1.0 HSE Management: Policy and Plan 1.1 Corporate HSE Commitment and Policies... 1 1.2 Matrix Scope of Operations... 1 1.3 Client and Contractor Operating Standards... 1 1.4 Program Philosophies... 2 a) Recognized HSE Standards... 2 b) Industry Initiatives... 2 c) Corporate Culture... 2 1.5 Due Diligence... 3 a) Information & Instruction... 3 b) Training... 3 c) Supervision... 3 1.6 Applicable Regulatory Requirements... 4 1.7 Corporate HSE Policy... 5 1.8 Fit For Duty... 5 a) Fitness for Duty... 6 b) Fatigue Management... 6 c) Alcohol and Drug Policy... 7 1.9 Discipline and Enforcement Policy... 10 1.10 Program Audits and Assessments... 12 1.11 References... 12 Forms: 01-01 Management Leadership & Commitment (AASP Section 1)
HSE Management Strategy 1.0 HSE POLICY Based on the principles of CSA Z1000 and ISO 14000 5.0 MANAGEMENT REVIEW 2.0 PLANNING 4.0 CHECKING & CORRECTIVE ACTION 3.0 IMPLEMENTATION & OPERATION Management, Leadership and Support What you need to know Corporate Commitment to HSE HSE Management Strategy Required Plans and Programs What you need to do Commitment to Company principles & policies Establish required plans and programs Establish performance standards and track
1.0 HSE MANAGEMENT: POLICY AND PLAN 1.1 Corporate HSE Commitment and Policies Matrix Drilling Fluids Ltd., and its wholly owned subsidiary, Matrix Specialty Chemicals, are committed to conducting their operations in a safe and environmentally responsible manner. To support this commitment, Matrix has: A Health, Safety and Environment Policy. This policy is posted in the Calgary office together as a reminder of the company s commitment to worker safety. A Policy on Discipline and Enforcement. This policy outlines disciplinary steps that will be followed where breaches of Company Policy, including the HSE policy and work rules occur. A Drug and Alcohol policy / work rule as provided in this section. The HSE Policy and Discipline and Enforcement Policy are included in this section. 1.2 Matrix Scope of Operations Matrix designs drilling fluid programs and provides field support services to its Clients in one of four ways: 1. 24 Hour On-Site Service: Matrix provides a Fluid Technician to be on-site continuously to provide field support to drilling operations and ensure the effective implementation of the fluid program. 2. Full Service: Matrix provides Fluid Technicians to service on a daily and/or as required basis to ensure constant monitoring and applications of fluid provided. 3. Partial Service: Matrix provides Fluid Technicians to periodically visit the wellsite to conduct a spot check to confirm drilling fluid properties. 4. No Field Support: Matrix provides the Client with a copy of the fluid program and arranges for delivery of the required chemical additives. No field support is provided. 1.3 Client and Contractor Operating Standards This manual was prepared by Matrix to establish an appropriate minimum standard for its wellsite supervisors. In the absence of adequate Client or contractor standards, this manual will be used by Matrix Fluid Technicians to guide their decision making. In addition, Matrix management are on call to provide technical and operations support to its Clients and Fluid Technicians. This document recognizes that most of Matrix s clients have developed their own operating standards, procedures and supporting documentation which forms the basis and minimum criteria when conducting well supervision work on behalf of those clients. In addition, each contractor hired by the client is responsible for ensuring current relevant acts, regulations and codes of practice applicable to their work are addressed by their workers. April 2014 Section 1.0 HSE Management Policy and Plan Page 1
Where differences exist between Client safety policies and procedures, Matrix will strive to implement the more stringent standard with a goal of zero worksite incidents. 1.4 Program Philosophies The following philosophies form the foundation for Matrix s HSE Program: a) Recognized HSE Standards To fulfill this commitment, Matrix has developed a Health, Safety and Environmental (HSE) Management System based on: CSA Z1000-06: Occupational Health and Safety Management 1.0 HSE POLICY Environmental, Management Systems (ISO 14001) Health & Safety Management (OHSAS 18001 CSA Z1000) 5.0 MANAGEMENT REVIEW 4.0 CHECKING & CORRECTIVE ACTION 2.0 PLANNING 3.0 IMPLEMENTATION & OPERATION Basic Safety Program (BSP) for Upstream Petroleum Industry (IRP Vol. 9) and the BSP Audit Protocol. OSHA Process Safety Management (PSM) requirements. The foundation for these processes is shown in the diagram on cover page. b) Industry Initiatives Matrix is committed to ensuring a strong future for our industry, the environment and the people of Canada. Matrix is a member of the Alberta Association for Safety Partnerships (AASP) and a supporter of the Stewardship Program. Matrix also recognizes the importance of the Partnerships program sponsored by Alberta Employment and Immigration and maintains a Certificate of Recognition for its safety program. c) Corporate Culture Corporate culture is the largest factor that determines how effectively a company s safety initiatives will work. The corporate culture, as it is related to achieving safety excellence, is driven by the following criteria: Top management is visibly committed. Middle management is actively involved. Supervision is performance-focused. Workers are engaged and actively participating. HSE system is based on defined values but with flexibility to meet needs. HSE system is positively viewed by the workforce. Based on the work of Dan Petersen, Ph.D. The Bottom Line: Matrix management believes that safety becomes part of your entire life and not just something you only practice at the workplace. April 2014 Section 1.0 HSE Management Policy and Plan Page 2
1.5 Due Diligence Matrix expects its managers and supervisors to have a clear understanding of their responsibilities within the HSE management system. Matrix believes that it is important to evaluate the effectiveness of safety management systems regularly. "Due diligence" is defined as taking all reasonable care to prevent the occurrence of an incident or event. Due diligence in safety management can be described as a system approach that provides information, instruction, training, supervision, verification of knowledge, correction of physical and human hazards and evolution of the system over time. a) Information and Instruction (Education): This part of the system ensures that workers receive the appropriate level of education they need to work safely. Education routinely takes place in classroomtype group settings, crew talks, one-on-one safety reviews, or through written or verbal directions. b) Training: Training typically takes place on the job assigned. A training system includes training standards, selection of trainers, supervision during training, verification of training, and demonstrated competencies when training is completed. c) Supervision: This part of the system ensures: Verification of training and education Identification and correction of hazards Direction and instruction of workers Response to worker questions and concerns Direct observation of workers Documentation Correcting unsafe or unwanted behaviour Monitoring the system to ensure safety goals are met As part of its due diligence, Matrix management reviews it HSE programs annually while performing their SECOR audit. Any management follow-up actions are recorded using the Corrective Action Plan form included in this section of the manual. April 2014 Section 1.0 HSE Management Policy and Plan Page 3
1.6 Applicable Regulatory Requirements and Inspections Within Canada, 80% of oil and gas development occurs in Alberta. With this in mind, the content of this manual is focused primarily on Alberta HSE regulatory requirements. Where appropriate, references are made to other provincial regulations where those requirements exceed or differ significantly from the standards established for Alberta. Overall, the differences are minimal as a result of the significant efforts being made to harmonize industry standards and regulatory requirements across Western Canada. In the event there are differences between provincial safety requirements Matrix defaults to the most stringent standards and strives for a target of 0 incidents. This manual is developed in consideration of the following regulatory jurisdictions: Alberta British Columbia Saskatchewan Specific Matrix policy documents and external regulations, standards and practices relevant to Matrix s operations are identified on a section-by-section basis. Where possible, electronic copies of these documents are provided on the HSE USB flashdrive. In some instances, due to copyright laws or information available only online, it is necessary to take the reader directly to a website for additional information. These links will be identified by italicized, blue underlined text. All workers, contractors, sub-contractors and vendor representatives will comply with all applicable provisions of Federal, Provincial and local laws and codes. Where regulations apply to a given task, the regulations and codes will be the minimum requirement. Matrix recognizes and adheres to the laws, codes, regulations and standards relevant to its operations. In addition to workplace health and safety requirements, the company is aware of the compliance requirements as outlined in the AER s Directive 19 as well as a Summary of Key Compliance Issues. Employees and contractors are reminded that: The enforcement process is simplified to include two enforcement processes: one for high risk and one for low risk activities. Enforcement actions are based on the risk levels predetermined by the AER. Enforcement actions will be escalated for persistent non-compliance; prompt reaction is expected and required whenever non-compliances are identified. Regulatory agencies may also carry out formal inspections at varying frequencies depending upon perceived risks and location. Copies of any inspection reports that are generated as a result of an inspection must be forwarded to the Matrix representative responsible for the operations. The process for reporting regulatory inspections is outlined in Section 7.0, Incident Management. April 2014 Section 1.0 HSE Management Policy and Plan Page 4
1.7 Corporate HSE Policy 1.8 Fit For Duty Matrix recognizes that fit for duty is a serious concern in our industry and can lead to incidents. All Matrix workers must be physically capable of performing their job. Matrix s fatigue management expectations and alcohol and drug policy are important steps towards ensuring that workers are fit for duty. These requirements are communicated to all workers during Matrix on-boarding orientations. Matrix will provide required assistance to employees in those circumstances where they are unable to perform their required duties safely. April 2014 Section 1.0 HSE Management Policy and Plan Page 5
a) Fitness for Duty Certain physical requirements of the job must be met in order to reduce the potential for incident. In addition those workers whom are returning to work after an incident should be assessed to avoid further injury and evaluate if further rehabilitation should be done prior to returning to work. Each position will require a specific criteria be met, these criteria will be outlined in a prejob hiring package / post incident evaluation package and be related to the specific position of that employee. b) Fatigue Management Put simply, fatigue means exhaustion, tiredness sluggishness or sleepiness. It s not just a perception a feeling of being tired but a physical state experienced by your body. Because of the importance of this issue, Matrix requires workers to report fatigue to their supervisor. In turn, supervisors must take action to address reported concerns. Unfortunately, many workers often feel the need to ignore these messages from their bodies. Lack of sleep and fatigue has contributed to some tragic workplace incidents and the AMA reports that fatigue is a factor in over half of all singlevehicle collisions! Fatigue can take a big toll on your body and can decrease your reaction times, impair memory, impair your vision and even lead to micro-sleeps where your brain goes on auto-pilot for up to 60 seconds at a time. Needless to say, fatigue is a serious concern for anyone operating a vehicle or equipment. Matrix considers the following in its fatigue management initiatives: Work Shifts: Since the best way to prevent fatigue is get enough quality sleep, Matrix aims to provide a work schedule that can help get enough quality sleep while on the jobsite. As a result, we endeavor to have work shifts of 12 hours followed by 12 hours of rest for most normal operating conditions. However, circumstances shall arise when we need employees to work longer than 12 hours. Matrix will monitor operations to ensure sufficient rest breaks for workers are allowed for rest and recovery time. Depending on the location, this may also include access to proper nutrition. Task Analysis: Job Safety Analysis (JSA) process includes period evaluation to consider and minimize fatigue hazards. This includes evaluating the type of work task, the length of the task, workplace conditions, etc. As highlighted in Matrix Vehicle Operations guideline, workers are to be reminded never to operate motor vehicles or heavy equipment while excessively fatigued. Worker Training: Training will include information on how to recognize fatigue, how to control fatigue through appropriate work and personal habits, and fatigue reporting. This is an important consideration in all tailgate safety meetings. Some closing thoughts: Matrix understands that even with adequate rest periods between shifts, the shift rotation can cause some employees to experience fatigue because their sleep cycles are not adjusting adequately. There are various tools workers can use to help their sleep cycles adjust. Eating regularly scheduled meals April 2014 Section 1.0 HSE Management Policy and Plan Page 6
and snacks at the same time every day of lean meats, fruits, vegetables and wholegrain breads and cereals will aid your sleep cycle. Consuming caffeine, highsugar drinks, sweets and fried foods before bed can worsen your sleep cycle. c) Alcohol and Drug Policy April 2014 Section 1.0 HSE Management Policy and Plan Page 7
Matrix Alcohol and Drug Work Rule Work Rule The inappropriate use of alcohol and drugs can have serious adverse effects on the safety and well-being of workers, contractors and the public. Awareness of the potential risks associated with the use of alcohol and drugs can assist in providing a safe, healthy and reliable workplace. The objective of this Alcohol and Drug (A&D) Work Rule is to eliminate the risk of incidents (safety, health, environmental and operational) of which alcohol and drug use may be a contributing factor or cause. No worker shall distribute, possess, consume or use alcohol or illegal drugs on a Matrix worksite. No worker shall report to work or be at work under the influence of alcohol or drugs that may or will affect their ability to work safely. No worker shall test positive for any alcohol or drugs at concentrations as specified in Section 3.1 of the Policy Model. No worker shall misuse prescription or non-prescription drugs while at work. If a worker is taking a prescription or non-prescription drug for which there is a potential unsafe side effect, he or she has an obligation to report it to the supervisor. Matrix will follow the Enform Alcohol and Drug Policy Model and recommended Guide for Alcohol and Drug Testing. These documents summarize the circumstances for testing and what the related response can be with references to what infrastructure is needed to support the testing, along with the specific section reference in the Policy Model. Roles and Responsibilities The successful implementation of the Canadian Model is the shared responsibility of owners, contractors, workers and labour providers. As part of this shared responsibility: Matrix and contractor supervisors or leaders must: Be knowledgeable about the Matrix s alcohol and drug work rule and procedures. Ensure they comply with the work standards as part of their responsibility to perform their work-related activities in an effective and safe manner. Be knowledgeable about the use of alcohol and drugs and be able to recognize the symptoms of the use of alcohol and drugs. Understand their company s performance management policy and how this Canadian Model is integral to that policy. Take action on performance deviations and reported or suspected alcohol or drug use by workers on Matrix worksites. April 2014 Section 1.0 HSE Management Policy and Plan Page 8
Matrix representatives and contractors are expected to: Ensure that all employees understand the existence of and content of the Matrix s A&D policy and work rule as part of the employee s orientation to that company. Provide supervisory training and awareness in dealing with the use of alcohol and drugs in the workplace. Provide prevention programs that emphasize awareness, education and training with respect to the use of alcohol and drugs. Ensure that the alcohol and drug testing is performed according to the standards set out in this document. Ensure the Matrix A&D policy and work rule are supported in the contractor s HSE performance management systems. Ensure effective employee assistance services are available to workers. Assist workers in obtaining confidential assessment, counselling, referral and rehabilitation services. Actively support and encourage rehabilitation activities and re-employment opportunities where applicable. Assist in the provision of rehabilitating opportunities for persons who have problems with the use of alcohol and drugs. All workers must: Have an understanding of the alcohol and drug work rule. Take responsibility to ensure their own safety and the safety of others. Ensure they comply with the work standards as part of their obligation to perform work activities in a safe manner. Comply with the work rule and follow appropriate treatment if deemed necessary. Use medications responsibly, be aware of potential side effects and notify their supervisor of any potential unsafe side effects where applicable. Encourage their peers or co-workers to seek help when there is a potential breach or breach of policy. The successful implementation of Matrix Alcohol and Drug Policy and the above work rule is the shared responsibility of owner companies, contractors, workers. April 2014 Section 1.0 HSE Management Policy and Plan Page 9
1.9 Discipline and Enforcement Policy Outlined below are the disciplinary steps that will be followed where breaches of company policy occur, including Matrix s HSE policy and work rules. Generally, all four steps will be employed. However there may be instances where, due to the seriousness of the offence, the process will begin at a higher level. The severity of the situation may justify immediate dismissal. A B C D NATURE OF INFRACTION Verbal Warning Examples may include minor breach of Client or Contractor policy or duty; however, no personal injury or property damage has or might reasonably be expected to have resulted. Written Warning Examples may include breach of Client or Contractor policy or duty, an incident where risk of personal injury or property damage was evident, or a repeat of Step A. Written Warning Breach of Company policy or duty, an incident resulting in minimal personal injury or minimal property damage, or a repeat of Step B. Suspension Breach of Company policy or duty; actions resulting in, or in the Supervisor s opinion, an incident which could or had the potential for serious personal injury or significant property damage; insubordination or other action by a worker, which may justify dismissal for cause; or a repeat of Step C. COMMENTS Contractor Management and the worker should privately discuss the incident. Management should present the facts and clearly describe the problem. Management must seek input from the worker on how to address the problem, what time frame should be set for resolving the problem and what follow-up discussions should occur. Unless requested by the worker, written documentation is at the discretion of Management, though noting the date of the discussion is recommended. A record of all verbal warnings will be maintained to provide supporting documentation in the event that escalating disciplinary action is required. Management and the worker privately discuss the incident. Management needs to check that the worker is clearly advised of: - Client or Contractor expectations regarding the issue - the specific behavior that was unacceptable - what is necessary to correct the situation - the designated time frame to improve, and; - the consequences of failure to improve. Management and the worker must document corrective actions. Management discusses the issue privately and then with the worker. Management will confirm that the worker has been clearly advised of all the issues outlined in Step B. The Management, Matrix Supervisor, and worker must document corrective actions and a copy must be placed on the worker s file. When immediate action is necessary or when all the facts are not available, the Supervisor may suspend the worker with pay for up to five working days to permit investigation of the incident. Management shall meet to review the circumstances surrounding the infraction. Following the meeting, Management will inform the worker if there will be a suspension with or without pay or termination of employment. Note: For infractions where intoxication is suspected, refer to the Matrix Drug and Alcohol Policy regarding company guidelines for alcohol and drug testing. April 2014 Section 1.0 HSE Management Policy and Plan Page 10
The following are examples, but are not limited to, the actions which shall involve discipline according to the aforementioned guidelines: 1. Stealing or willful damage to property; 2. Working and/or travelling while impaired by alcohol or drugs; 3. Habitual tardiness; 4. Smoking in areas where such is prohibited; 5. Having open fires where such practice is forbidden; 6. Carelessness in regard to accident prevention and/or safety of fellow workers; 7. Refusal to comply with Company or Governmental Safety Regulations; 8. Failure to report or failure to report accurately to the proper authorities, whenever required, accidents, operational breakdowns, personal injuries, etc.; 9. Insubordination, including refusals or failure to perform work at any time when called upon to do so, unless work is considered excessive, unsafe or illegal; 10. Absence from duty without notice to, or permission from the immediate Supervisor; 11. Sleeping while on duty; 12. Obtaining materials from operator location or other assigned places without proper authority; 13. Malicious mischief resulting in personal injury or destruction of Company or worker property; 14. Divulging confidential Company information; 15. Unauthorized use of a Company vehicle; 16. Accumulation of traffic violations, which put driver s license and/or Company vehicle insurance at risk. 17. Non-compliance with Matrix driving policy and/or provincial law. Notwithstanding the procedures outlined above, there may be circumstances where the nature of the infraction is so serious that, upon review by Matrix Management, the employment of the offending worker may be terminated immediately with cause. April 2014 Section 1.0 HSE Management Policy and Plan Page 11
1.10 Program Audits and Assessments Matrix is committed to maintaining a Certificate of Recognition (SECOR) for its HSE program. As part of this commitment, Matrix will prepare and submit a self-audit annually to its certifying partner, the Alberta Association of Safety Partnerships for their review and approval. Program documents are also submitted to Complyworks and ISNetworld for approval under the Review and Verification System (RAVS). In addition, the company may retain third party consultants to assist management with the review and improvement of the company s HSE management plans. 1.11 References Key regulations, standards and practices pertinent to this section include: Agency/Regulation Description CSA Z1000-06: Occupational Health and Safety Management Environmental, Health & Safety Management Systems ISO 14001 / OHSAS 18001 Environmental Management OSHA Process Safety Management (PSM) AER Directive 19 WorkSafeBC Enform APEGGA This standard specifies requirements for an occupational health and safety management system (OHSMS) and is applicable to an organization of any size or type. It is not intended to address product and services safety. OHSAS 18001 is a specific standard for occupational health and safety management systems designed to eliminate or minimize the risk to employees and other interested parties who may be exposed to occupational health and safety risks associated with the business activities. OHSAS 18001 is compatible with ISO 9001 and ISO 14001 management systems. OHSAS 18001 represents a progression of a management system philosophy, from quality to environmental, continuing to occupational health and safety. ISO 14001 is a specific standard in the series for a management system that incorporates a set of interrelated elements designed to minimize an organization s impact on the environment. The PSM of Highly Hazardous Chemicals (HHC's) standard, 29 CFR 1910.119 is intended to prevent or minimize the consequences of a catastrophic release of toxic, reactive, flammable or explosive HHC's from a process. The rule intends to accomplish its goal by requiring a comprehensive management program integrating technologies, procedures, and management practices. This Directive specifically focuses on the enforcement aspect of compliance assurance and applies to all AER requirements and processes except utility rate matters. Managing Safety from the Supervisor s Perspective (Four Cornerstones of Due Diligence) brochure The Key to a Safe Workplace and Due Diligence brochure IRP Volume #9 - Basic Safety Program Basic Learnings In Industrial Safety And Loss Management Faculty Of Engineering, University Of Alberta/APEGGA Publication - January 1998 April 2014 Section 1.0 HSE Management Policy and Plan Page 12
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