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HSE REQUIREMENTS FOR SUBCONTRACTORS

(HIGH CRITICALITY)

1 13/07/2017 XLU ISSUE FOR USE MIP FNO


A 15/06/2017 XLU ISSUE FOR REVIEW MIP FNO

Rev. Date Author Description Check Approval

DOCUMENT NUMBER Revision Status

905-PRO-0009 1 IFU
Company:

Document: HSE requirements for Subcontractors

TABLE OF CONTENTS

1 INTRODUCTION........................................................................................................................................... 3

2 CHANGE SINCE THE LAST REVISION...................................................................................................... 3

3 REFERENCES.............................................................................................................................................. 3

4 DEFINITIONS............................................................................................................................................... 3

4.1 Acronyms.................................................................................................................................. 3

4.2 Definitions................................................................................................................................. 4

5 RESPONSIBILITES...................................................................................................................................... 5

6 HEALTH, SAFETY AND ENVIRONMENTAL REQUIREMENTS..................................................................6

6.1 General requirements............................................................................................................... 6

6.2 Health........................................................................................................................................ 6

6.3 Safety........................................................................................................................................ 7

6.4 Training and awareness............................................................................................................ 8

6.5 Environment.............................................................................................................................. 8

6.6 Reporting.................................................................................................................................. 9

6.7 Offshore certifications................................................................................................................ 9

7 REQUIRED DOCUMENTS........................................................................................................................... 9

7.1 HSE document to be provided during the bidding stage............................................................ 9

7.2 HSE document to be provided upon contract award................................................................ 11

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1 INTRODUCTION
This document addresses minimum Health, Safety and Environment requirements that Subcontractors shall
comply with.
The subcontractor shall become familiar with the site HSE requirements and all HSE procedures developed by
GEOCEAN when necessary for the scope of work.
This document shall not release Subcontractors from their obligation of full compliance with any and all
requirements as established in the contract, by the Client, and by legislative requirements.
Subcontractors are requested to make their clarifications during bidding phase.

This document applies to all Subcontractors and their sub-subcontractors who will conduct activities on project
worksites (onshore & offshore) and categorized as “High criticality”.
See annex 1 of document 905-PRO-0007 - HSE management of vendors and Subcontractors for criticality
assigned according to the type of subcontracted activity.

2 CHANGE SINCE THE LAST REVISION


First issue.

3 REFERENCES
Item Name Codification Revision
Occupational Health and Safety
1 OHSAS 18001 2007
Management System
2 Environmental Management System ISO 14001 2008
3 HSE Management System 911-HSE-PRO-01 Rev 15
4 HSE Management at Corporate scale 911-HSE-PRO-02 Rev 13

4 DEFINITIONS
4.1 Acronyms
BOSIET Basic Offshore Safety Induction and Emergency Training
FAC First Aid Case
HRA Health Risk Assessment
HSE Health Safety Environment
ILO International Labour Organisation
JSA Job Safety Analysis
LTI Lost Time Injury
LTIFR Lost Time Injury Frequency Rate
LWD Lost Workdays
MEDEVAC Medical Evacuation
MTC Medical Treatment Case
NORM Naturally Occurring Radioactive Materials
NM Near Miss
OGP International association of Oil & Gas Producers
PPE Personal Protective Equipment
PTW Permit To Work
RTA Road Traffic Accident
SIMOPS Simultaneous Operations
SR Severity Rate
TRI Total Recordable Incidents
TRIFR Total Recordable Incident Frequency Rate
WRC Work Restricted Case
WRD Work Restricted Days
WMH Worked Man-hours

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4.2 Definitions
Accident An unplanned event or chain of events that results in harm to people (e.g. injuries) damage to
environment and / or assets, loss in production.

Client Company, Organization or establishment that has awarded a job to Goecean.

Commuting Injury Term to define all those injuries that occur during the movement of the worker from his/her place
of residence (whether provided by the company or his/her own) to the place of work and vice
versa.

Contract The General Conditions together with the schedules listed in the General Conditions, any
Amendments or Changes, and all drawings, plans and specifications listed therein, or issued to
the Subcontractor by Geocean.

Contractor Geocean

First Aid Case Term to define the treatment at any time of minor injuries that normally do not require the
specialist intervention of a doctor (scratches, cuts, burns, splinters, foreign bodies in the surface
of the eyes, etc.) and any subsequent examinations.
This treatment is considered a first aid case even if administered by a doctor.

Lost Time Injury Term to define any injury at work which makes the injured person temporarilyincapable of
carrying out any regular activity or restricted work during any day/shiftafter the day in which the
injury occurred (in this case "any day" includes days off, weekends and public holidays). The
day of the injury is not included in thecalculation of the lost workdays. The LTI include fatal
accidents, permanent total disability, permanent partial disability and temporary total disability.

Lost Time Injury Frequency Rate


LTIFR = (N° LTI x 1 000 000) / Total of worked man−hours

Lost Workdays Total number of calendar days in which the injure person has not been fit to work following an
LTI. The lost workdays are calculated starting from the second day after the misfortune has
occurred and includes the number of calendar days counted up to when the injured person is fit
again for work. Lost work days are not counted in the case of death or permanent total disability.

Medical Treatment Case Term to define any injury at work (infected wounds, stitches, deep presence of foreign
bodies in the eyes, etc.) which does not entail either lost work days or restricted work days,
but requires recurring treatment by the doctor or in accordance with his specific indication
or which could be considered a case that falls within the scope of a doctor's expertise.
Medical treatment does not include the First Aid Case even if the latter is provided by a
doctor or personnel with a recognised qualification.
Medical Treatment Case are:
• Treatment by a doctor;
• Impairment of bodily functions (e.g. normal use of limbs, senses);
• Damage to physical structure of non-superficial nature (fractures);
• Complications requiring follow up medical treatment;
• Loss of consciousness in the workplace; and
• Medical treatment more serious than just one time first aid.

Near Miss Danger event that, in slightly different circumstances, could have caused and accident with
consequences to people, the environment or assets. These incidents must not be classified as
TRI.

Severity Rate
Severity Rate = (No. of lost workdays ∗ 1 000)/Total of worked man – hours

Subcontractor The term subcontractor applies to all parties directly involved in the performance ofwork under a
contract with a Geocean Company. A Geocean Group company that hasa contract with another
Geocean company is not considered to be a subcontractor.
companies providing temporary labour are also considered subcontractors.

Total Recordable Incidents

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Term to define the sum of LTI, Work Restricted Cases and Medical Treatment Cases:
TRI = LTI+WRC+MTC

Total Recordable Incident Frequency


TRIFR = (Number of TRI ∗ 1 000 000)/Total of worked manhours

Work Related An event is "work related" when, as far as safety reporting performance is concerned, the event
occurs during employment or is related to the contractual activities of personnel, within site
boundaries and within normal working hours or overtime. An incident is also considered "work
related" when the exposure in the working environment is the discernible cause of or contributes
to an injury or significantly aggravates a pre-existing injury. The work environment refers to any
location where the definition of HSE Reporting Boundaries applies.
The following types of incident are NOT to be considered "work related":
- injuries sustained on Geocean or subcontractors' premises while off duty: injuries during lunch
breaks, rest breaks, in the accommodation area and sanitary facilities.

Work Restricted Case Term to define any injury at work, with the exception of deaths or lost work days, which
makes the person unfit for performing all his/her activities fully in the days after the injury at
work. In this case, the injured person is temporarily assigned to other duties or exempted
from some parts of his/her normal duties. An injury can only be classified as a WRC if there
is a written statement of no objections from the injured person. The maximum limitation
time can be 30 days. If the limitation exceeds 30 days, the injury must be classified as LTI.

Work Restricted Days Total number of calendar days starting from the day the restricted work starts up to the day
the workers resumes his/her regular work.
When the restricted work follows a period of lost workdays, the restricted workdays are
added to the lost workdays and the injury is recorded as an incident with lost days.

Worked Manhours Term to define the total number of hours worked by Geocean and subcontractors'
employees within the boundaries of the site. It includes paid overtime and training, but
excludes leave, sickness and other absences.

5 RESPONSIBILITES
The Subcontractor is responsible for respecting this document.

The Subcontractor shall:


 Observe and comply with all current applicable legislative and statutory requirements and guidelines
concerning HSE and welfare of personnel.
 Operate in accordance with HSE Work Instructions, HSE Manuals and other HSE documents, complying
with HSE requirements.
 Promote a high safety level and have in place proper systems for planning, implementation, maintenance
and improvement of HSE issues. Also, the subcontractor shall operate with the highest regard for the
health and safety of its own personnel and ensure that its activities do not endanger site personnel,
local communities and/or the environment.
 Be responsible, through its own organization, for implementing the necessary regulations and practices
required, so as to carry out safely the work assigned by Geocean and to prevent any accident or
incident that may endanger the safety of personnel or may produce damage to property and/or the
environment.
 Adopt appropriate management tools, technical know-how, and work practices to reduce the environmental
impact of its work (e.g. waste and noise production, air emissions, water discharges, etc.) and prevent
possible accidents and injuries. The subcontractor shall encourage and support elimination of waste of
environmental resources (e.g. water, power etc.).
 Fully cooperate with Geocean HSE, project / site management and site staff.
 Provide competent HSE staff and resources to manage risks.
 Ensure compliance with and implementation of Waste Management Plans.

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6 HEALTH, SAFETY AND ENVIRONMENTAL REQUIREMENTS


6.1 General requirements
The general HSE requirements that Subcontractor must comply with are the following, but not limited to:

1. The Subcontractor shall define and apply a HSE Policy that demonstrates its commitment to Health,
Safety and Environment within all its business activities and subcontracted scope of work.

2. The Subcontractor shall establish, implement and maintain a HSE Management System for the
subcontracted activities, which shall include the elements (organisational structure, planning activities,
responsibilities, practices, procedures, processes and resources) to establish HSE policy and objectives
and to achieve those objectives.

3. The Subcontractor HSE Management System shall include, as well, audits of HSE related aspects and
shall be aligned with Geocean HSE Management System.

4. Geocean reserves the right to conduct HSE audits on Subcontractor’s working procedures and
equipment at any time, upon previous notification given sufficiently in advance. At the time of such
audits of the HSE Management System, the Subcontractor shall provide to Geocean any assistance
necessary to allow checking of the used organizational HSE procedures, their efficiency and adequacy
to work methods, machinery, equipment and legal regulations.

5. The Subcontractor is contractually obliged to observe and comply with all currents applicable legislative
requirements and guidance concerning the HSE and Welfare of personnel. All documents required by
law shall be at site and made available to Control Authorities and Geocean.

6. The subcontractor shall make obvious and prove he promotes a high HSE level and has in place proper
systems for planning, implementation, maintenance and improvement of HSE issues. Also, the
subcontractor shall operate with the highest regard of the health and safety of its own personnel and of
environment and ensure that its activities do not endanger the safety of neither site personnel and local
communities.

7. The subcontractor is responsible, as well, for the appropriate selection of personnel who are suitable for
the work.

6.2 Health
1. The Subcontractor shall ensure, for all the personnel involved in the subcontracted activities, the proper
Fitness to Work Examination in order to assess their fitness to the assigned tasks. The certificates
stating the individual’s medical fitness (Medical Fitness Certificate) shall be made available on site upon
request to Geocean’s relevant representatives and/or to Geocean’s Medical Officer on site, preferably
prior to their actual involvement in the activities.

2. As part of HSE risk assessment, the Subcontractor shall perform and submit to Geocean, the health risk
assessment for the subcontracted scope of work.

3. For the entire duration of the subcontracted activities, the Subcontractor shall ensure adequate medical
care to its personnel on site. The level of the medical service organization shall be based upon the
health risk assessment. The medical facilities and services shall meet or exceed local standards and Oil
and Gas Best Practices.

4. When mobilized to the work site, the Subcontractor’s employees shall be always in possession of a
valid Medical Fitness Certificate. Geocean Medical personnel will have free access to the Medical
Fitness Certificates, which shall be easily available on site, always taking into account the confidentiality
of the private medical data.

5. The Subcontractor shall provide the vaccination and other means of protection (i.e. chemoprophylaxis)
to its personnel against the contagious diseases considered being a health related hazard in the area

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where the assignment is intended. The vaccination scheme shall be developed upon the local health
risk assessment, the specific job role of each individual and the actual epidemiological situation of the
area where the subcontracted activities are performed as well as applicable legislation.

6. If Subcontractor disposes of its own facilities, it shall develop a MEDEVAC Plan. The MEDEVAC plan
shall describe the response in case of medical emergency and evacuation to the nearest reliable
hospital (Primary evacuation).

7. Whenever a subcontractor activates a MEDEVAC Plan it has to inform Geocean immediately.

8. The Subcontractor shall establish, implement and manage an adequate “Alcohol and Drugs Policy”.
Through the control plan and program it will demonstrate the full commitment to maintain all the working
premises free of all substances that could impair the employee’s work performance and safety. These
documents shall be submitted to Geocean.

9. The Subcontractor, in accordance with applicable local and international regulations, if not otherwise
specified in the contract, shall inform its own personnel that they can be submitted to random checks to
determine the level of alcohol and drugs in their breath or urine.

10. The Subcontractor shall ensure the fulfilment of the measures of general and industrial hygiene in order
to prevent any occupational diseases, infectious outbreaks or exposure to toxic substances that could
impact on employees’ and/or community health.

11. The Subcontractor shall prove that all its employees are covered by medical insurance that shall also
cover the cost of repatriation with a third party medical assistance, if deemed necessary.

6.3 Safety
1. The Subcontractor shall properly plan and organize its own activities and works; all the existing risks
shall be assessed (e.g. interference risks, electrical hazards, mechanical hazards, risks of falling from
heights, risk burial, exposure to physical, chemical, radioactive sources).

2. The Subcontractor shall implement the necessary occupational health and safety procedures and
measures to carry out safely the assigned work and to prevent any incident with impact on the safety of
the personnel.

3. All Subcontractor’s site personnel shall comply with existing occupational health and safety procedures.

4. The Subcontractor shall comply with Geocean “Permit To Work” System for works and operations
identified as potentially hazardous (e.g. hot works, simultaneous operations, mechanical and electrical
isolations, lockout / tag out, working at height, excavations, entry into confined spaces, radio-active and
flammable materials handling, works that can generate sparks or other source of ignition, ...).

5. The Subcontractor shall provide to its personnel all equipment and devices required for carrying out the
work as well as all the necessary Personal Protective Equipment (PPE). Such equipment and devices
shall be suitable for the specific working environment, periodically inspected and properly maintained in
good condition or replaced when damaged and used according to the instructions and best practices.
Protective clothing and equipment shall be available on site and provided by Subcontractor to its own
visitors (if any).

6. All Subcontractor's own equipment used within Geocean site shall be tested, certified and compliant
with the applicable legislation.

7. Work at height shall be avoided where possible, for example doing the work from ground level. The
Subcontractor shall use work equipment or other measures to prevent falls, where work at height
cannot be avoided.

8. The Subcontractor shall choose the right work equipment and select collective measures to prevent falls
(such as guard rails and working platforms) before other measures which may only provide fall-arrest

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through personal protection equipment.

9. The Subcontractor shall carefully manage the storage areas for flammable and/or explosive
substances. Those areas have to be placed far from traffic and accommodation areas and equipped
with adequate fire prevention systems. All Subcontractor's personnel shall be aware of the location and
use of on-site means of intervention and fire prevention.

10. The subcontractor shall ensure a correct and effective communication between all levels of the
workforce, in order to guarantee that all relevant information concerning HSE issues, with respect to the
performance of the services, are properly handed over from shift to shift and formally recorded.

11. Upon receiving any chemical onsite, the Subcontractor's representative shall immediately submit to the
site doctor the MSDS for the relevant chemicals.

12. During the working period, a Safety Meeting shall be held at the Subcontractor’s site on a periodical
basis, to discuss the HSE aspects related to work performance. The meeting shall be attended by all
the Subcontractor’s key personnel.

6.4 Training and awareness


1. The Subcontractor shall develop and implement a HSE training program to provide instruction and
information on HSE standards, practices, procedures and work instructions.

2. The subcontractor shall be responsible to inform its own personnel about the HSE related risks of the
task and environment of the area where the job will be carried out.

3. The subcontractor shall guarantee that personnel involved in dangerous activities (e.g. working at a
height, activities in confined spaces) is properly informed, formed and trained for the specific activity.
Training activities shall include a theoretical (e.g. procedures and work instructions) and a practical
session (e.g. use and management of PPE).

4. Subcontractor's personnel shall attend Site Induction Training within the first day of entry to the site.

5. When operating in high Malaria risk areas, the Subcontractor shall make sure that its personnel are well
aware about disease before mobilization. Upon arriving on site Subcontractor's personnel shall
compulsory attend the Malaria Awareness organized by medical personnel on regular basis.

6. The Subcontractor shall ensure that its personnel have adequate training and practice for emergency
preparedness situations.

7. In case of drilling and work over operations where H2S is present (or is potentially a hazard), all
Subcontractor’s personnel shall attend training and drills on the use of breathing apparatuses and
escape sets.

8. The Subcontractor shall ensure that a least 1 First Aid trained personnel is available on site for 20
workers.

6.5 Environment
1. The Subcontractor shall comply with the Geocean Environmental Management Plan (if available for the
Project), all applicable environmental laws and any requirement from Client’s and Geocean
representative.

2. The Subcontractor shall notify to Geocean representative, within 24 hours from the event, any spillage
of oil, grease, paint, solvent, chemically treated drilling fluids, sewage or any other pollutant or waste.

3. The Subcontractor shall ensure that liquid waste shall not be discharged into any water, waterway drain,
watercourse or the ground, but it is properly collected in holding tanks and then removed from the site
for adequate treatment.

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4. The Subcontractor shall not burn any waste material without the approval of the relevant authority, and it
shall take all reasonable and practicable measures to prevent or minimize dust generation.

5. Medical solid waste, if any, shall be disposed and handled only using protective devices and following
written procedures. Appropriate containers for the medical waste shall be used allowing their safe
transportation to final disposal or incineration. The final elimination of medical waste shall comply with
local legislation.

6.6 Reporting
1. One section of the monthly progress report shall be dedicated to HSE topics, such as personnel
injuries, occupational health diseases, Safety Meetings results, communications on HSE and other HSE
issues.

2. The Subcontractor shall report every incident (including occupational diseases) involving its personnel
and/or equipment to the relevant Authorities, as well as to Geocean Representative. The event
notification shall be sent immediately (oral or email) to Geocean after the incident. T he results of the
investigation shall be documented through an investigation report to be delivered to Geocean.

3. The Subcontractor shall inform Geocean about any signs of dangerous situation for the personnel, the
environment and Geocean’s asset and it shall take immediately all measures in line with standards,
oilfield practices and / or in accordance with HSE applicable laws.

4. The Subcontractor shall develop an appropriate medical recording and reporting system for any medical
related event. All the events shall be reported to the medical staff on site or to the clinic personnel /
doctors linked to the Project. The records shall be accessible at any moment to Geocean’s medical
personnel, in compliance with confidentiality and privacy rules.

6.7 Offshore certifications


1. All Subcontractor’s personnel onboard Geocean vessels, shall have a valid offshore survival certificate
BOSIET type (Basic Offshore Safety Induction and Emergency Training).

2. Copy of the certificates of personnel scheduled to work offshore within the subcontracted activities shall
be issued to Geocean before embarking. Original copy has to be carried with all the personnel going on
board. Geocean representatives will have the right to refuse Subcontractors’ personnel if not in
possession of valid certification.

7 REQUIRED DOCUMENTS
The Subcontractor is required to provide, together with its offer, the following information and documentation:

7.1 HSE document to be provided during the bidding stage


HSE leadership

1. HSE Policy statement, including “Alcohol and drug” policy.

2. Company Organization chart and Project Organization Chart, specifying HSE positions and roles.

3. HSE Management System Manual.

4. Copy of HSE Certification (OHSAS 18001, ISO 14001...), if any.

5. Employee’s HSE training program and records of training activities.

Health and safety management

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1. Proposed Project HSE Plan in compliance with Geocean HSE Plan and HSE local and international
legislation. The Plan shall address at least the following, but not limited to:
 OH&S Objectives and Targets;
 OH&S Organization and Responsibilities;
 OH&S Communication System and Methods;
 OH&S Induction and Training;
 Hazard Identification and Risk Assessment including the Health Risk Assessment;
 Accident / Incident Investigation and Reporting;
 Emergency / Evacuation Procedures;
 OH&S Audit procedures;
 List of OH&S Procedures applicable to the scope of work.

2. Description of provision and upkeep of Personal Protective Equipment (PPE), both standard issue and
required for specialized activities.

3. Description of management of plant and equipment used within Subcontractor’s premises, sites or other
locations with reference to registration, control and maintenance in a safe working condition.

Health and Safety Past Performances

1. List of the last five years safety statistics within Subcontractor’s organization:
 Number of Fatalities;
 Worked Man-hours;
 Lost Time Injuries (LTI);
 Lost Time Injuries Frequency Rate (LTIF);
 Work Restricted Cases;
 Medical Treatment Cases;
 First Aid Cases;
 Occupational Health Diseases;
 Near-Misses.
 Where appropriate, separate statistics should be given for different locations.

2. Classification of accidents and near-miss incidents, categories of personnel included within


Subcontractor's safety statistics.

3. Explanation of most significant injuries happened over the last 5 years (Report of the Event,
Investigation Report, Medical report, ...).

4. Description of corrective actions undertaken to avoid recurrence of the reported injuries.

5. Any other pro-active indicator monitored by Subcontractor.

Environmental Management

1. Environmental Management System Manual.

2. Evaluation of environmental impacts related with Subcontractor’s specific activities, together with
measures of management of such impacts.

3. Procedures for the identification of significant environmental aspects.

4. Waste management plan or procedure (Typical).

5. Environmental emergency management plan or procedure (Typical).

6. Environmental training program.

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7. Environmental Management System audit program.

8. Environmental self evaluation based on statistical data and environmental incidents.

In case the above documents were not available:

9. Records of environmental training.

10. Environmental documents, plan and procedures regarding Subcontractor or a specific project/site.

11. Reports of disposal or recycle of material/substances.

12. Reports of environmental incidents with relevant corrective actions.

13. List of dangerous products/substances usually used.

14. Every other documentation on environmental management.

7.2 HSE document to be provided upon contract award


The Subcontractor is required to provide, within 30 days upon contract award, the following information and
documentation:

1. Project HSE Plan (refer to §7.1 for content) for the subcontracted scope of work.

2. Risk Assessment for the subcontracted scope of work.

3. HSE Procedures for the subcontracted scope of work, including Emergency Response Plan.

4. Personnel Training Program specific for the subcontracted scope of work.

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