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

2.9 IRP #7 OPX Consulting Inc. Section 2-14

Standards for Wellsite Supervision of Drilling, Completion and Workovers Industry Recommended Practice (IRP) Volume 7-2002 Sanctioned 2002-03

This document as well as future revisions and additions are available from: Enform 1538 25 Avenue NE Calgary, Alberta T2E 8Y3 Phone: (403) 250-9606 Fax: (403) 291-9408 Website: www.enform.ca

Table of Contents 7 Standards for Wellsite Supervision of Drilling, Completions and Workovers... 1 7.0 Acknowledgement & Disclaimer...1 7.1 Introduction...5 7.2 Scope...6 7.3 Definitions...7 7.4 Roles, Responsibilities and Duties...9 7.4.1 Operator and Prime Contractor...9 7.4.1.1 Regulatory Compliance...9 7.4.1.2 Safety...10 7.4.2 Wellsite Supervisor...12 7.4.2.1 General Duties...12 7.4.2.2 Safety...13 7.4.3 Employer s Supervision...15 7.5 Requirements for Assigning Duties of Wellsite Supervisor...17 7.5.1 A Supervisor Must be Assigned...17 7.5.2 Agreement of Duties...17 7.5.3 Identify Wellsite Supervisor...18 7.6 Training Requirements...19 7.6.1 Wellsite Supervisor...19 7.6.2 Operator or Prime Contractor...19 7.6.3 Training Requirements...20 7.6.4 Description of Training Courses...21 7.6.4.1 Safety Management and Regulatory Awareness for Wellsite Supervision...21 7.6.4.2 Safety Management and Regulatory Awareness for Wellsite Supervision (Refresher)...21 7.6.4.3 Second Line Supervisor s Well Control...22 7.6.4.4 Well Service Blowout Prevention (BOP)...22 7.6.4.5 Detection and Control of Flammable Substance...22 Standards for Wellsite Supervision of Drilling, Completions & Workovers Table of Contents i

7.6.4.6 Workplace Hazardous Materials Information Systems (WHMIS) Training...22 7.6.4.7 Standard First Aid...23 7.6.4.8 Transportation of Dangerous Goods (TDG)...23 7.6.4.9 H 2 S Alive...23 7.7 Work Experience Assessment...24 7.7.1 Requirement for Assessment...24 7.7.2 Frequency of Re-Assessment...25 7.7.2.1 Continuous Work Situations...25 7.7.2.2 Changes in Job Assignment...25 7.7.3 Assessment Process and Content Requirements...26 7.7.3.1 Process for Assessment of Skill Level...26 7.7.3.2 Required Information Record of Work History and References26 7.7.3.3 Minimum Skill Assessment Requirements...28 7.7.3.4 Additional Job Specific Skill Requirements...30 7.8 Performance Evaluation and Audits...31 7.8.1 Documentation...32 7.8.2 Inspections and Audits...33 7.8.3 Government Inspections...34 Appendix A :...35 Levels of Control and Responsibility for Safety Management...35 Appendix B :...36 Notice of Wellsite Supervisor (Sample)...36 Standards for Wellsite Supervision of Drilling, Completions & Workovers Table of Contents ii

7 Standards for Wellsite Supervision of Drilling, Completions and Workovers 7.0 Acknowledgement & Disclaimer This Industry Recommended Practice (IRP) is a set of best practices and guidelines compiled by knowledgeable and experienced industry and government personnel, and is intended to provide the operator with advice regarding STANDARDS FOR WELLSITE SUPERVISION OF DRILLING, COMPLETIONS AND WORKOVERS. It was developed under the auspices of the Drilling and Completions Committee (DACC). DACC is a joint industry/government committee established to develop safe, efficient and environmentally suitable operating practices for the Canadian Oil & Gas industry in the areas of drilling, completions and servicing of wells. The primary effort is the development of IRPs with priority given to: Development of new IRPs where non-existent procedures result in issues because of inconsistent operating practices. Review and revision of outdated IRPs particularly where new technology requires new operating procedures. Provide general support to foster development of non-irp industry operating practices that have current application to a limited number of stakeholders. Standards for Wellsite Supervision 1 Drilling, Completions and Workovers

The recommendations set out in this IRP are meant to allow flexibility and must be used in conjunction with competent technical judgement. It remains the responsibility of the user of the IRP to judge its suitability for a particular application. If there is any inconsistency or conflict between any of the recommended practices contained in the IRP, and the applicable legislative requirement, the legislative requirement shall prevail. Every effort has been made to ensure the accuracy and reliability of the data and recommendations contained in the IRP. However DACC, its subcommittees, and individual contributors make no representation, warranty, or guarantee in connection with the publication or the contents of any IRP recommendation, and hereby disclaim liability of responsibility for loss or damage resulting from the use of this IRP, or for any violation of any legislative requirements. This IRP has been sanctioned (sanction = review and support of the IRP as a compilation of best practices) by the following organizations: Alberta Energy and Utilities Board Alberta Human Resources and Employment British Columbia Workers Compensation Board Canadian Association of Oilwell Drilling Contractors Canadian Association of Petroleum Producers International Coil Tubing Association Oil & Gas Commission, British Columbia Petroleum Services Association of Canada Saskatchewan Energy & Mines Saskatchewan Labour Standards for Wellsite Supervision 2 Drilling, Completions and Workovers

The following list of individuals participated in the development of this Industry Recommended Practice (IRP) through the DACC sub-committee and/or one of several working teams responsible for various components. Apologies to anyone who may have inadvertently been missed. DACC Sub- Committee Members Doug Fletcher Les Groeller Kenn Hample Barry Holland Ron Hutzal Rod Loewen John Mayall Don Myers (CHAIR) George Myette Mark Nicklom Kim Richardson Bob Ross Brad Rowbotham Ken Shewan Murray Sunstrum Jack Thacker Willy Zukiwski Petro-Canada Shell Canada Alberta Workplace Health and Safety Workers Compensation Board of British Columbia Noyes Supervision Workers Compensation Board of British Columbia EUB - Alberta Burlington Resources (Canadian Hunter) Pajak Engineering Bissett Resources Marathon Oil Saskatchewan Labour, OH&S Division Roll'n Oilfield Industries Ltd. Frontier Engineering Canadian Petroleum Safety Council Husky Oil PanCanadian Standards for Wellsite Supervision 3 Drilling, Completions and Workovers

Other Contributors: Ron Berg Precision Drilling Bob Cunningham Canadian Petroleum Safety Council Adel Girgis AEUB Dave Graber PanCanadian Garth Gramlich Wayne Harvey Ron Lapp PanCanadian Safety Consultant Jade Drilling John Miller PanCanadian Ron Miller Consultant Lorne Polzin Barry Rock Petroleum Industry Training Service Shell Canada Jim Shaffer Bob Stockton Petroleum Industry Training Service Consultant Jim Storbakken Imperial Oil Rod Thomas Layne Wilk Bonus Resources Precision Well Servicing Standards for Wellsite Supervision 4 Drilling, Completions and Workovers

7.1 Introduction Drilling, completions and well workovers involve a wide variety of operations that often require a number of contractors, technical services and suppliers working together at the wellsite. These operations must be planned and executed by qualified and competent people at all levels to ensure the safety of workers and the public, the protection of the environment and the conservation of natural resources. The well owner or operator conducting these operations has overall responsibility for achieving these goals. The wellsite supervisor representing the operator or prime contractor plays a key role by directing and coordinating all employers at the wellsite to implement the planned work program. The purpose of this IRP is to recommend minimum standards to ensure that the operator or prime contractor provides competent supervision at the wellsite. The impetus for the development of this IRP was a growing need to improve minimum standards for safety management at the well site. Therefore, the primary focus during the development of this IRP was on safety. However, compliance with legislation and industry standards that relate to environmental protection and resource conservation is also a goal in these qualification standards. Standards for Wellsite Supervision 5 Drilling, Completions and Workovers

7.2 Scope This IRP deals with well operations that are generally known in the industry as drilling, completions and workovers. Minor well servicing on completed wells, which do not require removal of the wellhead and do not require the installation of temporary blow out prevention equipment to ensure well control during the operation, is beyond the scope of this IRP. However, the responsibilities of the prime contractor, in terms of safety management, are essentially the same for any operation involving two or more employers at a wellsite. The subject of the IRP is supervision at the wellsite by the prime contractor, which is usually the operator. Each employer or contractor at the well site must also provide competent supervision for their employees. Responsibilities of an employer s supervisor are discussed relative to the duties of the prime contractor s supervisor. Specific qualification requirements for supervisors of other employers at the wellsite are not part of this IRP. While the focus of the IRP is the wellsite supervisor, it must be recognized that the responsibilities are basically those of the operator and/or the prime contractor. Therefore the operator and/or prime contractor must have a good understanding of these requirements and a clear agreement with the wellsite supervisor as to how these obligations will be met. These recommendations are based on regulatory compliance and due diligence. The specific requirements for the work planned in drilling, completions and workover operations vary widely and part of the operator s due diligence is to assign competent supervision for the specific work being supervised. This IRP does not attempt to define supervisor competency requirements for every type of job but does describe the minimum steps the operator or prime contractor should take in making this determination. Standards for Wellsite Supervision 6 Drilling, Completions and Workovers

7.3 Definitions The following basic principals and definitions are used throughout this IRP. Please refer to the diagram in Appendix A for further clarification. Prime Contractor: When workers from more than one employer are working at a wellsite then one party must have overall responsibility for safety at that wellsite and co-ordination of all employers to carry out the planned work. In Alberta this party is known as the prime contractor and this term will be used throughout this IRP. In other jurisdictions this specific term may not be used, but the legislation has similar requirements and responsibilities for this function. Operator: The owner of the wellsite is the prime contractor unless he has specifically assigned this responsibility to another party by written agreement and has taken steps to ensure that the party is capable of fulfilling all the duties and responsibilities required of a prime contractor. When a well has more than one owner, the owner who is assigned as the operator has the responsibilities of prime contractor. Generally this is the licensee of the well. The term operator will have this meaning throughout this IRP. Standards for Wellsite Supervision 7 Drilling, Completions and Workovers

Wellsite Supervisor: The term wellsite supervisor is commonly used to describe the individual who is representing the operator or prime contractor at the wellsite and is generally responsible for directing all employers at the wellsite. The wellsite supervisor is therefore the representative of the prime contractor at the wellsite. This is the job function and the meaning of the term wellsite supervisor that is the subject of this IRP. Other commonly used terms for this person are consultant, company man, and engineer (the use of 'engineer' must be avoided unless the individual is a registered P. Eng.). Employer: In this document this term means any company that has one or more employees at the wellsite. This includes drilling contractors and service companies or 'sub-contractors' commonly referred to in the industry. It also includes any small contractors or businesses that have one or more people doing work at the wellsite whether they are employees, owner operators or self employed workers. Employer s Supervisor: In OH&S legislation it is a general requirement that employers provide their workers with adequate training and supervision. There are various detailed requirements that help define what constitutes adequate supervision and a competent supervisor. The term employer s supervisor in this IRP refers to the person directly responsible for the supervision of the work and workers of a specific employer at the wellsite. Examples of an employer s supervisor are: rig manager, driller, truck push, frac crew supervisor, logging supervisor, drill stem tester, power tong operator, cementing supervisor. Standards for Wellsite Supervision 8 Drilling, Completions and Workovers

7.4 Roles, Responsibilities and Duties 7.4.1 Operator and Prime Contractor 7.4.1.1 Regulatory Compliance The operator, as owner and licensee of the well and wellsite, has 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 and in the wellbore. There are many rules governing the design, planning and execution of oil and gas operations. These are provided in various legislated acts, regulations and guides as well as recognized standards and IRPs. The operator must ensure compliance with all of these. Responsibility for compliance with many of the rules may be assigned to people doing the planning, design and programming of well operations at the office level. When these programs are implemented in the field, the wellsite supervisor represents the operator/prime contractor. Standards for Wellsite Supervision 9 Drilling, Completions and Workovers

7.4.1.2 Safety The prime contractor has overall responsibility for health and safety at the wellsite. In fulfilling this responsibility, the prime contractor must ensure that contractors and employers at the wellsite comply with all applicable legislation. The following steps are recommended to help achieve this obligation: Implement an effective safety program that meets the requirements for a basic safety program as described in IRP Volume 9. Ensure all employers on site are aware of and comply with all requirements of this program that exceed or supplement their own safety program. Use employers at the wellsite that have an effective safety program in place for their own operations that meets the requirements for a basic safety program as described above, including safe work procedures for the work they do. All independent or self-employed workers who do not have their own safety program must be included in the safety program of the prime contractor or another employer on site. Co-ordinate the efforts of all employers at the wellsite. Ensure all employers, supervisors and workers know what their role and responsibilities are for the work planned. Ensure all safety procedures are compatible. Verify that all employers are providing their workers with training and supervision that addresses the tasks and hazards of the work they do at the wellsite. It is not the prime contractor s role to do this training and supervision directly but only to check that employers do provide supervision in a manner that meets legislated requirements as a minimum. However, if a worker is a direct employee of the prime contractor and reports to the wellsite supervisor, then the wellsite supervisor is responsible for the training and supervision as per Section 7.4.3. Standards for Wellsite Supervision 10 Drilling, Completions and Workovers

Inform all employers of any known hazards related to the specific wellsite, the planned program or the materials supplied by the prime contractor. Ensure that procedures are in place to eliminate or control these hazards. Ensure that site-specific emergency response procedures are in place and that all employers and workers know these procedures and are prepared to follow them. Monitor activity at the site to verify compliance with applicable legislation and safe work procedures. Standards for Wellsite Supervision 11 Drilling, Completions and Workovers

7.4.2 Wellsite Supervisor 7.4.2.1 General Duties The wellsite supervisor is generally responsible for directing and co-ordinating all employers at the wellsite to achieve the goals of the work planned by the operator and ensure compliance with all legislation pertaining to that work at the wellsite. The specific duties will vary considerably depending on the nature of the work and how the operator assigns certain responsibilities. Standards for Wellsite Supervision 12 Drilling, Completions and Workovers

7.4.2.2 Safety In terms of safety management, the duties of the wellsite supervisor, as the representative of the prime contractor, should include the following: Identify themselves at the wellsite and ensure they can be easily located and contacted at all times. An alternate competent representative of the prime contractor must also be identified who can be contacted if the wellsite supervisor becomes incapacitated or inaccessible for any reason. Check that all employers on the wellsite have an effective safety program and safe work procedures. Check that all employers understand and agree to follow all requirements of the prime contractor's safety program that are not already met by their own safety program. Provide for wellsite orientation of all employers and visitors on arrival at the wellsite. Co-ordinate the efforts of all employers at the wellsite. Resolve any discrepancies between safe work procedures before starting the work. Identify and document the name of the on-site supervisor for each employer prior to starting any work. Review and clarify the roles and responsibilities of all employers and on-site supervisors prior to doing any work. Check that all employers on site are providing their employees with the training and supervision described in Section 7.4.3. Ascertain the number of inexperienced workers and review job execution plans with the employer to ensure these workers receive adequate supervision. Standards for Wellsite Supervision 13 Drilling, Completions and Workovers

Identify hazards related to the specific wellsite, the planned program or the materials provided by the prime contractor. Inform all employers of these hazards and ensure proper controls are in place before the work begins. Establish and co-ordinate site-specific emergency response procedures. Post information, review procedures and conduct practice drills with all personnel on site. Ensure that well control and blowout prevention measures meet regulations and operator's requirements. Monitor the work performed by all employers to verify compliance with safety legislation as well as safety program requirements. Monitor the wellsite for proper use, handling, storage and maintenance of personal protective equipment by all workers. Check that the procedures for handling, transportation, disposal, storage and use of all hazardous substances, follows applicable regulations and safe practices. Implement detection and control of Hydrogen Sulfide and other hazardous gases to prevent harmful exposure of workers or the public. Implement detection and control of any flammable substances that may be emitted from the well or surface facilities, to prevent accidental fire or explosion. Direct work to be stopped when an unsafe act or condition is identified. Resume work only after the hazard is removed or safe procedures have been established. Ensure incidents/accidents or near misses are reported and investigated. Standards for Wellsite Supervision 14 Drilling, Completions and Workovers

7.4.3 Employer s Supervision Safety legislation requires that employers provide all workers with instruction, training and supervision by a competent supervisor to ensure they carry out their work in a safe manner. It is recommended that all employers provide their workers with training and supervision that includes the following: Provide all workers with a wellsite orientation. Inform all workers of the employer's safety program requirements and ensure these requirements are followed. Ensure workers are aware of their rights and responsibilities under OH&S legislation, including their right and obligation to refuse to do unsafe work. Provide workers with instruction and training on safe work procedures for the assigned tasks, including rules from relevant safety legislation. Ensure workers new to a position receive direct supervision by a competent worker until they have demonstrated the ability to perform the assigned tasks safely. Ensure only properly trained workers operate equipment or machinery. Conduct frequent inspections of the wellsite to ensure workers are following safe work practices and applicable OH&S regulations. Identify hazards, inform all workers and the prime contractor of the hazards. Establish procedures to remove or avoid the hazards and ensure these steps are followed. Stop work when an unsafe act or condition is identified and take action to ensure conditions are safe before work is resumed. Standards for Wellsite Supervision 15 Drilling, Completions and Workovers

Ensure all hazardous materials to be used in their work have been identified and that workers are given instruction as required by WHMIS legislation. Ensure the proper use and maintenance of Personal Protective Equipment (PPE). Ensure that site-specific emergency response procedures are in place and that all workers are prepared to follow them. Report and investigate any accidents or near misses. Standards for Wellsite Supervision 16 Drilling, Completions and Workovers

7.5 Requirements for Assigning Duties of Wellsite Supervisor 7.5.1 A Supervisor Must be Assigned IRP: The prime contractor must provide a competent wellsite supervisor who has been assigned specific duties and responsibilities as a representative of the prime contractor. The prime contractor will determine if the supervisor is competent based on the job requirements, the duties assigned and an assessment of the supervisor s training and work experience as described in Section 7.7. 7.5.2 Agreement of Duties IRP: Every wellsite supervisor must have a written description and agreement of the duties and responsibilities assigned to him by the prime contractor. As a minimum these duties must include those listed in Section 7.4.2.2. This written agreement must be renewed and updated at least every 2 years, and whenever the assigned duties are changed. Standards for Wellsite Supervision 17 Drilling, Completions and Workovers

7.5.3 Identify Wellsite Supervisor IRP: The name of the wellsite supervisor representing the prime contractor must be documented and posted at the wellsite. It is also important that the wellsite supervisor can be easily located and identified by all people at the wellsite. A sample form for posting the name and basic duties of the wellsite supervisor as well as the name of an alternate contact for the prime contractor is given in Appendix B. Standards for Wellsite Supervision 18 Drilling, Completions and Workovers

7.6 Training Requirements 7.6.1 Wellsite Supervisor IRP: All wellsite supervisors must have valid certificates for the training courses shown in the Section 7.6.3. 7.6.2 Operator or Prime Contractor It is recommended that any individual working for the operator or prime contractor who directs the work of a wellsite supervisor should have the training courses shown in Section 7.6.3. Standards for Wellsite Supervision 19 Drilling, Completions and Workovers

7.6.3 Training Requirements Course Renewal* Frequency (years) Drilling Supervisor Completions Workover Supervisor Person Directing Wellsite Supervisor Safety Management and Regulatory Awareness for 3 Yes Yes Yes Wellsite Supervision Second Line Supervisor s Well Yes 2 Yes No Control for drilling Yes Well Service Blowout Prevention 5 No Yes for completions & servicing Detection and Control of Flammable Substances 3 Optional Yes Optional WHMIS** 3 Yes Yes Yes Standard First Aid ** 3 Yes Yes Optional TDG ** 3 Yes Yes Yes H 2 S Alive 3 Yes Yes Yes *Note: The requirements for renewal of certification for each course vary. Except where denoted by **, the courses recommended were developed by Enform to meet the standards specified by industry. Certificates are issued by Enform and accepted by regulators as proof of adequate training. Some Enform courses can be franchised which means that outside instructors can be certified by Enform so that the course can be taught outside of Enform, and successful students will receive the Enform certificate. This process can be used if companies wish to include Enform courses in their own in house training. Standards for Wellsite Supervision 20 Drilling, Completions and Workovers

7.6.4 Description of Training Courses 7.6.4.1 Safety Management and Regulatory Awareness for Wellsite Supervision 7.6.4.2 Safety Management and Regulatory Awareness for Wellsite Supervision (Refresher) The three-day course, Safety Management and Regulatory Awareness for Wellsite Supervision has been designed to ensure wellsite supervisors and prime contractors are aware of their responsibilities and roles with respect to Health and Safety at the wellsite. Key legislated rules and industry practices for Alberta, British Columbia and Saskatchewan are discussed and summarized so that the wellsite supervisor/prime contractor can research further details as needed. Responsibilities for health and safety legislation, health and safety program elements, supervisor's role, hazard identification, risk assessment and control, inspections, incident investigation, emergency response, and leadership skills are covered in the course. This refresher course is designed to ensure wellsite supervisors and prime contactors maintain a high level of awareness of their responsibilities and roles with respect to safety management and regulatory compliance at the Wellsite. Key legislated rules and industry practices for Alberta, British Columbia, and Saskatchewan are discussed and are summarized in an index with references so that the wellsite supervisor/prime contractor can research further details as needed. Responsibilities for health and safety legislation, health and safety program elements, hazard identification, risk assessment and control, inspections, incident investigation, emergency response and leadership skills are reviewed. This refresher will emphasize regulatory changes and key industry issues from the preceding 3 years. Standards for Wellsite Supervision 21 Drilling, Completions and Workovers

7.6.4.3 Second Line Supervisor s Well Control 7.6.4.4 Well Service Blowout Prevention (BOP) 7.6.4.5 Detection and Control of Flammable Substance 7.6.4.6 Workplace Hazardous Materials Information Systems (WHMIS) Training This course deals with well control during open hole drilling operations. Participants are required to perform well control procedures and demonstrate the proper response to hole and equipment problems using test well equipment. The course also includes wellbore pressure concepts, well control strategies while on bottom, tripping and while out of the hole, appropriate techniques for management of people and equipment related to well control at the wellsite. This course covers sources and magnitude of pressures, causes of kicks, BOP equipment, kick warning signs, crew position and duties, well shut-in procedures and well killing procedures for cased-hole operations. This course includes an introduction to flammable substances, principles of flammable gas / vapor detection, care and preparation of combustible gas monitors, interpreting combustible gas readings and control methods. This course covers the basics of WHMIS, providing participants with general knowledge and skills to work safely around hazardous materials. Standards for Wellsite Supervision 22 Drilling, Completions and Workovers

7.6.4.7 Standard First Aid 7.6.4.8 Transportation of Dangerous Goods (TDG) 7.6.4.9 H 2 S Alive The course provides participants with a basic theoretical and practical knowledge of first aid procedures so they can apply them both on and off the wellsite. This training is not intended to meet any legislated requirements for first aid at the wellsite. Specific first aid requirements including training of first aid attendants at work sites vary between OH&S jurisdictions. Includes training in TDG legislation, classification of materials, safety marks, documentation, safe handling requirements, incident reporting and emergency response. This course covers the physical properties and health hazards of H 2 S, how to protect oneself and basic rescue techniques. Participants are required to operate self-contained breathing apparatus, an H 2 S detector device, and perform rescue breathing on a mannequin. Standards for Wellsite Supervision 23 Drilling, Completions and Workovers

7.7 Work Experience Assessment 7.7.1 Requirement for Assessment In addition to the required training, a wellsite supervisor must have experience with the type of work planned in order to carry out the duties assigned in a competent manner. The type and amount of experience required depends on the complexity of the work and the specific duties assigned. IRP: The prime contractor must 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. This evaluation must include the process steps and content described in Section 7.7.3. The evaluation must be documented, signed and kept on file by the person to whom the supervisor is reporting. Standards for Wellsite Supervision 24 Drilling, Completions and Workovers

7.7.2 Frequency of Re-Assessment 7.7.2.1 Continuous Work Situations 7.7.2.2 Changes in Job Assignment All supervisors must have a current assessment from the prime contractor they are working for. If the supervisor continues to work for the same prime contractor, the assessment must be updated at least every 2 years. When a supervisor is re-assigned to work that is significantly more complex, then the prime contractor must re-assess his skill levels to ensure they are adequate for the new work requirements. In some cases this may be done by adding an assessment of the additional skills required to the original assessment. In any event, the assessment that the operator has on file must include skill requirements for the major operations of the actual wellsite work being supervised. Standards for Wellsite Supervision 25 Drilling, Completions and Workovers

7.7.3 Assessment Process and Content Requirements 7.7.3.1 Process for Assessment of Skill Level 7.7.3.2 Required Information Record of Work History and References For each duty assigned, the assessor must determine if the skill level of the candidate meets the requirements to carry out the task. This determination must be based on the education, training and work history record plus the skills observed by the references and the assessor. It is suggested the assessor rate the candidate as either 'meets or exceeds requirements' or as 'requires additional training or experience' in which case comments should be included as to what is required. Required Information Record of Work History and References Name, address and phone # of the person being assessed List of training certificates and dates each was issued Record of all formal education and year each was completed, if available Record of work experience including: - relevant wellsite experience other than as wellsite supervision - experience as a wellsite supervisor, if not entry level - other relevant industry experience not at the wellsite Standards for Wellsite Supervision 26 Drilling, Completions and Workovers

List of references starting with the last three employers (or back 5 years) and including: - name and phone # of reference - name of the company or employer of the reference - dates when candidate was employed including month and year - was this reference contacted by assessor? If so, on what date? Information about the person who did the assessment including: - name - name of his company or employer - job title or position - address and phone # - date the assessment was completed or updated Standards for Wellsite Supervision 27 Drilling, Completions and Workovers

7.7.3.3 Minimum Skill Assessment Requirements The candidate must be assessed as having the skills required in the following categories, considering the points described and the work assigned: Supervision and Leadership - Demonstrate safe personal work habits - Establish and maintain effective working relationships - Communicate operational and safety requirements effectively Health & Safety - Implement operator s safety program at the Wellsite - Conduct effective safety meetings - Check that all employers have safe work procedures in effect - Check that all employer on-site supervisors are performing their duties - Monitor work to ensure safe work procedures and regulations are followed - Check that personal protective equipment is being used as required - Perform hazard assessments and implement hazard controls - Direct the detection and control of H 2 S, flammable emissions and other hazardous atmospheric conditions Emergency Response - Establish and co-ordinate site-specific emergency response procedures Standards for Wellsite Supervision 28 Drilling, Completions and Workovers

Environmental Protection - Carry out operations in accordance with environmental regulation - Check that waste disposal practices follow approved procedures - Contain and report spills, leaks or other environmental damage Well Control - Ensure BOPs and other well control equipment meets regulations - Ensure inspection, function testing and pressure testing is carried out - Ensure kick detection equipment and practices are in place - Ensure BOP training and certificates of personnel meet regulations - Conduct BOP drills as per regulations and operator requirements Operational Skills and Technical Knowledge - Review and understand well design and program requirements - Ensure all operations comply with regulations and industry standards - Plan and co-ordinate equipment and services requirements - Identify hazards associated with the work planned - Ensure rig and equipment layout and spacing meets regulations - Ensure transportation of equipment meets all regulations and bylaws Standards for Wellsite Supervision 29 Drilling, Completions and Workovers

7.7.3.4 Additional Job Specific Skill Requirements 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 including H 2 S potential, the location of the well and any specific issues related to public or environmental impact potential. 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. Note: Refer to IRP Volume 1 and ARP Volume 2 for specific requirements for supervision on wells classified as 'critical sour'. Standards for Wellsite Supervision 30 Drilling, Completions and Workovers

7.8 Performance Evaluation and Audits Good management practices require that results achieved must be compared to the goals and expectations on a regular basis in order to identify performance gaps and opportunities for improvement. The performance of wellsite supervisors must be monitored and evaluated as part of this process. New supervisors should be evaluated more frequently than supervisors with proven track records. Standards for Wellsite Supervision 31 Drilling, Completions and Workovers

7.8.1 Documentation Good management practices require that results achieved must be compared to the goals and expectations on a regular basis in order to identify performance gaps and opportunities for improvement. The performance of wellsite supervisors must be monitored and evaluated as part of this process. New supervisors should be evaluated more frequently than supervisors with proven track records. Standards for Wellsite Supervision 32 Drilling, Completions and Workovers

7.8.2 Inspections and Audits Operators and prime contractors should inspect wellsite operations on a regular basis. The person directing the wellsite supervisor should conduct informal audits by visiting the wellsite at appropriate times to observe operating procedures, check records kept on location and get feedback from the employers involved in the work. Operators and prime contractors should also periodically conduct formal audits of their safety management system using trained auditors. Refer to IRP Volume 9 for recommendations on safety program audits. Standards for Wellsite Supervision 33 Drilling, Completions and Workovers

7.8.3 Government Inspections Government agencies conduct field inspections and audits of field operations as necessary to ensure compliance with regulations. The wellsite supervisor and the prime contractor must assist the inspectors and support this process in a cooperative manner. Standards for Wellsite Supervision 34 Drilling, Completions and Workovers

Appendix A : Levels of Control and Responsibility for Safety Management Standards for Wellsite Supervision of Appendix A 35 Drilling, Completions and Workovers

Appendix B : Notice of Wellsite Supervisor (Sample) Note: Saskatchewan Labour has a sample Generic Form to assist in complying with Section 412 of OH&S regulations in that province. TAKE NOTICE that (operator/prime contractor) HEREBY APPOINTS (name of supervisor) as the wellsite supervisor of the following undertaking: Drilling Completion / Workover Description of well operations to be carried out: Located at the following well locations During the time period from: day, month, year to: day, month, year ALTERNATE CONTACT: representative for the prime contractor if the Wellsite Supervisor becomes incapacitated or is inaccessible: ( name ) Contact phone #s (work) (cell) (home) The Supervisor s duties and responsibilities include the following matters: Implement the prime contractor s safety program at the wellsite. Check that all employers on the wellsite have a safety program including safe work procedures. Ensure all employers understand and agree to follow all requirements of the prime contractor s safety program that are not already met by their own safety program. Direct and co-ordinate the efforts of all employers at the wellsite, including: - review and clarification of roles and responsibilities of all employers and supervisors - resolution of discrepancies between safe work procedures - safe transportation, storage, use and disposal all hazardous substances Identify hazards related to the specific wellsite, the planned program or the materials provided by the prime contractor. Inform all employers of these hazards and ensure procedures are in place to control these hazards. Ensure the following site specific hazard controls meet requirements and standards: - well control and blowout prevention - detection and control of Hydrogen Sulfide gas emissions - detection and control of any flammable substances that may be emitted Establish and direct site-specific emergency response procedures Monitor work activities of all employers and work activities to verify: - compliance with safety legislation - safe work procedures and proper use of PPE are followed - all employees receive supervision and training from their employer as per IRP Volume 7 The Supervisor is knowledgeable about and experienced in all of the matters listed above. Assigned By: (representative of operator/ prime contractor) Contact phone #s: (work) (cell) Accepted By: (signed by wellsite supervisor ) Contact phone #s: (work) (cell) Standards for Wellsite Supervision of Appendix B 36 Drilling, Completions and Workovers

SECTION 2 FORMS Work Site Safety Plan Checklist Bill C-45 Explanation WH&S Bulletin Due Diligence OPX Consulting Inc. Section 2-15

WORK SITE SAFETY PLAN CHECKLIST (Drilling & Completions Supervisors) OPERATOR: LOCATION: WELL SITE SUPERVISOR: RIG# / RIG MANAGER: DATES: From: To: The Operator is designated as the Prime Contractor for this operation. The Well Site Supervisor is the agent of the Operator. The following checklist summarizes the key elements of the required work site safety plan. Well Site Supervisors are requested to submit the completed checklist upon completion of the job. YES NO N/A GENERAL Have you reviewed and posted HARVARD s HS&E Policy & Safety Statement? Have all identified landowner requirements been identified and addressed? HAZARD IDENTIFICATION AND ASSESSMENTS / INSPECTIONS Is a Hazard Assessment completed for each task being conducted? Are the results of Hazard Assessments reviewed during the Safety Meeting Process? Review Well Site Layout (as per provincial regulatory requirements). Have the rig anchors been installed and tested as required? Are CAODC rig inspections or equivalent being completed as required? Have you received copies of all inspections completed on the worksite? Has the CAODC BOP been completed as required? Have the mouse/rat holes been identified prior to moving completion rig on site. SAFETY COMMUNICATION Are Safety Meetings held on regular basis? Are the meetings documented and are you receiving copies of the meeting minutes? As the Supervisor have you attended pre-job safety meetings for critical/non critical operations? Have you reviewed regulatory permits and license conditions? Safe Work Permits: have you identified requirements and issued necessary permits? Has a pre-job tailgate safety meeting been conducted prior to each specialized operation? INCIDENT REPORTING AND INVESTIGATION Are Contractors and their personnel aware of the HARVARD incident reporting procedures, and are they complying? Are you ensuring all incidents/near misses are investigated reported and corrective measures implemented? EMERGENCY RESPONSE PLANNING Has the Corporate/Site Specific ERP been reviewed with onsite personnel? Have emergency numbers and directions to lease been posted and is a map of area available for quick reference? Are lease signs adequate to direct emergency response workers to the site?

YES NO N/A Have muster points been identified and all personnel aware of them? Are First Aid/Emergency Services available including a transportation method? Are supplies well maintained and do they meet regulated standards? Has the communication equipment on the worksite been tested for emergency response procedures? HAVE SAFE WORK PROCEDURES BEEN ESTABLISHED FOR THE FOLLOWING JOB HAZARDS? Sour operations. Hot work. Confined space / Restriced space entry. Overhead power lines. Hazardous materials. Ground disturbances (buried pipelines, electrical, telephone) Control Hazardous Energy Pressure testing. Radioactive sources. Appropriate work procedures available on-site and posted as required. Fall protection to include use of man basket & high angle rescue training. Other non-regular operations. Well flow back operations including DST testing. LEL Monitoring. WORKER HEALTH AND SAFETY Is appropriate personal protective equipment and other safety equipment available and being used by all workers? (i.e. F. R. clothing). Is the PPE and safety equipment in good working order and is there a preventative maintenance and inspection program for equipment? Is there special monitoring equipment available? (i.e. H 2 S, LEL). Have you review local access hazards and speed limits? TRAINING REQUIREMENTS Have all workers on site completed an HARVARD Safety Orientation (Handbooks) and do they have an orientation hardhat sticker? Have you collected the orientation quizzes/acknowledgement sheets from the workers? First Aid/CPR; verify number of qualified people available on site H 2 S; verify number of qualified people on site. Blow out prevention certification: Rig Manager Drillers Site Supervisor WHMIS / TDG: Rig Manager Drillers Crew Site Supervisor CONTRACTOR SAFETY PROGRAMS Do Contractors have safety programs in place and available on site? ENVIRONMENTAL PROTECTION Have fuels and chemicals are properly stored? Is the required waste handling, storage and disposal procedures in place? Have all spills been cleaned up immediately and reported? CAMP (If Applicable) Are there adequate smoke detectors and fire extinguishers? Are regular emergency drills conducted, and do they correct deficiencies identified? Have Camp Rules been posted at the main entrance and kitchen area of camp?

WELL SITE SUPERVISOR S COMMENTS: SUPERVISOR DATE

Bill C-45: Criminal Liability of Organizations On March 31, 2004, criminal code amendments made to bill C-45 became law. These changes now base corporate criminal liability on the actions and moral fault of the organization as a whole. This would include the failure of managerial officers who reasonably ought to have known what was happening or who were not reasonably diligent in establishing or monitoring mechanisms for compliance with corporate policies. An organization is defined as a public body, body corporate, society, company, firm, partnership, trade union, municipality and associations, with a common purpose, with an operational structure that holds itself out as an association. The amendments to Bill C-45 have the following intent: Criminal liability of corporations and organizations is no longer dependent on a senior member of the organization but rather all PERSONS DIRECTING WORK must ensure reasonable steps have been taken to safeguard BOTH WORKER and the PUBLIC. The Criminal Code had the following provisions: Criminal Negligence 219. (1) Everyone is criminally negligent who (a) in doing anything, or (b) in omitting to do anything that is his duty to do, shows wanton or reckless disregard for the lives or safety of other persons. Definition of duty (2) For the purposes of this section, duty means a duty imposed by law. Duty of persons 217. Every one who undertakes to do an act is under a legal duty to do it if an undertaking acts omission to do the act is or may be dangerous to life. Bill C-45 introduced new Section 217.1 as follows: Duty of persons 217.1. Every one who undertakes, or has the authority, to direct how another person does work or performs a task is under a legal duty to take reasonable steps to prevent bodily harm to that person, or any other person, arising from that work or task. Section 217.1 creates an express legal duty for those directing minds who direct the work or another. This responsibility expands to include all representatives of the

corporation or organization who exercise delegated and operation authority. Representatives can include a director, partner, employee, member, agent or contractor. Penalties: Organizations cannot be imprisoned and so the Criminal Code provides for fines. For a summary conviction the fine increased from $25,000 to $100,000. For indictable offences there is no maximum fine established and it is non tax deductible. Probation is now an optional condition a court may consider imposing on an organization. These probation terms may include: 1. Making restitution to any person for the loss/damage caused. 2. Establish policies, standards and procedures to reduce the likelihood of another offence 3. Communicate these policies, standards and procedures to the representatives 4. Report to the court for the implementation of these policies, standards and procedures 5. Identify the senior offices responsible for the implementation of these policies, standards and procedures. 6. Provide information to the public as to the offence for which convicted, sentence imposed and measures the organization is taking to reduce the likelihood of repetition in the future. Recommendations: It is vital to your organization that you demonstrate due diligence. Here is a list of questions that can assist in limiting liability and exposure for your organization: 1. Do you have a Health and Safety program? 2. Have you ensured your Health and Safety program is being implemented? 3. Have you ensured your Health and Safety program meets regulations? 4. Is your organization in compliance WCB and Provincial Occupational Health and Safety acts, codes and regulations? 5. Have you verified that your personnel and contractors have appropriate training? 6. Have you established a paper trail to demonstrate training records and compliance to government Health and Safety regulations?

3.0 SAFETY PLAN MANAGEMENT A Safety Program is ineffective unless there is a plan to manage it. The manual is full of information to help manage the Program. Unless each element of the Program is put into practice there is no Program and the manual becomes useless. Putting it into practice requires the participation of all company employees and contractors. Safety is everyone s responsibility. This section of the manual attempts to provide a management plan that is easy to understand and provides specific tools to assist the supervisor to manage the Program in the field. 3.1 THE OPERATIONS PROGRAM (DRILLING & COMPLETIONS) The principle safety document for any drilling or completions operation should be the Operations Program. The Program should be well thought out by the Drilling/Completions Engineer and structured so that the project is accomplished in the most efficient and effective way with safety of workers and environmental protection an unconditional priority. It is important that the Wellsite Supervisor be clear in his/her understanding as to what his/her responsibilities and expectations are as the representative of the owner/operator and/or Prime Contractor. It is recommended that, in addition to a detailed operational procedure that accomplishes the above, a section be added to each drilling and completions program similar in content to the following: Instructions to Well Site Supervisor Regarding Safety and Waste Management All operations on this project must comply with HARVARD s Safety Program, the drilling contractors' Safety Program and all applicable regulations. The Well Site Supervisor is to complete the attached Work Site Safety Plan Checklist at the beginning of this project and return it to the Calgary office with the final operations report. Post HARVARD S "Safety Statement" in a prominent location such as the doghouse and/or camp dining area. An Emergency Response Plan must be prepared based on the work site hazard assessment with input from affected workers. Emergency response items must address, at a minimum, key internal and external contacts, first aid plan / medical transportation, fire protection, rescue and evacuation. Individual work sites may need to add additional items specific to their operation based both on the work site hazard assessment as well as regulatory requirements. Emergency response training must be appropriate to the work site and potential emergencies identified in the ERP. A copy of this ERP must be submitted with the final operations report. Well Site Supervisor is to issue Safe Work Permits for all Hot Work, Confined Space Entry and Ground Disturbances. Copies of these must be submitted with the final report. All contractors must be issued Safe Work Permits. The CAODC rig inspection checklist must be completed and discussed with the Drilling Engineer prior to drilling out surface casing. Further inspections are to be completed as required. OPX Consulting Inc. Section 3-1

Run BOP drill with each crew after drilling out. Have BOP stack and all associated equipment pressure tested individually and recorded on a chart. Post maximum allowable casing pressure (MACP) in doghouse and in manifold shack. Install safety fences around all sumps. Attend and take a lead role at all safety meetings. Safety meetings should be held regularly with each crew and before each critical operation. In accordance with ERCB Directive D58 all waste must be manifested prior to leaving the location. It is the Well Site Supervisors' responsibility to ensure this is done. All contractors must be fully covered by the WCB as well as carry a minimum liability insurance of $2,000,000. Notify HARVARD S field office, surface owner/occupant, and nearby area residents when moving rig on or off location and prior to any events that will significantly impact them. Report all safety and environmental incidents on the appropriate form. 3.2 THE SAFETY PLAN CHECKLIST This Checklist has been designed to provide the Production/Wellsite Supervisor with a guide to most of the safety issues that must be addressed on site. It is intended that the Checklist be applied to each of HARVARD s operating areas. It is recommended that the Production/Wellsite Supervisor for each area review the Checklist for his area(s) at regular intervals and that they be reviewed at safety meetings. 3.3 THE SAFETY STATEMENT This document is intended to be a statement to all workers at a work site from HARVARD management. It is to be posted in a conspicuous location such as the field office, lunch areas, etc. OPX Consulting Inc. Section 3-2

SECTION 3 FORMS Safety Statement OPX Consulting Inc. Section 3-3

SAFETY STATEMENT TO BE POSTED AT EVERY WORK SITE Well/Facility Name: TO: ALL EMPLOYEES AND EMPLOYERS AT THIS SITE HARVARD ENERGY LTD. IS COMMITTED TO A SAFE WORKING ENVIRONMENT. SAFETY WILL NOT BE COMPROMISED BY USING UNSAFE EQUIPMENT OR PROCEDURES. THE FOLLOWING CONDITIONS APPLY TO ALL HARVARD OPERATED WORK SITES. 1. All supervisory personnel, whether consultants or HARVARD employees, and contractor personnel employed at this site must have received suitable training and be sufficiently experienced to carry out his/her job duties. 2. Appropriate Personal Protective Equipment must be worn on work sites as indicated by a completed Hazard Assessment. This may include hard hats, hearing protection, CSA approved footwear, eye protection and other Personal Protective Equipment as required. 3. All unsafe equipment or working conditions must be reported to your supervisor or the well site supervisor immediately. Should the unsafe condition not be rectified the personnel involved should report to the following by collect telephone call: Project Manager: Business: Cell: Operations Manager: Business: Cell: 4. Regular safety meetings and inspections must be carried out and properly documented. 5. Any accident, whether lost time or otherwise, unsafe acts or near misses must be reported immediately by the work site supervisor to the above by telephone and in writing by the next morning. The contractor s written report, and if required, copies of the applicable provincial W.C.B. forms MUST BE FAXED TO THE CALGARY OFFICE AS SOON AS POSSIBLE. OPX Consulting Inc. Section 3-4

4.0 HAZARD IDENTIFICATION & ASSESSMENT 4.1 OVERVIEW Occupational Health and Safety Codes require employers to assess a worksite and identify existing or potential hazards before work begins or prior to the construction of a new work site, or before the construction of significant additions or alterations to a work site. Employers must prepare a report that provides the results of the assessment and specifies the methods that will be used to control or eliminate the hazards. All contractors are required to conduct their own pre-job safety hazard assessment. All HARVARD personnel must conduct a pre-job assessment and complete the required Job Safety Analysis (JSA) for the task at hand. HARVARD S HSE Department will review the prejob hazard assessments, update the JSA or develop new ones and review task analysis. Hazards are to be eliminated whenever it is reasonably practicable to do so. If elimination is not reasonably practicable, hazards must be controlled: First by using engineering controls; Then administrative controls; And finally, as a last option, by using personal protective equipment. There may also be situations where emergency action is required to control or eliminate a hazard that is dangerous to the safety or health of workers. Only those workers competent in correcting the hazardous condition may be exposed to the hazard. Recognizing potential hazards and taking steps to control them is a major part of HARVARD s Safety Program. A hazard is any situation with the potential to do injury or damage to people, property, or the environment. The objectives of the hazard assessment guidelines are to: Outline a strategy for identifying all potential process and work site hazards. Establish a standard for assessing critical and repetitive tasks. Establish standards for evaluating, prioritizing, and implementing alternate hazard control measures. With the development of hazard assessment guidelines, and the implementation of training programs, HARVARD is prepared to: 1. Identify, document, and assess any necessary process/operating safety information. 2. Identify, document, and report potential process and operative hazards and overall risk. 3. Estimate the likelihood and consequence of each hazard utilizing the Risk Matrix. OPX Consulting Inc. Section 4-1

4. Identify and document required safeguards for preventing, detecting or mitigating potential incidents. 5. Implement recommendations for controlling and eliminating the hazards identified. 4.2 RESPONSIBILITY HARVARD must, at all worksites: Be able to produce a thorough, comprehensive, written hazard assessment applicable to the worksite or work activities being reviewed; Indicate the methods used to control or eliminate the hazards identified; Where hazards are not eliminated, HARVARD should be able to justify the appropriateness of those chosen to control through the use of administrative procedures and personal protective equipment. Involve workers in assessing, controlling, and eliminating potential hazards; HARVARD should be able to indicate which workers were involved and to what extent. Be able to show how information regarding hazards and their controls are communicated to workers. HARVARD must be able to show how workers were informed of findings and recommendations, including when and by what means (ie: safety meetings, posted checklists, etc.), and how workers can access the written assessment. Ensure that any employer on a work site is made aware of any existing or potential work site hazards that may affect that employer s workers. 4.3 SIZE AND SCOPE OF ASSESSMENTS The size and scope of the written hazard assessment will vary based on the complexity of the operations and the extent to which those operations present hazards to workers. A single hazard assessment may be undertaken for multiple worksites IF the same hazards are faced at all worksites and the safe work practices to be followed are identical at each worksite. Should differences be discovered, then HARVARD must perform an individual assessment that takes the new findings into consideration. Once new controls are implemented, the job or work should be reviewed to ensure that the hazard(s) has been reduced to acceptable levels. 4.4 ASSESSMENT INTERVALS The findings of the initial hazard assessment may not change for an extended period of time but further assessments are required: At reasonably practicable intervals to prevent the development of unsafe and unhealthy working conditions. Hazard assessments shall include buildings, structures, grounds, excavations, tools, equipment, work procedures and practices. OPX Consulting Inc. Section 4-2

When a new work process is introduced. This may involve the use of new or different materials, chemicals, equipment, etc. with which workers are unfamiliar. When a work process or operation changes. This may include the introduction of a new process, operation, or piece of equipment. Prior to construction of a new worksite or before the construction of significant additions or alterations to the work site. This identifies potential problems being built into the new worksite and eliminates them at the design stage. If hazardous conditions are discovered every time an assessment or inspection is done, then assessments or inspections should be done more frequently, thus reducing the length of time that workers are exposed to a particular hazard. The presence of numerous, uncontrolled hazards would suggest that the assessment was inadequate and efforts to eliminate or control those hazards were incomplete or ineffective. If no hazardous conditions are found, assessment intervals should not be reduced. If everything is being done correctly and hazards are not being missed, then the inspections are doing what they are supposed to do keeping conditions safe and under control. 4.5 PROCESS OF HAZARD IDENTIFICATION In its simplest form, a hazard assessment answers the question What if?. For example, What if I don t put a guardrail around that elevated work platform? I don t enforce the wearing of seat belts in all company vehicles? I don t have our workers wear eye protection while grinding? I don t have the workers test the atmosphere before entering a vessel? When assessing hazards, it is important to determine whether a hazard is significant and whether satisfactory precautions have been taken to reduce the chances of worker injury. The hazard assessment process begins by listing all the types of work and work-related activities that happen at the worksite or the work area within the worksite. The next step is to break it down into clearly identifiable worksites so that the assessment task becomes manageable. Then consider the size and location of worksites, their geographical location, and the activities that happen there. For example, the operation might be broken down as follows: a. permanent worksite office building, warehouse b. field worksite locations where field operations are carried out c. mobile worksite vehicles and mobile equipment Once the worksites have been identified, proceed with the next four steps: Step 1 Describe the types of work and work-related activities carried out at each worksite. OPX Consulting Inc. Section 4-3

Step 2 Determine the hazards associated with the listed work-related activities. Hazards are often grouped into four categories: Physical hazards, for example: Lifting and handling loads Slipping and tripping Moving parts of equipment/machinery Working at heights Pressurized systems Vehicles Fire Electricity Excess noise Extreme temperatures Chemical hazards, for example: Chemicals (ie: solvents) Dusts (ie: from grinding, sandblasting) Fumes (ie: welding) Mists and vapours Biological hazards, for example: Viruses, bacteria Moulds Sewage Psychological hazards, for example: Stress Fatigue Working conditions Workplace violence SAFETY PROGRAM MANUAL Step 3 Based on these activities and hazards present, create checklists or similar tools to help identify existing or potential hazards (refer to Hazard Assessment Tools and Checklists, Section 4.8). Step 4 Identify and prioritize (ie: high hazard jobs, tasks, work areas) in order to determine which hazards need to be assessed first. 4.6 TYPES OF INSPECTIONS Formal and informal work site inspections are a critical process in recognizing potential hazards and in taking the necessary steps to control them. Inspections require the full participation of all workers, supervisors and management, who must take responsibility for identifying and controlling the hazards within their work area. Any unsafe or harmful conditions found in the course of such inspections shall be documented, remedied and communicated to workers without delay. OPX Consulting Inc. Section 4-4

4.6.1 On-Going Informal Inspections All company employees and contractors should be continually on the look-out for conditions or procedures that create circumstances which may lead to injury, harm to the environment or risk to the public. Workers should promptly report to their supervisor any hazards observed on the work site. 4.6.2 Planned Inspections (Formal) Supervisors must conduct and document regular inspections of process, equipment, work site conditions, employee actions and job procedures to identify hazards. Contractor work site inspections are done cooperatively with both the operating company and the contractor, using the standards set out by HARVARD, the government, and industry associations. 4.6.3 Safety Audits, Loss Prevention Surveys and Regulatory Inspections Formal inspections may also be carried out by corporate safety personnel or outside agencies such as insurance underwriter representatives or Occupational Health and Safety inspectors. These inspections are carried out at varying frequencies depending upon perceived risks and location. Copies of any inspection reports that are generated as a result of an inspection by an outside agency must be forwarded to the Head Office. 4.6.4 Equipment Preventive Maintenance Proper equipment maintenance is a preventive measure against accidents and costly breakdowns of all equipment including pressurized vessels, rotating equipment, personal protective and safety equipment. Each area should develop a detailed program with periodic and pre-shift equipment checklists, maintenance manuals, and maintenance procedures. Supervisors are to ensure all company equipment has preventive maintenance manuals and that proper maintenance is performed and recorded. Supervisors must also check the condition of rented equipment and ensure necessary maintenance before use. Operators or equipment are responsible for bringing any equipment or machine deficiencies to the supervisor s attention. OPX Consulting Inc. Section 4-5

4.6.5 Incident Investigation Findings The findings of incident investigations may identify hazards involved. Unfortunately, this is an after-the-fact manner of hazard identification therefore this approach should only be used as a supplement to the above methods. Figure 1: Hazard Identification, Elimination and Control Flowchart Hazards cannot always be eliminated, however, assessing and understanding their natures and potentials are critical to developing acceptable controls to avoid incidents, injury and losses in business. INSPECTIONS Ongoing (informal) Planned (formal) Safety & Loss Control Audit Physical Conditions Survey Loss Prevention Surveys Inspections Process Hazard Analysis (PHA s) (see Table 1, Summary of Inspections) Identify Hazard from Inspection Can hazard be corrected immediately? YES * NO Evaluate hazard using the Risk Matrix Correct the hazard by: Eliminating or controlling by use of engineering controls (ie: elimination, substitution, redesign, isolation, automation, barriers, ventilation, etc.); Administrative controls that control hazard to a level as reasonably achievable (ie: safe work practice, procedure, permits, training, etc.); Use of personal protective equipment. *Harvard recognizes that for the majority of field worksites, the hazards identified are addressed immediately and would not require a risk ranking procedure. You are not restricted to a single approach. Some hazards require the combined use of all three methods. OPX Consulting Inc. Section 4-6

4.7 RISK MATRIX SEVERITY MAJOR (Catastrophic) Personnel: Permanently disabling injury or fatality Public: Exposed to life threatening accident Environment: Large uncontained product/chemical release into water Equipment Damage which results in downtime of 10 days + SERIOUS Personnel: Lost time injury with partial or no disability Public: Exposed to potential injury accident Environment: Large uncontained product/chemical release Equipment: Damage which results in downtime of 1-10 days MINOR (Important / Noticeable) Personnel: Injury requiring medical/ first aid with no lost time Public: No impact Environment: Product/chemical release contained on lease Equipment: Damage which results in downtime less than 1 day NEGLIGIBLE Personnel: Injury requiring minimal or no first aid Public: No impact Environment: Product/chemical release contained in process Equipment: Negligible downtime of less than 6 hours NONE High: Requires Action Moderate: Action or further study Low: Investigation as resources permit FREQUENT Expected to occur routinely or repeatedly over the life of the facility. Weekly or monthly: probability 0.1 1 EXTREME RISK STOP: Evaluate thoroughly. Take steps to reduce risks before restarting 2 HIGH RISK Evaluate thoroughly. Take all necessary steps to reduce risks. 3 4 6 MEDIUM RISK Evaluate. Take appropriate steps to reduce risks. LOW RISK Evaluate. Consider alternatives for reducing risks. NEGLIGIBLE RISK Review to confirm potential risks PROBABLE Commonly known to occur but not routine. Likely to happen at several times in the life of the facility. Yearly or longer: probability 0.01 2 HIGH RISK Evaluate thoroughly. Take all necessary steps to reduce risks. 3 MEDIUM RISK Evaluate. Take appropriate steps to reduce risks. 4 5 LOW RISK Evaluate. Consider alternatives for reducing risks. MINIMAL RISK Review and evaluate need for reducing potential risks. 6 NEGLIGIBLE RISK Review to confirm potential risks LIKELIHOOD OCCASIONAL Likely to occur sometime in the facility life. Not normally expected unless precautionary measures fall. Once every 10 years: probability 0.0001 3 4 MEDIUM RISK Evaluate. Take appropriate steps to reduce risks. LOW RISK Evaluate. Consider alternatives for reducing risks. 5 6 MINIMAL RISK Review and evaluate need for reducing potential risks. NEGLIGIBLE RISK 7 Review to confirm potential risks. NO RISK No review required REMOTE (Unlikely) Has happened somewhere and could conceivably occur at this facility but is very unlikely. Probability 0.000001 to 0.001 4 LOW RISK 5 Evaluate. Consider alternatives for reducing risks. MINIMAL RISK 6 7 7 Review and evaluate need for reducing potential risks. NEGLIGIBLE RISK Review to confirm potential risks. NO RISK No review required NO RISK No review required IMPROBABLE So unlikely, assumed impossible that this will ever happen at this facility. Probability 0.000001 5 MINIMAL RISK 7 7 7 7 Review and evaluate need for reducing potential risks. NO RISK No review required NO RISK No review required NO RISK No review required NO RISK No review required OPX Consulting Inc. Section 4-7

4.8 HAZARD ASSESSMENT TOOLS AND CHECKLISTS SAFETY PROGRAM MANUAL Checklists or worksheets are a popular means of conducting an assessment and they serve as a survey tool, directing the person or team performing the assessment to look at the specific hazards. For each hazard identified, recommendations to eliminate or control it must be addressed. This process should include specific actions required to correct the problem, determine who is responsible for performing the corrective action, and when each corrective action is to be completed. One approach for hazard identification is a checklist as follows: Hazard Noise from (indicate equipment) Moving parts of (indicate equipment) Chemical (indicate chemical) Potential Harm Hearing loss assessed at more than 85 dba Cuts, bruising, arm trapped Burns, inhalation, etc. Action Proposed / Control No alternative machinery. Machine already enclosed. Workers to wear hearing protection. Place guards over moving parts. No adequate alternative chemical. Enclose process. Personal protective equipment FR clothing, gloves, safety glasses. Review MSDS. Completion Date Not applicable Within 2 days Within 1 week By who? Frequency of Follow-up Annual noise survey Check compliance monthly Check compliance monthly OPX Consulting Inc. Section 4-8

The following is an example of an equipment preventative maintenance checklist: SAFETY PROGRAM MANUAL Equipment Monthly Yearly Other Breathing Apparatus Visual Cylinders for air quality Metal composite cylinders hydrostatic Cranes Visual As per manufacturer s specifications Fire Extinguishers Visual As per NFPA 10 Portable Fire Extinguisher every 3 years Fibre-wrapped cylinders hydrostatic every 5 years Stored pressure hydrostatic every 5 years Cartridge operated hydrostatic every 12 years Gas Detectors As per manufacturer s specifications Hard Hats Visual Visual Every 3 year replacement Oxygen Analyzers As per manufacturer s specifications Pressure Vessels Per government regulations Rigging (means rope, wire rope, chains, slings, etc.) Per manufacturer s specifications Before using Per government regulations Per manufacturer s specifications OPX Consulting Inc. Section 4-9

The following lists are intended as a guideline for controlling identified hazards when conducting detailed site inspections. Additional controls and inspections may be required dependent upon the activities and identified hazards at the work site. INDEX OF HAZARD CONTROLS 4.8.1 Chemicals and Fuel 4.8.20 Mechanical Power Systems 4.8.2 Compress Gas Cylinders 4.8.21 Noise Exposure 4.8.3 Confined/Restricted Space 4.8.22 Personal Protective Equipment Entry 4.8.4 Electrical Power Systems 4.8.23 Platforms/Scaffolding 4.8.5 Emergency Instructions 4.8.24 Pneumatic Power Systems 4.8.6 Emergency Rescue 4.8.25 Pressure Vessel and Piping Equipment 4.8.7 Energy Isolation 4.8.26 Signs and Tags 4.8.8 Ergonomic Factors 4.8.27 Stacking and Storage 4.8.9 Exit/Egress 4.8.28 Stairs 4.8.10 Eye Bath and Showers 4.8.29 Substance Abuse 4.8.11 Fatigue 4.8.30 Trenching/Excavating 4.8.12 Fire Protection 4.8.31 Valves and Mechanical Controls 4.8.13 First Aid 4.8.32 Vehicles and Equipment Kits/Stations/Equipment 4.8.14 Hand and Portable Tools 4.8.33 Ventilation and Extraction 4.8.15 Hydraulic Power Systems 4.8.34 Violence and Harassment 4.8.16 Ladders 4.8.35 Warning Systems 4.8.17 Lifting/Gear Equipment 4.8.36 Waste Disposal 4.8.18 Lighting 4.8.37 WHMIS/TDG 4.8.19 Material Handling 4.8.38 Work Surfaces, Floors & Roadways 4.8.1 Chemicals and Fuels Tanks/drums are made of appropriate material. Tanks are adequately vented to a safe location. Pressure relief valves are provided on tanks. Tanks/drums are grounded and bonding provisions are made when dispensing. Adequate spill containment is available. Proper spill absorbent materials and/or drainage are provided. Container corrosion prevention is in place. OPX Consulting Inc. Section 4-10

Tanks/drums are adequately supported. Temperature is controlled to prevent boiling. Adequate storage cabinets are provided; fire resistant and vented. Sufficient cabinet storage space is available. Storage is heated by means not constituting a source of ignition. CSA or UL approved portable safety containers are used as required. No smoking signs are posted where required. Non arching type fans are installed in hazardous substance storage areas. Materials are separated to avoid incompatibility reactions. Means of exit/egress have been prescribed. Piping exterior is colour coded. Water is available to flush eyes and skin. 4.8.2 Compressed Gas Cylinders Stored upright and secured in accordance with manufacturer s specifications. Segregated by contents and legibly marked. Caps are in place and hand-tight. Protection against rust/corrosion is in place. Stored separate from heat sources and compressed oxygen cylinders. Stored away from stairs, elevators and egress routes. Inspected for dents, corrosion and test records. Adequate ventilation in storage areas. WHMIS information is available. 4.8.3 Confined & Restricted Space Entry Spaces that are restricted and which may become hazardous when a worker enters it due to the hazards identified. Spaces that are partially enclosed and have a restricted access/egress. Procedures for entry are available. Equipment is available. Workers are trained in procedures, testing, breathing apparatus and rescue. Toxic vapours, materials, and harmful atmospheric contaminants are identified. Oxygen deficiencies/enrichment is rectified/noted. 4.8.4 Electrical Power Systems High voltage and control panels are closed and secured. Control panels are identified and accessible. General conditions or wiring, insulation and fixtures are acceptable. Grounding is tested. Explosion-proof fixtures are installed in flammable areas. Flexible cords are free of splices. Energy isolation provisions as prescribed. OPX Consulting Inc. Section 4-11

Equipment energy-isolating devices have provision for individual disconnects. Electrical equipment is protected from fluids. Adequate provisions for manual re-starting after power failures. 4.8.5 Emergency Instructions Operational placards/decals are visible on emergency controls; for example, on-off, open-closed, etc. Potential emergencies have been identified and action plans established. Emergency instructions are posted at the primary telephone in each work area. Fire hazard symbols are posted in facilities containing hazardous substances. Back up communication systems are available. Emergency drills have been conducted. 4.8.6 Emergency Rescue Equipment Adequate equipment is available and properly located. Proper serviceable condition is maintained. Employees are adequately trained and qualified in the use and limitations of equipment. 4.8.7 Energy Isolation Positive energy isolators are provided for all power systems and individually powered equipment. Scissor lock-outs permit group lock-out by multiple personnel. Tags or colour codes indicate user of lock-out. Energy isolation provides means to reduce system/equipment to a zero energy state; for example steam, air, electrical, hydraulic. 4.8.8 Ergonomic Factors Design allows normal body positions when seated or standing. Controls are sized to permit operation with clothing/equipment normally worn. Controls follow normal response patterns (down for off, etc.) Standard colour codes are used for warnings and informational displays. Hand tools used permit normal body positions. Mechanical listing device is available where required. 4.8.9 Exit/Egress Sufficient exits for prompt escape. No locks or fastenings restrict escape. OPX Consulting Inc. Section 4-12

Routes and exits are clearly marked. Exits and exit signs are adequately illuminated. More than one exit from work area is available. Approaches to exits are unobstructed. Flammable materials are kept out of exits. Cleaned of snow and ice. Open outward onto level floor/ground. 4.8.10 Eye Baths and Showers Readily available and accessible in areas where caustic/corrosive chemicals are used. Water supply provides a minimum of 15 minutes flush at a comfortable temperature. Proper signs and instructions are posted. Flushed frequently to eliminate contaminants. 4.8.11 Fatigue Ensure workers have adequate recovery for sleep between shifts. Train company and contractor personnel in identifying and addressing fatigue related concerns. Conduct safety meetings to ensure workers understand the risks associated with working while fatigued. 4.8.12 Fire Protection Area/operation has been evaluated for explosion potential and procedures have been developed. Hot work procedures are developed. Ignition sources are identified. The possibility of a static electricity problem is addressed. Hazardous areas have been identified and access is controlled. Fire retardant clothing is available. Portable extinguishers appropriate for type of materials are readily available. Extinguishers are properly maintained and usable. Fire hoses are properly mounted, accessible and maintained. Fire equipment is visibly marked and access is unobstructed. Fire doors, lids and shutters are in good repair and unobstructed with fusible links intact. Sprinkler heads have proper clearance from materials and furnishings. Sprinkler master control valves are accessible and locked open. 4.8.13 First Aid Kits / Stations / Equipment Adequate materials and equipment are available and properly located. Sufficient number of people trained in first aid are available. OPX Consulting Inc. Section 4-13

4.8.14 Hand and Portable Tools Proper general conditions of tools, electrical cords and air hoses. Proper storage when not in use. Guards and safety devices are serviceable and used. Electrical grounding or double insulation protected. Power tools equipped with constant pressure switches. Tool retainers are installed on pneumatic tools. Adjustments are correct. Load rating is sufficient for work performed. Correct tools are provided with proper training. 4.8.15 Hydraulic Power Systems Pressure is regulated within power limits. General conditions; examine for leaks, dents, nicks and severe scratches of pressure lines and fittings. Fluid pressure lines are identified. Remote shut-off is available. Inspections are recorded. 4.8.16 Ladders Meet CSA standard. Safety feet are in serviceable condition. Non-painted and free of grease and oil. Properly positioned; tied in at top. Doors are blocked open, locked or guarded if in front of a ladder. Supported in place against window openings. 1 m extension above roof if used for access to roof (or platform). Defective ladders have danger tags affixed. Metal ladders are not used in electrical areas. Fixed ladders have landing platforms every 6.5 m. Fixed ladders above 3 m have cages. 4.8.17 Lifting Gear / Equipment General condition, damage, cleanliness, lubrication and servicing. Log books are maintained. Legibly labeled as to capacity and load testing. Safe access (steps or platform) to cab/seat. Limit stops are operational. Hoist motor brakes are operational. All controls are operational. Hooks are not deformed or damaged and safety latches intact. In-running nip points are guarded. OPX Consulting Inc. Section 4-14

4.8.18 Lighting Walking and working areas are adequately illuminated. Lighting fixtures are clean. Illumination level is sufficient for detail or work performed. 4.8.19 Materials Handling Adequate equipment is available. Containers are in good repair. Pallets and skids are of the correct type and are in good repair. Chains, slings, and ropes are adequate for loads and are in good repair. Lifting equipment is properly stored. Wheel chocks are provided. Equipment inspection records are available. 4.8.20 Mechanical Power Systems General condition and servicing is acceptable. Rotating collars, couplings, cams, clutches, fly-wheels, spindles, shafts, shaft ends, bolt ends, key ends and nip points are guarded. Transverse moving chains, belts and slides are guarded. Emergency stops are operational. Speed is regulated within design limits. 4.8.21 Noise Exposure Economically feasible engineering controls are implemented. Protection is available in areas where sound levels exceed standard. Hazardous noise areas are identified and marked. 4.8.22 Personal Protective Equipment Clothing is suitable for the hazards. Fire retardant clothing is available where exposure to fire/explosion is possible. Coveralls are done up. Gloves are worn to protect against cuts, blows, abrasions, chemicals. Clothing is clean and in good condition. Traffic safety vests are available where there is exposure to traffic hazards. Hard hats are available. Hard hat shell and suspension are inspected regularly and are in good condition. Eye protection that is CSA approved and appropriate to the hazards (welding flash flying objects, dust and chemicals) is available. Eye protection is in good condition and stored properly. Proper CSA Grade of footwear is being worn. OPX Consulting Inc. Section 4-15

Approved respirators, suitable for hazards, are available and a copy of the Code of Practice is available. Hearing protection is available where required. 4.8.23 Platforms / Scaffolding Working platforms are at least 0.5 m wide (light duty) or l m wide (heavy duty). REMOVE 1 m wide repealed Ladderjacks, pump jacks or similar systems may have a 0.3 m wide platform. Open spaces between the platform and structure must not be greater than 0.25 m in width. Adequate footing for workers in place. Continuous platform around obstructions. Maximum working load is identified. Toe boards are provided along all sides were prescribed. Proper non-skid flooring. Mesh screen below floor if open construction. Safe access to movable platforms. Access gates are self-closing and locking. Equipped with standard guard rail or other fall protection if higher than 1.2 m (permanent) or 3.5 m (temporary). Sound, rigid footing for scaffolds. No excess accumulation of tools or materials. No altering or moving of scaffolds in use. Condition of casters is acceptable. Condition of jacks and leveling screws is acceptable. 4.8.24 Pneumatic Power Systems Pressure is regulated within limits. Restraining clips are on hose lines. Compressor is drained and tested. General condition of hoses and connections is acceptable. Air lines are identified. Water entry in pneumatic tools is controlled. Hoses and tools are in usable condition. Eye and hearing protection signs are in place (requirements as noted). 4.8.25 Pressure Vessels and Piping Meters and controls are accessible. Safety valves are operational. Drains are clear and freeze protected. Inspection certificate/label appropriate to type is attached. Pipes, connections and vessels are free of dents, notches and severe scratches. Shields, platforms and landings are installed as appropriate. Remote shut-off to pumps is operational. OPX Consulting Inc. Section 4-16

Respiratory/rescue and confined space equipment is available. Piping can be properly isolated. Proper personnel control signs are available. 4.8.26 Signs and Tags Hazard warning, directional and informational signs and tags are posted where there are immediate dangers, potential hazards, or where there is a need for general instructions. Signs and tags are used consistently throughout the facility. Tags are affixed to all defective equipment not secured against use. WHMIS labels are available. TDG labels are available. 4.8.27 Stacking and Storage Aisles and access paths are clear and unobstructed. Small or irregularly shaped items are properly blocked and interlinked, with proper limitations of storage height. All stacks are stable and secure against sliding/collapsing. Proper drainage in storage area. Storage area is clean and cleared of foreign objects/materials. Rack and platform load limits are posted. Dangerously reactive materials are separated. 4.8.28 Stairs Stairs are provided where there is regular traffic between levels. At least 600 mm wide or as prescribed. Angled between 30º to 50º as prescribed. Steps are uniform in height and tread depth. Tread depth/clearance behind step is sufficient to allow safe footing. Outdoor stairs have grating type treads. Treads and nosings are slip resistant. Long flights are broken by rest platforms as prescribed. Handrails are provided on open sides. Handrails are on at least one side if closed. Sufficient vertical head clearance. Clear and unobstructed. 4.8.29 Substance Abuse Develop policies/procedures to address substance abuse. Company employees and contractors must report to work free from effects of alcohol and or illegal drugs. Inform workers if they are found to be under the influence or suffering from the affects of alcohol/illegal drugs they will removed from location and suspended from work immediately. OPX Consulting Inc. Section 4-17

Workers shall report use of prescription drugs to supervisor. In the event of a worker committing a criminal act while working for the company, the company will report the matter to the appropriate law enforcement or regulatory agency. 4.8.30 Trenching / Excavating Locates/crossing permits have been completed. Workers are hand locating the utilities. A spotter is available to assist the operator when visibility is restricted. Protection from cave-ins is adequate. Precipitation is controlled. Shoring is being installed properly. Spoil pile is set back at least 1m from the edge. Minimum depth of cover is maintained (stoppers, flanged tees, etc.) Access/egress is adequate and meets OH&S Code. Workers are staying clear of moving machinery. Vehicle/equipment vibration is accounted for. Ground water forces and/or displacement are accounted for. Barricades, fencing, signs, steel plates are used to protect the public. Workers are aware of the potential for an oxygen deficient atmosphere. 4.8.31 Valves and Mechanical Controls Properly identified. Operational. Readily accessible. Measures are in place to prevent inadvertent operation. 4.8.32 Vehicles and Equipment Emergency equipment (first aid kit, flares, fire extinguisher) is available. Interior and exterior are clean. Lights, horn, windshield, parking brake, etc. are in acceptable operating condition. Back-up alarm is functioning. Load/objects are secured. Guards are in place. Operators complete pre-trip inspection (lights, oil, coolant, tires, etc.) Operators complete circle check. Operators adjust mirrors properly. Operators/passengers use safety belts. Operators use helper to assist with back-up. 4.8.33 Ventilation and Extraction Monitors to monitor the working environment. Adequate means are provided to dilute or remove contaminants. Air inlets and openings are arranged to minimize escape of contaminants. OPX Consulting Inc. Section 4-18

Enclosures provide continuous inward airflow. Gas and H 2 S exposure are monitored. 4.8.34 Violence and Harassment Conduct risk assessment to determine risk of injury to workers from violence arising from employment. Establish procedures/policies and work arrangements to eliminate or minimize the risk. Train company and contractor personnel in identifying and addressing violence/harassment in the workplace. Establish procedures for reporting, investigating and documenting incidents of violence and harassment. Respond to incidents of violence/harassment (i.e. incident investigation, taking corrective actions, assisting in referrals to physician for treatment. 4.8.35 Warning Systems Emergency alarm systems are operational. Hazard warning systems are installed on appropriate vehicles and equipment. Over-pressure warning systems are installed on pressure vessels. Over-temperature warning systems are installed on fired pressure vessels, hazardous material storage and powered equipment. Personal monitors are adequate for the job, and workers are trained and qualified to use them. 4.8.36 Waste Disposal Adequate number of appropriate metal refuse containers is available. Separate containers are provided for oily rags, smoking materials, dusts, flammable scrap and chemical wastes. Safe disposal facilities for wastes are available. Anti-static devices are fitted as necessary. Chemical spill absorbent materials are available in work areas. 4.8.37 WHMIS / TDG Labels are affixed to all containers in storage and in use. Placards/labels are affixed to vehicles transporting hazardous materials meeting legislated requirements. Labels are legible and visible. Workers are adequately trained. MSDS are readily available and current. 4.8.38 Work Surfaces, Floors and Roadways Surfaces are in good repair. OPX Consulting Inc. Section 4-19

Free of slip, trip, or fall hazards. Free of protrusions, nails, etc. Sufficient width and vertical distance. Aisles are marked. Standard signs and marks are in place and in good condition. Prepared for seasonal weather extremes; i.e. snow, rain, heavy usage. Drainage is maintained. Openings are covered or barricaded. Load limits are posted on upper floors. Safe speeds are posted. OPX Consulting Inc. Section 4-20

4.9 WELL SERVICING SPACING REQUIREMENTS OPX Consulting Inc. Section 4-21

4.10 DRILL SITE SPACING REQUIREMENTS OPX Consulting Inc. Section 4-22

4.11 BATTERY SPACING REQUIREMENTS OPX Consulting Inc. Section 4-23

SECTION 4 FORMS Well Safety Checklist and Hazard Id Vehicle Safety Inspection Checklist Hazard Identification & Control Form Service Rig Inspection Checklist Drilling Rig Inspection Checklist OPX Consulting Inc. Section 4-24

Well Safety Check & Hazard Identification Facility Name: Location: Date Inspected: Completed by: 1 = Acceptable X = Unacceptable N/A = Not applicable/assessed SITE Proper signage Item Housekeeping. general appearance Snow removal - sufficient or piled By doors or on pipes. Driving Hazards flagged (risers, lines, etc) Bull plugs in place Fire extinguisher access and inspection dates Piping secured Slipping and tripping hazards Location access, road Flammable liquid storage (safe distance from heaters) Proper storage of chemicals Adequate WHIMIS labeling Date PSV s serviced Vegetation Control Steps and handrails Vibration Shutdowns not bypassed Safety equipment: SCBA Burn Blankets Eye wash stations First aid kits, clean/full ESDV s in service and block valves locked open Combustible materials present Guards on moving equipment satisfactory Electrical equipment secure Tanks Secondary Containment Truck Loading cable, containment Comments and/or if answered Unacceptable, describe Action Proposed / Control Date Completed Frequency of Follow-up

Vehicle Safety Inspection Checklist Vehicle No. Date: Items to be checked Comments/Deficiencies Brakes (Pedal Pressure) Emergency Brake Both Tail Lights Windshield Wipers Turn Signals Horn Back up lights Both headlights (high & low beam) Tires Tread Inflation Spare Brake Lights Hazard Lights Seat Belts First Aid Kit Tow Rope Flares/Reflectors Fire Extinguisher

HAZARD IDENTIFICATION & CONTROL The purpose of this form is to ensure a written, documented process, which both identifies hazards and establishes controls for all workplace tasks. Emphasis should be placed on the elimination of existing hazards. Corporation: Location: Task: Work Permit # (if applicable): Date: REFERENCE LIST OF POSSIBLE HAZARDS: List all hazards associated with the task in the spaces provided below. Please consider all hazards and not just the references listed. Flammable Gas Driving Hazards/ATV use Ground Disturbance (Excavation/Trenching) Flammable Liquids Fatigue Confined Space / Restricted Space Pressure H 2 S Iron Sulphides NORM/Asbestos Chemicals Working around moving vehicles Road/Lease Conditions Inadequate Equipment Guards Slips/Trips Working at heights Poor Illumination Protruding Objects/Pinch Points Excessive Noise/Vibration Extreme Weather Exposure Overhead Hazards (powerlines) Noxious Vapours (Benzene) Working Alone Suspended Overhead Equip. Rotating Equipment Wildlife Encounters Defective Tools/Equipment Hot/Cold Piping Equipment Violence/Harassment Hoisting Equipment REFERENCE LIST OF POSSIBLE CONTROLS List a control (s) for each identified hazard in the space provided below. Please consider all controls, not just the reference list given. Corporation Policies High LEL & H 2 S Shutdowns Safe Work Practices House Keeping Confined Space Permits/Plans LEL Monitoring/Function Testing Safety Standby/Safety Watch Equipment De-energized Muster Area Air Monitoring Isolation (Blinding/Blocking) Forced Ventilation Safe Work Permits Fire Extinguishers Secondary Containment/Spill Control Training/Certifications SCBA/SABA Safety Inspections (CAODC, walkabouts etc.) First Aid Plan Restricted Areas Explosion Proof Equipment Personal H 2 S Monitor Hearing Protection Guards/Shields Warning Signs PPE (Fire Retardant Coveralls) Safety Harness/Lifeline/Fall Protection Plan Unsure? Call a Supervisor! Respirator Wash Facilities Incident Reporting/Investigation Tailgate Meetings Audits/HSE Contract Inspections IDENTIFIED HAZARDS & CONTROLS HAZARDS CONTROLS This Hazard Identification & Control Form completed by: Signature Printed Name

SERVICE RIG INSPECTION CHECKLIST NOTE: ANY HAZARD OR DEFICIENCY MUST HAVE AN EXPLANATION AND BE CORRECTED *Transcribed from the CAODC Manual* Company: Rig No.: Rig Mgr: Rig Operator: Operating Company: Operating Company Representative: Date: Time: am/pm Location: (yr) (mo) (day) Current Operation Being Performed: GENERAL RIG 1 All guards in place and in good condition Yes No 2 Matting in good condition Yes No 3 Leveling jacks properly matted, locked and derrick centered over well properly Yes No 4 Guy lines properly anchored Yes No - Pull tested Yes No - Rating lbs. 5 Escape line pull test preformed Yes No - Rating lbs. 6 Guy line come-alongs, etc. in good condition Yes No 7 Minimum required clamps properly installed on: (a) Guy lines Yes No (b) Load lines Yes No (c) Escape line Yes No 8 Air shutoffs checked by operator and operational Yes No 9 Emergency shutoff control positions: (1) Operator s panel Yes No (2) Sandline controls Yes No 10 Operator s controls properly marked Yes No 11 Weight indicator working properly Yes No 12 Crown saver - Installed N/A Yes No - Set and tested Yes No 13 Exhaust pointed away from well and shielded Yes No 14 Railings in place on side walkways and stairs Yes No 15 Condition of handrailings, walkways and stairs Good Hazard 16 Hand tools: condition, clean and properly stored Good Hazard 17 Working floor, housekeeping, toe plates, ladders and handrails Good Hazard 18 Catwalk conditions N/A Good Hazard 19 Walkway from ground to catwalk (stairs) Yes No 20 Walkway from working floor to catwalk or ground Yes No 21 Rig properly secured in drawworks gear Good Hazard COMMENTS/EXPLANATION: DRAWWORKS 22 Conditions of drill line (slipped regularly) Good Hazard (a) Slip and cut record Yes No 23 Sufficient wraps (min.7) left on drum with blocks down Yes No 24 Braking system - Linkage/pin satisfactory Yes No - Block wear Good Hazard 25 Condition of sandline & rope socket to sinker bars Good Hazard 26 Handling winch/line Good Hazard Condition at: - Winch anchor points Good Hazard - Winch line Good Hazard - Winch line thimble Good Hazard - Tall chain Good Hazard - Safety hook Good Hazard - Hydraulic hoses & connections Good Hazard - upper shivs & assembly Good Hazard COMMENTS/EXPLANATION: MAST 27 Stand pipe properly anchored to mast Yes No 28 Kelly hose in good condition Yes No 29 Kelly hose safety lines or chain attached to derrick and swivel ends while in use Yes No 30 Levels I, II, III or IV inspections completed as required in CAODC RP 3.0 Yes No 31 Ladders in good condition Yes No 32 Rod basket in good condition N/A Yes No 33 Crown sheaves greased and in good condition Yes No 34 Safety cables attached to fingers on tubing board Yes No 35 Derrick locking pins in place Yes No 36 Derrick hydraulic system in good condition Yes No 37 Mast lighting secured adequately Yes No 38 Dead lines anchor and retainer properly placed Yes No COMMENTS/EXPLANATION: TRAVELING ASSEMBLY 39 Levels I, II, III or IV inspections completed as required in CAODC RP 4.0 Yes No 40 Blocks - nuts, safety pins in place and in good condition Yes No - Sheave guards/lock in good condition Yes No 41 Balls/links - good condition Yes No 42 Elevators - good condition Yes No 43 Rod hook - good condition Yes No 44 Transfer elevators - good condition Yes No 45 Safety latch/ring in place Yes No COMMENTS/EXPLANATION: POWER TONGS 46 Back-up in place and functional Yes No 47 Torque arms safety line, clamps in good condition Yes No 48 Tong positioner - operational and in good condition Yes No 49 Hoses, gauges and hydraulic fittings in good condition Yes No COMMENTS/EXPLANATION: ELECTRICAL/LIGHTING 50 Light bulbs enclosed with vapour-proof and shatter-proof covers Yes No 51 Covers on unused receptacles Yes No 52 Light switches vapour-proof Yes No 53 Electric motors within 8.5 metres radius must be explosion-proof Yes No 54 Equipment properly grounded Yes No 55 All cords and plug ends in good condition Yes No 56 Proper clearance from power lines Yes No COMMENTS/EXPLANATION: RIG PUMP AND TANK 57 Condition of pipe and unions Good Hazard 58 Pump and return lines laid out and secured Yes No 59 Kill line attached to well with valve open (steel lines only) Yes No 60 Pressure relief valve (proper size and rating) Yes No 61 Relief valve set at or below system working pressure NOTE: Only shear pins appropriate Yes No to the pop valve requirements as specified by the manufacturer shall be used 62 Relief valve discharge points down and away from pump motor and is securely fastened Yes No NOTE: No valve on relief line 63 Manifold conditions Good Hazard 64 Check valve in place on pump discharge Yes No 65 Exhaust away from rig tank Yes No 66 Emergency shutoff checked and operational Yes No 67 Pump controls properly marked Yes No 68 All railings in place on walkways/stairs of rig pumps and tank Yes No COMMENTS/EXPLANATION: DOCUMENTATION 69 Necessary transportation documentation and equipment present (i.e. registration, insurance) Yes No 70 Required inspection certificates available Yes No 71 Derrick log book available and updated Yes No COMMENTS/EXPLANATION: F

BLOWOUT PREVENTER SYSTEM 72 BOP function tested - From remote controls Yes No - From accumulator controls Yes No 73 All studs used on BOP stack Yes No 74 Hydraulic preventers installed Yes No - Pipe rams Yes No - Blind rams Yes No - Annular preventer Yes No 75 Condition of ram rubbers and elements Good Hazard 76 Fire-shielded hoses and their condition within 7 metres of wellhead Good Hazard 77 Remote stand 7 metres from well - Class I & II - Refer to BOP regulations Yes No - Or at remote accumulator - Class III Yes No 78 Nitrogen back-up supply pressure kpa - Min. 12,500 kpa if annular preventer is installed - Min. 7,000 kpa when only rams are installed 79 Pre-charge check date / / Good Hazard 80 BOP's adequately heated Yes No 81 Lines protected in vehicle crossing area when remote accumulator is used Yes No 82 Safety valve fully opened with proper thread connection on rig floor c/w closing wrench Yes No COMMENTS/EXPLANATION: ENVIRONMENTAL 83 All equipment free of leakage Yes No - If no, adequately contained Yes No 84 Rig site free of material that may create a fire hazard NOTE: Equipment spacing must ensure unimpeded access to well at all times Yes No COMMENTS/EXPLANATION: BOILER 85 Chemical storage Good Hazard 86 Blowdown line labeled Yes No 87 Pop valve line labeled Yes No 88 Controls - Labeled Yes No - Condition Good Hazard COMMENTS/EXPLANATION: VALID CERTIFICATES ON LEASE: HEALTH & SAFETY 89 Occupational Health and Safety manual at rig site Yes No 90 Proper BOP regulations at rig site (i.e. G-37) Yes No 91 Clothing policy in place Yes No 92 Rig Safety Equipment: (a) CSA approved full body harness Yes No (b) Escape line and buggy at station of work Yes No 93 Wind flags -Guy lines Yes No - Pump/tank area Yes No 94 Clothing - Hard hats Yes No - Safety boots Yes No - Protective clothing Yes No 95 Safety glasses or goggles available Yes No 96 Hearing protection available Yes No 97 Fire extinguishers: - Minimum 4 working and readily available for use (13.6 kg) Yes No - Extinguishers in good condition Yes No 98 First aid kit adequately stocked Yes No 99 Record book in place Yes No 100 Eyewash bottle Yes No 101 Stretcher and blanket Yes No 102 H2S detector - Chemical tube type Yes No 103 Breathing apparatus requirements met Yes No - Condition Good Hazard - Bottles full Yes No - Spare bottles Yes No - Date of hydrostatic test on bottles / / 104 Signs - No smoking Yes No - H2S area (if applicable) Yes No - No vehicles beyond this point Yes No 105 Housekeeping - Rig Good Hazard - Changeroom Good Hazard - Vehicles Good Hazard - Rig pump Good Hazard - Rig tank Good Hazard - Lease Good Hazard - Boilers N/A Good Hazard Winterizing - Pre-tab, heaters etc. Yes No 106 Condition of Fall Protection equipment Good Hazard COMMENTS/EXPLANATION: OTHER COMMENTS ON THIS INSPECTION: Rig Manager: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Operator: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Derrickman: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Floorhand: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Floorhand: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Other: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Other: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Other: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: N 50 m 25 m ROUGH IN LEASE DIAGRAM Water/fuel tanks WT/FT Mud Pump MP Boiler B Light Plant LP Crew change unit CCU Accumulator ACC Fire Extinguisher FE Others Specify Inspection completed by: Position: F In company with: Position:

DRILLING RIG INSPECTION CHECKLIST CONTRACTOR: RIG NO.: RIG MGR.: LEASE LOCATION AND LSD: CRITICAL SOUR WELL (Y/N): INSPECTED BY: DATE: / / TIME: hrs (Yr) (Mo) (Day ) (24 hr clock) Mark a check if adequate A or inadequate I or blank If not applicable (Note: Any INADEQUATE must have an explanation and be corrected) A. FUEL/WATER TANKS 01. No leaks 02. Pumps guarded 03. Signs at water/fuel tanks: a) No smoking sign posted b) Fuel sign posted c) Dangerous Goods placard posted B. BOILER HOUSE 04. No clothing etc. 05. Sight glass guarded 06. Pump guarded 07. Fire extinguisher 08. Safety valves: one year certificate 09. Boiler 25 m from wellheads 10. Housekeeping 11. Flammables removed from around boiler 12. Boiler License posted 13. Blow down line location & installation of steam deflector 14. Fuel/water and steamline leaks 15. Chemical addition vessel (pot) at boiler properly labeled (WHMIS) C. GENERATOR BUILDING 16. Generator/motor control centre - size; condition 17. Receptacles/circuit breakers identified 18. Properly grounded (2 grd rods 3 m apart) 19. Wiring off the ground & properly secured 20. No clothing/storage 21. Fans and belts guarded 22. No fuel/oil leaks 23. Compressor belts guarded 24. Fire extinguisher 25. All lights protected 26. Housekeeping 27. Rubber mat on floor at Motor Control Centre 28. Battery condition 29. Signs at Generator Building a) Auto Start sings posted b) Hearing Protection sign posted c) Electrical/High Voltage signs posted d) Water Hose Caution sign posted e) Lockout and Procedures 30. Wiring/electrical fixtures condition 31. Current turned off prior to connecting/disconnecting extension cords D. ACCUMULATOR AND TOOL HOUSE 32. No leaks/spillage 33. N2 bottles (12500 kpa/1800 psi) 34. Housekeeping 35. Storage of compressed gas cylinders, secured 36. Controls identified/accessible 37. Safety device blind/sheer ram controls 38. Fire extinguisher 39. Grinder tool rest 40. Eye protection available 41. Compressor guarded 42. Signs at Accumulator and Tool House a) Eye Protection signs posted b) Auto Start signs: compressor / accum pump c) Dangerous Goods placard/whims label 43. Accumulator reservoir vented outside of building/enclosure (A) / (I) 50. Piping, valves and unions meet pressure rating 51. Pulsation dampeners 52. Eyewash facility 53. Pop/bleed off lines secured and drained 54. Signs at Mud Pump area: a) Lockout Procedures posted b) Auto Start sign posted c) Hearing Protection sign posted d) No Smoking sign posted 55. Wiring/electrical fixtures condition F. MUD TANK AREA 56. Mud degasser(s) (size and placement) 57. Shale shaker belts guarded 58. Handrails, walkways 59. Adequate ventilation 60. Adequate lighting 61. Personal protective equipment eye protection, dust masks, rubber gloves/apron 62. Housekeeping 63. Tank level indicators operative 64. Trip tank level indicator Tank location 65. Mud van, stairs, lighting 66. Safety line rail sump side of tanks 67. Eyewash facility 68. Sings at Mud Tank area: a) Eye Protection at hoppers b) No Smoking signs posted c) Corrosive sign at caustic drum d) Applicable WHIMS labeling 69. Wiring/electrical fixtures conditions C. SUBSTRUCTURE 70. General condition 71. Matting condition 72. Drive pins installed c/w safety pins 73. Spreaders in place 74. Vent doors/fan 75. Illumination 76. Winterization condition 77. Hydraulic control lines condition fire guarded hose 78. Flow nipple split 79. Stripper/mud catcher split 80. Scaffolding/ladder(s) condition 81. Cellar area cribbed and drained 82. Wiring/electrical fixture condition 83. Housekeeping (oil leaks, etc.) H. BOP S 84. BOP and rig equipment conform to Government regulations 85. BOP secured properly 86. Non-steel hydraulic lines fire sheathed 87. Mud gas separator adequately connected meets minimum requirements, including line size and tie down 88. Required casing wear tests being preformed 89. BOP pressure tests recorded and test procedures satisfactory 90. Adequate heating 91. Manual ram locking wheels available (A) / (I) E. MUD PUMP AREA I. DOGHOUSE 44. Pop valve shear pin correct size and length 45. Pop valve cover in place 46. Guards in place and in good repair 47. Hoses safely chained 48. Fire extinguisher (No. ) 49. Housekeeping 92. Heated as per regulations 93. Adequate exits 94. Intercom meets regulations 95. Storage area, crew change area 96. Housekeeping 97. Fire extinguisher 98. Eye and hearing protection available 99. Eyewash available Page 1 of 3

100. First Aid kit stocked and cleaned 101. Safety belts 102. Condition of available hand tools 103. BOP controls, electrical, manual, air 104. Bulletin board 105. Drilling License posted 106. Emergency phone numbers posted 107. Signs at Doghouse: a) Hard Hat sign posted b) Hearing Protection sign posted c) No Smoking sign posted d) Maximum holdback casing pressure posted e) Blowout procedure posted and readable f) MSDS available 108. Wiring/electrical fixture condition J. BREATHING APPARATUS INSPECTION 109. Number of packs available 110. Location of air packs 111. General condition of apparatus and case 112. Condition of face piece 113. Condition of nose cup 114. Cylinder pressure 115. Low pressure alarm operational 116. Cleanliness and storage 117. Positive pressure capability 118. Number/condition of spare cylinders 119. Location of spare cylinder (chained) 120. Cascade system or safety trailer 121. SCBA cylinders hydrostatic test dates current 122. Other K. RIG FLOOR 123. Lockout on drawworks 124. Compound/drawworks guard 125. Crown saver (check) 126. Catline 127. Catline divider and spool 128. Spinning chain/wrench line 129. Headache post 130. Kelly cock condition 131. Kelly hose condition 132. Kelly hose safety line both ends 133. Line spooler/safety line 134. Backup post condition 135. Tongs condition 136. Tong line and tong line clamps 137. Slips condition 138. Dog collar condition 139. Stabbing valve and handle and X/O subs 140. Test plugs 141. Mud can condition 142. Drilling controls and identification 143. Brake handle hold-down cable/chain 144. Non-skid material around rotary 145. Lighting operational, floor and motor area 146. Motors: a) Fans and belts guarded b) No fuel/oil leaks c) Motor shutoff d) Fire extinguisher (No. ) e) Exhaust system 147. Stairs (min. 3 exits) from rig floor 148. Warning horn working 149. Hydromatic and guards 150. Brakes satisfactory 151. Tugger line condition, guards 152. V-door opening safety chained 153. Wiring/electrical fixture condition (A) / (I) L. DERRICK (Certification Date: ) 154. Block hanging line 155. Bumper blocks secured 156. Fingers straight 157. Fingers chained 158. Wind board installed 159. Ladder condition 160. Escape line installed. No blockage of line (i.e. tank or vehicle) 161. Escape buggy installed and accessible 162. Climbing device/cages 163. Derrickhand s belt and condition 164. Guy lines/outrigger 165. Condition of crown sheaves 166. No loose tools equipment cabled on derrick 167. All safety pins in place, secured 168. Lighting operational and safety cables/chains attached 169. Inspection prior to raising/lowering 170. Condition of tong counterweight assembly 171. Wiring/electrical fixture condition M. TRAVELING ASSEMBLY 172. Blocks 173. Bails/links 174. Elevators/latches 175. Weight indicator assembly 176. Weight indicator safety line 177. Automatic driller 178. Drilling line condition (slip/cut program) 179. Deadline anchor condition N. PIPE RACK AREA 180. Racks butt firmly to each other and catwalk 181. Catwalk in good condition 182. Stairs in good condition 183. Pipe rack level 184. Pipe rack ends properly pinned 185. Spacer between racks sturdy and secure 186. Derrick stand in good condition 187. Housekeeping 188. V-door ramp in good condition 189. Catwalk, tugger, guarded 190. Lay down line and block condition 191. Layers of drill pipe or casing properly choked 192. Adequate lighting O. MANIFOLD HOUSE 193. Heated 194. Valve handles installed 195. Proper gauges installed and positioned 196. Drill pipe pressure gauge installed 197. Unobstructed view to rig floor 198. Housekeeping 199. Manifold design meets Government requirements 200. Flare lines properly secured 201. Lighting operational 202. Choke/valve open to degasser 203. Well to: - End of flare line 50 m - Rubbish burn pile 50 m - Crude oil storage tank 50 m 204. Signs at Manifold House: a) Hold Back Pressure notice posted b) No Smoking sign posted 205. Choke and degasser lines and manifold prepared P. LEASE AREA 206. Lease clean and dry 207. Flare pit properly dug 50 m from wellbore 208. Adequate ditching and drainage 209. Incinerator/garbage bin 210. Open pits (e.g. sump) guarded/fenced 211. Sump fluids properly contained 212. Lease properly diked 213. Overhead lines flagged 214. Signs at Lease area: a) H2S Warning signs, if applicable b) Poisonous Gas signs posted c) Tight Hole Status sigh posted Q. CAMP/GENERAL FACILITIES 215. Propane tanks location (No. ) Propane distance from camp (min. 4 m) 216. Garbage disposal: incinerator - bins 217. Walkways 218. Kitchen First Aid kit 219. Kitchen fire extinguisher 220. Fire extinguisher (No. ) (A) / (I) Page 2 of 3

221. Generator Building: a) Grounded b) No clothing, storage c) No fuel/oil leaks d) Fire extinguisher 222. Furnace rooms 223. No unnecessary storage 224. Fire alarm system 225. Bedrooms exit to outside (shutters open) 226. Adequate distance from well centre 227. Housekeeping 228. Signs at Camp area: a) Hearing Protection sign posted 229. Exit signs over doors installed and illuminated 230. Emergency lighting installed and functional 231. Wiring/electrical fixtures condition (A) / (I) T. SAFETY/GENERAL 265. Condition of electrical tools 266. Personal safety equipment being used 267. Visitor hard hats 268. Toxic gas equipment (detector and tubes) 269. Oxygen resuscitator available 270. Adequate emergency vehicle available 271. Accident reporting and recoding 272. Directional rig signs 273. Stretcher, location (No. ) 274. Condition of handrails and stairs toe boards 275. Fire retardant clothing available 276. Fire extinguishers checked weekly and hydrostatic test dates are current 277. Suitcasing/walkways (A) / (I) R. RIG SITE TRAILERS 232. Adequate distance from well centre 233. Propane system 234. Door or knock out window (bedroom) 235. Emergency phone numbers posted 236. Intercom 237. Smoke detectors 238. Gas detection equipment 239. Breathing apparatus 240. Fire extinguisher 241. First Aid Kit U. ENVIRONMENT POLICY AND PROCEDURES 278. Company manual(s) On-site and Current 279. CAODC Waste Wall Chart Posted 280. Contractual Responsibilities Reviewed V. GENERAL LEASE CONDITIONS 281. Lease site clean and free of debris 282. Special Conditions 283. Berm integrity S. TICKETS/DOCUMENTS ( where not applicable) 242. BOP checks daily with record 243. BOP drill with records and signs by Rig Manager and Foreman 244. Motor kills weekly with records 245. Trip sheets completed 246. Weekly safety meeting with records 247. Well control ticket: Rig Manager and Foreman 248. BOP ticket Drillers 249. First Aid certificate (one per crew) 250. H2S training (all crew members) 251. Drilling prognosis 252. Emergency Response Plan 253. Well Site Emergency Contingency Manual 254. Company policy statement posted 255. Government Regulations available 256. OH&S Regulations available 257. Drilling Rig Health and Safety Committee Guidelines 258. WHMIS training all crew members 259. MSDS available current 260. Daily rig check by Foreman and Rig Manager 261. Slip and cut program recorded 262. Equipment certification/maintenance records available and current 263. Clothing policy posted 264. New employee orientation training W. SPILL RESPONSE 284. Employees trained 285. Sorbents available 286. Spill response report form available 287. Emergency response procedure X. WASTE MANAGEMENT 288. Waste separated into hazardous/non-hazardous 289. Secondary containment for hazardous waste 290. Waste bin in good condition 291. Recyclable waste properly segregated and stored 292. Non-Hazardous recyclable waste properly segregated and stored 293. Light plant waste properly stored Y. WASTE DOCUMENTATION 294. Waste manifests complete and maintained on file 295. Used oil recycled and documented 296. Used oil filters recycled/drained and documented 297. Oily rags recycled and documented 298. Batteries recycled and documented 299. Glycol recycled/properly disclosure and documented 300. Land filled wastes and sites indicated and properly documented Z. COMMENTS/EXPLANATIONS DRILLING FOREMAN SIGNATURE RIG MANAGER SIGNATURE Page 3 of 3

5.0 COMMUNICATION Communication is the most essential element in a safety program. Effective communication between all levels of workers is necessary to monitor and improve safety and environmental performance. In addition, good communication creates an opportunity for management to distribute information and receive the necessary feedback. 5.1 MEETINGS Safety meetings provide the opportunity for the sharing of information among all stakeholders. These meetings should include project kick-off safety meetings, tailgate safety meetings, and/or regular scheduled monthly meetings. The frequency and type of meeting may vary but the Occupational Health and Safety legislation states that employers hold regular meetings at least once each month for the review of: i) Reports of current accidents, near misses and hazards, identifying root causes and means of prevention. ii) Remedial actions taken or required by reports of assessments/inspections and providing investigations. iii) Any other matters pertinent to health and safety. Additionally, Project/Pre-Job/Tailgate Meeting are to be conducted for project or contractor work. Supervisors are required to hold pre-job meetings to discuss the scope of the task, hazards, and control measures implemented. A summary of these meetings is provided, as well as samples of meeting agendas. 5.1.1 General Health, Safety & Environment Meetings Should be held regularly Have an agenda (published and circulated). (See attachments for additional planning information and sample agendas). Minutes recorded and circulated. Held with all workers including contract personnel, consultants, contractors and sub-contractors. An annual safety meeting should be conducted for all HARVARD personnel. Topics may include: Safety rules and policies, hazard assessment and controls. Recent accident/incidents cause and prevention. Work procedures (new/revised/review) equipment use and condition review. Current issues including environment, insurance, emergency response plans, government acts and regulations, safety grams, bulletins, memos, etc. Training general and formal courses that can be worked on as a group. (e.g. Off-Highway Driving, Working with Propane). Presentations by area workers, Company departments or suppliers. OPX Consulting Inc. Section 5-1

Figure 1: PLANNING A GENERAL HSE MEETING What is the purpose of the General HSE Meeting? To Improve: Safety Quality Communication Cost Control Team relations Environmental Awareness Clarity of goals, rules, and procedures What are the components of a good meeting? Time is used efficiently There is a clear agenda There are clear results (who does what, by when) Expected results are clearly summarized in meeting minutes What skills do I need to lead the meeting? To Reduce: Injuries and loss Rejects and rework Misunderstandings Mistakes and waste Resistance to change Environmental damage Problems and confusion There is a set start and finish time There is open and active group discussion Signatures of all meeting attendees are obtained. Before: Plan: objectives, agenda, actions Communicate: purpose, time, place, subjects, expectations Prepare: meeting place, supplies, equipment presentation During: Get it going: start on time, thank attendees, introduce the subject, lay the groundwork Maintain momentum: promote participation, apply the art of asking questions, deal with sticky situations or problem participants, use repetition, memory and audiovisual aids Bring it to a stop: summarize, highlight action steps, thank participants, end on time After: Issue minutes and/or reports Express special appreciation Follow-up Evaluate and improve Is there a suggested format? Opening Remarks 2 min. Old Business 5 min. Presentation 15 min. Discussion of Presentation 5 min. New Business 20 min. Closing Remarks 3 min. I know the basics, but what else is classified as new business? Safety grams Hazard Assessment / Identification / Controls Incident / Accident / Spill Statistics Emergency Preparedness WHS/OH&S / WCB bulletins Key policies and procedures Where can I get help, especially with my presentation? Your supervisor or co-worker Formal training, self-teach programs, training videos OPX Consulting Inc. Section 5-2

5.1.2 Project / Pre-Job / Tailgate Meetings Project Meetings are: Held prior to start of construction project. Include principle contractor, consultants (company representatives), prime contractor(s), and sub-contractors. Minutes recorded and circulated. Pre-Job Meetings are: Held prior to start of a major job or project (ie: turnarounds, workovers, major overhauls, jobs where others may be affected, special projects such as environment clean-up, and tie-ins. Minutes recorded and circulated. Tailgate and/or Toolbox Meetings: Should be held daily Are crew or site-specific Task has limited scope. Review work permit and work procedure. Record of meeting documented (minutes or general entry in logbook). The following is list of topics that could be discussed at these meetings. This list is intended as a guide and topics may be added or deleted as necessary. OPX Consulting Inc. Section 5-3

Figure 2: Project / Pre-Job / Tailgate Agenda (add or delete items as necessary) SAFETY PROGRAM MANUAL 1. HARVARD expectations of contractors and orientation (see also handbook orientation quiz in Section 9.0). 2. Authority of Company Representatives to shutdown contractor work. 3. Right and responsibility of any worker to refuse unsafe work. 4. Scope of work and work area layout Outline of Job (layout, duration, manpower, etc.) Tracking of Workers on Location Check In / Check Out Location of Restricted Work Areas Trespassing Implications 5. Schedules Project Schedule Hours of Work Days off and Holidays Schedule Delays Critical Points on Project Schedule Permit Approvals When, Who, How? 6. Work Permit and Work Clearance System 7. Requirement to Report Hazards / Close Calls and Incidents 8. Hazard Assessment & Identification (written see Hazard Assessment & Identification section), ie: H 2 S Driving hazards & restrictions Overhead powerlines Location of buried lines & cables Equipment/material lifts Hot work Confined/Restricted space entry Combustible atmospheres Housekeeping Working at heights OPX Consulting Inc. Section 5-4

WHMIS / TDG Housekeeping 9. Job Procedures/Drilling and Completions general and critical tasks Fracing Drill Stem Testing, Swab Testing, Flow Testing Acidizing Coiled tubing Pressure Testing Energy-isolating device activated (electrical or auto- start equipment) In-the-Derrick Work Other non-regular operations Use of the Man Basket 10. Safety and Emergency Response Equipment (Safety / Emergency) and Location ie: outline of PPE requirements, location of first aid supplies, eye wash stations, etc. Emergency Response / Procedures: o Company Emergency Response Plan o Contractor Plan o Site-specific details such as emergency alarm system, safe areas, medical aid procedures (first aid transportation plan), name and location of first aider, first responder locations and contacts (ie: doctor, ambulance, hospital, fire department, police) 11. Review of Regulatory Requirements* 12. Communication Requirements / Methods (Mobile Telephones, Radios, etc.) 13. General Discussion and Other Job-Related Business *An employer must ensure that a current paper or electronic copy of the Provincial Occupational Health and Safety Act, Codes and Regulations are readily available for reference by workers. OPX Consulting Inc. Section 5-5

5.2 WORK PERMIT SYSTEM HARVARD has a work permit system which specifies the safety precautions to be taken when certain types of potentially hazardous work is being undertaken. Before any work begins the need for a JSA or work permit must be established. Overall work permit requirements are as follows: 1. All Calgary staff initiating and/or supervising in the field are required to obtain a work permit or a work clearance. No work will commence without a work permit or clearance in place unless otherwise authorized by the foreman responsible for the area. 2. A work permit, as defined by OH&S is required for: Hazardous or Hot Work Confined Space Entry Ground Disturbance Contractor Involvement 3. The existing work permit form will be used for both work permits and work clearance. If being used as a work clearance, the permit should identify the length of time the clearance is valid for. 4. If necessary, the work permit or clearance should be accompanied by a safety checklist or work procedure. At the discretion of the permit issuer, an ERP manual may be issued to the job supervisor at the time the work permit or clearance is issued. 5. Any HARVARD employee has the authority to suspend work until an approved work permit or clearance is in place. Any non-compliance problems will be referred to the employees/consultants manager for appropriate disciplinary action. Each area is responsible for developing site-specific guidelines for when work permits should be used. All work permits must be checked off as being one of the following designations: WORK CLEARANCE: This is a special work permit that is issued when the complete control of a site is turned over to another person. The person accepting the work clearance is responsible for ensuring continued site safety and for issuing any other safe work permits that may be required. This type of permit is good for the duration of the tasks to be carried out. NOTE: This is the type of permit that is given by the Production staff when they are turning a lease over to the well site supervisors of the Drilling and Completions department. OPX Consulting Inc. Section 5-6

WORK PERMIT: Hot Work This is issued whenever work is carried out that may introduce an ignition source in areas where combustible materials may or do exist. This includes such things as cutting, welding, burning, air gouging, riveting, drilling, grinding, chipping or using non-classified electrical equipment. Cold Work This is issued for work where no danger exists from ignition but where other potential hazards exist. This includes such things as toxic fumes, dust, vapours, chemicals, steam or pressure. BLANKET WORK PERMIT: This type of permit may be issued for an extended period of time (one year maximum). It is intended to be used for tasks that are carried out on an ongoing basis and where procedural guidelines have been established and agreed to by the contractor. An example of where this type of permit is used is for the hauling of fluids in a production area. NOTE: This type of permit would not be used in a drilling/completion operation. WORK ORDER: This permit is used by operating staff to communicate with maintenance staff regarding maintenance work needing to be done. In this case the operator will be his name on the Requested by: line and given an explanation of the work needing to be done in the Description of Work to be Done section. NOTE: This type of permit would not be used in a drilling/completion operation. 5.2.1 WORK CLEARANCE, PERMIT REQUIREMENTS AND PRE-JOB SAFETY MEETING REQUIREMENTS FOR DRILLING & SERVICE RIG OPERATIONS To address government regulations and HARVARD Safety Program requirements, this work permit system must be established for drilling and service rig operations. Work clearances and work permits are to be issued using HARVARD 'S work permit form (sample form attached). Many service companies have developed their own work permit system. It is permissible to use the contractors' work permit system when the contractors' work permit is more stringent or more applicable to the work being completed. A. WORK CLEARANCE PRIOR TO BEGINNING WELL OPERATIONS The intent of the work clearance is to ensure all known hazards or operating conditions that may affect safety at the site are identified, understood and communicated and all appropriate control measures have been implemented. When well operations work involves a well within an existing production area, the Well Site Supervisor is required to obtain a written work clearance from either the Production Superintendent or Foreman or their designate prior to commencing well operations. The Well Site Supervisor must also ensure the necessary emergency response support is available. OPX Consulting Inc. Section 5-7

It is the work clearance issuer's responsibility to advise the Well Site Supervisor of any known hazards relative to the planned well operation. B. WORK PERMIT REQUIREMENTS DURING WELL OPERATIONS While drilling, completing or servicing a well, work permits are to be issued by HARVARD 'S Well Site Supervisor for the following operations: 1. HOT WORK: As defined by OH&S. This includes any cutting, welding, burning, air gouging, riveting, drilling, chipping or other work where flame is used or sparks are produced, including operation of an internal combustion engine. There are two levels of hot work that need to be considered. Hazardous Hot Work - A work permit must be completed for any hot work carried out on the well site inside a designated hazardous area or in an area where flammable substances or residues have been detected or are likely. Hazardous areas for drilling and service rigs are summarized in the equipment spacing diagrams found in the Section 4.0 of this manual. Routine Hot Work - Work carried out on the well site outside any designated hazardous areas and away from any flammable substances. Hot work is prohibited in an atmosphere which exceeds 10% of the lower explosive limit. Field welding on fuel trucks, and other enclosed tanks such as accumulators or oil bunkers are also prohibited. This type of work must be performed in a shop. 2. CONFINED SPACE ENTRY: As defined by provincial OH&S regulations, is a restricted space which may become hazardous to a worker entering it because of an atmosphere that is or maybe injurious because of: a. An oxygen deficiency or enrichment, flammability, explosivity or toxicity. b. A condition or changing set of circumstances within the space that presents a potential for injury or illness c. The potential or inherent characteristics of any activity which can produce adverse or harmful consequences within the space. For each confined space entry requirement, the following steps must be taken in accordance with HARVARD s Confined Space Entry Code of Practice. Primary steps include: Providing proper ventilation; Testing the atmosphere; Providing proper respiratory equipment if hazards exist after testing; Assigning an attendant worker. A copy of HARVARD s Confined Space Entry Code of Practice can be found in Section 8.0 of this manual. OPX Consulting Inc. Section 5-8

Preplanning for the emergency rescue of the worker is critical. Prior to work commencing, any special rescue equipment required must be on site. Emergency response drills are encouraged to ensure that rig staff understands how to safely use specialized rescue equipment 3. GROUND DISTURBANCES IN THE VICINITY OF BURIED PIPING OR EQUIPMENT: This includes work around buried pipelines or other underground equipment and would include installing anchors, cat or backhoe work. HARVARD S requirements for ground disturbances are discussed in the Ground Disturbances Code of Practice which is found in the Work Procedures section of this manual (Section 8.0). Ground Disturbance Permits are valid only for that specific task and a specific location and are valid for a maximum of seven days. C. PRE-JOB SAFETY MEETINGS PRIOR TO PROCEEDING WITH CRITICAL OPERATIONS For other potentially hazardous operations, Well Site Supervisors will ensure that crews conduct a documented pre-job safety meeting. This would include, but not limited to, the following operations or procedures: Fracing Drill Stem Testing, Swab Testing, Flow Testing Acidizing Coiled tubing Pressure Testing Energy-isolating devices activated (electrical or auto-start equipment) In-the-Derrick Work Use of the Man Basket Other non-regular operations Work permits are not normally required for these operations. The Well Site Supervisor may elect to use the work permit to improve communications or to facilitate a pre-job safety meeting. The Well Operations Pre-Job Safety Meeting checklist found in this section of the manual can also be used for identifying and documenting the issues to be discussed. OPX Consulting Inc. Section 5-9

5.2.2 ISSUING A WORK PERMIT Can task be postponed until: Turnaround Scheduled shutdown Other suitable time YES Reschedule Work! Review work permit requirement at suitable time. NO Do ALL workers involved: Understand the scope of the work / task? Understand required work procedures? Have required training and are competent to complete the required task? Are trained to use and have necessary equipment available? What hazards does task involve? - Hot Work - Third Party Contractor - Cold Work - Chemicals, H 2 S, HVP, etc. - Confined Space - Breaking of system integrity - Other STOP Consider: Is this a critical task? Is a general or site-specific work procedure available? How does work to be done impact on other aspects of operations and/or workers? Complete Work Permit: Ensure permit issuer is competent and understands task. If necessary, review work procedures and attach to permit. Review completed permit with worker / crew. Post work permit at work site. When task is completed: Review work permit. Amend necessary work procedures. Develop work procedure. OPX Consulting Inc. Section 5-10

5.2.3 DEFINITIONS Please Read Prior to Issuing Access/Work Permit SAFETY PROGRAM MANUAL COLD WORK: HOT WORK: CONFINED SPACE: Used in hazardous maintenance work that does not involved hot work. Cold work permits are issued when there is no reasonable source of ignition, and when all contact with harmful substances has been eliminated or appropriate precautions taken. Means cutting, welding, burning, air gouging, riveting, drilling, grinding, chipping, using non-classified electrical equipment or introducing to a work process area a combustion engine or any other work where flame is used or sparks produced in a location where a flammable substance is or may be in the atmosphere or stored, handled, processed or used. A restricted space which may become hazardous to a worker entering it because of an atmosphere that is or maybe injurious because of oxygen deficiency, enrichment, flammability, explosivity or toxicity or because a condition or changing set of circumstances within the space that presents a potential for injury or the potential or inherent characteristics of any activity which can produce adverse or harmful consequences within the space. WORK CLEARANCE: TESTS: FLAMMABLE ATMOSPHERE: Work to be done that requires no preparation by operations personnel (environmental clean-up, etc.) Determination of whether the atmosphere contains a FLAMMABLE substance in a quantity sufficient to ignite, TOXICITY above the O.E.L. of a given chemical or OXYGEN CONTENT above or below considered safe limits. No testing shall be conducted inside a confined/restricted space unless a non-flammable atmosphere is established from outside the space providing the person testing is equipped with adequate personal protective equipment and no flammable atmosphere exists within the space. For Cold Work, or for entry without breathing apparatus, must not exceed 10% L.E.L. For Hot Work, must not exceed 0% L.E.L. OPX Consulting Inc. Section 5-11

TOXIC ATMOSPHERE: OXYGEN DEFICIENT ATMOSPHERE: OXYGEN EXCESSIVE ATMOSPHERE: ENERGY ISOLATION: ENERGY ISOLATION DEVICE: Above the Occupational Exposure Limited (O.E.L.) of a given substance. No person shall enter into an area where a toxic atmosphere exists without utilizing the proper personal protective equipment, e.g. approved respiratory equipment, protective clothing, eyewear, head gear, footwear, and appropriate rescue equipment and procedures. (Toxic atmosphere for H 2 S is above O.E.L. 10 ppm). Any atmosphere that contains less than 19 percent by volume of oxygen in air. Approved breathing apparatus must be worn by persons entering into any area that contains less than 19 percent by volume in air. (Normal oxygen content is 20.5 percent by volume in air). Any atmosphere which contains more than 23 percent by volume oxygen in air. No person shall enter into or perform hot work in any oxygen excessive atmosphere. A condition that prevents movement of control devices to the operating or on position. A mechanism or arrangement that will hold and maintain a control device in an inoperable or off position. COMMUNICATION AND ALERT: Where the atmosphere contains a harmful substance or a deficiency of oxygen, a worker must be attended by, and be in communication with another worker stationed at or near the entrance. Medical support must be contacted at the time of an alarm. NOTE: If any of the above gas levels are subject to change during the operation due to the agitation of sludge, temperature change, welding or cutting, use of solvents, purging with inert gases or deviation from procedures previously set, they may be required to be monitored on a continuous basis. Procedures to be followed may change accordingly. Given this situation, a new permit may be required. OPX Consulting Inc. Section 5-12

SECTION 5 FORMS Drilling and Completions HSE Meeting Report Monthly HSE Meeting Report Work Permit OPX Consulting Inc. Section 5-13

Location: Chair Person: Meeting Agenda: Monthly Health, Safety & Environment Meeting Report Start Time: Adjournment Time: Date: Presentation (video / speaker / other): Old Business: (record outstanding issues until resolution) Action # Mo/Yr Action By Closure Date Additional Agenda Items: Action # Mo/Yr Action By Closure Date New Business: Action # Mo/Yr Action By Closure Date Handouts Circulated: Page 1 of 2

Health, Safety & Environment Meeting Report Page 2 Incident Reviews: Action # Mo/Yr Action By Closure Date Safety Grams / Regulatory Bulletins: Action # Mo/Yr Action By Closure Date Hazard Alerts: Action # Mo/Yr Action By Closure Date Next Meeting Location: Date: Start Time: Chair Person: Attendee Sign In: Topic: Page 2 of 2

WORK Permit Hot Cold Clearance Confined Space/ Restricted Space Order Requested by: PERMIT No: Supervision Continuous Intermittent Location: Contractor: Description of Work to be Done / Comments: Issued by: Issued by: Phone No: Phone No: COMMUNICATION PROCEDURES Req'd Complete N/A Req'd Complete N/A 1 Job discussed with Worker/Contractor/Maintenance 24 Stand -by Man/Continuous Gas Monitoring 2 Work Procedures Reviewed 25 Electrical Equipment/Valve Handles Locked & Tagged 3 Safety Regulations Received/Reviewed 26 Grounding/Bonding Required 4 M.S.D.S. Reviewed 27 Equipment Cooled/Ventilated/Isolated 5 Safety Meetings 28 Blinds Installed/Bleeds Open 6 Area Roped Off & Warning Signs Up 29 Vessels/Lines Purged 7 Radio on Hand 30 Shoring/Cut Back Required 8 Review Code of Practice (Site Specific) 9 Specific Training Identified PERSONAL PROTECTIVE & SAFETY EQUIPMENT 31 Air Hood/Dust Respirators HAZARDS 32 Breathing Air - SABA / SCBA 10 Combustible Material Removed 33 Face Shield/Goggles/Safety Glasses 11 Drains Covered/Sumps Covered and Sealed 34 Hearing Protection 12 No Vessels/Pumps to be Vented/Depressured 35 Protective Clothing 13 Overheard Lines, Clearance Established 36 Safety Harness and Life Line 14 Underground Line, Located & Identified 37 Safety Belt and Lanyard 15 Other Hazardous Material 38 Explosion Proof & Low Voltage Electrical Equipment 16 High Voltage 39 Air Movers/Ventilators 17 Intrinsically Safe Equipment 40 Scaffolding 41 Wash Facilities EMERGENCY PLANNING 18 Safe Egress from Work Areas Identified 19 Fire Extinguisher Ready to Use Note: Completed checkbox, should be completed by permit receiver after 20 Steam/Water hose Ready to Use all requirements have been met. 21 Emergency Air horn 22 ERP Manual Discussed 23 Atmosphere Testing (Explosive, Toxic & Oxygen Deficiency ) Record Below AREA FREE OF (appropriate box) N/A N/A Combustible Gas (vapour) % LEL % LEL % LEL % LEL Hydrogen Sulphide ppmh 2 S ppmh 2 S ppmh 2 S ppmh 2 S Toxic Gas ppmh 2 S ppmh 2 S ppmh 2 S ppmh 2 S N O T E Oxygen Content % O 2 % O 2 % O 2 % O 2 Tester's Signature This permit is valid only as long as work conditions existing at the time of its issuance continue and expires upon occurrence of any hazard such as gas leak, liquid spill, drastic operating change in equipment, or change in wind direction blowing vapours into the work area. Any worker will have the right to stop the job if he has reasonable grounds to believe that the job is, or likely to become unsafe. Work shall not resume until a new permit is issued. Validity (Permit - only valid for single shift) FIRST TEST Hours SPECIAL PRECAUTIONS, INSTRUCTIONS & EQUIPMENT REQUIRED RETESTS Hours Issued Date: Time: Expiry Date: Time: N/A RETESTS Hours N/A RETESTS Hours We have read & understand the required precautions/instructions. Approval by: Supervisor Accepted By: Contractor Representative/Worker work indicated above has either been: completed or cannot be continued until the issuance of a new work permit. Signed: Supervisor Contractor Representative/Worker

6.0 INCIDENT INVESTIGATION AND ANALYSIS 6.1 OVERVIEW SAFETY PROGRAM MANUAL Regulations require that incidents be reported, investigated, and analyzed to determine corrective actions and prevent recurrences. Incident investigation involves specifying what actually happened, and determining the root and basic causes. Analysis is an overall study of accident types, frequencies, locations and common causes. It also involves identifying risk areas, safety needs and accident trends to determine where improvements are necessary. 6.2 INCIDENT REPORTING Every employee and contractor must immediately report all incidents, no matter how small, to HARVARD Supervisor. Supervisors must report accidents and close calls to their manager immediately to ensure the root cause of the incident has been identified and the follow up process is in place. Supervisors must also assist in the investigation all incidents, at least to the extent that the risk potential is determined, and then submit reports as required (i.e. ERCB, OGC, OH&S). All injury accidents must be classified as either first aid, medical aid, modified work, or lost time. Any non-compliance is to be reported immediately to the regulator and an incident report completed and submitted to HARVARD supervisor. This means at the first available opportunity without jeopardizing the safety of personnel responding to an incident, not when it is convenient and the emergency is over. You should be aware that failure to report an incident is often seen to be more serious than the incident itself and can result in administrative penalty or other enforcement action by the regulator. All non-compliance events will be reviewed to determine what factors led to the noncompliance and actions items identified to ensure the non-compliance will not reoccur. Additionally, all regulatory audits and inspections are to be reported as soon as results are made available to company staff or representatives. 6.3 ACCIDENT INVESTIGATION AND FOLLOW-UP The first line supervisor may initially being investigating all incidents and making recommendations to prevent occurrences. The HARVARD HSE person is responsible for completing and signing off on all incident investigations. Assistance of a safety professional in carry out the investigation may be required if the incident is, or has the potential of being, a major loss. 6.4 LOSS CONTROL STATISTICS Incident statistics are maintained and reviewed on a regular basis to determine the effectiveness of the safety program. These reports are also used to help determine the types of accidents occurring, common causal factors, where they are occurring, high risk tasks, program needs, accomplishments and trends. The statistics are reviewed by HARVARD s management. OPX Consulting Inc. Section 6-1

6.5 INCIDENT INVESTIGATION RESPONSIBILITY FLOWCHART LEVEL 1 Did the incident involve? Equipment damage under $10,000 First aid injury or medical aid injury YES Did the event have a significant potential of being a SERIOUS incident? NO YES NO Minor Incident Notify Production Manager * Line supervisor assumes responsibility of senior investigator An interim report is to be submitted within 24 hours. Submit completed Incident Report Form within 5 days LEVEL 2 Did the incident involve? Equipment damage between $10,000 and $250,000 A lost time injury A potential threat to public safety NO YES YES Did the event have a significant potential of being a MAJOR incident? NO Serious Incident Notify Production Manager * Area supervisor assumes responsibility of senior investigator Submit initial report immediately Submit final report after all documentation is complete LEVEL 3 Did the incident involve? A fatality A permanent disabling injury Equipment damage in excess of $250,000 Exposure of public to injury YES Major Incident Notify Production Manager * Area supervisor assumes responsibility of senior investigator and incident review committee Submit interim report within 48 hours and final report after all documentation is complete Ensure proper government and insurance notifications are made Field form to be submitted to HSE Department Level 2 incidents require a formal Incident Investigation Report completed by Harvard HSE Department. OPX Consulting Inc. Section 6-2

6.6 INCIDENT INVESTIGATION METHODOLOGY FLOWCHART SENIOR INVESTIGATOR / INCIDENT REVIEW COMMITTEE COLLECT EVIDENCE: - Photograph - Tear down analysis - Sketch and map - Analyze position - Test materials - Analyze parts - Reconstruct accident - Interview witnesses - Examine response and loss limitation actions DETERMINE IMMEDIATE CAUSES: - Substandard Practices - Substandard Conditions DETERMINE BASIC CAUSES: - Personal Factors - Job Factors DEVELOP AND TAKE REMEDIAL ACTIONS REPORT FINDINGS AND ACTIONS: - Incident report form for all incidents. - WCB form (employer s and employee s) for all medical and lost time accidents. - Include copies of any supporting documents such as police reports, lab reports, witness statements/reports, and pictures. FOLLOW-UP: - Ensure action items identified have been completed and are working effectively - Advise regulator of steps taken to correct non-compliance. - A written report to the regulator may be required and is to be submitted by the manager. OPX Consulting Inc. Section 6-3

6.7 INCIDENT INVESTIGATION REPORT Completing the Incident/Accident Report When determining the events surrounding an incident there are six key questions that will assist in the investigation process. WHO? Who saw the accident? Who was working with the employee? Who was injured? Who had instructed/assigned the employee? Who else was involved? Who assigned the work? Supervisor? Who else can help prevent recurrences? Who were the witnesses? WHAT? What was the accident/incident? What was the injury? What injured the employee? What was the employee doing? What had the employee being told to do? What tools had the employee being using? What machine/equipment was involved? What operation was the employee performing? What instructions had the employee been given? What specific precautions were necessary to FSM/FSH/Manufacture s operation manual? What specific precautions was the employee given by the supervisor? What protective equipment was the employee issued by the supervisor? What protective equipment was the employee using? What training had the employee been given to use the protective equipment correctly? What were the environmental conditions? (Hot/dry, wind/rain, ice, snow, etc.) What training had the employee received to perform the assignment? What were the initial precautions given to the employee in the Job hazard analysis? What additional precautions had the employee received in the tailgate safety session? What was the employee s tour of duty? What tour had the employee actually been working? What communication did the employee have? What communication equipment was required for the job? WHEN? When did the accident occur? When did the employee begin that job? When was the employee assigned on that job? When were the hazards pointed out to that employee? When had the employee s supervisor last checked on the job progress? When did the employee first sense something was wrong? When was the employee s last work/rest days? When was the employee tested/certified/carded to operate the equipment/machinery? When did the employee last check in? OPX Consulting Inc. Section 6-4

WHERE? Where did the accident occur? Where was the employee at the time? Where was the supervisor at the time? Where were co-workers working at the time? Where were other people who were involved at the time? Where were witnesses when the accident occurred? WHY? Why was the employee injured? Why did the employee do what he/she did? Why was the protective equipment not used? Why were specific instructions not given to the employees? Why was the employee in the position he/she was in? Why was the employee working beyond his/her scheduled tour of duty? Why did the employee not check with the immediate supervisor when they noted that things were not as they should be? Why was the employee using the tools or machinery he/she was using? Why was the employee not trained/certified to perform the job/operate the equipment? Why did the employee continue, even under the circumstances? Why was the supervisor not there at the time? Why was the employee working alone? HOW? How was the employee injured? (Based on facts only) How did the accident occur? ( Based on facts only) Summary of Responsibilities and Explanations for Filling out the Form A copy of the incident report form with section numbers referenced is provided at the end of this section. SECTION 1 This section should be filled out by the person preparing the initial report form: Environment is checked if it is an oil, water, chemical spill, gas release or a TDG incident etc. Safety is checked if it is an injury, vehicle accident, damaged property, etc. SECTION 2 This section should be filled out by the person preparing the initial incident report form. Close Call is checked if the incident did not result in an injury, environmental release, damaged equipment or property leading to a loss of production, etc. Injury is checked if the incident resulted in any type of injury no matter how small to company or contract personnel working for or on one of HARVARD s locations. Vehicle is checked if the incident involved a company vehicle even if there was no noticeable damage to the vehicle. This is also checked if the incident involved a contractor s vehicle. Release is checked if the incident involved a release of oil, water, produced water, gas (sweet or sour) or chemical, etc. Property Damage is checked if the incident involved damage to company equipment, property or theft of equipment or property. OPX Consulting Inc. Section 6-5

Non-Conformance / Compliance is checked if the incident involved a non-compliance or contravention of a permit or license. This is also checked if the incident involved equipment non-conformance, which includes issues such as equipment alterations, material or specification changes etc. that are not consistent with HARVARD QMPQAP. Deficiencies identified as a result of an inspection by a regulatory body such as ERCB or OH&S, Saskatchewan Labour, Workplace Safety and Health (Man.) & SER. SECTION 3 This section should be filled out by HARVARD Supervisor. Interim Report is checked when the report is missing information such as final costs, follow-up action to identified assignments, etc. Final Report is checked when it is the final report completely filled out including final costs, injury information, cleanup description and follow-up, etc. NOTE: It is most important to complete a thorough incident investigation. If additional time is needed to complete a proper review of incident and to identify the required follow-up actions, an INTERIM report should be forwarded to Calgary by the end of the next working day with basic incident information. The FINAL report should be submitted once the investigation is completed, typically within one week. SECTION 4 This section should be filled out by the person preparing the initial accident report. District is Field is SECTION 5 This section should be filled out by the person preparing the initial incident report. Date of Occurrence is the date and time that the incident took place. SECTION 6 This section should be filled out by the person preparing the initial incident report. Date Reported is the date and time that the incident was first reported to the Calgary Office. SECTION 7 This section should be filled out by the person preparing the initial incident report. Location is the LSD the incident occurred on. Exact Location of Incident is the actual location on the lease that the incident happened (e.g. separator building, water injector building or 400 bbl. tank). If it is a vehicle incident this would be the location the accident occurred (e.g. Corner of 100 th Avenue and 108 th St., Kilometre 21 on Road 234). OPX Consulting Inc. Section 6-6

SECTION 8 - NOTIFICATIONS This section should be filled out by the person who is doing the notifications. Notifications include all government agencies or landowners that are notified. The name of the person and time they were contacted should be recorded. Following are the notification requirements for safety and environment incidents. (The following is meant as a guide only. The appropriate regulation should be consulted for full details). SAFETY INCIDENTS AB WCB: Employer s Notification Requirements: a. Complete and submit an Employer s Report of Injury or Occupational Disease to the WCB if the accident disables or is likely to disable the worker beyond the date of accident. You should report the injury within 24 hours of being notified. Failure to report injuries within 72 hours could result in a penalty. b. Report fatalities immediately. c. Report the accident if the worker needs medical aid not covered under basic health services; e.g. drugs, dressings, prosthetic replacement, dental repair and eyeglass replacement. Other Employer Responsibilities Include: a. Keep records of all first aid administered. b. Provide the worker with immediate transportation from the injury site to a medical treatment facility. You must ensure that adequate means of transport by land, water or air is available at all times. c. Pay the worker his regular salary for the day the injury occurred. If disablement goes beyond the accident day, compensation payments start the first regular working day afterward. Cheques are issued every two weeks. If you continue to pay the worker his full salary, you may arrange to receive compensation cheques on assignment by notifying the WCB. d. Work with the WCB and health care providers in developing an effective return to work plan for the injured worker. Injured Worker s Responsibilities Include: a. Submit a Worker s Report of Injury or Occupational Disease to WCB. b. Keep employer s informed of their progress to help employer plan for their return to work. c. Maintain ongoing communication with the WCB. d. Follow the advice of health care providers in order to recover as quickly as possible. OPX Consulting Inc. Section 6-7

AOH&S: a. An injury or accident that results in death. b. An injury or accident that results in a worker being admitted to a hospital for more than two days. c. An unplanned or uncontrolled explosion, fire or flood that causes a serious injury or that has the potential of causing a serious injury. d. The collapse or upset of a crane, derrick or hoist. e. The collapse or failure of any component of a building or structure necessary for the structural integrity of the building or structure. BC WCB: Employer s Notification Requirements: a. Report every work-related injury. The report must be made within three days of the injury s occurrence. b. Report every disabling occupational disease, or allegation of an occupational disease. The report must be made within three days of receiving the worker s report of the disease. c. Report every work-related death immediately to the Board and the Board s local representative. d. The report must be on the form prescribed by the Board and must state: The name and address of the worker. The time and place of the disease, injury or death. The nature of the injury or alleged injury. The name and address of any physician or qualified practitioner who attended the worker, and Any other details required by the board or by regulation. Employer s responsibilities include the Occupational First Aid Regulation under Section 5.70(1) of the Worker s Compensation Act. Injured Worker s Responsibilities Include: a. Report an injury or disabling occupational disease as soon as possible to the employer. The report must include: The name of the worker. The time and place of the occurrence. A description of the disease or injury and its cause. MAN WCB: Employer s Notification Requirements: a. Complete and submit Employer s Report of Injury Form to the WCB. You should report the injury within five business days of the accident. OPX Consulting Inc. Section 6-8

b. Report any fatalities immediately. Other Employer Responsibilities Include: a. Keep records of all first aid administered b. Provide the worker with transportation from the injury site to the medical treatment facility. You must ensure that adequate means of transport by land, water, or air is available at all times. Injured Worker s Responsibilities: a. Report the incident to your employer as soon as possible b. If you miss time from work because of the work related injury, report the accident to WCB by phone, fax or mail. c. Be sure and get medical attention d. Keep in contact with your employer and let them know how you are recovering e. Be sure to follow the advice of your medical professional MAN WHS: a. An incident that results in death or serious injury b. Collapse or structural failure of a building, tower, crane, hoist, temporary construction support system or excavation c. An uncontrolled spill or escape of a toxic, corrosive or explosive substance d. Explosion, fire or flooding SASK WCB: Employer s Notification Requirements: a. Must report injury within five days of it occurring b. Provide appropriate first aid c. Arrange for immediate transportation so worker can receive appropriate treatment from a qualified health care professional Injured Worker s Responsibilities: a. Get medical help if you need it b. Have your caregiver report to WCB c. Report the incident to your employer immediately d. Complete and submit Worker s Initial Report of Injury as soon as possible OPX Consulting Inc. Section 6-9

e. Participate with your employer, caregiver and WCB in setting up a personalized return-to-work plan SASK OH & S a. OH&S notification is required for any hospital stay of 72 hours or more due to medical aid, restricted duty or lost time accidents POLICE: LANDOWNER/ OCCUPANT: Any fatality Any incident that impacts or has the potential to impact the landowner/occupant. ENVIRONMENTAL INCIDENTS LANDOWNER/ OCCUPANT: GOVERNMENT AGENCY: Any incident that impacts or has the potential to impact the landowner/occupant. See Regulatory Reporting Requirements in Forms at the end of this section. SECTION 9 DESCRIPTION OF INCIDENT This section should be filled out by the person preparing the initial report and reviewed by the Production Foreman and the Production Engineer/Manager or their equivalent. Detailed Description of Incident is a complete detailed description of the incident including What, When, Where, Why, Who information, equipment, site diagrams, QMP reports, vehicle report forms and any other appropriate documentation. Vehicle Report is information that is necessary for insurance reporting requirements. There is a time limited for reporting an incident to the insurance company that may result in a claim. That can be done with a phone call. Unit Number is the vehicle number if the incident involved a HARVARD vehicle. Severity Potential section should be filled out by the Production Engineer or equivalent: Minor Personnel: Public: Environment: Regulatory: Injury requiring minimal or no first aid. No impact. Product or chemical release contained on lease or in process (Non-reportable spills typically less than 2 m 3 ). Written or verbal warning only. No fines or control orders likely to result. OPX Consulting Inc. Section 6-10

Serious Personnel: Public: Environment: Equipment: Regulatory: Injury requiring medical first aid with no lost time. Public exposure with potential to result in a complaint. Reportable product or chemical off-lease release or large spill contained on lease (Priority 3 spills - typically 2-20 m 3 ). Damage which results in down time less than 1 day. Infraction resulting in potential for a fine control order. Major Personnel: Public: Environment: Regulatory: Serious injury or health effects (Lost time injury). Exposed to potential accident or injury. Large uncontained product or chemical release (Priority 1 and 2 spills typically over 20 m 3 ). Potential for a significant fine or a control order requiring facility or operations shutdown. Probability of Occurrence Seldom is checked when the likelihood to occur is sometime in the facilities life. Not normally expected unless precautionary measures fail. Once every 10 years. Occasional is checked when it is commonly know to occur periodically. Likely to happen several times in the life of the facility. Usually yearly or longer within the district. Frequent is checked when it is expected to occur routinely or repeatedly over the life of the facility. Usually monthly or weekly within the district. This information is summarized in the Risk Matrix located in Section 4. NOTE: When evaluating the severity and probability of an incident, the description should note if the hazard was identified beforehand and if the necessary work permits were issued. SECTION 10 INJURY INFORMATION This section should be filled out by the person preparing the initial incident report. Copy of Applicable WCB Form Attached is checked when there was a reportable injury. An injury that involved medical aid, modified work, lost time or fatality is responsible. The applicable WCB form(s) are to accompany the incident form. All injury incidents must be classified as either first aid, medical aid, modified work, or lost time. The classification standard endorsed by the Canadian Association of Petroleum Producers and being used by HARVARD is ANSI Z16.4. To assist you in accurately filling out our incident report forms, outlined below are the four categories of injury accidents and some explanation of what type of incident fits into each category. OPX Consulting Inc. Section 6-11

1. First Aid This is defined as any one treatment and subsequent observation of minor scratches, cuts, burns, splinters and so forth, which do not ordinarily require medical care by a physician. The transport of an injured worker to a physician for observation or for diagnosis as a safety precaution can still be considered a first aid case. 2. Medical Aid The decision as to whether a case involves medical aid should be made on the basis of whether the case normally would require medical treatment. The decision cannot be made on the basis of who treats the case. A physician can administer first aid. Medical aid is defined as a work injury other than a first aid which requires treatment by a physician or other medical professional and includes: Impairment of body functions (e.g. loss of consciousness). Damage of a non-superficial nature to physical structure (fractures, cuts requiring stitches etc.) Complications (e.g. debridement following burns, treatment of infections arising from injury). Ongoing medical treatment (e.g. physiotherapy, repeat administration of a prescription pain killer, etc.) Diagnostic procedures such as x-rays or preventive procedures such as tetanus shots are not in and of themselves considered medical aid. 3. Modified Work This is any work injury which results in a temporary work assignment that does not include all the normal duties of the person s regular job. The temporary work assigned must be considered meaningful. Initiation of Modified Work Plan Employee reports to supervisor about need for medical limitations due to injury or illness. Employee presents medical information from recognized health care provider using HARVARD s Medical Limitation report. Employee has his/her supervisor develop a Modified Work Plan. Content of Modified Work Plans All modified work plans will specifically identify the: Medical limitations that require modified work Work duties or tasks to be modified Assigned work duties and the hours of work Physical demands of the assigned work duties Any change in assignment of supervision Employees commitment to follow and continue rehabilitation and medical care Frequency of medical progress reporting Employee and supervisor s commitment to adhere to the plan. OPX Consulting Inc. Section 6-12

Informal Modified Work Plan Medical advice indicates that normal job duties may be resumed within two weeks. The work plan may be developed and documented between the employee and their front line supervisor based on the medical limitations and work capability recommended by a recognized health care provider. Formal Modified Work Plan Medical advice indicates that modified work will be required for longer then two weeks. The work plan will be developed between the employee, the front-line supervisor and the area supervisor. A more detailed description of the physical demands of the proposed work duties may be required. The work plan will be documented and submitted to the appropriate health care provider and, when needed, by other interested stakeholders for input or approval. Return to Work Before employees return to work following a disability that resulted in medical limitations, the employee will present a progress report providing medical clearance to full work duties. 4. Lost Time Injury This is defined as an injury where the injured worker is unable to report for the next scheduled day of work or to modified work. Injured Party Company is checked when the injured party is a HARVARD employee. Public is checked if the person injured was someone that is not working for HARVARD as an employee or contract worker. Contractor is checked if the injured person was working for HARVARD as a contract operator, consultant or working for a company doing work for HARVARD. HARVARD that the injured party is working for must also be noted here. Name is the name or names of the injured person or persons. Employee Number is the injured person s HARVARD employee number. Phone Number is the injured person s home phone number. Address, City and Postal Code is the injured person s home address. Occupation is the occupation of the injured person. Experience is the number of years the person has been doing their present job. Injured Part of Body identifies which part of the body was injured in the incident. OPX Consulting Inc. Section 6-13

Immediate Supervisor is the injured person s direct supervisor be it a contract or HARVARD person. SECTION 11 ENVIRONMENT The first part of this section should be filled out by the person preparing the initial incident report. The second part should be filled out by the Production Foreman or their equivalent. Liquid is checked if the release was an unrefined petroleum product, produced water, fresh water or crude oil. Gas is checked for any accidental sweet or sour gas release. Other is checked if the release was a chemical or a refined petroleum product such as diesel, gasoline, etc. Terrain Affected o Land is checked if the release affected any of the surrounding area including on lease. o Water is checked if the release got into any river, creek or body of water. o Both are check when the release affected the surrounding area and body of water. Contained on Lease o Yes is checked if no product got off the lease or right-of-way. o No is checked if product did get off the lease or right-of-way. Rehabilitation Required o Yes is checked if work may have to be done at a later date to restore the spill area back to its original condition. o No is checked if no work is required other than the initial clean up. Waste Manifest is checked if a waste manifest needs to be filled out for any material hauled off location. Public Complaint is checked if there is a complaint from any party not working for HARVARD or if a spill or release is reported by a landowner, etc. GAS Discharged is the estimated amount of gas released expressed in m 3. This should include accidental or emergency flared gas volumes. Sweet or Sour indicates if the release contained H 2 S levels in excess of 10 ppm. WATER BASE MATERIAL PW is checked if the spill involved produced water. FW is checked if the spill involved fresh water. DISCHARGED is the estimated amount of water release expressed in m 3. RECOVERED is the actual amount of water cleaned up expressed in m 3. OPX Consulting Inc. Section 6-14

LIQUID HYDROCARBON Discharged is the estimated amount of hydrocarbon released expressed in m 3. Recovered is the actual amount of hydrocarbon cleaned up expressed in m 3. OTHER Discharged is the estimated amount of chemical, refined petroleum product released expressed in m 3. Recovered is the actual amount of chemical etc. cleaned up expressed in m 3. H 2 S% is the H 2- S content of the release expressed in %. Smoke is checked yes if there was a fire involved in the release or a flare stack or lit pit was involved. Otherwise no is checked. Odour is checked yes if there was a release that emitted an odour that may be noticeable to the surrounding public or contract personnel. Also if there was a complaint in the area. No would be checked if none of these apply. Noise is checked yes if there was a condition resulting in noise exceeding permitted levels. Also if there is a complaint from the public. Otherwise no is checked. Wind Direction is the direction the wind was blowing during or after the release. CONTROL MEASURES Description of Clean Up and Rehabilitation is a detailed description of what was done on location. How was the spill contained? What was the area affected? What was used to recover the fluid? Where was the recovered fluid taken and how was it disposed of? If hauled away to where? Was it treated on location? Were any of the fluids recycled? What special activity took place during the spill response and why? What amendments were applied to the site? A sketch of the spill area should be included with the report. (See Forms at the end of this section). AMENDMENTS APPLIED Quantab Values is the initial values obtained using the Quantabs provided in the spill kits. The final report should state what values were achieved. Date is the date the amendments were started or applied. Government File Number is the file number issued by the government at the time the release was reported. This number should be asked for when reporting the release. Date Rehabilitation Was Completed is the final date work was performed on the location. Calcium Nitrate is the amount of calcium nitrate used in the reclamation expressed in Kg s. Ammonium Nitrate is the amount of fertilizer (ammonium nitrate) used in the reclamation expressed in Kg s. OPX Consulting Inc. Section 6-15

Seed Mixture Applied is the type and amount of seed used in the reclamation. Other is any other product that may have been used in the reclamation of the lease e.g. straw, hay or Oil-Gator, etc. SECTION 12 VESSEL PIPELINE This section should be filled out by the Production Foreman or their equivalent. This section is used by the Calgary office for creating a history of failures on a particular line. This information can then be used to indicate if the entire line may need replacing. License Number is the Board license number found on the pipeline application to the government. Line Number is the number found on the license application. Line OD is the outside diameter of the line in the area of the failure (expressed in mm). Grade is the grade or type of pipe used: sour, sweet, schedule 40 etc. MOP is the maximum operating pressure of the failed line as stated on the pipeline license (expressed in kpa). Type of Wrap is the type of outside coating of the line (e.g. yellow jacket). Internal Coated yes is checked if the line has any type of internal coating. If not coated check no. Wall Thickness is the pipe thickness in the area of the failure (expressed in mm). Normal Operating Pressure is the operating pressure of the line under normal operating conditions (expressed in kpa). Depth of Cover is the amount of material that is covering the line in the area of the failure. Type is the type of line (e.g. fiberglass, plastic, etc.) Vessel I.D. is the Alberta Number or CRN registration number off the vessel. NON-CONFORMANCE RELATED TO: Repairs and Alterations is checked if the cause of the failure was related to any repairs or alterations done to the line or vessel. Material or Specification Changes is checked if the material or specifications in the area of the failure were not the same as on the licensing agreement or if any changes are being made. OPX Consulting Inc. Section 6-16

SECTION 13 SUMMARIZE ALL COSTS RELATING TO INCIDENT SAFETY PROGRAM MANUAL This section should be filled out by the Production Foreman or their equivalent. Note: This information is used by our insurance company to determine if a claim should be initiated. Final Costs is checked if this is the known final cost of the incident. Estimated Costs is checked if the costs are not known or there may be more costs added at a later date. Covering Costs o Company is checked if HARVARD is covering all the repair or clean-up costs. o Third Party is checked if the costs are being charged to or paid for by a contractor, trucking company, or someone else s insurance company, etc. Estimated Repair Replacement Costs is an estimated cost of the repair or replacement of a vehicle, piece of equipment or pipeline repair, etc. For larger incidents this information is needed right away for insurance reporting requirements. There is a time limit for reporting an incident to the insurance company that may result in a claim. This can be done with a telephone call. Final Repair Replacement Costs is the actual cost of repairs or replacement. Estimated Clean-Up Costs is the estimated cost of the clean-up including all transportation, disposal, clean-up and seeding costs, etc. For larger incidents this information is needed right away for insurance reporting requirements. This is a time limit for reporting an incident to the insurance company that may result in a claim. This can be done with a telephone call. Final Clean-Up Costs is all actual costs associated with the clean-up of the site. SECTION 14 WHAT WAS THE CAUSE OF THE INCIDENT The first part of this section should be filled out by the person preparing the initial incident report. This section should be checked by the Production Foreman and the Production Engineer / Manager or their equivalent. Describe any Unsafe Conditions. This is a detailed written explanation of any unsafe condition or conditions and should include the what, how and why. Any unsafe condition or conditions that contributed to the incident should be checked off. The written description should also discuss any unsafe conditions that are not included in the check boxes. Describe any Unsafe Acts. This is a detailed written explanation of any unsafe act or acts and should include the what, how and why. Any unsafe act or acts that contributed to the incident should be checked off. The written description should also discuss any unsafe acts that are not included in the check boxes. OPX Consulting Inc. Section 6-17

SECTION 15 CORRECTIVE ACTION TAKEN TO ADDRESS THE ROOT CAUSE OF THE INCIDENT This section should be filled out of the Production Foreman and reviewed by the Production Engineer/Manager. If required, the Calgary office may be asked to help with the investigation depending on the severity of the incident. Corrective Action is a detailed explanation outlining what actions have or will be taken to prevent the recurrence of a similar incident. The written description should also discuss any recommended actions not included in the check boxes. NOTE: Corrective actions should be based on an understanding of the basic causes. A summary of basic or root causes is provided in the Forms at the end of this section. SECTION 16 BLANK SECTION 17 FOLLOW-UP ASSIGNMENTS This section should be filled out by the Production Engineer/Manager. What is a brief description of follow-up that needs to be done to prevent a recurrence or to finish rehabilitation. Who is the person responsible to make sure the follow-up is completed. When is the date this follow-up is expected to be completed. Submitted By is the operator or person initiating the original report. Reviewed and Approved by is the Foreman or the Rig Construction Supervisor. Reports should be forwarded to HARVARD Calgary Office via fax (403) 229-0603 OPX Consulting Inc. Section 6-18

SECTION 6 FORMS Incident Investigation Report Spill Site Assessment Sheet Basic Causes of Loss Regulatory Reporting Requirements for Spills and Releases Reportable Spill Volumes for TDG Controlled Substances OPX Consulting Inc. Section 6-19

INCIDENT INVESTIGATION REPORT Please ensure you have provided all information for the incident you are reporting Note: See Instructions in Section 6.0 for completing form. ENVIRONMENT NEAR MISS INJURY VEHICLE RELEASE INTERIM REPORT SAFETY PROPERTY DAMAGE NON CONFORMANCE / COMPLIANCE FINAL REPORT DISTRICT: FIELD: Date of Occurrence: Date Reported: YYYY / MM / DD TIME YYYY / MM / DD TIME LOCATION N ERCB / MEM Name: Time: O LSD SEC TWP T MEI / SEM / NEB Name: Time: I W MER F WCB / OH&S Name: Time: EXACT LOCATION OF INCIDENT: I C AEP / MELP Name: Time: A T POLICE Name: Time: I LANDOWNER Name: Time: O N PROVIDE AN EXACT DETAILED DESCRIPTION OF THE INCIDENT, NON CONFORMANCE AND / OR PROPERTY AFFECTED: (attach diagram if appropriate) EQUIPMENT / VEHICLE INFORMATION - (including QMP) VEHICLE FORM ATTACHED UNIT NO. SEVERITY POTENTIAL Minor Serious Major PROBABILITY OF OCCURRENCE Seldom Occasional Frequent INJURY INFORMATION COPY OF APPLICABLE WCB FORM ATTACHED First Aid Medical Aid Lost Time Fatality Other Specify Injured party: Employee Public Contractor (Company Name) : Name: Employee # Phone # Address: City: Occupation: Postal Code: Experience: Yrs Injured Part of Body Immediate Supervisor: Modified Work Any product spill - Off Lease, Into a Water Course, or Over 2m³ on Lease is to be reported. On Lease spills under 2m³ do not need to be reported. ENVIRONMENTAL Liquid Other Terrain Affected Land Water Both Contained on Lease? Yes No Rehabilitation Required? Yes No Waste Manifest Yes No Public Complaint? Yes No Gas: Water Base Material (m 3 ) PW FW Liquid Hydrocarbon (m 3 ): Other: Discharged: Discharged: Discharged: Discharged: Sweet/Sour Recovered: Recovered: Recovered: H 2 S %: Smoke: Yes No Odour: Yes No Noise: Yes No Wind Direction: CONTROL MEASURES INCLUDING A DESCRIPTION OF CLEAN UP AND REHABILITATION: (Recovered product recycled? - Contaminated Soil? - Treated? Hauled Away? - Where?) Quantab Values: Amendments Applied: Date: Government File: Date Rehab Completed: Calcium Nitrate: kg Ammonium Nitrate: kg Seed Mixture Applied: Other: Straw etc. VESSEL / PIPELINE INFORMATION - (if applicable) License No. Line No: Line OD (mm): Grade: MOP (kpa): Type of Wrap: Internal Coat: Yes No Wall Thickness (mm): Normal OP. Press (kpa): Depth of Cover (m): Type: Vessel I.D. #: NON CONFORMANCE RELATED TO: Repairs or Alterations Material or Specification changes Page 1 of 2

INCIDENT INVESTIGATION REPORT Please ensure you have provided all information for the incident you are reporting Summarize all costs relating to incident Indicate Final Costs Estimated Costs Covering Costs Company Third Party Estimated Repair / Replacement Costs $ Final Repair / Replacement Costs $ Estimated Clean-Up Costs $ Final Clean-Up Costs $ What was the cause of the accident? (Determine the cause by analyzing all factors concerned. A person, a machine, or a physical condition? How? Why? A. Describe any UNSAFE CONDITIONS: CONGESTED WORK AREA OR RESTRICTED ACTION DEFECTIVE TOOLS, EQUIPMENT OR MATERIALS HAZARDOUS ATMOSPHERE: UNSAFE FLOOR, RAMPS, STAIRWAYS OR ROADWAY HAZARDOUS SUBSTANCE (GASES, DUST SMOKE, VAPOUR) INADEQUATE GUARDS OR PROTECTION INADEQUATE OR IMPROPER PROTECTIVE EQUIPMENT IMPROPER MATERIAL STORAGE INADEQUATE WARNING SYSTEM HIGH OR LOW TEMPERATURE INADEQUATE VENTILATION EXCESSIVE NOISE INADEQUATE / EXCESSIVE ILLUMINATION POOR HOUSEKEEPING RADIATION EXPOSURE INTERNAL CORROSION / EROSION UNSTABLE GROUND CONDITIONS EQUIPMENT FAILURE (WEAR & TEAR) B. Describe any UNSAFE ACTS: VIOLENCE / HARASSMENT FAILURE TO SECURE / LOCK-OUT FAILURE TO USE PROPER TOOLS OR EQUIPMENT FAILURE TO USE PERSONAL PROTECTIVE EQUIPMENT FAILURE TO USE GUARDS PROVIDED IMPROPER LIFTING, LOWERING OR CARRYING MAKING SAFETY DEVICES INOPERABLE IMPROPER LOADING OR PLACEMENT UNSAFE POSITION FOR TASK SERVICING EQUIPMENT IN OPERATION OPERATING AT UNSAFE SPEED OPERATING WITHOUT AUTHORITY INFLUENCE OF ALCOHOL AND/OR DRUGS USING DEFECTIVE EQUIPMENT USING EQUIPMENT IMPROPERLY LACK OF SKILL OR KNOWLEDGE UNNECESSARY HASTE HORSEPLAY UNSAFE ACT OF OTHER (3RD PARTY) UNAWARE OF HAZARD PHYSICAL LIMITATION / MENTAL ATTITUDE FATIGUE CORRECTIVE ACTION TAKEN TO ADDRESS THE ROOT CAUSES OF THE INCIDENT: Explain what you have done or what you recommended to prevent a recurrence of a similar incident / accident IMPROVED LAYOUT OR DESIGN IMPROVED / INCREASED SUPERVISION ADDITIONAL / PROPER JOB PROCEDURES IMPROVED CONSTRUCTION STANDARDS IMPROVED HIRING STANDARDS INCREASED ON THE JOB INSTRUCTION IMPROVED EQUIPMENT STANDARDS IMPROVED JOB PLACEMENT STANDARDS INCREASED ENFORCEMENT OF WORK STANDARDS IMPROVED PREVENTATIVE MAINTENANCE IMPROVED JOB PLANNING METHODS INCREASED ENVIRONMENTAL CONTROLS INCREASED INSPECTION / MAINTENANCE FREQUENCY ADDITIONAL TRAINING OR AWARENESS ADDITIONAL CONTRACTOR CONTROLS CORRECTIVE ACTION PLAN FOR QMP CONFORMANCE: SIGNATURE: INSPECTOR DATE FOLLOW-UP ASSIGNMENTS: WHAT? WHO? WHEN? SUBMITTED BY: (please PRINT) REVIEWED AND APPROVED BY: INCIDENT REPORTED BY SUPERVISOR / FOREMAN SIGNATURE DATE SUPERINTENDENT / MANAGER FORWARD REPORT TO: Page 2 of 2 This report is required as part of Harvard obligations under the Occupational Health & Safety Act of Alberta and is subject to the protections of sections 18 and 19 of that act. Further, any statements given herein are made subject to the protections provided by section 6 of the Alberta Evidence Act and section 5 of the Canada Evidence Act to the extent that they may apply.

SPILL SITE ASSESSMENT SHEET SAFETY PROGRAM MANUAL Contractor: SITE SKETCH Weather: Date: N Legal Description: W M NTS Location: Longitude: Latitude: Legend: Wellhead Sump Erosion Slope bl Building S ust Underground tank Pipeline Riser fp Flare Pit st Surface Tanks Spills/Contamination tsp Top soil pile ssp Sub soil pile Drainage direction Berm Trench ac Access Comments: OPX Consulting Inc. Section 6-20

BASIC CAUSES OF LOSS SAFETY PROGRAM MANUAL PERSONAL FACTORS JOB FACTORS Inadequate Physical/Physiological Capability - inappropriate height, weight, size, strength, reach etc. - restricted range of body movement - limited ability to sustain body positions - substance sensitivities or allergies - sensitivities to sensory extremes (temperature, sound, etc.) - vision deficiency - hearing deficiency - other sensory deficiency (touch, taste, smell, balance) - respiratory incapacity - other permanent physical disabilities - temporary disabilities Inadequate Mental Physiological Capability - fears and phobias - emotional disturbance - mental illness - intelligence level - inability to comprehend - poor judgment - poor coordination - slow reaction time - low mechanical aptitude - low learning aptitude - memory failure Physical or Physiological Stress - injury or illness - fatigue due to task load or duration - fatigue due to lack of rest - fatigue due to sensory overload - exposure to health hazards - exposure to temperature extremes - oxygen deficiency - atmospheric pressure variation - constrained movement - blood sugar insufficiency - drugs Mental or Psychological Stress - emotional overload - fatigue due to mental task load or speed - extreme judgment decision demands - routine monotony, demand for uneventful vigilance - extreme concentration perception demands - meaningless or degrading activities - confusing directions - conflicting directions - preoccupation with problems - frustration - mental illness Lack of Knowledge - lack of experience - inadequate orientation - inadequate initial training - inadequate update training - misunderstood directions Lack of Skill - inadequate initial instruction - infrequent performance - inadequate practice - lack of coaching Improper Motivation - improper performance is rewarding - improper performance is punishing - lack of incentives - excessive frustration - inappropriate aggression - improper attempt to save time or effort - improper attempt to avoid discomfort - improper attempt to gain attention - inappropriate peer pressure - improper supervisory example - inadequate performance feedback - inadequate reinforcement of proper behaviour - improper production incentives Inadequate Leadership and Supervision - unclear or conflicting reporting relationships - unclear or conflicting assignment of responsibility - improper or insufficient delegation - giving inadequate policy, procedure, practices or guidelines - giving objectives, goals or standards that conflict - inadequate work planning or programming - inadequate instructions, orientation and/or training - providing inadequate reference documents, directives and guidance publications - inadequate identification and evaluation of loss exposures - lack of supervisory management job knowledge - inadequate matching of individual qualifications and job task requirements - inadequate performance measurement and evaluation - inadequate or incorrect performance feedback Inadequate Engineering - inadequate assessment of loss exposures - inadequate consideration of human factors ergonomics - inadequate standards, specifications and/or design criteria - inadequate monitoring of construction - inadequate assessment of operational readiness - inadequate monitoring of initial operation - inadequate evaluation of charges Inadequate Purchasing - inadequate specifications on requisitions - inadequate research on materials & equipment - inadequate specifications to vendors - inadequate mode or route of shipment - inadequate receiving inspection and acceptance - inadequate communication of safety and health data - improper handling of materials - improper storage of materials - improper transporting of materials - inadequate identification of hazardous items - improper salvage of waste disposal Inadequate Maintenance - inadequate preventive - inadequate reparative assessment of needs communication of needs lubrication and servicing scheduling of work adjustment assembly examination of units cleaning or resurfacing part substitution Inadequate Tools and Equipment - inadequate assessment of needs and risks - inadequate human factors ergonomic considerations - inadequate standards or specifications - inadequate availability - inadequate adjustment repair maintenance - inadequate salvage and reclamation - inadequate removal and replacement of unsuitable items Inadequate Work Standards - inadequate development of standards - inadequate communication of standards - inadequate maintenance of standards Wear and Tear - inadequate planning of use - improper extension of service life - inadequate inspection and/or monitoring - improper loading or rate of use - inadequate maintenance - use by unqualified or untrained personnel - used for wrong purpose Abuse or Misuse - condoned by supervision - not condoned by supervision - unintentional/intentional OPX Consulting Inc. Section 6-21

Regulatory Reporting Requirements Page 1 TYPE PRODUCT/ INCIDENT CONDITIONS VOLUME/ SEVERITY ALTA B.C. Federal Any situation or dangerous occurrence that had the potential for Any WHS WCB NEB/TSB serious injury of workers (ie: structural failure or collapse of a support system, excavation, or contact with a pipeline) Actual injury / fatality of employee or contractor Any WHS WCB NEB/TSB WCB Notes: 1) In Alberta, WHS notification includes any hospital stay >2 days due to medical aid, restricted duty or lost time accidents Life Safety 2) WCB notification must occur immediately for fatalities or within 72 hours for injuries 3) Confirm with Incident Commander that local ambulance service or Stars Link Centre (Alberta) has been notified. Any situation that has or potentially may threaten the health and safety of the public On-Lease crude oil / salt water spill OR Product losses / vandalism Any AB: 2m3 or more BC: 100 L oil and >200 L salt water ERCB LDDS EMA Police * AT-via EMA ERCB PEP OGC/PEP Police * DTH OGC/PEP WLAP NEB/TSB Spills Off-Lease crude oil/ salt water spill or any pipeline release or any pipeline release that may, has, or could cause an adverse effect Crude oil/ salt water spill Into watercourse Transportation of Dangerous Goods (TDG) incident involving refined or unrefined products. This includes On or Off lease truck loading/ unloading spills Refined product or chemicals: Any significant spill, or a spill into water, or a spill that may, has or could cause an adverse effect Refined or unrefined spills involving PCBs or spills on aboriginal land, in National Parks or on railway right of ways Any volume ERCB OGC/PEP WLAP Any volume ERCB OGC/PEP AE PCD WLAP Volumes according to TDG regs EMA Local Police OGC/PEP Local Police Reportable volumes in AE PCD OGC/PEP TDG regs and CEPA EMA WLAP In addition to above spill notification requirements notify ECAN NEB/TSB ECAN DFO NEB/TSB cont d on next page

Regulatory Reporting Requirements Page 2 TYPE PRODUCT/ INCIDENT CONDITIONS VOLUME/ SEVERITY ALTA B.C. Federal Sour Gas Any volume ERCB OGC/PEP NEB/TSB WLAP Releases Odours/fugitive gas emissions In Alberta EUB unless from a refined product then notify AE-PCD Nuisance / noticeable, public complaint received ERCB OGC/PEP WLAP Flaring report to agency which issued approval Pipeline Contact/Failure/ Rupture Fire/ Explosion Unscheduled or Emergency Flaring Black Smoke or flaring that may cause an adverse effect Any EUB or NEB licensed pipeline is contacted, fails or ruptures Note: WHS must also be notified if situation causes or had potential to cause serious injury Any explosions and On or Off lease fires Note: As required, confirm with that local fire fighters/ forest fire/ or industrial fire fighters have been notified. AE-PCD: Exceeds facility approval AE-PCD or ERCB ERCB: exceeds approved volume or flaring for more than 24 hours ie: public complaint AE-PCD or received Any Any ERCB ERCB or NEB, as applicable WHS see Note ERCB WHS LDDS OGC/PEP WLAP OGC/PEP WLAP OGC/PEP WCB NEB/TSB NEB/TSB Pressure vessel Incident involving pressure vessel, boiler or pressure piping Any ABSA ML-BVS NEB/TSB Electrical Incident involving/possibly caused by electrical equipment Any SCO ML-ES NEB/TSB Vehicle accident Single or multiple vehicle accidents Any Local Police Local Police NEB/TSB Security Incident Threatening phone call or trespassers on company property. Any Local Police * AT-via EMA Local Police * DTH Abbreviation Government Regulatory Agency Phone # For Spill Reporting ERCB Energy Resources and Conservation Board Regional Offices 24 hrs.: Bonnyville (780) 826-5352, Drayton Valley (780) 542-5182, Grande Prairie (780) 538-5138, St. Albert (780) 460-3800, Calgary/Midnapore (403) 297-8303, Medicine Hat (403) 527-3385, Red Deer (403) 340-5454, Wainwright (780) 842-7570 AE-PCD Alberta Environment Pollution Control Division Pollution Control Division 24 hr. Spill Reporting Line (780) 422-4505 EMA & AT*; LDDS Emergency Management Alberta (*Alberta Transportation); Local Director of Disaster Services Emergency Coordination Centre 1-800-272-9600; Emergency Management s Local Director of Disaster Services for the region can also be notified via 1-800 number. WHS Workplace Health & Safety (also notifies WCB) 24 hr. reporting 1-866-415-8690 OGC / PEP; DTH*; WLAP BC Oil & Gas Commission & Provincial Emergency Program; (*Dept. of Transportation & Highways); Water, Lands, Air & Parks PEP 24 hr. (Provincial Emergency Program) 1-800-663-3456 Effective April 1, 2004 all incidents previously reported to OGC or WLAP are to be routed to the PEP emergency line. BC WCB BC Workers Compensation Board 24 Hour 1-888-6221-7233 ECAN Environment Canada In Alberta (Alberta Ministry of Environment) 1-800-222-6514 In BC (ECAN) 604-666-6100 DFO Department of Fisheries and Oceans navigable waters only Environmental Emergencies 1-800-889-8852; Navigable Waters Protection Branch Alberta (780) 495-3701 or B.C. (604) 775-8867 SCO Safety Codes Officer Alberta Municipal Affairs Safety Services, Electrical Discipline 780-415-0481 NEB & TSB National Energy Board & Transportation Safety Board NEB Regulated Lines Only - NEB Emergency Line 1-800-632-1663, Transportation Safety Board Incident Reporting 24 hr. (819) 997-7887 ABSA Alberta Municipal Affairs Regional Offices (daytime reporting) Edmonton (780) 437-9100 Calgary (403) 291-7070 Grand Prairie (780) 538-9922 Fort McMurray (780) 714-3067 Lethbridge (403) 381-5465 Red Deer (403) 341-6677 Medicine Hat (403) 529-3514 After Hours # for deaths or serious accidents (780) 437-9100. (* Highway Authorities for emergencies that impact or require closure of 1 or 2 digit highway

Regulatory Reporting Requirements - Page 3 TYPE PRODUCT/INCIDENT CONDITIONS VOLUME/SEVERITY SASK. MAN. FEDERAL Any situation or dangerous occurrence that had the potential for serious injury of workers: (ie: structural failure or collapse of a support system, Any OH&S WSH NEB/TSB excavation, or contact with a pipeline) Life Safety Actual injury / fatality of employee or contractor OH&S WSH Notes: 1). In Saskatchewan there must be notification to OH&S for any hospital stay of over 72 hours due to work related injury Any WCB WCB NEB/TSB 2). In Man. & Sask. WCB & OH&S (WHS) must be notified immediately for fatalities and within 5 days for any injuries Any situation that has or potentially may threaten the health and safety Any OH&S WSH NEB/TSB of the public Police Police On-Lease crude oil/salt water spill Sask: 1.6m3 or more SER OR Man: 0.5m3 or more Product losses/vandalism Off-Lease crude oil/salt water spill or any pipeline release or any Any Volume SER pipeline release that may, has, or could cause an adverse effect Manitoba Conservation Manitoba Conservation NEB/TSB Spills Crude oil/salt water spill into watercourse Any Volume SER Dept. of Environment Manitoba Conservation Transportation of Dangerous Goods (TDG) incident involving refined or Volumes according to Dept. of Environment Manitoba Conservation unrefined products. This includes - On or Off lease truck TDG regulations Local Police Local Police loading/unloading spills Refined product or chemicals: Any significant spill, or a spill into Reportable volumes in Dept. of Environment Manitoba Conservation water, or a spill that may, has or could cause an adverse effect TDG regulations & CEPA Refined or unrefined spills involving PCBs or spills on aboriginal In addition to above spill notification requirements notify ECAN land, in National Parks or on railway right of ways ECAN, DFO, NEB/TSB

Regulatory Reporting Requirements - Page 4 TYPE PRODUCT/INCIDENT CONDITIONS VOLUME/SEVERITY SASK. MAN. FEDERAL Sour Gas Any Volume SER Manitoba Conservation NEB/TSB Releases Odours/fugitive gas emissions Nuisance/noticeable, SER public complaint received Manitoba Conservation Flaring - report to agency which issued approval Unscheduled or Emergency Flaring Exceeds Facility Approval SER Manitoba Conservation Black Smoke or flaring that may cause an adverse effect IE: Public complaint SER Manitoba Conservation Pipeline Contact/Failure/ Rupture Any Provincial or NEB licensed pipeline is contacted, fails or ruptures NOTE: OH&S or WSH must also be notified if situation causes or had potential to cause serious injury Any SER Engineering Services Branch Manitoba Conservation NEB/TSB Any explosions and On or Off lease fires SER WSH Fire/Explosion NOTE: As required, confirm with the local fire fighters/forest fire or Any Fire Dept. Fire Dept. NEB/TSB industrial fire fighters have been notified. Pressure Vessel Incident involving pressure vessel, boiler or pressure piping Any Corrections & Public Safety Man. Labour/Imm. Mechanical & Engineering Branch NEB/TSB

Regulatory Reporting Requirements - Page 5 TYPE PRODUCT/INCIDENT CONDITIONS VOLUME/SEVERITY SASK. MAN. FEDERAL Electrical Incident involving/possibly caused by electrical equipment Any Sask Power Labour/Imm. Mechanical & Engineering NEB/TSB Vehicle Accident Single or multiple vehicle accidents Any Local Police Local Police NEB/TSB Security Incident Threatening phone calls or trespassers on company property Any Local Police Local Police Abbreviation Government Regulatory Agency Phone # For Spill Reporting SER Saskatchewan Energy and Resources Regina - 1-866-727-5427, Saskatoon - 1-800-667-5023 Regional Area Offices Petroleum Dev. Branch: Area I - Lloydminster - 1-(306) 825-6434 - Area II - Kindersley - 1-(306) 463-5400 - Area III - Swift Current 1-(306) 778-8252 - Area IV - Estevan - 1-(306) 637-4541 OH&S Saskatchewan Occupational Health & Safety 1-800-567-7233 - Office: 1-(306) 787-4496 Sask. WCB Sask. Workers Compensation Board Filing Claim - 1-800-787-9288 Sask. Dept. of Env. Saskatchewan Dept. of Environment Spill Control Centre: 1-800-667-7525 Dept. of Pipeline Sask. Petroleum & Development Branch Pipeline Conserv. Contact - 1(306) 787-2603 Corrections & Public Safety Sask. Corrections & Public Safety Pressure Vessel Reporting: 1(306) 787-4524 Man. Conserv. Manitoba Conservation Emergency Number: 1(204) 994-4888 WSH Manitoba Workplace Safety & Health Reporting Line: 1(204) 945-6848 After Hours - 1-(204) 945-0581 Man. WCB Manitoba Worker's Compensation Board Reporting Line: 1-800-362-3340 ECAN Environment Canada ECAN - Man. 1-(204) 945-4888 ECAN - Sask. 1-800-667-7525 DFO Department of Fisheries and Oceans Environmental Emergencies 1-800-889-8852 navigable waters only Navigable Waters Protection Branch NEB/TSB National Energy Board & NEB Regulated Lines Only - NEB Emergency Line 1-800-632-1663 Transportation Safety Board Transportation Safety Board Incident Reporting 24hr. (819) 997-7887

Reportable Spill Volumes For TDG Controlled Substances TDG Act 1992; Transportation of Dangerous Goods Clear Language Regulations 2002 ITEM CLASS DIVISION QUANTITIES OR LEVELS 1 1 Explosives Any quantity that could pose a danger to public safety or 50 kg 2 2.1 Flammable Gases 3 2.2 Non-Flammable, Non-Toxic 4 2.3 Toxic Gases 6 3 Flammable Liquids At least 200 L (44 Gallons) 7 4 Flammable solids At least 25 kg (55.12 lbs) 8 5.1 Oxidizing substances At least 50kg or 50L (110.2 lbs) Any quantity that could pose a danger to public safety or any sustained release of 10 minutes or more 9 5.2 Organic Peroxides At least 1 kg (2.2 lbs) or 1 L (0.22 Gallons) 10 6.1 Poisonous Substances At least 5 kg (11.02 lbs) or 5 L (1.10 Gallons) 11 6.2 Infectious Substances Any quantity that could pose a danger to public safety 12 7 Radioactive Materials (as per section 20 of the Packaging and Transport of Nuclear Substances Regulations) 1) Any quantity that could pose a danger to public safety; 2) packages transported under exclusive use - any discharge or a radiation level exceeding 10 msv/h external surface, 2 msv/h on surface of conveyance, 0.1 msv/h at a distance of 2 m from surface of conveyance; 3) packages not being transported under exclusive use 0.1 msv/h at a distance of 1 m from package, 2 msv/h on surface of conveyance, 0.1 msv/h at a distance of 2 m from surface of conveyance. 13 8 Corrosive Substances At least 5 kg (11.02 lbs) or 5 L (1.10 Gallons) 14 9 Miscellaneous Products, Substances or Organisms At least 25 kg (55.12 lbs) or 25 L * Additional B.C. Reporting Requirements as per Waste Management Act Spill Reporting Regulation 166/93 (Items above listed in B.C. s Spill Reporting Schedule are reflected above as per new Federal Clear Language TDG Regulations) 17 Waste asbestos as defined in section 1 of the Special 50 kg Waste Regulation. 18 Waste oil as defined in section 1 of the Special Waste 100 L Regulation. 19 Waste containing a pest control product as defined in 5 kg section 1 of the Special Waste Regulation. 20 A substance not covered by items 1 to 19 that can cause 200 kg pollution. 21 Natural Gas 10 kg, if there is a breakage in a pipeline or fitting operated above 100 psi that results in a sudden and uncontrolled release of natural gas.

7.0 EMERGENCY PREPAREDNESS 7.1 OVERVIEW Although proper hazard assessment procedures will identify and address most worksite hazards, some unanticipated emergencies must be planned for. The primary objectives of emergency preparedness preparations are: to save lives, implement protective actions, and restore operations. Supervisors are responsible for ensuring that emergency response requirements for their area are identified and addressed. Emergency Response Plans Harvard s mandate and commitment is to conduct all business in a competent and safe manner. Harvard believes that although the likelihood of an emergency situation occurring is low, the potential certainly exists. Therefore Harvard has developed both a Corporate Emergency Response Plan and site or job-specific plans. Emergency Response Plans must be developed to provide a seamless response structure and built from an implementer s perspective. They also outline the responsibilities of both Company and contract personnel, as well as government agencies should an emergency incident occur. Corporate ERP All Company operations will be covered under a Corporate ERP. The Corporate ERP gives general guidelines of what to do, who to notify, and how to plan for and manage an emergency. Higher risk worksites such as: sour facilities, densely populated areas, drilling, or remote locations may require higher levels of emergency response planning and site specific ERP s. Harvard s Corporate Emergency Response Plan defines the major categories of an emergency, which are: Serious injury or fatality; Incidents, including automobile incidents that result in or could result in a serious injury or loss of life; Plant, pipeline, facility, or other explosion; Well blow-out or other emergencies related to drilling or service rig operations; Major fire, or incidents where damage has occurred or threatens Company and/or public property; Uncontrolled spill of product or chemicals; Telephone threat, explosion, bomb threat, hostage taking, or ransom; and Natural disasters including but not limited to flooding and tornados. The Corporate Emergency response Plan contains telephone numbers of key Corporation personnel and appropriate provincial regulatory agencies to contact in times of emergency. Regulatory Requirements In accordance with Alberta OH&S Code Part 7, Emergency Preparedness and Response, the following applies in relation to the development and maintenance of an ERP. OPX Consulting Inc. Section 7-1

An employer must establish an emergency response plan for responding to an emergency that may require rescue or evacuation. The employer must involve affected workers to ensure the emergency response plan is current, and lastly, provide training and emergency simulation exercises in keeping with sections 115 (1-3) and 117(3). In accordance with Canadian Standards Association CAN/CSA-Z731 employers are required to develop, maintain and implement their ERP in accordance with the requirements of the aforementioned Standard. ERCB Directive 071 (revised April 8, 2008) states that when a site-specific ERP is not required, a corporate level ERP is used by the license to handle emergency events. 1) All licensees must have a corporate-level ERP with preplanned procedures that will aid in effective response to handle emergency events. Licensees are expected to determine the level of detail required to address each item in a corporate level ERP, depending on the nature of the operations that the plan covers. 2) As a minimum, the licensee must include information in its ERP on a) key licensee contacts including 24 hour numbers b) classing incidents and response actions for specified incidents, c) a communications plan that address communications with response team, support services, and government, communications with the public and media and downgrading emergency levels, Responsibilities of licensee personnel and Incident management centers. 3) The licensee must include the following in the corporate level ERP: The Assessment Matrix for Classifying Incidents (see Directive 71 Appendix 5) As a minimum, the actions outlined in Responses for Specified Incidents (see Directive 71 Appendix 5) 4) The licensee must define appropriate actions including protection measures that would be taken for each level of emergency. The following sections of Directive 071 should be consulted for: 1) Corporate Level ERP s - Part A Section 2-4 & Part B Section 11-13 2) Sour Well Site-Specific Drilling/Completions ERPs - Part A Section 3-6 & Part B Section 12-15 3) Sour Operations ERPs - Part A Section 3-5, 7 & Part B Section 12-14 4) ERP s for High Vapour Pressure Pipelines - Part A Section 3-5, 8 & Part B Section 12-14 5) ERP s for Cavern Storage Facilities Storing HVP Product - Part A Section 3-5, 9 & Part B Section 12-14 6) Spill Cooperative Response Plans - Part A Section 10 & Part B Section 16 OPX Consulting Inc. Section 7-2

Note: The reader is advised that the above references are for the Province of Alberta only. Reference material for British Columbia can be found with BC-Oil and Gas Conservation Regulation, BC Oil and Gas Handbook, BC Pipeline Act and Regulation, BC Drilling Regulations. For Saskatchewan, the only reference identified is the CAN/CSA Z731. OPX Consulting Inc. Section 7-3

8.0 WORK PROCEDURES Detailed work procedures for critical tasks are important to both management and workers. In each jurisdiction, the Occupational Health and Safety Regulations require that safe work procedures be developed and implemented where work to be performed constitutes a hazard to the worker. Most importantly, work procedures set guidelines for operating performance and provide reference for training. Job Safety Analysis (JSA) and Observation Job Safety Analysis (JSA) and observation help to eliminate hazards before they cause problems. Supervisors must regularly observe the work site and work practices to assess the safety of operations and determine where improvements are needed. The key to successful work procedures is to continually encourage safe and efficient work practices. Shortcuts which compromise safety are unacceptable. The following HARVARD Codes of Practice and Work Procedures are included in this section to help guide supervisors in maintaining safe working conditions at the work site: 8.1 Codes of Practice 8.1.1 Asbestos 8.1.4 Release of Harmful Substance 8.1.2 Benzene 8.1.5 Respiratory Protective Equipment 8.1.3 Confined Space Entry 8.1.6 Sour Service 8.2 Work Procedures 8.2.1 Air Craft Awareness 8.2.22 Hot Oiling 8.2.2 All Terrain Vehicles (ATVs) 8.2.23 Hot Taps 8.2.3 Blowdowns 8.2.24 Hot Work Procedures 8.2.4 Cables, Chains And Ropes 8.2.25 Housekeeping 8.2.5 Chemical & Biological Hazards 8.2.26 Hydrate / Ice Plug Handling 8.2.6 Communication Equipment 8.2.27 Managing Control of Hazardous Energy 8.2.7 Compressed Gas Cylinders 8.2.28 Naturally Occurring Radioactive Materials (NORM) 8.2.8 Cranes And Hoisting Devices 8.2.29 Noise Exposure 8.2.9 Critical Lift Procedure 8.2.30 Pigging Guidelines 8.2.10 Crown Savers 8.2.31 Portable Pumping Equipment 8.2.11 Driving Conduct 8.2.32 Purging 8.2.12 Fall Protection 8.2.33 Rig Anchors 8.2.13 Fire Prevention 8.2.34 Safe Work Permits 8.2.14 Fire & Explosion Hazard Management 8.2.35 Tank Truck Loading Procedures For Flammable Fluids 8.2.15 Flammable & Hazardous Liquid 8.2.36 Timber Removal 8.2.16 Flowbacks 8.2.37 Trailers & Bunkhouses 8.2.17 Fuel And Chemical Storage 8.2.38 Trenching 8.2.18 Ground Disturbances 8.2.39 Vehicle, Mobile Equipment & Machinery 8.2.19 Hand And Power Tools 8.2.40 Welding & Burning 8.2.20 Heaters & Open Flame 8.2.41 Wildlife Awareness Equipment 8.2.21 High Pressure Gas Wells 8.2.42 Working Alone 8.2.43 Working Near Overhead Powerlines OPX Consulting Inc. Section 8-1

8.1 CODES OF PRACTICE 8.1.1 ASBESTOS Code of Practice SCOPE AND PURPOSE Outline type and uses of asbestos Identify health hazards Identification and control Removal TYPES AND USES Asbestos is the name given to a group of naturally occurring silicate mineral fibres. The three most common forms are: Chrysotile (White Asbestos) o Most common o Insulating pipes, boilers, furnaces Amosite (Brown Asbestos) o Sprayed coatings o Insulating (as above) o In Cement Products Crocidolite (Blue Asbestos) o No longer used (was used very rarely in past) USES INCLUDE Roof tiles, floor tiles, wallboard, brake shoes, clutch plates, gaskets NOTE: Most insulation used before 1975 was asbestos or asbestos based. HEALTH HAZARD Primary hazard of asbestos results from breathing asbestos fibres. Three principle diseases associated with asbestos are: o Asbestosis is a chronic lung disease resulting from prolonged exposure to asbestos dust. The fibres gradually cause the lungs to become scarred and stiff, resulting in increased breathing difficulty. o Lung Cancer may be caused by asbestos fibres in the lung. The exact way in which asbestos causes lung cancer is not fully known. The combination of smoking and inhaling asbestos fibres greatly increases the risk. o Mesothelioma is a rare but very malignant form of cancer affecting the lining of the chest or abdominal cavity. OPX Consulting Inc. Section 8-2

IDENTIFICATION Four step process: 1. Visual Inspection o Check drawings and blueprints o Exposed asbestos may be soft or hard o Check under physical barriers: gyproc, plywood, metal sheeting, paint NOTE: Asbestos that is encapsulated behind a barrier or sealed poses very little risk to the worker, unless it is disturbed. 2. Collect Sample(s) o Identification coupons (samples) should be taken as deep as possible as other types of insulation may have been put over top of asbestos insulation. o See attached procedure 3. Sample Analysis o Use only experienced specially equipped laboratories (contact the Calgary Office for the list). 4. Inventory o Indicate on drawings and blueprints o Establish an asbestos log book. Record areas, removal and disposal o Identify area with placard: CAUTION: INSULATION CONTAINS ASBESTOS FIBRES DO NOT DISTURB or use label system similar to WHMIS Identification. ASBESTOS REMOVAL General Information All projects of moderate to high risk removal require government notification (see OH&S Regulations). Transportation of asbestos waste must follow TDG regulations: o Manifests required o Placards in place if over 550 kilograms A. Low Risk Definition o No more than 2 workers are required o Volumes to be removed will fit into Glove Bag o Task is no longer than one shift o Worker can be protected by PPE o No power tools are used OPX Consulting Inc. Section 8-3

Removal: o Glove Bag (see attached procedure) B. Moderate to High Risk Definition o More than 2 workers are required o Area to be removed is large than Glove Bag method can accommodate o Power tools are used o Task lasts more than one day o Medical surveillance of workers required by provincial regulations o Disposal is, or can be, a problem Removal o If one or more of the above conditions are present, removal by an approved Removal and Abatement Contract is required. Contact the provincial government for a list of approved contractors. (Contractors must meet standards of Partnerships Program and be able to supply references). OPX Consulting Inc. Section 8-4

ASBESTOS REMOVAL VIA GLOVE BAG AREA: INCIDENT POTENTIAL Major LIKELIHOOD High Serious Minor Moderate Low SCOPE AND PURPOSE: Remove asbestos from piping up to 16 in diameter and 10 in length using glove bags and no power tools. POTENTIAL HAZARDS: Breathing asbestos dust PPE REQUIRED: Rubber gloves (disposable) Rubber boots Respirator with asbestos cartridge Disposable hooded coveralls EQUIPMENT REQUIRED: Glove bag(s) 6 ml (suitable size) Scraping blades, wire brush Tin snips or wire cutters Wetting agent with detergent Coating or sealant for sealing raw edges Disposal bag (6 ml), duct tape, bucket of detergent water, barricades of warning signs TRAINING: Review provincial regulations ACTS, REGULATIONS AND STANDARDS: Review provincial regulations OPX Consulting Inc. Section 8-5

Issue work permit ASBESTOS REMOVAL VIA GLOVE BAG Erect barricades or signs Signs to State: ASBESTOS WORK IN PROGRESS Put on PPE Put all equipment in glove bag Fasten glove bag to pipe Remove cladding, lay in bottom of glove bag Wet pipe and clean with scraper and brushes Bag may be moved along pipe at this point Seal any exposed insulation with sealant Put all equipment into one glove Remove glove bag and seal Pull glove with equipment inside out, cut off and seal with duct tape Place glove with equipment under water and clean Remove coveralls, cut off glove, respirator cartridge and glove bag in 6ml disposal bag Label disposal bag Label to state: CONTAINS ASBESTOS CANCER HAZARD, AVOID BREATHING DUST Wash face, hands and respirator face piece Dispose of all bags in approved land fill Contact Calgary Head Office OPX Consulting Inc. Section 8-6

ASBESTOS BULK SAMPLE COLLECTION AREA: INCIDENT POTENTIAL: Major LIKELIHOOD: High Serious Minor Moderate Low SCOPE AND PURPOSE: Steps to collect bulk samples POTENTIAL HAZARDS: Breathing asbestos dust Clothing contamination PPE REQUIRED: Rubber gloves (disposable) Respirator with asbestos cartridge (if doing more than one sample) Disposable hooded coveralls (if doing more than one sample) EQUIPMENT REQUIRED: Coating and sealant Glass jar with screw top lid Ziploc plastic bag(s) Utility knife Spray bottle with detergent water Duct tape TRAINING: Review provincial regulations Work permit (if more than one sample taken) ACTS, REGULATIONS AND STANDARDS: Review provincial regulations OPX Consulting Inc. Section 8-7

ASBESTOS BULK SAMPLE COLLECTION Remove cladding sample size (approximately 1 ) Wet down insulation with water Collect sample in jar or Ziploc bag Seal cut area (use sealant and duct tape) Label sample contained with location Label to state and date: DANGER, CONTAINS ASBESTOS FIBRES AVOID BREATHING Remove gloves, coveralls and respirators (if used) and dispose of in 6ml plastic bag (landfill trash) Wash tools, face and hands Send sample to approved laboratory Contact Calgary Head Office 8.1.2 BENZENE Code of Practice This code of practice is intended to provide guidance and information to workers at facilities likely to come into contact with fluids containing Benzene. Potential Hazards Benzene and the associated compounds, Toluene, Ethylbenzene and Xylene (BTEX) have an anesthetic effect and primarily attack the central nervous system. Prolonged exposure to Benzene concentrations of 100 ppm will have adverse consequences. Benzene is most commonly taken into the body through inhalation of vapour but can be taken in to a far lesser extent, by absorption through the skin. Inhaled Benzene vapours are eliminated from the body by the lungs when the victim is taken into fresh air. BTEX compounds are normally found as liquids in gas condensates and Crude Oil streams. If liquid hydrocarbon streams at gas plants show that concentrations of Benzene exceed the 0.1% level and are in the range of 0.5% to 1.5%, extra caution must be taken. Normally, condensate is stored and transported in a closed system of vessels, lines and OPX Consulting Inc. Section 8-8

pumps, but workers can be exposed when those systems are opened for maintenance. Benzene has also been found as a vapour at the vents of dehydrators at levels of 50 ppm, which can be a concern if there is prolonged exposure to those vapours. Occupational Exposure Limits The current Occupational Exposure Limit (OEL) for Benzene in: Alberta 0.5 ppm average for 8 hours, 2.5 ppm for 15 minutes. BC - 0.5 ppm average for 8 hours, 2.5 ppm for 15 minutes Benzene is a skin sensitizer, known carcinogen and an ALARA substance meaning that all exposures must be kept As Low As Reasonably Achievable. Employer Responsibility Surveys will be conducted to identify all steams at facilities where Benzene is likely to be present at significant levels; All tasks and activities will be studied to determine where exposure to condensate could occur. This will include all routine job s, such as process surveillance and sampling, as well as occasional tasks, such as routine preventative maintenance and component replacement; When tasks are identified where worker exposure could occur, procedures will be developed to control that exposure. This will involve the provision of suitable workplace ventilation and or use of appropriate personal protective equipment (PPE); Workers who may have to work in an area where exposure to Benzene containing streams could occur will be given training in controlling Benzene exposure; and Workers shall attend information sessions on the health hazards associated with Benzene and participate in training with required PPE. Worker Responsibility Workers must be aware that respiratory protective equipment on its own will not fully protect a worker; Workers must be aware of which streams contain Benzene and the potential for exposure involved with specified tasks, and must follow all written and verbal instructions; and\ These responsibilities are incumbent on contractors employees as well as company employees. OPX Consulting Inc. Section 8-9

Site Specific Procedures Each facility shall develop site-specific procedures to cover its own operations; These procedures must identify streams where Benzene is present, list routine operational or maintenance jobs involving those streams, and specify measures to be taken to prevent worker exposure; and The procedures must allow for action at 25% of the OEL or Critical Limit, to ensure that over exposure does not occur. Caution: This program does not represent a complete guideline to the subject area, consult your supervisor before continuing. 8.1.3 CONFINED SPACE ENTRY Code of Practice This code of practice is intended to provide assistance in the recognition, evaluation and control of potentially dangerous or unhealthy atmospheres in confined spaces that could lead to illness, injury, death or property loss. Where confined space work is to be performed by workers, responsibility for safety, both at the time of entry and during the entire operation rests with the employers on-site supervisor. The work to be performed shall be under the direction of a competent supervisor who is knowledgeable of the hazards that may be encountered, accident prevention requirements and rescue measures. All workers performing the work in the confined space shall, before entry, be informed of the hazards they may encounter, precautionary measures required and rescue measures and methods required. AREA: INCIDENT POTENTIAL: Major LIKELIHOOD: High Serious Minor Moderate Low SCOPE AND PURPOSE: Detailed site/job specific procedures must be developed identifying key aspects of this task such as: Isolation points Energy Isolation Requirements Venting procedures Site-specific hazards OPX Consulting Inc. Section 8-10

POTENTIAL HAZARDS: Physical hazards mixers, trays etc. Chemical hazards (sludge, scale) H 2 S Gas Explosive atmosphere Oxygen deficient atmosphere PPE REQUIRED: SCBA/SABA Fire retardant clothing H 2 S monitor Oxygen analyzer Explosive meter Safety harness and other rescue equipment Head, eye, face, hand, foot and body protection as indicated by hazards EQUIPMENT REQUIRED: Blanks/blinds or equipment for other acceptable methods of isolation Water, steam, or nitrogen where purging is necessary Vacuum truck Catch pan Hand tools Energy isolating devices TRAINING: Safety Orientation (ie: task, handbook, etc.) Confined space entry/rescues H 2 S WHMIS ACTS, REGULATIONS AND STANDARDS: HARVARD HS&E Handbook Work Permit Applicable provincial OH&S regulations PROCEDURE/ACTION: General: Work permits must be issued and discussed with the workers each day. Other topics to be discussed with workers include: o At Operating Facilities any alarms that may occur and their meaning. o MSDS sheets of any chemicals that may be encountered. OPX Consulting Inc. Section 8-11

The method of worker rescue must be planned and discussed prior to vessel entry. Additional safety equipment (tripod) that may be necessary to effect a rescue must be in place before a confined space entry occurs. Ensure unauthorized personnel and vehicles are kept out of the area. Caution exercised and atmosphere testing should be carried out in enclosed areas around the confined space (e.g. inside dikes around tanks). Proper bonding and grounding procedures must be followed and explosion proof electrical equipment used where necessary. No person shall walk on a tank roof unless there is a proper walkway or is wearing a safety belt and line. Preparation: Confined space must be depressurized and/or fluid levels pumped as low as possible. All inlet and outlet lines will be isolated by the use of blanks/blinds or an approved alternate method (listed in the CAPP Petroleum Industry Guideline for Entry into Confined Space) that provides an equal level of safety. Breathing apparatus may be necessary to perform these functions. All hazardous energy sources to the confined space shall be secured by an energy-isolating device. Where purging is necessary to prevent the development of hazardous atmospheres in the confined space, water, steam or nitrogen may be used. Caution must be exercised with any exhaust vapours. Ventilation: The confined space will be thoroughly ventilated, preferably by a positive method of mechanical ventilation. If ventilation requires opening manways or clean out doors then a catch pan and possibly a vacuum truck should be available to control and take away the flow of liquids/sludge coming out of the confined space. Ventilation should continue throughout the project. Inerting: The introduction of an unreactive gas such as nitrogen into a confined space may be required to displace all oxygen. Inerting may need to be considered where it is very difficult to control ignition sources in a confined space. The inerting creates an oxygen deficient atmosphere and workers entering this environment must be properly trained and equipped with self-contained breathing apparatus or supplied air breathing apparatus with escape bottle. Refer to work procedure on Purging for additional information. OPX Consulting Inc. Section 8-12

Initial Entry: All atmospheres that have not been tested should be considered dangerous to life and health. Initial testing for H 2 S, LEL and oxygen can be taken in the exhaust air. If the exhaust air is considered safe, (above 19.5% oxygen, below 20% LEL and less than 10 ppm H 2 S CAPP guideline) a qualified worker wearing breathing apparatus and other appropriate PPE may now enter to do further testing of all areas of the confined space. Disturbance of any sludge that is present in the confined space may result in the release of hydrocarbon gases. This may result in the development of a toxic, flammable or an oxygen deficient atmosphere. All efforts should be made to remove the sludge prior to a confined space entry or when this is not possible, a breathing apparatus must be worn at all times. Ensuing Entries: The work should be performed from the outside as much as possible. If the atmosphere tests safe as stated above, workers wearing the appropriate PPE may enter the confined space. Caution must also be exercised to address any physical hazards (mixers, blades, etc.) in the space. Where an ignition source is to be introduced into the confined space, combustible gas testing must confirm that the atmosphere is and remains at 0% LEL (CAPP Guideline). Monitoring should take place from upon each entry to ensure a contaminant has not unpredictably re-entered the confined space, if work is suspended for a significant period of time, or if Hot Work is to be carried out. A stand-by/safety watch must be in place at all times while a worker is in a confined space. This person must be knowledgeable of the confined space rescue plan and be in communication with the person in the confined space. He must also be available to call for additional help in the event of an emergency. Consideration should also be given to having additional stand-by men if more than one worker is in the confined space. Waste Disposal: All wastes generated during the cleaning process should be properly managed including: manifested, characterization, classification and disposal. Consult the facility Waste Management Wall Chart or contact HARVARD s Calgary Office for assistance in classifying and manifesting the waste. OPX Consulting Inc. Section 8-13

Job Completion: A thorough inspection must be conducted to ensure that no workers, tools or equipment has been left behind. Ensure all blanks/blinds or other isolating devices are removed and valves are returned to their correct positions. When returning the confined space back into service, caution must be exercised to avoid the possibility of an ignition source being introduced to a flammable atmosphere (nitrogen purge or controlled flow rate). Return the work permit to the responsible supervisor. 8.1.4 RELEASE OF HARMFUL SUBSTANCE Code of Practice Purpose In accordance with regulatory agencies this Code of Practice is intended to provide guidance on the steps to be taken to prevent an uncontrolled release and, should such an event occur, the steps to mitigate its harmful effects. Prevention In order to prevent an uncontrolled release, the following procedures apply: The design of new facilities will comply with appropriate codes and accepted industry engineering practices; Equipment will be operated within the design limits as required by the manufacturer; Regular inspection of piping and vessels will be conducted to ensure equipment integrity; When building new facilities or maintaining or upgrading existing ones, suitable materials will be selected to contain the hazardous substances under the conditions of temperature, pressure, and corrosiveness normally expected; Workers will demonstrate competence in maintenance procedures and operation of equipment, prior to working independently; and Equipment will be maintained and not allowed to continue to operate outside its prescribed tolerances. Controlled Release There may be times in our operations when quantities of H 2 S (or other hazardous substances) will be released during the course of normal operation and maintenance activities. These releases are considered controlled releases because they are anticipated and planned for. Systems and procedures shall be in place to control the amount released so that workers and the public are not at risk. OPX Consulting Inc. Section 8-14

Many controlled releases must also be reported or approved. Uncontrolled Release Occasionally there are unplanned events in the movement or storage of substances. Where this occurs, company and contract personnel will: Protect people; Take action to control the effect on the environment; Not enter the area where the release has occurred unless equipped with appropriate personal protection; Initiate controlled shut down of affected equipment when failure to do that would present greater risks; Isolate and contain the release; Document and report all occurrences in a proper manner to the appropriate authorities; and Investigate the occurrence to determine root cause, so as to prevent future occurrences. 8.1.5 RESPIRATORY PROTECTIVE EQUIPMENT Code of Practice 8.1.5.1 SELECTION, MAINTENANCE AND USE OF RESPIRATORY PROTECTIVE EQUIPMENT In accordance with occupational health and safety regulations, HARVARD S Code of Practice for the Selection, Maintenance and Use of Respiratory Protective Equipment is outlined as follows: 1. Selection and Use of Air Purifying and Atmosphere Supplying Respirators The overall requirements to be considered when selecting respiratory protective equipment are summarized in Figure 1. A work sheet to assist with the selection of equipment is provided together with more detailed information regarding common petroleum industry hazards and the most appropriate equipment for that hazard. 2. Fit Testing Requirements and Procedures The requirements and procedures for fit testing respiratory equipment. 3. Inspection of Air Purifying and Atmosphere Supplying Respirators The requirements and procedures for properly inspecting respiratory equipment. OPX Consulting Inc. Section 8-15

4. Cleaning and Storage of Respiratory Protective Equipment The requirements and procedures for properly cleaning and storing respiratory equipment. 5. Training of Workers The requirements for proper training of workers using respiratory equipment. In addition, commonly used definitions relating to the use of respiratory equipment are summarized in this Code of Practice. OPX Consulting Inc. Section 8-16

Figure 1: SELECTION OF RESPIRATORY PROTECTIVE EQUIPMENT HAZARD Toxic Contaminant Oxygen Deficiency Non-IDLH (Not immediately dangerous to life or health) IDLH (Immediately dangerous to life or health) Contaminant exceeds Occupational Exposure Limits (Consult Provincial Chemical Regulations) Gas or Vapour Particulate Gas or Vapour and Particulate Chemical Cartridge Respirator Gas Mask Powered Air-Purifying Respirator Filter Respirator Combination Cartridge Plus Filter Respirator Gas Mask SCBA (Self-Contained Breathing Apparatus) SABA (Supplied Air Breathing Apparatus with escape provision) OPX Consulting Inc. Section 8-17

RESPIRATORY PROTECTIVE EQUIPMENT WORKSHEET AREA: LOCATION: HAZARD: Particulate (dust) Gas Vapour Mist Fume Combination Oxygen Deficiency NOTE: Review MSDS and Provincial Regulations for toxic limits. WORKER EXPOSURE Short Term (minutes, hours) Long Term (hours) RESPIRATOR Type Model Training Available Air Capacity (time) Expiry Date (cartridge type filters) Manufacturer/Supplier Information OPX Consulting Inc. Section 8-18

RESPIRATORY HAZARDS ASSOCIATED WITH PETROLEUM INDUSTRY HAZARD Ammonia Asbestos Biological (low levels) Chemical Fumes Chlorine Heavy Metals Hydrogen Sulphide (H 2 S) TYPE OF PROTECTION RECOMMENDED Self Contained Breathing Apparatus (SCBA) or Supplied Air Breathing Apparatus (SABA) P100 or HEPA Filter (asbestos approved), Powered Air Purifying Respirator (PAPR), full or half mask respirator P100 or HEPA Filter (ie: sewage lagoons, Hanta Virus) Chemical Cartridge (specific to components of Chemical involved) or SCBA SCBA or SABA P100 filter and metal-specific cartridge combination SCBA or SABA Hydrocarbon Vapours: 1. Painting Combination P100 filter / organic chemical cartridge (spray painting disposable type, brush reusable, solvents/organic vapours - chemical cartridge) 2. General Chemical Cartridge (organic vapours), protection against low level concentration hydrocarbons (ie: benzene) 3. Process Areas SCBA or SABA used in case of leak, equipment failure or turn-around. Nuisance Dusts P100 or HEPA filter (disposable) Nuisance Odours Chemical cartridge filter (typically organic, disposable) Oxygen Deficiency SCBA or SABA Radioactive (NORM) P100 filter (disposable, preferably half or full face mask) Sandblasting (Major Operation) Total body-encapsulated suit with SCBA or SABA Silica P100 or HEPA filter (disposable, preferably half or full face mask) Sulphur Dioxide (SO 2 ) Welding Fumes Chemical cartridge or SCBA Combination P100 or HEPA filter and chemical cartridge (disposal or half mask) OPX Consulting Inc. Section 8-19

AIR-PURIFYING RESPIRATORS SELECTION & USE TYPE OF DEVICE USED FOR LENGTH OF SERVICE Mechanical Filter Use for airborne aerosols, 1. Filters, cartridges or disposable including all dusts, mists, metal respirators may be used until fumes, smoke. breathing resistance increases to an uncomfortable level. 2. Disposable units should be discarded after each use. 3. Filters and cartridges may be used in successive days, until breathing resistance indicates replacement is necessary. Chemical Cartridge Use for low concentrations of organic vapours and gases, alkaline and acid gases, mercury vapours, pesticides, paint vapours or any combination of the above 1. Cartridges can be used until the odour of the contaminant can be smelled, irritation occurs, or the substance can be tasted by the wearer. 2. Cartridges must not be used after the expiration date printed on the label (control inventory). PRECAUTIONS FOR USE & SELECTION 1. Not for use in IDLH atmospheres. 2. Not for use in oxygen deficient atmosphere. 3. High-efficiency filter cartridge must be used if wearer is exposed to highly toxic particulate matter (e.g. asbestos) 4. A combination chemical cartridge filter mask must be used if particulate contaminant and gases and vapour contaminant are present. 5. Full face-piece must be worn where eye irritation is possible. 6. Consult manufacturer or supplier for proper unit. 1. Not for use in IDLH atmosphere. 2. Not for use in oxygen deficient atmosphere. 3. Must not be used in environments where odour or irritation is not easily detected or not reliable stopped by the cartridge. 4. Not for use where the odour threshold is above the recommended OEL. 5. Full face-piece must be worn where eye irritation is possible. 6. Consult manufacturer and/or supplier for proper unit. STYLES AVAILABLE 1. Quarter mask with single filter. 2. Half mask with twin filters. 3. Full face-piece with single or double filters. 4. Disposable 1. Half mask with twin cartridges. 2. Full face-piece with twin cartridges. OPX Consulting Inc. Section 8-20

TYPE OF DEVICE USED FOR LENGTH OF SERVICE Gas Masks Use for relatively high 1. Canisters can be used until: concentrations of organic vapours - indicator changes colour or gases, alkaline and acid gases, - contaminant is detected by pesticides, paint vapours and wearers: smell, taste or mists, and radioactive particulate irritation - breathing resistance develops 2. Never re-use a used canister 3. Never use an outdated canister. Check expiry date on label (inventory control) Self-Contained Breathing Apparatus (SCBA) oxygen-deficient environment area containing multiple hazards confined space (providing egress and mobility allow for use of unit) environment may be subject to rapid change environment where superheated air may be present 1. Unit can be worn until low-air warning bell advises wearer to exit area. 2. Cylinder capacity determines length of wearing times (30 to 60 minutes). 3. Hydrostatic testing of cylinders: Steel - every 5 years Fibreglass wrapped aluminum - every 3 years. Testing to be done by approved supplier. PRECAUTIONS FOR USE & SELECTION 1. Gas masks may be used for escape from IDLH atmosphere, but never for re-entry into such atmospheres. 2. Not for use in oxygen deficient atmospheres. 3. Additional precautions same as above for chemical cartridge respirators. 1. Weight of unit may reduce work time. 2. Air supply may be reduced depending on individual task being done. 3. Wearer may be claustrophobic (test before sending wearer into environment). 4. Ensure all units within area are from the same manufacturer. 5. Positive-pressure only should be used. STYLES AVAILABLE 1. Chin type canister with full face-piece. 2. Canister type with full face-piece connected to face-piece with hose. 1. Half face-piece (should not be used in our industry). 2. Full face-piece. OPX Consulting Inc. Section 8-21

TYPE OF DEVICE USED FOR LENGTH OF SERVICE Supplied Air Breathing Apparatus (SABA) Same as above (SCBA) Where extended periods of work are required Confined space where - there is limited mobility - egress is difficult and/or time consuming 1. Select most appropriate air supply: a) single cylinder: 210 cu. ft, about 6 hrs for/man b) cascade system supply dependent upon number of cylinders c) compressor air supply unlimited PRECAUTIONS FOR USE & SELECTION 1. Not for use in: a) long distance separation (over 300 ft between wearer and source) b) areas where air-line could sustain mechanical/ chemical damage c) areas where air-line may entrap worker d) areas where the compressor intake may pick up contaminants (if used) 2. Specification for breathing air hose: a) max length: 300 ft b) min diameter: ¼" (6mm) c) min working pressure: 250 psi (1725 KPa) d) connections installed by a approved installer 3. Positive pressure only should be used STYLES AVAILABLE 1. Same as above OPX Consulting Inc. Section 8-22

8.1.5.2 FIT TESTING REQUIREMENTS AND PROCEDURES FOR RESPIRATORY PROTECTION SAFETY PROGRAM MANUAL Persons who are or may be required to wear respiratory protection equipment must be clean shaven where the facepiece seals with the skin to ensure an effective facial seal. Every time a respirator is used, one of the following tests should be included: A. Negative Pressure Fit Test B. Positive Pressure Fit Test During fit testing, the face-piece head straps should be as comfortable as possible. A. NEGATIVE PRESSURE FIT TEST To conduct a negative pressure fit test: Put on a respirator (should be comfortable) Close off inlet with the palm of your hand; or shut off air supply on SCBA/SABA s Inhale so that face-piece collapses slightly Hold breath for about 10 seconds Fit is considered adequate if: Face-piece remains slightly collapsed No inward leakage is detected B. POSITIVE PRESSURE FIT TEST Note: This test may be difficult or impossible to carry out on valveless respirators. To conduct a positive pressure fit test: Put on respirator (should feel comfortable) Close off exhalation valve Exhale gently into face-piece Fit is considered adequate if: A slight positive pressure builds-up in face-piece No outward leakage is detected OPX Consulting Inc. Section 8-23

8.1.5.3 INSPECTION OF AIR PURIFYING RESPIRATORS AND ATMOSPHERE SUPPLYING RESPIRATORS 1. Before and after each use, inspect for: SAFETY PROGRAM MANUAL Excess dirt Cracks, tears, holes or physical distortion of shape from improper storage Inflexibility of rubber face-piece (stretch and knead to restore flexibility) Cracked or scratched lens in full face-piece Incorrectly mounted full face-piece lenses Broken or missing mounting clips Cracked or broken air-purifying element holders, badly worn threads, or missing gaskets (if required) Nose cap 2. Examine the head straps or head harness for: Breaks Loss of elasticity Broken or malfunctioning buckles and attachments Excessive worn serration on head harness which might permit slippage (full face-piece only) 3. Examine the exhalation valve for the following (after removing its cover) Foreign materials such as detergent residue, dust particles, or human hair under the valve seat Cracks, tears, or distortion in the valve material Improper insertion of the valve body in the face-piece Cracks, chips or breaks in the valve body, particularly in the sealing surface Missing or defective valve cover Improper installation of the valve in the valve body 4. Check and examine: Regulator Gauges Hoses Connections Cylinder for condition and hydrostatic test date OPX Consulting Inc. Section 8-24

5. Examine the air-purifying element for: Correct cartridge, canister or filter for the hazard Incorrect installation, loose connections, missing or worn gasket or cross-threading in the holder Expired shelf-life date on cartridge or canister Cracks or dents in the outside case of filter cartridge or canister (indicated by absence of sealing material, tape, foil, etc. over the inlet) 6. If device has a corrugated breathing tube, examine it for: Broken or missing connections Missing or loose hose clamps Deterioration (determined by stretching the tube and looking for cracks) 7. Examine the harness of a front or back mounted gas mask for: Damage or wear to the canister holder (which may prevent its being held in place) Broken harness straps for fastening 8. Miscellaneous Condition of carrying cases and boxes Note: Use of Authorized Parts only is permitted. Check with supplier as to when service must be conducted by trained personnel. 8.1.5.4 CLEANING AND STORAGE OF RESPIRATORY PROTECTIVE EQUIPMENT 1. All types of respirators should be cleaned and disinfected after each use and stored in a clean, sealable container. This is particularly important if not individually assigned Remove filters, cartridges or canisters on APR s Disassemble face-pieces, removing speaking diaphragms and any valves or valve assemblies Wash all components in 122ºF (55ºC) Drain components Where cleaner does not contain a sanitizing agent, the components should be immersed for 2 minutes in a solution of 9 parts water to 1 part laundry bleach Rinse components as above ensuring all sanitizing agent is rinsed away Drain OPX Consulting Inc. Section 8-25

Hand dry all components with clean lint-free cloth or air-dry Reassemble face-piece, install filters, canisters, or cartridges where necessary Watch shelf-life date Store in appropriate area 2. Respiratory protection equipment should be sorted to protect against: Dust Direct sunlight Excessive heat Extreme cold Excessive moisture Damaging chemicals 3. Respirators placed in work areas should be stored in clearly marked containers which are quickly accessible at all times. 4. Respirators stored in lockers or tool boxes should be protected from contamination, distortion and damage. 5. Breathing air compressors should be turned on for 20 minutes every week to reduce contaminant buildup and tested semi-annually by accredited laboratory. 8.1.5.5 TRAINING OF WORKERS IN THE SELECTION, USE, CARE AND MAINTENANCE OF RESPIRATORY PROTECTION EQUIPMENT All employees who may be required to use respiratory protection equipment must be trained in: Selection of protection equipment (including MSDS training) Care and maintenance Use Supervisors must: Receive the same training as employees Monitor the selection, care and use of all respiratory protection equipment OPX Consulting Inc. Section 8-26

On-the-Job Training As a minimum, OTJ training should include: The nature, extent and effects of respiratory hazards the wearer may be exposed to The operation, limitations and capabilities of the selected respirator Inspecting, wearing, fit testing, maintaining and storing respirators Emergency situations using different respirators Training Resources: Suppliers and Manufacturers Outside consultants Other experienced workers Other companies studies and reports 8.1.5.6 DEFINITIONS RESPIRATORY HAZARDS Confined/Restricted Space: As defined by the regulatory authority. Examples include: storage tanks, process vessels, boilers, silos, tank cars, pipelines, tubes, ducts, sewers, underground utility vaults, tunnels and PITS. All confined spaces are considered IDLH unless proven otherwise. Dust: Solid, mechanically produced particles or fibres. Exposure Limited (EL): A permissible exposure limit to airborne contaminants as defined by the regulatory authority. Also know as Occupational Exposure Limit (OEL). Fume: Solid particles generated by condensation from the gaseous state, generally after volatization from melted substances (e.g. welding) and often accompanied by a chemical reaction such as oxidation. Gas: A substance that is in the gaseous state at ambient temperature and pressure. Hazardous Atmosphere: Any atmosphere that is oxygendeficient or that contains an air-borne toxin or diseaseproducing contaminant in concentrations exceeding the exposure limit. High-Efficiency Particulate Air Filter (HEPA): A filter that has been tested to assure an efficiency equal to or exceeding 99.97% for removal of particles having a mean aerodynamic diameter of 0.3 um from the air. OPX Consulting Inc. Section 8-27

Immediately Dangerous to Life or Health (IDLH): A condition in any worksite, space, or area where a hazardous atmosphere exists to such an extent that a person without appropriate respiratory protection could be fatally injured or suffer immediate, irreversible or incapacitating health effects. Lower Explosive Limited (LEL): The lower limit of flammability of gas, vapour, or dust, or any combination of these at ambient temperatures. For gases and vapours, this is expressed as a percentage in air by volume. For dusts, this is expressed as weight of dust per volume of air. Mist: Liquid particles in a gaseous medium. Oxygen Deficiency: As defined by the regulatory authority for physiological effects. For certain respirators, refer to the minimum oxygen concentration where such devices may be utilized. Particulate: Includes air-borne dust, fumes or mist. Respirator: A device designed to protect the wearer from inhaling a hazardous atmosphere. SCBA: Self-Contained Breathing Apparatus SABA: Supplied Air Breathing Apparatus Vapour: The gaseous state of a substance that is solid or liquid at ambient temperature and pressure. 8.1.6 SOUR SERVICE Code of Practice APPLICATION AND SCOPE A facility is considered sour at 10 ppm H 2 S. If workers can be exposed to H 2 S levels exceeding 10 ppm, Occupational Health and Safety Regulations require: Detection: To determine the level of H 2 S in a work area, either a continuous or personal monitor is to be used. In addition, oil and gas regulations require poisonous gas warning signs to be posted at all wells and facilities when the potential H 2 S content is 10 ppm or greater. Note: Wells and facilities with a H 2 S content less than 10 ppm must have a flammable gas/liquid warning sign. OPX Consulting Inc. Section 8-28

Training: Workers are to be provided H 2 S training. Employers are required to develop and communicate safe work policies for sour operations. Protection: When H 2 S is present in an area, either an approved supplied air or self-contained breathing apparatus must be worn when OH&S maximum time exposures are exceeded. These are: H 2 S Concentration Maximum Time Exposure 10 ppm 8 Hours 15 ppm 15 Minutes / Ceiling HARVARD s safe work guideline for working in sour production areas are as follows: 1. H 2 S Monitoring: H 2 S detection must be used to monitor the work environment in areas where the potential of exposure to H 2 S levels above 10 ppm exists. Detection equipment can be either continuous or personal monitors. Personal H 2 S monitors shall be worn at all times by full time personnel. Contractors shall wear H 2 S monitors as directed by HARVARD representative and/or their work permit. Known danger areas must be clearly posted in accordance with Occupational Health and Safety requirements. 2. Normal Routine Operations Normal routine operations in sour production areas may be performed by an operator working alone subject to the following restrictions: a. When entering sour locations, employees are to ensure that: H 2 S monitoring equipment is turned on and used at all times when on location. Communication equipment is in good working order. A breathing apparatus in good working order with an adequate supply of air must be available. b. Caution should be taken before entering any building that does not have a permanent H 2 S monitor. Ventilation may be required. c. Workers should not enter dike areas and tank gauging should only be done using external gauges unless breathing apparatus is worn. OPX Consulting Inc. Section 8-29

d. A site specific operating procedure may be developed for completing a routine operation where sour product may be released but the potential for H 2 S levels to exceed occupational exposure limits is known to be minimal. A backup man is not needed in these situations. e. If an H 2 S monitor alarms at any time while a worker is entering or working at a location, all workers are to immediately retreat to a safe area. Report conditions at the site to the appropriate HARVARD representative. 3. Operations when H 2 S Levels Exceed Occupational Exposure Limits a. No employee shall work alone in an area where the measured atmospheric H 2 S levels exceed occupational exposure limits. The appropriate HARVARD representative must be notified immediately and suitable precautions taken before work is continued. b. Under no circumstances is a worker to don a breathing apparatus to repair an uncontrolled release without a back-up man present. The back-up man must also be equipped with a breathing apparatus. c. When completing any operation and the release of gas is expected to expose a worker to H 2 S levels that exceed the occupational exposure limits, a breathing apparatus is required. A back-up man is required in these situations. d. For any job requiring the use of a breathing apparatus, the foreman or supervisor will determine deployment of workers taking into account the scope of the job, H 2 S exposure levels and the availability of required safety equipment and work procedures, including the need of a back-up man. H 2 S GENERAL INFORMATION All personnel (company and contract) working in H 2 S areas shall have a valid H 2 S Alive Certificate and shall be made aware of site specific procedures where applicable. The 8-hr time weighted average Threshold Limited Value (TLV.- TWA) or Occupational Exposure Limit (O.E.L.) for Hydrogen Sulphide Gas is 10 ppm. These are generally accepted as the maximum limit to which nearly all unprotected workers may be exposed for eight hours, five days/week without adverse health effects or the concentration that is immediately dangerous to life and health, whichever is lower. The maximum exposure limit (TLV/OEL Ceiling concentration) for Hydrogen Sulphide is recommended at 15 ppm. No worker should be exposed to concentrations at or above the ceiling limit. OPX Consulting Inc. Section 8-30

Hydrogen sulphide gas, H 2 S, an acid gas that is sometimes present in natural gas, is the most dangerous poisonous gas encountered in our operations. In low concentration, it has a high characteristic odor of rotten eggs and a sweet taste. In higher concentrations, the sense of smell is quickly paralyzed. Smell, therefore, must NEVER be relied upon to indicate the amount of H 2 S present. Hydrogen sulphide may be present in natural gas produced alone or in combination with crude oil. Concentrations may be from the faintest odour to a percentage that will result in sudden death. Accordingly, wherever H 2 S is present, respiratory protection is of extreme importance. Hydrogen sulphide is heavier than air, having a specific gravity of 1.189, with respect to air which is 1.0, so heavier concentrations will be found at ground or lower levels, such as cellars, open ditches and natural topographical low spots. Hydrogen sulphide is highly flammable and has an explosive range of 4.3% to 46% volume in air. When H 2 S is known to be present in natural gas or crude oil, all products are handled in systems designated to confine and, when necessary, dispose of the gas in a safe manner. When, through accident, leakage or necessary opening of a closed system, H 2 S becomes present in the atmosphere, employees present shall wear positive pressure breathing apparatus protection and take such other precautions as required. If your eyes become irritated or you notice a halo around an electric light while working in a plant or are which has being determined to be safe from H 2 S, take the following precautions: o Leave the location at once. o Wash your eyes thoroughly with water. o Wear positive pressure supplied air breathing apparatus with a full face piece if it is deemed necessary to re-enter the area. Since the result of exposure to H 2 S is paralysis of the nerves controlling respiration; persons stops breathing and lose consciousness quickly. If the victim is promptly removed from the exposure and artificial respiration is started immediately, the chances of complete recovery are good. Any delay in the start of artificial respiration appreciably reduces the change of recovery. Even though the chances of recovery may seem slim, artificial respiration should be continued until normal breathing is resumed. Cardiopulmonary Resuscitation (CPR) may be required if the heart has stopped. OPX Consulting Inc. Section 8-31

Any persons overcome by hydrogen sulphide must be taken to a hospital for observation after recovery. Hydrogen sulphide reacts with iron and steel to form iron sulphide. Iron sulphide reacts with air to form iron oxide. The conversion of iron sulphide to iron oxide creates heat sufficient to ignite flammable vapours. 8.2 WORK PROCEDURES 8.2.1 AIRCRAFT SAFETY AWARENESS The purpose of this section is to ensure employee and contractor personnel are not subjected to unnecessary risk during the use of charter or other aircraft, the following guidelines have been adopted from several insurance industry sources, and are applicable to all employees and contract personnel utilizing fixed wing, helicopter, charter, or other aircraft. Standard Safety Briefing The standard safety briefing shall consist of an oral briefing provided by a crew member or by audio-visual means, and includes the following information as applicable to the aircraft, equipment, and operation: o Embarking and disembarking procedures; o No smoking in or around any aircraft; o When, where, why, and how carry-on baggage is required to be stowed; o The fastening, unfastening, tightening, and general use of safety belts or safety harnesses; o The location of emergency exists, exit location signs, and how each exit operates; o The location, purpose of, and advisability of reading the craft specific safety features card; o The requirement to obey crew instructions; o The use, location, operation, and deployment, as applicable, of emergency equipment such as life rafts, life preservers, fire extinguisher, ELT (Emergency Locator Transponder), survival equipment, and first aid kit including means of access to any locked compartment; o Where applicable, the method of egress from a wide body helicopter in the event of a roll-over incident; and o Any special instructions related to emergency evacuation if the craft is configured with external devices. Where no additional passengers have boarded the flight for subsequent takeoffs on the same day, the pre-take-off and after take-off briefing may be omitted provided a crew member has verified that all carry-on baggage is properly stowed, safety belts or harnesses are properly fastened, and seat back and chair table are properly secured. OPX Consulting Inc. Section 8-32

Note: This is not a complete guide for aircraft safety, please consult the pilot and/or your supervisor for additional information. Helicopter Safe Approach Area Diagram OPX Consulting Inc. Section 8-33

8.2.2 ALL TERRAIN VEHICLES (ATVs) All company employees and contractors that are required to use an All- Terrain Vehicle (ATV, snowmobile and/or ARGO) must be competent operators regarding the type of equipment they are using. HARVARD Site Supervisor will identify training requirements, but regardless all drivers, as a minimum, must review the manufacturer s guidelines for safe operation. Workers who do not have a working level of knowledge and skill are recommended to take a hands-on training course, provided by a certified and reputable trainer. In general, all ATV riders must: Wear the appropriate PPE, including: CSA-approved helmet Eye protection (safety glasses, face shield and/or goggles) Sturdy footwear Work gloves Long-sleeved shirt and pants Hearing protection (recommended) Reflective vest and/or safety flags Drive the ATV in accordance with local regulations, Possess a valid driver s license for insurance purposes, implement the required procedures and carry appropriate equipment, including: Working alone/check-in procedure Head lights and tail lights on First Aid Kit (remote areas) Operator s manual Survival Kit (remote areas) Communication device and a GPS (when working in remote areas) *Optional equipment may include an axe, gas line anti-freeze, spark plugs, winch, bear deterrents, fire extinguisher. Properly maintain their ATV (servicing, pre-ride inspection in accordance with manufacturer s guidelines see ATV Checklist). When riding an ATV, all riders are expected to scan the area, identify hazards, predict what will happen, decide what to do, and execute the decision. All ATV riders must adjust their driving attitudes to the surrounding conditions, where unfamiliarity and adverse weather conditions require a more cautious approach in operations. Formal hazard assessments are required when traversing slopes with a potentially dangerous grade. If an ATV rider does not feel comfortable in their ability to complete a task, they should inform their supervisor immediately. OPX Consulting Inc. Section 8-34

ATV CHECKLIST Satisfactory S Unsatisfactory U Not Applicable N/A Location (LSD): Description of ATV activities (brief): Date (yy/mm/dd): ATV Activities Personnel Using ATV Name: Make: Model: Pre-Use Inspection S U N/A S U N/A Walk-Around Lights and Switches General ATV Condition Ignition switch in good condition Tires, wheels, or tracks in good condition Stop switch works Brake controls operate smoothly Headlights work Throttle and other cables move smoothly Tail lights work and snap closed Winch works (if equipped) Engine No leaks on drive shaft Oil and Fuel Nuts and bolts securely fastened Adequate oil level Adequate gasoline level Personal Protective Equipment Proper fuelling area Helmet worn Proper fuel storage Safety glasses/eye protection worn Proper fuel transport Wearing work boots Gloves available Hearing protection available Tools and Equipment Clothing fully covering legs and arms First aid kit Reflective Vest and/or Safety Flags Survival kit (for remote surveys) Communication system (for remote surveys satellite phone) Trailer (if equipped) Ensure securely mounted to ATV Map and GPS (for remote surveys) Tires in good condition Fire Extinguisher (fully charged) Signature: Comments Site Supervisor s Name (print) OPX Consulting Inc. Section 8-35

8.2.3 BLOWDOWNS SCOPE AND PURPOSE To provide safe procedures for conducting blowdowns. Blowdowns include operations to: 1. Depressurizing wells for the purpose of unloading accumulated liquids. 2. Depressurizing pipelines and other facilities for the purpose of working on them and for removing hydrates and other plugging substances. For the purpose of this work procedure, it is assumed that all fluids recovered from the well or facility are sweet and the facility is designed as a typical sweet gas wellsite facility with separator of dehydrator and buried blowdown tank. If sour fluids are expected refer to applicable safe work procedures for sour fluids. Refer to Industry Recommended Practice for Well Testing and Fluid Handling IRP Vol. 4. BLOWING DOWN WELLS The following steps should be taken when a well is to be blown down to unload liquids. In most cases a buried blowdown tank is provided as a permanent facility. A block valve will be located in the flowline, downstream of the blowdown line. A wellhead choke may also be provided. 1. Shut the well in by closing the block valve in the flowline downstream of the blowdown line. 2. If it is necessary to build up reservoir energy to facilitate the lifting of liquids, leave the well shut in for sufficient time to build up pressure. The necessity to blow down a well is usually characterized by low tubing pressure and high casing pressure (if the well does not have a packer). Blowdown is usually done from the tubing as that is the way the well is normally produced. 3. Check and record the shut-in wellhead pressure(s). 4. Check fluid level in the blowdown tank to ensure there is room for the anticipated volume of liquid to be recovered. 5. Check the blowdown tank vent line to ensure that it is unrestricted. 6. Check to ensure there are no potential sources of ignition within 25 meters of the blowdown tank vent line. If there are vehicles on location, ensure they are parked upwind. OPX Consulting Inc. Section 8-36

7. Slowly open the block valve on the blowdown line to avoid pressure shocking the blowdown tank and avoid blowing liquids out the vent line. If the wellhead is equipped with a choke, the choke should be used to slowly open the well to the blowdown tank. 8. Continuously monitor the blowdown until it is felt that all or sufficient liquids have been recovered. 9. Close the choke at the wellhead (if one is provided) and then the block valve on the blowdown line. 10. Check and record shut-in wellhead pressure(s). 11. Slowly open the block valve in the flowline downstream of the blowdown line and then open the wellhead choke (if provided) to return the well to production. Note: If blowdown cannot be done upstream of meter run, then ensure orifice plate is removed before blowdown. Once blowdown is completed, re-install the orifice plate. BLOWING DOWN PIPELINE SEGMENTS The following procedure should be used when depressurizing pipelines to remove hydrates or other obstructions. In all cases where hydrates are suspected, the line must be depressurized on both sides of the hydrate. Refer to safe working procedures for detecting and removing hydrates. 1. If Hot Tapping is required, refer to appropriate safe work procedures for hot tapping and ensure that competent and suitably trained personnel are available to perform the hot tapping operation. 2. If liquid recovery is anticipated during the blowdown, appropriate containment must be planned for. 3. Slowly open the bleeder valve to avoid a surge of fluids to the containment tank. 4. When all line pressure has depleted and there is no further flow, close the bleeder valve. 8.2.4 CABLES, CHAINS AND ROPES The following precautions should be taken when working with ropes: Inspect ropes before using. Look for abrasions in rope fibers. Untwist the rope in several places. If black or rusty brown spots are noticed, they may indicate chemical burns. OPX Consulting Inc. Section 8-37

Do not take chances. Notify the immediate supervisor if in doubt as to the condition of any rope. Inspect all chains, hooks and cables before using and do not use if worn or frayed. Also inspect cables for kinks before use. Return defective equipment to the approved repair shop and notify your immediate supervisor. 8.2.5 CHEMICAL & BIOLOGICAL HAZARDS There are a variety of chemical hazards (ie: benzene, solvents, heavy metals, lead, diesel exhaust), biological hazards (ie: micro-organisms in sewage, toxic mould, hanta virus), and harmful substances (ie: asbestos, silica, nuisance dusts) that may be present on the work site. Proper and documented work practices for handling, storage, transport, and disposal of these substances are required to minimize both worker and public exposure. The route of exposure (inhalation, ingestion or skin absorption), duration of exposure (8 hours, short-term or long-term), and effect of more than one substance, all factor into the total affect on the worker. Airborne concentration measurements obtained by a competent worker should be related to allowable limits to determine potential impacts. Common hazards that require controls include: 8.2.5.1 ASBESTOS HARVARD has developed an asbestos management plan, located in detail in 8.1.1 of this manual. All employees and contractors involved with handling of asbestos should be familiar with this code. Contact the area supervisor to determine if there is asbestos in the area facilities that you are working. 8.2.5.2 BENZENE Benzene is found naturally in many geological formations and therefore may be found at HARVARD production facilities. A Code of Practice regarding Benzene can be located in section 8.1.2 of this manual. 8.2.5.3 HANTA VIRUS Hanta Virus is a flu-like illness, which can be contracted from inhaling air contaminated from saliva, droppings and dried urine of rodents (ie: deer mice). Avoid inhalation of contaminated air or direct contact with contaminated areas by: Ventilating closed buildings or areas before start of cleaning; Cleaning up droppings by first wetting down the area with a solution of five parts water to one part bleach. Do not use a broom or vacuum; use a damp rag for clean-ups; Disposing of dead animals and droppings in a twist-tied plastic bag using disposable rubber or plastic gloves. OPX Consulting Inc. Section 8-38

Control rodent infestation by: 8.2.5.4 SEWAGE SAFETY PROGRAM MANUAL Sealing holes that are larger than 0.5 cm around buildings; Clearing brush/grass from around foundations; Storing food in containers with tight lids; Elevating garbage cans or use well-fitting lids; Using spring-loaded mouse traps continuously in infested areas; Using rodenticide approved for exterior use in covered bait stations. Proper site drainage and storage of biological wastes is important for both health implications and reduction of environmental impacts. Septic tanks should be stored away from the primary residence area and be routinely cleaned out. Proper PPE should be worn during this process. 8.2.6 COMMUNICATION EQUIPMENT All electronic devices such as cell phones, pagers, and mobile phones must be intrinsically safe if they are to be used in a potentially explosive environment. 8.2.7 COMPRESSED GAS CYLINDERS All cylinders shall be returned promptly to a storage area after use. They shall not be permitted to lay about the Work Site. Protective caps shall be placed over the cylinder valves when not in use or when being transported by any means. Cylinders shall be stored in the upright position and secured to some stationary object or structure and handled in accordance with Provincial Occupational Health and Safety and/or Workers Compensation Board Regulations. 8.2.8 CRANES AND HOISTING DEVICES Cranes and hoisting devices are to be operated only by trained and experienced personnel. Additionally, the crane operator is to work with an experienced signaler. All lifting devices must have the rated load capacity marked on the equipment as per manufacturer s specifications; If a lifting device is not commercially manufactured it must be certified by an engineer; OPX Consulting Inc. Section 8-39

An employer must ensure that a lift calculation is completed for any lift exceeding 75 percent of a crane s rated capacity. Mobile cranes equipped with outriggers must be set up with the outriggers on load-bearing floats or pads that are adequate in size, strength and rigidity. Workers should ensure they keep themselves from under loads being hauled by cranes. The operator must keep the load as close to the ground as possible. In working near electrical power lines ensure the crane operator keeps a safe distance. OH&S regulations require that a log for each lifting device be kept and readily available with equipment information, maintenance and inspection records. The log book requirement does not apply to manually operated hoists. Cranes and hoists must be inspected and maintained as per manufacturer recommendations. 8.2.9 CRITICAL LIFTS SCOPE This section includes guidelines and requirements applicable to critical lifts and describes the planning and documentation required to perform a critical lift. Critical lift permit is required. REFERENCES 29 CFR 1926, SUBPART N ANSI/ASME B-30.7 SERIES RESPONSIBILITIES RESPONSIBILITIES Management Make determinations of critical lifts Provide supervisor and employee training Provide safe and proper equipment for critical lifts Provide inspection procedures Supervisors Follow guidelines and inspection procedures Supervise all critical lifts Ensure employees have adequate operational knowledge and experience Immediately remove from service any equipment that fails inspection OPX Consulting Inc. Section 8-40

Employees Follow lifting and rigging procedures Immediately report any problems with equipment Not attempt any critical lifts unless authorized and approved CRITICAL LIFT DETERMINATION The decision to designate a lift as a critical lift is a management decision. Guidelines provided here are intended to aid in making that decision. A lift should be designated as a critical lift if dropping, upset or collision could cause or result in any one of the following: 1. Damage that would result in serious economic consequences. 2. Damage that would result in unacceptable delay to schedule or other significant deleterious programmatic impact (such as loss of vital data) 3. Undetectable damage that would jeopardize future operations or safety of a facility. 4. Significant release of radioactive or other hazardous material to the environment or creation of an undesirable condition. 5. Personnel injury or significant adverse health impact, either onsite or offsite. 6. In addition, a lift that meets one of the following criteria shall be designated as a critical lift: Any lift that requires the use of multiple cranes Any lift that exceeds exceptional 80% of the crane s rated capacity within the lift configuration of the crane. The item to be lifted requires exceptional care in handling because of size, weight, close-tolerance installation, high susceptibility to damage or other unusual factor. The item, although non-critical, requires exceptional care in handling because it is being lifted above a critical item. The manager who has the responsibility for the item being lifted has the authority to require that it be handled as a critical lift. In addition, the manager at the facility where the lift will be performed also has the authority to require that it be handled as a critical lift. The manager who designates the lift as a critical lift shall ensure that a person-in-charge (PIC) is assigned. (The PIC need not be in the manager s organization). CRITICAL LIFT PROCEDURES The PIC shall ensure that a step-by-step procedure is prepared for critical lifts. Although individual procedures are prepares for one-time critical lifts, general procedures may be employed to accomplish routine recurrent critical lifts, For example, a general procedure may be used to lift an item or series of similar items that are frequently lifted or repeatedly handled in the same manner. A critical lift procedure should contain the following, as applicable. Identify the items to be moved OPX Consulting Inc. Section 8-41

Special precautions, if any (such as outrigger or track cribbing for mobile cranes) Weight of the item and total weight of the load (For mobile cranes, see the manufacturers instructions regarding components and attachments that must be considered as part of the load). Centre of gravity location A list of each piece of equipment (e.g. Crane, hoist, fork truck), accessory, and rigging component (e.g., slings, shackles, spreader bars, yokes) to be used for the lift. (This list shall identify each piece of equipment by type and rated capacity). Designated checkpoints and hold points and estimated instrument readings, as relevant, so that job progress can be checked against the plan. NOTE: Sign off s in the procedure are generally appropriate. For example, initials and time/date the procedures as key steps are completed. Hold points or sign-off points should be provided for personnel assigned to witness the work. Rigging sketch(s), which include the following: Lift point identification Method(s) of attachment. Load vectors Sling angles Accessories used. Other factors affecting the equipment capacity. Rated capacity of equipment in the configuration(s) in which it will be used. (For mobile cranes, many factors affect rated capacity, including boom length, boom angle and work area). A load-path sketch that shows the load path and height at key points in the job. (For lifts with mobile cranes, include the crane position(s) relative to the load and relative to surrounding obstructions. Where appropriate, include floor-loading diagrams). A sketch indicating lifting and travel speed limitations. (This may be noted on the load path sketch or on a separate sketch). A sign-off sheet to verify that equipment and tackle inspections or tests are current. NOTE: Practice lifts are recommended. (If used, requirements for the practice lift should be documented in the procedure.) APPROVAL OF CRITICAL LIFTS The critical lift procedure should be approved as required by the responsible contractor s procedures. In the absence of direction from the OPX Consulting Inc. Section 8-42

contractor s procedures, a critical lift procedure shall be approved (signed and dated) by the following: Procedure author Manager of the lift operation Engineer in charge Safety department / Field safety consultant REVISIONS TO CRITICAL LIFT PROCEDURES Revisions to the procedure shall be reviewed and approved through the same cycle as the original procedure. PRE-LIFT MEETING Before the critical lift is performed, a pre-lift meeting with all participating personnel shall be held. During the meeting, the critical lift procedure shall be reviewed and questions shall be resolved. The pre-lift meeting shall be documented. DOCUMENTATION Critical lift documentation is required. When the job is finished, the PIC shall transmit the critical lift documentation to the manager (or designee) for whom the lift was done. This documentation is subject to audit for one year after the critical lift is completed. Documentation of a critical lift shall include the following: The critical lift procedure, recording job completion with approval signatures and hold point sign-offs. Documentation of the pre-lift meeting; containing, as a minimum, the meeting date and list of attendees (NOTE: it is recommended that documentation of the pre-lift meeting can be included as part of the critical lift procedure. Any additional documentation deemed appropriate by the PIC or other responsible personnel (e.g., lessons learned) 8.2.10 CROWN SAVERS This work procedure was developed to reflect HARVARD s practice that all contracted rigs have crown savers installed and are regularly function tested before operation of the rig is commenced. PROCEDURE 1. It is the Well Site Supervisor s responsibility as a representative of HARVARD to NOT approve the start of rig operations until the crown saver has been function tested. OPX Consulting Inc. Section 8-43

2. It is the rig contractor s responsibility to supply, install and function test crown savers in accordance with the rig manufacturer s design and specifications. 3. Subsequent function testing of crown saver equipment must be carried out at appropriate times. 8.2.11 DRIVING CONDUCT VEHICLE CHECK Keep vehicles in proper operating condition Ensure loads are secure at all times Large units should have mud flaps in place and be checked for rocks between wheels Walk around required BEFORE STARTING Ensure proper signage and documentation is in place ON THE ROAD Wearing seat belts is mandatory Drive with headlights and taillights on at all times to increase visibility Obey all traffic signs and speed limits Stay on the right side of the road on corners, crest of hills, and at intersections. Slow down when merging Yield extra road surface to larger traffic Watch for following cars, and pull over to the side when safe to let faster traffic pass Do not use cell phones and field radios while driving. Pull off to a safe spot to answer or make calls. Always try to back into parking spots. DRIVING IN POOR CONDITIONS Reduce speed when driving on poor roads or in visibility conditions. Do not pass in loose gravel, during poor visibility, or slippery road conditions. LICENSING AND MECHANICAL INSPECTION If a worker uses a personal vehicle for work purposes, an employer must ensure the worker complies with the appropriate licensed driver requirements of Provincial legislation. The worker must ensure their vehicle is maintained in sound mechanical condition. OPX Consulting Inc. Section 8-44

REFUELING Workers must not smoke within 7.5 metres of a vehicle when it is being refueled. Vehicles must not be refueled if there is an ignition source within 7.5 metres of the vehicle. Workers must not dispense flammable fuels into the fuel tank of a motor vehicle while the engine is running unless it is otherwise permissible by the manufacturer or certified by a professional engineer. 8.2.12 FALL PROTECTION Fall protection regulations require employers to prepare written procedures in a fall protection plan. This plan must be in place before work commences on any task where a fall of vertical 3 meters or more can occur and where workers are not protected by guardrails. The plan must also be in place if there is an unusual possibility of injury if a worker vertically falls less than 3 meters, such as falling into or onto a hazardous substance or object or through an opening in a work surface. The plan must include procedures for rescuing workers who have fallen but are unable to rescue themselves. In the event a plan is required, it must be available and reviewed with the workers prior to undertaking the task (See Fall Protection Plan Form at the end of this section.) The fall protection plan must specify the following: The potential fall hazards at the work site. The fall protection system to be used at the worksite. The anchors to be used during the work The clearance distances below the work area, if applicable, have been confirmed as to prevent the worker from striking the ground or an object at below the work area. The procedures to assemble, maintain, inspect, use and disassemble the fall protection system(s). Rescue procedures to be used if worker falls, is suspended by personal fall arrest system or safety net and needs to be rescued. The fall protection plan must be updated when conditions affecting fall protection change. Furthermore OH&S regulations state that employers must ensure that a worker at a permanent work area is protected from falling by a guardrail if they worker can fall a vertical distance of more than 1.2 metres and less than 3 metres). If it is not reasonable for guardrails to be in place then a worker must use a travel restraint system or other effective means to keep worker from falling. OPX Consulting Inc. Section 8-45

INSTRUCTION OF WORKERS An employer must ensure that all workers are trained in the safe use of the fall protection system before allowing the worker to work in an area where a fall protection system must be used. The training must include the following: Review of pertinent legislation pertaining to fall protection Understanding of what a fall protection plan is Fall protection methods a worker is required to use Identification of all hazards Assessment and selection of specific anchors that a worker may use Instructions for the use of connecting hardware Information on the effects of a fall on the human body Pre-use inspection Emergency response procedures to be used if necessary Practice in inspecting, fitting, connecting, adjusting etc. FALL PROTECTION EQUIPMENT There are many types of fall protection equipment, which are to be determined by the job type and work site. All protection equipment must meet CSA standards, be inspected prior to use for any damage or malfunction, and kept free from substances and conditions that could contribute to deterioration of the equipment. It should be noted that any fall arrest system equipment that has stopped a fall should be removed from service after the incident. A professional engineer or manufacturer must certify that the system is safe for continued use. Typical fall arrest equipment includes but is not limited to: Full body harness Body belt Lanyard must be made of wire rope or appropriate material for job and related hazards: o If a tool or corrosive agent could sever, abrade, or burn, ensure that lanyard material is able to withstand hazards. o If working in the area of an energized conductor, the employer must ensure worker uses another effective means of fall protection. Shock absorber, shock absorbing lanyard to be used in fall arrest system and consists of a full body harness and a lanyard equipped with a shock absorber or similar device. When a shock absorber is used, ensure that allowance is made for the potential increase in total fall distance. When a worker is using a personal fall arrest system without a shock absorber the employer must ensure the fall arrest system limits a worker s free fall distance to 1.2 metres. The connection components in the system include the following: o Carabineers OPX Consulting Inc. Section 8-46

o D-rings o O-rings o Oval rings o Self locking connectors o Snap hooks TRAVEL RESTRAINT SYSTEMS When using a personal travel restraint system a worker must limit the vertical distance of a fall by: Selecting the shortest length of lanyard that will still permit unimpeded performance of the duties. Securing the lanyard to an anchor no lower than the worker s shoulder, or if not available to an anchor point that is as high as reasonably practical. Using only a single lanyard between worker and anchor, with the exception of electrical danger noted above. Another important safety concern in fall arrest systems is limiting the amount of free fall which a worker may experience if a fall occurs. The personal Fall Arrest system must be arranged so that a worker cannot hit the ground or an object below the work area. Furthermore it must be ensured that the maximum arresting force exerted on the worker is 6 kilonewtons unless the worker is using an E6 type shock absorber in which case the maximum arresting force must not exceed 8 kilonewtons. ANCHORS If a worker is required to use a personal fall arrest system or travel restraint system the worker must ensure that it is safely secured to an anchor that meets CSA and ANSI standards. Any anchor with multiple attachment points designed to support combinations of suspension lines, tie-back lines and lifelines, is to be certified in writing by a professional engineer. An employer must ensure that a worker visually inspects anchors prior to attaching a fall protection system. If an anchor is damaged the worker must not reuse the anchor until it is repaired, replaced or re-certified by the manufacturer or a professional engineer. If a temporary travel restraint anchor point is to be used it must meet the following criteria: Have a minimum breaking strength in which the load may be applied of at least 3.5 kilonewtons per worker attached in any direction in which the load may be applied. Be installed, used and removed according to the manufacturer s specifications or specifications certified by a professional engineer. Be permanently marked as being for travel restraint only. OPX Consulting Inc. Section 8-47

The anchor must also be removed from use, immediately after the work involving the anchor point is complete or at the time specified by the manufacturer or a professional engineer. If a permanent travel restraint anchor is to be used, the following criteria must be met: The anchor must have a minimum breaking strength per worker of 16 kilonewtons or two times the maximum arresting force in any direction in which load may be applied (not applicable to anchors installed before July 1, 2009). Is installed and used according to the manufacturer s specifications or certified by a professional engineer. Is permanently marked as being for travel restraint only. WIRE ROPE SLING AS ANCHOR When a wire rope sling is used as an anchor it must be terminated at both ends with a Flemish eye splice rated to at least 90 percent of the wire rope s minimum breaking strength. FALL ARREST SYSTEMS Fall arrest anchors to which a personal fall arrest system is attached must meet the following guidelines, with the exception of temporary horizontal lifeline systems. Must have an ultimate load capacity of at least 16 kilonewtons per worker attached in any direction in which load may be applied. If structure to which an anchor is attached is not capable of withstanding 16 kilonewtons of force without damage; an anchor designed, installed and used as part of a fall protection system that is capable of withstanding twice the maximum arresting force that the anchor is subject to, may be used. The anchor is to be designed, installed and used in accordance with the manufacturer s specifications, or with specifications certified by a professional engineer. The anchor to which a personal fall arrest system is attached is not to be part of an anchor used to support or suspend a platform. Life Safety Ropes are one of the key components in fall arrest systems. There are a number of critical points in regards to life safety ropes which must be adhered to: Vertical lifeline must extend downward to within 1.2 meters of ground level or another safe lower surface. Vertical lifeline must be free of knots or splices except for a stopper knot at its lower end. OPX Consulting Inc. Section 8-48

Only one worker is to be attached to a life safety rope at any one time, unless the manufacturer s specifications or specifications of a certified engineer allow for the attachment of more than one worker. Any safety life rope must be effectively protected to prevent abrasion by sharp or rough edges. Be made of appropriate material to the hazard and able to withstand adverse effects. Is installed and used in a manner that minimizes the hazards of swinging and limits the swing drop distance to 1.2 metres if a worker falls. Before a horizontal lifeline systems is used a professional engineer, a competent person authorized by the professional engineer, the manufacturer, or a competent person authorized by the manufacturer must certify that the system has been properly installed according to the manufacturer s or professional engineer s specifications. All flexible and horizontal lifeline systems must meet the CSA requirements. Rigid and horizontal lifeline systems must be designed, installed and used in accordance with manufacturers or professional engineers certified specifications. CONTROL ZONES Control zones are marked areas in which an unguarded edge is present. Control zones may be used only if a worker can fall from a surface that has a slope of no more than 4 degrees towards the unguarded edge or that slopes inwardly away from an unguarded edge and is not less than 2 metres wide when measured from an unguarded edge. Control zones are not to be used to protect workers from falling from a skeletal structure in a work area. However, if the worker will at all times remain further from the unguarded edge than the width of the control zone, no other fall protection system is needed. Control zones are to be clearly marked with an effective raised warning line or other equally effective method if a worker is working within 2 meters of the control zone. If work must be done within the control zone then the use of a travel restraint system or equally effective means of preventing worker from getting to the unguarded edge is necessary. Also no persons who are not directly required to work in the control zone are permitted inside control zone. PROCEDURES IN PLACE OF FALL PROTECTION EQUIPMENT Procedures may be developed in place of fall protection equipment where it is not reasonable practicable to use an approved fall protection system or if the use of procedures in place of fall protection equipment is restricted to the installation or removal of fall protection equipment; roof inspection; emergency repairs, at height transfers between equipment and OPX Consulting Inc. Section 8-49

structures (if allowed by manufacturer s specifications) or in situations where a worker must work on top of a vehicle or load. When using procedures in place of fall protection equipment a hazard assessment must be completed before work at height begins. Additionally, the procedures to be followed while performing the work must be in writing and available to all workers before the work begins. The work must be carried out in a way that minimizes the number of workers exposed to a fall hazard. The work must be limited to light duty tasks and be completed by a competent worker and do not expose the worker to additional hazards. WORK POSITIONING If a worker uses a work positioning system, the worker s vertical free fall distance, in the event of a fall, is restricted by the work positioning system to 600 millimetres or less. If the centre of gravity of a worker using a work positioning system extends beyond the edge from which the worker could fall or if the work surface presents a slipping or tripping hazards because of its state or condition, the worker must use a back-up fall arrest system in combination with the work positioning system. A worker must use a back up personal fall arrest system in combination with the work positioning system if their centre of gravity extends beyond an edge from which the worker could fall or if the work surface presents a slipping or tripping hazard. SPECIAL PROCEDURES There are also a number of special protection procedures which must be followed while undertaking certain operations, they are as follows: Any worker on a boom elevating work platform, boom-supported aerial device or forklift truck work platform is required to use a personal fall restraint system. The fall arrest system must be connected to an anchor specified by the manufacturer of the work platform. If no anchor is specified by the manufacturer an anchor point must then be certified by a professional engineer that meets CSA requirements. A fall arrest system must be used when connected to the anchor, the lanyard, if reasonably practicable, is short enough to prevent the worker from being ejected from the work platform or aerial device but is long enough to allow the worker to perform their work. An employer must ensure that a worker on a scissor lift or an elevating work platform, with similar characteristics uses a travel restraint system consisting of a full body harness and lanyard connected to an anchor specified by the manufacturer and when connected to the anchor, the lanyard, if reasonable practicable, is sort enough to prevent the worker falling out of the scissor life or aerial work platform but is long enough to allow the worker to perform their work. OPX Consulting Inc. Section 8-50

Fork mounted work platforms elevated to a height of 3 meters or more above the ground, with any portion of the guardrail system removed, workers on platform must use a travel restraint system. This does not apply however, if the manufacturer s specifications allow a worker to work from the scissor lift or elevating work platform using only its guardrails for fall protection and if the scissor lift or elevated work platform is operating on a firm and level surface. If in any of above cases workers movement can not be adequately restricted in all directions to prevent a fall, then the use of a fall arrest system is mandatory. Anyone being raised or lowered in a man basket must use a personal fall arrest system. When working over water and the where the worker could drown by falling into the water, use of the appropriate fall protection equipment in conjunction with a personal floatation device must be used. A floatation device need not be worn if a fall protection system prevents a fall into the water. An employer using a leading edge fall protection system consisting of fabric or netting panels must ensure the system is only used to provide leading edge protection, is used and installed as per manufacturer s specifications and a copy of the specifications available on the worksite. Work or activities at height which incorporate a working line, safety line and a full body harness in combination with any other devices that allow a worker to ascend, descend and traverse to and from a work area under their own control is considered Industrial Rope Access Work. If scaffolding or a temporary work platform can be damaged by powered mobile equipment or a vehicle contacting it, measures must be taken to protect the scaffolding or temporary work platform from being contacted. Workers that have to climb onto a vehicle or its load at any location and where it is not reasonably practicable to provide a fall protection system the employer must take steps to eliminate or reduce the need for the for the worker to climb onto the vehicle or load. If the load is not secured against movement the worker must not climb onto the load. 8.2.13 FIRE PREVENTION Adequate ventilation must be provided for all rooms or buildings where gas or light oil products are handled. Special vacuum vents and flame arresters should be inspected frequently to determine that they are in good operating condition. Vegetation control must be present around tanks, buildings and wells. A sufficient area must be cleared to prevent the spread of fires. Spontaneous combustion may develop from oily rags. Rags must be placed in metal containers with self closing lids. OPX Consulting Inc. Section 8-51

Gas leaks shall be located only with a gas detector, soap suds or other safe means. If a gas leak is suspected or detected in any confined area, all motors, engines and sources of ignition shall be shut down immediately. DANGER: Leaks must never be located with an open flame. All building heating systems, offices, etc. are to be odorized ( Z662-94) The use of plastic pails or containers for flammable products are to be avoided. Barrels stored in buildings are to have bungs removed and capped. All gas regulators are to be vented outside and their doors kept closed. NO SMOKING signs shall be permanently posted in all hazardous areas. Flammable liquids shall be disposed of in a proper manner. Sewer, sump, or drain systems are not to be used for this purpose unless the system is specifically designed for this use.. Iron sulphide or lead sludge shall be removed from vessels etc. as quickly as practical and be kept wet with water until disposed of in a pit or fill site. Oils that cause sulphur deposits must be closely monitored at all times. Rags used to wipe zinc thread lubricant must be kept in a separate covered metal container. Static electricity shall be minimized or eliminated to prevent a spark from causing a fire, explosion, or both. Top fill lines on tanks should be avoided to reduce the chance of static discharges. If unavoidable, a downpipe shall be installed near the bottom of the tank and filling pipe bonded to the tank. Only equipment approved by Underwriters Laboratories for hazardous atmospheres are permitted for use in or around flammable vapours. This shall include all power tools, flashlights, electric lanterns etc. Attach Ground Cable signs shall be posted at all truck loading / unloading points. Truckers shall not carry out repairs to electrical wiring systems while engaged in loading or unloading fluids. 8.2.14 FIRE & EXPLOSION HAZARD MANAGEMENT To address regulatory requirements, HARVARD has established a systematic approach for identifying and managing fire and explosion hazards (see Fire and Explosion Prevention Form & Fire Prevention Triangle at the end of this section.) This process involves: Evaluating of potential risks with respect to fire and explosion hazards. Identifying means to effectively manage these potential risks. OPX Consulting Inc. Section 8-52

Determining the need for specific control measures to prevent fires and explosions. Putting the required control measures in place.. General Fire & Explosion Control Measures In hazardous locations, where an explosive atmosphere may exist, employers must ensure they use intrinsically safe equipment (i.e. lighting, cell phones, radios etc). Intrinsically safe equipment is defined as equipment and wiring which is incapable of releasing sufficient electrical or thermal energy under normal or abnormal conditions to cause ignition of a specific hazardous mixture in its most easily ignitable condition A person must not enter or work at an area if more than 20 percent of the lower explosive limit of a flammable or explosive substance is present in the atmosphere. A person must not smoke in a work area where a flammable substance is stored, handled, processed or used. A person must not use an open flame in a work area where a flammable substance is stored, handled, processed or used. A person should not mix, clean or use a flammable or combustible liquid at a temperature at or above its flash point in an open vessel if a potential source of ignition is in the immediate vicinity. A person should not use a flammable or combustible liquid at a temperature above its flash point in a washing or cleaning operation, unless the equipment is specifically designed and manufactured for the use of the liquid. A person must not store contaminated rags used to clean or wipe up flammable substances other than in a covered container that has a label that clearly indicates it is to be used for the storage of contaminated rags. Flammable substances stored or used at a non-hazardous work area must not be in sufficient quantity to produce an explosive atmosphere if inadvertently released. Flammable substances should not be stored within 30 metres of an underground shaft or in the immediate vicinity of the air intake of a ventilation supply system, an internal combustion engine or the fire box of a fired heater or furnace. Only CSA, NFPA and ULC approved containers can be used to store flammable substances. If work requires the contents of metallic or conductive containers be transferred from one to another, an employer must ensure static electricity is controlled while the contents are being transferred. In hazardous locations, employers must ensure that equipment used will not ignite a flammable substance and that static electricity is controlled. If a work area is considered hazardous, the boundaries of the hazardous location must be clearly identified to warn workers of the nature of the hazards and associated with the presence of the flammable substance. OPX Consulting Inc. Section 8-53

Procedures must be in place for hazardous locations that will prevent the inadvertent release of flammable substance or oxygen gas if it can contact a flammable substance. For further information concerning Fire & Explosion Hazard Management please refer to the Provincial Acts, Codes and Regulations 8.2.15 FLAMMABLE & HAZARDOUS LIQUIDS Flammable and hazardous liquid containers and storage tanks shall be labeled or identified and located in a safe place away from any open flame, fire or engines in operation. Where there is a potential for pressure build up or plastic container degradation, drums and small non-safety containers must not be left exposed to direct sunlight. Containers must be grounded when pouring flammable liquids in or out of them and containers must be of an approved type. Metallic or conductive containers and vessels used for flammable and combustible liquids must be bonded to one another and electrically grounded when pouring to prevent sparks and accidental ignition. Gasoline engines must be refueled only when engines are stopped. Safety cans must be used unless the tank is filled directly from the storage container via a piped system. Smoking is not permitted near gasoline storage area(s). A sign stating No Smoking or Open Flame must be posted at all storage areas. 8.2.16 FLOWBACKS SCOPE AND PURPOSE To provide safe operating practices for equipment, procedures and supervision of flowbacks from wells. This is intended to include all situations of flow from wells, including circulating, swabbing, fracture and chemical treatment cleanups, depressurizing, etc., but does not include production testing or drill stem testing. Reference: Alberta Industry Recommended Practice IRP Vol. 4, Subsection 4.0.7.20 SAFE OPERATING PRACTICES 1. An open fluid handling system should only be used when sweet, nonflammable fluids are being pumping or flowed back from a well. Sour and high-vapour pressure hydrocarbons must always be flowed back into closed systems. OPX Consulting Inc. Section 8-54

2. Prior to commencing a flowback of sweet, non-flammable fluids, planning must be done by the preparation of a detailed program of operations. The detailed program must state all pertinent well data, expected pressure and flow rates, fluid properties and characteristics, equipment requirements and layout, and identify all safety and environmental hazards. 3. As specified in IRP Vol. 4, consideration must be given to the following issues when preparing for a flowback: a. Wellhead control b. Expected produced fluids c. Equipment design and layout d. Procedures for special operations such as well killing, coiled tubing cleanouts using air, pumping flowbacks and swabbing. e. Supervision and monitoring during flowbacks for detection of sour fluids and explosive mixtures. f. Safety meetings and the use of safety checklist. 8.2.17 FUEL AND CHEMICAL STORAGE Above ground storage tanks, less than 5 m 3 do not require secondary containment unless the fluids could result in ground contamination problems. The following above ground storage tanks smaller than 5 m 3 should have secondary containment due to the potential for environmental damage: Glycols Amines Demulsifiers Corrosion inhibitors Solvents Fuel tanks Methanol tanks and tanks that are less than 5 m 3 do not normally require any secondary containment unless they: Are within 100 metres of a water course, or Have the potential for the contents to move off lease OPX Consulting Inc. Section 8-55

8.2.18 GROUND DISTURBANCE The potential consequence to individual workers and HARVARD for accidents involving ground disturbance work are very serious and therefore the appropriate time and resources must be allocated to ensure that the work is carried out safely. The following procedure should be followed in any ground disturbance operation (see definitions): Responsibilities as Owners of Pipeline 1. Provide information to persons undertaking a ground disturbance and ensure compliance to IRP 17. 2. Referencing all available sources of information as far as reasonable and practical to determine the existence of all pipeline and underground utilities in the proposed Ground Disturbance work area. The following are sources that can be referenced: Company Maps & Plot Plans Oil & Gas Regulators such as NEB, ERCB, etc. One-Call Systems Area Operations Personnel Land Titles Landowner Visible Markers Rural Gas Utilities 3. Locate the pipeline and mark the surface location using a qualified line locator. 4. Carry out inspections that are necessary to keep the pipeline safe. 5. HARVARD s Representative must be at the Work Site until the pipeline or utility has been exposed. 6. Inspect the pipeline before backfilling. 7. Report any damage. Supervision 1. A designated supervisor is responsible for ensuring that the work is carried out safely. This includes determining the existence of underground facilities and their proper locating and exposure. 2. A supervisor must ensure that proper markers are positioned around a ground disturbance to make workers aware. 3. The supervisor must have specific experience and training to supervise ground disturbance activities. 4. The supervisor must ensure that if workers are required to enter an excavation or trench the confined space entry code of practice has been reviewed and applied if necessary. As a minimum, a means of exit and entry must be provided for workers that are within 8 metres of any excavation greater than 1.5 metres in depth OPX Consulting Inc. Section 8-56

Search and Notification 1. Records must be searched for buried facilities within 30 metres of the proposed ground disturbance. 2. Owners or the owner s designate of a facility within the search area are to be informed of the intent to create a ground disturbance and asked to confirm the location, type, and content (as applicable) of their facility. Crossing Agreements and Approvals 1. Agreements are required if the ground disturbance is on a lease or right-of-way or within five metres of any facility. 2. The crossing agreement must be on site before starting the ground disturbance. Locating Facilities 1. All facilities within the 30 metre search area should be located and marked by competent personnel. Permits 1. A site-specific ground disturbance permit must be completed as part of the work permit for each crossing or disturbance within five metres of a located buried facility. Pre-Job Safety Meeting 1. A pre-job safety meeting must be conducted. Exposure 1. The facility owner may request to have a representative on-site during the exposure. 2. All hand exposed zones must be exposed 1 metre on each side of the locate marks for a buried facility other than a high pressure pipeline. High pressure pipelines must be hand exposed within 5 metres on each side of the locate marks, unless the entire excavation is hydrovac d to 15 cm below the ground disturbance depth. 3. Mechanical equipment within 60 cm of a buried line should not be used. 4. If contact with a pipeline occurs that damages the pipe, all work must stop until the necessary go-ahead is received. 5. Any damage must be reported immediately to the owner of the facility. 6. It is the facility owner s responsibility to notify the appropriate government agencies. OPX Consulting Inc. Section 8-57

Backfill 1. The line owner should inspect the crossings before and during burial. Some other excellent sources of information and guidelines regarding ground disturbances are: a. Underground Facilities pamphlet published by the Alberta Construction b. Safety Association. c. Safe Procedures for Pipelines and Utility Crossings booklet published by the Edmonton Area Pipeline and Utility Operator s Committee. 2. Backfill inspection form must be completed. 8.2.19 HAND AND POWER TOOLS Tools are to only be used for their intended function and must be maintained in good condition. Appropriate personal protective equipment must be worn at all times when using any tool. Operators are to inspect equipment and verify that it is in safe operating condition before starting work. The power must be disconnected from the tool and any pressure discharge before any adjustments are made. All guards are to be properly fitted and in good condition at all times. All portable and stationary grinding tools shall be operated in accordance with manufacturer s specifications and must be equipped with the appropriate guards and tool rests. Eye protection must be worn at all times when using hand operated power tools. 8.2.20 HEATERS & OPEN FLAME EQUIPMENT When lighting fired heaters and furnaces, face shields and gloves are to be worn. Portable heaters are to be used only for the service for which it has been approved and adequate ventilation should be maintained in order to prevent a build up of exhaust gases. All flammables are to be removed from the immediate area. Flame type equipment such as open flame space heaters (Herman Nelson) are to be used only in extenuating circumstances and then only in conjunction with a HARVARD Hot work Permit. OPX Consulting Inc. Section 8-58

8.2.21 HIGH PRESSURE GAS WELLS (EQUIPPING, START- UP AND OPERATION) SCOPE AND PURPOSE To provide safe operating guidelines for wellsite piping design, initial startup and production operations of sweet gas wells with higher reservoir pressure (maximum expected shut-in pressure) than the highest working pressure rating of downstream vessels and gathering lines. EQUIPPING For wellhead design and installation, refer to Industry Recommended Practices Minimum Wellhead Requirements, IRP Volume 5. In all situations where the maximum expected shut-in pressure of a well exceeds the lowest working pressure rating of downstream facilities, the wellhead will be equipped with a suitable adjustable choke for controlling flow rates, methanol injection pump, and emergency shutdown (ESD) valve and the wellsite vessel equipped with a suitable pressure safety valve (PSV). These components must be designed, installed and maintained in accordance with the appropriate API, ASME, and/or CSA standards for components and piping installations. STARTUP AND OPERATION When wells with shut-in pressure higher than the working pressure rating of any downstream vessel or pipeline are opened up from a shut-in condition, care and caution must be exercised to avoid pressure surges on the downstream facilities. The following procedure is recommended: 1. Fully open the master valve of the wellhead with the adjustable choke in the closed position. 2. Check and record shut-in wellhead pressures. 3. The adjustable choke should be opened gradually allowing the flow from the well to increase in stages to the desired rate. 4. The static pressure in the downstream vessel must be continuously monitored until conditions have stabilized at the desired pressure. 5. Frequent checks and recordings or pressures, temperatures and flow rates should be made during the first few days to ensure that conditions have stabilized, hydrate formation is not occurring and pressures are within normal operating limits. 6. Adjustable chokes, ESD valves and PSV s are to be serviced and tested according to prescribed methods. OPX Consulting Inc. Section 8-59

8.2.22 HOT OILING Field operations personnel shall follow the following procedure when hot oiling equipment (wells, flowlines, etc,). PROCEDURE COMPLETE THE HOT WORK PERMIT 1. Whenever possible, rig up hot oiler upwind and 50 meters from well, rig tanks, power lines, rig shacks, etc. (Note: if the hot oiler is equipped with a flame arrestor the unit may be rigged up as close as 25 meters from the well, etc.) Many leases do not allow 50 meters distance from the wellhead. Always try to maintain at least 25 meters from the wellhead. When rigging up, ensure at the point of entry (wellhead, etc.) there is a check valve with a bypass (for bleeding off) installed in the hot oiler s flowline. Note: Hot oiling should only be done using the metal pipe supplied on the hot oiler. The flexible, high pressure hose is only designed for cold pressure work. 2. The hot oil unit must be grounded at all times and if accompanied by a tank truck, it must be grounded to the hot oil unit before unloading/loading and located at least 15 meters away ( down wind) from the hot oil unit. 3. Ensure tank vapours are vented off down wind of the hot oil unit, This can be done by connecting a section(s) of suction hose to the tank vent. 4. Hold pre-job safety meeting. Communicate clearly to the hot oil unit operator what work is required. Maximum pressure, temperature and pump rate will be determined by the equipment being hot oiled. (Type of scraper rods are nylon, plastic, and metal. Pressure ratings of equipment.). Do not exceed the manufacturers recommended temperature. If H 2 S is present; define where all personnel are to proceed if a catastrophic leak/failure occurs. 5. Pressure test the hot oiler s lines to 1.5 times the anticipated maximum working pressure. Ensure the maximum operating pressure of the hot oiler s lines are not exceeded and the pop valves have been set accordingly. OPX Consulting Inc. Section 8-60

HOT OIL SAFETY EQUIPMENT REQUIREMENTS Hard hat, safety shoes, fire retardant clothing, goggles, gloves and H 2 S Alive certificate for the operator and swamper. 8.2.23 HOT TAPS A Hot Tap refers to any penetration into live piping or a pipeline where there is no existing fitting or when welding on pressurized pipeline or a pipeline. Welding on pressurized piping systems without taking the proper precautions is dangerous and can result in a major failure. Fatalities have occurred as a result of welding on pressurized pipeline. If proper steps are not followed, it is possible for a Hot Tap to result in: Pipe failure caused by burn through during welding; Ignition and burning of the product inside the pipe; Damage to equipment downstream of the hot tap due to cuttings; Delayed failure of the weld due to hydrogen or stress corrosion cracking. Workers involved in supervising or performing a Hot Tap are expected to ensure the proper pre-planning is completed including a formal Hot Tap plan. Step 1: Determine if the hot tap is really necessary. Step 2: Assess the risk to ensure that the likelihood and consequence of failure are acceptable. In all cases, the decision to proceed with a hot tap will be based on the ability to perform the hot tap safely. All Hot Tap procedures require HARVARD ENGINEERING approval in writing prior to commencing. 8.2.24 HOT WORK PROCEDURES SCOPE AND PURPOSE The following special precautions are a minimum requirement to ensure that adequate precautions are taken when dealing with Hot Work. DEFINITION Hot work is any operation that produces a source of ignition. HAZARDOUS LOCATION The area within a radius of 25 meters of the Hot Work is considered a hazardous location and kept free of flammable substances. Where this is not possible, competent supervisory personnel must be in constant attendance and a Hot Work Permit issued. OPX Consulting Inc. Section 8-61

EQUIPMENT ISOLATION All equipment on which Hot Work is to be performed must be positively isolated from all possible sources of combustible, explosive or toxic material. Positive isolation means blinding off, plugging or the complete removal and blanking off of inter-connecting piping vessels or sewers which may contain hazardous material. PURGING AND GAS TESTING No equipment, vessel, line or any type of container which has contained a hazardous material shall be safe for Hot Work unless it has been purged, gas tested and inspected. Steaming is an excellent way to remove residual hydrocarbons. HOT WORK PRECAUTIONS 1. All combustible materials within 7.5 meters of the Hot Work must be suitably isolated or cleared from hot work location. 2. When welding is carried out for the purpose of hot tapping on a pipeline, vessel or tank; the line shall be full of stock and have a positive flow, or in the case of vessels and tanks, they shall be filled with fluid at least one meter above the point at which welding is to be carried out. 3. Oil surfaces and oil spills must be hosed down and sanded over (minimum depth 1 inch). Oil soaked ground must be dug out and removed. 4. Testing must show that the atmosphere does not contain a flammable substance, in a mixture with air, in an amount exceeding 20 percent of that substance s lower explosive limit for gas or vapours or the minimum ignitable concentration for dust. 5. All trash and oily rags must be removed. 6. Particular attention is required for the danger of expansion of oil or gas in equipment (lines, vessels, etc.) immediately adjacent to the Hot Work. 7. Flammable solvents must not be used or be present in the area of Hot Work. 8. Fire blankets or appropriate fire retardant material shall be used when there is a danger of sparks being carried outside the work area. Fire blankets should be kept damp if spark impingement is intensive. OPX Consulting Inc. Section 8-62

9. Valves cannot be accepted as leak proof. Bleeder valves on pumps, lines and vessels shall be plugged off when such pumps, line or vessel contains flammable fluids. This is consistent with accepted practices that all bleeders are provided with plugs to prevent fire due to bleeder valves opening from vibration. FIRE EQUIPMENT 1. All fire equipment provided at the job site shall be checked and readily available for the personnel performing the Hot Work and personnel shall be fully familiar with the operation of such equipment. 2. Portable extinguishers permanently located in the operating area must not be used as standby fire equipment for Hot Work. 3. Portable extinguishers shall be placed in an accessible position and not so close to the Hot Work that they may become involved should a fire take place. ACCESS AND EGRESS Walkways, ladders, tank or tower manways and other approaches to the area must be accessible and free from obstacles that may obstruct personnel engaged in fire fighting or escape in case of fire. WELDERS, CYLINDERS AND GENERATORS 1. Welding machines, gas cylinders and generators must be located a safe distance from the Hot Work area, leaving easy access for removal in case of fire. 2. Welding machine ground wires must not be attached to any valves, fittings, machinery or other equipment in operation. 3. Welding cables must be in good condition and located clear of hot lines and equipment. Splices and joints in cables must be properly made and insulated. 8.2.25 HOUSEKEEPING HARVARD shall ensure that healthy and safe working conditions are provided and maintained for all employees. It is the responsibility for employees to maintain these conditions through good housekeeping and good personal hygiene practices. Good housekeeping is more then cleanliness; it is cleanliness and order. Cultivate the habit of good housekeeping. OPX Consulting Inc. Section 8-63

PRACTICES All working areas shall be kept clean and free from obstructions at all times. Tools, loose objects, oil, grease, and other materials are tripping and slipping hazards. Working areas shall be left clean and tidy at the end of each shift and on completion of work assignments. Materials shall not be stored in aisles or overhead. Never place equipment and tools on stair treads. Oil, paint, or chemically saturated rags must be placed in metal containers with covers. Rubbish must be placed in metal containers for waste disposal. Pools of oil or water, acids or caustic, shall be cleaned up immediately. If this is impractical, it should be reported your supervisor and guarded by a standby until the condition is corrected. Floor or ground openings shall be adequately barricaded. Rags are to be used when cleaning up around compressors etc. When purchasing rags, they should be of cotton base. Polyester rags are NOT to be purchased. All tools should be kept clean and in good repair at all times. 8.2.26 HYDRATE / ICE PLUG HANDLING Prevention is the best method for handling hydrates. Hydrates can be prevented and should not be accepted as normal operating routine. SCOPE AND PURPOSE Hydrates and ice plugs pose a real threat to both people and equipment if not handled properly. If proper procedures are not used when removing hydrates, very large forces may be created as hydrates begin to move, which can result in serious injury to personnel and damage to equipment. The following provides procedures for the proper identification and safe removal of gas hydrates. DEFINITION Gas hydrates are solid compounds formed by the reaction of a gas with water. Some of the light hydrocarbons that are components of natural gas form hydrates under pressure at temperatures above 0ºC. These hydrates form as crystals and look like snow. In pipelines, they can pack solidly to form a restriction resulting in partial or no flow. This is often referred to as line freezing. IDENTIFICATION Static pressure spiking on pipeline systems is the first indication that hydrates are beginning to form. A drop in flow should not solely be attributed to liquid hold-up; hydrates must be considered as the possible OPX Consulting Inc. Section 8-64

cause. The same applies to flowing wells, particularly if the wellhead pressure and temperature are dropping. A pipeline system should not be run when hydrates are forming unless methanol is being injected or the flowing temperature is being increased over a short period of time. REMOVAL PROCEDURES Removal of a solid hydrate should be directly supervised by the foreman/field engineer or his trained designate. Hydrates can be removed by increasing the temperature, depressurizing or injecting methanol into the line. Particular attention must be paid to the rapid vapourization of hydrates and the resultant pressure surge. 1. Heating a. Open flames (e.g. torches, fires, etc.) must not be used for hydrate removal. b. The use of vehicle exhaust for heating should follow hot work procedures. The area must be well ventilated due to the danger of carbon monoxide and attention must be paid to the possibility of gas ignition. This includes the presence of gas, and the condition of the vehicle engine and ignition system for possible sources of ignition. See OH&S Code, Part 10. Cross reference Safe Work Permits and Hot Work Safe Operating Procedures. c. When steaming is to take place, safe steaming procedures must be followed. 2. Depressurizing a. The most effective method for the removal of a hydrate plug is shutting in and depressurizing. Injecting chemical and alternating the pressure on either side of the plug has had limited success. b. When depressurizing, the hydrate plug should be depressurized from both sides. One side only should not be depressurized, followed by an attempt to move the hydrate with the pressure drop. This will only cause a more severe hydrate plug which may exist for days after depressurizing. c. When depressurizing requires hot tapping, refer to a standard procedure for hot tapping that is applicable to this operation. d. Caution must be exercised when a line, where hydrates are suspected is being depressurized and opened. The hydrates may OPX Consulting Inc. Section 8-65

3. Chemicals SAFETY PROGRAM MANUAL plug the line and trap pressure as well as dissolve and release hydrocarbons and toxic gases under pressure. a. Gas hydrates can be prevented or the hydrates dissolved by the injection of methanol or glycol. Glycols are not recommended, unless a specific circumstance dictates, particularly if the injection point is upstream of any compressors. b. When pumping of chemicals is to occur, the procedures on portable pumping should be followed. 8.2.27 MANAGING CONTROL OF HAZARDOUS ENERGY Before maintenance work, testing or inspection begins on any machinery, equipment or powered mobile equipment, all sources of hazardous energy at the location must be isolated by activation of an energy-isolating device. The machinery or equipment must be rendered inoperative in a way that could result in accidental activation, movement of equipment or otherwise cause damage to a person, property or process. The equipment or machinery must be isolated and secured at the main source of energy or control device. Shut down equipment Block in, de-pressure and purge vessel and piping if necessary. Install blinds where necessary. Ensure all energy isolating devices are in off position and attach a completed signed and posted checklist describing the work to be performed and the name of the operator installing the energy isolating device. Remove valve handles where practical or use energy isolating devices and chains to prevent handles from being moved. Place Do Not Operate tags on all valves. Test Local Start / Stop switch to ensure equipment is inoperative. LOCKS A person installing a lock has the only key that will operate that particular lock. The supervisor may have an alternate key to be used in an emergency. Use of the alternate key must be documented. Have each worker or each trade or group of trade workers install their own energy isolating device on the mechanical lock out clamp prior to commencing work. Locks must be removed by the person who installed it when they have completed their work on the equipment. OPX Consulting Inc. Section 8-66

ISOLATION Piping containing harmful substances under pressure must be able to be isolated by blinding, blanking or by using double block and bleed valves providing two blocking seals on either side of the isolation point and an operable bleed-off between the two seals. Blank, blind or double block and bleed the piping during repair, modification, maintenance or replacement. Clearly mark piping that has been blanked or blinded. Where two valves and a bleed off are used to isolate the piping, ensure that the bleed off valve is secured in the Open position and the valves or similar blocking seals in the flow lines are functional and secured in the Closed position. If it is not reasonably practicable to provide blanking, blinding or double block and bleed isolation, an employer must ensure that an alternate means of isolation provides adequate protection to workers, certified as appropriate and safe by a professional engineer, is implemented. The device used to secure the valve or seals must have a positive mechanical means of keeping the valves or seals in the required position and is strong enough and designed to withstand inadvertent opening without the use of excessive force, unusual measures, or destructive techniques. Work in confined or restricted spaces must be isolated from all sources of contamination. This means that all lines to and from a confined space must be blinded or blanked before work begins. See applicable Provincial regulations (i.e. Alberta OH&S Code 2009) for additional detailed information concerning the Control of Hazardous Energy. BULL PLUGS Bull plugs must be installed in all open ended valves that, if accidentally opened, could release a product that could create a hazard to personnel or the environment. Install bull plugs in all valves that could be accidentally opened. Bull plugs should only be installed hand tight so pressure cannot build up between the bull plug and the valve creating a safety hazard when the plug is removed. PUMP JACKS All oil well pump jack installations and dismantling must be supervised by an experienced supervisor. OPX Consulting Inc. Section 8-67

All pump jacks are equipped with rotating weights that are needed to counterbalance the weight of the rod string. A pump jack can start to rotate on it s own due to gravity. It is imperative to make it properly secured by one of the following methods. The brake should not be used as the only method for securing the jack. a. A chain threaded through the hole in the brake drum nearest the trunnion and then around the trunnion, or, b. If equipped, the brake pawl on the brake drum should be engaged, or, c. Use heavy timbers under the crank ends to stop downwards movement. The brake must also be engaged. Before starting up a jack pump, the crank guards and belt cover are to be in place. If there is livestock present, the wellhead should also be guarded. All pump jack manufacturers supply manuals that give detailed instruction for the safe installation and operation of pump jacks. When installing or dismantling, it is the supervisor s responsibility to be familiar with the instructions in the appropriate manual. All production operators must be familiar the operating instructions for the makes of pump jacks they operate. 8.2.28 NATURALLY OCCURRING RADIOACTIVE MATERIALS (NORM) NORM originates in some geological oil or gas formations and is brought to surface in produced water. The amount of radiation able to penetrate processing equipment is generally not large enough to present a health risk. However, scales and sludge that accumulate in the processing equipment may be harmful when the equipment is opened for inspection and repair. Exposure may occur by inhaling or ingesting radioactive dust. If workers are going to be exposed to scales and sludge the local field supervisors should be consulted to determine if NORM is an issue in the area. If unknown, or if the data is older than three years, arrangements for a NORM survey must be made. 8.2.29 NOISE EXPOSURE Exposure to high sound levels and/or sharp impact sounds for sustained periods, coupled by the effects of getting older can reduce or impair hearing levels. Noise is a recognized workplace hazard that must be assessed, eliminated or controlled. Area sound level measurements and noise dosimeters are taken at various workspaces to identify where noise levels exceed 85 dba over an 8-hour work period. If a noise hazard is OPX Consulting Inc. Section 8-68

identified, the first step is to engineer out the hazard (substitution, modification, isolation, and/or maintenance) by: Applying controls to limit time spent in hazard area; and, Training workers in the proper use of PPE (disposable ear plugs, reuseable ear muffs, and/or custom-made ear plugs for noise-exposed workers ). Audiometric hearing tests at sites with noise issues are to be administered by a certified third party. Testing will establish a baseline for all noiseexposed workers and ongoing testing will ensure there are no adverse health impacts. Additionally, all new or renovated worksites, new work processes, or new equipment brought into a workplace must achieve a noise level as low as reasonable practicable and preferably lower than 85 dba. 8.2.30 PIGGING GUIDELINES SCOPE AND PURPOSE Pigging operations in oil and gas field operations present a serious hazard. Due to each area or facility having individual pig trap design and operation, a site-specific practice must be developed. These guidelines will help to develop a safe procedure when pigging any pipeline for the removal of wax, other solid deposits and trapped fluids. DEVELOPMENT OF SITE SPECIFIC PRACTICE 1. When developing a site-specific practice, the following concerns must be addressed in all cases: a. Is this a two man job? b. Are sour products expected? c. Proper isolation and de-pressurizing. d. Characteristics of the fluid to be pigged. e. The hazard of potential plugging of the bleed-off valves. f. Proper receiving and launching techniques stressing potential hydraulic shock. g. Routine inspection of the cap, barrel and seals. h. Individual marking or identification of pigs and logging with respect to launching and receiving times. i. When to make up? 2. In a system requiring pigging, proper pipe internal diameter, full opening valves, long radius elbows and barred tees must be used during any piping modifications. OPX Consulting Inc. Section 8-69

3. Where the receiver is vented to a proper drain or flare system, the barrel must be fully vented to atmosphere prior to opening the receiver or launcher. 4. Where the cap is not secured to the receiver or launcher, the operator must position himself to ensure he is not in the line of trajectory of the pig or cap should unsuspected pressure be present when the cap is removed. 5. Where the cap is secured through a hinge arrangement the operator must be very careful of the swing of the cap should unexpected pressure be present. 6. Proper disposal methods must be used for recovered wax, other solids and fluids. SOUR PIGGING GUIDELINES 1. If the H 2 S content of the oil or gas expected is less than 10 ppm, pigging may be done without masks or buddy system unless some special hazard is recognized by the operator. 2. If the maximum H 2 S content of the oil or gas expected is less than 15 ppm and the line size is 125 mm or less, the operator may pig the line without using a mask but the buddy system must be used with the second man standing 15 meters upwind with mask equipment close by. The pigging should be done masked up if any special hazards are recognized. 3. If the maximum H 2 S content of the oil or gas expected is greater than 15 ppm or if the line size is greater than 125 mm with an H 2 S content of 10 ppm or greater, the operators shall use the buddy system and the operator performing the pigging shall be masked up. The second operator shall be upwind 15 meters with mask equipment close by. 8.2.31 PORTABLE PUMPING EQUIPMENT AND OPERATIONS SCOPE AND PURPOSE Provide safe procedures and guidelines for portable pumping operations. APPLICABLE PROCEDURES Portable pumping applications include hot oiling tanks, pipelines and wells for wax removal, pressure testing of surface equipment and pumping of chemicals for various operations including wax and hydrate removal. OPX Consulting Inc. Section 8-70

WORK PERMITS An authorized HARVARD representative must be on site for all pumping operations where a hazard exists for personnel or equipment. A work permit must be issued for the job by HARVARD representative. EQUIPMENT POSITIONING 1. The pumping equipment must be positioned a minimum of 25 meters from the wellhead, tanks and any process equipment. The unit should be positioned upwind and directed for quick exit. Refer to (Alberta) Oil & Gas Conservation Regulations 8.090 and 8.100. 2. All fire equipment and safety equipment should be position for use. A minimum of two 30 lb fire extinguishers must be on site. 3. The unit must be grounded to the equipment to be serviced. PRE-JOB SAFETY MEETING A pre-job safety meeting must be held and documented. The meeting must cover; safety equipment and regulation checklist, a site-specific procedure encompassing maximum testing and operating pressures, fluid characteristics, maximum operating temperature, and equipment layout. TIE-IN EQUIPMENT 1. The tie-in equipment must have a pressure rating sufficient for the application and must include a check valve and isolated valve upstream of the tie-in point. 2. Where the pressure is expected to exceed 1500 kpa, or hot or corrosive fluids are to be pumped, all tie-in lines must be steel with chick-sans. No flexible lines will be allowed. All lines must be securely staked. RETURN LINES 1. Where return lines are used, the specifications for tie-in lines will apply. Where the return fluids are hot or contain flammable gases, the returns must be made to a vented tank located 25 meters away from any ignition sources or equipment. The vent line must be of sufficient size to handle the quantity of vented gas, and terminated downwind no less than 25 meters for any ignition source or equipment. 2. All lines must be pressure tested to 1.5 times maximum working pressure. The maximum working pressure must not exceed the allowable working pressure of the equipment to be serviced. 3. The working temperature must not exceed 80% of the flash temperature of the fluids. OPX Consulting Inc. Section 8-71

4. While hot fluids are being pumped, attention should be paid to the effect of metal or fluid expansion. 5. Reference Industry Recommend Practice for Well Testing and Fluid Handling IRP Vol 4, Subsection 4.0.7.20. 8.2.32 PURGING Purging is the practice of displacing the existing gas and/or fluid in a vessel, container or piping system with another gas and/or fluid. Purging is often used to remove toxic or explosive/flammable fluids and gases from a system before opening the system to atmosphere or prior to shipment of equipment. Alternately, before equipment start-up, air may be purged from equipment in preparation for it being put back into service. A site-specific purging procedure must be developed for any purging operation other than routine operations covered by the Task Competency Manual or other documented standard procedures. The site-specific procedure must identify the hazards associated with the task and the control methods utilized to address those hazards. POSSIBLE PURGING MEDIUMS Consideration should be given to the use of an inert purge medium. However, it is recognized that it is not always practical to use an inert purge medium for all operations. Flammable purge mediums can be successfully used as long as special precautions and procedures are used. Depending on the application, commonly used purge mediums are listed below. Each of these has advantages and disadvantages. INERT GASES (N 2, CO 2 ) Addresses both, potentially toxic and explosive atmospheres. It is the preferred method of preparing a tank or vessel for confined space entry. The atmosphere will be oxygen deficient. If a confined space entry is planned, the space must be ventilated prior to entry or breathing apparatus must be worn. This purge medium must be purchased and is not reasonably available at all locations. PROPANE OR SWEET GAS Commonly used to purge sour hydrocarbons from equipment to address the toxic vapour hazard. May also be used to purge air from equipment prior to start-up but caution must be exercised because the air hydrocarbon mixture will create an explosive atmosphere. OPX Consulting Inc. Section 8-72

By itself, is not suitable for purging in preparation for confined or space entry. SOUR GAS (WELL GAS) This readily available purge medium is used at small remote locations to purge air prior to start-up of equipment. Similar to propane or sweet gas, caution must be exercised because the air hydrocarbon mixture will create an explosive atmosphere. The added hazard created by any toxic vapours vented must also be addressed. By itself, it is not suitable for purging in preparation for confined or restricted space entry. WATER May be used to flood a vessel or tank to push out the hydrocarbon hazards and is a suitable purge medium for preparing a tank/vessel for confined space entry. When the water is drained and air is introduced into the system, caution must be taken since sludge in the vessel/tank may release flammable and or toxic fumes. Depending on the amount of water used, it may also pose a problem in safe and economical disposal. STEAM Similar to water, steam may be used to push out the hydrocarbons to deal with both the flammable and toxic hazards and therefore is a suitable purge medium for preparing a tank/vessel for confined space entry. Steam also has the added benefit of driving additional flammable/toxic vapours from the sludge. Caution must be exercised so that workers do not receive burns from escaping steam. AIR Often used to purge an inert gas from a tank/vessel in preparation for a confined space entry (forced ventilation). Warning: If air used to purge hydrocarbons, an explosive mixture inside the vessel or tank being purged will be created at some time during the operation. Air should NOT be used unless ALL potential ignition sources have been eliminated. Even then work should proceed with extreme caution. OPX Consulting Inc. Section 8-73

GENERAL PRECAUTIONS Regardless of the purge medium used, each presents its own hazards. Hazards must be assessed and appropriate steps taken. Depending on the task to be completed, and the purge medium used, some general precautions include: Pre-job safety meetings should be conducted whenever nonroutine purging operations take place. Exhaust gases can be used to test for O 2 content, LEL, and toxicity. When purging hydrocarbon with air or air with hydrocarbon, introduce the purge gas slowly. This will help prevent the build up of static and/or potentially causing any loose debris to tumble through a pipe or vessel and causing a spark. Purging should be done as near to atmospheric pressure as possible, as increased pressure changes the explosive limits and lowers the ignition temperature. Individuals involved in purging operations, as a minimum, must wear the proper personal protective equipment as outlined in this Handbook. All elements of the system being purged must be electrically bonded and grounded. Considerations for the purged gases include: The air gas mixture must be considered when purging to a live flare system; In some cases flares should be snuffed out prior to purging, or a temporary/alternate vent system laid out to a safe area. Potential ignition sources that need to be considered include: Flashbacks from flares; Static electricity; Friction heat (from valve operation or high velocity debris); Spontaneous combustion at critical pressures and temperatures; Spontaneous combustion of compounds such as sulphides; Electrical currents from lightning and power sources; Closed tanks/vessels must be de-pressured and not be on vacuum before opening the system. Consider the corrosive effects of fluids that may be purged. Consider the environmental impact of escaped fluids, gas or waste products. 8.2.33 RIG ANCHORS Rig derricks, masts or self contained snubbing units are either designed to be free standing or to be secured with anchored guy lines. This work procedure was developed to reflect HARVARD s practice that all contracted rigs, with derricks that required anchored guy lines, have OPX Consulting Inc. Section 8-74

anchors installed and guy lines secured before operation of the rig is commenced. PROCEDURE 1. It is the Well Site Supervisor s responsibility as a representative of HARVARD to NOT approve the start of rig operations until anchored guy lines have been have been installed. 2. It is the rig contractor s responsibility to supply, install and test anchors and attach guy lines in accordance with the rig manufacturer s design and specifications. 3. The installation of rig anchors is a ground disturbance activity. It is the Well Site Supervisor s Responsibility to check for the location of buried pipelines, electrical cables, etc. before anchors are installed. Refer to the Ground Disturbance Code of Practice in this section. 4. Must have separate anchors for escape lines. 8.2.33.1 RIG INSPECTIONS Drilling rigs, service rigs or snubbing units must be inspected by a competent worker before the rig is placed into service and every 7 th day on which it is used for as long as it is in service. 8.2.34 SAFE WORK PERMITS INTRODUCTION This procedure has been developed to provide guidelines on the use of safe work permits at all HARVARD s work sites. Each area is responsible for developing its own site-specific procedure for the use of work permits. To be valuable, a Safe Work Permit must identify the work to be done, the hazards involved and the precautions to be taken. It determines that all hazards and precautions have been considered before work starts. It is an agreement between the issuer and the receiver that documents the conditions, preparations, precautions and limitations, which must be clearly understood before work commences. The permit records the steps to be taken to prepare the equipment, building or area for work. Also the safety precautions, safety equipment or specific procedures that must be followed to enable the worker to safely complete the work. PERMIT REQUIREMENTS The site-specific Safe Work Permit procedure should address how the permit system is administered as well as when Safe Work Permits will be OPX Consulting Inc. Section 8-75

used. Consideration should be given to the following circumstances in determining when a Safe Work Permit is to be issued: 1. The product being contained may escape to atmosphere. 2. A safeguard has to be removed or disabled. 3. A safeguard requires repair or maintenance. 4. Working on rotating equipment that requires a energy isolation device. 5. Hazardous chemicals are handled. 6. Hot work occurs (stand-by person required). 7. Confined or restricted space entry occurs (stand-by person required). 8. Vehicle entry where vehicles and/or portable rotating equipment are present outside of normal parking or traffic areas and/or are in the immediate vicinity of process equipment. 9. When lifting with equipment occurs. 10. Contractor involvement in the task. 11. Ground disturbance. 12. Sour gas. Note: The stand-by person will be a qualified individual (employee or contractor) assigned to the task. SPECIAL PRECAUTIONS Hot Work A Safe Work Permit must be issued for any kind of Hot Work. This kind of work must be supervised at all times by an individual acting in the capacity of a stand-by person. Procedures have to be in place and implemented to ensure continuous safe performance of Hot Work. Atmospheric testing must be done and recorded on the permit before any work commences. If the Hot Work is of a lengthy nature, the atmosphere must be continually monitored or re-tested periodically during the job and results recorded on the permit. Hot Work must immediately be halted if gas testing or other conditions indicate that the work may no longer be carried out safely. Confined Space Entry All confined space entry work must also conform to HARVARD Confined Space Entry Code of Practice. Communication Permit issuers, job supervisors and workers must all be aware of the tasks that are to be completed and the Safe Work Permit requirements. If the worker is to be working at more than one location, those locations must be listed on the Safe Work Permit. If there are so many locations that listing them is impractical or impossible, communication between the worker and the permit issuer should be on-going throughout the day. OPX Consulting Inc. Section 8-76

Permit Responsibilities Permits issued where more than one department is involved, should be issued to the senior person who will be involved from the start to finish of the task at hand. He/she will be responsible for ensuring proper communication and that safe work practices are followed. More than one permit may be required depending on the scope of the job. Displaying Permits A copy of an active permit is to be displayed in a conspicuous place. If this is not practical, it must be readily producible by the permit holder. A Safe Work Permit is valid for one working day, but if conditions are unchanged and communication occurs between the two concerned parties, an extension on the permit may be given. On each copy of the permit, the new date and/or times must be clearly indicated and initiated. No expired permits are to be displayed. When the work has been completed, permits are to be signed off and returned to the originator. If work is incomplete, it should be noted on the permit when returned. Work permits will be kept on file for a period of two years. Blanket Work Permits A blanket work permit is a special permit that may be issued for an extended period of time (up to one year). It is intended to be issued for tasks carried out on an on-going basis by contractors (e.g. field hauling of fluids) where specific procedural guidelines have been established and agreed to by the contractor. Work Clearances A Clearance may only be issued when Complete control of a site is to be turned over to a worker. A Work Clearance may be issued for the total period of time that is required to complete the tasks at that site. The worker receiving the Clearance is responsible for issuing any Safe Work Permits at the affected site as may be required by the Code of Practice or the applicable government regulations. After the work covered under the Work Clearance has been completed, the clearance must be signed off and returned to the issuer. 8.2.35 TANK TRUCK LOADING PROCEDURES FOR FLAMMABLE LIQUIDS a. Observe all posted rules and regulations at lease entrance. b. Tank trucks must be equipped with positive air intake shut offs. c. Self-contained breathing apparatus must be used when coupling or uncoupling load hoses where H 2 S exceeds the OH&S exposure limits summarized in Section 7.2. OPX Consulting Inc. Section 8-77

d. External tank gauges are to be used to determine volume of fluid loaded. Thief hatches on production tanks are to remain closed as production tanks may be pressurized with sour gas. e. Lights on trucks are to be shut off prior to loading. f. Bonding/grounding cables are to be connected prior to loading. g. Emergency brakes are to be fully engaged and wheels are blocked. h. Servicing or maintenance on trucks while loading or unloading is prohibited. i. Drivers must remain outside their vehicles to monitor for leakage of hoses, pumps, lines, valves and tank truck levels to eliminate spills. 8.2.36 TIMBER REMOVAL Workers responsible for logging operations shall plan and conduct such operations in a manner consistent with regulations and with recognized safe working practices. In British Columbia, all fallers must be certified. Workers operating chain saws shall wear effective, protective clothing including leg protective devices. It is a requirement that all chainsaw operators have formal training. Any trees, snag and other objects that might endanger worker shall be felled for removal. Particular care shall be taken in falling snags and in working around snags. 8.2.37 TRAILERS & BUNKHOUSES All trailers and bunkhouses must be located at a safe distance from drilling rigs and operation equipment and must be positioned upgrade of any fuel storage facilities. The hitches must be accessible so the trailer or bunkhouse can be readily moved in case of emergency. Electrical wiring and fixtures must meet the applicable Provincial Electrical Code. Smoke detectors and fire extinguishers shall be provided as required by the Provincial Fire regulations. 8.2.37.1 TOILETS & WASHING FACILITIES Ensure signage is in place for potable and non-potable water; Potable water supplies should be maintained as per manufacturer s recommendations. Lunch room, change room, toilet, urinal, wash basin, hand cleaning facility, circular wash fountain or shower at a work site must be clean, sanitary and operational. OPX Consulting Inc. Section 8-78

8.2.38 TRENCHING Precautions NO worker shall enter a trench with a depth of more than: Alberta British Columbia Saskatchewan Manitoba 1.50 metres 1.22 metres 1.22 metres 1.80 metres Unless protected from any cave-in or sliding material by: Cutting back Shoring Or a combination of both of the above No two trenching projects are identical, therefore each project must be considered unique and the following completed: Hazard assessment conducted Site-specific work procedure developed Consider soil conditions prior to task Work Permit issued, both pre-trenching and trenching Follow all other codes of practice (Ground Disturbance, Confined Space Entry, Working Near Overhead Power Lines) Ensure any ground thawing is done using safe environmental practices Ensure the area surrounding the ditch is safe Review and follow applicable provincial regulation 8.2.39 VEHICLE, MOBILE EQUIPMENT & MACHINERY All authorized vehicles required in a Hazardous Area are to be listed on the Work Permit and only allowed on a Work Site after the permit is obtained. All unauthorized vehicles will park in the designated areas only and will under no circumstances be allowed on a Work Site. a. Internal combustion engines (gas or diesel) may not be operated in areas classified as hazardous by the Canadian Electrical code unless atmosphere tests have been made that indicate that the work may be done safely. In particular, precautions should be taken within 2 metres of a wellhead and 3 metres of process equipment and buildings. Procedures must be in place to ensure the continued safe performance of this hot work. b. Diesel engines that are to remain running within 25 metres of a potential gas release must be equipped with a positive air intake shut-off device unless continuous gas monitoring is in place. OPX Consulting Inc. Section 8-79

c. All vehicles on site must be in safe operating condition and operated in a safe and courteous manner. d. All mobile welding rigs must be equipped with proper fire extinguishers before entering the Work Site. All welders and helpers must know how and when to use such fire extinguishers. e. Where an operator s view of the direction of travel of powered mobile equipment is obstructed or restricted the equipment must be equipped with a warning device appropriate to the hazard. This could include an audible warning device, flashing lights, or an automatic stopping system. Where one of these systems is not practicable, the equipment must not be moved in the direction of the restricted vision unless under the direction of a competent worker who has a clear view of both the area and the operator. f. Any lawnmowers over 700 kg require engineered roll bars. g. No person shall operate any equipment or machinery unless the operator has received the required training and is authorized to do so. h. Mobile equipment must have rollover structures, protective back up alarms and seat belts where required by safety regulations. WARNING SIGNAL The large size of some powered mobile equipment makes it impossible for the operator to have a clear view around the equipment. This view can be directly with the eyes or indirectly with a mirror, close circuit television, or other effective means. A serious hazard can result if the equipment is moved in a direction that the operator cannot see clearly. If the operator cannot see what is in the direction of travel, the powered mobile equipment must be equipped with one or more of three acceptable alternatives. a. An automatic audible warning device. The audible warning must be loud enough to be heard above other noise in the immediate area. For most equipment this is the familiar back up alarm ; b. An alternate warning device or method appropriate to the hazard of the work site- this may include flashing/rotating lights, strobe lights, or other effective means; or c. An automatic stopping system - this system may use motion, thermal or other detectors to sense the presence of a worker or obstruction in the path of travel and automatically stop the equipment. If it is impracticable to equip the powered mobile equipment with a warning device then the operator must ensure that the operator and other workers are protected from injury before moving the equipment by: a. Completing a visual inspection on foot of the area into which the equipment will move. b. Following the directions of a traffic control or warning system OPX Consulting Inc. Section 8-80

c. Getting directions from a worker who has an unobstructed view of the area into which the equipment will move, or is stationed in a safe continuous view of the operator. d. Ensuring all other workers are removed from the area into which the equipment will move. 8.2.40 WELDING AND BURNING All work to install or repair pressure equipment will be completed by Contractors with a registered quality control program. Only experienced workers are allowed to use welding and burning equipment. Precautions must be in place to ensure that welding or allied process equipment is erected, installed, assembled, started, operated, used, handled, stored, stopped, inspected, serviced, tested, cleaned, maintained, repaired and dismantled in accordance with the manufacturer s specifications. Suitable precautions must be taken against exposure of welding (and other) personnel to excessive ultraviolet radiation, fire, explosion, asphyxiation or exposure to toxic gases, fumes or dust when welding or cutting equipment is used. All gas-welding hoses are to be equipped with appropriate flame arrestors or check valves. All acetylene oxygen welding units are required to have two flame arrestors. A serviceable fire extinguisher is to be immediately available at welding and burning sites. Before beginning to weld: a. Area is to be gas checked, b. Fire detectors are to be bypassed. c. When welding at a hazardous location, a standby man with an extinguisher is to be on site. 8.2.41 WILDLIFE AWARENESS To ensure wildlife protection requirements are met, abide by the following: Plan and maintain sites in a manner that respects and preserves native wildlife to the greatest extent possible Minimize disturbance to the native flora and fauna Store potential food sources away from wildlife and in an animal resistant manner Do not harass or feed wildlife in any way Ensure all personnel are aware that with the exception of approved Wildlife Monitors, firearms are prohibited on work sites. OPX Consulting Inc. Section 8-81

Understanding the basics of animal life will assist workers to remain safe and protected from animals. One of the primary ways to protect yourself from bears is avoidance. If you suspect that bears are within your work area, it is best to leave the area. Scan the horizon on a regular basis so you don t suddenly encounter a bear. If you sight a bear, report the sighting immediately to your supervisor. BEAR SAFETY Make noise Keep food and garbage tripled sealed Learn to identify bear signs like hair on trees, droppings, and paw prints Take note of working in areas of berry bushes and water holes Do not use a walkman or stereo- must be able to hear all sounds Carry a bear-scare device Other Wildlife concerns; cougar, moose, wolf, fox, coyotes, caribou, deer, ungulates, livestock, dogs, buffalo, etc. GRIZZLY BEARS Grizzly bears graze on: Above ground vegetation during summer Shallow roots in early spring Berries in late summer and fall They also supplement their diet with animals whenever possible including: Eggs in the spring Arctic ground squirrels in late summer Arctic fox pups in the summer Caribou calves in the early summer Grizzly bears den from September to October and emerge March to May. Dens are generally excavated in the ground and are composed of a tunnel and nest chamber. Often dens can be found along in streams and riverbanks, in sand dunes, along hillside and on mounds. The dens are usually made for one season and then collapse. General wildlife awareness is a component of this orientation standard. However, changes in location, seasons and habitat may require expanded wildlife orientation and or training. Site specific orientations are an excellent opportunity to review worker knowledge as well as recent wildlife sightings and behavior. OPX Consulting Inc. Section 8-82

8.2.42 WORKING ALONE HARVARD presently has various systems in place to control hazards associated with working alone or otherwise. These include Codes of Practice, standardized procedures, use of personal monitors and protective equipment, core safety training of staff and use of ticketed workers. Emergency Response Plan training, and the ongoing casual and formal contact among workers during the day. ROUTINE OPERATIONS WITH COMMUNICATIONS IN PLACE HARVARD will ensure all operators working alone will be provided with an effective communication system consisting of radio communication, landline, cellular telephone communication or some other effective means of electronic communication that includes regular contact by HARVARD or a designate at intervals appropriate to the nature of the hazard associated with the operator s work. If effective electronic communication is not practicable at a work site HARVARD will ensure that they or a designate visits the worker or the worker contacts HARVARD or a designate at intervals appropriate to the nature of the hazard associated with the workers work. This process should be documented, see (Figures 1 and 2 at the end Section 8). In areas where HARVARD has a contract operator who looks after another companies properties in the same area, HARVARD will maintain their call-out policy. HARVARD s approach will be to ensure good communication and concentrate on circumstances where the work location or timing reduces the ability to respond to an incident. WORKING ALONE SITUATIONS Circumstances where the risks of working alone are increased would include such things as: Any task being completed in an area where communication is not reliable. Situations where workers work overtime or respond to call-outs and there is limited communication available. Travel into remote or other areas where the response time is significant in the event the worker does not check in at the end of the day. Travel in areas where incidental contact with other workers or the public is not likely to happen. Travel by ATV s which would increase the risk of injury to the worker and communications. OPX Consulting Inc. Section 8-83

8.2.43 WORKING NEAR OVERHEAD POWERLINES Extreme caution must be used when working near overhead powerlines. Activities involving such things as high loads, excavation work, crane work or using gin-pole trucks, creates circumstances with the potential for injuries, fire and explosion or property damage. The following outlines requirements when working under or near powerlines and is consistent with both regulatory and utility company requirements. The first two important steps that need to be taken are: 1. Notify the utility company and obtain any required crossing agreements; 2. Confirm the voltage and maintain the minimum clearance required by the power company. Typical clearances are: Operating Voltage of Overhead Power Line Between Conductors 0 750 V Insulated or polyethylene covered conductors (1) 0 750 V Bare, uninsulated Above 750 V Insulated conductors (1) (2) Safe Limit of Approach Distance for Persons and Equipment 300 mm 1.0 m 1.0 m 750 V 40 kv 3.0 m 69 kv, 72 kv 3.5 m 138 kv, 144 kv 4.0 m 230 kv, 260 kv 5.0 m 500 kv 7.0 m When working under or near overhead powerlines, the following precautions must be taken: Danger Overhead Power Lines signs must be in place before work commences. These signs are 51 cm x 71 cm in size, 1.8 m above ground and 7 m on either side of the line when operating equipment either under or near the powerline; When work is required inside the specific clearance area, it shall be performed with the powerlines de-energized. This task shall be conducted by a qualified utility employee; If the line cannot be de-energized, the work must be supervised by a qualified utility employee and requires a designated signaler with communication; Once the safe limit of approach distance has been established the employer must ensure that no work is done or equipment operated at distances less than the established safe limit of approach distance. OPX Consulting Inc. Section 8-84

Work in the vicinity of the powerlines must be performed in accordance with the standards established by the appropriate jurisdiction. Be aware when working near powerlines that certain weather conditions can create electrical charges on nearby facilities and equipment. OPX Consulting Inc. Section 8-85

SECTION 8 FORMS Figure 1: Check-in Procedure Worksheet Figure 2: Working Alone Check-in Procedure Fire and Explosion Prevention Plan Form Fire Tetrahedron Fall Protection Plan Form OPX Consulting Inc. Section 8-86

Figure 1: Check-in Procedure Worksheet SAFETY PROGRAM MANUAL This procedure can be used for more than one area and for different circumstances. Check-In Procedure Number: Date: 1) Establish who will be the check-in contact. 2) Determine how often the check-in will be required (every hours). Document reason for frequency selection. 3) Establish documentation procedure. As a minimum the documentation must list name, phone number, time of check-in, expected time of next check-in, and location of individual. 4) Determine process if check-in not made at pre-arranged time. 5) Outline procedures for emergency response, including any sitespecific assistance contacts and their phone numbers. OPX Consulting Inc. Section 8-87

Figure 2: WORKING ALONE CHECK-IN PROCEDURE Location: Date: Working Alone Check-in Task / Area Procedure Areas where communication is unreliable: Emergency Response Actions Documentation Employees who work overtime: Workers who respond to call-outs: Workers who travel to remote locations: Tasks which require travel by all terrain vehicles (ATVs): OPX Consulting Inc. Section 8-88

Worksite location: FIRE AND EXPLOSION PREVENTION PLAN FORM Date: Issued by: BRIEF DESCRIPTION OF JOB SCOPE: CRITICAL RISK FACTORS: FUELS LIQUID HYDROCARBONS YES NO HYDRO CARBON VAPOURS YES NO HYDROCARBON GASES YES NO HYDROGEN SULPHIDE YES NO HYDROCARBON-BASED WORKOVER FLUID YES NO FLAMMABLE AND EXPLOSIVE CHEMICALS YES NO IGNITION / ENERGY OPEN FLAME SOURCE YES NO HOT WORK YES NO VEHICLES IN CLOSE PROXIMITY YES NO ELECTRICAL EQUIPMENT YES NO STATIC, FRICTION OR MECHANICAL SPARKS YES NO PYROPHORS (ie: iron sulphide) YES NO OXYGEN PLANNED AIR INTRODUCTION (ie:purging) YES NO UNDERBALANCED OPERATIONS YES NO VACUUM CREATING OPERATIONS (ie: swabbing) YES NO POCKETS FROM SERVICING OR INSTALLATION OF EQUIPMENT YES NO OXIDIZERS OR CHEMICAL REACTIONS YES NO WEATHERED HYDROCARBONS YES NO Fire and Explosion controls (Actions taken to prevent the completion of The Fire Triangle.) Have the safety meeting and all applicable permits been completed? YES NO Have all the deficiencies identified in the inspection been rectified? YES NO Comments and observations Emergency Controls (Plan of action or response to an elevation of risk.) Can personnel identify and act on changing conditions to prevent fires and explosions? YES NO Comments and observations Worker Training and Awareness. Workers have been informed, and can recognize potential Fire and Explosion hazards relating to the planned activities. Affected workers have been made aware of this Fire and Explosion Prevention Plan? Initial Comments: Worksite Supervisor s Name Signature

PREVENTING FIRES AND EXPLOSIONS USING THE FIRE TETRAHEDRON Chemical Chain Reaction This fourth element is necessary for the composition of a fire. Otherwise known as an exothermic chemical reaction. This reaction provides the heat to maintain the fire. Knowledge of the chemical chain reaction is important in understanding how to fight certain types of fires. HEAT OR IGNITION SOURCES Open Flames Hot Work Vehicles and Other Running Engines Electrical Equipment Static, Friction or Mechanical Sparks Pyrophors (ie: Iron Sulphide) Chemical Reactions and Sparks Spontaneous Combustion Sudden Decompression Compression Ignition Catalytic Reactions Chemical Chain Reaction OXYGEN SOURCES or OXIDIZERS 1. Planned Intoduction of Oxygen Air Based Operations (Numatic) Air Purging 2. Unplanned Introduction of Oxygen Underbalanced Operations Swabbing and Other Operations Where a Vaccum is Created Serviceing and Instalation of Equipment Chemical Reactions Oxidizers and Oxidized Hydrocarbon Tank Drawdown GASES Natural Gas Hydrogen Sulphide LPG Gases (ie: propane, butane, pentane.) Other Ignitable Gases. LIQUIDS/VAPOURS Crude Oil Condensate NGL Liquids Gasoline, Diesel and Other Fuels Methane CHEMICALS Chemicals Used for Well Servicing and Stimulation Special Compounded Hydraulic Fluids and Lubricants Solvents and Cleaning Agents SOLIDS Lubricants Sealants Packings, O Rings, Diaphragms and Valve Seats Paints and Coatings

9.0 TRAINING 9.1 OVERVIEW Occupational health and safety regulations require that every employer ensure the adequate direction and instruction of workers in the safe performance of their duties. Every supervisor is responsible for the proper instruction of the workers under his direction and control, and for ensuring the work is performed without undue risk. HARVARD recognizes that it is important for employees to be familiar both with safety concerns and with technological advancements being made in our industry. Employee participation in external and internal training programs is encouraged. Some of this training is provided through orientations and on-the-job training, while other training is provided through formal courses. HARVARD has established a minimum standard that includes a number of core (required) safety courses that must be completed by all staff at field locations as well as standards for those headquartered in Calgary and temporarily working at field site locations. The following outlines all training requirements. 9.1.1 Safety and Environment Orientation Begin first week and consider: Personal Protective Equipment Personal Conduct Regulatory Requirements Company Vehicle Care (if applicable) Contractor Responsibilities Emergency Response Work Procedures HS&E Handbook & Questionnaire 9.1.2 On-The-Job Training Begin in first days: General Operations o All applicable tasks Housekeeping Safety Precautions o Hazards o Equipment o Procedures Record keeping and sign off OPX Consulting Inc. Section 9-1

9.1.3 Safety Training Personnel must have the appropriate training certification pertaining to potential hazards in the workplace. These may include: H 2 S Alive Defensive Driving First Aid/CPR WHMIS TDG Fire Extinguisher Training 9.1.4 Supervisory Training Those employees that are, or have potential for supervisory positions, shall receive appropriate training. 9.1.5 Optional and Non-Optional Training Complete as applicable: High Vapour Pressure Release Training Confined Space Entry Off Highway Driving (Theory) Collision Avoidance Course H 2 S Rescue Propane Training Wilderness Survival Training ATV Training Leadership for Safety Excellence Standards for Wellsite Supervision, Drilling, Completions & Workovers as per IRP Vol. 7, Subsection 7.6.3: o Wellsite Supervision o Second Line Supervisor s Well Control o Safety Management for Wellsite o Regulatory Awareness for Wellsite o Detection & Control of Flammable Substances o Well Service BOP OPX Consulting Inc. Section 9-2

9.2 SAFETY ORIENTATION Every worker and contractor who is new to a work site must receive an orientation to the site. This orientation is an introduction to critical aspects of HARVARD 's Health, Safety and Environment Program. It provides immediate information that workers need to know and includes a review of Company policies and other practices in the Health, Safety and Environment Handbook. A Handbook Review Questionnaire and Answer Key are available to confirm that employees understand the contents of the handbook. The employee is required to familiarize themselves with the contents and then sign the acknowledgement form located on the back page and turn it in to their supervisor. Individuals will then be issued a HARVARD Safety Orientation hardhat sticker. The signed acknowledgement forms and a copy of the questionnaire are to be filed at the applicable field offices. As part of the orientation, core safety training requirements should be determined and scheduled as soon as possible. Following this, a site walk-through is given, highlighting locations of personal protective and emergency equipment. Company safety procedures are discussed and personal protective equipment is issued (i.e. coveralls, prescription safety glasses, hard hats, etc.). 9.3 ON-THE-JOB TRAINING After the initial orientation, employees receive regular on-the-job training. On-the-job training is a hands-on explanation and demonstration of how to do the job(s) to which the worker will be assigned. In addition, on-the-job training allows supervisors to refresh their workers previous training by repeating information learned earlier. All workers that are new to a job or work site should receive on-thejob training. It should be conducted when work procedures are changed or when reviewing safety requirements. An example for developing on-the-job training is provided in this section. 9.4 OPTIONAL AND NON-OPTIONAL TRAINING Additional optional and non-optional courses are suggested in Section 9.1 and may be completed by employees as they move through their training program. These must be initially approved by the Area Supervisor: Note: Well Servicing BOP Training For pump changes, etc. where it is not necessary to mount a BOP or move the tubing string, HARVARD supervisor does not require the Well Servicing Blowout Prevention certificate if at least one member of the rig crew on location at all times has the required certificate. However, if a job requires that the tubing be moved and the BOP s be utilized, then HARVARD supervisor must have the Well Servicing Blowout Prevention Certification regardless of the certification of the rig crew members. OPX Consulting Inc. Section 9-3

9.5 TECHNICAL TRAINING HARVARD encourages on-going technical training. 9.6 SUPERVISORY TRAINING Supervisors receive training in overseeing and managing technical work, including pertinent procedures and components of safety programs. Employees having potential to become supervisors may be identified and enrolled in supervisory training. 9.7 TRAINING RECORDS The majority of safety courses are valid for a three (3) year period. It is the operations manager s responsibility to ensure training is kept up-to-date and adequate training records are maintained. Certification must be maintained in the course that has an expiry date. OPX Consulting Inc. Section 9-4

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. Section 9-5

CHECKLIST FOR DEVELOPING AN ON-THE JOB TRAINING PROGRAM 1. Prioritize job needing on-the-job training: 5. Observe work doing the job for the first time: List all jobs for each worksite Review procedure Identify hazardous jobs (prioritize) Review tools Identify most important jobs Review critical tasks Finalize list of jobs meeting Review hazards and their controls On-the-job training Observe and coach Discuss observations with worker 2. Develop standards for each job: 6. Coach and train as required: Determine regulatory requirements Test progress with questions Check manufacturers standards / industry Perform critical point checks practices Conduct review Set time frame to perform job under normal conditions List special conditions 3. Develop procedures: 7. Observe worker doing the job independently: Include job standards and critical tasks Allow minor errors List tools required Stop only if critical List special abilities required Review, reinforce, evaluate, and then List job steps correct minor errors Identify hazard points and their controls Question understanding of procedures Choose critical checkpoints Schedule testing of critical checkpoints 4. Demonstrate job to worker: 8. Set schedule for review: Lay out procedure Follow-up commitment Lay out tools Spot check Explain procedure Set performance objectives Explain hazards and their controls Explain as you perform work 9. Continued communication: Respond to questions Communicate effectively Test worker Prepare report Page1 of 1

HS & E HANDBOOK REVIEW QUESTIONNAIRE Name (please print): Date: Company: HARVARD is committed to protecting the health and safety of all workers on our sites. Part of this commitment is the expectation that all workers be familiar with and follow standard guidelines and procedures. The initial step to accomplish this is an orientation to our Health, Safety & Environment Handbook. This review checklist is intended to ensure that workers have the basic knowledge associated with the HS&E handbook. Complete the following questions by either circling the correct answer or filling in the blank(s) if answers are not provided. It is acceptable to use the handbook to find the answers. Return the review checklist to your supervisor or HARVARD Representative. POLICY ON HEALTH, SAFETY & THE ENVIRONMENT 1) Who is responsible for protecting the health and safety of people and preserving the quality of the environment: a) employees b) management c) contractors d) everyone RESPONSIBILITIES FOR EMPLOYEES AND CONTRACTORS 2) If asked to perform a task that you believe would put yourself or other workers at risk of injury you should: a) carry on as usual b) refuse to perform the task c) be extra careful as you carry out the assigned task d) ask someone else to do the job for you 3) What must you do if you refuse to perform a task because there is imminent danger: a) leave the site immediately b) go have coffee c) notify the supervisor of your reasons d) reconsider and carry on with the task OPX Consulting Inc. Page 1 of 6

4) Local emergency phone numbers must a) not be worried about b) be confirmed and posted c) be memorized d) all of the above EMERGENCIES 5) It is recommended that at least one vehicle have a a) communication device b) siren c) flashing light d) high ground clearance to be able to get off the lease 6) Which of the following shows the correct emergency response actions? a) sound the alarm, protect equipment at all costs and then call for medical aid b) get out, sound alarm, assess situation, assist others, call for medical aid, secure the area, and protect equipment only if it is safe to do so. c) get out of the area and wait for someone to show up so you can tell them what happened d) try to fix what went wrong so no one will find out about it. 7) You must present yourself for work: INDIVIDUAL RESPONSIBILITIES & DUTIES a) physically fit b) mentally fit c) head and facial hair at a length that does not present a hazard d) all of the above 8) Smoking is permitted: a) in designated areas only b) where ever you want c) outside of buildings only d) beside vehicles only 9) You are not permitted to do which of the following at an HARVARD work site: a) to be under the influence of or in possession of drugs or alcohol b) to engage in practical jokes c) harass other workers because of their race, sex, age or religion. d) all of the above OPX Consulting Inc. Page 2 of 6

10) It is the Contractor s responsibility to: CONTRACTOR REQUIREMENTS a) provide all tools, safety equipment, proper clothing for their workers b) enforce all policies and procedures outlined in the HSE handbook c) take steps necessary to ensure the safety of your employees and sub-contractors d) all of the above 11) It is the Prime Contractor s responsibility to: a) ensure that appropriate first aid supplies and services are on site b) determine if an ambulance is required and where it is to be positioned c) ensure that workers are aware of the location of all first aid supplies d) all of the above PERSONAL PROTECTIVE EQUIPMENT 12) Two items of PPE that must be worn at all times on HARVARD locations are: a) face shields and leggings b) hard hats and safety footwear c) safety glasses and hearing protection d) all of the above 13) At work sites where there is a possibility for hydrocarbon release, clothing requirements include: a) fire retardant clothing as the outside layer b) natural fiber clothing such as wool or cotton as inner wear c) nylon outerwear d) both a & b HAZARDS 14) When lighting fired heaters and furnaces, face shields and gloves must be worn: a) true b) false 15) On any work site, before beginning any job or task: a) identify and document the hazards b) identify and implement control measures for all the hazards c) both a) and b) d) ignore the low risk hazards OPX Consulting Inc. Page 3 of 6

16) Prior to any work being done in an area containing a flammable substance, testing may be necessary: a) true b) false 17) When entering a sour location, employees are to ensure that: a) H 2 S monitoring equipment is turned on and used at all times while on location b) communication equipment is in good working order c) a breathing apparatus in working order and with an adequate supply of air must be available d) all of the Above 18) The term Hot Work refers to: a) any work that is done indoors or outdoors on a hot day b) any work where a flame is used or sparks and other sources of ignition could be produced c) work that requires you to take off your jacket and fire retardant clothes because increased temperatures 19) What is the maximum acceptable noise level on a worksite over an eight hour work period? a) 80 dba b) 90 dba c) 75 dba d) 85 dba 20) A written fall protection plan must be in place before work commences on a task where there is a potential of a fall of more than: a) ½ metre b) 10 metres c) 20 metres d) 3 metres MEETINGS AND COMMUNICATION 21) A pre-job Safety Meeting is the expected manner of ensuring permit requirements are known and workers are aware of all activities, hazards and applicable work practices. a) true b) false 22) Employers should hold regular safety meetings at least once a month for the following purposes: a) to report current accidents or diseases, their causes and prevention b) to see whose been slacking off on the work sites c) to determine if there are any matters pertinent to health and safety d) both a & c OPX Consulting Inc. Page 4 of 6

SAFE WORK PERMITS & CLEARANCES 23) Before beginning any work at a HARVARD location, you must determine if a work permit or work clearance is required. a) true b) false 24) A Blanket Work Permit refers to: a) a permit that is used for ongoing tasks where specific guidelines have been established b) a permit that is issued for a maximum of one year c) a permit that requires specialized blankets to keep the workers protected from the cold d) both a & b INSPECTIONS AND AUDITS 25) Unsafe working conditions found during inspections should be: a) fixed immediately or reported to a supervisor b) brought up at the next safety meeting c) ignored because everybody already knows it s a hazard ENVIRONMENT 26) Only supervisors are responsible for meeting regulations and industry guidelines: a) true b) false 27) We must all take necessary steps to prevent spills and control emissions: a) true b) false 28) A facility is considered sour at: a) 1 PPM H 2 S or greater b) 10 PPM H 2 S or greater c) 100 PPM H 2 S or greater d) 1000 PPM H 2 S or greater SOUR SERVICE 29) It is your responsibility to report all: a) wildlife sightings b) unsafe acts and/or conditions c) incidents and infractions d) b and c INVESTIGATING REPORTING INCIDENTS OPX Consulting Inc. Page 5 of 6

30) How soon must injuries be reported to a HARVARD representative? a) before anything else b) as soon as possible but within 24 hours c) within a week d) at the end of the job 31) Good housekeeping is: a) only a minor issue b) good to do when you have the time c) mandatory 32) Before handling chemicals you should: GOOD HOUSEKEEPING WHMIS/TDG a) review the MSDS sheet b) carefully breathe in the vapours to see if they are harmful c) make sure no one else is in the area d) move the chemicals outside DRIVING CONDUCT 33) In general all ATV (All Terrain Vehicle) riders must a) be competent in their ability to operate an ATV b) drive the ATV in accordance with local regulations c) possess a valid driver s license for insurance purposes d) all of the above 34) Driving incident are the leading cause of injury, fatalities and property damage in the oil and gas industry. a) true b) false OPX Consulting Inc. Page 6 of 6

ANSWER KEY HS & E HANDBOOK REVIEW QUESTIONNAIRE Name (please print): ANSWER KEY Date: Company: HARVARD is committed to protecting the health and safety of all workers on our sites. Part of this commitment is the expectation that all workers be familiar with and follow standard guidelines and procedures. The initial step to accomplish this is an orientation to our Health, Safety & Environment Handbook. This review checklist is intended to ensure that workers have the basic knowledge associated with the HS&E handbook. Complete the following questions by either circling the correct answer or filling in the blank(s) if answers are not provided. It is acceptable to use the handbook to find the answers. Return the review checklist to your supervisor or HARVARD Representative. POLICY ON HEALTH, SAFETY & THE ENVIRONMENT 1) Who is responsible for protecting the health and safety of people and preserving the quality of the environment: a) employees b) management c) contractors d) everyone RESPONSIBILITIES FOR EMPLOYEES AND CONTRACTORS 2) If asked to perform a task that you believe would put yourself or other workers at risk of injury you should: a) carry on as usual b) refuse to perform the task c) be extra careful as you carry out the assigned task d) ask someone else to do the job for you 3) What must you do if you refuse to perform a task because there is imminent danger: a) leave the site immediately b) go have coffee c) notify the supervisor of your reasons d) reconsider and carry on with the task OPX Consulting Inc. Page 1 of 6

4) Local emergency phone numbers must a) not be worried about b) be confirmed and posted c) be memorized d) all of the above EMERGENCIES 5) It is recommended that at least one vehicle have a a) communication device b) siren c) flashing light d) high ground clearance to be able to get off the lease 6) Which of the following shows the correct emergency response actions? a) sound the alarm, protect equipment at all costs and then call for medical aid b) get out, sound alarm, assess situation, assist others, call for medical aid, secure the area, and protect equipment only if it is safe to do so. c) get out of the area and wait for someone to show up so you can tell them what happened d) try to fix what went wrong so no one will find out about it 7) You must present yourself for work: INDIVIDUAL RESPONSIBILITIES & DUTIES a) physically fit b) mentally fit c) head and facial hair at a length that does not present a hazard d) all of the above 8) Smoking is permitted: a) in designated areas only b) where ever you want c) outside of buildings only d) beside vehicles only 9) You are not permitted to do which of the following at a HARVARD work site: a) to be under the influence of or in possession of drugs or alcohol b) to engage in practical jokes c) to harass other workers because of their race, sex, age or religion. d) all of the above OPX Consulting Inc. Page 2 of 6

10) It is the Contractor s responsibility to: CONTRACTOR REQUIREMENTS a) provide all tools, safety equipment, proper clothing for their workers b) enforce all policies and procedures outlined in the HSE handbook c) take steps necessary to ensure the safety of your employees and sub-contractors d) all of the above 11) It is the Prime Contractor s responsibility to: a) ensure that appropriate first aid supplies and services are on site b) determine if an ambulance is required and where it is to be positioned c) ensure that workers are aware of the location of all first aid supplies d) all of the above PERSONAL PROTECTIVE EQUIPMENT 12) Two items of PPE that must be worn at all times on HARVARD locations are: a) face shields and leggings b) hard hats and safety footwear c) safety glasses and hearing protection d) all of the above 13) At work sites where there is a possibility for hydrocarbon release, clothing requirements include: a) fire retardant clothing as the outside layer b) natural fiber clothing such as wool or cotton as inner wear c) nylon outerwear d) both a & b HAZARDS 14) When lighting fired heaters and furnaces, face shields and gloves are to worn: a) true b) false 15) On any work site, before beginning any job or task: a) identify and document the hazards b) identify and implement control measures for all the hazards c) both a) and b) d) ignore the low risk hazards OPX Consulting Inc. Page 3 of 6

16) Prior to any work being done in an area containing a flammable substance testing may be necessary: a) true b) false 17) When entering a sour location employees are to ensure that: a) H 2 S monitoring equipment is turned on and used at all times while on location b) communication equipment is in good working order c) a breathing apparatus in working order and with an adequate supply of air must be available d) all of the Above 18) The term Hot Work refers to: a) any work that is done indoors or outdoors on a hot day b) any work where a flame is used or sparks and other sources of ignition could be produced c) work that requires you to take off your jacket and fire retardant clothes because increased temperatures 19) What is the maximum acceptable noise level on a worksite over an eight hour work period? a) 80 dba b) 90 dba c) 75 dba d) 85 dba 20) A written fall protection plan must be in place before work commences on a task where there is a potential of a fall of more than: a) ½ metre b) 10 metres c) 20 metres d) 3 metres MEETINGS AND COMMUNICATION 21) A pre-job Safety Meeting is the expected manner of ensuring permit requirements are known and workers are aware of all activities, hazards and applicable work practices. a) true b) false 22) Employers should hold regular safety meetings at least once a month for the following purposes: a) to report current accidents or diseases, their causes and prevention b) to see whose been slacking off on the work sites c) to determine if there are any matters pertinent to health and safety d) both a & c OPX Consulting Inc. Page 4 of 6

SAFE WORK PERMITS & CLEARANCES 23) Before beginning any work at a HARVARD location you must determine if a work permit or work clearance is required. a) true b) false 24) A Blanket Work Permit refers to: a) a permit that is used for ongoing tasks where specific guidelines have been established b) a permit that is issued for a maximum of one year c) a permit that requires specialized blankets to keep the workers protected from the cold d) both a & b INSPECTIONS AND AUDITS 25) Unsafe working conditions found during inspections should be: a) fixed immediately or reported to a supervisor b) brought up at the next safety meeting c) ignored because everybody already knows it s a hazard ENVIRONMENT 26) Only Supervisors are responsible for meeting regulations and industry guidelines: a) true b) false 27) We must all take necessary steps to prevent spills and control emissions: a) true b) false 28) A facility is considered sour at: SOUR SERVICE a) 1 PPM H 2 S or greater b) 10 PPM H 2 S or greater c) 100 PPM H 2 S or greater d) 1000 PPM H 2 S or greater 29) It is your responsibility to report all: a) wildlife sightings b) unsafe acts and/or conditions c) incidents and infractions d) b and c INVESTIGATING REPORTING INCIDENTS OPX Consulting Inc. Page 5 of 6

30) How soon must injuries be reported to a HARVARD representative? a) before anything else b) as soon as possible but within 24 hours c) within a week d) at the end of the job 31) Good housekeeping is: a) only a minor issue b) good to do when you have the time c) mandatory 32) Before handling chemicals you should: GOOD HOUSEKEEPING WHMIS/TDG a) review the MSDS sheet b) carefully breathe in the vapours to see if they are harmful c) make sure no one else is in the area d) move the chemicals outside DRIVING CONDUCT 33) In general all ATV (All Terrain Vehicle) riders must a) be competent in their ability to operate an ATV b) drive the ATV in accordance with local regulations c) possess a valid driver s license for insurance purposes d) all of the above SAFETY PROGRAM MANUAL 34) Driving incidents are the leading cause of injury, fatalities and property damage in the oil and gas industry: a) true b) false OPX Consulting Inc. Page 6 of 6

10.0 CONTRACTOR OPERATIONS 10.1 OVERVIEW Each employer is responsible for the health and safety of their respective workers and compliance with the regulations for operations involving their workers. The Prime Contractor (see Section 2.0 Responsibilities) is responsible for coordination of the industrial health and safety activities of the multiple employers. When an operation on a company site requires the services of one or more employers, the operator or his representative as the Prime Contractor, shall be responsible for the safety of the operation and the coordination of each employers operations. In compliance with occupational health and safety regulations, HARVARD, insists on safe work performance throughout its operations, including those tasks carried out by contractors. Contractors must comply with government and Company safety regulations and must ensure that employees and sub-contractors are competent to perform their work properly. Procedures must be in place to ensure that loss exposures presented by the use of contractors are identified and controlled. This can be accomplished by identifying key activities in the selection, control and follow-up of contractor operations. 10.2 SELECTION HARVARD as Prime Contractor, will give serious consideration to past safety performance and membership in industry associations when selecting its contractors. All other factors being equal, a contractor with a better safety record, or one taking significant measures to improve its record, should be awarded contract work over others. All HARVARD documents and contracts should contain a section on safety, detailing HARVARD s contractors and sub-contractors safety specifications, requirements and guidelines. 10.3 CONTROL On the job site, reporting to HARVARD will provide leadership in safe work practices and ensure that all parties involved are knowledgeable of potential hazards and safety expectations. This requires that adequate communication be established between the Calgary office, the field office and contract personnel. 10.4 FOLLOW-UP Steps should be taken to verify that the contractor is implementing sound safety practices as required by their own safety programs, HARVARD guidelines and occupational health and safety regulations. Follow-up on any deficiencies noted, or recommendations made, should take place. Upon the completion of a contract, safety considerations should be taken into account in the evaluation of the contractor s overall performance. The criteria used in the selection, control and follow-up of contractors may vary slightly depending on the nature of the contract work. The following checklist provides suggestions for the kinds of activities that will help HARVARD utilize contractors in a safe and efficient manner. OPX Consulting Inc. Section 10-1

SECTION 10 FORMS Contractor Safety Evaluation OPX Consulting Inc. Section 10-2

CONTRACTOR SAFETY EVALUATION Contractor Name: Date: INSURANCE A. Certificate of Insurance B. $2 million minimum general commercial liability insurance C. $2 million minimum automotive liability insurance D. Worker's Compensation coverage Yes No SAFETY PROGRAM A. Has the contractor submitted a current safety program manual? B. Does the program meet the criteria of the base safety program? Yes No ACCIDENT HISTORY A. Workers Compensation: WCB Number: Statement Date: Employer Rate: Industry Rate: B. Occupational Health and Safety Statement Date: Employer Lost Time Rate: Industry Lost Time Rate: C. Lost Time Accidents in the Past 3 Years DATE DESCRIPTION D. Medical Aid Cases in Past 3 Years DATE DESCRIPTION Page 1of 1

11.0 HEALTH AND SAFETY CONTROLS 11.1 OVERVIEW Health and Safety controls within HARVARD are important for the continued protection of employees, contractors, and visitors to our operating facilities. The issues discussed in this section provide the necessary guidelines for compliance, or for the development of site specific rules and/or standards. All operational areas must review their existing programs and ensure they have identified and developed rules and standards for key health and safety issues: The programs must include: a. Storage and handling of controlled (hazardous) materials in order to comply with legislation under both the Workplace Hazardous Information Systems (WHMIS) and the Transportation of Dangerous Goods Control Act and Regulations (TDG). b. Occupational health programs. c. Personal protective equipment requirements and standards, such as purchases, use, maintenance, cleaning, fit testing and training. d. Availability of first aid facilities, supplies, and the appropriate training. e. Site-specific rules and general enforcement standards. 11.2 STORAGE AND HANDLING OF HAZARDOUS MATERIAL 11.2.1 Transportation of Dangerous Goods TDG regulations were brought into effect to promote safety in handling, shipping, transporting and receiving of dangerous goods by air, rail, road or marine modes. The regulations deal with five main areas: classification, packaging, documentation, safety marks and training. Anyone handling or transporting dangerous goods must be trained and certified. Goods regulated under TDG fall into nine classes. Some of these classes are further sub-divided depending upon the natural and degree of the hazard they present. Note: The legislation is Federal and is directed by the Transportation of Dangerous Goods Control Act and Regulations. OPX Consulting Inc. Section 11-1

11.3 OCCUPATIONAL HEALTH PROGRAMS 11.3.1 Hearing Conservation Workplaces with potential noise exposures higher than the designated limit must comply with provincial regulations, which usually require a hearing conservation program be implemented. Occupational exposure limits vary from province to province. HARVARD s hearing conservation program consists of: Employee noise exposure assessment; Proper use of hearing protection devices; Administrative and engineering noise controls; Audiometric testing; Education. See also Noise Exposure in Section 8.2.29 of this manual and the handbook. 11.3.2 Naturally Occurring Radioactive Materials (NORM) HARVARD is responsible for monitoring production facilities on a regular basis for abnormal radiation levels arising from NORM. Should circumstances warrant, appropriate control and hygiene procedures would be implemented to protect Company and contract personnel. See also NORM in Section 8.2.28 of this manual and the handbook. Reference can also be made to CAPP s Naturally Occurring Radioactive Material (NORM) Guide, June 2000. 11.3.3 Asbestos Control HARVARD employees, under normal circumstances, will not handle asbestos. The requirement for asbestos removal or containment is to hire a certified asbestos contractor, as required. A control program would aim to keep the concentration of airborne asbestos fibres within a facility well below the current permissible concentrations set out in most provincial occupational health and safety regulations. Before you begin any program dealing with asbestos, it is recommended that you review HARVARD s asbestos management plan, located in detail in 8.1.1 of this manual. OPX Consulting Inc. Section 11-2

11.3.4 Benzene Benzene is carcinogen. Exposure to high concentrations may lead to symptoms ranging from headaches to irritability to death. It is present in crude oil and natural gas condensate. The concentrations depend on characteristics of the well. Workplace exposure assessments are required to determine if benzene is a hazard requiring implementation of control measures. Workers may need to protect themselves from exposure by inhalation, ingestion and skin contact. Occupational exposure levels for Alberta are 0.5 ppm. Reference can also be made to CAPP s publication Managing Human Exposure to Benzene in the Upstream Oil & Gas Industry. As well as the developed code of practice on benzene in this manual 8.1.2. 11.4 PERSONAL PROTECTIVE EQUIPMENT 11.4.1 General Personal protective equipment helps reduce the consequences of worker exposure to various worksite hazards. This equipment must be worn by workers where a danger of personal injury exists. By means of hazard analysis, each area will develop written, site-specific standards on the use of PPE. HARVARD supplies necessary personal protective equipment for its employees and trains them in how to wear, fit, clean, and store this equipment. Contractors and sub-contractors are responsible for providing and maintaining personal protective equipment for their employees. Supervisors are responsible for ensuring employees and contractors are aware of and use appropriate PPE for each job. Note: Due to the nature of the workplace and the number of different hazards, it is not possible to cover specialized limb and body protection in detail. If in doubt about the selection or need for personal equipment, consult with HARVARD management and/or the Material Safety Data Sheet (MSDS). Refer also to the appropriate Regulation/Standard: Alberta OH&S Code, Part 18 British Columbia WCB Regulation, Section 14 Saskatchewan Occupational Health & Safety Act & Regulations Manitoba Workplace Safety & Health Regulations HARVARD Protective Clothing Standards HARVARD Respiratory Protective Equipment Code of Practice OPX Consulting Inc. Section 11-3

11.4.2 Head Protection CSA/ANSI approved hard hats must be worn by all personnel and visitors on Company worksites. 11.4.3 Eye and Face Protection Safety glasses must be worn when entering a process building, where there is a specific job hazard, or when directed by a HARVARD representative. Goggles and/or face shield must be worn where there is a specific job hazard (ie: when doing jobs where flying objects could harm the eyes). All eye and face protection must be CSA approved. 11.4.4 Hearing Protection Hearing protection for work environments with noise levels exceeding regulated levels (Alberta - greater than 85 dba) or as indicated by signage. The protection must attenuate noise levels to below occupational exposure levels. 11.4.5 Hand Protection Gloves must be worn when handling sharp objects or chemicals or as required by HARVARD representative and/or job hazard. Gloves must address hazards specific to the task. 11.4.6 Body Protection Fire resistant work wear must be worn at all times when at a hazardous location. Chemical suits must be worn when mixing chemicals. 11.4.7 Respiratory Equipment Breathing apparatus is required for toxic and oxygen deficient environments. A dust mask for silica protection is also required. A Code of Practice for respiratory equipment is developed. 11.4.8 Foot Protection Safety boots must meet CSA Class 1, or ANSI standards. To comply with OH&S requirements for the oil and gas industry, the safety boots must have non-canvas uppers and completely cover the ankle. OPX Consulting Inc. Section 11-4

11.4.9 Fire Retardant Clothing Standard PURPOSE The purpose of this standard is to establish employee clothing standards to minimize burn-related injuries liable to be caused by the wearing of unsuitable clothing in areas where there is a significant potential for a flash fire. SCOPE For the purpose of this standard, all wells sites from spud to abandonment and all Oil and Gas facility sites are considered hazardous locations. This standard applies to permanent and temporary employees as well as contract personnel and visitors. Additional personal protective equipment for the protection of hands, face, feet and head shall be worn as appropriate. REQUIREMENTS This standard acknowledges the existence of two levels of risk: Level I Attendance by an individual at a location where: 1. There is no direct involvement in the operations. 2. There is constant supervision. 3. There are no activities being carried out at the location which increase the potential for hydrocarbon release. Personnel in this category are not required to wear fire retardant outerwear. However, they are not permitted to wear nylon or other synthetic, static generating materials. Acceptable clothing is made from cotton, wool, or leather. Short sleeved shirts and shorts are not considered acceptable. An example of someone in this category would be individuals taken on a tour of a facility. Level II Personnel who are in attendance or working at a Hazardous Location and directly involved in supervision, drilling servicing, construction, operation, maintenance or repair of wells and facilities at that location shall wear acceptable fire retardant outer wear at all times and must refrain from wearing unsuitable fusible fabrics, such as nylon, as inner wear. Long pants and long sleeve shirts under fire retardant outer wear provides an additional layer of insulation with increased protection in the event of a fire and therefore should be worn in most cases. However, in cases of extreme heat, this may not be practical and under these circumstances shorts and short sleeve shirts are permissible. OPX Consulting Inc. Section 11-5

ADMINISTRATION HARVARD or HARVARD s designated Field Supervisors are responsible for ensuring that all work activities are carried out in accordance with the requirements of this policy. Failure to comply with this standard will result in disciplinary action being taken. Clothing must be in conformance with HARVARD policy. 11.4.10 Prescription Safety Glasses Purchase Procedure 1. Prescription safety glasses will be available for all qualifying employees. 2. Frames must be a CSA certified safety frame. The optical dispenser will be able to advise which frames qualify. Certain tasks may also require the utilization of side shields. 3. Lenses shall be made from CR-39 or Polycarbonate material. A scratch resistant coating will be applied to the lenses. No glass lenses will be issued unless extenuating circumstances prove that there is no other alternative. The use of tinted and photo chromatic lenses are not allowed unless they are recommended by the attending Optometrist. Note: All extenuating circumstances should be discussed with the appropriate Department Manager prior to making a purchase. 4. An employee requiring safety glasses should obtain a completed and signed authorization form from the Area Supervisor, or in the case of Calgary based employees, the Department Manager. Forms are available by contacting the Department Manager. 5. Employees may go to any dispensing Optometrist in the Province and present the signed authorization form. If the services of an Ophthalmologist are required, the employee should obtain a prescription form from that physician and to a dispensing Optometrist to have the glasses provided. 6. Eye examination charges are the responsibility of the employee. OPX Consulting Inc. Section 11-6

11.5 RULES AND ENFORCEMENT 11.5.1 Overview HARVARD has adopted a number of written policies and standards which govern virtually all aspects of HARVARD s operations. They are designed to ensure that HARVARD S operations are conducted in a reasonable and responsible manner relative to its employees, shareholders and the public. All employees are expected to follow HARVARD Health, Safety and Environment Policy and pertinent government legislation. Applicable legislation consists of Occupational Health and Safety Act, Workers Compensation Acts, Provincial Fire Codes, Provincial Energy Regulations (ie: ERCB, BCOGC, SER), Highway Traffic Act, TDG Control Act and Regulations, and Labour Standards. Management and supervisors must notify workers of all government acts and regulations as well as site or area specific rules. It is the worker s responsibility to understand and comply with all government and Company rules that are applicable. Copies of the Policy on Health, Safety and Environment and The Petroleum Industry Guiding Principles for Worker Safety are provided in the Introduction section of this manual. 11.5.2 Enforcement Guidelines In instances where the policies and standards are not complied with, it is essential that there be an equitable and consistent enforcement and disciplinary procedure. Safety rules are enforced first through proper orientation and on-the-job training and communication; and second, through disciplinary measures that will be taken against those who fail to comply with them. HARVARD s prevention program is a positive one. HARVARD has adopted an approach which places an emphasis on coaching and problem solving. OPX Consulting Inc. Section 11-7

12.0 MANAGEMENT COMMUNICATION & PROGRAM AUDITING 12.1 MANAGEMENT COMMUNICATION Safety regulations in each province specify that the employer has the responsibility to develop, implement and maintain a program which prevents injuries and diseases in the place of employment. To safely complete its activities, HARVARD has a responsibility to: Develop, implement and maintain a safety program. Ensure that supervisors safety responsibilities are clearly established and monitored. Ensure key hazards are identified, documented and communicated in project planning and field work. Coordinate health and safety at job sites emphasizing emergency procedures. Provide visible management support for work of supervisors with respect to safety. HARVARD is committed to safety excellence in every operation. By working together; workers, contractors, supervisors and management can keep the workplace accident free. Management communicates its commitment through the following: Company Policy Statement This commitment to safety is clearly outlined in HARVARD s Policy on Health, Safety and Environment. This policy is included in the Introduction of the manual and is posted throughout the workplace to remind workers of the importance of safety. Guiding Principles Both HARVARD and its contractors have a responsibility for protecting all workers within the oil and gas industry. Five petroleum industry associations, representing both contractors and operating companies, have established a set of guiding principles and has them posted at worksites. HARVARD supports these guiding principles and has them posted at worksites. Safety Responsibilities The general safety and loss control responsibilities required to implement HARVARD Safety Program are identified in this manual. Management and supervisors at all levels are responsible for ensuring that specific responsibilities are identified and communicated effectively to all employees and contractors. These responsibilities are used to set standards for performance evaluation. OPX Consulting Inc. Section 12-1

General Communication Company management will provide and assume a leadership role in the promotion of safety through policies, guidelines, loss control meetings, monthly reports, and other communications. In addition, a Safety and Environment Review Committee is established to provide guidance and support to HARVARD s Safety Program. Management will conduct walk-arounds on work sites to observe operations and talk to employees about safety concerns. Employees should present any safety concerns to management during these walk-arounds. OPX Consulting Inc. Section 12-2

SECTION 12 FORMS Health, Safety and Environment Management Review OPX Consulting Inc. Section 12-3

HEALTH, SAFETY AND ENVIRONMENT MANAGEMENT REVIEW Contractor Company: Address: Date: Phone: Service Provided: Location: Issued By: Harvard Representative Phone: Received By: Contractor Representative Phone: Note: If unsatisfactory is selected, an explanation must be provided in the Comments section. The contractor is responsible to ensure that all deficiencies in this inspection are corrected. Management Involvement Not Applicable (NA) Unsatisfactory (U) Satisfactory (S) U S 1. Is there a written safety program (company manual)? 2. Does management regularly tour worksites to observe work practices and site conditions? (When) Comments: Records Management and documentation 1. Is all critical data for operation and environmental concerns stored onsite and updated? Comments: Quality Management 1. Is there a Quality Management system and do contractors follow that system? Comments: Communication 1. Is the permit system being used? (ie:safe work permits, hot work permits) 2. Are Loss Control Meetings taken place in a timely manner? 3. Are Risk Management and OH&S bulletins posted and discussed? Comments: Emergency Response Planning 1. Is the area emergency Response Plan in place and up-to-date? 2. Are there regular exercises and training to implement the ERP? Comments: Hazard Identification Control 1. Are Equipment and vehicles inspected and at what frequency? (Show examples and completed documentation.) 2. Is there a system for hazard assessment, reporting and follow-up (written or verbal)? Comments: Page 1 of 3

Rules and Work Procedures U S 1. Are there procedures for high risk or critical work? Are they available and used? 2. Are there written emergency plans available and communicated to personnel at the work site? i) ERP ii) Emergency Transportation Plan iii) Working Alone Comments: Incident Reporting 1. Do you have an incident reporting process? 2. Do you have a near miss/incident reporting form that includes follow-up? 3. Are incidents reported and was the problem rectified the previous near miss or accident, and were management and workers involved in the solutions? Comments: Training N/A U S 1. Have you received a safety orientation? (What and When) 2. How often are Loss Control meetings held? (Show examples and documentation) 3. Is the appropriate training in place? 4. First Aid Training 5. H 2 S Training 6. WHMIS Training 7. TDG Training 8. Fire Extinguisher or Fire Fighting Training 9. Job Specific Training/Certification Personal Protective Equipment N/A U S 1. Is the appropriate PPE available and being used? 2. Hard Hat 3. Safety Glasses or Eye Protection 4. Footwear 5. Protective Clothing 6. Hearing Protection 7. Respiratory Protection (For the Nature of the Hazard) 8. Personal Monitor or H 2 S Detector 9. Communication Equipment Comments: Safety Equipment N/A U S 1. Is the appropriate Safety Equipment available and being used? 2. Fire Fighting Equipment (ie: inspected, tagged, accessible and condition) 3. Rotating Equipment Guards 4. First Aid Kit 5. Fall Arrest Equipment (including ladders, steps or stairways, safety belts and lanyards) 6. Bonding and Grounding Equipment 7. Emergency Shut Down and Alarm Systems (including diesel positive air shutoffs and backup alarms) Comments: Page 2 of 3

Contractors N/A U S 1. Is the contractor aware of the safety expectations and standards of the Corporation? Comments: Environmental, Storage and Handling 1. Are potential environmental concerns addressed and corrected? 2. D-58 Compliance (Proper waste storage, ie: filters, contaminated soil and fluid. Show waste manifests.) 3. D-55 Compliance (ie: double walled tanks, tank condition, secondary containment.) Comments Note: The following questions must be completed by the Harvard Issuer. Does this Management Review warrant a follow-up work site inspection by a Harvard Representative? YES NO Instructions for Health, Safety and Environment Management Review. Purpose 1. Harvard representatives hiring contractor(s) are obligated to ensure that the contractor(s) is working within the terms and requirements of the job of project. The Management Review is designed as the go see step in the process of establishing Harvard due diligence. The frequency of the review is dependent on the knowledge and experience of the contractor(s), the nature of the work and the associated hazards. 2. The review is designed for use by a Harvard Representative with the questions focused in the area of the contractor s work site safety management and the minimum Corporation and Regulatory requirements. 3. The review is designed as a mechanism to trigger a more detailed inspection coordinated by the Corporation should the results of the review not meet expectations. 4. The intent is to improve contractor work site safety performance in alignment with the Harvard HSE program Process 1. Harvard Representative conducts a Management Review for Contractor. 2. Leave copy with Contractor to manage any follow up. 3. Harvard Representative completes bottom section which identifies whether or not the Contractor requires a more detailed inspection by Corporation. 4. Harvard Representative will forward a copy to Harvard Calgary Office. 5. Harvard Calgary Office will coordinate follow up inspection of the contractor. PHOTOCOPY DISTRIBUTION: Contractor Harvard Representative Harvard - Calgary office Page 3 of 3

13.0 RECORDS MANAGEMENT AND DOCUMENTS 13.1 OVERVIEW To demonstrate compliance with the regulations, a copy of relevant safety records must be available including safety meetings, inspections, investigations, and work procedures. Field/contract supervisors should have copies of the relevant legislation at the work site. Our work is governed by a variety of regulatory requirements. Safety legislation and Company rules/ guidelines are designed to protect workers, the public and the environment. Noncompliance with these standards could result in personal injuries, fines, legal proceedings and/or Company disciplinary actions. Standards should be made part of day-to-day operations as much as possible but there is some basic information that should be kept on hand for reference purposes. There are many facets to HARVARD s Safety Program and consideration must be given to keeping records of the activities that are carried out in support of the program. Some of these activities may be easily kept track of in a personal diary (e.g. an informal safety inspection) while others require a more formalized method. The purpose of the records is to: Manage an effective program. Comply with legislated standards. Allow for consistent measurement against a set of operating parameters. Provide documentation in the event of legal proceedings. Provided in Section 13.4 is a list of key records that should be kept, and some indication of how long, for each element of the Safety Program. 13.2 MANAGEMENT OF CHANGE Changes in operations, procedures, site standards, facilities or personnel must be evaluated and managed to ensure that safety and environmental risks arising from these changes remain at an acceptable level. Similarly, changes in laws and regulations must be reflected in facilities and operating practices to ensure ongoing compliance. All changes that are made should be properly reflected in the appropriate documentation. This can be accomplished by: 1. Thoroughly reviewing and documenting changes to standards, processes and/or equipment. 2. Providing support and training to employees who are affected by the change. 3. Reaffirming responsibilities and accountabilities when staff changes occur. 4. Identify changes in laws and regulations and reflect those changes in facilities as required. OPX Consulting Inc. Section 13-1

13.3 REFERENCE DOCUMENTS Include, but are not limited to: 13.3.1 Company Documents 1. Safety Program Manual 2. Emergency Response Manual (if applicable) 13.3.2 Government Documents Alberta 1. Occupational Health and Safety Act, Regulation, and Code 2. Public Safety Services Act 4. ERCB Pipeline Act and Regulations 5. W.C.B. Act 6. Personal Information Protection Act British Columbia 1. Workers Compensation Act 2. Occupational Health and Safety Regulations 3. Industrial First Aid Regulations 4. Occupational Safety and Health Policy and Procedure Manual 5. OGC s Oil and Gas Handbook 6. Health Act Industrial Camp Health Regulations 7. Personal Information Protection Act Manitoba 1. The Workplace Health & Safety Act and Regulations 2. Manitoba The Oil & Gas Act 3. WCB Act 4. Freedom of Information and Protection of Privacy Act Saskatchewan 1. Occupational Health & Safety Act and Regulations 2. Worker s Compensation Act 3. Pipeline Act & Regulations 4. Oil & Gas Conservation Act 5. Freedom of Information and Protection of Privacy Act Federal 1. Transportation of Dangerous Goods Act and Regulations 2. Canadian Standards Association regulations (ie: Z-731, Z-622) 3. Canadian Environmental Protection Act OPX Consulting Inc. Section 13-2

13.3.3 General Documents 1. CAPP Users Guide for Permits of Equivalent Safety 2. CAPP Guidelines for Entry into Confined Spaces 3. CAPP Guidelines for Respiratory Protective Equipment 4. CAPP Guidelines for Mutual Aid Agreement for Emergency Responses 5. Alberta Industry Recommended Practices 13.4 RECORD KEEPING It is important that a complete record of all safety meetings both at the field level and at the corporate level be kept on file for possible review by corporate and regulatory personnel. It is suggested that all field safety meeting records be submitted to the head office at the completion of each project. Files should be established with retrieval capability on a project basis. In addition, and probably more important is the requirement to record and file hazard identification and incident reports. Statistics must be kept on incident type and frequency for comparison with industry and corporate goals. FILE COMMENTS 1. WORK SITE HAZARDS ASSESSMENTS AND INSPECTIONS a. General Safety Inspections - Keep on file for 2 years. b. Safety Equipment Inspections (Fire extinguishers, breathing apparatus) - Keep on file for at least 2 years. c. Loss Prevention/Boiler and - Keep on file for 3 years or Machinery Inspections until all recommendations have been completed, whichever is longer. d. Process Hazard Analysis Reports - Keep in permanent file. 2. QUALITY MANAGEMENT PLAN (If Applicable) The Quality Management Plan Manual should be consulted for record keeping requirements. 3. MEETINGS AND COMMUNICATIONS a. Safety Meeting Minutes - Keep on file for 3 years. b. Work Permits - Keep on file for 2 years. c. Risk Management Bulletins - Depending on Nature of Document and other Safety Communications 4. ENVIRONMENT Incident Reports and Spill Clean-up Records - Permanent file. OPX Consulting Inc. Section 13-3

5. WORK PROCEDURES Site Specific Work Procedures and - It is suggested that there is a Codes of Practice permanent file for current procedures as well as a revision file. Consideration should also be given to an archive file for all procedures. 6. WORKER HEALTH AND SAFETY a. Audiometric Test Results - Due to the confidential nature of these results the records are kept at the head office with a copy sent directly to the employee. b. Workers Compensation Claim - Permanent file. (lost time and medical aid) c. TDG Declarations - File for 2 years. d. Site Specific Rules and Regulations - Permanent file. e. MSDS - Permanent file kept current. 7. CONTRACTOR OPERATIONS a. Approved Contractor List - Permanent file that is kept current. b. Contractor Evaluations - Permanent file that is kept current. 8. EMERGENCY RESPONSE PLANNING - A revision file to track changes to Emergency contact numbers, resident information and mapping. 9. TRAINING a. Safety Orientation - Copy to permanent file. b. On-the-Job Training - Permanent file. c. Non-certifiable Safety Training - Keep on file for 3 years or (Fire Fighting, WHMIS, ERP Training) until up-dated training is received, whichever is longer. d. Certifiable Core Safety Courses - The expiry date for these (First Aid/CPR, H 2 S, TDG) is 3 years. e. Other Training - Permanent file. OPX Consulting Inc. Section 13-4

10. INCIDENT INVESTIGATION AND ANALYSIS a. Incident Reports - 3 Year file unless an injury or third party is involved and then use discretion to determine if it should be kept in permanent file. 11. MANAGEMENT COMMUNICATION AND PROGRAM AUDITING a. Safety Audit Reports - File for 3 years or until the next audit is conducted (whichever is later). OPX Consulting Inc. Section 13-5

14.0 ENVIRONMENTAL STANDARDS AND GUIDELINES 14.1 OVERVIEW SAFETY PROGRAM MANUAL Operating in an environmentally responsible way and complying with the law are priorities for HARVARD. Our Policy on Health Safety and the Environment emphasizes the responsibilities for ensuring that good environmental practices are followed. As a minimum, all employees should ensure they do the following: 1. Identify environmental requirements for the job. 2. Obtain all required regulatory approvals prior to commencing work. 3. Provide the required equipment and procedures to manage the environmental impacts of operating activities and prevent pollution. 4. Ensure that all incidents are reported to the Calgary head office. Begin clean-up immediately and, if necessary, obtain direction as to the proper methods needed to reduce any negative impact. Supervisors are responsible for ensuring that environmental issues in their area are identified and addressed. To ensure all concerns are addressed promptly, supervisors should review environmental issues at every safety and environment meeting. The key environmental concerns related to HARVARD s drilling and completion/production operations include: Proper storage of hazardous chemicals and products Managing and reducing drilling and completion wastes Preventing and controlling releases to land and water Conserving energy and water Minimizing releases to the atmosphere Protecting local habitat, wildlife and other local environmental and community issues The following programs have been developed by HARVARD to help manage environmental issues. 14.2 WASTE MANAGEMENT Improper handling and disposal of oilfield wastes leads to costly remedial measures. Many of today s expensive reclamation problems are the result of previous sub-standard practices. Even if wastes are shipped off-site for disposal by third parties, HARVARD may still be responsible for environmental problems caused by these wastes. OPX Consulting Inc. Section 14-1

DRILLING WASTE Wastes generated from drilling operations at the lease are divided into non-sump wastes and sump wastes. The following regulatory directives govern the management of these two types of waste: ERCB D - 50 -Sump Wastes (wastes from downhole - cuttings, muds, etc) ERCB D -58 -Drilling Maintenance (used oil, coolants, solvents, filters, domestic refuse) The focus of D-50 and D-58 is to place responsibility for waste on the generator. Once a waste has been generated the generator is responsible for the waste from cradle to grave. Properly characterizing, tracking and disposing of waste will demonstrate compliance of HARVARD 'S Waste Management System with these regulatory initiatives. Properly managed sump waste includes: Developing a drilling plan (determining appropriate disposal method) Sampling the sump (characterization) Notification to proper regulatory authorities Copies of all submissions are to be forwarded to the Calgary Office. Submitting forms for the Drilling Waste Database to HARVARD office will allow HARVARD to demonstrate compliance and ensure wastes are tracked. The management of non-sump wastes includes: Selecting an approved contractor Completing a HARVARD Waste Tracking Form for Non-DOWs Completing a manifest for DOWs and regulated waste (ERCB manifest in AB, provincial manifest in BC, SK & MB) Submitting these completed forms to the Calgary Office Completing a manifest or tracking form occurs only when waste is sent off a lease for disposal or treatment. This form does not need to be completed when transferring waste from one drill site to another. For additional information regarding non-sump waste, reference the Waste Management Manual for drilling. For additional information or assistance contact the Calgary Office directly. PRODUCTION WASTES Under the AEPEA, the Waste Control Regulation (AR 192-96) provides for management and disposal of Hazardous Wastes in Alberta. Oilfield wastes are exempt from this Act and the Regulation. Instead they are regulated by ERCB rather then by Alberta Environment. Within the upstream petroleum industry, wastes that would be considered hazardous wastes are termed dangerous oilfield wastes. In British Columbia, special wastes are classified in a similar way to hazardous wastes in Alberta, with a few exceptions. The following are the two most significant exceptions: There is no exemption for wastes produced by the oil and gas industry. Any wastes containing greater than 3% oil by weight are classified as special wastes. OPX Consulting Inc. Section 14-2

In Saskatchewan, oilfield production wastes are regulated by Saskatchewan Energy and Resources (SER) under the Oil and Gas Conservation Act and Regulations and by Saskatchewan Environment under the Transportation of Dangerous Goods Act. Wastes can not be stored or disposed of in such a manner as to cause pollution of soil or groundwater. Waste Management Guidelines for the Upstream Oil and Gas Industry (SPIGEG Guidelines No.1) were introduced in February of 1996. SER and Saskatchewan Environment approved oilfield waste management facilities. They will be permitted for specific types of oilfield waste. The ERCB is committed to ensure that oilfield wastes are managed to at least an equivalent standard of care as other industries that are regulated by Alberta Environment (AE). The ERCB prescribes several policies, including: Encourage the 4R s (reduce, reuse, recycle, recover). Waste management is to be integrated into all design and operation decisions. Oilfield wastes will be regulated to equivalent standards of other industries. WASTE CHARACTERIZATION The first step in managing wastes is to characterize and classify the material. Characterization is the assessment of a waste. There are two main reasons for characterization; first, to determine the hazards relating to transportation and second, to determine the environmental consequences of the waste so that a disposal or management option that appropriately deals with those consequences may be used. ERCB Directive 58 provides details for characterizing wastes. Depending on chemical properties such as flammability, spontaneous combustion, toxicity and other criteria, some wastes will be classified as dangerous oilfield wastes. It is the responsibility of the waste generator to ensure that each waste has been properly identified, characterized, and is handled, treated and disposed of correctly. It is possible to divide oilfield wastes into three major categories. Dangerous oilfield waste; Not a dangerous oilfield waste; or Testing required. Directive 58 describes the criteria to classify wastes according to their properties: Flammability (TDGR Classes 4, and 4.1) Spontaneous Combustion Potential (TDGR Class 4.2) Water Reactive (TDGR Class 4.3) Oxidizing Substances and Organic Peroxides (TDGR Class 5) Toxicity (TDGR Class 6.1) Corrosive (TDGR Class 8) PCB Content (TDGR Class 9) Leachate Toxicity (TDGR Class 9.3) Once the waste has been classified, the generator can then decide on the best method of treatment and disposal. Handling and shipping must be done in accordance with TDG Regulations. OPX Consulting Inc. Section 14-3

Dangerous oilfield wastes are regulated for the transportation by the Transportation of Dangerous Goods Act and also require an Alberta Waste Manifest for disposal. WASTE MANIFESTING Records must be kept of wastes destined for treatment, transportation and disposal. Refer to Directive 58-Oilfiield Waste Management Requirements for the Upstream Petroleum Industry. A manifest is a document that must accompany dangerous oilfield wastes when they are transported. Most upstream petroleum industry wastes will be classified as Dangerous Goods due to flammable or corrosive properties and will therefore be required to meet the manifest requirements of the TDG Regulations. 14.3 AUDITS AND INSPECTIONS An inspection checklist for drilling/completions and construction operations is included in this section. The purpose of the checklist and sub-section 1.1 is to review these operations and ensure they are in compliance with regulatory guidelines and industry standards. These inspections will be carried out on an ongoing basis and contractors will be notified of the inspection schedule. 14.3.1 ENVIRONMENTAL IMPACTS Understanding and managing potential environmental impacts associated with Company operations is essential. As a Company, there is a growing requirement to: Demonstrate commitment to the environment. Identify and deal with the environmental issues related to our operations. Raise awareness of the organization s environmental policies and objectives. Inform internal or external interested parties about HARVARD s environmental commitment and performance as appropriate. To minimize or prevent negative environmental impacts, HARVARD has established and maintains a series of environmental programs. These programs can be classified as follows: Land Use Management Air Quality Protection Resource Conservation Soil/Water Quality Protection Waste Management Risk Management A summary of the current and required programs is provided below. For each of these programs, operational controls need to be established to ensure our environmental performance is consistent with Company policies and objectives. The need for environmental programs and controls is an ongoing process determined by past, current and potential future impacts of our activities. Additional programs can be developed and implemented as the need arises. OPX Consulting Inc. Section 14-4

14.3.2 COMMUNICATION AND REPORTING SAFETY PROGRAM MANUAL Changing regulations are shifting the emphasis to companies policing their own activities. As a result, the requirements for monitoring, communicating and reporting environmental activities and performance is increasing. NOW is the time to begin to build working relationships with government agencies and residents NOT when there is a problem. Regular contact with local government agencies to clarify expectations and improve environmental performance is important. Remember too, the public and other stakeholders have a legal right to be informed. It is important to let our neighbours know about and contribute to matters that affect the environment, their lives, families and communities. Neighborly communication is good business and the benefits far exceed that of addressing any specific problem. 14.3.3 ENVIRONMENTAL MANAGEMENT SYSTEM The programs outlined above are a key part of the overall environmental management system our Company is expected to develop to deal with specific issues. All programs should outline standards and guidelines for consistent Company wide environmental performance including: 1. Identify key environmental issues and the strategy for dealing with these issues. 2. Identify the responsibilities for achieving environmental objectives and targets. 3. The means and time frame by which they are to be achieved. To ensure the effectiveness of our environmental efforts, a program of audits and assessments will be maintained to monitor the impact of our activities and our compliance with relevant environmental regulations. OPX Consulting Inc. Section 14-5

14.4 Procedures 14.4.1 ENVIRONMENTAL PROTECTION Drilling Waste Management PURPOSE Effective drilling waste management minimizes environmental impacts form drilling operations and drilling waste disposal. BACKGROUND Drilling rigs and service rigs have the potential to contaminate soil or groundwater by spilling chemicals or drilling mud. CONSIDERATIONS The Directive 50 Drilling Waste Management describes methods for drilling waste management disposal and IL 2001-03 Management of Drilling Wastes Associated with Advanced Gel Chemical Systems. LANDSPREADING Landspreading is a disposal method in which waste is spread over a predetermined land area based on an acceptable loading rate, and is incorporated into the soil. Landspreading is usually done on the drilling lease. Its goal is to dispose of waste in a manner that preserves the soil s chemical, biological and physical properties and protects the quality of surface water and groundwater. Typical methods for landspreading are: Ripping subsoil to a depth of 50 cm (or less), then spreading and incorporating the waste on-site. Spreading (squeezing) the waste on-site, drying and incorporating to a depth of 50 cm (or less). Applying liquids or solids on cultivated land (off-site) and incorporating them by cultivating. Note: Liquids are defined as wastes that have less than 1,200kg/cubic metre mud weight (s.g. <1.20). Solids are defined as wastes that have greater than 1,200 kg/cubic metre mud weight (s.g. >1.20). Total waste is defined as Liquids and Solids combined as one material. OPX Consulting Inc. Section 14-6

MIX-BURY-COVER Mix-bury-cover (MBC) is a disposal method whereby sump solids (and sometimes liquids or the total waste) are stabilized and diluted by mixing with subsoil. The ratio of soil to waste is at least three parts soil to one part waste. The soil/waste mixture is then placed into the original sump or other PITS where the base of the final soil/waste mixture is at least 1m above the water table or a layer of impermeable material and is covered with at least 1m of clean subsoil, and then with the original surface soil. The goal of MBC is to incorporate waste, (meeting the required criteria) into the soil below the major rooting zone and above the water table in a manner that preserves soil chemical properties and protects groundwater quality. Typical MBC methods are: Mixing waste and soil in the sump and covering. Mixing waste and soil on the surface, putting the mixture back in the sump and covering. Mixing waste and soil, putting the mixture into a new pit and covering. Bailing the waste onto the surface, mixing with the soil, and burying when filling a cut. Spreading wastes on a surface, allowing them to dry, putting the wastes back into the sump, mixing and covering. PUMPOFF (LIQUIDS ONLY) Pumpoff is a disposal method in which drilling waste fluids are applied offsite onto vegetated land. The waste is not incorporated into the soil. The goal of pumpoff is to dispose of the liquids in a manner that preserves the chemical, biological and physical properties of the soil, does not harm the vegetation and protects the quality of surface water, groundwater and vegetation. Because it is done off-site, pumpoff allows access to a larger spread area. Typical pumpoff methods are: Pumping through hoses or irrigation equipment (big gun, sprinklers, grated pipe, perforated hose). Vehicle application (vacuum trucks, Terragator, wagons, etc.) with a spray bar or deflector plate. OPX Consulting Inc. Section 14-7

LANDSPREADING WHILE DRILLING Landspreading while drilling (LWD) is a disposal method in which drilling wastes from approved mud systems are spread off-site at low application rates usually during the drilling phase of the well. Drilling wastes are normally spread on agricultural land using a variety of techniques (vacuum trucks, Terragators, wagons, etc.) at a thickness usually less than 5mm. The goal of this disposal method is to dispose of drilling wastes in such a manner that soil and vegetation are not adversely impacted and the quality of surface water is protected. Mud systems presently approved for LWD are: Fresh Water Gel Gypsum Water Nitrate Gypsum Water Any other mud systems proposed for LWD must be proven to the appropriate regulatory office by a Microtox bioassay. Fluids recovered from drill stem tests and cement returns must be isolated from the drilling wastes and may not be disposed of by LWD. Cement returns may be buried under 1m of clean fill. Drill stem test fluids must be conserved or disposed by the other disposal methods. LANDFARMING Landfarming is a waste treatment/disposal method whereby a single application (or multiple applications from one waste source) of biodegradable waste is made on a dedicated parcel of land. The land is managed in a manner which allows the soil system to degrade, transform and assimilate the waste constituents. The landfarming site may be used only once. The goal of landfarming is to biodegrade the organic constituents in a waste using natural soil processes in a manner that protects soils and groundwater quality. Elevated oil contents may arise when hydrocarbon based systems are used or drilling conditions result in the unforeseen production of hydrocarbons. Landfarming may be used for wastes where landspreading or MBC oil criteria cannot be met. Wastes that require landfarming may have high salt contents, thus management practices must deal with both the salt and the organic constituents. OPX Consulting Inc. Section 14-8

Landfarming may be done in either the topsoil or the subsoil. Landfarming is an active practice that requires frequent tillage and application of nutrients to break down the organic constituents in the waste. Organic amendments (manure, straw) are added to increase biological activity and aeration of the soil. Frequent sampling and analysis may be necessary to monitor the progress of the remediation. TESTING AND DISPOSAL PROCEDURES For each of the five disposal methods D-50 describes: Testing Requirements Sampling and Analysis Calculation of Spreading Rates Disposal Criteria Notification The option of subsurface disposal of drilling waste liquids in accordance with ID 81-1 has been retained, provided the disposal zone is deeper than the deepest potable water zone. Other disposal options must be approved by the appropriate regulatory agencies. In these cases, a detailed plan must be provided that will meet environmental protection and reclamation requirements. WASTE MANAGEMENT Look for opportunities to minimize waste by re-use of materials or containers and by using recyclable materials. Order chemical in bulk. Return empty containers to the supplier. Choose non-hazardous materials whenever possible. Segregate waste for proper disposal. Waste fluids must be properly disposed of at an approved ERCB waste management facility. RELEASE PREVENTION Inspect service rigs for leaks at valves, fittings, pumps, tanks, etc. Provide adequate containment for all fluids, including those that can be produced from the formation. Do not dump the contents of rig or other tanks on-site. Prevent all wash fluids from spilling on the ground. MISCELLANEOUS Keep lease site clean at all times. Domestic wastes should be kept separate from rig wastes. Keep all rig wash and chemicals out of the sump. Collect used lube oils for recycling. Oil filters and oil rags should be separated from other wastes for proper disposal. OPX Consulting Inc. Section 14-9

Pick up garbage and place in suitable storage containers on-site. Garbage should be taken for disposal to an approved landfill. Use environmentally friendly rig wash and lead-free pipe dope. REFERENCES: ERCB ID 81-01 Subsurface Disposal of Drilling Fluids ID 90-01 Completion and Servicing of Sour Wells Section 3 rescinded by Directive 71) ID 96-03 Oilfield Waste IL 2001-03 Management of Drilling Wastes Associated Advanced Gel Chemical Systems Directive D-70 Drilling Waste Disposal Inspection Manual Directive D-50 Drilling Waste Management Directive D-58 Oilfield Waste Management Directive D-37 Service Rig Inspection Manual Directive D-36 Drilling Rig Inspection Manual 14.4.2 ENVIRONMENTAL PROTECTION General Housekeeping PURPOSE High standards of maintenance and housekeeping at oil and gas facilities not only provide an attractive appearance, but create safer working conditions. BACKGROUND Regular maintenance and upkeep of the general appearance of facilities improves employee morale and community relations, reduces site abandonment and reclamation costs, and minimizes unsafe working conditions. CONSIDERATIONS General housekeeping guidelines include the following: Areas exposed to fire hazards must be kept free of weeds or other vegetation and any other combustible material. All releases must be cleaned up immediately and the facility kept clean. Garbage should be collected in appropriate containers and disposed of on a regular basis. OPX Consulting Inc. Section 14-10

Surface facilities should be graded to prevent pooling of rain water or snow melt. Grading or dykes may be needed to prevent the inflow of water from off lease. Facilities must post signage that meets regulatory requirements for identifying the well, the name and telephone number of the operator, and the legal land description (O&G Regulations. Sec. 6.020). Wells with pumping units located within 800 m of populated areas must have a fence that prevents access (O&G Regs. Sec. 8.170). Oily rags, filters, etc. should be collected in approved containers while awaiting recycling or proper disposal. Used lube oil should be collected for disposal at an appropriate oil recycling center. Lube oil cannot be added to the sales oil stream or spread on roads. Waste or surplus equipment, tubing or drums, should be stored in an orderly fashion while arrangements are being made for disposal. Oil must not be stored in earthen pits. Ensure buildings, vessels and piping are appropriately labeled according to WHMIS. Batteries must be fenced and posted with warning signs if H 2 S is greater then 1%. Near occupied dwellings and other public facilities an industrial fence is required. In other areas a four strand barbed wire fence is adequate (O&G Regulations, Section 8.170) In Saskatchewan, facilities and wells must have a sign meeting regulatory requirements which identify the well or facility name, the name of the owner and the legal description. In Saskatchewan, no produced fluids may be stored in earth excavations or storage receptacles that are inadequate or likely to cause waste or loss. 14.4.3 ENVIRONMENTAL PROTECTION Historical Resources Protection PURPOSE This section addresses methods that will protect historical and archaeological resources from any loss or damage by construction of oil and gas facilities. BACKGROUND Construction of oil and gas facilities and pipelines has the potential to damage or destroy valuable historical and archaeological resources that are irreplaceable. OPX Consulting Inc. Section 14-11

CONSIDERATIONS The Historical Resources Act (1980) is intended to protect archaeological, historical and paleoecological resources of Alberta and minimize the risk of damage to these resources. The ERCB requires a Historical Resources Impact Assessment with some project applications as described in IL 82-11. As described in the Alberta Environmental Protection and Enhancement Act, pipelines with a construction index greater than 2690 require a formal Historical Resources Impact Assessment. If a known or suspected archaeological or historical site is encountered during construction, contact the Resource Management Program (403-431-2300). REFERENCES: Alberta Historical Resources Act (1980) Alberta Environmental Protection and Enhancement Act - Conservation and Reclamation Reservation (AR 115/93) Alberta ERCB IL 82-11 Preservation of Archaeological, Paleoecological and Historical Resources Policy Update 14.4.4 ENVIRONMENTAL PROTECTION Lease Preparation PURPOSE Effective lease preparation ensures that environmental factors are considered in the construction of wellsites and access roads. BACKGROUND Construction of a wellsite, battery site or other site preparation is an important first step toward minimizing long-term impact of the facility. This includes erosion protection, salvage of trees and topsoil conservation. CONSTRUCTION METHODS Do not begin construction until all necessary government and landowner consents are obtained. All construction activities must take place within the approved boundaries of the lease as indicated in the field by flagging. OPX Consulting Inc. Section 14-12

Topsoil must be salvaged for future recovery and reclamation requirements. It must be stored in such a manner that it can be recovered when needed. Lease or road construction that cannot avoid wet or muskeg areas should be undertaken on frozen ground. On side hills with a cut and fill layout, the cut material should be placed on the downslope side for future recovery and reclamation. During construction, work activity in stream beds must be avoided, unless regulatory permits have been obtained. CLEARING Minimize removal of vegetation to reduce soil erosion or the risk of polluting nearby water courses. Near stream crossings, clearing should employ hand-felling within 15m of the stream. At the edge of the lease, care should be taken to ensure trees are felled so they fall within the lease and not onto the surrounding forest where they will be difficult to recover. Salvaged timber may only be used as rip-rap in wet areas and stream crossings with Forestry approval. Unless special exemption is obtain, all timber must be limbed, topped and stockpiled for salvage by the nearest timber rights holder. Burning permits are required for burning of slash and debris. Adequate fire fighting equipment and manpower must be provided on the site. Unburned debris and ash from a burn pile may be buried with at least 1m of cover and the surface area recontoured. Ash and a small amount of burn debris may be scattered on the surface if this can be done in an aesthetically satisfactory manner. Cleared slash and debris must be disposed of within one year to avoid unnecessary fire risk. In some cases, it is preferable to save slash and limbs to work into the surface of slopes as a way to minimize erosion potential. Note: On private land, permission must be obtained from the landowner before proceeding. OPX Consulting Inc. Section 14-13

SITE LAYOUT The lease layout must meet the ERCB and OH&S spacing requirements. Vegetation must be cleared around flare stacks and other open flames. However, on many leases, vegetation can be retained to avoid erosion, dust and weeds, and to maintain an attractive appearance. The outer perimeter of any dyke must be at least 60 m from any surface improvements other than a public roadway (O&G Regulations. Sec. 8.030). The lease should be provided with drainage runs or culverts to minimize the amount of surface runoff flowing onto the lease and berms built on the downslope side of the lease to capture storm water or releases. Contaminated runoff water must not be released from the lease. SURFACE SOIL STRIPPING AND STORAGE In all agricultural areas (including land that has the potential for future agriculture), it is required that surface soils be salvaged and stored for recovery during reclamation at the time of abandonment. (Alberta Environmental Protection and Enhancement Act, Part 5 and Conservation and Reclamation Regulations, AR 115/93). Topsoil storage sites should be seeded to prevent soil erosion. A seed mix compatible with vegetation in the surrounding area should be chosen. Records should be kept of the storage location. DRILLING SUMPS AND PITS Drilling sumps should be constructed on the high side of the lease in undisturbed impervious subsoil. If local soil conditions are not suitable, a remote sump or mud tanks should be employed. Sumps must be of adequate size to contain all expected drilling mud volume and rainfall/ snow melt and provide an adequate freeboard. The shape and size of the drilling sump should be selected to maximize re-use of fluid/water. Several designs are shown in the CAPP Environmental Operating Guidelines; Section 4.0. After drilling operations, sumps should be fenced to keep out wildlife and cattle, and to protect the public. Earthen PITS may not be used to store produced fluids. (IL 946). OPX Consulting Inc. Section 14-14

Excavated subsoil must be stockpiled for future recovery during reclamation. The drilling flare pit shall (ERCB Drilling Rig Inspection Manual): o Be excavated to a depth of not less than 2 m. o Have side and back walls rising not less than 2 m above ground level. o Be constructed to resist the erosion of a high-pressure flow of gas or liquid. o Be shaped to contain all liquids. o Be replaced by a flare tank when environmental restrictions will NOT allow a flare pit. DYKING REQUIREMENTS Dykes are required around all tanks containing any fluid except fresh water. On leases where the surrounding contours could cause an inflow of surface water, dykes should be constructed on the high side of the lease to divert the water away from the site in a non erosive matter. In some cases, it may be possible to take advantage of the natural contours to minimize the need for containment dykes around a lease. Although dykes are not required around pop tanks they provide an added degree of protection. The pop tank must be maintained empty, must have a capacity equal to the unattended production and the pop lines must be self draining to the upper third of the pop tank. Other areas where containment dykes could be considered include: o Around process areas, such as the treater building or water plant, where release containment on the lease is important. o At a wellsite with a flowing well. o At any oil well or disposal well near a body of water or other environmentally sensitive area. o Around pumping units, headers and major pig traps. DYKING CONSTRUCTION Shall be constructed with earthen, concrete or synthetic material that will not deteriorate or develop leaks during the projected life of the structure and will withstand the hydrostatic head associated with it being full of liquid. OPX Consulting Inc. Section 14-15

Shall be sized to at least 110% of the capacity of the largest tank within the dyke. Larger dyked volumes should be considered at unattended facilities that have potential for larger releases. Shall have no uncontrolled opening in the dyke that provides a direct connection to any place beyond the dyked area. Shall be maintained in good condition and the area encompassed by it kept free from grass, weeds or other extraneous combustible material. Land lines should be routed to terminate outside the dyke wall to reduce unnecessary traffic over the dyke and to reduce the risk of entering a sour atmosphere. The load line should also be protected with secondary containment. PIPELINE ROUTE SELECTION The objective in pipeline route selection is to choose a route that considers engineering, economic and environmental constraints (physical, biological and cultural) and minimizes disturbance and adverse environmental effects. The following steps are suggested for pipeline selection: Identify control points and other routing requirements. Identify the approximate corridor within which the proposed pipeline will be located. Assemble environmental information for the proposed route from maps, Company records, and other existing public data. Contact government agencies, local authorities, and landowners regarding general concerns on or near the preferred route. Parallel existing pipelines or utilize existing rights-of-way. Route around country residential subdivisions, industrial subdivisions and urban areas. Minimize the crossing of steep slopes as well as side hills. Minimize the number of watercourse crossings. Cross watercourses as close as possible to right angles where approach slopes are stable. Avoid, where possible, environmentally sensitive areas such as critical wildlife areas, natural areas, parks, archaeological or historical sites. OPX Consulting Inc. Section 14-16

Avoid, where feasible, special land use areas. Minimize the crossings of muskegs, wetlands, lakes and sloughs. Avoid, where feasible, farm buildings, farmsteads, well sites, aquifer recharge areas and shelterbelts. Cross road and rail lines at or near right angles. Consider landowner requests. Construction activities shall be confined to the allotted right-of-way and traffic shall be restricted to existing roads, the right-of-way and approved shoo-flies. Construction and clean-up shall be completed as quickly as possible and the distance between front-end and back-end operations shall be kept to a minimum. All construction garbage shall be continuously collected and disposed of at an approved facility. Activities should be scheduled to avoid adverse environmental effects and interference with landowners activities. Construction activities should be designed and carried out in a manner that minimizes environmental effects, including visual impacts, on and adjacent to the right-of-way. For successful reclamation, disturbance should be minimized. The reconstructed right-of-way should conform to, or blend into, the surrounding land unless otherwise approved by the regulatory authorities and the landowner. Right-of-way boundaries shall be clearly marked so that construction vehicles will not trespass off the right-of-way and that soil handling, tree clearing and slash disposal are carried out in a manner which minimizes impacts. The objectives of clearing is to create a right-of-way while minimizing erosion potential, disturbance of adjacent forest cover, and loss of merchantable timber. In Saskatchewan, right-of-way width will usually be restricted to 15 meters. Slash must be contained in the 15 m right-of-way and not pushed into off right-of-way areas. OPX Consulting Inc. Section 14-17

CAMPS, SEWAGE AND STORAGE Camps should be located in the prevailing upwind direction. Provision must be made for the containment and acceptable disposal of garbage and sewage. Temporary fuel storage locations must be surrounded by an impervious dyke with sufficient capacity to contain the volume of the tank(s). REFERENCES: Alberta Environmental Protection and Enhancement Act Alberta Environmental Protection and Enhancement Regulations Conservation and Reclamation Regulations (AR 115/93) Conservation and Reclamation Information Letter, Reclamation Criteria for Wellsites and Associated Facilities (C&R/IL/94-1) ERCB IL 2001-05 Construction of a Wellsite Prior to the Issuance of a Well License IL 94-6 Discharge of Produced Liquids to Earthen Structures 14.4.5 ENVIRONMENTAL PROTECTION Noise Control PURPOSE This section discusses methods that will ensure facilities operate in compliance with appropriate noise control regulations and standards. BACKGROUND Noise from pump stations or compressors can be a nuisance to surrounding residents. This can be avoided by incorporating acoustic design features in accordance with current ERCB regulations. As well, the ERCB requires operators to respond to noise complaints from residents and undertake noise surveys or mitigation measures to respond to these complaints. CONSIDERATIONS The ERCB has issued ID 99-8, Noise Control Directive. The User s Directive D-38 is available to explain the technical details. The directive is not intended to guarantee that a resident will not hear any sound from oil and gas facilities. The aim is to preserve the quality of life for neighbours of such facilities. The allowable sound levels are not specified at the facility but the nearest residence. Even for facilities with no dwellings nearby, uncontrolled sound generation will not be allowed. OPX Consulting Inc. Section 14-18

If new dwellings are constructed near existing facilities, the operator may be required to retrofit the equipment to meet applicable sound levels. This interim directive applies to all facilities under the jurisdiction of the ERCB. It applies to both new and existing facilities and to temporary and permanent facilities. A noise impact statement may be required for new facilities or for expansion to existing facilities. The permissible sound level is the maximum sound level to which a facility must be designed. If a noise-related complaint is received, the comprehensive sound level must be measured and compared to the permissible sound level. The comprehensive sound level is determined by conducting a continuous sound monitoring survey for a 6 or a 24 hour period. The permissible sound level can be determined following the procedures described in the directive. It reflects a basic sound level which depends on population density and is adjusted for a number of factors including a daytime adjustment, seasonal adjustment, whether the facility is permanent or temporary and some other factors. In no case is it less than 40 dba or more than 66 dba. HEARING PROTECTION Noise is unwanted sound. Noise can prevent people from performing at optimum levels. At high level it can cause hearing damage. There are regulations to control noise levels in the work environment and to control the noise resulting from industrial activities that may affect the public. The human ear can hear sound over a wide range of sound pressure levels. The unit of measurement commonly used is the decibel (db), which is usually expressed on the A scale which attempts to represent the way a human ear hears different sounds. In addition to the sound level measured at any instant in time, dba, the average noise level over a six or 24 hour time period can be measured to provide an average noise level. This is called the equivalent sound level (Leq). Some typical sound levels of familiar sources are: SOURCE SOUND LEVEL (dba) Quiet Office 40 Quiet Street 50 Noisy Office 60 Highway Traffic at 15 m 75 Tractor at 15 m 80 to 95 Freight Train at 15 m 95 Jet Taking Off at 600 m 100 Air Raid Siren 130 OPX Consulting Inc. Section 14-19

At oil and gas facilities, the common noise sources are large engines and compressors. Noise levels are a potential concern to employees working in the vicinity of the equipment and to neighbours who could be disturbed by the noise. This environmental standard focuses primarily on the effect of noise on the public. GUIDELINES Operators should discuss noise matters with area residents during the design, construction and operating phases of an energy facility. Permanent facilities are defined as those that will be at a location for longer than two months. These requirements also apply to drilling and service rigs. They are considered temporary if they will be on location less than two months. For drilling rigs and service rigs, the responsibility for noise control belongs to the well licensee. REFERENCES: ERCB ID 99-8 Noise Control Directive Directive D-38 Noise Control Directive User Guide 14.4.6 ENVIRONMENTAL PROTECTION Site Selection PURPOSE To ensure environmental and community relations issues are included in selecting the location for well-sites, access road and other facility sites. BACKGROUND The location of a wellsite, access road or other oil and gas facilities can have long term implications on environmental protection, operating efficiency and community relations. The factors to consider in choosing the location for wellsites and facilities include: Environmental factors such as terrain damage, soil quality, vegetation disturbance, surface soil stripping and storage, protection of water quality, disturbance of drainage patterns, aquatic habitat, wildlife impact, wind exposure, and seasonal weather conditions. Public impacts such as landscape, noise, odours and traffic. Safety of the public, employees and wildlife, and protection of company and public property. OPX Consulting Inc. Section 14-20

Operational efficiencies which can be enhanced by the choice of access and site layout including such factors as proximity to existing infrastructure, road quality and grade, landscape and common access. Regulatory requirements relating to spacing restrictions, setback disturbances, noise guide-lines, seasonal restrictions, separation distances, wildlife restrictions, disposal of waste products and reclamation requirements. CONSIDERATIONS Selection and construction of lease sites and pipeline routes involve consideration of many aspects of the ERCB and Alberta Environment Regulations, Interim Directives and Informational Letters. The approval of the location of an oil and gas facility begins with application to the ERCB for a Well License. In parallel, surface approval must be obtained from the landowner (White Zone) or Land and Forest Services or Public Lands (Green Zone). TERRAIN FACTORS Locations must be 100 m from any surface improvement or 40 m from a surveyed roadway or road allowance. Special circumstances may be permitted by the ERCB for lesser distances (O&G Regulations. Sec. 2.110) Maximum advantage should be taken of natural topography and drainage patterns to reduce the amount of ditching and berm construction for erosion control. Sites on level ground are preferred so the need for cut and fill can be minimized. Areas of muskeg or with a high water table should be avoided if possible. Winter construction under frozen muskeg conditions is recommended. The use of geotextile material should also be considered. Sites within areas of Native Prairie (roughly the area east and south of Red Deer) require special land preservation techniques (IL-96-9). VEGETATION IMPACTS The lease layout should preserve vegetation where possible without violating minimal spacing requirements and safety criteria. Sites and access roads should be chosen to minimize impact on agricultural operations. OPX Consulting Inc. Section 14-21

WILDLIFE CONCERNS Sites for winter operations in many forested areas may face activity restrictions to reduce disturbance to large mammals. Check with local Fish and Wildlife Officers for restrictions. Harassment of wildlife and illegal possession of firearms is prohibited. Consideration should be given to the use of doglegs on pipelines at the edge of the road allowance to minimize the line of sight. Survey crews should be instructed to avoid long lines-of-sight that cause interference with wildlife movement patterns. PROTECTION OF STREAMS AND AQUATIC HABITAT Wells must be 100 m from the high water mark of a river, stream or waterbody (O&G Regulations Sec. 2.12). Construction or pipeline or road crossings of permanent streams generally requires a Water Resources Permit. Consult local Fish and Wildlife Officers. Sites should be chosen which reduce the threat of erosion or releases into nearby streams or waterbodies. At stream crossings, timber should be hand-felled away from the stream. Contact local Fish and Wildlife Officers concerning beaver dam removal. Most fish bearing streams have construction restrictions during specific times of the year depending on the fish species in the watershed. (See CAPP Environmental Operating Guidelines for Alberta). Disruption of natural water flow should be minimized if possible by the use of culverts, drainage runs or changing the access route. POTENTIAL IMPACTS TO RESIDENTS Wellsites or facility locations for sour gas operations face many restrictions. Setback distances are described in GB 99-04 and ERCB EnerFaq No. 5. Consideration must be given to the size of Emergency Planning Zones and preparations of Emergency Response Plans (GB 99-04, D-71, D-56 and IL 95-07). Operators are required to have early and thorough consultation with landowners and other nearby residents which may be affected by the operation. OPX Consulting Inc. Section 14-22

Before looking for a location for a new gas plant, operators are required by the ERCB to look for existing processing capacity in the local area to avoid unnecessary proliferation of gas plants. Applicants for new wells and production facilities are required to advise the Rural Authority of their intent to apply for ERCB approval. Similarly, for locations within 1.5 km of the corporate limits of an urban center, the applicant must advise the Urban Authority. Wellsites with a pumpjack that are within 800 m of residences, incorporated areas or other centers of human activity will require a secure fence (O&G Reg. Sec. 8.170). Visual appearance, landscaping, water drainage and other factors in populated areas will improve public acceptance. LOCATION OF ROADS Following site selection, the operator must acquire a well license and a surface lease from the landowner or the Crown before beginning construction. New roads should be located to take maximum advantage of existing cut lines and cleared areas. Stream crossings should be oriented at a 90 angle to minimize bank disturbance. Roads should be located a minimum of 100 m from streams or other waterbodies. Surveyors should place flagging at lease or right-of-way boundaries to ensure all construction work takes place within the approved area. MISCELLANEOUS LOCATION FACTORS Drilling locations should be chosen with a view toward minimizing the impact of noise from drilling or permanent facilities. In areas where there is the potential for disturbance to archaeological or historical resources by lease or road construction, clearance is required from Archaeological Survey of Alberta. Well licenses within 5 km of a lighted airport or 1.6 km of an unlighted airstrip must first be referred to Transport Canada. The ERCB recommends that an applicant for approval of a surface facility confirm that the parcel of land is not underlain by an abandoned coal mine. The information is available from the ERCB s Information Services, Coal Mine Atlas (IL-91-13). OPX Consulting Inc. Section 14-23

REFERENCES: Oil and Gas Conservation Act Oil and Gas Conservation Regulations Pipeline Act Pipeline Regulations Alberta Environmental Protection and Enhancement Act Alberta Environmental Protection and Enhancement Regulations (AR 115/93) Conservation and Reclamation Regulations Reclamation Criteria for Wellsites and Associated Facilities (Alberta Environment C&R/IL 95-3) Guide for Pipelines Pursuant to Alberta Environmental Protection and Enhancement Act March, 1994) (Alberta Environment C&R/IL 94-1). Public Consultation Guidelines for the Canadian Petroleum Industry, The Canadian Petroleum Association (October, 1989). Alberta Environment Conservation and Reclamation Information Letters C&R/IL 94-1 Reclamation Criteria for Wellsites and Associated Facilities (replaced by IL 95-3) C&R/IL 94-2 Conservation and Reclamation Notice C&R/IL 94-3 Certification Requirements for Wellsites with No Surface Disturbance (Surveyed only) C&R/IL 94-4 Burial of Material on Lease C&R/IL 94-5 Environmental Protection Guidelines for Pipelines C&R/IL 94-6 Environmental Protection Guidelines for Oil Production Site (Heavy Oil) C&R/IL 94-7 Questions About the Reclamation Criteria for Wellsites and Associated Facilities (replaced by IL 95-3) C&R/IL 95-1 Conservation and Reclamation Code of Practice for Alberta OPX Consulting Inc. Section 14-24

C&R/IL 95-2 Environmental Protection Guidelines for Electric Transmission Lines C&R/IL 95-3 Reclamation Criteria for Wellsites and Associated Facilities 1995 Update ERCB ID 81-3 Minimum Distance Requirements Separating New Sour Gas Facilities from Residential and Other Developments. ID 99-8 Noise Control Directive IL 90-21 Oil and Gas Development Rumsey Block IL 91-13 Impact of Abandonment on Coal Mines on Surface Developments IL 96-09 Revised Guidelines for Minimizing Disturbance on Native Prairie Areas IL 94-17 Notification of Pipeline Project to Conservation and Reclamation Inspectors IL 95-07 Subdivision and Development Regulation Requirements IL 2001-05 Construction of a Wellsite Prior to the Issuance of a Well License IL 2002-01 Principles for Minimizing Surface Disturbance in Native Prairie & Parkland Areas Directive D-13 Pipeline Information System Users Manual Directive D-38 Noise Control Directive User Guide Directive D-56 Energy Development Applications & Schedules 14.4.7 ENVIRONMENTAL PROTECTION Release Site Response & Reclamation RELEASE RESPONSE The first priorities after discovering a Release are to protect the safety of all personnel and public, minimize damage to the environment and control costs associated with loss of product or equipment. The key actions to take immediately following a release are: Assess the safety of the situation (including surrounding public). Remove sources of ignition; if safe to do so. Approach release site from up-wind side is possible. Positive Pressure Breathing Apparatus (PPBA) to be worn in H 2 S release area until such time as atmospheric tests prove the area safe. Shut in the source of the release; if safe to do so. OPX Consulting Inc. Section 14-25

Information regarding the hazards of chemicals handled on-site can be round in the Material Safety Data Sheets (MSDS) located in the Area Office. Notify supervisor. The senior employee or company representative on-site is responsible to initiate the notification and responses procedures. Implement Site Emergency Response Plan and Corporate ERP if required. Begin containment process (dykes, booms, etc.) Conduct pre-job safety meeting. Notify Government authorities, landowners, etc. (See section 3.02 or the Loss Management Manual E.P). Begin recovery process (vacuum trucks, etc.) Conduct pre-job safety meeting prior to beginning recovery. Obtain assistance from appropriate oil release Co-op or consultants for clean up and reclamation as required. Report all releases on HARVARD Incident/Near Miss Report Form. PURPOSE Proper site maintenance and reclamation procedures will reduce the impact of oil and salt water releases on land surrounding oil and gas facilities. BACKGROUND Both oil and produced salt water can be toxic to vegetation and cause damage to soils. Most produced water is high in salts, largely sodium chloride (NaCl), which can cause significant long term damage to soils. In fact, salt water releases can be much more damaging to soils than hydrocarbon releases since oil is biodegradable and the site usually can be reclaimed within a year or two. Without prompt action, releases of produced water can take much longer to reclaim. CONSIDERATIONS The Oil and Gas Conservation Regulations (Section 8.050) and the Pipeline Regulations (Section 54) require that the operator take immediate steps to contain and clean up releases. The Alberta Environmental Protection and Enhancement Act states that An operator must conserve and reclaim specified land and secure a reclamation certificate in respect of the conservation and reclamation. The regulations accompanying the Alberta Environmental Protection and Enhancement Act OPX Consulting Inc. Section 14-26

define specified lands as sites occupied by wells, pipelines and plants. The Alberta Environmental Protection and Enhancement Act also has provisions for enforcement whereby orders can be given for clean-up of adversely affected sites. SITE ASSESSMENT After as much fluid as possible has been recovered and the site is safe to work on, reclamation activities can begin. Hot water is often used to flush oil into collection trenches, berms or bellholes. Caution should be exercised with hot water since it could increase the flammable vapour concentrations or cause the release of hydrogen sulphide. IF THERE IS SALT WATER ASSOCIATED WITH THE RELEASE, DO NOT FLUSH WITH WATER. See Salt Water Releases. Releases that are contained entirely within the lease do not usually require immediate reclamation of the soil for plant growth. In this case, the contaminated soil should be excavated and the area repaired with clean fill or gravel. The contaminated soil can be sent to an approved waste management facility or treated on site by landfarming. For off-lease releases, it is usually necessary to restore the chemical and physical properties of the soil to allow crops or native vegetation to reestablish. This can often be accomplished by adding the appropriate soil amendments and allowing the natural micro-organisms in the soil to decompose the residual oil. A reclamation program should begin with a site assessment to establish the extent of contamination and to use the results of soil analysis to develop a reclamation plan. This information should be documented for submission to regulatory officials and to keep track of the work since it usually takes several years to completely restore the site. Some suggestions for site assessment include the following: Make a sketch of the site, take photographs, and make notes of the surrounding terrain conditions and nearest watercourses. Collect a sample of the released water. Keep a record of released and recovered volumes, disposal methods, soil treatments and other reclamation work. For a salt water release, it may be valuable to conduct an electromagnetic soil conductivity survey to define the contamination boundaries. Samples should be taken from the surface soil, at the 10 cm depth (and deeper if necessary to get below the contamination) and from the adjacent field in an uncontaminated area as a control sample. The control sample should be collected first so the sampling shovel or auger is not contaminated. OPX Consulting Inc. Section 14-27

The samples should be analyzed for ph, electrical conductivity, chlorides, sulphates, nutrients, oil percentage, gypsum requirement, lime requirement and fertilizer recommendations. OIL RELEASES For oil releases on water, specialized equipment (booms, skimmers, etc.) can be obtained from the nearest co-op equipment unit or from the PROSCARAC trailer. These units also have a variety of general purpose equipment for release clean-up. Consult the Oil Spill Co-Op Manual for techniques to contain and clean-up oil releases, and Oil Spills Cooperatives for a listing of Cooperatives in Western Canada. The local office of the ERCB should be contacted for approval of a release reclamation project. It is very important to work with the landowner to understand his requirements for that season s land use and his long term plans. There are a variety of factors to consider in designing the reclamation plan for an oil release. In most cases, it is possible to spread the oil contaminated soil on the surface and add fertilizer to encourage natural decomposition. Generally the maximum oil loading rate in the surface soil should be in the order of three to five percent. A temporary fence may be needed to keep out stock. In most cases, the area should not be seeded unless the oil concentration is less than one percent. Manure and fertilizer should be worked into the soil and tilled every three or four weeks. Lime will probably be needed to correct the ph and generally the laboratory can recommend the required addition rates. Once the oil concentration has been degraded to less than one percent, the site can be revegetated. SALT WATER RELEASES After as much fluid as possible has been recovered, soil remediation should begin IMMEDIATELY. This is of the utmost importance for salt water releases. ON AGRICULTURAL LANDS, DO NOT FLUSH WITH WATER AS THIS IS DETRIMENTAL TO THE SOIL. Flush with a diluted solution of calcium nitrate as soon as possible. Caution should be used to ensure that calcium nitrate does not contaminate any surface water. Gypsum can be used after the initial application of calcium nitrate to make further calcium available to the soil. On forest soils, water can be used to flush released fluid toward ditches and bellholes where it can be recovered. On agricultural soils, a source of calcium should be added immediately after fluid recovery is complete. OPX Consulting Inc. Section 14-28

In summer, broadcast calcium nitrate at 1000 kg/ha to the surface of the release before the area dries. Subsequently apply gypsum at 5 tonnes/ha and incorporate it into the soil as soon as conditions permit. In winter, the frozen soil may result in runoff of the nitrate which could be toxic, so only gypsum should be added to frozen soil. On forest soils, immediate water flushing and the use of ditches and bellholes to recover fluids is recommended. On well-drained forest soils, flushing with calcium nitrate may also be beneficial in removing salts. Again, caution should be exercised to ensure that surface water will not be contaminated. When the concentration of salt (chloride) has been reduced by flushing to 700 ppm, recovery operations can usually be stopped and reclamation of the area can begin. PIPELINE REPAIRS Hydrocarbon contaminated soil that is excavated during a pipeline repair should be treated on the surface and not returned to the pipeline excavation or bellhole. All contaminated soil should be excavated when the line break is exposed. If the subsoil is contaminated by salts (produced water), gypsum should be mixed with the backfill. DEBRIS DISPOSAL Contaminated soil from an oil release clean-up can be sent to an approved waste management facility or preferably treated on-site by landfarming. Oilsoaked vegetation, solvent and rags from the release can be burned in the air curtain incinerator available from PROSCARAC. Contact the local Oil Spill Cooperative. Permission for disposal by incineration is required by the ERCB. GOVERNMENT INSPECTIONS All HARVARD s facilities are subject to inspection. A government inspector may call in advance to advise of their planned visit or their arrival may be unexpected. It is important that employees be aware of their responsibilities to cooperate with the inspectors and avoid statements or actions that may incriminate themselves or HARVARD. Generally, an inspection is a review by the regulators for the purpose of ensuring technical compliance with approvals or legislative standards. An investigation is used by the government to gather sufficient information to support a change and conviction. Safety and environmental inspectors and investigators have quite broad powers for warrantless search and removal documents or samples. The inspector can enter, examine and inspect places, things and vehicles. The inspector can use any equipment, examine and take documents, take samples, conduct tests and make reasonable inquiries of any person. They may also ask the person to operate mechanical or process OPX Consulting Inc. Section 14-29

equipment. Safety or environment investigations may be undertaken with or without search warrants. COMMUNITY RELATIONS HARVARD intends to be a good neighbor in the communities in which it operates. Regulators expect all operators to operate in a manner that minimizes the impact to the community and to involve landowners and others in planning for new facilities. In Alberta, this is described in ERCB IL 89-4, Public Involvement in the Development of Energy Resources. Although Saskatchewan does not normally require public involvement, the same level of care used in Alberta should be applied in Saskatchewan. ERP s may include a formal public consultation requirement. This is usually completed by conducting an open house information session. REFERENCES: Alberta Environmental Protection and Enhancement Act Release Reporting Regulations (AR 117/93) Release Reporting Guidelines (June, 2001) Oil and Gas Conservation Act Oil and Gas Conservation Regulations: Section 8.050 Pipeline Act Pipeline Regulations: Section 54 14.4.8 ENVIRONMENTAL PROTECTION Storage PURPOSE This section addresses methods for minimizing the risk of environmental impacts from storage tanks at oil and gas facilities. BACKGROUND Above ground and below ground storage tanks have been a historic source of soil and groundwater contamination in the upstream petroleum industry. CONSIDERATIONS The ERCB Directive 55 - Storage Requirements for the Upstream Petroleum Industry was issued to identify requirements and acceptable levels of storage practices of materials produced, generated (including wastes), or used by the upstream petroleum industry. These requirements apply to all new facilities constructed after January 1, 1996 under the jurisdiction of the ERCB. OPX Consulting Inc. Section 14-30

The ERCB required facilities constructed prior to January 1, 1996 to demonstrate that their storage practices, facilities and containment devices met the requirements stated in Directive 55. It was expected that all tanks, aboveground and underground, would be inspected and/or tested prior to October 31, 2001. The storage requirements apply to storage of all materials produced, generated or used by the upstream petroleum industry including: Produced Water Crude Oil Emulsions Condensates Chemicals Solvents Produced Sand Non-Motor Vehicle Lubricants Oil Field Wastes Oily Wastes Bitumen The guideline does not change the following current regulatory requirements: Storage of natural gas liquids will continue to be governed by the National Standard of Canada Propane Installation Code CAN/CGA-B149.2-M86. Pressurized process vessels (both above ground and underground) are regulated by the Boilers and Pressure Vessels Branch of Alberta Labour for a working pressure of 15 psig or more. Companies can apply to conduct their own vessel inspections. Contact Alberta Boilers Safety Association (formerly Alberta Boilers Branch. Storage of fuels such as diesel, gasoline and used motor vehicle lubricants in above ground or underground storage tanks must comply with the requirements under the Alberta Fire Code, Section 4.3. The Petroleum Tank Management Association of Alberta (formerly the MUST program) have guidelines for installation, testing, removal and clean-up of underground storage tanks. Sulphur storage areas must be operated in accordance with the condition on the facility s Alberta Environment approval. This includes collection, treatment and disposal of runoff water from sulphur blocks and base pad areas. Storage of sulphur must also conform to the requirements of IL 84-11 and GB 92-04. OPX Consulting Inc. Section 14-31

Alberta Environment regulates storage of materials produced, generated and used in activities under the Environmental Protection and Enhancement Act (EPEA). In situations where an upstream petroleum facility requires both ERCB and AE approval, D-55 sets the minimum storage requirements, while additional requirements may be specified in Alberta Environment s approval. The following is summarizes some of the general storage requirements of Directive D-55. Anyone designing or specifying a new storage facility is advised to refer directly to Directive D-55 to ensure compliance with the latest edition. GENERAL STORAGE REQUIREMENTS Environmental protection and safety measures related to storage in the upstream petroleum industry may include the following: Storage sites should be selected to minimize the potential for environmental damage. In most cases, secondary containment is required (graded). This usually is provided by an earthen dyke, with impervious liner, sized to contain at least 110 percent of the tank or 100% of largest tank plus 10% of the aggregate volume if more than one tank. Above-ground storage tanks with an interval volume of 5 m 3 or greater to have secondary containment consisting of a dike and liner system or to be double-walled. Small above-ground storage tanks (interval volume between 1 m 3 and 5 m 3 ) that exceed a total combined volume of 5 m 3 per site, to have secondary containment or be double-walled. Underground storage tanks to be double-walled. Containers (portable storage devices that do not exceed 1 m 3 in volume) that exceed a total combined volume of 1 m 3 per site, to have secondary containment. All lined earthen excavations to have secondary containment. Bulk pads storing materials that may generate a leachate to have leak detection systems. Monthly monitoring of all leak detection systems, including visual and interstitial space monitoring, associated with above-ground and underground tanks, containers, line earthen excavations, and bulk pads. OPX Consulting Inc. Section 14-32

Some form of weather protection is required. For above ground storage tanks, this usually is achieved by painting the exterior with a protective coating. Materials should not be stored for excessive periods of time. Most material should be consumed in two years or less. The maximum storage period for oilfield waste is one year. Records of storage inventories, corrosion monitoring, groundwater monitoring and leak detection must be retained for a period of five years. Temporary storage (typically less than three months) during plant turn-arounds, construction, release clean-up and well drilling are expected to meet the intent of the regulations. Temporary production batteries of (12 months or less) are not required to install impervious liners, however, equipment spacing and dyking requirements must be met. All stand-alone storage facilities require signs at the entrance to the facility indicating the operator name, emergency telephone number and legal description (Section 6.020 and Schedule 12 of the Oil and Gas Conservation Regulations). The use of concrete as a primary containment in situations where liquids are being stored or where there is potential for leachate to be generated is prohibited. ABOVE GROUND STORAGE TANK ( NEW FACILITIES) Above ground storage tanks include steel, plastic and fiberglass tanks. Bolted tanks are not acceptable for new installations. Above ground tanks with the volume less then 1 m 3 are considered to be containers. Above ground storage tanks which are larger then 5 m 3 have the following requirements for secondary containment, leak detection and weather protection. Steel tanks should have cathodic protection and be externally coated. A secondary containment system is required that will contain leakage and prevent it from impacting the environment. All tanks must be placed on an impervious natural clay or synthetic liner and surrounded by a dyke. The dyke can be constructed of earthen, concrete, or synthetic material that will not deteriorate, and must be sized to contain 110% of the capacity of the largest tank. There can be no uncontrolled opening through the dyke. The dyke must be maintained in good condition and area encompassed kept free from grass, weeds, and other extraneous combustible material. OPX Consulting Inc. Section 14-33

SAFETY PROGRAM MANUAL Secondary containment for indoor above ground tanks must include an impervious containment wall or curbing that has a capacity of at least 110% of the capacity of the largest tank. Leak detection systems for above ground storage tanks must include one or more of the following on a monthly basis; Visual inspection of tanks and tank containment area liner surface for evidence of damage or leakage. Annulus/interstitial space monitoring for double walled and bolted tanks. Soil vapour and or ground water monitoring in the immediate vicinity of the containment area. Sub-liner leakage detection devices (e.g. weeping tile system) Weather protection is intended to preserve the integrity of the tank. For above ground storage tanks, this is usually achieved by painting the exterior with a protective coating. UNDERGROUND STORAGE TANK ( NEW FACILITIES) An underground storage tank is defined as a tank that is partially or completely buried and does not allow for the visual inspection of the top, complete sides, and the bottom of the tank without excavation. Both leak detection and secondary containment are required for any underground storage tank. Steel tanks must have cathodic protection and be externally coated to minimize corrosion. Underground storage tanks must also be inspected on a monthly basis. Secondary containment systems for underground storage tanks must include the following; Double-walled steel or fiberglass tanks that possess the capability to monitor the interstitial space between the two tanks. Impervious synthetic liner. Tanks contained in reinforced concrete or steel vaults. Overflow vents from underground storage tanks must be directed downward to a containment area. Breathing vents must be designed to prevent the overflowing of fluids onto the ground. Leak detection systems for underground storage tanks must include one or more of the following; Monthly hydrostatic leakage tests. OPX Consulting Inc. Section 14-34

Monthly pneumatic leakage tests. Monthly sampling of a monitoring well positioned between the synthetic liner under the tank and the tank. Monthly monitoring of the annular space in a double hulled tank. Visual detection of vaulted tanks. Monthly monitoring of weeping tiles system under single walled tanks. STORAGE REQUIREMENTS FOR CONTAINERS ( NEW FACILITIES) Containers are small vessels which have an aggregate volume of less then 1m 3. For example, a collection of approximately 5 45 gallon drums. If the aggregate volume is greater then 1m 3, secondary containment is required for the amount over 1 m 3. The secondary containment would typically consist of dykes, curbs, or collection trays and should have a minimum height of 15 cm, or a net capacity greater then that of the largest container, or 10% of the total volume of all containers in a storage area, whichever is greater. Weather protection may also be appropriate to maintain the integrity of the container. The type of secondary containment and weather protection is dependent on the nature of the contained material, the type of container and the design of the storage compound. APPLICATION TO EXISTING FACILITIES (OPERATING PRIOR TO JAN 1 st 1996) The above requirements apply specifically to facilities constructed after January 1, 1996. However, the guidelines require that pre existing facilities comply with the intent of these requirements. It is the responsibility of the operator to design and implement a suitable testing and inspection program to verify the mechanical integrity of existing storage tanks. Tanks which pose a higher risk should be given a priority schedule for testing and inspection. The results of tests and inspections should be documented and records are available for ERCB inspection. Existing above ground storage tanks should be inspected prior to October 31, 2001 and there in after a minimum of once every 5 years. Suitable testing methods may include; 100% external inspection (if bottom of tank is visible), internal inspection (if bottom is not visible), or the results of existing monitoring programs. All underground storage tanks were to be inspected prior to October 31, 2001. There in after, tanks were required to be integrity tested at least once every three years. Testing and inspection may include hydrostatic OPX Consulting Inc. Section 14-35

leakage tests, pneumatic leakage tests and/or the results of monitoring programs. DISCONTINUED STORAGE OPTIONS (EFFECTIVE JANUARY 1, 2002) The 2001 edition of D-55 discontinues the following storage options: Use of single-walled underground tanks where a synthetic liner or the natural impermeable soil conditions (ie: hydraulic conductivity of 10-6 cm/s or less) are used for secondary containment; The use of concrete-lined earthen excavations with an underlying leakage monitoring system, but no secondary containment, and; The use of concrete as primary containment for lined earthen excavations or for bulk pads where there is a potential for the stored materials to generate a leachate. Any of the above storage systems installed prior to January 1, 2002, will be required to meet the requirements within the appropriate sections of Appendix 2 of D-55. REFERENCES: National Standard of Canada Propane Installation Code CAN/CGAB149.2- M86 Alberta Fire Code, Section 4.3 Alberta Labour Act and Regulations, MUST Program Fire Protection Handbook, 15 th Edition, NFPA 30 - Flammable and Combustible Liquids Code National Fire Protection Association Alberta Boilers Safety Association (formerly Alberta Boilers Branch) ERCB IL 84-11 Approving, Monitoring and Control of Sulphur Storage Sites GB 92-4 Requirements for Sulphur Storage Facilities Directive D-55 Storage Requirements for the Upstream Petroleum Industry OPX Consulting Inc. Section 14-36

14.4.9 ENVIRONMENTAL PROTECTION Surface/Groundwater Protection PURPOSE Effective surface water and groundwater protection minimizes pollution from oil and gas facilities. BACKGROUND During decommissioning and reclamation of facilities, remediation of contaminated groundwater can be difficult and expensive. The most common sources of contamination are long term leaks and release from storage tanks (especially underground tanks), under processed skids, around water disposal plants and from flare pits or other earthen pits. The groundwater development act has been replaced by the Alberta Environmental Protection and Enhancement Act. Two regulations, the Water (ministerial) and Regulation (AR205/1998) and the Potable Water Regulation (AR214-96) are intended to protect and conserve Alberta s groundwater. In Saskatchewan, the use and protection of groundwater is regulated by Sask Water and Saskatchewan Environment. Any use or contamination of groundwater should be reported to both groups for review and permitting. Water use charges may be levied for the industrial use of groundwater. Hydrocarbons from crude oil or emulsion released on the ground surface can migrate downward by gravity or be carried by infiltration with rainwater until it reaches the water table. Since it is lighter then water, oil tends to stay on the surface of the water table and migrate horizontally in the down slope direction. However, the groundwater table is not constant, it rises and falls with the seasons, so wide layers of sub soil can become contaminated. Some organic compounds such as benzene, toluene, ethylbenzene and xylene (BETEX) are more soluble in water and are toxic so they pose a bigger risk since they can travel farther with the groundwater flow. Produced water is very mobile in the groundwater regime, so large underground plumes of salt can become established from an area that is exposed to chronic produced water releases. The underlining groundwater regime can be very difficult to predict from surface observations. The water table could be a meter below the surface or many meters down. The rate of flow of groundwater can vary from many meters per day in coarse soil to only a few cm per year in clay soil. However, even in a tight clay soil there are fractures or lenses of coarser material that may allow groundwater contaminant to travel many meters, either horizontally or vertically. Underground salt water plumes can often be mapped with an electro magnetic survey that uses a handheld instrument to measure the soil conductivity. This can be a very useful tool to determine the extent of saltwater contamination but it does not provide an accurate measure of the concentration of a groundwater contaminant. The only meaningful way to OPX Consulting Inc. Section 14-37

measure the concentration of groundwater containment and to test the soil quality is to drill a test hole. A groundwater observation well, a piezometer, is used to measure the water level and collect water samples for chemical analysis. Several wells are needed to map an area and determine the direction and rate of flow. Since groundwater flow is usually slow and groundwater levels move up and down with the seasons, it can often take more then one year to define a problem and may take several years to correct it. Groundwater remediation may involve methods that include pumping the water to the surface for treatment or could rely on in-situ treatment. Often the only viable approach is to excavate the entire area and treat or dispose the contaminated soil. All of these methods are time consuming and expensive. Rainfall or snow melt on a production facility could cause adverse effects or soil damage in several ways: Water which soaks into the ground could carry contaminants downward to the groundwater. Impounded water could become contaminated and carry the contamination off-site when the water is discharged to the surroundings. Run-off water from a lease could cause erosion when it is discharged. Water on the lease could undermine footings or foundations, along with making foot and vehicle traffic difficult. CONSIDERATIONS Some guidelines to avoid surface water or groundwater contamination problems include the following: Consider the use of dykes, berms or culverts on the upslope side of the lease to divert run-off water around the site in a non-erosive manner. Run-off water should be directed to well- vegetated areas or soil protected from erosion by rip-rap or other means. Rainfall or snow melt water which falls on undeveloped (clean) areas of the site can be discharged directly to the surrounding watershed. Rainfall or snow melt which falls within the developed process area of the site should be directed to a retention pond or berm so it can be visually inspected before it is discharged. No water that exhibits a hydrocarbon sheen or other sign of contamination can be discharged without treatment. Stormwater impounded on a facility with an approval from AE may require testing and permission from AE prior to discharge. Check OPX Consulting Inc. Section 14-38

the terms and conditions of the approval (formerly called a Clean Water Licence). Run-off water from open sulphur storage areas (sulphur blocks) must be retained on site and tested for acidity before being discharged in accordance with the facility s AE approval. In most cases this acid run-off will be diverted to a retention pond and neutralized with lime before discharge. Surface run-off water collected within the secondary containment system must be field tested and meet the following criteria prior to being released in a controlled fashion to adjacent lands. o Chloride content: 500 mg/l maximum (e.g. test strips) o ph: 6.0 to 9.0 (e.g. test strips and/or meter readings) o No visible hydrocarbon sheen o No other chemical contamination o Landowner consent o Water must not be allowed to flow directly into any watercourse o Each release must be recorded including the pre-release test data and the estimated volume of water released. Water that is retained on site that meets the criteria described above may be discharged off-site to the surrounding environment. Run-off water can be drained or pumped to the surrounding land in a non-erosive manner. It should be discharged to an area with well established vegetation. However, it should not be discharged where it can run directly into a natural watercourse, well or dugout. REFERENCES: Oil and Gas Conservation Act - Oil and Gas Conservation Regulations Section 8.030 ERCB Directive D-55 Storage Requirements for the Upstream Petroleum Industry Directive D-64 Facility Inspection Manual OPX Consulting Inc. Section 14-39

14.4.10 ENVIRONMENTAL PROTECTION Well Site Reclamation PURPOSE Prompt and effective reclamation of surface leases allows land to be returned to appropriate use in a timely manner and can result in cost savings for oil and gas companies. BACKGROUND Oil and gas exploration and development is a relatively short-term land use. Drilling and abandoning a dry exploration well takes only a few weeks or months. Many production facilities operate for less than twenty years. After the resources have been depleted, the well must be abandoned and the land surface returned to productive use which is compatible with the surrounding land. Wellsites and other production facilities should be reclaimed as soon as possible after abandonment and decommissioning. Some of the reasons for prompt completion of reclamation include the following: Surface rentals (lease payments) can be terminated when a reclamation certificate is received. The ERCB review each company s ratio of active to inactive wells, which should be greater than 1.0. Landowner relations are improved by returning the lease to productive use. The potential for further contamination by migration of pollutants from unattended sites is reduced. Other working interest owners are still available to share the cost. The administrative costs of carrying non-productive facilities are eliminated. Note: The ERCB is responsible for suspension and abandonment activities at all upstream oil and gas facilities. AE has responsibility for all decontamination and reclamation activities. Under the Saskatchewan Oil and Gas Conservation Act and Regulations an operator first obtains a survey then applies to Saskatchewan Environment (SE) for a well license. The operator must also obtain a rightof-entry or a surface lease from the landowner. On crown land there are several different agencies who can be the land manager depending on the type of land. If HARVARD is not able to reach an agreement with the landowner, they can precede through the Arbitration Board. Land which is posted in environmentally sensitive areas should show a notation to advise the operator to contact the appropriate government agency. In OPX Consulting Inc. Section 14-40

many cases, it is worth while to check this out by telephone with the Environmental Assessment Branch of Saskatchewan Environment. RECLAMATION TERMS The following terms are commonly used in abandonment and reclamation work. Equivalent Land Capability Equivalent Land Capability means the ability of the land to support various land uses after reclamation is similar to that which existed before the disturbance Reclamation Criteria Reclamation Criteria are the standards to which a lease site must be reclaimed in order to receive a Reclamation Certificate. A Reclamation Certificate is issued by AE or Alberta Agriculture, Food and Rural Development (AFRD) following an inspection that proves the operator has reclaimed the site to a standard that is consistent with the reclamation criteria. Decommissioning Decommissioning refers to the closure of all or part of an industrial facility followed by the removal of process equipment, buildings and structures, surface and subsurface decontamination. Reclamation Reclamation refers to the entire process from abandoning a facility to returning the land to equivalent land capability. A Reclamation Certificate will be issued for those facilities that fall into the Alberta Environmental Protection and Enhancement Act definition of specified land when reclamation is completed to the satisfaction of the AE. Those facilities that are not specified land under the Alberta Environmental Protection and Enhancement Act will have to meet decontamination requirements. Decontamination Decontamination is the removal or neutralization of substances and/or hazardous material from a site as to prevent, minimize, or mitigate any adverse effects on the environment now or in the future. Land Reclamation Land Reclamation is the stabilization, contouring, maintenance, conditioning, or reconstruction of the surface of the land to a state that permanently renders the land with a capability equivalent to its predisturbed state. OPX Consulting Inc. Section 14-41

CONSIDERATIONS Specific reclamation practices vary from one area of the province to another. Often specialists are required to develop a site-specific plan. In general it will include: Initial Site Assessment: Review production history with foreman or operator in the field. List on-site work required to meet reclamation criteria (soil sampling may be required to identify chemical contamination and/or to determine what soil treatment or amendments are required). Contact landowners. Reclamation Plan: Remove or treat contaminated soil. Restore the physical conditions of the soil to produce optimal plan growth (e.g. compaction, gravel/rocks). Contour the site if necessary to prevent erosion, ponding of water and/or to maintain slope stability. Identify critical plant growth factors such as topsoil recovery and replacement, fertilization, organic matter additions, and seed mixes which are compatible with the surrounding land use. Implement site maintenance factors such as fencing to keep animals off the site until vegetation has been established. Site Decommissioning Develop safe work procedures. Ensure a proper recycling, re-use or disposal plan is in place for handling all fluids, wastes and other material. Remove all equipment, structures, underground tanks, scrap metal, garbage etc. from the site. Improvements such as pad and roads may be left in place if prior written consent of the land-owner or AE has been obtained. Onsite disposal of concrete or other inert material requires approval from the ERCB, AE and landowner. OPX Consulting Inc. Section 14-42

Final Site Assessment SAFETY PROGRAM MANUAL Reclamation criteria identify the field measurements or investigations necessary to ensure a site has been successfully reclaimed. The following is a general guide to site characteristics for which information must be compiled prior to applying for a Reclamation Certificate. Landscape: Drainage, erosion, contours, stability, rocks, debris. Soil: Topsoil quantity, topsoil and subsoil quality, rocks, compaction, presence of contaminants (e.g. salts, hydrocarbons, heavy metals, etc.) Vegetation: Species composition, vigor, density, height, cover, rooting characteristics, bare areas. Application for a Reclamation If the site meets the reclamation criteria, an application for a reclamation certificate should be submitted. The site will be inspected and a reclamation certificate issued if the criteria have been met. The wellsite reclamation certificate application form is to be used in Alberta. In Saskatchewan, surface restoration, removal of gravel and recontouring of the lease is required under the Oil and Gas Conservation Act and Regulations. Saskatchewan Energy and Resources will inspect and approve surface restoration. Reclamation certificates will be issued for crown lands from the crown agency who controls the lease. Reclamation certificates for public lands are also required. It is important that reclamation be completed successfully. REFERENCES: Alberta Environment Alberta Environmental Protection and Enhancement Regulations Conservation and Reclamation Regulation (AR 115/93) Alberta Environment Conservation and Reclamation Informational Letters Reclamation Criteria for Wellsites and Associated Facilities (C&R/IL 95-3) Burial of Materials on Lease (C&R/IL 94-4) Decommissioning and Reclamation Guidelines for Small Oil and Gas Sites in Western Canada, CAPP - September, (1992) ERCB Oil and Gas Conservation Act/Regulations; Pipeline Act GB 2000-17 Expanded Orphan Program Implementation ID 90-4 Suspension Guidelines for Inactive Wells ID 2000-09 Notification Requirements for the Discontinuation and Abandonment of Pipelines and the Abandonment of Facilities Directive D-20 Well Abandonment Guide OPX Consulting Inc. Section 14-43

Directive D-56 Energy Development Application Guide Directive D-59 Well Drilling and Completion Data Filing Requirements OPX Consulting Inc. Section 14-44

14.4.11 ENVIRONMENTAL PROTECTION Environmental Inspection Checklist BASIC INFORMATION LOCATION LEGAL ENVIRONMENTAL INSPECTOR INSPECTION DATE WELL TYPE (gas/oil, sweet/sour) General Terrain: Flat Rolling Steep Slopes Comments: Soil Type: Dry Wet Sandy Loam Gravel Muskeg Land Use: Forestry Cultivated Grazing/Livestock Wildlife (Y/N) Comments: Closest Residence: < 1 km 1 4 km > 4 km Comments: Nearest Water Course: <100 m 100 500 m > 500 m Type Size Flowing (Y/N) OPX Consulting Inc. Section 14-45

ENVIRONMENTAL MANAGEMENT AND PLANNING SAFETY PROGRAM MANUAL Policies, Responsibilities and Training, Environmental Performance Improvement 1. ENVIRONMENTAL PROTECTION PLAN AUDIT ITEM N/A SAT U/S Is there an Environmental Policy and Procedures Manual; is it current and available? Presence of CAODC Waste Management Wall Chart (Drilling Locations) CAMP RULES / ENVIRONMENTAL STANDARDS is a standard present, understandable and adhered to? Are biodegradable cleaning products used? RIG INSPECTIONS Standard is to have rigs inspected for environmental deficiencies on a regular basis. Ensure that inspections are done and that records are kept. Determine if identified deficiencies are corrected in a timely manner. All vehicles shall arrive on site free of weeds. Is there a C&R Plan for this project? (If yes, proceed to C&R section to follow) 2. DRILLING OPERATIONS Training AUDIT ITEM N/A SAT U/S Are regular environmental meetings held in the field? Are following tops covered in meetings? Proper Maintenance Release Detection / Assessment Handling of Specific Hazardous Chemicals Hazardous Waste Disposal Company Policies Legal Responsibilities Reporting Requirements What are the environmental training requirements for field staff? ERP Waste Management TDG / WHMIS Company Environmental Policy Review OPX Consulting Inc. Section 14-46

3. CONSERVATION AND RECLAMATION PLAN CONDITIONS Following is a listing of potential impacts from the project determine applicability of each impact and provide documentation of mitigation strategy employed (Rating system should reflect success of mitigation for impact). AUDIT ITEM N/A SAT U/S 1. Loss of Agricultural Capability / soil Degradation (Applies to operations in agricultural areas only) a) topsoil and subsoil mixing b) compaction and rutting c) weed introduction d) stones brought to surface 2. Upper Soil and Grubbings Conservation (Non-agriculture areas) 3. Muskeg Areas 4. Surface Disturbance a) water and wind erosion b) disturbance of sod layer 5. Water Crossings a) interruption of stream flow b) disturbance of drainage / watercourse substrates and banks c) siltation and sedimentation 6. Vegetation a) loss of native vegetation b) loss of timber c) rare and endangered species d) damaged trees e) weeds f) revegetation (agricultural zones) 7. Wildlife a) loss of habitat/biodiversity b) disturbance of wildlife c) attraction of nuisance animals d) blockage of ungulate movements e) increased hunter access f) rare and endangered species 8. Release of Pollutants Introduction of fuel or other pollutant(s) to waterbody or soil during operations. If there has been an occurrence, the Hazardous Materials Contingency Plan should be activated (Attached) 9. Interference with Other Land Uses (Non-Agricultural) a) interference with future timber operations b) interference with other industrial activities c) interference with trapping activities in Registered Trapping Areas Agricultural d) disturbance of farming operations e) disturbance of livestock operations f) risk of fire spreading off r.o.w. 10. Native Consultation / Issues 11. Archaeological, paleontological sites or historical resources 12. Operations Phase a) reclamation b) maintenance 13. Abandonment OPX Consulting Inc. Section 14-47

4. CONSTRUCTION AND DRILLING General Lease Conditions SAFETY PROGRAM MANUAL AUDIT ITEM N/A SAT U/S Is a Move on / Move Off inspection done at each site? Are there any special lease or MSL conditions? Attach documentation, ensure conditions are met. (Determine proximity to water, sumpless drilling, buried tanks, etc.) Check the berm integrity around the lease for containment. Check the lease for any off-lease erosion or other impacts. Are cattle guards and fences maintained? General housekeeping of site / rig / camp / facilities. 5. CONSTRUCTION AND DRILLING General Access Conditions/Concerns AUDIT ITEM N/A SAT U/S Observe number and condition of river crossings. Are all crossing approvals in place? Are any C&R conditions in place? Are they met? Is erosion on the access controlled? Are soil conservation methods required / in place? Are there any special license conditions that must be adhered to? (ie: wildlife issues, restricted access, access controls) Is wildlife protection required in this area? What is being done to protect wildlife? Are requirements detailed under C&R plan? Construction activities shall be confined to the allotted ROW. Construction traffic shall be restricted to existing roads, approved ROW and approved shooflies. Construction traffic shall be restricted to work side of the ROW to reduced area subjected to compaction. Wildlife shall not be harassed or fed. Dogs and firearms are not allowed on the ROW. The recreational use of ATV s by the construction personnel on the ROW is not allowed. Any incidents with nuisance wildlife or collisions with wildlife are to be reported to Fish and Wildlife and the local police detachment. Fires: Personnel shall be made aware of proper disposal methods for welding rods, cigarette butts, and other hot or burning materials; Equipment exhaust and engine systems shall be in good working condition. When the fire hazard is high, equipment should not be parked in tall grass; Construction equipment shall be equipped with spark arrestors; A water truck should be available when the fire hazard is high; Each crew shall carry (minimum) 2 shovels, 1 fire extinguisher, and a radio; A fire contingency plan should be in place and implemented when necessary. Floods: Drainage construction shall be postponed if excessive flow or flood conditions are present or anticipated. Ensure that all spoil piles are above the flood line. Archaeological or Historical Discoveries: Work shall be suspended if discoveries are made. Work shall not recommence until permission from authorities is received. Damaged trees: Fell or prune trees damaged during construction activities immediately. Do not postpone until clean-up. OPX Consulting Inc. Section 14-48

6. DRILLING OPERATIONS Prevention / Maintenance SAFETY PROGRAM MANUAL AUDIT ITEM N/A SAT U/S Does HARVARD use lead free drillpipe and collar lubricants? Do the policies for hiring subcontractors include environmental conditions / provisions? Does HARVARD use lead free non-toxic paints on all components? When components are cleaned, are non hazardous products used (degreasers, etc)? Is biodegradable rig wash used? What procedures are used to prevent freezing of BOP s? What is done with water and glycol after use? 7. CONSTRUCTION / DRILLING Surveying and Cleaning AUDIT ITEM N/A SAT U/S Landowners are to be notified prior to entry Staking: - both sides of an r.o.w. are to be marked. Do not clear beyond stakes unless approval is given - staking should be done to cross drainage s and roads at right angles, and slopes should be traversed along the fall line Working Space: - extra working space should be taken at sidebend and slopes, as well as at drainage crossings - approval must be obtained before taking additional working space Fences: need to be braced before cutting, install gates and keep closed Drainages: - minimize removal of vegetation adjacent to drainage s - fell trees away from drainage s, remove anything within the high water area Slash Disposal dispose of slash as directed by landowner. Do not conduct burning during high winds 8. CONSTRUCTION / DRILLING Grading and Topsoil Salvage AUDIT ITEM N/A SAT U/S Grading minimize along routs, minimize graded widths and on slopes Strip topsoil where grading is required and windrow to near edge. Drainage should be away from graded area. Cut and Fill should not exceed 4:1, ensure graded material does not spread onto r.o.w. Topsoil salvage measures are to be used. OPX Consulting Inc. Section 14-49

9. CONSTRUCTION / DRILLING Planning, Construction / Inspection, Monitoring (Post Construction) Abandonment, Decommissioning and Reclamation AUDIT ITEM N/A SAT U/S What is typical for clean-up efforts prior to leaving the site permanently? Are there policies in place and who is responsible? Is documentation available (checklists, sign-offs, etc.)? Are all applicable licenses and permits available as part of the EPP? Ensure these permits and licenses were obtained prior to beginning activity. List all applicable permits / licenses and ensure conditions are being met. If shoo-flies are used, they must be reclaimed as part of the clean-up. 10. DRILLING OPERATIONS Wellsite Clean-up AUDIT ITEM (BC Oil and Gas Handbook) N/A SAT U/S All analysis required for clean-up should reference analytical procedures. BC to use ERCB G-55 as guide. Disposal of wellsite waste must be Oil & Gas Production Waste Control Regulation. Hydrocarbons are not to be mixed with drilling mud wastes. Sump fluid analysis and bioassay must be conducted before submitted clean-up proposal. The district office is to be notified 24 hours before testing. A wellsite and access clean-up proposal must be submitted to the district office upon completion of initial lease and camp clean-up. A site-specific survey is to be included with the clean-up package showing dimensions of cleared areas, stock-piled topsoil, seeded and unseeded areas, etc. Specific sampling instructions are to be followed for sump samples. A sketch must accompany each sample taken for analysis. Disposal of sump fluids by the following methods: 1. Disposal of pump off; 2. Trap and mix disposal (mix bury cover); 3. Disposal of subsurface formation (encouraged by regulator). Invert systems have unique clean-up requirements. Is invert used? 11. COMPLETIONS, WORKOVERS, SUSPENSIONS AUDIT ITEM BC OIL and GAS HANDBOOK (Drilling and Production Regulation 45-48, 52, 53, 56-59) An Application to Alter a Well must be submitted to the district office. Approval may be verbal, but must be confirmed by writing on the application. The office must be notified by phone before commencing any workover or completion. A Notice of Commencement of Suspension of Operations must be submitted within 7 days after the well is placed on continuous production. Completion/Workover reports must be submitted within one month to MEI Victoria. Daily reports must be submitted to the district office within one week. N/A SAT U/S OPX Consulting Inc. Section 14-50

12. WASTE MANAGEMENT Minimization, Storage Disposal, Record Keeping, Special Materials (Asbestos, Radioactive) AUDIT ITEM N/A SAT U/S Do the companies on site have waste management plans? List companies, provide documentation. Are ERCB (or applicable) storage requirements met? Are all waste movements documented/manifested as required under applicable regulations? Where is regular equipment maintenance performed? Does HARVARD have policies/guidelines for maintenance (especially fate of wastes)? 13. DRILLING Waste Storage AUDIT ITEM N/A SAT U/S Waste bin on site? Supplied by? What is disposal path? Storage for waste lube oil. Used filter barrel storage. Mud sack storage. Casing protector storage. All construction garbage shall be continuously collected and disposed of at an approved facility to avoid the attraction of nuisance animals. Waste containers shall accompany each working unit. All garbage will be stored in bear proof containers when conflict may occur. Storage for recyclables at camp (bottles/cans). 14. DRILLING OPERATIONS/CONSTRUCTION Waste Disposal/Documentation AUDIT ITEM N/A SAT U/S Earthen pits used to store fluid from drilling or servicing must: Be constructed of impermeable material; Be located so as to not collect natural run-off; Not to be filled <1 m from top; Be emptied and filled within 1 month of rig release; Produced water may be stored if approved by local district office. Spent acid and other workover fluids require approval before disposal. If done in accordance with D&P Regulations (97), then disposal is authorized. Disposal of wash water requires approval for discharges to the environment (should not be deep welled). Used Oil Disposal Used oil should be disposed of to bulk dealer or recycled. Determine disposal path and documentation chain. Garbage / Waste bins bins from approved third party suppliers are required Determine Company Policy! Oilfield Waste All wastes must be properly identified / labeled (DOW/NDOW, Special Waste (BC)). OPX Consulting Inc. Section 14-51

AUDIT ITEM N/A SAT U/S Waste will be disposed of according to ROWMR (AB) or provincial equivalent. Wastes should be segregated: DOW/NDOW (Special) Containers Wood Metal Cable Plastic Paper Separation of recyclables: Lube oil Filters Rags Municipal Landfillable Wastes Used Oil and Fuel Filters Classified as DOW (Hazardous) policy is to have secure on-site storage, then use RB Williams for disposal. Determine disposal scheme documentation. Used gas filters are to be drained/crushed and disposed of with rig waste to local landfill. Ensure policy is adequate. TDG/WHMIS Covered under safety audit. Wastes must be manifested. Land fillable wastes must be documented. How is camp waste disposed of? (ie: grease, garbage, oil, antifreeze) Is there a camp incinerator? Is it approved? 15. ENVIRONMENTAL PROTECTION Noise, Smoke, Burning AUDIT ITEM (BC Oil and Gas Handbook) N/A SAT U/S Noise Follow ERCB Noise Directive if noise is an issue to wildlife or people contact the local district office of BCGOC. Smoke no visible smoke is allowed within 20 km of an urban centre (except in emergencies). Burning covered in other sections. 16. ENVIRONMENTAL PROTECTION Potable Water AUDIT ITEM (BC Oil and Gas Handbook) N/A SAT U/S Must comply with Safe Drinking Water Regulations. MOH Permit is required for waterworks systems regardless of source. A permit fee is required for 15 or more connections. OPX Consulting Inc. Section 14-52

17. ENVIRONMENTAL PROTECTION Gaseous Emissions/Flaring AUDIT ITEM (BC Oil and Gas Handbook) N/A SAT U/S Approvals required under WMA for any emissions. As of September 1/96 many of these emissions are authorized. Applications in writing must be made before any well testing involving flaring is done. In emergencies, this may be done over the telephone. 18. ENVIRONMENTAL PROTECTION Fuel and Chemical Storage / Handling AUDIT ITEM (BC Oil and Gas Handbook) N/A SAT U/S Fuel storage areas must have adequate berms and security. Fuel storage and refueling facilities must be >100 m from watercourses. In equipment & servicing areas, ensure the following conditions are met: An impervious tarp is to be used when servicing equipment; Oil changes and maintenance shall be conducted a minimum of 100 m away from waterbodies; Fuel and service vehicles shall carry a minimum of 10 kg of commercial sorbent material; No fuel, oil or hazardous material storage is allowed within 100 m of a waterbody; Mufflers should be used to minimize air pollution and noise; Equipment is not to be washed in waterbodies; Equipment used in water crossing construction shall be inspected to ensure they are free of leaks. Where immobile equipment is within 100 m of a watercourse: All containers, hoses, and nozzles must be free of leaks; Fuel nozzles are to be equipped with automatic shut-offs; Operators are stationed at both ends of the hose during refueling; Fuel remaining in the hose is returned to the storage facility. Proper electrical grounding must be provided for storage containers and loading/unloading equipment. All chemical bulk tanks should be grounded and have external gauges. 19. ENVIRONMENTAL PROTECTION Substance Release AUDIT ITEM N/A SAT U/S Does company have an Emergency Response Plan for releases? Provide copy if available. What are reporting requirements/flows? Release response kit on-site / complete? Any release incidents reported / cleaned-up? Incidents are to be reported to regulatory and local officials. OPX Consulting Inc. Section 14-53

15.0 CONSTRUCTION SAFETY 15.1 INTRODUCTION The Construction Supervisor, as HARVARD s representative is responsible for ensuring compliance with Occupational Health and Safety Act regulations. Of prime concern is coordinating safety activities when there is more than one employer on site. The Construction Supervisor must be aware of and fulfill his responsibilities as the representative of the Prime Contractor (See Section 2.0). All sections of this manual apply to HARVARD s facility and pipeline construction activities. 15.2 SAFETY PLAN CHECKLIST The Construction Safety Plan Checklist included in this section has been designed to provide the Construction Supervisor with a guide to most of the safety issues that must be addressed at the job site. It is intended that the checklist be completed by the Construction Supervisor at the time of the Kick-Off Safety Meeting and that it be returned to the Calgary office with final project reports. 15.3 EMERGENCY CONTACT INFORMATION In cases where the project does not fall under the jurisdiction of a site specific or area specific Emergency Response Plan, the Construction Supervisor shall complete and post a list of emergency contacts using a form similar to that attached under Forms. 15.4 WEEKLY SAFETY MEETINGS In addition to the project Kick-Off Safety Meeting (before any critical procedure) and informal Tailgate Safety Meetings, it is recommended that a meeting be held once a week involving the construction Supervisor, all Contractor Foremen, applicable contractor staff and if necessary, applicable HARVARD production operation staff. This meeting should include a review of potential safety hazards that are expected to be encountered in the coming week and identify and deal with any hazards that may have arisen since the previous meeting. Some useful safety meeting forms are attached. Also see Section 5.0 for more information about safety meetings and HARVARD work permit system. 15.5 SHUT DOWN OF PRODUCTION When modifications are being made at or near operating production facilities, the risk of damaging operating equipment or exposing workers to hazardous conditions must be determined. If standard work practices still leave a degree of higher than normal risk, consideration must be given to shutting down the operating facility. OPX Consulting Inc. Section 15-1

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 OPX Consulting Inc. Section 15-2

CONSTRUCTION SAFETY PLAN CHECKLIST PROJECT: DATE: CONTRACTOR: SAFETY First Aid Kits on Site Contractor has Safety Program on Site and Responsible for Worker Safety Safety Meeting Requirements Established Safety Committee (Multi-Contractor) Contractor Safety Meetings Tailgate Meetings Housekeeping Procedures Reviewed Work Permit Requirements Established Safety Equipment Requirements Determined Personal Protection Equipment Requirements Determined Location of Safety and Emergency Equipment Established Driving Procedures Established Vehicle and Equipment Operation Procedures Established Accident/Incident Reporting Procedures Reviewed Authority of Supervisor to Shut Down Work Identified PROJECT SCOPE Scope of Work Reviewed Restricted Work Areas Established (Where Applicable) Project Schedule Reviewed Hours of Work Established ENVIRONMENTAL REVIEW Topsoil Handling and Site Grading Fuel and Chemical Storage Waste Handling, Storage and Disposal Equipment Oil Changes HAZARD REVIEW Site Inspection to Identify, Assess and Communicate Hazards - documented H 2 S and Respiratory Equipment Review Overhead Power Lines Equipment/Material Lifts Ground Disturbance / Location of Buried Lines and Equipment Hot Work Combustible Atmospheres Confined Space Entry / Restricted Space WHMIS Trenching Energy Isolation Procedures EMERGENCY Harvard Emergency Response Plan Reviewed Emergency Procedures Reviewed Contact Information Sheet Posted Safe Areas Established First Aid Personnel Identified Fire Extinguisher Stations Established Method to Track Number of Workers on Site Established Plant Emergency Alarm Operation (Where Applicable) OTHER (list) OPX Consulting Inc.

EMERGENCY CONTACT INFORMATION LEGAL DESCRIPTION OF LOCATION: LONGITUDE: LATITUDE: FIRST AID NAMES: DOCTOR LOCATION: TELEPHONE NUMBER: CELL: AMBULANCE LOCATION: TELEPHONE NUMBER: CELL: HOSPITAL LOCATION: TELEPHONE NUMBER: CELL: FIRE DEPARTMENT LOCATION: TELEPHONE NUMBER: POLICE LOCATION: TELEPHONE NUMBER: HELICOPTER FIRM: TELEPHONE NUMBER: CELL: REGULATORY CONTACT: ERCB B.C.O.G.C. NAME: PHONE: CELL: ENVIRONMENT/FORESTRY NAME: PHONE: CELL: LOCAL MUNICIPALITY (Director of Disaster Services) NAME: PHONE: CELL: OPX Consulting Inc. Section 15-3

Lease Construction Tailgate Meeting Report Location: Contractor: Date: Project#: Employees Present: Print Signature Site Specific Hazard Identification Yes No N/A Action to be Taken Location of: Buried Pipelines Buried Cables Overhead Lines Wellhead Sumps Digging Sumps Knocking Down Trees Leveling and Slopes Towing of Trucks U/G & O/H Utilities Ditch Cut Digging Burrows/Snakepits Driving Speed Limits Other Personnel/Equipment PPE Required Emergency Contact # s Other Other Worksite Plan Company Representative (Print) Signature Contractor Representative (Print) Signature

CONSTRUCTION HSE MEETING REPORT SAFETY PROGRAM MANUAL DATE: TIME OF MEETING: LENGTH: OPERATION: FACILITY PIPELINE SITE/LOCATION: CONTRACTOR(S): CONTRACTOR SUPERVISOR(S): Harvard REPRESENTATIVE: OUTSTANDING CONCERNS: RECOMMENDED ACTION: TARGET DATE: NEW CONCERNS: RECOMMENDED ACTION: TARGET DATE: OTHER TOPICS DISCUSSED: TRAINING GIVEN: REPRESENTATIVE SIGNATURE

SAFETY MEETING ATTENDANCE CONTRACTOR: MEETING DATE: NAME SIGNATURE OPX Consulting Inc. Section 15-4

GROUND DISTURBANCE PERMIT Location: Project Activities: New Installation Tie-in/Re-entry Repairs Company Representative: Reclamation Construction Other Contractor: Date: If ANY of the items listed are answered NO, proceeding with any ground disturbance may contravene company policy, and may result in injury to personnel, damage to equipment, or environment. Supervisor approval is recommended. Documentation of decision is required. RECORD CONFIRMATION YES NO N/A 1. Do you have a copy of the Survey Drawing for the well site, access road, and/or proposed ground disturbance area? *NOTE* If the survey drawing is older than 60 days, consideration should be given to getting an updated survey drawing. 2. Do you have a copy of the Surface Acquisition report? 3. Does the survey drawing Table of Crossing match with the Surface Acquisition Report Table of Crossings? 4. If questions 1-3 are N/A, has the proposed area of the disturbance and buffer zone been electronically scanned? 5. Do you have a recent copy of the Land Title Certificate or Public Land Standing Report? 6. Do you have a copy of the most recent Provincial/Company Pipeline baseline map? 7. Did you notify the Land Agent (Crown Land) or Land Owner (Freehold Land) of your intentions and review any existing underground facilities? Name: 8. Do you have a copy of all Crossing Agreements for any facility identified within 30 metres of the work area? 9. Did you adhere to the crossing notification requirements? 10. Did you contact local Production office and review scope of work and crossings? Name: 11. Have all pipelines, power lines, and utilities in the 30 metre search/controlled area been identified? 12. Has the One Call System been notified of our intentions? VISUAL INSPECTION 1. Are all buried pipelines, power lines, or utilities identified on above drawings, and staked on the ground in proposed area? 2. Are overhead power line Caution Signs in place? 3. Are all the locate stakes or marks referenced to fixed features? 4. Are all of the lines within the 30 meter search/controlled zone identified on the ground? 5. Are there any signs of new ground disturbances within the proposed working area, including the search/controlled zone? This may include pipelines, power lines, Gas Co-op, utility cables, new clearings, road construction, pipeline signs, settlement, vegetation color change or growth. If there is any visual sign of activity that is not reflected on Survey Drawing, re-surveying should be considered. PRE-CONSTRUCTION 1. Is the proposed ground disturbance expected to be any depth below the surface? *CAUTION* - any depth below the surface is a general rule. Ground disturbances located at any depth may encounter lines improperly installed or changed due to shifting ground disturbances. Additional crossing material should be considered. 2. Are there any pipelines, power lines, or utility cables being crossed within the 5 meters where no right-of-way or within the distance outline in crossing agreements? 3. Are ALL the conditions of the Crossing Agreements being met? 4. Have all the underground facilities been exposed as per the company requirements, crossing agreements, and the Regulations? 5. Distance to which mechanical equipment may be operated after exposure from agreement mm 6. Did you conduct a pre-job task meeting with foreman and equipment operators? Review Procedures & ERP. NOTE: This document is designed to be a GUIDE to the minimum safety standards for Ground Disturbance. Refer to the Provincial Regulations, Company Standard Safety Practices Manual, contractor s safety program, and Provincial Health & Safety Statute and Regulations for further details. If project involves interprovince activity, the National Energy Board has additional requirements. SEE NEXT PAGE FOR REFERENCES. Comments: Company Representative: Contractor Representative: Ver. 1.0

DEFINITIONS GROUND DISTURBANCE - is any work, operation, or activity without limitation that results in a disturbance of the earth at any depth. SEARCH AREA- is the 30 meters surrounding the ground disturbance area in which all reasonably necessary precautions must be taken to determine whether or not an underground facility exists. NOTIFICATION - Every owner within the ground disturbance area and the 30 meter search area must be notified of the nature and schedule of the ground disturbance. Notification must be done as per the crossing agreement or as per provincial Regulations of a minimum of 2 working days and a maximum of 7 working days, or greater, as specified in the crossing agreement. CROSSING AGREEMENTS (also referred to as APPROVALS) - Anytime a ground disturbance takes place within a right-of-way, or within 5 meters of a facility where there is no right-of-way, an approval must be in writing. NOTE: A crossing agreement is commonly used as the approval and does not mean an actual crossing is taking place. HAND EXPOSURE - Hand exposure must be done if the ground disturbance crosses or is carried out within 5 meters of an existing underground facility before commencing any mechanical excavation. When exposing the underground facility it must be done sufficiently to identify the facility. Excavation techniques have been developed using water or air jets. These have generally been accepted, although all procedures may not have specific regulatory approval. Care should be taken to evaluate the best method of hand exposure, taking into consideration, damage to coatings, and methods of soil disposal. CAUTION: Even after hand exposure, mechanical equipment must not be used within the distance specified on the crossing agreement, OR, if a crossing agreement is not present, not closer than 60 cm. to the underground facility. REFERENCES ITEMS # 1, 2, 3, 5, & 6 ITEM # 5: ITEM # 10: ITEM # 12: GENERAL: Your surveyors or line locating company usually provide these items. For Freehold Land, this is referred to as Certificate of Title which includes registered ownership and any incumbencies against the property. For Public Lands, this is referred to as the Public Land Standing Report, which includes a listing of any registered dispositions against the property. Plot Plans or lease drawings should be obtained and discussed with area Operations Personnel. Experienced company personnel familiar with area operations may have knowledge of pipelines or utilities not otherwise documented. One-Call Systems provide a no-charge, computerized communication service to advise and help the ground disturber with the location of buried pipelines and utilities. CAUTION: Not all companies are One-Call System members, and as such, it is probable that not all underground facility owners will be notified that you are creating a ground disturbance in the area. It is necessary to perform all the steps to a ground disturbance to ensure as far as it is reasonable and practicable, what is in the ground before you start to dig. The Provincial Acts and Regulations should be available for reference and further resources. Ver. 1.0

BACK FILL INSPECTION FORM NAME OF EXISTING FACILITY OWNER PROJECT: Crossing Agreement Number AB/BC LSD SEC TWP RGE W M BC QTR UNIT BLOCK /MAP SUB DIV SHEET TYPE OF FACILITY: (Check One) Pipeline Road Rail Road Water Course Data Cable Other: (Specify) Type of Damage Damage repair satisfactory Regulatory agencies notified if damage Indicate approximate location on above plan R.R. Depth Existing Depth New Road River Bed Existing Depth NewPL OR Depth Existing Existing Depth Grade Depth Cased Uncased Road, RR X-ing River/Creek R/W Pipeline - R/W INDICATE: 1. Depth to existing line (On Elevation) 2. Depth to new line above or below existing line (On Elevation) 3. Cathodic protection installed: YES NO 4. If yes, what type of protection? Owner of foreign or existing facility: Size and condition of existing facility: (New) oil, gas, water, etc.: Contractor doing work: Approval Print Name Date Completed Company Signature Print Name Date Completed Contract Signature Ver 1.0

16.0 GENERAL INFORMATION 16.1 GLOSSARY OF TERMS ACGHI American Conference of Governmental Industrial Hygienists ACCIDENT An undesired event that results in physical harm to a person, damage to property of loss to process (ILCI) ANSI American National Standards Institute API American Petroleum Institute APPROVED Refers to approval by a recognized testing agency or authority for use under existing conditions (e.g. NIOSH, CSA) ASME American Society of Mechanical Engineers BLANKING Equipment used to isolate piping and prevent accidental exposure to or release of flammable or toxic liquids or gases into work areas. BONDING A bond is an electrical tie or connection between two conducting bodies, which are usually metallic. The purpose of bonding is to prevent sparking by providing a path over which stray currents and static charges may drain. BOP Blowout Preventor CANUTEC The Canadian Transport Emergency Centre CARCINOGEN A cancer-producing substance or agent CCOHS Canadian Centre for Occupational Health and Safety CHIEF OPERATING EXECUTIVE The most senior decision-making person at a location. OPX Consulting Inc. Section 16-1

COMBUSTIBLE MATERIAL Combustible materials are ones that, either by themselves or in combination with their packaging, are highly susceptible to ignition and will contribute to the intensity and rapid spread of fire. Moderately combustible materials are ones that, either by themselves or in combination with their packaging, will contribute fuel to fire. Noncombustible materials are ones that will neither ignite nor support combustion. COMPETENT Competent, when referring to a worker, means adequately qualified, suitably trained and with sufficient experience to safely perform work without or with minimal supervision. CONFINED SPACE A restricted space which may become hazardous to a worker entering it because of: an atmosphere that is or may be injurious by reason of oxygen deficiency or enrichment, flammability, explosivity or toxicity; a condition or changing set of circumstances within the space that presents a potential for injury or illness; or has the potential or inherent characteristics of any activity which can produce adverse or harmful consequences within the space. Confined spaces include but are not limited to: tanks, bins, vessels, towers, furnaces, tank cars, sewers, pipeline, sumps, utility tunnels, dyked areas, excavations, boilers, silos, ventilation and exhaust ducts, vessel skirts, utility vaults, valve wells and pipe racks. CONFINED SPACE ENTRY A person is considered to have entered a confined space when that person has sufficiently approached or passed the threshold of the confined space, to be essentially breathing the atmosphere of the confined space. CONSULTANT An individual hired to provide professional or expert advice or services. CONTRACTOR An individual or company hired under contract to provide services or supplies to another individual or company. CONTROLLED PRODUCT A product, material or substance included in any of the classes listed in Schedule II of the Hazardous Products Act (specified by the regulations made pursuant to paragraph 15 (1) (a) of the Act). CORROSIVE Having the quality to corrode or consume (e.g., acid, or H 2 S). CRITICAL JOB/TASK A specific element of work which historically has produced and/or which possesses the potential to produce major loss (people, property or financial) when not properly performed. OPX Consulting Inc. Section 16-2

CRITICAL JOB/TASK INVENTORY LIST A comprehensive list of critical job/tasks produced from systematic survey of all jobs/tasks in the department. The list should include a statement of the criteria used to identify a critical job/task CRITICAL PART/ITEM An item or component part of machinery, equipment, material, structure or area that is likely to result in a major problem or loss when worn, damaged, abused, misused or improperly applied, etc. Those critical few items or parts, which when worn, damaged, abused, misused, or improperly applied, are more likely to result in a major problem or loss. CSA Canadian Standards Association DETECTION SYSTEM A device or control to identify hazardous, potentially hazardous, or abnormal conditions and to provide a warning to people and/or prevent loss. EMPLOYEE Any person employed by a company, including managers, supervisors and workers. ENGINEERING CONTROL Methods of controlling employee exposure to safety and health hazards by enclosing the hazard, isolating the employee from the hazard, or reducing the transmission of the hazard to the employee, without the use of personal protective equipment. ERGONOMICS A rational approach to designing and constructing equipment and environments so that they allow workers to be more productive and efficient while making fewer errors and facing fewer safety hazards than in other situations. Ergonomics are used to make equipment and environments more convenient, more comfortable, less confusing, less frustrating and less tiring. EXCAVATION Any man-made cavity or depression in the earth s surface, including its sides, walls or faces, formed by earth removal and producing unsupported earth conditions by reason of the excavation. If installed forms or similar structures reduce the depth-to-width relationship, an excavation may become a trench (a trench is always an excavation, but an excavation is not necessarily a trench). FIRST AID One-time treatment of minor scratches, cuts, burns, etc. with possible follow-up visits for observation, but not treatment. FIRST AID UNIT Equipment and facilities for administration of necessary first aid treatment and for removal of people from hazardous areas. OPX Consulting Inc. Section 16-3

FLAMMABLE LIQUID Any liquid with a flash point below 200 F. FLASH POINT The lowest temperature at which vapours over volatile combustible substances will ignite when exposed to external sources of ignition (and will continue to burn after the source is removed). FUGITIVE EMISSION Gas, solid, liquid, fume, mist, fog or dust that escapes, unplanned from process equipment, emission control equipment or from a product. HANDLING Storing, dispensing and disposing of materials or containers. HARMFUL SUBSTANCE A substance which because of its properties, application, or presence, creates or could create a danger, including a chemical or biological hazard, to the health and safety of a worker exposed to it. HAZARD CLASSIFICATION A designation of relative loss potential. A system that classifies substandard practices or conditions by the potential severity of the loss, should an accident or loss occur. HAZARD LABEL A label required on controlled products. HAZARDOUS CONDITION Any situation which exposes workers to a physical, chemical, electrical, high energy, etc. hazard that may adversely affect their health or safety. HAZARDOUS ENERGY Means electrical, mechanical, hydraulic, pneumatic, chemical thermal, gravitational, or any other form of energy that could cause injury due to the unintended motion, energizing, start-up or release of such stored or residual energy in machinery, equipment, piping, pipelines or process systems. HAZARDOUS LOCATION A place where fire or explosion hazards may exist due to flammable gases or vapours, flammable or combustible dust or ignitable fibres or flyings, as described in the Canadian Electrical Code HAZARDOUS PRODUCT Any product that is prohibited, restricted or controlled, and can cause harm to workers or the environment. OPX Consulting Inc. Section 16-4

HOT TAPPING The process of welding a branch or connection onto a pressure vessel, tank, connected piping or pipeline that contains flammable or other materials. The welding is done without blinding and purging the equipment beforehand. HOT WORK Any work involving burning, welding, riveting, grinding or other similar fire or spark-producing tools or operations, as well as work which produces a source of ignition, such as drilling, abrasive blasting, and space heating. H 2 S Hydrogen Sulphide IAPA Industrial Accident Prevention Association of Ontario ILCI International Loss Control Institute INCIDENT An undesired event that, under slightly different circumstances, could have resulted in personal harm, property damage, or loss to process. Also referred to as a near miss (ICLI) INSPECTION The careful examination of people, equipment, materials, and the environment, the close and critical scrutiny for comparison with standards. ISOLATE Means using a mechanical device to restrain, regulate, direct, or dissipate hazardous energy. ISOLATION A process whereby a confined or isolated space is completely protected against the inadvertent release of material or energy. JOB/TASK ANALYSIS A systematic analysis of the steps involved with doing a job/task, the loss exposures involved, and the controls necessary to prevent loss. It should be a prerequisite to the development of work procedures and practices. An important step in the analysis would be consideration of the elimination or reduction of hazards. JOURNEYMAN ELECTRICIAN An electrician who has completed a specified number of hours of practical work and training as well as classroom study and exams. The requirements vary among the provinces. LC 50 Lethal concentration. LC 50 indicates the atmospheric concentration of a substance at which half of the group of test animals die after a specified exposure time. OPX Consulting Inc. Section 16-5

LD 50 Lethal dose; lowest dose of a substance introduced by any route, other than inhalation, over any given period of time in one or more divided portions and reported to have caused death in half of the test animals. LEL Lower explosive limit. LOCAL VENTILATION Removal by mechanical means of gases, dust, etc., at their source or origin. LOST-TIME ACCIDENT An accident that causes a person to be away from work beyond the day of the injury. OR A disabling injury where the employee was not able to show up for his or her regular work shift the next day. LOWER EXPOSURE LIMIT The minimum concentration of a combustible gas or vapour in air, expressed in percent by volume, which will ignite if an ignition source is present. MANAGER/SUPERVISOR A person who has charge of a work place or authority over a worker. MANUFACTURER S RATED CAPACITY The manufacturer s specifications, instructions or recommendations which outline how equipment is to be erected, installed, assembled, started, operated, used, handled, stored, stopped, adjusted, maintained, repaired or dismantled. They may include manufacturer s instruction, operating or maintenance manual and drawings. MATERIAL SAFETY DATA SHEET (MSDS) An information sheet containing health and safety information on the handling and storage of a product. MEDICAL AID An injury that requires treatment from a professional medical doctor or dentist. The injury is not severe enough to prevent the employee from returning to work the next day. MEDIVAC Medical evacuation service. MSHA Mine Safety and Health Administration (of the U.S. Department of Labour) NEC National Electrical Code NFPA National Fire Protection Association OPX Consulting Inc. Section 16-6

NIOSH National Institute for Occupational Safety and Health OCCUPATIONAL ILLNESS Any abnormal condition or disorder of an employee (other than one resulting from an occupational injury), caused by exposure to environmental factors associated with employment. OCCUPATIONAL INJURY Any injury that results from a work accident or from exposure to environmental factors associated with employment. OH&S Occupational Health and Safety OSHA Occupational Safety and Health Administration (USA) PERSONAL PROTECTIVE EQUIPMENT The equipment or clothing worn by a worker to reduce the consequences of exposure to various hazards associated with working conditions or a work site. Personal protective equipment includes: burning goggles, chainsaw pants, chemical goggles, chemical suits and aprons, cold weather clothing, dust masks, face shields, fire-retardant clothing, gloves, hard hats, hearing protection, high visibility safety vests, hoods, safety goggles, safety helmets and safety toes footwear. POLICY A senior management statement which guides administration, reflects management s attitudes and commitment to safety and health, and defines the authority and respective relationships required to accomplish the organization s objectives. POSITIVE ISOLATION The blinding off, plugging or the complete removal and blanking off of inter-connecting piping, vessels or sewers which may contain hazardous material. PPM Parts Per Million PRESSURE VESSELS Devices designed to contain gas or vapour under pressure. PREVENTABLE MOTOR VEHICLE ACCIDENT A preventable accident is any occurrence involved in a Company owned, leased, rented or operated vehicle which results in property damage and/or personal injury regardless of who was injured, what property was damaged, to what extent, or where it occurred, in which the driver in question failed to do everything the worker reasonably could have done to prevent the occurrence. OPX Consulting Inc. Section 16-7

PROCEDURE An established and defined method of performing specified work. PRODUCT IDENTIFIER The brand name, code name or code number specified by a supplier, or the product s chemical name, common name, generic name or trade name. This should be the name under which the product is sold. PSV Pressure Safety Valve PURGE To rid of impurities or undesirable by bleeding, venting, etc., generally with steam, inert gas, nitrogen or C0 2. QUALIFIED PERSON A person designated by the employer as capable (by experience, education and/or specified training) to properly fulfill the required function. RESPIRATORY PROTECTION Refers to any respiratory protective device or system designed to protect the wearer from inhalation of toxic or irritating substances. It can include air-purifying respirators, supplied air respirators or self-contained breathing apparatus. RESTRICTED SPACE An enclosed or partially enclosed space that is not designed or intended for continuous human occupancy with a restricted means of entry or exit and may become hazardous to a worker entering it because of its design, construction, location or atmosphere; the work activities, materials or substances in it; provision of first aid, evacuation, rescue or other emergency response service is compromised or of other hazards relating to it. SAFE WORK PERMIT A written record that authorizes specific work at a specific work location. It identified the known hazards and safe work practices required for the work. SAFE WORK PROCEDURE A set of guidelines for performing specific work assignments properly (efficiently, safely, productively). SAFETY EQUIPMENT Equipment used to reduce the consequences of worker exposure to various work site hazards. Safety equipment includes oxygen and other monitors, personal protective equipment, safety belts, lanyards and lifelines. SECURE Refers to an energy-isolating device that cannot be released or activated by removing any activating device, attaching a lock to the energy-isolating device that is operated by a key or similar device, or attaching to the energy-isolating device a mechanism other than a lock which is designed to withstand inadvertent opening without the use of excessive force, unusual measures, or destructive techniques. OPX Consulting Inc. Section 16-8

SCBA Self-Contained Breathing Apparatus SNUBBING Means the act of moving tubulars into or out a wellbore when pressure is contained in the well through the use of stripping components or closed blowout preventers (BOP s) and mechanical force is required to move the tubular in order to overcome hydraulic force exerted on the tubular in the wellbore. SPECIFICATIONS The written instructions, procedures, drawings, or other documents of a professional engineer or employer. They can relate to equipment, work process or operation. SPOIL The material resulting from an excavation. STANDARD The defined criterion of effective performance. SUB-CONTRACTOR An individual or company hired to perform all or part of the work contracted to someone else. TDG Transportation of Dangerous Goods (Act) THRESHOLD LIMIT VALVE (TLV) Concentration of airborne materials which are used as guides in the control of health hazards and represent time weighted averaged concentration to which workers may be repeatedly exposed eight (8) hours per day over extended periods without adverse effects. TOXIC SUBSTANCE Any substance that is present or has the potential to be present in concentrations which may adversely affect the health of an exposed individual, as defined by provincial chemical exposure regulations. TOXICITY The ability of a chemical to cause harmful effects in a biological system. TRENCH A narrow excavation made below the surface of the ground. In general, the depth is greater than the width, but the width of a trench is not greater than 4.6m (15 feet). TRENCH SHIELD A shoring system composed of steel plate and bracing, welded or bolted together to support the walls of a trench from the ground level to the trench bottom. The shield can be moved along as the work progresses. OPX Consulting Inc. Section 16-9

UEL Upper explosive limit, or the maximum proportion of vapour or gas in air above which propagation of flame does not occur. VAPOUR Gaseous phase of a substance which is liquid at normal temperature and pressure. WCB Workers Compensation Board WORK POSITIONING SYSTEM Means a system of components attached to a vertical safety line and including a full body harness, descent controllers and positioning lanyards used to support or suspend a worker in tension at a work position. WHMIS Workplace Hazardous Materials Information System WORKER An employee under the supervision of a manager or supervisor. ZERO ENERGY A piece of equipment is in a state of zero energy when all sources of energy (e.g. electrical, mechanical, hydraulic, pneumatic pressures, spring tension, gravitational etc.) are effectively blocked or isolated and physically prevented from being energized by a isolation device. OPX Consulting Inc. Section 16-10

17.0 FORMS & CHECKLISTS 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. Section 17-1

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

SAFETY STATEMENT TO BE POSTED AT EVERY WORK SITE Well/Facility Name: TO: ALL EMPLOYEES AND EMPLOYERS AT THIS SITE HARVARD ENERGY IS COMMITTED TO A SAFE WORKING ENVIRONMENT. SAFETY WILL NOT BE COMPROMISED BY USING UNSAFE EQUIPMENT OR PROCEDURES. THE FOLLOWING CONDITIONS APPLY TO ALL HARVARD OPERATED WORK SITES. 1. All supervisory personnel, whether consultants or Harvard employees, and contractor personnel employed at this site must have received suitable training and be sufficiently experienced to carry out his/her job duties. 2. Appropriate Personal Protective Equipment must be worn on work sites as indicated by a completed Hazard Assessment. This may include hard hats, hearing protection, CSA approved footwear, eye protection and other Personal Protective Equipment as required. 3. All unsafe equipment or working conditions must be reported to your supervisor or the well site supervisor immediately. Should the unsafe condition not be rectified the personnel involved should report to the following by collect telephone call: Project Manager: Business: Cell: Operations Manager: Business: Cell: 4. Regular safety meetings and inspections must be carried out and properly documented. 5. Any accident, whether lost time or otherwise, unsafe acts or near misses must be reported immediately by the work site supervisor to the above by telephone and in writing by the next morning. The contractor s written report, and if required, copies of the applicable provincial W.C.B. forms MUST BE FAXED TO THE CALGARY OFFICE AS SOON AS POSSIBLE. OPX Consulting Inc. Section 3-5

WORK SITE SAFETY PLAN CHECKLIST (Drilling & Completions Supervisors) OPERATOR: LOCATION: WELL SITE SUPERVISOR: RIG# / RIG MANAGER: DATES: From: To: The Operator is designated as the Prime Contractor for this operation. The Well Site Supervisor is the agent of the Operator. The following checklist summarizes the key elements of the required work site safety plan. Well Site Supervisors are requested to submit the completed checklist upon completion of the job. YES NO N/A GENERAL Have you reviewed and posted HARVARD s HS&E Policy & Safety Statement? Have all identified landowner requirements been identified and addressed? HAZARD IDENTIFICATION AND ASSESSMENTS / INSPECTIONS Is a Hazard Assessment completed for each task being conducted? Are the results of Hazard Assessments reviewed during the Safety Meeting Process? Review Well Site Layout (as per provincial regulatory requirements). Have the rig anchors been installed and tested as required? Are CAODC rig inspections or equivalent being completed as required? Have you received copies of all inspections completed on the worksite? Has the CAODC BOP been completed as required? Have the mouse/rat holes been identified prior to moving completion rig on site. SAFETY COMMUNICATION Are Safety Meetings held on regular basis? Are the meetings documented and are you receiving copies of the meeting minutes? As the Supervisor have you attended pre-job safety meetings for critical/non critical operations? Have you reviewed regulatory permits and license conditions? Safe Work Permits: have you identified requirements and issued necessary permits? Has a pre-job tailgate safety meeting been conducted prior to each specialized operation? INCIDENT REPORTING AND INVESTIGATION Are Contractors and their personnel aware of the HARVARD incident reporting procedures, and are they complying? Are you ensuring all incidents/near misses are investigated reported and corrective measures implemented? EMERGENCY RESPONSE PLANNING Has the Corporate/Site Specific ERP been reviewed with onsite personnel? Have emergency numbers and directions to lease been posted and is a map of area available for quick reference? Are lease signs adequate to direct emergency response workers to the site?

YES NO N/A Have muster points been identified and all personnel aware of them? Are First Aid/Emergency Services available including a transportation method? Are supplies well maintained and do they meet regulated standards? Has the communication equipment on the worksite been tested for emergency response procedures? HAVE SAFE WORK PROCEDURES BEEN ESTABLISHED FOR THE FOLLOWING JOB HAZARDS? Sour operations. Hot work. Confined space / Restriced space entry. Overhead power lines. Hazardous materials. Ground disturbances (buried pipelines, electrical, telephone) Control Hazardous Energy Pressure testing. Radioactive sources. Appropriate work procedures available on-site and posted as required. Fall protection to include use of man basket & high angle rescue training. Other non-regular operations. Well flow back operations including DST testing. LEL Monitoring. WORKER HEALTH AND SAFETY Is appropriate personal protective equipment and other safety equipment available and being used by all workers? (i.e. F. R. clothing). Is the PPE and safety equipment in good working order and is there a preventative maintenance and inspection program for equipment? Is there special monitoring equipment available? (i.e. H 2 S, LEL). Have you review local access hazards and speed limits? TRAINING REQUIREMENTS Have all workers on site completed an HARVARD Safety Orientation (Handbooks) and do they have an orientation hardhat sticker? Have you collected the orientation quizzes/acknowledgement sheets from the workers? First Aid/CPR; verify number of qualified people available on site H 2 S; verify number of qualified people on site. Blow out prevention certification: Rig Manager Drillers Site Supervisor WHMIS / TDG: Rig Manager Drillers Crew Site Supervisor CONTRACTOR SAFETY PROGRAMS Do Contractors have safety programs in place and available on site? ENVIRONMENTAL PROTECTION Have fuels and chemicals are properly stored? Is the required waste handling, storage and disposal procedures in place? Have all spills been cleaned up immediately and reported? CAMP (If Applicable) Are there adequate smoke detectors and fire extinguishers? Are regular emergency drills conducted, and do they correct deficiencies identified? Have Camp Rules been posted at the main entrance and kitchen area of camp?

WELL SITE SUPERVISOR S COMMENTS: SUPERVISOR DATE

Well Safety Check & Hazard Identification Facility Name: Location: Date Inspected: Completed by: 1 = Acceptable X = Unacceptable N/A = Not applicable/assessed SITE Proper signage Item Housekeeping. general appearance Snow removal - sufficient or piled By doors or on pipes. Driving Hazards flagged (risers, lines, etc) Bull plugs in place Fire extinguisher access and inspection dates Piping secured Slipping and tripping hazards Location access, road Flammable liquid storage (safe distance from heaters) Proper storage of chemicals Adequate WHIMIS labeling Date PSV s serviced Vegetation Control Steps and handrails Vibration Shutdowns not bypassed Safety equipment: SCBA Burn Blankets Eye wash stations First aid kits, clean/full ESDV s in service and block valves locked open Combustible materials present Guards on moving equipment satisfactory Electrical equipment secure Tanks Secondary Containment Truck Loading cable, containment Comments and/or if answered Unacceptable, describe Action Proposed / Control Date Completed Frequency of Follow-up

SERVICE RIG INSPECTION CHECKLIST NOTE: ANY HAZARD OR DEFICIENCY MUST HAVE AN EXPLANATION AND BE CORRECTED *Transcribed from the CAODC Manual* Company: Rig No.: Rig Mgr: Rig Operator: Operating Company: Operating Company Representative: Date: Time: am/pm Location: (yr) (mo) (day) Current Operation Being Performed: GENERAL RIG 1 All guards in place and in good condition Yes No 2 Matting in good condition Yes No 3 Leveling jacks properly matted, locked and derrick centered over well properly Yes No 4 Guy lines properly anchored Yes No - Pull tested Yes No - Rating lbs. 5 Escape line pull test preformed Yes No - Rating lbs. 6 Guy line come-alongs, etc. in good condition Yes No 7 Minimum required clamps properly installed on: (a) Guy lines Yes No (b) Load lines Yes No (c) Escape line Yes No 8 Air shutoffs checked by operator and operational Yes No 9 Emergency shutoff control positions: (1) Operator s panel Yes No (2) Sandline controls Yes No 10 Operator s controls properly marked Yes No 11 Weight indicator working properly Yes No 12 Crown saver - Installed N/A Yes No - Set and tested Yes No 13 Exhaust pointed away from well and shielded Yes No 14 Railings in place on side walkways and stairs Yes No 15 Condition of handrailings, walkways and stairs Good Hazard 16 Hand tools: condition, clean and properly stored Good Hazard 17 Working floor, housekeeping, toe plates, ladders and handrails Good Hazard 18 Catwalk conditions N/A Good Hazard 19 Walkway from ground to catwalk (stairs) Yes No 20 Walkway from working floor to catwalk or ground Yes No 21 Rig properly secured in drawworks gear Good Hazard COMMENTS/EXPLANATION: DRAWWORKS 22 Conditions of drill line (slipped regularly) Good Hazard (a) Slip and cut record Yes No 23 Sufficient wraps (min.7) left on drum with blocks down Yes No 24 Braking system - Linkage/pin satisfactory Yes No - Block wear Good Hazard 25 Condition of sandline & rope socket to sinker bars Good Hazard 26 Handling winch/line Good Hazard Condition at: - Winch anchor points Good Hazard - Winch line Good Hazard - Winch line thimble Good Hazard - Tall chain Good Hazard - Safety hook Good Hazard - Hydraulic hoses & connections Good Hazard - upper shivs & assembly Good Hazard COMMENTS/EXPLANATION: MAST 27 Stand pipe properly anchored to mast Yes No 28 Kelly hose in good condition Yes No 29 Kelly hose safety lines or chain attached to derrick and swivel ends while in use Yes No 30 Levels I, II, III or IV inspections completed as required in CAODC RP 3.0 Yes No 31 Ladders in good condition Yes No 32 Rod basket in good condition N/A Yes No 33 Crown sheaves greased and in good condition Yes No 34 Safety cables attached to fingers on tubing board Yes No 35 Derrick locking pins in place Yes No 36 Derrick hydraulic system in good condition Yes No 37 Mast lighting secured adequately Yes No 38 Dead lines anchor and retainer properly placed Yes No COMMENTS/EXPLANATION: TRAVELING ASSEMBLY 39 Levels I, II, III or IV inspections completed as required in CAODC RP 4.0 Yes No 40 Blocks - nuts, safety pins in place and in good condition Yes No - Sheave guards/lock in good condition Yes No 41 Balls/links - good condition Yes No 42 Elevators - good condition Yes No 43 Rod hook - good condition Yes No 44 Transfer elevators - good condition Yes No 45 Safety latch/ring in place Yes No COMMENTS/EXPLANATION: POWER TONGS 46 Back-up in place and functional Yes No 47 Torque arms safety line, clamps in good condition Yes No 48 Tong positioner - operational and in good condition Yes No 49 Hoses, gauges and hydraulic fittings in good condition Yes No COMMENTS/EXPLANATION: ELECTRICAL/LIGHTING 50 Light bulbs enclosed with vapour-proof and shatter-proof covers Yes No 51 Covers on unused receptacles Yes No 52 Light switches vapour-proof Yes No 53 Electric motors within 8.5 metres radius must be explosion-proof Yes No 54 Equipment properly grounded Yes No 55 All cords and plug ends in good condition Yes No 56 Proper clearance from power lines Yes No COMMENTS/EXPLANATION: RIG PUMP AND TANK 57 Condition of pipe and unions Good Hazard 58 Pump and return lines laid out and secured Yes No 59 Kill line attached to well with valve open (steel lines only) Yes No 60 Pressure relief valve (proper size and rating) Yes No 61 Relief valve set at or below system working pressure NOTE: Only shear pins appropriate Yes No to the pop valve requirements as specified by the manufacturer shall be used 62 Relief valve discharge points down and away from pump motor and is securely fastened Yes No NOTE: No valve on relief line 63 Manifold conditions Good Hazard 64 Check valve in place on pump discharge Yes No 65 Exhaust away from rig tank Yes No 66 Emergency shutoff checked and operational Yes No 67 Pump controls properly marked Yes No 68 All railings in place on walkways/stairs of rig pumps and tank Yes No COMMENTS/EXPLANATION: DOCUMENTATION 69 Necessary transportation documentation and equipment present (i.e. registration, insurance) Yes No 70 Required inspection certificates available Yes No 71 Derrick log book available and updated Yes No COMMENTS/EXPLANATION: F

BLOWOUT PREVENTER SYSTEM 72 BOP function tested - From remote controls Yes No - From accumulator controls Yes No 73 All studs used on BOP stack Yes No 74 Hydraulic preventers installed Yes No - Pipe rams Yes No - Blind rams Yes No - Annular preventer Yes No 75 Condition of ram rubbers and elements Good Hazard 76 Fire-shielded hoses and their condition within 7 metres of wellhead Good Hazard 77 Remote stand 7 metres from well - Class I & II - Refer to BOP regulations Yes No - Or at remote accumulator - Class III Yes No 78 Nitrogen back-up supply pressure kpa - Min. 12,500 kpa if annular preventer is installed - Min. 7,000 kpa when only rams are installed 79 Pre-charge check date / / Good Hazard 80 BOP's adequately heated Yes No 81 Lines protected in vehicle crossing area when remote accumulator is used Yes No 82 Safety valve fully opened with proper thread connection on rig floor c/w closing wrench Yes No COMMENTS/EXPLANATION: ENVIRONMENTAL 83 All equipment free of leakage Yes No - If no, adequately contained Yes No 84 Rig site free of material that may create a fire hazard NOTE: Equipment spacing must ensure unimpeded access to well at all times Yes No COMMENTS/EXPLANATION: BOILER 85 Chemical storage Good Hazard 86 Blowdown line labeled Yes No 87 Pop valve line labeled Yes No 88 Controls - Labeled Yes No - Condition Good Hazard COMMENTS/EXPLANATION: VALID CERTIFICATES ON LEASE: HEALTH & SAFETY 89 Occupational Health and Safety manual at rig site Yes No 90 Proper BOP regulations at rig site (i.e. G-37) Yes No 91 Clothing policy in place Yes No 92 Rig Safety Equipment: (a) CSA approved full body harness Yes No (b) Escape line and buggy at station of work Yes No 93 Wind flags -Guy lines Yes No - Pump/tank area Yes No 94 Clothing - Hard hats Yes No - Safety boots Yes No - Protective clothing Yes No 95 Safety glasses or goggles available Yes No 96 Hearing protection available Yes No 97 Fire extinguishers: - Minimum 4 working and readily available for use (13.6 kg) Yes No - Extinguishers in good condition Yes No 98 First aid kit adequately stocked Yes No 99 Record book in place Yes No 100 Eyewash bottle Yes No 101 Stretcher and blanket Yes No 102 H2S detector - Chemical tube type Yes No 103 Breathing apparatus requirements met Yes No - Condition Good Hazard - Bottles full Yes No - Spare bottles Yes No - Date of hydrostatic test on bottles / / 104 Signs - No smoking Yes No - H2S area (if applicable) Yes No - No vehicles beyond this point Yes No 105 Housekeeping - Rig Good Hazard - Changeroom Good Hazard - Vehicles Good Hazard - Rig pump Good Hazard - Rig tank Good Hazard - Lease Good Hazard - Boilers N/A Good Hazard Winterizing - Pre-tab, heaters etc. Yes No 106 Condition of Fall Protection equipment Good Hazard COMMENTS/EXPLANATION: OTHER COMMENTS ON THIS INSPECTION: Rig Manager: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Operator: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Derrickman: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Floorhand: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Floorhand: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Other: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Other: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: Other: BOP Exp. / H2S Exp. / First Aid Exp. / TDG Exp. / WHIMS Exp. / Boiler Exp. / Other: N 50 m 25 m ROUGH IN LEASE DIAGRAM Water/fuel tanks WT/FT Mud Pump MP Boiler B Light Plant LP Crew change unit CCU Accumulator ACC Fire Extinguisher FE Others Specify Inspection completed by: Position: F In company with: Position:

DRILLING RIG INSPECTION CHECKLIST CONTRACTOR: RIG NO.: RIG MGR.: LEASE LOCATION AND LSD: CRITICAL SOUR WELL (Y/N): INSPECTED BY: DATE: / / TIME: hrs (Yr) (Mo) (Day ) (24 hr clock) Mark a check if adequate A or inadequate I or blank If not applicable (Note: Any INADEQUATE must have an explanation and be corrected) A. FUEL/WATER TANKS 01. No leaks 02. Pumps guarded 03. Signs at water/fuel tanks: a) No smoking sign posted b) Fuel sign posted c) Dangerous Goods placard posted B. BOILER HOUSE 04. No clothing etc. 05. Sight glass guarded 06. Pump guarded 07. Fire extinguisher 08. Safety valves: one year certificate 09. Boiler 25 m from wellheads 10. Housekeeping 11. Flammables removed from around boiler 12. Boiler License posted 13. Blow down line location & installation of steam deflector 14. Fuel/water and steamline leaks 15. Chemical addition vessel (pot) at boiler properly labeled (WHMIS) C. GENERATOR BUILDING 16. Generator/motor control centre - size; condition 17. Receptacles/circuit breakers identified 18. Properly grounded (2 grd rods 3 m apart) 19. Wiring off the ground & properly secured 20. No clothing/storage 21. Fans and belts guarded 22. No fuel/oil leaks 23. Compressor belts guarded 24. Fire extinguisher 25. All lights protected 26. Housekeeping 27. Rubber mat on floor at Motor Control Centre 28. Battery condition 29. Signs at Generator Building a) Auto Start sings posted b) Hearing Protection sign posted c) Electrical/High Voltage signs posted d) Water Hose Caution sign posted e) Lockout and Procedures 30. Wiring/electrical fixtures condition 31. Current turned off prior to connecting/disconnecting extension cords D. ACCUMULATOR AND TOOL HOUSE 32. No leaks/spillage 33. N2 bottles (12500 kpa/1800 psi) 34. Housekeeping 35. Storage of compressed gas cylinders, secured 36. Controls identified/accessible 37. Safety device blind/sheer ram controls 38. Fire extinguisher 39. Grinder tool rest 40. Eye protection available 41. Compressor guarded 42. Signs at Accumulator and Tool House a) Eye Protection signs posted b) Auto Start signs: compressor / accum pump c) Dangerous Goods placard/whims label 43. Accumulator reservoir vented outside of building/enclosure (A) / (I) 50. Piping, valves and unions meet pressure rating 51. Pulsation dampeners 52. Eyewash facility 53. Pop/bleed off lines secured and drained 54. Signs at Mud Pump area: a) Lockout Procedures posted b) Auto Start sign posted c) Hearing Protection sign posted d) No Smoking sign posted 55. Wiring/electrical fixtures condition F. MUD TANK AREA 56. Mud degasser(s) (size and placement) 57. Shale shaker belts guarded 58. Handrails, walkways 59. Adequate ventilation 60. Adequate lighting 61. Personal protective equipment eye protection, dust masks, rubber gloves/apron 62. Housekeeping 63. Tank level indicators operative 64. Trip tank level indicator Tank location 65. Mud van, stairs, lighting 66. Safety line rail sump side of tanks 67. Eyewash facility 68. Sings at Mud Tank area: a) Eye Protection at hoppers b) No Smoking signs posted c) Corrosive sign at caustic drum d) Applicable WHIMS labeling 69. Wiring/electrical fixtures conditions C. SUBSTRUCTURE 70. General condition 71. Matting condition 72. Drive pins installed c/w safety pins 73. Spreaders in place 74. Vent doors/fan 75. Illumination 76. Winterization condition 77. Hydraulic control lines condition fire guarded hose 78. Flow nipple split 79. Stripper/mud catcher split 80. Scaffolding/ladder(s) condition 81. Cellar area cribbed and drained 82. Wiring/electrical fixture condition 83. Housekeeping (oil leaks, etc.) H. BOP S 84. BOP and rig equipment conform to Government regulations 85. BOP secured properly 86. Non-steel hydraulic lines fire sheathed 87. Mud gas separator adequately connected meets minimum requirements, including line size and tie down 88. Required casing wear tests being preformed 89. BOP pressure tests recorded and test procedures satisfactory 90. Adequate heating 91. Manual ram locking wheels available (A) / (I) E. MUD PUMP AREA I. DOGHOUSE 44. Pop valve shear pin correct size and length 45. Pop valve cover in place 46. Guards in place and in good repair 47. Hoses safely chained 48. Fire extinguisher (No. ) 49. Housekeeping 92. Heated as per regulations 93. Adequate exits 94. Intercom meets regulations 95. Storage area, crew change area 96. Housekeeping 97. Fire extinguisher 98. Eye and hearing protection available 99. Eyewash available Page 1 of 3

100. First Aid kit stocked and cleaned 101. Safety belts 102. Condition of available hand tools 103. BOP controls, electrical, manual, air 104. Bulletin board 105. Drilling License posted 106. Emergency phone numbers posted 107. Signs at Doghouse: a) Hard Hat sign posted b) Hearing Protection sign posted c) No Smoking sign posted d) Maximum holdback casing pressure posted e) Blowout procedure posted and readable f) MSDS available 108. Wiring/electrical fixture condition J. BREATHING APPARATUS INSPECTION 109. Number of packs available 110. Location of air packs 111. General condition of apparatus and case 112. Condition of face piece 113. Condition of nose cup 114. Cylinder pressure 115. Low pressure alarm operational 116. Cleanliness and storage 117. Positive pressure capability 118. Number/condition of spare cylinders 119. Location of spare cylinder (chained) 120. Cascade system or safety trailer 121. SCBA cylinders hydrostatic test dates current 122. Other K. RIG FLOOR 123. Lockout on drawworks 124. Compound/drawworks guard 125. Crown saver (check) 126. Catline 127. Catline divider and spool 128. Spinning chain/wrench line 129. Headache post 130. Kelly cock condition 131. Kelly hose condition 132. Kelly hose safety line both ends 133. Line spooler/safety line 134. Backup post condition 135. Tongs condition 136. Tong line and tong line clamps 137. Slips condition 138. Dog collar condition 139. Stabbing valve and handle and X/O subs 140. Test plugs 141. Mud can condition 142. Drilling controls and identification 143. Brake handle hold-down cable/chain 144. Non-skid material around rotary 145. Lighting operational, floor and motor area 146. Motors: a) Fans and belts guarded b) No fuel/oil leaks c) Motor shutoff d) Fire extinguisher (No. ) e) Exhaust system 147. Stairs (min. 3 exits) from rig floor 148. Warning horn working 149. Hydromatic and guards 150. Brakes satisfactory 151. Tugger line condition, guards 152. V-door opening safety chained 153. Wiring/electrical fixture condition (A) / (I) L. DERRICK (Certification Date: ) 154. Block hanging line 155. Bumper blocks secured 156. Fingers straight 157. Fingers chained 158. Wind board installed 159. Ladder condition 160. Escape line installed. No blockage of line (i.e. tank or vehicle) 161. Escape buggy installed and accessible 162. Climbing device/cages 163. Derrickhand s belt and condition 164. Guy lines/outrigger 165. Condition of crown sheaves 166. No loose tools equipment cabled on derrick 167. All safety pins in place, secured 168. Lighting operational and safety cables/chains attached 169. Inspection prior to raising/lowering 170. Condition of tong counterweight assembly 171. Wiring/electrical fixture condition M. TRAVELING ASSEMBLY 172. Blocks 173. Bails/links 174. Elevators/latches 175. Weight indicator assembly 176. Weight indicator safety line 177. Automatic driller 178. Drilling line condition (slip/cut program) 179. Deadline anchor condition N. PIPE RACK AREA 180. Racks butt firmly to each other and catwalk 181. Catwalk in good condition 182. Stairs in good condition 183. Pipe rack level 184. Pipe rack ends properly pinned 185. Spacer between racks sturdy and secure 186. Derrick stand in good condition 187. Housekeeping 188. V-door ramp in good condition 189. Catwalk, tugger, guarded 190. Lay down line and block condition 191. Layers of drill pipe or casing properly choked 192. Adequate lighting O. MANIFOLD HOUSE 193. Heated 194. Valve handles installed 195. Proper gauges installed and positioned 196. Drill pipe pressure gauge installed 197. Unobstructed view to rig floor 198. Housekeeping 199. Manifold design meets Government requirements 200. Flare lines properly secured 201. Lighting operational 202. Choke/valve open to degasser 203. Well to: - End of flare line 50 m - Rubbish burn pile 50 m - Crude oil storage tank 50 m 204. Signs at Manifold House: a) Hold Back Pressure notice posted b) No Smoking sign posted 205. Choke and degasser lines and manifold prepared P. LEASE AREA 206. Lease clean and dry 207. Flare pit properly dug 50 m from wellbore 208. Adequate ditching and drainage 209. Incinerator/garbage bin 210. Open pits (e.g. sump) guarded/fenced 211. Sump fluids properly contained 212. Lease properly diked 213. Overhead lines flagged 214. Signs at Lease area: a) H2S Warning signs, if applicable b) Poisonous Gas signs posted c) Tight Hole Status sigh posted Q. CAMP/GENERAL FACILITIES 215. Propane tanks location (No. ) Propane distance from camp (min. 4 m) 216. Garbage disposal: incinerator - bins 217. Walkways 218. Kitchen First Aid kit 219. Kitchen fire extinguisher 220. Fire extinguisher (No. ) (A) / (I) Page 2 of 3

221. Generator Building: a) Grounded b) No clothing, storage c) No fuel/oil leaks d) Fire extinguisher 222. Furnace rooms 223. No unnecessary storage 224. Fire alarm system 225. Bedrooms exit to outside (shutters open) 226. Adequate distance from well centre 227. Housekeeping 228. Signs at Camp area: a) Hearing Protection sign posted 229. Exit signs over doors installed and illuminated 230. Emergency lighting installed and functional 231. Wiring/electrical fixtures condition (A) / (I) T. SAFETY/GENERAL 265. Condition of electrical tools 266. Personal safety equipment being used 267. Visitor hard hats 268. Toxic gas equipment (detector and tubes) 269. Oxygen resuscitator available 270. Adequate emergency vehicle available 271. Accident reporting and recoding 272. Directional rig signs 273. Stretcher, location (No. ) 274. Condition of handrails and stairs toe boards 275. Fire retardant clothing available 276. Fire extinguishers checked weekly and hydrostatic test dates are current 277. Suitcasing/walkways (A) / (I) R. RIG SITE TRAILERS 232. Adequate distance from well centre 233. Propane system 234. Door or knock out window (bedroom) 235. Emergency phone numbers posted 236. Intercom 237. Smoke detectors 238. Gas detection equipment 239. Breathing apparatus 240. Fire extinguisher 241. First Aid Kit U. ENVIRONMENT POLICY AND PROCEDURES 278. Company manual(s) On-site and Current 279. CAODC Waste Wall Chart Posted 280. Contractual Responsibilities Reviewed V. GENERAL LEASE CONDITIONS 281. Lease site clean and free of debris 282. Special Conditions 283. Berm integrity S. TICKETS/DOCUMENTS ( where not applicable) 242. BOP checks daily with record 243. BOP drill with records and signs by Rig Manager and Foreman 244. Motor kills weekly with records 245. Trip sheets completed 246. Weekly safety meeting with records 247. Well control ticket: Rig Manager and Foreman 248. BOP ticket Drillers 249. First Aid certificate (one per crew) 250. H2S training (all crew members) 251. Drilling prognosis 252. Emergency Response Plan 253. Well Site Emergency Contingency Manual 254. Company policy statement posted 255. Government Regulations available 256. OH&S Regulations available 257. Drilling Rig Health and Safety Committee Guidelines 258. WHMIS training all crew members 259. MSDS available current 260. Daily rig check by Foreman and Rig Manager 261. Slip and cut program recorded 262. Equipment certification/maintenance records available and current 263. Clothing policy posted 264. New employee orientation training W. SPILL RESPONSE 284. Employees trained 285. Sorbents available 286. Spill response report form available 287. Emergency response procedure X. WASTE MANAGEMENT 288. Waste separated into hazardous/non-hazardous 289. Secondary containment for hazardous waste 290. Waste bin in good condition 291. Recyclable waste properly segregated and stored 292. Non-Hazardous recyclable waste properly segregated and stored 293. Light plant waste properly stored Y. WASTE DOCUMENTATION 294. Waste manifests complete and maintained on file 295. Used oil recycled and documented 296. Used oil filters recycled/drained and documented 297. Oily rags recycled and documented 298. Batteries recycled and documented 299. Glycol recycled/properly disclosure and documented 300. Land filled wastes and sites indicated and properly documented Z. COMMENTS/EXPLANATIONS DRILLING FOREMAN SIGNATURE RIG MANAGER SIGNATURE Page 3 of 3

Location: Chair Person: Meeting Agenda: Monthly Health, Safety & Environment Meeting Report Start Time: Adjournment Time: Date: Presentation (video / speaker / other): Old Business: (record outstanding issues until resolution) Action # Mo/Yr Action By Closure Date Additional Agenda Items: Action # Mo/Yr Action By Closure Date New Business: Action # Mo/Yr Action By Closure Date Handouts Circulated: Page 1 of 2

Health, Safety & Environment Meeting Report Page 2 Incident Reviews: Action # Mo/Yr Action By Closure Date Safety Grams / Regulatory Bulletins: Action # Mo/Yr Action By Closure Date Hazard Alerts: Action # Mo/Yr Action By Closure Date Next Meeting Location: Date: Start Time: Chair Person: Attendee Sign In: Topic: Page 2 of 2

HAZARD IDENTIFICATION & CONTROL The purpose of this form is to ensure a written, documented process, which both identifies hazards and establishes controls for all workplace tasks. Emphasis should be placed on the elimination of existing hazards. Corporation: Location: Task: Work Permit # (if applicable): Date: REFERENCE LIST OF POSSIBLE HAZARDS: List all hazards associated with the task in the spaces provided below. Please consider all hazards and not just the references listed. Flammable Gas Driving Hazards/ATV use Ground Disturbance (Excavation/Trenching) Flammable Liquids Fatigue Confined Space / Restricted Space Pressure H 2 S Iron Sulphides NORM/Asbestos Chemicals Working around moving vehicles Road/Lease Conditions Inadequate Equipment Guards Slips/Trips Working at heights Poor Illumination Protruding Objects/Pinch Points Excessive Noise/Vibration Extreme Weather Exposure Overhead Hazards (powerlines) Noxious Vapours (Benzene) Working Alone Suspended Overhead Equip. Rotating Equipment Wildlife Encounters Defective Tools/Equipment Hot/Cold Piping Equipment Violence/Harassment Hoisting Equipment REFERENCE LIST OF POSSIBLE CONTROLS List a control (s) for each identified hazard in the space provided below. Please consider all controls, not just the reference list given. Corporation Policies High LEL & H 2 S Shutdowns Safe Work Practices House Keeping Confined Space Permits/Plans LEL Monitoring/Function Testing Safety Standby/Safety Watch Equipment De-energized Muster Area Air Monitoring Isolation (Blinding/Blocking) Forced Ventilation Safe Work Permits Fire Extinguishers Secondary Containment/Spill Control Training/Certifications SCBA/SABA Safety Inspections (CAODC, walkabouts etc.) First Aid Plan Restricted Areas Explosion Proof Equipment Personal H 2 S Monitor Hearing Protection Guards/Shields Warning Signs PPE (Fire Retardant Coveralls) Safety Harness/Lifeline/Fall Protection Plan Unsure? Call a Supervisor! Respirator Wash Facilities Incident Reporting/Investigation Tailgate Meetings Audits/HSE Contract Inspections IDENTIFIED HAZARDS & CONTROLS HAZARDS CONTROLS This Hazard Identification & Control Form completed by: Signature Printed Name

WORK Permit Hot Cold Clearance Confined Space/ Restricted Space Order Requested by: PERMIT No: Supervision Continuous Intermittent Location: Contractor: Description of Work to be Done / Comments: Issued by: Issued by: Phone No: Phone No: COMMUNICATION PROCEDURES Req'd Complete N/A Req'd Complete N/A 1 Job discussed with Worker/Contractor/Maintenance 24 Stand -by Man/Continuous Gas Monitoring 2 Work Procedures Reviewed 25 Electrical Equipment/Valve Handles Locked & Tagged 3 Safety Regulations Received/Reviewed 26 Grounding/Bonding Required 4 M.S.D.S. Reviewed 27 Equipment Cooled/Ventilated/Isolated 5 Safety Meetings 28 Blinds Installed/Bleeds Open 6 Area Roped Off & Warning Signs Up 29 Vessels/Lines Purged 7 Radio on Hand 30 Shoring/Cut Back Required 8 Review Code of Practice (Site Specific) 9 Specific Training Identified PERSONAL PROTECTIVE & SAFETY EQUIPMENT 31 Air Hood/Dust Respirators HAZARDS 32 Breathing Air - SABA / SCBA 10 Combustible Material Removed 33 Face Shield/Goggles/Safety Glasses 11 Drains Covered/Sumps Covered and Sealed 34 Hearing Protection 12 No Vessels/Pumps to be Vented/Depressured 35 Protective Clothing 13 Overheard Lines, Clearance Established 36 Safety Harness and Life Line 14 Underground Line, Located & Identified 37 Safety Belt and Lanyard 15 Other Hazardous Material 38 Explosion Proof & Low Voltage Electrical Equipment 16 High Voltage 39 Air Movers/Ventilators 17 Intrinsically Safe Equipment 40 Scaffolding 41 Wash Facilities EMERGENCY PLANNING 18 Safe Egress from Work Areas Identified 19 Fire Extinguisher Ready to Use Note: Completed checkbox, should be completed by permit receiver after 20 Steam/Water hose Ready to Use all requirements have been met. 21 Emergency Air horn 22 ERP Manual Discussed 23 Atmosphere Testing (Explosive, Toxic & Oxygen Deficiency ) Record Below AREA FREE OF (appropriate box) N/A N/A Combustible Gas (vapour) % LEL % LEL % LEL % LEL Hydrogen Sulphide ppmh 2 S ppmh 2 S ppmh 2 S ppmh 2 S Toxic Gas ppmh 2 S ppmh 2 S ppmh 2 S ppmh 2 S N O T E Oxygen Content % O 2 % O 2 % O 2 % O 2 Tester's Signature This permit is valid only as long as work conditions existing at the time of its issuance continue and expires upon occurrence of any hazard such as gas leak, liquid spill, drastic operating change in equipment, or change in wind direction blowing vapours into the work area. Any worker will have the right to stop the job if he has reasonable grounds to believe that the job is, or likely to become unsafe. Work shall not resume until a new permit is issued. Validity (Permit - only valid for single shift) FIRST TEST Hours SPECIAL PRECAUTIONS, INSTRUCTIONS & EQUIPMENT REQUIRED RETESTS Hours Issued Date: Time: Expiry Date: Time: N/A RETESTS Hours N/A RETESTS Hours We have read & understand the required precautions/instructions. Approval by: Supervisor Accepted By: Contractor Representative/Worker work indicated above has either been: completed or cannot be continued until the issuance of a new work permit. Signed: Supervisor Contractor Representative/Worker

INCIDENT INVESTIGATION REPORT Please ensure you have provided all information for the incident you are reporting Note: See Instructions in Section 6.0 for completing form. ENVIRONMENT NEAR MISS INJURY VEHICLE RELEASE INTERIM REPORT SAFETY PROPERTY DAMAGE NON CONFORMANCE / COMPLIANCE FINAL REPORT DISTRICT: FIELD: Date of Occurrence: Date Reported: YYYY / MM / DD TIME YYYY / MM / DD TIME LOCATION N ERCB / MEM Name: Time: O LSD SEC TWP T MEI / SEM / NEB Name: Time: I W MER F WCB / OH&S Name: Time: EXACT LOCATION OF INCIDENT: I C AEP / MELP Name: Time: A T POLICE Name: Time: I LANDOWNER Name: Time: O N PROVIDE AN EXACT DETAILED DESCRIPTION OF THE INCIDENT, NON CONFORMANCE AND / OR PROPERTY AFFECTED: (attach diagram if appropriate) EQUIPMENT / VEHICLE INFORMATION - (including QMP) VEHICLE FORM ATTACHED UNIT NO. SEVERITY POTENTIAL Minor Serious Major PROBABILITY OF OCCURRENCE Seldom Occasional Frequent INJURY INFORMATION COPY OF APPLICABLE WCB FORM ATTACHED First Aid Medical Aid Lost Time Fatality Other Specify Injured party: Employee Public Contractor (Company Name) : Name: Employee # Phone # Address: City: Occupation: Postal Code: Experience: Yrs Injured Part of Body Immediate Supervisor: Modified Work Any product spill - Off Lease, Into a Water Course, or Over 2m³ on Lease is to be reported. On Lease spills under 2m³ do not need to be reported. ENVIRONMENTAL Liquid Other Terrain Affected Land Water Both Contained on Lease? Yes No Rehabilitation Required? Yes No Waste Manifest Yes No Public Complaint? Yes No Gas: Water Base Material (m 3 ) PW FW Liquid Hydrocarbon (m 3 ): Other: Discharged: Discharged: Discharged: Discharged: Sweet/Sour Recovered: Recovered: Recovered: H 2 S %: Smoke: Yes No Odour: Yes No Noise: Yes No Wind Direction: CONTROL MEASURES INCLUDING A DESCRIPTION OF CLEAN UP AND REHABILITATION: (Recovered product recycled? - Contaminated Soil? - Treated? Hauled Away? - Where?) Quantab Values: Amendments Applied: Date: Government File: Date Rehab Completed: Calcium Nitrate: kg Ammonium Nitrate: kg Seed Mixture Applied: Other: Straw etc. VESSEL / PIPELINE INFORMATION - (if applicable) License No. Line No: Line OD (mm): Grade: MOP (kpa): Type of Wrap: Internal Coat: Yes No Wall Thickness (mm): Normal OP. Press (kpa): Depth of Cover (m): Type: Vessel I.D. #: NON CONFORMANCE RELATED TO: Repairs or Alterations Material or Specification changes Page 1 of 2

INCIDENT INVESTIGATION REPORT Please ensure you have provided all information for the incident you are reporting Summarize all costs relating to incident Indicate Final Costs Estimated Costs Covering Costs Company Third Party Estimated Repair / Replacement Costs $ Final Repair / Replacement Costs $ Estimated Clean-Up Costs $ Final Clean-Up Costs $ What was the cause of the accident? (Determine the cause by analyzing all factors concerned. A person, a machine, or a physical condition? How? Why? A. Describe any UNSAFE CONDITIONS: CONGESTED WORK AREA OR RESTRICTED ACTION DEFECTIVE TOOLS, EQUIPMENT OR MATERIALS HAZARDOUS ATMOSPHERE: UNSAFE FLOOR, RAMPS, STAIRWAYS OR ROADWAY HAZARDOUS SUBSTANCE (GASES, DUST SMOKE, VAPOUR) INADEQUATE GUARDS OR PROTECTION INADEQUATE OR IMPROPER PROTECTIVE EQUIPMENT IMPROPER MATERIAL STORAGE INADEQUATE WARNING SYSTEM HIGH OR LOW TEMPERATURE INADEQUATE VENTILATION EXCESSIVE NOISE INADEQUATE / EXCESSIVE ILLUMINATION POOR HOUSEKEEPING RADIATION EXPOSURE INTERNAL CORROSION / EROSION UNSTABLE GROUND CONDITIONS EQUIPMENT FAILURE (WEAR & TEAR) B. Describe any UNSAFE ACTS: VIOLENCE / HARASSMENT FAILURE TO SECURE / LOCK-OUT FAILURE TO USE PROPER TOOLS OR EQUIPMENT FAILURE TO USE PERSONAL PROTECTIVE EQUIPMENT FAILURE TO USE GUARDS PROVIDED IMPROPER LIFTING, LOWERING OR CARRYING MAKING SAFETY DEVICES INOPERABLE IMPROPER LOADING OR PLACEMENT UNSAFE POSITION FOR TASK SERVICING EQUIPMENT IN OPERATION OPERATING AT UNSAFE SPEED OPERATING WITHOUT AUTHORITY INFLUENCE OF ALCOHOL AND/OR DRUGS USING DEFECTIVE EQUIPMENT USING EQUIPMENT IMPROPERLY LACK OF SKILL OR KNOWLEDGE UNNECESSARY HASTE HORSEPLAY UNSAFE ACT OF OTHER (3RD PARTY) UNAWARE OF HAZARD PHYSICAL LIMITATION / MENTAL ATTITUDE FATIGUE CORRECTIVE ACTION TAKEN TO ADDRESS THE ROOT CAUSES OF THE INCIDENT: Explain what you have done or what you recommended to prevent a recurrence of a similar incident / accident IMPROVED LAYOUT OR DESIGN IMPROVED / INCREASED SUPERVISION ADDITIONAL / PROPER JOB PROCEDURES IMPROVED CONSTRUCTION STANDARDS IMPROVED HIRING STANDARDS INCREASED ON THE JOB INSTRUCTION IMPROVED EQUIPMENT STANDARDS IMPROVED JOB PLACEMENT STANDARDS INCREASED ENFORCEMENT OF WORK STANDARDS IMPROVED PREVENTATIVE MAINTENANCE IMPROVED JOB PLANNING METHODS INCREASED ENVIRONMENTAL CONTROLS INCREASED INSPECTION / MAINTENANCE FREQUENCY ADDITIONAL TRAINING OR AWARENESS ADDITIONAL CONTRACTOR CONTROLS CORRECTIVE ACTION PLAN FOR QMP CONFORMANCE: SIGNATURE: INSPECTOR DATE FOLLOW-UP ASSIGNMENTS: WHAT? WHO? WHEN? SUBMITTED BY: (please PRINT) REVIEWED AND APPROVED BY: INCIDENT REPORTED BY SUPERVISOR / FOREMAN SIGNATURE DATE SUPERINTENDENT / MANAGER FORWARD REPORT TO: Page 2 of 2 This report is required as part of Harvard obligations under the Occupational Health & Safety Act of Alberta and is subject to the protections of sections 18 and 19 of that act. Further, any statements given herein are made subject to the protections provided by section 6 of the Alberta Evidence Act and section 5 of the Canada Evidence Act to the extent that they may apply.

HS & E HANDBOOK REVIEW QUESTIONNAIRE Name (please print): Date: Company: HARVARD is committed to protecting the health and safety of all workers on our sites. Part of this commitment is the expectation that all workers be familiar with and follow standard guidelines and procedures. The initial step to accomplish this is an orientation to our Health, Safety & Environment Handbook. This review checklist is intended to ensure that workers have the basic knowledge associated with the HS&E handbook. Complete the following questions by either circling the correct answer or filling in the blank(s) if answers are not provided. It is acceptable to use the handbook to find the answers. Return the review checklist to your supervisor or HARVARD Representative. POLICY ON HEALTH, SAFETY & THE ENVIRONMENT 1) Who is responsible for protecting the health and safety of people and preserving the quality of the environment: a) employees b) management c) contractors d) everyone RESPONSIBILITIES FOR EMPLOYEES AND CONTRACTORS 2) If asked to perform a task that you believe would put yourself or other workers at risk of injury you should: a) carry on as usual b) refuse to perform the task c) be extra careful as you carry out the assigned task d) ask someone else to do the job for you 3) What must you do if you refuse to perform a task because there is imminent danger: a) leave the site immediately b) go have coffee c) notify the supervisor of your reasons d) reconsider and carry on with the task OPX Consulting Inc. Page 1 of 6

4) Local emergency phone numbers must a) not be worried about b) be confirmed and posted c) be memorized d) all of the above EMERGENCIES 5) It is recommended that at least one vehicle have a a) communication device b) siren c) flashing light d) high ground clearance to be able to get off the lease 6) Which of the following shows the correct emergency response actions? a) sound the alarm, protect equipment at all costs and then call for medical aid b) get out, sound alarm, assess situation, assist others, call for medical aid, secure the area, and protect equipment only if it is safe to do so. c) get out of the area and wait for someone to show up so you can tell them what happened d) try to fix what went wrong so no one will find out about it. 7) You must present yourself for work: INDIVIDUAL RESPONSIBILITIES & DUTIES a) physically fit b) mentally fit c) head and facial hair at a length that does not present a hazard d) all of the above 8) Smoking is permitted: a) in designated areas only b) where ever you want c) outside of buildings only d) beside vehicles only 9) You are not permitted to do which of the following at an HARVARD work site: a) to be under the influence of or in possession of drugs or alcohol b) to engage in practical jokes c) harass other workers because of their race, sex, age or religion. d) all of the above OPX Consulting Inc. Page 2 of 6

10) It is the Contractor s responsibility to: CONTRACTOR REQUIREMENTS a) provide all tools, safety equipment, proper clothing for their workers b) enforce all policies and procedures outlined in the HSE handbook c) take steps necessary to ensure the safety of your employees and sub-contractors d) all of the above 11) It is the Prime Contractor s responsibility to: a) ensure that appropriate first aid supplies and services are on site b) determine if an ambulance is required and where it is to be positioned c) ensure that workers are aware of the location of all first aid supplies d) all of the above PERSONAL PROTECTIVE EQUIPMENT 12) Two items of PPE that must be worn at all times on HARVARD locations are: a) face shields and leggings b) hard hats and safety footwear c) safety glasses and hearing protection d) all of the above 13) At work sites where there is a possibility for hydrocarbon release, clothing requirements include: a) fire retardant clothing as the outside layer b) natural fiber clothing such as wool or cotton as inner wear c) nylon outerwear d) both a & b HAZARDS 14) When lighting fired heaters and furnaces, face shields and gloves must be worn: a) true b) false 15) On any work site, before beginning any job or task: a) identify and document the hazards b) identify and implement control measures for all the hazards c) both a) and b) d) ignore the low risk hazards OPX Consulting Inc. Page 3 of 6

16) Prior to any work being done in an area containing a flammable substance, testing may be necessary: a) true b) false 17) When entering a sour location, employees are to ensure that: a) H 2 S monitoring equipment is turned on and used at all times while on location b) communication equipment is in good working order c) a breathing apparatus in working order and with an adequate supply of air must be available d) all of the Above 18) The term Hot Work refers to: a) any work that is done indoors or outdoors on a hot day b) any work where a flame is used or sparks and other sources of ignition could be produced c) work that requires you to take off your jacket and fire retardant clothes because increased temperatures 19) What is the maximum acceptable noise level on a worksite over an eight hour work period? a) 80 dba b) 90 dba c) 75 dba d) 85 dba 20) A written fall protection plan must be in place before work commences on a task where there is a potential of a fall of more than: a) ½ metre b) 10 metres c) 20 metres d) 3 metres MEETINGS AND COMMUNICATION 21) A pre-job Safety Meeting is the expected manner of ensuring permit requirements are known and workers are aware of all activities, hazards and applicable work practices. a) true b) false 22) Employers should hold regular safety meetings at least once a month for the following purposes: a) to report current accidents or diseases, their causes and prevention b) to see whose been slacking off on the work sites c) to determine if there are any matters pertinent to health and safety d) both a & c OPX Consulting Inc. Page 4 of 6

SAFE WORK PERMITS & CLEARANCES 23) Before beginning any work at a HARVARD location, you must determine if a work permit or work clearance is required. a) true b) false 24) A Blanket Work Permit refers to: a) a permit that is used for ongoing tasks where specific guidelines have been established b) a permit that is issued for a maximum of one year c) a permit that requires specialized blankets to keep the workers protected from the cold d) both a & b INSPECTIONS AND AUDITS 25) Unsafe working conditions found during inspections should be: a) fixed immediately or reported to a supervisor b) brought up at the next safety meeting c) ignored because everybody already knows it s a hazard ENVIRONMENT 26) Only supervisors are responsible for meeting regulations and industry guidelines: a) true b) false 27) We must all take necessary steps to prevent spills and control emissions: a) true b) false 28) A facility is considered sour at: a) 1 PPM H 2 S or greater b) 10 PPM H 2 S or greater c) 100 PPM H 2 S or greater d) 1000 PPM H 2 S or greater SOUR SERVICE 29) It is your responsibility to report all: a) wildlife sightings b) unsafe acts and/or conditions c) incidents and infractions d) b and c INVESTIGATING REPORTING INCIDENTS OPX Consulting Inc. Page 5 of 6

30) How soon must injuries be reported to a HARVARD representative? a) before anything else b) as soon as possible but within 24 hours c) within a week d) at the end of the job 31) Good housekeeping is: a) only a minor issue b) good to do when you have the time c) mandatory 32) Before handling chemicals you should: GOOD HOUSEKEEPING WHMIS/TDG a) review the MSDS sheet b) carefully breathe in the vapours to see if they are harmful c) make sure no one else is in the area d) move the chemicals outside DRIVING CONDUCT 33) In general all ATV (All Terrain Vehicle) riders must a) be competent in their ability to operate an ATV b) drive the ATV in accordance with local regulations c) possess a valid driver s license for insurance purposes d) all of the above 34) Driving incident are the leading cause of injury, fatalities and property damage in the oil and gas industry. a) true b) false OPX Consulting Inc. Page 6 of 6

ANSWER KEY HS & E HANDBOOK REVIEW QUESTIONNAIRE Name (please print): ANSWER KEY Date: Company: HARVARD is committed to protecting the health and safety of all workers on our sites. Part of this commitment is the expectation that all workers be familiar with and follow standard guidelines and procedures. The initial step to accomplish this is an orientation to our Health, Safety & Environment Handbook. This review checklist is intended to ensure that workers have the basic knowledge associated with the HS&E handbook. Complete the following questions by either circling the correct answer or filling in the blank(s) if answers are not provided. It is acceptable to use the handbook to find the answers. Return the review checklist to your supervisor or HARVARD Representative. POLICY ON HEALTH, SAFETY & THE ENVIRONMENT 1) Who is responsible for protecting the health and safety of people and preserving the quality of the environment: a) employees b) management c) contractors d) everyone RESPONSIBILITIES FOR EMPLOYEES AND CONTRACTORS 2) If asked to perform a task that you believe would put yourself or other workers at risk of injury you should: a) carry on as usual b) refuse to perform the task c) be extra careful as you carry out the assigned task d) ask someone else to do the job for you 3) What must you do if you refuse to perform a task because there is imminent danger: a) leave the site immediately b) go have coffee c) notify the supervisor of your reasons d) reconsider and carry on with the task OPX Consulting Inc. Page 1 of 6

4) Local emergency phone numbers must a) not be worried about b) be confirmed and posted c) be memorized d) all of the above EMERGENCIES 5) It is recommended that at least one vehicle have a a) communication device b) siren c) flashing light d) high ground clearance to be able to get off the lease 6) Which of the following shows the correct emergency response actions? a) sound the alarm, protect equipment at all costs and then call for medical aid b) get out, sound alarm, assess situation, assist others, call for medical aid, secure the area, and protect equipment only if it is safe to do so. c) get out of the area and wait for someone to show up so you can tell them what happened d) try to fix what went wrong so no one will find out about it 7) You must present yourself for work: INDIVIDUAL RESPONSIBILITIES & DUTIES a) physically fit b) mentally fit c) head and facial hair at a length that does not present a hazard d) all of the above 8) Smoking is permitted: a) in designated areas only b) where ever you want c) outside of buildings only d) beside vehicles only 9) You are not permitted to do which of the following at a HARVARD work site: a) to be under the influence of or in possession of drugs or alcohol b) to engage in practical jokes c) to harass other workers because of their race, sex, age or religion. d) all of the above OPX Consulting Inc. Page 2 of 6

10) It is the Contractor s responsibility to: CONTRACTOR REQUIREMENTS a) provide all tools, safety equipment, proper clothing for their workers b) enforce all policies and procedures outlined in the HSE handbook c) take steps necessary to ensure the safety of your employees and sub-contractors d) all of the above 11) It is the Prime Contractor s responsibility to: a) ensure that appropriate first aid supplies and services are on site b) determine if an ambulance is required and where it is to be positioned c) ensure that workers are aware of the location of all first aid supplies d) all of the above PERSONAL PROTECTIVE EQUIPMENT 12) Two items of PPE that must be worn at all times on HARVARD locations are: a) face shields and leggings b) hard hats and safety footwear c) safety glasses and hearing protection d) all of the above 13) At work sites where there is a possibility for hydrocarbon release, clothing requirements include: a) fire retardant clothing as the outside layer b) natural fiber clothing such as wool or cotton as inner wear c) nylon outerwear d) both a & b HAZARDS 14) When lighting fired heaters and furnaces, face shields and gloves are to worn: a) true b) false 15) On any work site, before beginning any job or task: a) identify and document the hazards b) identify and implement control measures for all the hazards c) both a) and b) d) ignore the low risk hazards OPX Consulting Inc. Page 3 of 6

16) Prior to any work being done in an area containing a flammable substance testing may be necessary: a) true b) false 17) When entering a sour location employees are to ensure that: a) H 2 S monitoring equipment is turned on and used at all times while on location b) communication equipment is in good working order c) a breathing apparatus in working order and with an adequate supply of air must be available d) all of the Above 18) The term Hot Work refers to: a) any work that is done indoors or outdoors on a hot day b) any work where a flame is used or sparks and other sources of ignition could be produced c) work that requires you to take off your jacket and fire retardant clothes because increased temperatures 19) What is the maximum acceptable noise level on a worksite over an eight hour work period? a) 80 dba b) 90 dba c) 75 dba d) 85 dba 20) A written fall protection plan must be in place before work commences on a task where there is a potential of a fall of more than: a) ½ metre b) 10 metres c) 20 metres d) 3 metres MEETINGS AND COMMUNICATION 21) A pre-job Safety Meeting is the expected manner of ensuring permit requirements are known and workers are aware of all activities, hazards and applicable work practices. a) true b) false 22) Employers should hold regular safety meetings at least once a month for the following purposes: a) to report current accidents or diseases, their causes and prevention b) to see whose been slacking off on the work sites c) to determine if there are any matters pertinent to health and safety d) both a & c OPX Consulting Inc. Page 4 of 6

SAFE WORK PERMITS & CLEARANCES 23) Before beginning any work at a HARVARD location you must determine if a work permit or work clearance is required. a) true b) false 24) A Blanket Work Permit refers to: a) a permit that is used for ongoing tasks where specific guidelines have been established b) a permit that is issued for a maximum of one year c) a permit that requires specialized blankets to keep the workers protected from the cold d) both a & b INSPECTIONS AND AUDITS 25) Unsafe working conditions found during inspections should be: a) fixed immediately or reported to a supervisor b) brought up at the next safety meeting c) ignored because everybody already knows it s a hazard ENVIRONMENT 26) Only Supervisors are responsible for meeting regulations and industry guidelines: a) true b) false 27) We must all take necessary steps to prevent spills and control emissions: a) true b) false 28) A facility is considered sour at: SOUR SERVICE a) 1 PPM H 2 S or greater b) 10 PPM H 2 S or greater c) 100 PPM H 2 S or greater d) 1000 PPM H 2 S or greater 29) It is your responsibility to report all: a) wildlife sightings b) unsafe acts and/or conditions c) incidents and infractions d) b and c INVESTIGATING REPORTING INCIDENTS OPX Consulting Inc. Page 5 of 6

30) How soon must injuries be reported to a HARVARD representative? a) before anything else b) as soon as possible but within 24 hours c) within a week d) at the end of the job 31) Good housekeeping is: a) only a minor issue b) good to do when you have the time c) mandatory 32) Before handling chemicals you should: GOOD HOUSEKEEPING WHMIS/TDG a) review the MSDS sheet b) carefully breathe in the vapours to see if they are harmful c) make sure no one else is in the area d) move the chemicals outside DRIVING CONDUCT 33) In general all ATV (All Terrain Vehicle) riders must a) be competent in their ability to operate an ATV b) drive the ATV in accordance with local regulations c) possess a valid driver s license for insurance purposes d) all of the above SAFETY PROGRAM MANUAL 34) Driving incidents are the leading cause of injury, fatalities and property damage in the oil and gas industry: a) true b) false OPX Consulting Inc. Page 6 of 6

HEALTH, SAFETY AND ENVIRONMENT MANAGEMENT REVIEW Contractor Company: Address: Date: Phone: Service Provided: Location: Issued By: Harvard Representative Phone: Received By: Contractor Representative Phone: Note: If unsatisfactory is selected, an explanation must be provided in the Comments section. The contractor is responsible to ensure that all deficiencies in this inspection are corrected. Management Involvement Not Applicable (NA) Unsatisfactory (U) Satisfactory (S) U S 1. Is there a written safety program (company manual)? 2. Does management regularly tour worksites to observe work practices and site conditions? (When) Comments: Records Management and documentation 1. Is all critical data for operation and environmental concerns stored onsite and updated? Comments: Quality Management 1. Is there a Quality Management system and do contractors follow that system? Comments: Communication 1. Is the permit system being used? (ie:safe work permits, hot work permits) 2. Are Loss Control Meetings taken place in a timely manner? 3. Are Risk Management and OH&S bulletins posted and discussed? Comments: Emergency Response Planning 1. Is the area emergency Response Plan in place and up-to-date? 2. Are there regular exercises and training to implement the ERP? Comments: Hazard Identification Control 1. Are Equipment and vehicles inspected and at what frequency? (Show examples and completed documentation.) 2. Is there a system for hazard assessment, reporting and follow-up (written or verbal)? Comments: Page 1 of 3

Rules and Work Procedures U S 1. Are there procedures for high risk or critical work? Are they available and used? 2. Are there written emergency plans available and communicated to personnel at the work site? i) ERP ii) Emergency Transportation Plan iii) Working Alone Comments: Incident Reporting 1. Do you have an incident reporting process? 2. Do you have a near miss/incident reporting form that includes follow-up? 3. Are incidents reported and was the problem rectified the previous near miss or accident, and were management and workers involved in the solutions? Comments: Training N/A U S 1. Have you received a safety orientation? (What and When) 2. How often are Loss Control meetings held? (Show examples and documentation) 3. Is the appropriate training in place? 4. First Aid Training 5. H 2 S Training 6. WHMIS Training 7. TDG Training 8. Fire Extinguisher or Fire Fighting Training 9. Job Specific Training/Certification Personal Protective Equipment N/A U S 1. Is the appropriate PPE available and being used? 2. Hard Hat 3. Safety Glasses or Eye Protection 4. Footwear 5. Protective Clothing 6. Hearing Protection 7. Respiratory Protection (For the Nature of the Hazard) 8. Personal Monitor or H 2 S Detector 9. Communication Equipment Comments: Safety Equipment N/A U S 1. Is the appropriate Safety Equipment available and being used? 2. Fire Fighting Equipment (ie: inspected, tagged, accessible and condition) 3. Rotating Equipment Guards 4. First Aid Kit 5. Fall Arrest Equipment (including ladders, steps or stairways, safety belts and lanyards) 6. Bonding and Grounding Equipment 7. Emergency Shut Down and Alarm Systems (including diesel positive air shutoffs and backup alarms) Comments: Page 2 of 3

Contractors N/A U S 1. Is the contractor aware of the safety expectations and standards of the Corporation? Comments: Environmental, Storage and Handling 1. Are potential environmental concerns addressed and corrected? 2. D-58 Compliance (Proper waste storage, ie: filters, contaminated soil and fluid. Show waste manifests.) 3. D-55 Compliance (ie: double walled tanks, tank condition, secondary containment.) Comments Note: The following questions must be completed by the Harvard Issuer. Does this Management Review warrant a follow-up work site inspection by a Harvard Representative? YES NO Instructions for Health, Safety and Environment Management Review. Purpose 1. Harvard representatives hiring contractor(s) are obligated to ensure that the contractor(s) is working within the terms and requirements of the job of project. The Management Review is designed as the go see step in the process of establishing Harvard due diligence. The frequency of the review is dependent on the knowledge and experience of the contractor(s), the nature of the work and the associated hazards. 2. The review is designed for use by a Harvard Representative with the questions focused in the area of the contractor s work site safety management and the minimum Corporation and Regulatory requirements. 3. The review is designed as a mechanism to trigger a more detailed inspection coordinated by the Corporation should the results of the review not meet expectations. 4. The intent is to improve contractor work site safety performance in alignment with the Harvard HSE program Process 1. Harvard Representative conducts a Management Review for Contractor. 2. Leave copy with Contractor to manage any follow up. 3. Harvard Representative completes bottom section which identifies whether or not the Contractor requires a more detailed inspection by Corporation. 4. Harvard Representative will forward a copy to Harvard Calgary Office. 5. Harvard Calgary Office will coordinate follow up inspection of the contractor. PHOTOCOPY DISTRIBUTION: Contractor Harvard Representative Harvard - Calgary office Page 3 of 3

CONSTRUCTION SAFETY PLAN CHECKLIST PROJECT: DATE: CONTRACTOR: SAFETY First Aid Kits on Site Contractor has Safety Program on Site and Responsible for Worker Safety Safety Meeting Requirements Established Safety Committee (Multi-Contractor) Contractor Safety Meetings Tailgate Meetings Housekeeping Procedures Reviewed Work Permit Requirements Established Safety Equipment Requirements Determined Personal Protection Equipment Requirements Determined Location of Safety and Emergency Equipment Established Driving Procedures Established Vehicle and Equipment Operation Procedures Established Accident/Incident Reporting Procedures Reviewed Authority of Supervisor to Shut Down Work Identified PROJECT SCOPE Scope of Work Reviewed Restricted Work Areas Established (Where Applicable) Project Schedule Reviewed Hours of Work Established ENVIRONMENTAL REVIEW Topsoil Handling and Site Grading Fuel and Chemical Storage Waste Handling, Storage and Disposal Equipment Oil Changes HAZARD REVIEW Site Inspection to Identify, Assess and Communicate Hazards - documented H 2 S and Respiratory Equipment Review Overhead Power Lines Equipment/Material Lifts Ground Disturbance / Location of Buried Lines and Equipment Hot Work Combustible Atmospheres Confined Space Entry / Restricted Space WHMIS Trenching Energy Isolation Procedures EMERGENCY Harvard Emergency Response Plan Reviewed Emergency Procedures Reviewed Contact Information Sheet Posted Safe Areas Established First Aid Personnel Identified Fire Extinguisher Stations Established Method to Track Number of Workers on Site Established Plant Emergency Alarm Operation (Where Applicable) OTHER (list) OPX Consulting Inc.

EMERGENCY CONTACT INFORMATION LEGAL DESCRIPTION OF LOCATION: LONGITUDE: LATITUDE: FIRST AID NAMES: DOCTOR LOCATION: TELEPHONE NUMBER: CELL: AMBULANCE LOCATION: TELEPHONE NUMBER: CELL: HOSPITAL LOCATION: TELEPHONE NUMBER: CELL: FIRE DEPARTMENT LOCATION: TELEPHONE NUMBER: POLICE LOCATION: TELEPHONE NUMBER: HELICOPTER FIRM: TELEPHONE NUMBER: CELL: REGULATORY CONTACT: ERCB B.C.O.G.C. NAME: PHONE: CELL: ENVIRONMENT/FORESTRY NAME: PHONE: CELL: LOCAL MUNICIPALITY (Director of Disaster Services) NAME: PHONE: CELL: OPX Consulting Inc. Section 15-3

CONSTRUCTION HSE MEETING REPORT SAFETY PROGRAM MANUAL DATE: TIME OF MEETING: LENGTH: OPERATION: FACILITY PIPELINE SITE/LOCATION: CONTRACTOR(S): CONTRACTOR SUPERVISOR(S): Harvard REPRESENTATIVE: OUTSTANDING CONCERNS: RECOMMENDED ACTION: TARGET DATE: NEW CONCERNS: RECOMMENDED ACTION: TARGET DATE: OTHER TOPICS DISCUSSED: TRAINING GIVEN: REPRESENTATIVE SIGNATURE

SAFETY MEETING ATTENDANCE CONTRACTOR: MEETING DATE: NAME SIGNATURE OPX Consulting Inc.

GROUND DISTURBANCE PERMIT Location: Project Activities: New Installation Tie-in/Re-entry Repairs Company Representative: Reclamation Construction Other Contractor: Date: If ANY of the items listed are answered NO, proceeding with any ground disturbance may contravene company policy, and may result in injury to personnel, damage to equipment, or environment. Supervisor approval is recommended. Documentation of decision is required. RECORD CONFIRMATION YES NO N/A 1. Do you have a copy of the Survey Drawing for the well site, access road, and/or proposed ground disturbance area? *NOTE* If the survey drawing is older than 60 days, consideration should be given to getting an updated survey drawing. 2. Do you have a copy of the Surface Acquisition report? 3. Does the survey drawing Table of Crossing match with the Surface Acquisition Report Table of Crossings? 4. If questions 1-3 are N/A, has the proposed area of the disturbance and buffer zone been electronically scanned? 5. Do you have a recent copy of the Land Title Certificate or Public Land Standing Report? 6. Do you have a copy of the most recent Provincial/Company Pipeline baseline map? 7. Did you notify the Land Agent (Crown Land) or Land Owner (Freehold Land) of your intentions and review any existing underground facilities? Name: 8. Do you have a copy of all Crossing Agreements for any facility identified within 30 metres of the work area? 9. Did you adhere to the crossing notification requirements? 10. Did you contact local Production office and review scope of work and crossings? Name: 11. Have all pipelines, power lines, and utilities in the 30 metre search/controlled area been identified? 12. Has the One Call System been notified of our intentions? VISUAL INSPECTION 1. Are all buried pipelines, power lines, or utilities identified on above drawings, and staked on the ground in proposed area? 2. Are overhead power line Caution Signs in place? 3. Are all the locate stakes or marks referenced to fixed features? 4. Are all of the lines within the 30 meter search/controlled zone identified on the ground? 5. Are there any signs of new ground disturbances within the proposed working area, including the search/controlled zone? This may include pipelines, power lines, Gas Co-op, utility cables, new clearings, road construction, pipeline signs, settlement, vegetation color change or growth. If there is any visual sign of activity that is not reflected on Survey Drawing, re-surveying should be considered. PRE-CONSTRUCTION 1. Is the proposed ground disturbance expected to be any depth below the surface? *CAUTION* - any depth below the surface is a general rule. Ground disturbances located at any depth may encounter lines improperly installed or changed due to shifting ground disturbances. Additional crossing material should be considered. 2. Are there any pipelines, power lines, or utility cables being crossed within the 5 meters where no right-of-way or within the distance outline in crossing agreements? 3. Are ALL the conditions of the Crossing Agreements being met? 4. Have all the underground facilities been exposed as per the company requirements, crossing agreements, and the Regulations? 5. Distance to which mechanical equipment may be operated after exposure from agreement mm 6. Did you conduct a pre-job task meeting with foreman and equipment operators? Review Procedures & ERP. NOTE: This document is designed to be a GUIDE to the minimum safety standards for Ground Disturbance. Refer to the Provincial Regulations, Company Standard Safety Practices Manual, contractor s safety program, and Provincial Health & Safety Statute and Regulations for further details. If project involves interprovince activity, the National Energy Board has additional requirements. SEE NEXT PAGE FOR REFERENCES. Comments: Company Representative: Contractor Representative: Ver. 1.0

DEFINITIONS GROUND DISTURBANCE - is any work, operation, or activity without limitation that results in a disturbance of the earth at any depth. SEARCH AREA- is the 30 meters surrounding the ground disturbance area in which all reasonably necessary precautions must be taken to determine whether or not an underground facility exists. NOTIFICATION - Every owner within the ground disturbance area and the 30 meter search area must be notified of the nature and schedule of the ground disturbance. Notification must be done as per the crossing agreement or as per provincial Regulations of a minimum of 2 working days and a maximum of 7 working days, or greater, as specified in the crossing agreement. CROSSING AGREEMENTS (also referred to as APPROVALS) - Anytime a ground disturbance takes place within a right-of-way, or within 5 meters of a facility where there is no right-of-way, an approval must be in writing. NOTE: A crossing agreement is commonly used as the approval and does not mean an actual crossing is taking place. HAND EXPOSURE - Hand exposure must be done if the ground disturbance crosses or is carried out within 5 meters of an existing underground facility before commencing any mechanical excavation. When exposing the underground facility it must be done sufficiently to identify the facility. Excavation techniques have been developed using water or air jets. These have generally been accepted, although all procedures may not have specific regulatory approval. Care should be taken to evaluate the best method of hand exposure, taking into consideration, damage to coatings, and methods of soil disposal. CAUTION: Even after hand exposure, mechanical equipment must not be used within the distance specified on the crossing agreement, OR, if a crossing agreement is not present, not closer than 60 cm. to the underground facility. REFERENCES ITEMS # 1, 2, 3, 5, & 6 ITEM # 5: ITEM # 10: ITEM # 12: GENERAL: Your surveyors or line locating company usually provide these items. For Freehold Land, this is referred to as Certificate of Title which includes registered ownership and any incumbencies against the property. For Public Lands, this is referred to as the Public Land Standing Report, which includes a listing of any registered dispositions against the property. Plot Plans or lease drawings should be obtained and discussed with area Operations Personnel. Experienced company personnel familiar with area operations may have knowledge of pipelines or utilities not otherwise documented. One-Call Systems provide a no-charge, computerized communication service to advise and help the ground disturber with the location of buried pipelines and utilities. CAUTION: Not all companies are One-Call System members, and as such, it is probable that not all underground facility owners will be notified that you are creating a ground disturbance in the area. It is necessary to perform all the steps to a ground disturbance to ensure as far as it is reasonable and practicable, what is in the ground before you start to dig. The Provincial Acts and Regulations should be available for reference and further resources. Ver. 1.0

CONTRACTOR SAFETY EVALUATION Contractor Name: Date: INSURANCE A. Certificate of Insurance B. $2 million minimum general commercial liability insurance C. $2 million minimum automotive liability insurance D. Worker's Compensation coverage Yes No SAFETY PROGRAM A. Has the contractor submitted a current safety program manual? B. Does the program meet the criteria of the base safety program? Yes No ACCIDENT HISTORY A. Workers Compensation: WCB Number: Statement Date: Employer Rate: Industry Rate: B. Occupational Health and Safety Statement Date: Employer Lost Time Rate: Industry Lost Time Rate: C. Lost Time Accidents in the Past 3 Years DATE DESCRIPTION D. Medical Aid Cases in Past 3 Years DATE DESCRIPTION Page 1of 1

BACK FILL INSPECTION FORM NAME OF EXISTING FACILITY OWNER PROJECT: Crossing Agreement Number AB/BC LSD SEC TWP RGE W M BC QTR UNIT BLOCK /MAP SUB DIV SHEET TYPE OF FACILITY: (Check One) Pipeline Road Rail Road Water Course Data Cable Other: (Specify) Type of Damage Damage repair satisfactory Regulatory agencies notified if damage Indicate approximate location on above plan R.R. Depth Existing Depth New Road River Bed Existing Depth NewPL OR Depth Existing Existing Depth Grade Depth Cased Uncased Road, RR X-ing River/Creek R/W Pipeline - R/W INDICATE: 1. Depth to existing line (On Elevation) 2. Depth to new line above or below existing line (On Elevation) 3. Cathodic protection installed: YES NO 4. If yes, what type of protection? Owner of foreign or existing facility: Size and condition of existing facility: (New) oil, gas, water, etc.: Contractor doing work: Approval Print Name Date Completed Company Signature Print Name Date Completed Contract Signature Ver 1.0

Drilling/Completions/Workovers Pre-job Safety Meeting Form Date: Location: Harvard Supervisor: Rig # / Rig Manager: Safety Meeting Discussion (Topics should include job scope, PPE requirements, specific hazards, people responsibilities) Persons in Attendance Name (Please Sign) Company Supervisor Signature:

Lease Construction Tailgate Meeting Report Location: Contractor: Date: Project#: Employees Present: Print Signature Site Specific Hazard Identification Yes No N/A Action to be Taken Location of: Buried Pipelines Buried Cables Overhead Lines Wellhead Sumps Digging Sumps Knocking Down Trees Leveling and Slopes Towing of Trucks U/G & O/H Utilities Ditch Cut Digging Burrows/Snakepits Driving Speed Limits Other Personnel/Equipment PPE Required Emergency Contact # s Other Other Worksite Plan Company Representative (Print) Signature Contractor Representative (Print) Signature