scheduled training.

4. Conduct Incident investigations, internally, and participate in Customer investigations.

5. Warn/discipline or terminate (depending on the severity of the violation) those employees

who do not comply HSE programs or regulations.

The HSE Director for LRSI will oversee and direct the company’s HSE program, within the

company, and with customer Contract Managers. His responsibilities will be to ensure proper

management of LRSI programs, and to facilitate the interface with the customer’s HSE Programs,

policies and procedures as well as overseeing the HSE Coordinators. Additionally, the HSE Director

will be responsible for the duties including, but not limited to:

1. Development, implementation, and maintenance of LRSI training programs and records.

2. Confirm regulatory compliance with all applicable agencies

3. Assists in Incident investigations and action planning

4. Maintain LRSI documents for regulatory and work scope status.

The North Slope Safety and Environmental Coordinators will be responsible for the daily operations

of the LRSI HSE program, with duties to include, but not limited to:

1. Maintenance of LRSI training programs and records.

2. Conduct employee orientation to explain the HSE Plan, LRSI’s Safety and Environmental

Programs, compliance issues, and other site-specific HSE regulations.

3. Assists in Incident investigations and action planning

4. Conduct periodic field audits and inspections to ensure compliance with all applicable

Federal, State, and customer requirements.

The North Slope Field Supervisors will monitor and direct safety and environmental efforts at the

crew level. The field supervisors will report to the Vice-President of Operations and the HSE

Director regarding HSE issues.

1.4 Goals and Performance Measures

Annual performance goals are set out and agreed to by the management staff of LRSI. This process

defines the targets on which performance will be reviewed on a quarterly and annual basis.

Key performance targets and objective that LRSI sets are based on the following key areas and their

sub-parts-

1. Employee Safety and Health

2. Environmental Stewardship

3. Processes and Systems

4. Equipment and Tools

5. Financials



The Goal setting process is a collaborative process that includes a review of the previous years results

in the target areas as well as a open discussion of the upcoming issues and projected customer focus

points.

Once initial goal concepts are determined, feedback and agreement is gathered from the Management

Team to ensure that everyone is aligned on the targets.

The President/ CEO has final approval on the target and objectives for the year and these are

communicated to the employee base as appropriate and followed up on by the President and Vice-

President of Operations throughout the year. Ongoing progress will be shared with the employees

throught he use of safety meetings, tail-gate meetings and other media formats as necessary.

1.5 Safety and Environmental Processes

The Company has established formal systems that ensure operational HSE integrity throughout all

LRSI activities. These include:

1. Company policies

2. Recommended practices,

3. Standard Operating Procedures,

4. Management processes, and

5. Emergency preparedness and response plans.

Work standards are documented in the LRSI Safety Policies and Procedures manual, and the LRSI

Policies and Procedure Documents the Alaska Safety Handbook and the North Slope

Environmental Field Handbook.

2.0 Risk Assessment and Management

2.1 Risk Management Process

Within LRSI, hazards and potential risks are identified and discussed in job planning, pre-job

activities, and daily operations. LRSI Safety Policies and Procedures Manual addresses operational

risks that have been identified for hot oil operations.

2.2 Workplace Risk Assessment

Work-place risk assessments are completed prior to job start-up using the LRSI Pre Job Safety

Checklist and Emergency Response Plan. Other risk assessments may periodically be conducted

prior to non-routine operations by the NS Field Managers and NS / HSE Coordinator during pre-job

planning sessions.

3.0 Equipment Design and Construction

3.1 Design Standards

GenTex Incorp. and Keyway International manufacture LRSI hot oil units. Additional equipment is

assembled from off the shelf components, (Pipe, Fittings, Valves,) of the highest quality.



3.2 Technical Authorities

The technical authorities for LRSI equipment are the OEM who provided the components that are

integral to the various systems. Hose assemblies are built to Hose And Rubber Manufactures

Association standards.

4.0 Operations and Maintenance

4.1 Recommended Practices and SOPs

4.1.1 LRSI Standard Procedures

LRSI Safety Policies and Procedures Manual (SPPM) and Standard Operating Procedures

(SOP) contains information regarding SOP for company operations. The following items

are some examples of what can be found in this manual:

• Safety policy and rules

• Emergency response

• H2S procedures

• Job specific procedures

• Vehicle operations

• Equipment operating limits

• Spill response

• Environmental procedures

• Waste management procedures

4.1.2 LRS Environmental Management Systems (EMS) Plan Little Red Services Environmental Management System outlines the methods of minimizing

the environmental impacts of the operations. This includes a assessment of environmental

and critical impacts, waste stream process and hazard risk analysis.

4.1.3 North Slope Safety Handbook

LRSI utilizes the policies and procedures outlined in the Alaska Safety Handbook when

working in the various fields on the North Slope. All LRSI employees are required to attend

classes provided by the North Slope Training Cooperative, which is the training authority of

the contents of the Alaska Safety Handbook.

4.1.4 North Slope Environmental Handbook

LRSI utilizes the policies and procedures outlined in the NS Environmental Field Handbook

when working in the various fields on the North Slope. All LRSI employees are required to

attend classes provided by the North Slope Training Cooperative, which is the training

authority of the contents of the NS Environmental Handbook.

4.2 Pre-job Meetings

Pre-job meetings are conducted with other service providers and with the customer representative to

identify operational plans. Safety and environmental issues are identified and managed. The pre-job

meeting and location inspection are documented using the LRSI Pre Job Safety Checklist and

Emergency Response Plan.

4.3 Customer Interface

Each LRSI operator will work closely with the customer Representative to ensure a safe and

environmentally sound operation. Using the LRSI Pre Job Safety Checklist and Emergency



Response Plan the project will be reviewed and documented prior to job startup. Special instructions

and job scope will be noted in the areas provided on the form.

4.4 Sim-ops

Simultaneous operations are handled as per customer guidelines for the operating area. LRSI

operators will make every effort to work in conjunction with other contractors for the safe and

efficient completion of the project.

4.5 Health and Industrial Hygiene

LRSI has developed and continually updates a variety of applicable Industrial Hygien/ Employee

Health related programs in order to ensure the safety of our employees. This is accomplished through

a combination of in-house efforts and through collaboration with customer on-site IH professionals.

These programs include, but are not limited to:

• Hearing Conservation;

• Respiratory Protection;

• Blood-borne Pathogens Safety

LRSI provides all necessary Personal Protective Equipment that has been identified for

the duties performed by its employees.

4.6 Hydrogen Sulfide

Each LRSI employee has been trained in the proper procedures for dealing with Hydrogen Sulfide.

H2S monitors are provided when necessary for the protection of LRSI employees. LRSI Pre Job

Safety Checklist and Emergency Response Plan generate site-specific emergency action plans with

regards to emergency escape plans and muster areas identified and communicated to all affected

personnel.

4.7 Equipment Maintenance and Testing

LRSI utilizes a planned preventative maintenance system to ensure the operational integrity of the

field units. LRSI full time mechanics are responsible for implementing maintenance protocols and

record keeping used by the system.

Documented testing is conducted on LRSI equipment on a regular and ongoing basis. Pressure and

system integrity tests are conducted on field hose and piping systems prior to each job.

Each truck will under go a pre operational inspection conducted by an LRSI operator. The completed

checklist will be signed off and retained in the equipment file.

HSE related equipment and tools undergoes a routine and periodic testing and inspection process to

ensure it meets accepted standards for use. These inspections are recorded and corrective actions

undertaken to correct any identified deficiencies.

5.0 Management of Change

5.1 LRSI MOC Process

LRSI utilizes a “routed form” management of change protocol. Any change required in company

owned equipment is submitted by the operator on an LRSI MOC form that is routed through the

management and maintenance teams for review and approval.

5.2 Changes To Company Owned Equipment

Any changes to company owned equipment will only be completed as per the OEM

recommendations. Replacement in kind of worn out components will not addressed through the



MOC process, however, they will be tracked using the preventative maintenance system to identify

high wear and replacement before failure opportunities.

5.3 Changes To Company SOPs

SOP’s are reviewed during each job cycle for effectiveness and applicability. Any changes required

will be documented and submitted using the MOC protocol. Necessary changes will be completed

and communicated to the employees through postings and safety meetings.

Deviations from SOPs that are job site specific will be reviewed by the NS Field Managers and

approval for nonstandard operations received before commencing work.

5.4 Changes To Customer Equipment

LRSI employees will not make changes to customer owned equipment without the prior written

approval of the assigned customer representative. Customer MOC protocols will be used to

document any changes necessary for the competition of the work.

6.0 Resources and Documentation

6.1 LRSI Policies and Procedures

LRSI Safety Management System

LRSI Standard Operations Procedures

LRSI Safety Policies and Procedures Manual

LRSI Environnemental Management System

LRSI Waste Management Plan (Compliance Matrix)

6.2 Customer Policies and Procedures

All LRSI employees involved review applicable customer policies and procedures prior to job start-

up. Standards documented in the NS Safety Handbook, and the NS Environmental Handbook will

be used by LRSI personnel when working on the customer location.

6.3 Local, State, and Federal Regulations

LRSI will operate within all applicable laws governing their type of business. Periodic reviews are

conducted to determine if statute changes or additional regulations have occurred that will impact

LRSI operations. LRSI enlists the services of subscription based compliance resources such as J.J.

Keller© , Keller On-Line© and various periodicals to ensure we are aware of, and conform to any

changes. Currently there are no State or Federal permits required for LRSI internal operations. LRSI

maintains a classification as an “Exempt Small Quantity Generator” as described by EPA regulations.

The following is a list of HSE related laws and regulations that apply to LRSI operations:

� State and Federal OSHA regulations including Alaska 8AAC 61.1180.

� Alaska environmental standards:

1. 18 AAC 60 Solid waste management

2. 18 AAC 62 Hazardous waste

3. 18 AAC 75 Oil and Hazardous substance pollution control

� Federal environmental standards

1. 40 CFR 260-272 Solid and Hazardous waste

2. 40 CFR 302, 355 Chemical release reporting

6.4 Waste Transfer and Disposal

As a matter of policy LRSI will not remove waste materials from the customers operational area. All

residual waste and equipment contamination will be handled through the customers approved waste



handling system BEFORE LRSI equipment leaves the job site. In addition, waste generated by LRSI

outside the customer’s operational area will not be transported to the customer’s job site.

The waste stream generated by LRSI within its own operations is handled as per the guidelines set

forth in the LRSI North Slope Operations Waste Stream Identification (EMS attach. #3). The prime

objective of this system is to maintain the status of “Exempt Small Quantity Generator” for LRSI

operations. Details of this system can be found in the LRSI Environmental Management System

6.5 Material Safety Data Sheets

Material Safety Data Sheets are maintained for all chemicals in use by LRSI and are kept at the field

office in Deadhorse. Additional MSDS information provided by the customer is reviewed prior to job

start-up and retained with job documents after job completion.

6.6 Confidential Records

All records kept by LRSI pertaining to work performed for our customers, is held as confidential

information, and will only be released by written approval from the customer.

LRSI employee records are maintained in accordance with federal confidentiality laws.

6.7 Document List

The following documents describe the HSE operational information sources used by LRSI.

DOCUMENT NAME STEWARD STATUS

LRSI Safety Policies and Procedures Manual LRSI Ongoing

LRSI Environmental Management System LRSI July, 2010

NS Alaska Safety Handbook 2006 BP/Phillips 2006

NS Environmental Handbook 2005 BP/Phillips May 2005

NS Waste Management Guide (Redbook) BP Aug 2008

SSD HSE SOPs (Drilling Manual) BP / SSD Current

BPXA Hazardous Material SOP BP Current

7.0 Personnel and Training

7.1 Employee Selection and Evaluation

Little Red Services strives to select the most qualified employee for the specific job requirement.

Components of the selection process include a Job Description, Job Posting, Training Records,

Annual Performance Reviews, Resumes, and interviews. Personnel placement is approved and

authorized by Management personnel. The level of detail of the selection process is dependent on the

level of the position to be filled and the risk involved.

Each truck driver is required to maintain a current Alaska Commercial Drivers license with Hazmat

endorsement. In addition drivers are to maintain compliance with basic DOT regulations when

operating LRSI trucks and equipment.

7.2 Drug and Alcohol Policy

LRSI maintains a comprehensive Drug and Alcohol Program to ensure the quality of our work force.

The program includes pre-employment, for-cause, post accident, return-to-duty and random drug



testing for all employees under both FMCSA and PHMSA specifications. Full details of the LRSI

Drug and Alcohol Policies can be found in the LRSI FMCSA and PHMSA Anti-Drug and Alcohol

Programs

7.3 Training and Employee Development

Specific training systems are used for basic and refresher training to meet all company and regulatory

requirements. A training matrix was developed and describes all necessary training for individual

employees. Training is documented through attendance records, test scores, and training completion

recognition. The NS/ HSE Coordinator maintains training records for LRSI personnel. Table 2

details training requirements.

7.4 Training Requirements

Table 2: Sample Training Requirements

TRAINING REQUIREMENT LRSI Required OSHA

Required

Frequency

Alaska Safety Handbook-NSTC All Employees I

Audiometric Testing All Employees X A

Behavior Based Safety Systems All Employees I

Benzene Awareness All Employees X I

BP Crude Loading All BP based Employees I

BP EMS Systems All BP based Employees A

Cold Environments- NSTC All Employees X I

Confined Space Entry All Affected Employees X I

CPR Managers X 2

DOT Controlled Substances-Alcohol All Employees X I

Electrical Safety- Unqualified All Employees X I

Emergency Response Plan All Employees X I

Environmental Excellence-NSTC All Employees I

Facility PSM and Orientation All Employees 3

Fall Protection All Affected Employees X I

Fire Extinguisher (Portable) All Employees X A

First Aid All Employees X 3

Hazard Communication -NSTC All Employees X I

HAZWOPER basic All Employees X I

Hearing Conservation -NSTC All Employees X A

Hydrogen Sulphide-NSTC All Employees X 2

Incident Investigation Managers I

Lock-Out/Tag-Out All Employees X I

LRSI Orientation (Sec 7.4.1) All Employees X I

North Slope Training Coop All Employees I

Facility Orientations, per API 75,

7.2.1

All Employees working in

BOEMRE- req locations

I

NPR-A Orientation All Employees X I

Personal Protective Equipment- All Employees X I



NSTC

Polar Bear Awareness All Employees X I

Respiratory Protection All Employees X A

Redbook-Hazardous Waste Disposal All Employees X A

Scaffold User All Employees X I

Vehicle Driving Policy All Employees A

Wildlife Interaction All Employees I

7.4.1 LRSI orientation

The following is a representative listing of the content of the LRSI employee orientation.

Work schedule Rules for travel

Management structure Benefits and profit sharing

Clothing requirements General work rules

Training schedule Theft and dishonesty

Drugs and alcohol Basic safety rules

Customer safety requirements Protective equipment

Emergency procedures Medical treatment

Accident reporting Spill reporting

Behavior based safety Reporting unsafe conditions

Employee’s responsibility

Spill Prevention-PowerPoint Pres

EMS Training-PowerPoint Pres

Quality control

HSE Policy-PowerPoint Pres

More Information can be found in the Policies and Procedures Manual

7.5 LRSI Progressive Disciplinary System

LRSI employees may be discharged or disciplined after management deems it necessary to protect

itself and others from unsafe or environmentally unsound acts committed by employees. The extent of

disciplinary action taken is directly proportional to the severity of the undesired behavior.

Disciplinary action can range from a written Personnel Action Notice (PAN) to be put in the

employee’s file, to immediate dismissal.

8.0 Third Party Services

8.1 Selection of Contractors and Service Providers

All third party service providers operate under the same HSE requirements as LRSI. The use of third

party services required by LRSI is minimal at best.

9.0 Incident Investigation and Follow Up

9.1 Incident Reporting and Investigation Protocol

All incidents that occur with or involving LRSI people or equipment is investigated. The LRSI NS

Field Managers and the NS HSE Dept conduct incident investigations. Upon notification, the

investigation team will initiate the Incident Notification and Investigation process, visit the site and

complete a detailed report of the situation, including apparent cause and effect. The crews involved

will also complete full written reports leading up to and following the incident. Depending on the



severity of the incident, a Taproot Investigation may be conducted. The LRSI management will

generate a summary of the report and recommended corrective actions. The LRSI HSE Department

will complete reporting to specific agencies, if necessary, with approval by upper management.

9.2 Follow Up and Sharing Lessons Learned

LRSI shares findings of audits and incident investigations with employees and customers to provide

continuous improvement across North Slope operations. Lessons learned are routinely shared

through daily morning meetings, weekly staff meetings, Customer HSE Forums, monthly safety

statistics, technical presentations, quarterly reviews, Hazard Alerts, and customer reporting protocols

as appropriate.

10.0 Emergency Preparedness

10.1 Emergency Response Plans

10.1.1 Field Plans

Site-specific field emergency action plans are developed using the LRSI Pre Job Safety

Checklist and Emergency Response Plan. All preparations for emergency are closely

coordinated with the customer and other service providers on the job site.

10.1.2 Facility Plan

LRSI maintains a written emergency action plan for the Deadhorse facility. This is located at

all points of egress at the facility as well on file at the HSE Office.

10.2 Agency Reporting and Public Communications

LRSI maintains a protocol for notification of agencies, should the need arise. The notification

procedures are documented in the LRSI Incident Notification and Investigation Policy.

The LRS Anchorage Office Manager handles communication with the public and or the news media,

in cooperation with customer and employee representatives. Any contact regarding LRSI operations,

customers, or employees, will be directed immediately to General Manager in the Anchorage office.

11.0 Operations Assessment and Improvement

11.01 Audits and Inspections

Each level of LRSI management is responsible for periodic inspections of the work site. Daily,

weekly, and monthly audits are conducted based on operational needs and timing. LRSI managers

and employees are expected to participate in customer audit programs and behavior based

observations.

11.02 Action Items and Follow-up

Action items developed from inspections, audits, and investigations will be dated and tracked by the

NS HSE Coordinators. The HSE manager will monitor progress toward completion of action items

weekly.



Revision Log

Revision Date Authority Reviser Revision Details

5-5-2005 HSE Cwarner Annual Update

3-29-2006 HSE Cwarner Annual Update

2-14-2008 HSE CWarner Annual review- Revised Exec Managers


9-15-2009 HSE CWarner Update Exec Managers


10-15-2011 HSE CWarner Update training to include BOEMRE req

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