HEALTH, SAFETY, AND ENVIRONMENT
MANAGEMENT SYSTEM (HSEMS)
June 2010
TABLE OF CONTENTS
PAGE
PART I INTRODUCTION
Corporate Health, Safety and Environment Policy…………………….. 1
Purpose ............................................................................................. 2
HSEMS Framework........................................................................... 3
PART II HSEMS
1. Management Leadership and Accountability............................. 5
2. Employee Leadership ............................................................... 6
3. HSE Policy ................................................................................ 6
4. Management of Risks ............................................................... 7
5. Compliance and Advocacy ........................................................ 7
6. Objectives and Targets ............................................................. 7
7. Financial, Human and Physical Resources .............................. 8
8. Practices and Procedures ......................................................... 8
9. Competency and Training ......................................................... 8
10. Emergency Preparedness and Response ................................. 10
11. Personal Protective Equipment ................................................. 11
12. Contractor Control .................................................................... 11
13. Environmental Protection .......................................................... 12
14. Occupational Health .................................................................. 13
15. Security and Travel .................................................................. 13
16. Management of Change ............................................................ 14
17. Reliability of Operations ............................................................ 14
18. Efficiency of Operations ............................................................ 14
19. Documentation and Records ..................................................... 15
20. Incident Management ................................................................ 15
21. HSEMS Audits ......................................................................... 16
22. Management Review ................................................................ 17
June 2010
HEALTH, SAFETY AND ENVIRONMENT POLICY STATEMENT
Valeura Energy Inc. is committed to conducting its business in a manner that protects the health and safety of its
employees, contractors and the public and is environmentally responsible.
Key Beliefs
Nothing is more important than protecting human health, safety and the environment.
All incidents can be prevented
Management is accountable for Health, Safety and Environment (HSE) performance
Working safely and in an environmentally responsible manner are conditions of employment
Preventing incidents and managing environmental impacts are fundamental to good business
Guiding Principles
LEADERSHIP
Valeura management will demonstrate visible and active leadership to our employees and contractors to achieve
our HSE objectives.
ACCOUNTABILITY
Valeura management will ensure that employees under their direction are:
Competent to manage their HSE responsibilities
Knowledgeable of the hazards and risks associated with their jobs
Provided with practices, procedures and tools to conduct their work in a safe and environmentally
responsible manner
All employees and contractors have a responsibility to perform their jobs with integrity and in a safe and
environmentally acceptable manner and are accountable for:
Compliance with relevant HSE regulations and corporate policies, practices and procedures
Their own personal safety
The safety of their co-workers
Reporting all incidents and taking action whenever they see an unsafe act or condition
INTEGRATION
Valeura will integrate HSE considerations in business plans, project designs, operating practices and employee
development programs.
PREVENTION
Valeura uses a Health, Safety and Environment Management System (HSEMS) to systematically identify, assess
and manage risks to employees, contractors, the environment and the communities in which we operate. The
goal is to anticipate, prevent and mitigate harm to health, safety and the environment.
PREPAREDNESS
Valeura will ensure that an emergency response capability is in place for all of its operations and is periodically
tested. In the event of an incident, Verenex will respond promptly in a manner that protects the health and safety
of its employees, contractors and the public, and that minimizes the incident’s impact on the environment.
MEASUREMENT
Valeura will measure and report on health, safety and environmental performance and maintain regular
communications with stakeholder groups and communities in which we operate.
CONTINUAL IMPROVEMENT
Valeura aspires to eliminate all occupational injuries and incidents. This requires active engagement and
progressive improvement in competencies and performance by all employees in how we identify and manage
hazards and risks associated with our work.
April 2010 HSEMS Framework 1
PURPOSE
Valeura Energy Inc. (the “Company”) has adopted a Health, Safety and Environment
Management System (HSEMS) to support the Corporate Health, Safety and Environment
Policy. Use of the HSEMS throughout the Company will assure that the HSE policy and
principles are applied consistently to all operations. The HSEMS is a management tool to
achieve the Company’s commitment to conduct its business in a way that protects the health
and safety of its employees, contractors and the public and is environmentally responsible.
This document describes a comprehensive HSEMS for the Company. The HSEMS consists of
elements that contain specific principles and expectations. The principles and expectations
communicate corporate expectations. Each business unit will determine for themselves how
best to meet these expectations by setting their own priorities and addressing the
expectations.
The HSEMS will ensure that all business units conduct business in accordance with the HSE
Policy. For the Management System to be successful, employees should have an appropriate
understanding of the process and their accompanying responsibilities within it. Managers are
responsible for establishing programs and procedures to meet these principles and
expectations.
April 2010 HSEMS Framework 2
PART I Introduction
HSEMS FRAMEWORK
The HSEMS is built on the ISO 14001, OHSAS 18002:2000, OGP and API Standard models to
ensure that health, safety, and environmental issues are systematically identified, controlled,
and monitored. There are several reasons for selecting these standards as models for the
Company’s HSEMS framework:
The standards ensure that performance of the HSEMS improves over time – continual
improvement.
The ISO 14001 Standard for Environmental Management Systems is an accepted
international Standard for Environment Management Systems.
The OHSAS 18002:2000 Occupational Health and Safety Management Systems is an
accepted international standard for Occupational Health and Safety Management Systems.
The OGP Management System model is a standard for International Oil and Gas
Exploration companies.
The API (American Petroleum Institute) Model HSEMS is a voluntary tool for companies
interested in developing an HSEMS or enhancing an existing one and is widely used within
the Petroleum industry.
The standards are consistent with the key elements found in most management system
models.
April 2010 HSEMS Framework 3
PART I Introduction
The HSEMS is organized into four (4) phases with twenty two (22) distinct elements.
Phase 1: Leadership & Accountability
1. Management Leadership and Accountability
2. Employee Leadership
Phase 2: Policy and Planning
3. HSE Policy
4. Management of Risks
5. Compliance and Advocacy
6. Objectives and Targets
7. Financial, Human and Physical Resources
Phase 3: Implementation & Operations
8. Practices and Procedures
9. Competency and Training
10. Emergency Preparedness and Response
11. Personal Protective Equipment
12. Contractor Control Program
13. Environmental Protection
14. Occupational Health
15. Security and Travel
16. Management of Change
17. Reliability of Operations
18. Efficiency of Operations
19. Incident Management
20. Documentation and Records
Phase 4: Assessment & Corrective Action
21. HSEMS Audits
22. Management Review
April 2010 HSEMS Framework 4
PART II HSEMS
HSEMS
The HSEMS is organized around the following 4 phases and 22 elements. The following
pages list the principles and expectations of each element of the HSEMS. The principles and
expectations provide a benchmark against which current practices can be assessed and
modified, as required.
Phase 1: Leadership & Accountability
ELEMENT 1 MANAGEMENT LEADERSHIP & ACCOUNTABILITY
Principle Effective management leadership is vital to the success of an HSE
Program and lays the foundation upon which a solid HSE program is
built. Management must see their role in the HSEMS as a key
responsibility and must be held accountable for the HSE performance
of the company.
Expectations 1.1 Management demonstrates leadership commitment to HSE
performance through words, actions and visible participation in the
HSEMS (i.e. walk the talk).
1.2 Management at all levels should establish a vision and objectives for
their organization and participate in the review process.
1.3 Management reward systems should recognize and take into
consideration HSE leadership behaviors as well as HSE results.
1.4 An internal communication strategy should be implemented to
communicate HSEMS issues and raise awareness of HSE to
employees, contractors and the public.
April 2010 HSEMS Framework 5
ELEMENT 2 EMPLOYEE LEADERSHIP
Principle HSE leadership from all levels of the organization is key to the
success of an HSE Program. All employees must demonstrate HSE
leadership on a daily basis if the organization’s HSE program is to be
successful. Many times it is the non-management employees that are
supervising most the high risk activities in the company.
Expectations 2.1 Employees should understand the HSEMS and their leadership role in
assisting the company to achieve its HSE objectives.
2.2 Employee reward systems should consider HSE leadership behaviors
and results in assessment of performance.
Phase 2: Policy and Planning
ELEMENT 3 HSE POLICY
Principle A clearly defined HSE Policy ensures that the health and safety as
well as the protection of the environment are top priorities.
Expectations 3.1 Health, Safety and Environment policies are clearly documented and
implemented.
3.2 Health, Safety and Environment policies are widely distributed, easily
accessible, communicated and understood by all affected individuals.
3.3 Health, Safety and Environment policies are reviewed periodically to
ensure they are relevant and appropriate to the organization.
April 2010 HSEMS Framework 6
ELEMENT 4 MANAGEMENT OF RISK
Principle A risk management process is necessary to identify HSE risks and
hazards which can then be mitigated.
Expectations 4.1 Procedures exist to identify risks and hazards in all Company
operations.
4.2 Potential adverse impacts associated is each HSE hazard are
evaluated.
4.3 Identified hazards have action plans put in place to mitigate the hazard
and these action plans are documented and tracked.
4.4 Qualified and experienced personnel of the organization are involved
in the risk assessment and management process.
ELEMENT 5 COMPLIANCE & ADVOCACY
Principle There are HSE legislation, regulations and by-laws with which the
Company must comply. These regulations set the minimum
standards on how business will be conducted to ensure the health
and safety of employees and the public, and reduce impacts on the
environment. It is important that employees are aware of regulations
that affect the company and comply with them.
Expectations 5.1 A process exists to identify activity specific HSE regulations, guidelines
industry standards, and corporate policies and incorporate into
relevant programs.
5.2 Employees and contractors are aware of current HSE regulations,
guidelines and corporate polices related to their areas of responsibility.
ELEMENT 6 OBJECTIVES & TARGETS
Principle Each level of the organization will establish objectives and targets for
HSE performance. Annual HSE action plans should be developed to
achieve the stated objectives and targets. The action plans should
include responsibilities and timeframes.
Expectations 6.1 A process exists to develop HSE performance objectives and targets
at each organizational level.
6.2 Progress towards meeting the objectives and targets is monitored,
reported and communicated.
April 2010 HSEMS Framework 7
6.3 A process exists at each organizational level to develop and revise
action plans to meet HSE objectives and targets.
6.4 The HSE objectives, targets and action plans are communicated to all
relevant employees and contractors.
ELEMENT 7 FINANCIAL, HUMAN & PHYSICAL RESOURCES
Principle Management shall ensure that appropriate financial, human and
physical resources are provided to achieve the Company’s HSE
goals, objectives and targets.
Expectations 7.1 Senior management has designated specific management
representative(s) with defined responsibilities and authority for the
development, maintenance and communication of the HSEMS
framework.
7.2 Each business unit will customize the management system to manage
their specific HSE risks.
7.3 An individual at the Corporate and business unit level has been
assigned with the ownership of the HSEMS.
7.4 HSEMS training has been provided for personnel expected to
implement and manage the HSEMS.
7.5 Adequate financial resources have been allocated in each business
unit to implement and maintain the Management System.
Phase 3: Implementation & Operations
ELEMENT 8 PRACTICES & PROCEDURES
Principle HSE practices and procedures are prescriptive “how to’s” of job
tasks. They must be followed to protect the health and safety of
employees, contractors and the public and to protect the
environment.
Expectations 8.1 Practices and procedures are developed (from identified HSE hazards)
and implemented to manage associated risks.
8.2 Industry standards are used in the development of practices.
April 2010 HSEMS Framework 8
8.3 A documented process is in place to regularly review and update all
practices and procedures.
8.4 A process is in place to monitor workplace behaviours and activities to
ensure conformance with practices and procedures.
ELEMENT 9 COMPETENCY & TRAINING
Principle It is important that personnel have the necessary skills and
competencies to carry out their HSE responsibilities in a safe and
effective manner. Managers will ensure all employees have the
appropriate skills and knowledge, and will provide training where
necessary.
Expectations 9.1 A process is in place to identify, evaluate, and review HSE training
needs for each level and function within the organization.
9.2 All employees are trained, as applicable, to ensure work is performed
in a safe and environmentally responsible manner.
9.3 HSE trainers shall be appropriately qualified.
9.4 Training records are maintained.
9.5 HSE training and education programs are evaluated for effectiveness.
April 2010 HSEMS Framework 9
ELEMENT 10 EMERGENCY PREPAREDNESS & RESPONSE
Principle It is important that all areas of operation have the necessary
emergency response plans, skills and equipment to respond quickly
to any emergency.
Expectations 10.1 An up-to-date Corporate Crisis Management Plan is in place and is
integrated with each Business Unit’s Emergency Response Plan.
10.2 Business Unit Emergency Response Plans are up-to-date and in
place, to deal with known hazards and potential emergency
situations.
10.3 Responsibility has been assigned to identify and list possible
emergencies, identify their effects and impact, and review response
scenarios for each.
10.4 Regular emergency response training exercises, tabletop exercises
and emergency drills are conducted to ensure readiness.
10.5 Equipment and facilities required to respond to emergencies are
maintained and readily available.
10.6 Trained personnel are prepared to fulfil their role in emergency
situations.
10.7 Emergency response plans are accessible, clearly communicated
and understood by all employees and contractors.
10.8 The roles and responsibilities of government, emergency response
agencies and mutual aid partners are understood by key parties and
incorporated into emergency response plans.
April 2010 HSEMS Framework 10
ELEMENT 11 PERSONAL PROTECTIVE EQUIPMENT
Principle Proper selection, use, and care of personal protective equipment
(“PPE”) are necessary to reduce the risk of accidents and personal
injuries.
Expectations 11.1 A process exists to conduct risk assessments for PPE usage.
11.2 PPE guidelines regarding the type and specific applications have m
been established.
11.3 PPE is used in accordance with applicable regulatory requirements,
established industry standards, corporate practices and guidelines,
and manufacturer’s recommendations.
11.4 The consistent use of PPE is duly recognized and positively
reinforced. Issues of non-compliance are dealt with immediately.
ELEMENT 12 CONTRACTOR CONTROL
Principle It is important that controls be in place to ensure that activities
undertaken by contractors, vendors and service providers are carried
out in an efficient, safe, and environmentally responsible manner.
Expectations 12.1 HSE performance is considered in the selection of all contractors,
vendors and service providers.
12.2 All contractors, vendors and service providers are informed of the
Company’s HSE expectations.
12.3 Contractors, vendors and service providers are regularly monitored
to ensure compliance with HSE expectations.
12.4 Contract work is evaluated at the conclusion of projects and
applicable feedback is provided regarding HSE performance.
April 2010 HSEMS Framework 11
ELEMENT 13 ENVIRONMENTAL PROTECTION
Principle A top priority of the Company is the protection of the environment
and complying with established regulations. The management and
minimization of environmental risks and liabilities must be integral to
the management of our operations.
Expectations 13.1 Environmental issues are managed to comply with all applicable
laws, regulations and approvals
13.2 Air and water emissions are managed to ensure regulatory
compliance and good environmental stewardship.
13.3 Vegetation is managed using practices that comply with permits/
licenses and regulations, with appropriate measures being taken to
manage lands surrounding the facilities / pipelines.
13.4 Noise sources have been identified and measures taken to
minimize noise disturbances to the public.
13.5 The generation, storage, transport, treatment and disposal of all
waste, including hazardous waste, is safely and properly managed,
reported and documented.
13.6 Processes exist to manage the risk of groundwater and soil
contamination resulting from operations.
13.7 Contaminated sites are assessed and properly remediated.
13.8 Processes exist to reduce water usage, minimize waste, and
efficiently use energy and natural resources.
13.9 Project planning considers opportunities to minimize environmental
impacts.
April 2010 HSEMS Framework 12
ELEMENT 14 OCCUPATIONAL HEALTH
Principle Occupational health programs ensure that all people working at or
near the Company’s locations are not adversely affected by exposure
to hazardous physical or chemical agents. Occupational health
programs encourage and promote the consistent identification,
evaluation, and control of potential occupational health hazards,
before injuries or losses occur.
Expectations 14.1 Potential occupational health exposures have been identified and
evaluated.
14.2 An established monitoring program measures and identifies
potential health exposures.
14.3 Health hazard controls are developed, maintained and assessed for
effectiveness.
14.4 Employees using, handling, storing or exposed to hazardous
material in the workplace are trained in hazard prevention and
notification procedures.
14.5 Potential exposure to harmful substances is always considered
during pre-job planning and procedure development.
ELEMENT 15 SECURITY AND TRAVEL
Principle It is important to review and identify the HSE risks associated with
new projects, asset purchases and divestitures. During the planning
stage of new projects or business developments it is important to
provide HSE controls that will reduce the risk of injury, illness,
environmental damage and corporate liability.
Expectations 15.1 A process is in place to ensure security of personnel, contractors
and assets for all company projects.
15.2 A process is in place for updating security risk levels and provides
necessary controls.
15.3 A process is in place to ensure safety of personnel while traveling
and the tracking of such personnel.
April 2010 HSEMS Framework 13
ELEMENT 16 MANAGEMENT OF CHANGE
Principle Any change that has the potential to introduce HSE risks to people,
property and the environment (including changes to the organization,
operation and personnel) should be managed prior to and during
implementation.
Expectations 16.1 A system is in place to assess, approve, and manage all changes
(such as technology, organization, personnel or project activity) to
ensure that potential HSE risks introduced with such changes are
minimized.
16.2 Affected personnel understand the impact of changes being made
and have appropriate skills and knowledge to manage the
associated hazards.
ELEMENT 17 RELIABILITY OF OPERATIONS
Principle Reliability of equipment, processes, procedures and people are
critical to preventing incidents and improving HSE performance.
Expectations 17.1 A process is in place to identify critical structures, equipment and
work processes and to assess possible failure modes and
consequences.
17.2 A process is in place to establish and use a standard set of
equipment operation and surveillance duties and readings for all
critical structures, equipment and work processes.
17.3 A process is in place to plan, schedule and complete necessary
maintenance for all structures, equipment and protective devices.
ELEMENT 18 EFFICIENCY OF OPERATIONS
Principle Environmental stewardship starts with maximizing the efficiency of
all operations and conserving natural resources.
Expectations 18.1 A process is in place to analyze operational processes and improve
the efficient use of people time and assets.
18.2 A process is in place to track and improve energy efficiency of all
operations.
18.3 A process is in place to measure and reduce emissions.
April 2010 HSEMS Framework 14
18.4 Each facility should have a process in place to conserve natural
resources by reducing raw materials and recycling materials when
possible.
ELEMENT 19 INCIDENT MANAGEMENT
Principle All incidents and near misses shall be reported, investigated, and
recorded. Serious incidents shall include root cause analysis to
identify areas for improvement and prevent recurrence.
Expectations 19.1 A documented procedure exists to ensure that all types of incidents
and near misses are reported, investigated and recorded.
19.2 Employees report all incidents and near misses.
19.3 A qualified person(s), trained in incident investigation root cause
analysis, thoroughly investigates all serious incidents and serious
near misses
19.4 Corrective actions are developed and responsibilities assigned to
address incident investigation findings.
19.5 Incident, accident and near miss reports are reviewed at least
annually to determine trends.
19.6 Lessons learned from incidents and near misses are shared
throughout the Company to facilitate improvement in performance.
19.7 Management participates in the incident management process.
ELEMENT 20 DOCUMENTATION & RECORDS
Principle Business units must ensure that all documents and records required
by regulations and corporate requirements are maintained, organized
and accessible.
Expectation 20.1 All working documents related to the HSEMS are readily accessible
to personnel who may require them.
20.2 Record retention guidelines are in place and adhered to.
20.3 Records are maintained and properly managed.
April 2010 HSEMS Framework 15
Phase 4: Assessment & Corrective
ELEMENT 21 HSEMS AUDIT
Principle Compliance with regulatory requirements and the Company’s HSEMS
must be periodically measured and audited as part of the continuous
improvement process.
Expectations 21.1 HSEMS audits are conducted on Business Units to measure the
effectiveness of the implemented HSEMS.
21.2 A documented protocol exists that provides guidance to the
auditors.
21.3 The audit team possesses the appropriate skills to perform the audit
effectively.
21.4 A system is in place to develop and implement efficiently all
recommendations for improvement.
21.5 Recommendations for improvements established from the HSEMS
audits are tracked to ensure they are implemented efficiently.
April 2010 HSEMS Framework 16
ELEMENT 22 MANAGEMENT REVIEW
Principle Ensuring the suitability and effectiveness of the HSEMS requires that
the Company’s management conducts a review of the management
system at appropriate intervals to identify areas for improvement.
Expectations 22.1 Management personnel at each level of the organization annually
review the HSEMS to ensure it is effectively meeting objectives and
managing risks.
22.2 Outcomes from the review of the HSEMS include documented
recommendations relating to elements, principles, expectations,
processes and programs in need of improvement.
22.3 Recommendations from the review are implemented to ensure a
continual improvement process.
22.4 There is a process in place for management to receive and respond
to concerns related to HSE issues anonymously from employees as
well as the public.
April 2010 HSEMS Framework 17
