SAFETY PROGRAM MANUAL

2009

TABLE OF CONTENTS DISTRIBUTION LIST (at end of Table of Contents) DISCLAIMER FORMS CD Safety Program Forms 1.0 INTRODUCTION Section 1 - Forms Policy On Health Safety And The Environment Policy On Drug and Alcohol Policy On Violence and Harassment Petroleum Industry Guiding Principles for Worker Safety 2.0 RESPONSIBILITIES 2.1 HARVARD 2.1.1 PRIME CONTRACTOR/OWNER RESPONSIBILITIES 2.1.2 OWNER RESPONSIBILITIES 2.1.3 WORK SITE SAFETY PLAN 2.1.4 MONITORING PROCESS 2.2 MANAGERS RESPONSIBILITIES 2.3 SUPERVISORS RESPONSIBILITIES 2.4 WORKERS RESPONSIBILITIES 2.5 SAFETY PROFESSIONALS RESPONSIBILITIES 2.6 VISITORS RESPONSIBILITIES 2.7 DUE DILIGENCE 2.8 DRILLING & COMPLETIONS SPECIFIC RESPONSIBILITIES 2.9 STANDARDS FOR WELLSITE SUPERVISION OF DRILLING, COMPLETION AND WORKOVERS VOL. 7 2002 Section 2 - Forms Work Site Safety Plan Checklist Bill C-45 Explanation WHS Bulletin Due Diligence 3.0 SAFETY MANAGEMENT PLAN 3.1 THE OPERATIONS PROGRAM (DRILLING & COMPLETIONS) 3.2 THE SAFETY PLAN CHECKLIST 3.3 THE SAFETY STATEMENT Figure 1: The Elements of a Basic Safety Program Section 3 - Forms Safety Statement OPX Consulting Inc. Table of Contents - i

4.0 HAZARD IDENTIFICATION AND ASSESSMENT SAFETY PROGRAM MANUAL 4.1 OVERVIEW 4.2 RESPONSIBILITY 4.3 SIZE AND SCOPE OF ASSESSMENTS 4.4 ASSESSMENT INTERVALS 4.5 PROCESS OF HAZARD IDENTIFICATION 4.6 TYPES OF INSPECTIONS 4.6.1 ON-GOING INFORMAL INSPECTIONS 4.6.2 PLANNED INSPECTIONS (FORMAL) 4.6.3 SAFETY AUDITS, LOSS PREVENTION SURVEYS AND REGULATORY INSPECTIONS 4.6.4 EQUIPMENT PREVENTATIVE MAINTENANCE 4.6.5 INCIDENT INVESTIGATION FINDINGS Figure 1: Hazard Identification, Elimination & Control Flowchart 4.7 RISK MATRIX 4.8 HAZARD ASSESSMENT TOOLS & CHECKLISTS 4.8.1 CHEMICALS AND FUELS 4.8.2 COMPRESSED GAS CYLINDERS 4.8.3 CONFINED SPACE ENTRY 4.8.4 ELECTRICAL POWER SYSTEMS 4.8.5 EMERGENCY INSTRUCTIONS 4.8.6 EMERGENCY RESCUE EQUIPMENT 4.8.7 ENERGY ISOLATION 4.8.8 ERGONOMIC FACTORS 4.8.9 EXIT/EGRESS 4.8.10 EYE BATH AND SHOWERS 4.8.11 FATIGUE 4.8.12 FIRE PROTECTION 4.8.13 FIRST AID KITS/STATIONS/EQUIPMENT 4.8.14 HAND AND PORTABLE TOOLS 4.8.15 HYDRAULIC POWER SYSTEMS 4.8.16 LADDERS 4.8.17 LIFTING GEAR/EQUIPMENT 4.8.18 LIGHTING 4.8.19 MATERIAL HANDLING 4.8.20 MECHANICAL POWER SYSTEMS 4.8.21 NOISE EXPOSURE 4.8.22 PERSONAL PROTECTIVE EQUIPMENT 4.8.23 PLATFORMS/SCAFFOLDING 4.8.24 PNEUMATIC POWER SYSTEMS 4.8.25 PRESSURE VESSEL AND PIPING 4.8.26 SIGNS AND TAGS 4.8.27 STACKING AND STORAGE 4.8.28 STAIRS 4.8.29 SUBSTANCE ABUSE 4.8.30 TRENCHING/EXCAVATING 4.8.31 VALVES AND MECHANICAL CONTROLS 4.8.32 VEHICLES AND EQUIPMENT 4.8.33 VENTILATION AND EXTRACTION 4.8.34 VIOLENCE AND HARASSMENT 4.8.35 WARNING SYSTEMS 4.8.36 WASTE DISPOSAL 4.8.37 WHMIS/TDG 4.8.38 WORK SURFACES, FLOORS AND ROADWAYS 4.9 WELL SERVICING SPACING REQUIREMENTS OPX Consulting Inc. Table of Contents - ii

4.10 DRILL SITE SPACING REQUIREMENTS 4.11 BATTERY SPACING REQUIREMENTS Section 4 Forms Well Safety Check and Hazard Identification Vehicle Safety Inspection Checklist Hazard Identification & Control Form Service Rig Inspection Checklist Drilling Rig Inspection Checklist 5.0 COMMUNICATION 5.1 MEETINGS 5.1.1 GENERAL SAFETY AND ENVIRONMENT MEETINGS Figure 1: Planning a General HSE Meeting 5.1.2 PROJECT / PRE-JOB / TAILGATE SAFETY MEETINGS Figure 2: Project / Pre-Job / Tailgate Safety Meeting Agenda 5.2 WORK PERMIT SYSTEM 5.2.1 WORK CLEARANCE, PERMIT REQUIREMENTS AND PRE-JOB SAFETY MEETING REQUIREMENTS FOR DRILLING & SERVICE RIG OPERATIONS 5.2.2 ISSUING A WORK PERMIT 5.2.3 DEFINITIONS READ PRIOR TO ISSUING ACCESS/WORK PERMIT Section 5 Forms Drilling and Completions HSE Meeting Report HSE Meeting Report Work Permit 6.0 INCIDENT INVESTIGATION AND ANALYSIS 6.1 OVERVIEW 6.2 INCIDENT REPORTING 6.3 ACCIDENT INVESTIGATION AND FOLLOW-UP 6.4 LOSS CONTROL STATISTICS 6.5 INCIDENT INVESTIGATION RESPONSIBILITY FLOWCHART 6.6 INCIDENT INVESTIGATION METHODOLOGY FLOWCHART 6.7 INCIDENT INVESTIGATION REPORT SUMMARY OF RESPONSIBILITIES AND EXPLANATIONS FOR FILLING OUT THE FORM Section 6 - Forms Incident Investigation Report Spill Site Assessment Basic Causes of Loss Regulatory Reporting Requirements for Spills and Releases Reportable Spill Volumes for TDG Controlled Substances OPX Consulting Inc. Table of Contents - iii

7.0 EMERGENCY PREPAREDNESS 7.1 OVERVIEW 8.0 WORK PROCEDURES 8.1 CODES OF PRACTICE 8.1.1 ASBESTOS 8.1.2 BENZENE 8.1.3 CONFINED SPACE ENTRY 8.1.4 RELEASE OF HARMFUL SUBSTANCE 8.1.5 RESPIRATORY PROTECTIVE EQUIPMENT 8.1.5.1 SELECTION, MAINTENANCE & USE OF RESPIRATORY PROTECTIVE EQUIPMENT Figure 1: Selection of Respiratory Equipment Respiratory Protective Equipment Worksheet 8.1.5.2 FIT TESTING REQUIREMENTS & PROCEDURES FOR RESPIRATORY PROTECTION 8.1.5.3 INSPECTION OF AIR PURIFYING RESPIRATORS & ATMOSPHERE SUPPLYING RESPIRATORS 8.1.5.4 CLEANING & STORAGE OF RESPIRATORY PROTECTIVE EQUIPMENT 8.1.5.5 TRAINING OF WORKERS IN THE SELECTION, USE, CARE AND MAINTENANCE OF RESPIRATORY PROTECTION EQUIPMENT 8.1.5.6 DEFINITIONS RESPIRATORY HAZARDS 8.1.6 SOUR SERVICE 8.2 WORK PROCEDURES 8.2.1 AIRCRAFT AWARENESS 8.2.2 ALL TERRAIN VEHICLES (ATVs) - ATV CHECKLIST 8.2.3 BLOWDOWNS 8.2.4 CABLES, CHAINS AND ROPES 8.2.5 CHEMICAL & BIOLOGICAL HAZARDS 8.2.5.1 ASBESTOS 8.2.5.2 BENZENE 8.2.5.3 HANTA VIRUS 8.2.5.4 SEWAGE 8.2.6 COMMUNICATION EQUIPMENT 8.2.7 COMPRESSED GAS CYLINDERS 8.2.8 CRANES AND HOISTING DEVICES 8.2.9 CRITICAL LIFT PROCEDURES 8.2.10 CROWN SAVERS 8.2.11 DRIVING CONDUCT 8.2.12 FALL PROTECTION 8.2.13 FIRE & EXPLOSION HAZARD MANAGEMENT 8.2.14 FIRE PREVENTION 8.2.15 FLAMMABLE AND HAZARDOUS LIQUID 8.2.16 FLOWBACKS 8.2.17 FUEL AND CHEMICAL STORAGE 8.2.18 GROUND DISTURBANCE 8.2.19 HAND AND POWER TOOLS 8.2.20 HEATERS & OPEN FLAME EQUIPMENT OPX Consulting Inc. Table of Contents - iv

9.0 TRAINING SAFETY PROGRAM MANUAL 8.2.21 HIGH PRESSURE GAS WELLS (EQUIPPING, START-UP & OPERATIONS) 8.2.22 HOT OILING 8.2.23 HOT TAPS 8.2.24 HOT WORK PROCEDURES 8.2.25 HOUSEKEEPING 8.2.26 HYDRATE / ICE PLUG HANDLING 8.2.27 MANAGING CONTROL OF HAZARDOUS ENERGY 8.2.28 NATURALLY OCCURRING RADIOACTIVE MATERIALS (NORM) 8.2.29 NOISE EXPOSURE 8.2.30 PIGGING GUIDELINES 8.2.31 PORTABLE PUMPING EQUIPMENT & OPERATIONS 8.2.32 PURGING 8.2.33 RIG INSPECTIONS 8.2.33.1 RIG ANCHORS 8.2.34 SAFE WORK PERMITS 8.2.35 TANK TRUCK LOADING PROCEDURES FOR FLAMMABLE LIQUIDS 8.2.36 TIMBER REMOVAL 8.2.37 TRAILERS & BUNKHOUSES 8.2.37.1 TOILETS & WASHING FACILITIES 8.2.38 TRENCHING 8.2.39 VEHICLE, MOBILE EQUIPMENT & MACHINERY 8.2.40 WELDING & BURNING 8.2.41 WILDLIFE AWARENESS 8.2.42 WORKING ALONE 8.2.43 WORKING NEAR OVERHEAD POWER LINES Section 8 Forms Figure 1: Check-in Procedure Worksheet Figure 2: Working Alone Check-in Procedure Fire and Explosion Prevention Plan Fire Tetrahedron Fall Protection Plan Form 9.1 OVERVIEW 9.1.1 SAFETY AND ENVIRONMENT ORIENTATION 9.1.2 ON-THE-JOB TRAINING 9.1.3 CORE SAFETY TRAINING 9.1.4 SUPERVISORY TRAINING 9.1.5 OPTIONAL AND NON-OPTIONAL TRAINING 9.2 SAFETY ORIENTATION 9.3 ON-THE-JOB TRAINING 9.4 OPTIONAL AND NON-OPTIONAL TRAINING 9.5 TECHNICAL TRAINING 9.6 SUPERVISORY TRAINING 9.7 TRAINING RECORDS Section 9 - Forms Checklist For Developing An On-The-Job Training Program HSE Handbook Review Questionnaire HSE Handbook Review Questionnaire ANSWER KEY OPX Consulting Inc. Table of Contents - v

10.0 CONTRACTOR OPERATIONS 10.1 OVERVIEW 10.2 SELECTION 10.3 CONTROL 10.4 FOLLOW-UP Section 10 - Forms Contractor Safety Evaluation 11.0 HEALTH AND SAFETY CONTROLS 11.1 OVERVIEW 11.2 STORAGE AND HANDLING OF HAZARDOUS MATERIALS 11.2.1 TRANSPORTATION OF DANGEROUS GOODS 11.3 OCCUPATIONAL HEALTH PROGRAMS 11.3.1 HEARING CONSERVATION 11.3.2 NATURALLY OCCURRING RADIOACTIVE MATERIALS (NORM) 11.3.3 ASBESTOS CONTROL 11.3.4 BENZENE 11.4 PERSONAL PROTECTIVE EQUIPMENT 11.4.1 GENERAL 11.4.2 HEAD PROTECTION 11.4.3 EYE AND FACE PROTECTION 11.4.4 HEARING PROTECTION 11.4.5 HAND PROTECTION 11.4.6 BODY PROTECTION 11.4.7 RESPIRATORY EQUIPMENT 11.4.8 FOOT PROTECTION 11.4.9 FIRE-RETARDANT CLOTHING STANDARD 11.4.10 PRESCRIPTION SAFETY GLASSES PURCHASE PROCEDURE 11.5 RULES AND ENFORCEMENT 11.5.1 OVERVIEW 11.5.2 ENFORCEMENT GUIDELINES 12.0 MANAGEMENT COMMUNICATION & PROGRAM AUDITING 12.1 MANAGEMENT COMMUNICATION Section 12 - Forms Health Safety and Environment Management Review 13.0 RECORDS MANAGEMENT AND DOCUMENTS 13.1 OVERVIEW 13.2 MANAGEMENT OF CHANGE 13.3 REFERENCE DOCUMENTS 13.3.1 COMPANY DOCUMENTS 13.3.2 GOVERNMENT DOCUMENTS 13.3.3 GENERAL DOCUMENTS 13.4 RECORD KEEPING OPX Consulting Inc. Table of Contents - vi

14.0 ENVIRONMENTAL STANDARDS AND GUIDELINES 14.1 OVERVIEW 14.2 WASTE MANAGEMENT 14.3 AUDITS AND INSPECTIONS 14.3.1 ENVIRONMENTAL IMPACTS 14.3.2 COMMUNICATION & REPORT 14.3.3 ENVIRONMENTAL MANAGEMENT SYSTEM SAFETY PROGRAM MANUAL 14.4 PROCEDURES 14.4.1 ENVIRONMENTAL PROTECTION - DRILLING WASTE MANAGEMENT 14.4.2 ENVIRONMENTAL PROTECTION - GENERAL HOUSEKEEPING 14.4.3 ENVIRONMENTAL PROTECTION - HISTORICAL RESOURCES PROTECTION 14.4.4 ENVIRONMENTAL PROTECTION - LEASE PREPARATION 14.4.5 ENVIRONMENTAL PROTECTION - NOISE CONTROL 14.4.6 ENVIRONMENTAL PROTECTION - SITE SELECTION 14.4.7 ENVIRONMENTAL PROTECTION - SPILL SITE RESPONSE & RECLAMATION 14.4.8 ENVIRONMENTAL PROTECTION - STORAGE 14.4.9 ENVIRONMENTAL PROTECTION - SURFACE/GROUNDWATER PROTECTION 14.4.10 ENVIRONMENTAL PROTECTION - WELL SITE RECLAMATION 14.4.11 ENVIRONMENTAL PROTECTION - ENVIRONMENTAL INSPECTION CHECKLIST 15.0 CONSTRUCTION SAFETY 15.1 INTRODUCTION 15.2 SAFETY PLAN CHECKLIST 15.3 EMERGENCY CONTACT INFORMATION 15.4 WEEKLY SAFETY MEETINGS 15.5 SHUT DOWN OF PRODUCTION Section 15 - Forms Construction Safety Plan Checklist Emergency Contact Information Lease Construction Tailgate Meeting Report Construction HSE Meeting Report Safety Meeting Attendance Ground Disturbance Permit Backfill Inspection Form 16.0 GENERAL INFORMATION 16.1 GLOSSARY OF TERMS OPX Consulting Inc. Table of Contents - vii

17.0 FORMS AND CHECKLISTS Section 17 Forms HARVARD Policy on Health, Safety and the Environment HARVARD Policy on Violence and Harassment HARVARD Policy on Drug and Alcohol HARVARD Safety Statement Worksite Safety Plan Checklist Well Safety Check and Hazard ID Service Rig Inspection Checklist Drilling Rig Inspection Checklist Monthly HSE Meeting Report Hazard Identification and Control Work Permit Incident Investigation Report HSE Handbook Review Questionnaire HSE Handbook Review Questionnaire Answer Key Health, Safety and Environment Management Review Construction Safety Plan Checklist Emergency Contact Information Construction HSE Meeting Report Safety Meeting Attendance Ground Disturbance Permit Contractor Safety Evaluation Backfill Inspection Form Drill and Completions HSE Meeting Report Lease Construction Tailgate Meeting Form OPX Consulting Inc. Table of Contents - viii

DISTRIBUTION LIST NAME LOCATION MANUAL NUMBER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 OPX Consulting Inc. Table of Contents - ix

DISCLAIMER The information and data contained in this document has been set forth to be the best knowledge, information and belief of OPX Consulting Inc. Although every effort has been made to confirm all such information and data is factual, complete and accurate, OPX Consulting Inc. make no guarantees or warranties whatsoever, whether expressed or implied, with respect to such information or data and accepts no responsibility for any loss or damage sustained by the use of this information. Any use, which a third party makes of this document, any reliance on, or decision to be made based on it, is the responsibility of such third parties. OPX Consulting Inc. accepts no responsibility for damages, if any, suffered by any third party as a result of decisions or actions based on this document. OPX Consulting Inc. Table of Contents - x

1.0 INTRODUCTION Harvard Energy Ltd. is an oil and gas exploration and development company operating primarily in Western Canada. HARVARD is committed to conducting operations in a safe and environmentally sound manner. In support of this commitment, HARVARD has developed a General Policy on Health, Safety and the Environment. A copy of this document follows in this Introduction Section. In order to fulfill this commitment, HARVARD has developed a Safety Program to ensure its operations comply with this policy. The program includes a Management Plan for implementing the Program. This manual is intended to present that Plan and to provide management, employees and contractors with the tools, information and references they need to carry out that Plan. It is HARVARD s practice to provide each user of this manual (i.e. operators, supervisors and contractors) with training in its use. This training should be considered as the primary orientation of new personnel to HARVARD s operations. Complementary documents, tools and training include HARVARD s: Health, Safety & Environment Handbook Emergency Response Plan(s) Supervisory Training This manual in its entirety should always be considered a work-in-progress. All users are encouraged to provide suggestions to the Engineering and Operations Department for improvements to its content and format. The development of this Safety Program, together with supporting training, will help all HARVARD staff, contractors and supervisors to: 1. Make maximum use of the combined resources of HARVARD, government agencies, and other outside services to: Assist with orienting, informing, guiding and motivating Company employees and contractors. Implement policies, procedures, practices, and standards relating to Company operations. Provide and maintain a safe working environment including tools, machines, and equipment. 2. Maintain effective communication. 3. Ensure immediate, competent responses when handling an emergency. 4. Control work site hazards, thus minimizing the risk to HARVARD employees, its contractors, and the public. OPX Consulting Inc. Section 1-1

All personnel directly involved with HARVARD operations, including both Company and Contract personnel, are responsible for ensuring their activities are consistent with this manual. Following is a brief description of each section of this manual: Section 2 of this manual describes the legislated responsibilities of Owners and Prime Contractors at the work site. It is critically important that HARVARD staff and well site supervisors understand their responsibilities as representatives of the Owner, who normally will be the Prime Contractor. In addition, all contractors who are employers at the well site must understand their responsibilities in providing their own safety programs and competent employees to carry out their activities. Also in this section is a summary of responsibilities of HARVARD Managers, Supervisors and Workers. Section 3 contains information to assist HARVARD management and staff to plan for implementing the Safety Program. Section 4 provides information on hazard identification and assessment. Identifying and eliminating hazards is the most important element of a safety program and must be done at every work site to comply with Provincial regulations. Section 5 deals with communication and gives the supervisor the necessary tools to communicate with other employees and all workers at the site. Once hazards are identified and procedures put into place to eliminate or mitigate the hazards it is necessary to communicate that information to all affected workers. Of particular importance in this section is the description of the use of Safe Work Permits. Section 6 presents HARVARD s procedures for incident investigation and analysis. This is an essential part of any safety program. Section 7 gives the supervisor some basic information about area emergency response plans and some suggestions for keeping area plans up to date. Section 8 presents a number of established Codes of Practice and Work Procedures. The Codes of Practice are to be followed when dealing with the subject issues. The Work Procedures presented have been developed as HARVARD s policy. This section of the manual should be considered a work in progress. The codes and procedures should constantly be reviewed for relevancy to current HARVARD policies, government regulations and practices in the industry. New codes and procedures will be developed as the need arises. Section 9 outlines the training expected of HARVARD production employees and the employees of all contractors involved at a well site. Section 10 gives the production supervisor some guidelines to use in selecting contractors in the field. Section 11 presents Health and Safety Controls. These, for the most part, are existing regulations or HARVARD policy and must be strictly adhered to. Special attention should be paid to HARVARD s Fire Retardant Clothing Standard. OPX Consulting Inc. Section 1-2

Section 12 provides some suggestions for keeping HARVARD senior management involved in the Program. Section 13 provides some guidelines for keeping records and provides a list of reference material. Section 14 is intended to provide information to the well site supervisor to help him/her deal with environmental issues encountered in the field. Section 15 provides safety information for Construction Supervisors. Section 16 includes a Glossary and is available to add additional relevant information to this manual. Section 17 includes a section of commonly used forms and checklists. OPX Consulting Inc. Section 1-3

SECTION 1 FORMS Policy on Health, Safety and the Environment Policy on Drug and Alcohol Policy on Violence and Harassment Petroleum Industry Guiding Principles for Worker Safety OPX Consulting Inc. Section 1-4

Harassment and Violence Workplace Policy Harvard Energy Ltd. will not tolerate unlawful workplace conduct, including discrimination, intimidation/harassment or violence. Harvard is dedicated to maintaining a positive workplace where everyone adheres to relevant human rights legislation and acts ethically, honestly and treats colleagues with dignity, fairness, and respect. This policy applies to management, employees, and contractors of Harvard. This policy further applies to interactions on or off Company premises and includes formal and informal Company social gatherings, conferences and client-related events. This policy is not intended to constrain reasonable and appropriate consensual social interactions. Harassment whether or not it is intentional or directed toward a specific person, includes unwanted physical, verbal, written, electronic, graphic or non-verbal behavior that results in intimidation hostility or violence or contributes to an offensive workplace. Any incident or complaint involving alleged harassment or threatened/actual violence should be reported promptly to either any member of the Board of Directors or any Officer of the Corporation. Any incident or complaint will be treated sensitively, promptly and in confidence, to the extent practical; and investigate thoroughly. Harvard will attempt resolution, however, disciplinary action up to and including termination can be taken for violations of this policy. Filing a known false complaint or retaliation against complaints is not tolerated and will be subject to disciplinary action, also including termination. OPX Consulting Inc. Section 1-6

Alcohol and Drug Policy Harvard Energy Ltd. is committed to protecting the health and safety of all individuals affected by our activities as well as the communities in which we work. We recognize that the use of illicit drugs and the inappropriate use of alcohol and medication can adversely affect job performance, the work environment and the safety of our employees, contractors and the public. This policy relates to all management, employees and contractors when they are engaged in Company business, working on or off Company premises. Harvard s contractors are expected to develop and enforce Alcohol and Drug policies that are consistent with the policy. The following are expressly prohibited while on Company business or Company premises: The use of possession, distribution, offer for sale of illicit drugs or illicit drug paraphernalia; The unauthorized use, possession, distribution, offering for sale of alcoholic beverages; The possession of prescribed medication not authorized or specifically prescribed for personal use; Reporting for duty impaired by any of the foregoing substances. Investigation procedures that may be utilized in support of this Policy include: Pre-assignment testing if in safety sensitive situations; Reasonable cause testing; Post-incident testing; Reasonable searches of Company grounds; Impaired driving investigations. Disciplinary action up to and including termination will be taken for violations of this policy. OPX Consulting Inc. Section 1-7

Petroleum Industry Guiding Principles For Worker Safety We, the members of the petroleum industry, have a responsibility to protect all workers engaged in its activities from personal injury and health hazards. To meet our responsibility we will operate under the following guiding principles: RESPONSIBILITY The operating company, when acting as prime contractor, is responsible for coordination and general supervision of all activities at the worksite, including activities carried out by contractors, subcontractors, service companies and suppliers. While all parties have a responsibility to promote worker safety, the operating company recognizes its leadership role worksite situations. It is the responsibility of workers and employers to refuse to perform unsafe work practices. PRIORITY Activities will be conducted on the basis that safety of all personnel is of vital importance, whether those personnel are employed by an operating company, a contractor, a subcontractor, a service company or a supplier. RECOGNITION The process of selecting contractors, subcontractors, service companies and suppliers, and the administration of contracts, will include recognition and support of good safety performance. Support and recognition based on good safety performance will also be provided by all employers to their employees. IMPROVEMENT The operating company, in cooperation with service companies within the industry, will promote methods and practices that have potential for improving safety performance. Wallace E. Baer President/CEO Enform Signed on behalf of the following six sponsoring associations representing the Canadian petroleum industry: Signature Title Company Date Petroleum Industry Guiding Principles For Worker Safety - www.enform.ca Revised September 2008

2.0 RESPONSIBILITIES 2.1 HARVARD HARVARD s overall company responsibilities are to: Insist on safe performance throughout operations by ensuring contractors and employees are competent. Have an effective safety program. Ensure the safety program and operations comply with contractual and regulatory requirements. Ensure contractors and employees know HARVARD s expectations. Provide sufficient time for contractors and employees to do their job properly. Hire contractors who have Safety Programs and good safety records. Perform responsibilities of Prime Contractor/Owner 2.1.1 Owner/Prime Contractor Responsibilities Every work site must have a Prime Contractor, if there are two or more employers involved in work at the worksite at the same time The Prime Contractor for a worksite is the contractor, employer or other person who enters into an agreement with the owner of the work site to be the Prime Contractor, or if no agreement has been made or no agreement is in force, the owner of the work site. Owners, who have limited capabilities of performing the Prime Contractor function have the opportunity to assign Prime Contractor responsibilities to a party that is better equipped to manage those responsibilities. 2.1.2 Owner Responsibilities The Owner has two alternatives when dealing with the Prime Contractor issue. The Owner can either keep the Prime Contractor responsibilities or it can enter into an agreement with another party so that the party assumes the Prime Contractor responsibilities. This agreement should be completed in written form. If the Owner transfers the responsibility to another party, the Owner will be expected to exercise due diligence in transferring those responsibilities. That is, the Owner must do everything reasonably practicable to ensure that the contractor assigned the responsibility is capable of fulfilling the Prime Contractor responsibilities. The Owner must be able to demonstrate that the agreement is likely to establish compliance. Follow-up on the Owner s part is necessary to ensure the system is maintained. OPX Consulting Inc. Section 2-1

Other considerations include: Once the Owner enters into an agreement, it should step away and not be involved as a Prime Contractor of the work site. If the owner starts to assume the role of Prime Contractor, it may become liable for those responsibilities even though it has entered into an agreement to have someone else assume those responsibilities. The Prime Contractor, be it the Owner/Operator or some other party, is responsible for ensuring that the Occupational Health and Safety Act, Code, and its regulations are complied with at the work site. In most situations, the Prime Contractor will meet these responsibilities through the development of a system that will ensure compliance. The Prime Contractor at a work site has the overall responsibility for occupational health and safety. However, this does not relieve other employers of their responsibilities at the work site. The Well Site Supervisor usually accepts the role of Prime Contractor s representative at the work site. In addition to developing a system for ensuring compliance, the role of the Prime Contractor will be to implement the system, monitor to ensure that it is functioning, and then make any necessary changes to ensure the system continues to perform as intended. The advantages of the system approach are that the process is manageable and that the Prime Contractor limits its responsibilities. If the Prime Contractor were to take direct control of all occupational health and safety activities at the work site, particularly on a large site, it would become an onerous task. If the Prime Contractor begins to take a more assertive role in directing the occupational health and safety activities of other employers on the work site, it may end up with those responsibilities. OPX Consulting Inc. Section 2-2

2.1.3 Work Site Safety Plan To successfully address the requirements for a system, the Prime Contractor should develop a Work Site Safety Plan that is coordinated under the direct supervision of a SITE DESIGNATE. A Work Site Safety Plan communicates the Prime Contractor s system of managing health and safety on the work site. The Work Site Safety Plan Checklist found behind the Safety Management tab of this Manual outlines the elements for developing a specific Work Site Safety Plan. The generic plan must be carefully reviewed as it may not be applicable to the particular conditions experienced on a specific work site, or to the role of the Site Designate on a particular project. Employers coming to the site should have functioning health and safety programs in place. All workers and employers should be competent for the tasks they intend to perform. (i.e. Workers are adequately qualified, properly trained and with sufficient experience to safely perform work without supervision [or with only a minimum degree of supervision]). It is important to monitor the effectiveness of the plan, keep records and document the activities around establishing and maintaining this system. If doubt ever arises, this proves that everything reasonably practicable has been done to make the work site safe. The minimum that will be accepted are the standards demonstrated by the industry. Additional tools for developing a Work Site Safety Plan as well as the Work Site Safety Plan Checklist are found at the end of this section.. 2.1.4 Monitoring Process To ensure that the responsibility for health and safety at the work site is fulfilled, the Prime Contractor must set up a system for monitoring the safety performance of employers, workers and suppliers. The Prime Contractor must evaluate the outputs of the system/process in order to verify its effectiveness. The following are some monitoring system/process tips: Instruct employers on site to investigate all accidents/incidents and submit documentation to you. Require that all accidents/incidents be analyzed and discussed by the workers during a safety meeting. Ensure that the workers are identifying, reporting and recording hazards on the site. Ensure that workers are correcting the hazards identified. Ensure that critical or repetitive hazards are discussed by workers during a safety meeting. OPX Consulting Inc. Section 2-3

Participate in New Employee Orientations. Educate the new workers to HARVARD and its plan to control accidents and near miss accidents. Require worker participation in safety inspection/audits. Promote safety awareness on the work site through leadership by example. Ensure all work site emergency safety equipment is easily identifiable to all site personnel (e.g. fire suppression equipment, first aid room, stretcher, etc.) and is in good operating condition. Have work site safety on site meeting agendas. 2.2 MANAGERS RESPONSIBILITIES Managers protect employees and HARVARD by: Insisting on performance and behavior that meet the standards of HARVARD s safety program. Encouraging employee involvement in safety by demonstrating managements commitment to safety. Ensuring Company, Contractor and Subcontractor operations comply with government safety requirements. Providing adequate supervision at every work site. Ensuring accidents and incidents are reported and investigated and corrective actions are taken. Providing appropriate, well-maintained safety and other equipment required for each job. Ensure public consultation is included in project planning. Ensuring workers are adequately qualified to perform their work. Ensuring training needs are identified and met. 2.3 SUPERVISORS RESPONSIBILITIES Supervisors maintain a safe work site by ensuring: Workers know what safety responsibilities are expected of them. Training needs are identified and addressed. OPX Consulting Inc. Section 2-4

Unsafe conditions and behavior are corrected immediately. Only safe work practices are used. Appropriate equipment is available and well maintained and workers are trained to safely operate the equipment. Regulatory requirements are met. Hazards are identified, documented, and removed where possible. Workers know and are prepared to deal with the hazards of their work and any specific hazards on the work site. Personal protective equipment is available, properly used, stored, maintained and replaced when necessary. All accidents and incidents are reported. 2.4 WORKERS RESPONSIBILITIES Workers protect themselves, fellow workers, the public and the environment by: Being thoroughly familiar with the safety program. Actively participating in safety program development and maintenance. Following safety standards and safe work procedures set out by the employer, employees and regulatory requirements. Refusing to perform work when unsafe conditions exist (as defined in provincial occupational health and safety legislation). Refusing to perform work they are not competent to perform. Reporting unsafe conditions and potential hazards to supervisors. Immediately reporting to supervisors all accidents, incidents, injuries and illnesses. Participating in all training offered by the employer, either on or off the work site (e.g. first aid or H 2 S). Using required personal protective and safety equipment. Being trained in the safe operation of equipment. Checking tools and equipment, including personal protective and safety equipment, for hazards before using them. OPX Consulting Inc. Section 2-5

Knowing the location, type and operation of emergency equipment. Presenting themselves physically and mentally fit at the start of each working shift, capable of performing their duties safely and efficiently. Reporting to the Supervisor any physical or mental circumstances such as illnesses or fatigue as this may impede the worker from safely completing their assigned tasks. Performing their functions as efficiently as possible while giving due regard to the safety of themselves, their co-workers and the public. Cooperating with others during normal and emergency conditions. Having cranial and facial worn at a length that will not obstruct vision, snag moving parts or if applicable, prevent the worker from utilizing a breathing apparatus or mechanical resuscitator in a toxic or oxygen environment. Ensuring they wear clothing that fits close to the body and do not wear dangling jewelry (i.e. necklaces, wristwatches, bracelets) when working near moving parts of machinery or electrically energized equipment. Not smoking in any location regardless of a Hot Permit issued, except for designated areas. Strike anywhere matches and single action lighters are not permitted. Informing the Harvard Representative if they are taking medication prescribed by a physician that could impair their judgment. It may be necessary to adjust the workers duties accordingly. Not being in possession of, or under the influence of, alcohol, illegal or mind altering drugs. Workers will not be permitted to enter or be allowed to remain on a Harvard Work Site. Adhering to Harvard s policy regarding firearms or explosives. Both firearms and explosives are not permitted on a Harvard operated property unless required by job responsibilities (flare pistol, seismic work). Refraining from engaging in practical jokes, wrestling and other forms of horseplay on Harvard premises. Reviewing applicable Data Sheets, as per WHMIS legislation, prior to handling chemicals. Understanding Harvard prohibits all types of harassment and violence in the workplace. Harassment, including harassment based on characteristics specified in human rights legislation, such as sex, race, national origin, religion, disability and age is illegal and will not be tolerated. As an employer, Harvard has a legal duty to maintain a safe and harassment free workplace. Actual or threatened violence is strictly prohibited. Incidents of this nature are to be reported to Harvard management. Ensuring they have the necessary training and when applicable possesses a valid certificate when responsible for the transporting of dangerous goods and handling material or wastes. OPX Consulting Inc. Section 2-6

2.5 SAFETY PROFESSIONALS RESPONSIBILITIES The responsibilities of the Safety Professional are to: SAFETY PROGRAM MANUAL Develop and maintain a safety program manual and ensure this document is available to all employees. Maintain copies of legislation relevant to Company s operations and ensure copies are available at all work sites. Maintain supporting documentation (e.g. standard work procedures, codes of practice, emergency response plans and other detailed instructions for training, inspections, audits, accident reporting, investigation and other activities) and ensure copies are accessible at all work sites. Maintain files for results of audits, inspections, incident investigation reports and safety and environmental performance assessments. Develop and support loss control activities including inspections, loss control meetings, new employee orientations, on-the-job training sessions, safety and environmental audits and emergency response drills. Develop and support a communication framework that may include management walkarounds at work sites, newsletters, memos, posters or other communication instruments. Contribute to industry Health, Safety & Environment associations. Provide assistance to field personnel in the response and reporting of Safety and Environmental incidents. 2.6 VISITORS RESPONSIBILITIES Visitors must: Ensure they receive an orientation before working/entering work sites. Follow the instructions of the site supervisor or personal escort. Wear personal protective equipment when required. Never walk about a work site unescorted. 2.7 DUE DILIGENCE See Workplace Health & Safety bulletin and the Bill C-45 Explanation at end of this Section. OPX Consulting Inc. Section 2-7

2.8 DRILLING & COMPLETIONS SPECIFIC RESPONSIBILITIES Rig Site Supervisor -Responsibilities and Duties Corporate and Engineering HARVARD, as owner and licensee of the well and wellsite, has an overall responsibility to ensure the safety of workers and the public, the protection of the environment and the conservation of resources related to all activity at the wellsite. Many rules govern the development, planning and execution of oil and gas operations, including the management of Health and Safety of workers on the worksite. These rules are identified in various acts and regulations, as well as guides and industry recognized standards and recommended practices. The responsibilities for compliance, with many of these rules, are assigned to the people planning, designing and programming of well operations both at the office and field level. When these responsibilities are assigned to the Wellsite Supervisors, the Wellsite Supervisors conduct their activities as the operator/prime contractor s representative, and within HARVARD, is considered an employee equivalent in regards to legislated acts and regulations. Safety HARVARD has overall responsibility for health and safety at the wellsite. In fulfilling this responsibility, HARVARD will ensure that contractors and employers at the wellsite comply with all applicable legislation by monitoring the activities at the site to verify compliance with applicable legislation and safe work procedures. The following responsibilities are assigned to HARVARD to help achieve this obligation: Implement an effective safety program, including visible management support, that meets the requirements for a basic safety program as described in IRP #9, ensuring that all employers on site are aware of, and comply with, all requirements of this program. Select contractors that have implemented a safety program that effectively manages their own operations, and that meets the requirements for a basic safety program as described above, including safe work procedures and hazard assessments of the hazardous procedures completed. Any independent contractors or self-employed workers, who do not have a safety program, will be adopted into either HARVARD s safety program or the safety program of HARVARD they are sub-contracted to. Coordinate the efforts and actions of all contractors at the wellsite, ensuring all employers are aware of their roles and responsibilities, and that they have been informed of any known hazards of the specific wellsite, program or materials, ensuring that procedures are in place to eliminate or control these hazards. Ensure that all safety procedures are compatible and verify that contractors are providing their workers with training and supervision that addresses the hazards of the tasks they are exposed to at the wellsite. It is not HARVARD s role to do this training or supervision for contracted workers, but to ensure that contractors provide training and supervision in a manner that meets legislated requirements as a minimum, as per Section 7.4.3. of IRP #7. (Please see IRP#7 on page 2-14) OPX Consulting Inc. Section 2-8

Ensure that site-specific emergency response procedures are in place and that all employers and workers know these procedures, have completed drills and are prepared to follow them. Ensure that Site Supervisors safety responsibilities have been clearly established and communicated to all workers completing supervisory activities and that monitoring is completed on a regular basis. Conduct an assessment of the supervisor s work experience and training to ensure he has the skills and knowledge required to meet the requirements for the work and duties being assigned. The evaluation will include the steps and content described below, and be documented, signed and kept on file by the person to whom the supervisor is reporting to. Wellsite Supervisor - General Duties HARVARD must provide a competent Wellsite Supervisor who has been assigned specific duties and responsibilities as a representative, with HARVARD determining if the supervisor is competent based on the job requirements, the duties assigned and assessment of the Supervisor s training and work experience. The Wellsite Supervisor is generally responsible for managing Health and Safety on the worksite, including directing and coordinating all employers at the wellsite. The specific duties will vary considerably depending on the nature of the work and how the operator assigns certain responsibilities. Safety In terms of health and safety management, as HARVARD s representative, the Wellsite Supervisor s responsibilities include the following: Identify themselves at the wellsite, through use of the applicable Safety Statement, ensuring they can be either easily located and contacted or have identified an alternate, competent, person who must also be easily contacted if the Wellsite Supervisor becomes unavailable for any reason. Note: Site Supervisors are required to be on the worksite during all non-standard/critical work tasks. Ensure that all contractors on the worksite effectively implement their own safety programs and work procedures, and that all contractors understand and agree to follow all requirements of HARVARD s Safety Program that is not identified within their own Safety Program. Ensure that applicable corporate information has been posted in an appropriate place on location, including the posting of HARVARD s Health and Safety Policy and Partnership Certificate within the supervisor s workspace, and that a copy of the Safety Statement and Petroleum Industry Guiding Principles has been posted in the contractors workspace ( doghouse ). OPX Consulting Inc. Section 2-9

Identify and document the name of the On-Site Supervisor for each employer prior to starting any work and review and clarify the roles and responsibilities of all Contractors On- Site Supervisors prior to starting any work. Check that all contractors have provided the applicable employees, including visitors, with the training and supervision described in Section 7.4.3. of IRP #7. (Please see IRP#7 on page 2-14) Identify inexperienced workers arriving on the worksite, ensuring these workers receive adequate supervision and provide a wellsite orientation on arrival at the wellsite. Coordinate the efforts of all employers at the wellsite, resolving any discrepancies between conflicting work procedures, identifying the hazards related to the specific wellsite, the planned program or the materials provided by the contractors. Inform all employers of the hazards identified and ensure proper controls are in place before the work begins. Establish and coordinate site-specific emergency response procedures and drills. Ensure the hazard assessment and identification programs described in the Hazard Identification and Assessment section of the Safety Program is implemented and reviewed with relevant workers on the worksite. Ensure the hazards identified on the worksite are communicated through the safety meeting and work permit systems, ensuring safety meetings are conducted prior to all nonstandard/critical operations. Ensure well control and blowout prevention measures meet regulations and operators requirements and the appropriate information and procedures have been posted and reviewed with all personnel on site. Monitor the work performed by all employers to verify compliance with safety legislation and Safety Program requirements. Check that the procedures for handling, transportation, disposal, storage and use of all hazardous substances follow applicable regulations and safe practices. Monitor the wellsite for proper use, handling, storage and maintenance of personal protective equipment. Ensure appropriate equipment is utilized to detect and control Hydrogen Sulfide and other flammable or poisonous substances that may be emitted at the worksite. Ensure work is stopped when an unsafe act or condition is identified, resuming work only after the hazard is removed or safe procedures have been established. Ensure all emergency equipment and specialized safety equipment is easily identifiable and readily available to all site personnel. Ensure incidents/accidents or near misses are promptly reported and investigated, as described within the Incident Investigation Section 6.0. OPX Consulting Inc. Section 2-10

WORK EXPERIENCE ASSESSMENT Additional Job Specific Skill Requirements Good management practices require that results be compared to corporate goals and expectations on a regular basis, in order to identify performance gaps and opportunities for improvement. The performance of Wellsite Supervisors must be reviewed and evaluated as part of this process. Documentation of the actions taken at the wellsite is an important step in demonstrating due diligence in the performance of assigned duties. Records of specific items such as safety meetings, practice drills, inspections, pressure tests, etc., will be collected on the worksite and forwarded to Calgary for filing. HARVARD s operators and Wellsite Supervisors will implement the use of the Work Site Safety Plan Checklist at appropriate times during the project to ensure that specific safety program steps have been completed. HARVARD engineering staff and management directing Wellsite Supervisor activities will conduct worksite reviews by visiting the wellsite on a regular basis to observe operating procedures, check documentation kept on location and get feedback from the contractors on the worksite. Specific knowledge and experience requirements for a particular job depends on the type of work planned, the depth and complexity of the well, the reservoir fluid properties, H 2 S potential, the location of the well and any specific issues related to public or environmental impact. The assessor must have this knowledge about the job prior to assessing and assigning an appropriate supervisor. Additional requirements for the job must be included in the assessment of potential supervisors based on these factors. Assessment Process and Content Requirements For each task assigned, HARVARD will determine the skill level of the site supervisor, ensuring that the supervisor s skill level is appropriate to the requirements of the assigned job. To determine if the supervisor s skills are appropriate, the assessment must be based on the supervisor s education, training and work history record, plus the skills observed by the references and the assessor. HARVARD will indicate on the assessment record if the supervisor either meets or exceeds requirements or requires additional training or experience to complete the assigned tasks. Agreement of Duties In addition to the required training, every Wellsite Supervisor completing work for HARVARD must have a written description and agreement of the duties and responsibilities assigned to him and has experience with the type of work planned. This written agreement must be renewed and updated at least every two years, and whenever the assigned duties are changed. In any event, the assessment on file will include skill requirements for the major operations of the actual wellsite work being supervised. As a minimum, these duties must include those listed above. OPX Consulting Inc. Section 2-11

Required Information Record of Work History and References Name, address and telephone number of the site supervisor List of training certificates and expiry dates Record of all formal education Record of work experience including o Relevant industry experience, other than as a Wellsite Supervisor, and o Experience as a Wellsite Supervisor List of references starting with the last three employers (or back five years), including: o Name and telephone number of references, including company or employer name, o Dates when candidate was employed including month and year, and o If the reference was contacted by the assessor. Information about the person who did the assessment including: o Name, company/employer name, o Job title or position, address and telephone number, and o Date the assessment was completed or updated. Minimum Skill Assessment Requirements The candidate must be assessed as having the skills required in the following categories: Supervision and leadership, and the demonstration of safe personal work habits. Establishment and maintenance of effective working relationships. Effective communication of operational and safety requirements. Implementation of HARVARD s safety program, including the use of appropriate PPE. Ensuring contractors have, and are using, safe work procedures that follow regulations. Performance of hazard assessments and implementation of hazard controls. Ensuring the detection and control of hazardous atmospheres is conducted. Emergency Response and establishment of site-specific emergency response procedures. Carry out operations in accordance with environmental regulations, including the disposal of wastes, BOP training and drills and training certificates. OPX Consulting Inc. Section 2-12

Containment and reporting of spills, leaks or other environmental damage, as per incident reporting guidelines (see Section 6.0). Ensuring BOPs and other well control equipment meet regulations, and is function tested prior to commencing operations. Ensuring all operations comply with regulations and industry standards. Planning and coordinating equipment and service requirements. Ensuring transportation of equipment, rig and equipment layout and spacing meet equipment spacing regulations. Contractors Supervision Legislation requires that contractors provide their workers with appropriate training and supervision to ensure they carry out their work in a safe manner. HARVARD requires all employers to provide the following: A wellsite orientation on their first day of employment A safety program that includes information that identifies the worker as responsible to follow the requirements of the safety program. Information to ensure workers are aware of their rights and responsibilities under OH&S legislation, including their right and obligation to refuse to do unsafe work. Safe work procedures and practices for the assigned tasks, including rules from relevant safety legislation. Direct supervision, by a competent worker, of workers new to a position until they have demonstrated the ability to perform the assigned tasks safely. Frequent inspections of the wellsite, to ensure workers are following safe worker practices and applicable OH&S regulations. A hazard identification program/process, ensuring all personnel on the worksite are made aware of the hazards and procedures to remove or control the hazards. Directions to stop work when unsafe acts or conditions are identified then take action to ensure conditions are safe before work is resumed. Instructions, as required by WHMIS legislation, to ensure all hazardous materials are identified and PPE is used to protect the worker from exposure. Site-specific emergency response procedures are in place and all workers are prepared to play their role in the event of an emergency. Directions for the prompt reporting and investigation of any incidents on location. OPX Consulting Inc. Section 2-13