Suncor Life Saving Rules Document Number: RGS0013A Revision Date: 2015/03/19 Revision: 1 Review Cycle: 3 Years Standard Administrative Document Owner (Title): General Manager, Environment, Health & Safety, Oil Sands & In Situ Applies To: Regional Wood Buffalo Summary of Changes Rev No. Section Changed Revision Made 1 New Document Scope This standard applies to all Suncor employees, contractors, subcontractors and on-site visitors and/or vendors working in the Regional Municipality of Wood Buffalo (RMWB). This standard has been developed based on the Oil Sands Safety Association (OSSA) Regional Safety Rules Regional Code of Practice (RSR2013) document. Purpose To establish a common approach and a set of common regional Life Saving Rules that are recognized and enforced by all Suncor business areas operating within the RMWB. These rules are common across all OSSA member companies and are based upon the International Association of Oil & Gas Producers (IOGP) Life-Saving Rules to maximize industry alignment. Compliance All Suncor business areas operating within the RMWB, including Oil Sands, In Situ, Major Projects and Refining & Marketing Pipelines where the work occurs within the boundaries of RMWB, must comply with this standard unless there is a more restrictive Suncor-wide or regulatory requirement that dictates otherwise. Any changes to the definitions must be endorsed by the Board of Directors of OSSA. Roles and Responsibilities The following individuals and groups have the following roles and responsibilities: Document Owner Ensures this document is reviewed according to the required revision cycle. Ensures the document is updated to accommodate changes to Suncor, provincial, and federal regulation. Ensures the document is updated to mitigate risks found as the result of an incident. Continued on next page Page 1 of 9
Roles and Responsibilities Continued Document Approver Ensures this standard is necessary and that it aligns with management and company direction. Suncor s Member Of The OSSA Board Of Directors Incident Review Committee Member(s) Senior Leaders, Managers Endorse and approve revisions or exceptions to safety training standard and/or an OSSA Regional Code of Practice. Ensure no changes are made to the OSSA-approved symbols or definitions. Regularly review all investigations to ensure a consistent approach to investigations and any associated application of discipline. Ensure the symbols and definitions outlined in this document are preserved in their entirety. Ensure the rules outlined in this document are implemented effectively. Enforce the message that everyone is authorized and required to stop work if there are doubts about the safety of an activity. Ensure personnel are trained on the Safe Work Practices outlined in this document. Ensure rule infractions are investigated following the processes defined by Operational Excellence Management System (OEMS) Element 15: Incident Management. Ensure consistency in the application of discipline when an infraction occurs. Supervisors/Front Line Leaders Ensure personnel are properly trained for the work they conduct, as outlined in this document. Promote and enforce the Life Saving Rules. Ensure that work is stopped if there is a rule infraction. Report any rule infraction to the Manager and initiate an investigation following the processes defined by Operational Excellence Management System (OEMS) Element 15: Incident Management. Health & Safety Managers/Specialist Provide subject matter expertise on safety rules. Support the Investigation and Root Cause Analysis of the incident. Provide input on any disciplinary decisions based on investigation results. HR Advisors Provide subject matter expertise on any disciplinary actions that are a result of a rule infraction. Continued on next page Page 2 of 9
Roles and Responsibilities Continued Workers Responsible for protecting the health and safety of themselves and other workers. Responsible for following the Life Saving Rules. References OSSA Regional Safety Rules Code of Practice RSR 2013 RGP09001 - Safe Work Control (SWC) Procedure Regional or EHS ILP RGS0009A - Personal Protective Equipment LMP0058A - Incident Learning and Prevention Process Terms, Definitions and Acronyms The following terms, definitions and acronyms are used in this standard: IOGP LSR OEMS OSSA International Association of Oil and Gas Producers Life Saving Rule Operational Excellence Management System Oil Sands Safety Association An association made up of member companies in the Wood Buffalo region, including Shell Albian Sands, Canadian Natural Resources Ltd., Suncor Energy Inc., and Syncrude Canada Ltd. OSSA issued the Regional Safety Rules Regional Code of Practice RSR2013 document on which this standard is based. RMWB Regional Municipality of Wood Buffalo Standard 1. Fundamental Requirements To effectively implement the safety rules, the following requirements must be met: Safe Work Practices Personal Protective Equipment 1.1 Safe Work Practices must follow the requirements of RGP09001 Safe Work Practices. 1.2 Personal protective equipment must be provided and worn in accordance with the requirements identified by the risk assessment and specific work-site policies, standards and procedures as per RGS0009A. Continued on next page Page 3 of 9
Continued Awareness of Responsibility Incident Learning and Prevention 1.3 Everyone must be aware that they are authorized and required to stop work if they are in doubt about the safety of an activity. 1.4 All incidents must be classified, investigated and managed using the Suncor Incident Learning and Prevention Standard LMP0058A. 2. Life Saving Rules Requirements Adopt and Enforce Rules 2.1 All areas of RMWB must adopt and enforce the following Life Saving Rules for approved work sites. Note: In all areas of Suncor s approved work sites in RMWB, the first 6 rules are mandatory and must be prominently posted in the work areas. The 7th rule is mandatory for all Oil Sands Mining operations areas and does not apply to other sites in the region. Usage Support 2.2 Each rule must have a Safe Work Practice in place to support its usage. Continued on next page Page 4 of 9
Continued Consistency of Rules 2.3 References to the Life Saving Rules must use the circular symbols (shown in Figure 1: Seven Life Saving Rules). No changes to the symbols are allowed. Changes must not be made to the 7 Life Saving Rules. The Life Saving Rules can be supplemented by additional relevant Supporting Safety Rules. The use of Supporting Safety Rules must be approved for use in the area and follow guidelines as outlined in Appendix B - Area Specific Supporting Rules Request / Approval Form. Background information: These life-saving rules have been endorsed and implemented to improve safety performance and/or to mitigate risks to workers where there has been a history of significant injuries or fatalities related to these high risk work activities. Figure 1: Seven Life Saving Rules 3. Supporting Safety Rules Requirements Consistency of Rules 3.1 All Supporting Safety Rules must have the symbol and primary text definitions used consistently where they are applied or required at approved work sites and all Supporting Safety Rules outlined in Figure 2.12: Supporting Rules. Additions or changes must not be made to the symbols or definitions of any of the Supporting Safety Rules Continued on next page Page 5 of 9
Continued Approval and Location of Site- Specific Rules 3.2 Because the subsequent 12 supporting rules are not considered Suncor s Life Saving Rules, and to avoid confusion between the Life Saving Rules and Supporting Rules, any Supporting Safety Rule(s) must be approved for use in the area. Supporting Safety Rules must be shown to the right of or beneath the Life Saving Rules, and identified as Site Specific with a demarcation line. Each rule must have a Safe Work Practice in place to support its usage. Figure 2: 12 Supporting Rules Awareness of Rules 3.3 All rules must be reviewed with new workers and contractors before the start of work. Page 6 of 9
4. Enforcement Requirements Reporting and Tracking 4.1 All incidents involving a Life Saving Rule must be reported and tracked throughout the region. Note: This data is used as a primary precursor measure for managing high potential incidents. Compliance trends with Life Saving Rules will be regularly reviewed by senior management. The goal is to improve safety performance and to eliminate serious injuries and fatalities throughout the RMWB. Investigations 4.2 All incidents involving a Life Saving Rule must be investigated. Note: The processes detailed under OEMS Element 15: Incident Management is to be used to drive the investigation. Non-Compliance Identification Non-Compliance Consequences Supervisor Impacts of Non- Compliance 4.3 When a root cause analysis shows a clear behavioural link between the incident and a violation of a Life Saving Rule, the incident must be declared a Life Saving Rule non-compliance. 4.4 A non-compliance is unacceptable and must result in consequences to the violator, which may include removal from site and/or termination of employment. 4.5 Because supervisors play a key role in reinforcing Life Saving Rules in terms of employee engagement and ensuring compliance, a manager/leader must apply consequences to a supervisor, up to and including removal from site and/or termination of employment, if a supervisor: Does not ensure adequate training or communication of the rules Tolerates the behaviours or conditions that lead to rule breaking Fails to follow through if a rule is broken Note: The area leader should consult with the HR and EHS leaders in the area and make a determination of consequence. Non-Compliance Consequences Applicability and Compliance 4.6 Incident Review Committee must regularly review incidents to ensure consistency in the application of discipline and assist, if required, in the decision to apply a consequence. 4.7 The implementation of this standard must be audited to ensure the standard meets the needs of the work place and complies with the Regional Code of Practice (RSR2013) and other applicable requirements, such as the Occupational Health and Safety Act (Alberta) and Code. End of Standard Page 7 of 9
Appendix A Combining Life Saving Rules with Supporting Safety Rules Additional Guidance Examples of how Life Saving rules are to be combined with Supporting Safety Rules. In order to add additional rules, approval must be obtained by the area VP as well as area EHS Leader. In each case the Supporting Safety Rule(s) must be shown to the right of or beneath the Life Saving Rules, and identified as Site Specific with a demarcation line. Page 8 of 9
APPENDIX B Area Specific Supporting Rules Request/Approval Form To obtain approval to use the supporting safety rules, complete this form and submit to the area VP and area EHS Leader for approval. Initiator: Area: Date: Supporting Rule Request (check all that apply): Wear your seat belt Follow prescribed journey Prevent dropped objects management plan Position yourself in a safe zone in Obtain authorization before starting Conduct a gas test when required relation to moving equipment excavation activities While driving, do not use your phone and do not exceed speed limits Do not work under or near overhead electric power lines Do not smoke outside designated smoking areas Wear a personal flotation device when Follow prescribed lift plan Do not walk under a suspended load required of why supporting rule(s) are required General nature of work: History of incidents associated with the rule(s): Describe the risk of not including this rule for the area: Required Documentation Are procedures in place to support the usage of the additional supporting rule? Yes No If yes, what are the DMS numbers for the supporting procedure(s)? Document Name DMS Number Are you aware of the visual identity requirements for the Life Saving Rules? Yes No By signing this document, you agree to comply with the visual identify requirements outlined in the Safety Rules Standard (RGS0013A) Approvals Initiator (Print): Area VP (Print): Area EHS Leader (Print): Signature: Signature: Signature: Email completed form to oilsandsehs@suncor.com Page 9 of 9
The following individuals have approved and signed this document. UserName: Steve Stewart (sstewart) Title: GM EH&S MP SCM FL Date: Tuesday, 24 March 2015, 01:54 PM Mountain Time Meaning: Approver 1 Signed ================================================ UserName: Jim Chuey (jchuey) Title: GM EH&S Oil Sands & In Situ Date: Tuesday, 24 March 2015, 04:05 PM Mountain Time Meaning: Approver 2 Signed ================================================