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Environmental, Health & Safety Policy Manual

2011 EH&S Policy Manual


Environmental, Health, & Safety Policy Manual

This Manual Includes:


2008 EH&S Safety Policy Manual w/ updates
2011 Emergency Response Plan
2011 Hazard Communication (HAZCOM)/ MSDS Program
2011 Spill Prevention, Control and Countermeasure Plan (SPCC)

TOPPS WELL SERVICE


Elaine Topaha-Silas (Owner)
East Hwy 262
PO Box 467
Montezuma Creek, Utah
84534

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Acknowledgements and Disclaimer
This manual was developed and edited by Darin Begay for TOPPS Well Service Inc (TWS). Principal
Editors, authors, and support staff within TWS included: Elaine Topaha-Silas (Owner & President), and
Valdis Joe (Rig 3098 Operator). This manual shall supersede all previous versions of policies and procedure
provided by TWS.
A three-member peer review team provided technical review and advice during the preparation of the
manual. Much of the material presented in the manual was adapted from various publications developed by
Federal, State and Navajo Nation agencies for construction, operations, and maintenance in the Oil and Gas
Industry plus related fields. In many cases, pertinent text and illustrations were directly utilized within the
manual with permission. The photographs were primarily obtained from public sources. The following is a
list of agencies whose publications were extensively used in the preparation of this handbook:
Navajo Nation Environmental Protection Agency
Resolute Natural Resources
Navajo Nation Oils and Gas
Utah Petroleum Association's (UPA)
San Juan College: School of Energy
Texas Engineering Extension Service (TEEX)
SafeLand USA Program
Occupational Safety and Hazard Association (OSHA)
ABC Fire and Safety, Cortez Co
Use of trade names, brand names, or drawings designating specific products is for reference purposes only
and does not constitute an endorsement of products or services by TWS, review team members, the Navajo
Nation, or any of the cooperative agencies/organizations. Information describing possible solutions to
problems and concerns, repairs, and emergency actions are intended for guidance only. The employee should
seek qualified professional help for a coherent understating of all OSHA regulated policies. Site-specific
plans, emergency actions, and repair procedures should be developed on a case-by-case basis; TWS, review
team members, the Navajo Nation, any of the cooperative agencies/organizations and references cited assume
no responsibility for the manner in which the contents of the Manual are used or interpreted, or the results
derived there from. Current OSHA regulations pertaining to the Oil and Gas Industry should take
precedence to information contained within this Manual.
The Emergency Response Plan is not intended to replace sound judgment. It is to be used as a guideline only
in responding to a well control emergency. Oil Drilling Related Emergencies require common sense and
professional judgment on the part of all personnel involved in the intervention. TOPPS Well Service cannot
and does not guarantee, warrant or represent the accuracy of or accept any responsibility for the use of any
information contained herein. No operation should be undertaken if it involves risk to personnel.
Modification to the emergency response plan and its actions may be necessary depending on the
circumstances of the event.
Accurate information is essential to an effective blowout intervention project. Recommendations are included
for the required information to be gathered both from the well site and from office records.

EARLY INTERVENTION IS CRITICAL!


Call at the earliest detection of ANY incident regarding well control.

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Table of Contents

1.0 EH&S POLICY INTRODUCTION................................................................................................. 17


1.1 SCOPE .................................................................................................................................. 17
1.2 COMPANY POLICY ............................................................................................................... 17
2.0 EMPLOYMENT REQUIREMENTS .............................................................................................. 19
2.1 RIG OPERATOR: ................................................................................................................... 19
2.2 DERRICK, FLOORHAND 1&2, PUSHER, SUPERVISOR: .......................................................... 19
3.0 GENERAL SAFETY RULES ......................................................................................................... 20
3.1 ACCIDENT PREVENTION ...................................................................................................... 20
3.2 CLOTHING............................................................................................................................ 20
3.3 ELECTRICAL.......................................................................................................................... 20
3.4 EYE PROTECTION ................................................................................................................. 20
3.5 FIRE CONTROL ..................................................................................................................... 20
3.6 DRUGS AND ALCOHOL ........................................................................................................ 20
3.7 DRUG TESTING PROGRAM .................................................................................................. 21
3.8 GASOLINE ............................................................................................................................ 21
3.9 GUARDS ............................................................................................................................... 21
3.10 HAZARDOUS CHEMICALS .................................................................................................. 22
3.11 HEARING CONSERVATION ................................................................................................ 22
3.12 HORSEPLAY ....................................................................................................................... 22
3.13 HOUSEKEEPING ................................................................................................................. 22
3.14 LADDER SAFETY (FALL PROTECTION) ................................................................................ 22
3.15 MATERIAL STORAGE ......................................................................................................... 22
3.16 OPERATION CHANGES ...................................................................................................... 23
3.17 PARTING FLANGES ............................................................................................................ 23
3.18 PROPER LIGHTING ............................................................................................................. 23
3.19 PROTECTIVE FOOTWEAR .................................................................................................. 23
3.20 REPORTING PERSONAL INJURIES ...................................................................................... 23
3.21 SAFE WORK OPERATIONS ................................................................................................. 23
3.22 SAFETY HATS ..................................................................................................................... 23
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3.23 SEAT BELTS ........................................................................................................................ 23
3.24 SMOKING .......................................................................................................................... 23
3.25 TOOLS ................................................................................................................................ 23
4.0 SAFETY MEETING AND TRAINING ........................................................................................... 24
4.1 GENERAL ............................................................................................................................. 24
4.2 RESPONSIBILITIES ................................................................................................................ 24
4.3 TRAINING ............................................................................................................................ 24
5.0 TAILGATE SAFETY MEETINGS .................................................................................................. 26
5.1 GENERAL ............................................................................................................................. 26
5.2 RESPONSIBILITIES ................................................................................................................ 26
6.0 JOB SITE SAFETY CHECKLIST .................................................................................................... 27
6.1 GENERAL ............................................................................................................................. 27
6.2 RESPONSIBILITY ................................................................................................................... 27
7.0 EMERGENCY PREPAREDNESS.................................................................................................. 28
8.0 ENVIRONMENTAL, HEALTH & SAFETY POLICY ........................................................................ 29
8.1 OPERATIONS GOALS ........................................................................................................... 29
8.2 COMMUNICATIONS ............................................................................................................ 29
8.3 EVALUATION ....................................................................................................................... 29
9.0 PERSONAL PROTECTIVE EQUIPMENT (PPE) ............................................................................ 30
9.1 POLICY ................................................................................................................................. 30
9.2 RESPONSIBILITIES ................................................................................................................ 30
9.3 PROCEDURES....................................................................................................................... 30
FOOT PROTECTION ............................................................................................................... 30
CLOTHING.............................................................................................................................. 30
HAND PROTECTION ............................................................................................................... 30
HEAD PROTECTION ............................................................................................................... 30
EYE AND FACE PROTECTION ................................................................................................. 30
HEARING PROTECTION ......................................................................................................... 31
FALL PROTECTION ................................................................................................................. 31
BACK SUPPORTS .................................................................................................................... 31
10.0 HAZARD COMMUNICATION.................................................................................................. 32
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10.1 GENERAL INFORMATION .................................................................................................. 32
10.2 CONTAINER LABELING ...................................................................................................... 32
10.3 LABEL SYSTEMS: COLORS, NUMBERS, AND SYMBOLS...................................................... 33
10.4 MATERIAL SAFETY DATA SHEETS (MSDS) ......................................................................... 33
10.5 CHEMICAL IDENTITY.......................................................................................................... 34
10.6 PHYSICAL HAZARDS ........................................................................................................... 34
10.7 PHYSICAL AND CHEMICAL CHARACTERISTICS .................................................................. 35
10.8 REACTIVITY ........................................................................................................................ 35
10.9 HEALTH HAZARDS ............................................................................................................. 36
10.10 AVOID CHEMICAL EXPOSURES ........................................................................................ 36
10.11 PRECAUTIONS AND CONTROLS ...................................................................................... 36
10.12 PRACTICE CHEMICAL SAFETY .......................................................................................... 36
10.13 USE OF PERSONAL PROTECTIVE EQUIPMENT ................................................................ 37
10.14 BE PREPARED FOR EMERGENCIES .................................................................................. 37
10.15 EMPLOYEE INFORMATION AND TRAINING .................................................................... 37
10.16 NOTES ON TRAINING: ..................................................................................................... 38
10.17 HAZARDOUS NON-ROUTINE TASKS ................................................................................ 38
10.18 INFORMING CONTRACTORS ........................................................................................... 38
10.19 TRAINING RECORD FOR HAZARD COMMUNICATIONS ................................................... 40
10.20 HAZARDOUS CHEMICAL LIST .......................................................................................... 41
10.21 MSDS REQUEST FORM .................................................................................................... 42
11.0 ACCIDENT/ INCIDENT REPORTING POLICY ........................................................................... 43
11.1 PURPOSE ........................................................................................................................... 43
11.2 RESPONSIBILITIES .............................................................................................................. 43
11.3 PROCEDURES..................................................................................................................... 43
11.4 TOPPS WELL SERVICE INC. INJURY AND ILLNESS .............................................................. 44
11.5 CONTRACTOR EMPLOYEE WORKSITE OCCUPATIONAL INJURY AND ILLNESS .................. 44
11.6 TOPPS WELL SERVICE INC. VEHICLE ACCIDENTS............................................................... 45
12.0 DISCIPLINARY ACTION ........................................................................................................... 46
12.1 VERBAL WARNING ............................................................................................................ 46
12.2 WRITTEN WARNING .......................................................................................................... 46
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12.3 WRITTEN NOTICE OF SUSPENSION ................................................................................... 46
12.4 TERMINATION ................................................................................................................... 46
13.0 FIRST AID AND CPR ............................................................................................................... 47
13.1 PROCEDURES..................................................................................................................... 47
13.2 EMERGENCY TREATMENT ................................................................................................. 47
HEAVY BLEEDING .................................................................................................................. 47
BREATHING STOPPED ........................................................................................................... 47
CARDIOPULMONARY RESUSCITATION.................................................................................. 48
SHOCK ................................................................................................................................... 48
BURNS ................................................................................................................................... 49
INSECT BITES ......................................................................................................................... 49
SNAKE BITES .......................................................................................................................... 49
HEAT EXHAUSTION ............................................................................................................... 50
HEAT STROKE ........................................................................................................................ 50
FROSTBIT ............................................................................................................................... 50
PLANT POISONING ................................................................................................................ 51
SWALLOWED POISONS ......................................................................................................... 51
INHALATION OF H2S, POISON GAS AND SMOKE .................................................................. 51
BLOOD BORNE PATHOGENS (INFECTIOUS DISEASE) ............................................................ 51
14.0 HYDROGEN SULFIDE (H2S) SAFETY ....................................................................................... 52
14.1 INTRODUCTION ................................................................................................................. 52
14.2 SCOPE ................................................................................................................................ 52
14.3 RESPONSIBILITIES .............................................................................................................. 52
14.4 PHYSICAL CHARACTERISTICS ............................................................................................. 52
14.5 TOXICITY ............................................................................................................................ 52
14.6 GENERAL PROCEDURES .................................................................................................... 52
14.7 FIELD AND PLANT OPERATIONS ........................................................................................ 53
15.0 RESPIRATORY PROTECTION .................................................................................................. 54
INTRODUCTION ..................................................................................................................... 54
SCOPE .................................................................................................................................... 54
RESPONSIBILITIES .................................................................................................................. 54
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15.1 RESPIRATORY USE ............................................................................................................. 54
15.2 SELECTION AND USE ......................................................................................................... 55
CANISTER TYPE GAS- ............................................................................................................. 55
CARTRIDGE TYPE RESPIRATOR .............................................................................................. 55
WORK MASKS ........................................................................................................................ 55
DUST RESPIRATOR................................................................................................................. 55
15.3 LIMITATIONS AND CAUTIONS FOR AIR SUPPLIED BREATHING EQUIPMENT ................... 55
15.4 INSPECTION ....................................................................................................................... 56
16.0 DRIVING SAFETY .................................................................................................................... 57
16.1 COMPANY RESPONSIBILITIES ............................................................................................ 57
16.2 EMPLOYEE RESPONSIBILITIES ........................................................................................... 57
17.0 FIRE PREVENTION ................................................................................................................. 58
17.1 PROCEDURES..................................................................................................................... 58
18.0 FIRE PROTECTION.................................................................................................................. 60
18.1 INTRODUCTION ................................................................................................................. 60
18.2 FUNDAMENTALS OF FIRE EXTINGUISHMENT ................................................................... 60
18.3 CLASSIFICATION OF FIRES ................................................................................................. 60
19.0 TRENCHING AND EXCAVATION SAFETY ................................................................................ 61
INTRODUCTION ..................................................................................................................... 61
SCOPE .................................................................................................................................... 61
RESPONSIBILITIES .................................................................................................................. 61
19.1 GENERAL PROVISIONS ...................................................................................................... 61
19.2. TRENCHING AND EXCAVATION SAFETY ........................................................................... 61
GENERAL SURFACE AND UNDERGROUND CONSIDERATIONS .............................................. 61
ACCESS AND EGRESS ............................................................................................................. 62
19.3 PERSONNEL PROTECTION FROM SURFACE HAZARDS ...................................................... 62
19.4 HAZARDOUS ATMOSPHERE .............................................................................................. 62
19.5 WATER ACCUMULATION .................................................................................................. 63
19.6 STABILITY OF ADJACENT STRUCTURES ............................................................................. 63
19.7 LOOSE ROCK SOIL PROTECTION ........................................................................................ 63
19.8 INSPECTIONS ..................................................................................................................... 63
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19.9 FALL PROTECTION ............................................................................................................. 64
19.10 CLASSIFICATION OF SOIL ................................................................................................. 64
DEFINITIONS- ........................................................................................................................ 64
SOIL CLASSIFICATION SYSTEM .............................................................................................. 64
20.0 ELECTRIC SAFETY ................................................................................................................... 65
POLICY ................................................................................................................................... 65
PROCEDURES......................................................................................................................... 65
21.0 LOCKOUT/ TAGOUT POLICY .................................................................................................. 66
POLICY ................................................................................................................................... 66
SCOPE .................................................................................................................................... 66
22.0 CONFINED SPACE ENTRY PROGRAM .................................................................................... 69
22.1 PROGRAM ......................................................................................................................... 69
22.2 PURPOSE ........................................................................................................................... 69
22.3 REQUIREMENT .................................................................................................................. 70
22.4 OBJECTIVES ....................................................................................................................... 70
22.6 SAFETY REPRESENTATIVE / OFFICIAL: ............................................................................... 70
22.7 AREA SUPERVISORS: ......................................................................................................... 71
22.8 ENTRY SUPERVISORS:........................................................................................................ 71
22.9 TRAINED AND AUTHORIZED EMPLOYEE AND ENTRANTS ................................................ 71
22.10 TRAINING FREQUENCY.................................................................................................... 71
22.11 TRAINING CONTENT:....................................................................................................... 71
22.12 INVENTORY ..................................................................................................................... 72
22.13 RECLASSIFICATION OF PERMIT REQUIRED CONFINED SPACES ...................................... 72
22.14 PERMIT REQUIRED SPACES ............................................................................................. 72
22.15 PERMIT REQUIREMENTS ................................................................................................. 73
22.16 POSTING OF CONFINED SPACES ..................................................................................... 73
22.17 OTHER NECESSARY PRECAUTIONS.................................................................................. 73
22.18 ENTRY PROCEDURES: ...................................................................................................... 73
22.19 REVIEW OF ENTRY OPERATIONS AND PROCEDURES ..................................................... 74
22.20 CONFINED SPACE EQUIPMENT ....................................................................................... 74
22.21 EVALUATION OF PERMIT SPACE CONDITIONS ............................................................... 74
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22.22 CONFINED SPACE HAZARD IDENTIFICATION AND EVALUATION .................................... 75
22.23 NUMBER OF ATTENDANTS REQUIRED............................................................................ 75
22.24 MULTIPLE EMPLOYERS/CONTRACTORS ......................................................................... 75
22.25 RESCUE PLAN: ................................................................................................................. 76
22.26 RESCUE EQUIPMENT: ...................................................................................................... 76
22.27 RESCUE PRACTICE ........................................................................................................... 76
22.28 RESCUE PLAN AND ENTRY PERMIT ................................................................................. 76
22.29 OFFSITE RESCUE SERVICES .............................................................................................. 76
22.30 CONFINED SPACE EVALUATION FORM ............................................................................... 77
22.31 CONFINED SPACE ENTRY PERMIT ....................................................................................... 79
CONFINED SPACE ENTRY PERMIT ................................................................................................. 79
23.0 WELL SERVICING SAFETY....................................................................................................... 80
23.1 BASIC SAFETY EQUIPMENT ............................................................................................... 80
UNIT FIRST AID KIT ................................................................................................................ 80
EYEWASH .............................................................................................................................. 80
BURN BLANKET ..................................................................................................................... 80
GERONIMO............................................................................................................................ 80
FULL BODY HARNESS............................................................................................................. 80
LANYARDS ............................................................................................................................. 80
PERSONAL PROTECTIVE EQUIPMENT ................................................................................... 81
FIRE EXTINGUISHERS ............................................................................................................. 81
STATIC LINE ........................................................................................................................... 81
23.2 SWABBING OTHER WIRE LINE OPERATIONS .................................................................... 81
23.3 BLOW OUT PREVENTERS................................................................................................... 82
23.4 PUMPING UNITS ............................................................................................................... 82
23.5 PUMPS............................................................................................................................... 82
23.6 TANKS ................................................................................................................................ 83
23.7 RIG INSPECTION PROCEDURES ......................................................................................... 83
23.8 DERRICKS ........................................................................................................................... 83
23.9 DRILLINGS/ SANDLINES/ WINCHLINES.............................................................................. 85
23.10 HOISTING BLOCK ............................................................................................................. 85
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23.11 WEIGHT INDICATORS ...................................................................................................... 85
23.12 DRAWWORKS .................................................................................................................. 85
23.13 TUBING/ ROD TONGS...................................................................................................... 86
23.14 POWER SWIVELS ............................................................................................................. 86
23.15 LADDERS, STAIRWAYS, RUNWAYS, FLOORS AND PLATFORMS ...................................... 86
23.16 OPERATORS STATION..................................................................................................... 87
23.17 TUBING BOARD/ ROD BASKET ........................................................................................ 87
24.0 HOT WORK PERMIT PROCEDURES ........................................................................................ 88
INTRODUCTION ..................................................................................................................... 88
DEFINITIONS.......................................................................................................................... 88
GENERAL REQUIREMENTS .................................................................................................... 88
24.1 HOT WORK OUTSIDE A DESIGNATED HOT WORK AREA................................................... 88
24.2 FIRE PREVENTION PRECAUTIONS ..................................................................................... 89
24.3 INSTRUCTIONS FOR COMPLETING HOT WORK PERMIT ................................................... 89
25.0 DRIVERS AUTHORIZATION ................................................................................................... 90
25.1 PURPOSE ........................................................................................................................... 90
25.2 PROCEDURES..................................................................................................................... 90
26.0 BLOODBORNE PATHOGEN EXPOSURE CONTROL PLAN ....................................................... 91
PURPOSE AND SCOPE ........................................................................................................... 91
26.1 DELEGATION OF RESPONSIBILITY ..................................................................................... 91
26.2 WRITTEN EXPOSURE PLAN................................................................................................ 91
26.3 EXPOSURE DETERMINATION PLAN ................................................................................... 91
26.4 METHOD OF COMPLIANCE ............................................................................................... 92
26.5 ENGINEERING & WORK PRACTICE CONTROLS.................................................................. 92
26.6 PERSONAL PROTECTIVE EQUIPMENT ............................................................................... 92
26.7 HOUSEKEEPING ................................................................................................................. 92
26.8 WASTE HANDLING ............................................................................................................ 92
26.9 HEPATITIS B VACCINATION ............................................................................................... 93
26.10 POST-EXPOSURE EVALUATION & FOLLOW-UP ............................................................... 93
26.11 FIRST AID CARE INCIDENT REPORTS ............................................................................... 94
26.12 MEDICAL RECORDS ......................................................................................................... 94
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26.13 LABELS AND SIGNS .......................................................................................................... 94
26.14 INFORMATION AND TRAINING ....................................................................................... 94
26.15 AVAILABILITY OF RECORDS ............................................................................................. 95
26.16 BLOODBORNE PATHOGEN EXPOSURE CONTROL PLAN ................................................. 96
27.0 HAZARDOUS WASTE AND OPERATIONS AND EMERGENCY RESPONSE ( HAZWOPER) ........ 97
27.1 INTRODUCTION ................................................................................................................. 97
27.2 SCOPE ................................................................................................................................ 97
27.3 FIRST RESPONDER AWARENESS LEVEL ............................................................................. 97
27.4 FIRST RESPONDER OPERATIONS LEVEL ............................................................................ 97
27.5 HAZARDOUS MATERIAL TECHNICIAN ............................................................................... 97
27.6 HAZARDOUS MATERIAL SPECIALIST ................................................................................. 97
27.7 ON SCENE INCIDENT COMMANDER ................................................................................. 97
27.8 METHODS TO IDENTIFY HAZARDOUS MATERIALS ........................................................... 97
27.9 POTENTIAL HAZARDOUS MATERIALS IN OPERATIONS INCLUDE: .................................... 98
27.10 EXPOSURE TO HAZARDOUS MATERIALS......................................................................... 98
ROUTES OF ENTRY ................................................................................................................ 98
TYPES OF EXPOSURES ........................................................................................................... 98
TYPES OF HEALTH EFFECTS ................................................................................................... 98
27.11 EMPLOYEE RESPONSE ACTIONS...................................................................................... 98
FIRST RESPONDER ACTIONS INCLUDE .................................................................................. 98
PERSONAL SAFETY................................................................................................................. 99
28.0 EMERGENCY RESPONSE PLAN (ERP) ................................................................................... 100
28.1 SHUTTING-IN THE WELL .................................................................................................. 100
WELL SHUT-IN PROCEDURES ............................................................................................... 100
WHILE DRILLING/ON BOTTOM ........................................................................................... 100
WHILE TRIPPING.................................................................................................................. 101
RESPONSE LEVELS ............................................................................................................... 101
28.2 LEVEL 1 ................................................................................................................................ 102
LEVEL 1 EVENT DEFINED ..................................................................................................... 102
LEVEL 1 RESPONSE .............................................................................................................. 102
LEVEL 1 CONSIDERATIONS .................................................................................................. 102
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28.3 LEVEL 2 ................................................................................................................................ 103
LEVEL 2 EVENT DEFINED ..................................................................................................... 103
LEVEL 2 RESPONSE .............................................................................................................. 103
LEVEL 2 CONSIDERATIONS .................................................................................................. 103
28.4 LEVEL 3 ................................................................................................................................ 104
LEVEL 3 EVENT DEFINED ..................................................................................................... 104
LEVEL 3 RESPONSE .............................................................................................................. 105
28.5 IMMEDIATE RESPONSE ACTIONS FIELD ........................................................................... 106
28.6 INITIAL EVALUATION AND INFORMATION GATHERING ..................................................... 107
28.7 IMMEDIATE RESPONSE ACTIONS OFFICE ........................................................................ 107
28.8 INCIDENT COMMAND STRUCTURE (ICS) ORGANIZATION .................................................. 108
28.9 INTERIM ACTION PLANS...................................................................................................... 108
28.10 EVACUATION OF AREA POPULATION ............................................................................... 109
28.11 VOLUNTARY IGNITION ...................................................................................................... 109
28.12 RESPONSE METHODOLOGY OF WILD WELL CONTROL ..................................................... 110
28.13 TYPICAL EQUIPMENT REQUIREMENTS ............................................................................. 111
28.14 TYPICAL SUPPORT SERVICE REQUIREMENTS .................................................................... 111
28.15 SITE SAFETY PLAN ............................................................................................................. 112
28.16 HAZARD ASSESSMENT ...................................................................................................... 112
28.17 H2S OPERATIONS .............................................................................................................. 113
28.18 COMMUNICATION/PR PLAN ............................................................................................. 113
28.19 RELIEF WELL CONSIDERATIONS ........................................................................................ 113
28.20 EMERGENCY CONTACT INFORMATION ............................................................................ 115
29.0 SPILL PREVENTION, CONTROL AND COUNTERMEASURES PLAN (SPCC) ............................ 116
29.1 EMERGENCY CONTACT INFORMATION .......................................................................... 117
29.2 SPILL PREVENTION .......................................................................................................... 118
HAZARDOUS SUBSTANCE MANAGEMENT .......................................................................... 118
29.3 EMPLOYEE TRAINING ...................................................................................................... 119
29.4 HAZARDOUS SUBSTANCE INVENTORY............................................................................ 119
29.5 SPILL RESPONSE EQUIPMENT ......................................................................................... 119
29.6 SPILL RESPONSE, FIRST AID EQUIPMENT AND FIRE ALARM LOCATION(S): .................... 120
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29.7 EMERGENCY RESPONSE PLAN ........................................................................................ 120
29.8 RESPONSE ACTIONS IN THE EVENT OF A SPILL OR RELEASE .......................................... 120
29.9 EVACUATION PROCEDURES ............................................................................................ 121
29.10 SPILL CLEANUP AND DISPOSAL ..................................................................................... 121
29.11 REPORTING A RELEASE ................................................................................................. 121
29.12 HAZARDOUS SUBSTANCE INVENTORY.......................................................................... 123
29.13 JOB LOCATION SET-UP (TYPICAL).................................................................................. 124
SPILL REPORT FORM ................................................................................................................... 125
30.0 FLAME RESISTANT CLOTHING PROGRAM (FRC) ................................................................. 126
30.1 RESPONSIBILITIES ............................................................................................................ 126
30.2 PROCEDURE .................................................................................................................... 127
30.3 SYNTHETICS ..................................................................................................................... 127
30.4 BODY HARNESSES AND TRAFFIC VESTS .......................................................................... 127
30.5 PROVISION OF FR CLOTHING .......................................................................................... 128
30.6 FREQUENT EXPOSURES ................................................................................................... 128
30.7 REPLACEMENT OF FR CLOTHING .................................................................................... 128
30.8 CLOTHING ALLOWANCES ................................................................................................ 129
30.9 PERSONAL FR CLOTHING ................................................................................................ 129
31.0 GENERAL AND EMERGENCY RESCUE .................................................................................. 130
31.1 PURPOSE ......................................................................................................................... 130
31.2 PSYCHOLOGY................................................................................................................... 131
31.3 BEHAVIOR ....................................................................................................................... 131
31.4 RESCUE PLAN .................................................................................................................. 132
31.5 THE APPRECIATION PROCESS ......................................................................................... 132
31.6 RESCUE BY PHASES ......................................................................................................... 133
PHASE 1RECONNAISSANCE AND SURVEY ....................................................................... 134
PHASE 2ELIMINATION OF UTILITIES (RISK ASSESSMENT AND CONTROLS) .................... 134
PHASE 3PRIMARY SURFACE SEARCH AND RESCUE ......................................................... 134
PHASE 4EXPLORATION OF ALL VOIDS ............................................................................. 134
PHASE 5ACCESS BY SELECTED DEBRIS REMOVAL ........................................................... 134
PHASE 6TERMINATE BY GENERAL DEBRIS REMOVAL ..................................................... 134
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31.7 LOCATION TECHNIQUES ................................................................................................. 135
LINE AND HAIL SEARCH ....................................................................................................... 135
HEARING A VICTIM.............................................................................................................. 136
CONTACT WITH VICTIM ...................................................................................................... 136
31.8 SAFETY IN TRAINING AND OPERATIONS ......................................................................... 137
31.9 BASIC PRECAUTIONS ....................................................................................................... 137
31.10 PROTECTIVE CLOTHING AND SAFETY ........................................................................... 138
31.11 RESCUE/ SAFETY HARNESSES ........................................................................................ 138
31.12 RESCUE TECHNIQUES USING NO EQUIPMENT ............................................................. 138
31.13 RESCUE HANDLING TECHNIQUES ................................................................................. 138
SINGLE-RESCUER HUMAN CRUTCH .................................................................................... 139
PICK-A-BACK ........................................................................................................................ 139
FIREFIGHTERS CRAWL ........................................................................................................ 139
REMOVAL DOWN STAIRS METHOD .................................................................................... 140
HELPING A CASUALTY DOWN A LADDER ............................................................................ 140
TWO-RESCUER HUMAN CRUTCH ........................................................................................ 141
TWO-HANDED SEAT ............................................................................................................ 141
THREE-HANDED SEAT.......................................................................................................... 142
FOUR-HANDED SEAT ........................................................................................................... 142
THE FORE AND AFT METHOD.............................................................................................. 143
IMPROVISED SINGLE-POINT LOWER ................................................................................... 144
31.14 IMPROVISED .............................................................................................................. 144
32.0 EMPLOYEE SAFETY ORIENTATION ...................................................................................... 146
POLICY ................................................................................................................................. 146
PROCEDURES....................................................................................................................... 146
32.1 EXAMINATION ................................................................................................................. 146
A. PRODUCTION WITH SAFETY ........................................................................................... 146
B. THE ATTITUDE OF A SAFE WORKER ................................................................................ 146
C. TOPPS WELL SERVICE INC BELIEVES................................................................................ 147
D. DISCIPLINARY ACTION .................................................................................................... 147
E. PERSONAL PROTECTIVE EQUIPMENT ............................................................................. 147
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F. HARD HATS ...................................................................................................................... 147
G. EYE PROTECTION ............................................................................................................ 147
H. EAR PROTECTION (EAR MUFFS, PLUGS, ETC.) ................................................................ 147
I. SAFETY MEETINGS ............................................................................................................ 147
J. TAILGATE SAFETY MEETINGS ........................................................................................... 148
K. ACCIDENT AND INJURY CAUSES ...................................................................................... 148
L. REPORTING INJURY, ACCIDENTS AND NEAR MISSES ...................................................... 148
M. CONCLUSION ................................................................................................................. 148

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1.0 EH&S POLICY Introduction


1.1 SCOPE
Manual Content
This manual contains safety information and instructions for carrying out basic acceptable
safety practices for TOPPS Well Service Inc.. It should not be assumed, however, that all basic
safety practices for all facilities have been included in this manual. Common sense and
experience must be applied when considering safety any specific work assignment.

1.2 COMPANY POLICY


The Operations Department recognizes its obligations to provide employees with reasonably
safe healthful workplace. TOPPS Well Service Inc. will provide the human, physical, and financial
resources necessary to meet this objective. We expect employees at all levels of TOPPS Well
Service Inc. to use these resources to make our operations safe and healthful.
MANAGEMENT RESPONSIBILITY:
1. Promote safety on and off the job.
2. Implement the nine required minimum safety element required.
3. Implement fire and safety training programs.
4. Apply all Contracting Companys Safety Policy and Procedures to work days.
5. Endeavor to control occupational hazards by providing reasonably safe work environment.
6. Requires safety and tailgate meetings.

SUPERVISORY RESPONSIBILITIES:
1. The administration of TOPPS Well Service Inc.. The safety department will be responsible for
upholding a reasonable level of safety performance.
2. Institute work practices, which reflect safe and efficient methods for accomplishing required
tasks.
3. Educate and train our employees about job safety.
4. Endeavor to hold a Monthly Safety Meeting pertaining to job related activities.
5. Take minutes at routine Safety Meetings and any other meetings or training -sessions, which are
directly related to the job.
6. Keep all documents as OSHA policy requires.

EMPLOYEES RESPONSIBILITIES:
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1. Be expected to perform their jobs in a safe manner as prescribed.
2. Be expected to conduct them in a way that enhances their personal safety as well as the safety
of their fellow workers.
3. Report workplace hazards and make suggestions for hazard control.
4. Be expected to cooperate and contribute toward the overall success of the Safety Program.
5. Report accidents/ incidents, near misses & spills to Supervisor and Company Representative as
soon as in which it occurred.
6. Attend Safety Meetings/ Trainings unless specifically excused by his/ her Supervisor.
7. Contact his/ her Supervisor with any questions or concerns regarding Safety.
8. Provide positive feedback from company policy for possible changes.

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2.0 EMPLOYMENT REQUIREMENTS


The following job classifications must meet the listed requirements for employment.
2.1 RIG OPERATOR:
1. Well Control Certification
2. SafeLand Core Compliance Training
3. Hydrogen Sulfide Safety- H2S
4. CPR/ First Aid
5. Respiratory Protection- S.C.B.A. (Self Contained Breathing Apparatus)
6. Personal Protective Equipment- PPE
7. Hazard Communication
8. Hazardous Energy Control- Lockout/ Tagout
9. Confined Space Entry
10. Fire Protection- Fire Extinguishers
11. Hazardous Waste Operations and Emergency Response- HAZWOPER
12. CDL Class B Drivers License w/HAZMAT

2.2 DERRICK, FLOORHAND 1&2, PUSHER, SUPERVISOR:


1. Well Control Awareness Training
2. SafeLand Core Compliance Training
3. Hydrogen Sulfide Safety- H2S
4. CPR/First Aid
5. Respiratory Protection- S.C.B.A. (Self Contained Breathing Apparatus)
6. Personal Protective Equipment- PPE
7. Hazard Communication
8. Hazardous Energy Control- Lockout/ Tagout
9. Confined Space Entry
10. Fire Protection- Fire Extinguishers
11. Hazardous Waste Operations and Emergency Response- HAZWOPER

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3.0 GENERAL SAFETY RULES


3.1 ACCIDENT PREVENTION
Each Supervisor is responsible for prevention for his/ her responsibility to train these
employees in the safest and most efficient way to work. It is further their responsibility of each
employee to correct or repot to their supervisor any unsafe conditions or practice which he/she
may observe.
3.2 CLOTHING
All employees shall be clothed in a manner, which will not impair safety. A shirt and long pants
shall be worn at all times. Ragged/ Loose fitting clothing and jewelry (rings, watches, necklaces,
etc.) can catch on machinery and cause serious injury. Flame Resistant Clothing will be issued
by TWS and shall be worn on job location by employee on site.
3.3 ELECTRICAL
Only qualified and designated employees shall work on electrical lines and equipment.
3.4 EYE PROTECTION
ANSI Z87 approved safety glasses, with side shields or other appropriate eye protection shall be
worn at all times. Additional eye and face protection devices are required to be worn when
grinding, buffing, welding, chipping, sawing, drilling, scrapping, pouring, chemicals, cutting
wires, or when ever flying particles may cause eye injury.
3.5 FIRE CONTROL
It is not the intent of TOPPS Well Service Inc. to train employees as professional fire fighters.
The roll of TOPPS Well Service Inc. in fire fighting is during incipient stage of the fire. And
Incipient Stage Fire is defined as a Fire which is in the initial or beginning stages and which can
be controlled or extinguished by portable extinguishers, or even small hose systems without
the need for protective clothing or breathing apparatuses. Employees shall not fight fires that
are beyond their training and the limitations of the available firefighting equipment. In the
event of an emergency, if there is any doubt about your training of the capability of available
equipment to safely control the fire emergency, call for professional trained fire fighters
immediately, rather than attempt to control the fire.
3.6 DRUGS AND ALCOHOL
Illegal Drugs (DOT Reg... Part 199.3 Marijuana, Cocaine, Opiates, Amphetamines, Phencyclidine
(PCP): Including Alcoholic Beverages and Firearms. The use, possession, transportation,
promotion, or sale of illegal drugs, controlled substances without a valid prescription, and/ or
drug Paraphernalia by anyone while on company premises is absolutely prohibited. TOPPS Well
Service Inc. employees who are found in violation of these prohibitions will not be allowed on
Company Premises and may be referred to law enforcement Agencies for their actions.
The term Company Premises in this clause is used in the broadest sense and includes all land,
property, buildings, structures, installations, boats, planes, cars, trucks and other means of
conveyance owned by or leased by this company and all companies TOPPS Well Service Inc. do
Business.
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Entry into Company Premises constitutes consent to and recognition of the right of TOPPS Well
Service Inc. and companies we are contracted to and authorized Representatives to search the
person, vehicle, and other property of individuals or test this individual while on company
premises. Such searches or testing may be initiated by TWS, Company Representatives and/ or
a Medical Reviews Officer without prior announcement and will be conducted at such times
and locations as deemed appropriate. Employees who refuse to cooperate with the search or
testing will not be allowed on Company Premises.
Definition of Accidents- Incident Reportable under DOT Regulations, Part 191 involving gas
pipeline facilities or liquefied natural gas facility, or an accident reportable under part 1195
involving hazardous liquid pipeline facilities.
Definition of Employee- any person who performs on a pipeline or liquefied natural gas facility
in an operation, maintenance, or emergency response function regulation by DOT Regulation,
Part 1992, 193, or 195 including applicants for employment.
Effective March 2, 1999 TOPPS Well Service Inc. put into effect a Drug Test Policy in accordance
with the Department of Transportation (DOT) Rules and Regulations.
3.7 DRUG TESTING PROGRAM
TOPPS WELL SERVICE INC. SHALL REQUIRE ALL EMPLOYEES TO BE TESTED FOR USE OF
CONTROLLED SUBSTANCE BY:
COMPLIANCE DRUG & ALCOHOL
343 E MAIN ST # 300
CORTEZ, CO 81321-3772
(970) 565-9515
THE PURPOSE IS TO REDUCE ACCIDENTS THAT RESULT FROM USE OF CONTROLLED
SUBSTANCES, THERE BY REDUCING FATALITIES, INJURIES, AND PROBATE DAMAGED. TOPPS
WELL SERVICE INC. WILL NOTIFY EACH APPLICANT OF TEST RESULT IF REQUIRED WITHIN 60
DAYS. A MEDICAL REVIEW OFFICER (MRO) PHYSICIAN (MD/DO) FAMILIAR WITH DRUGS WILL
DO TESTING. THE EMPLOYEE ASSISTANCE PROGRAM WILL PROVIDE A DRUG EDUCATION
PROGRAM FOR EMPLOYEES AND WILL TRAIN SUPERVISORS IN EARLY DETECTION OF DRUG
ABUSE. THIS RULE DOES NOT REQUIRE TOPPS WELL SERVICE INC. TO PROVIDE A
REHABILITATION PROGRAM.
TOPPS Well Service Inc. will take whatever steps it deems necessary to insure that involvement
with drugs on the part of our employees working on Companies Premises or with company
personnel does not create a presence of drug-related problems in the workplace.
3.8 GASOLINE
Gasoline shall not be used as a washing or cleaning fluid, when cleaning solvent is required, use
a safety solvent.
3.9 GUARDS
Guards shall not be removed while equipment is operating and must be in place before start
up.

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3.10 HAZARDOUS CHEMICALS
Personal Protective Equipment as outline in the material Safety Data Sheet (MSDS) or by
supervisor in charge must be worn by employees when handling hazardous Chemicals.
3.11 HEARING CONSERVATION
All personnel working in high- noise level areas are required to wear hearing Protection.
3.12 HORSEPLAY
Horseplay such as wrestling, rock throwing etc. can be dangerous and is prohibited.
3.13 HOUSEKEEPING
Good housekeeping is an aide to safety. All employees shall keep tools, equipment, and areas
clean and orderly. Trash, oil spills, etc. must be cleaned as soon as possible.
3.14 LADDER SAFETY (FALL PROTECTION)
Fall Protection usage is a vital part for any Ladder Usage. Work with, on or around ladders
greatly increases the risk of injury. Ladder safety should begin with the following factors:
1. Proper Footing (Nonskid feet and stable base)
2. Good top support
3. Rungs clear of nay hazardous condition
4. All carried loads securely balanced
5. To prevent slippage of ladder and dropping of materials
6. Have a spotter to ensure ladder does not slip
7. Use fall protection equipment at heights above 6 ft
8. Do not overreach for objects

Approved Full Body Harness and lanyards


with shock absorber shall be worn by
employees working at unprotected level
excess of 6 (six) feet above ground level.
Unprotected levels are defined as these
levels without guard rails, landing, cages,
etc. Full Body Harness and lanyard shall be
carefully inspected before each use and
replaced necessarily.
3.15 MATERIAL STORAGE
Material should be stored in a safe and orderly fashion. Waste material shall be removed at
once and properly disposed.

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3.16 OPERATION CHANGES
Operational Changes (i.e. start or stop compressors, open or close valves, change fluid level in
Vessels) shall be performed under the direction of the Operator or Supervisor in charge, except
in emergencies.
3.17 PARTING FLANGES
The internal pressure on any fitting to be un-flanged or unscrewed from a piping system,
vessels, pumps, Christmas trees, well heads, etc, shall be equalized to atmospheric pressure
before starting such un-flanged or unscrewing operation. Hen ever opening flanges first loosen
studs, wedge the flange open to vent of drain, and then finally remove the studs. Always use
proper eye protection and clothing during any procedure.
3.18 PROPER LIGHTING
Proper lighting is safe lighting. Lenses, covers and reflectors shall be kept clean and in good
condition.
3.19 PROTECTIVE FOOTWEAR
Z89.1 or .2 approved safety footwear is required to be worn by personnel at field location.
3.20 REPORTING PERSONAL INJURIES
All on the job personal injuries and accidents even of minor nature must be reported to the
Supervisor immediately, but no later than the end of a shift in which the injury occurred as
Detailed in Section 5.0 of this manual. An accident injury investigation must be completed
within 24 hours.
3.21 SAFE WORK OPERATIONS
Supervisors shall plan the work, observe whether employees are working safely, and give
appropriate instruction if employees are not working in a safe manner.
3.22 SAFETY HATS
MSA Class B Safety Hats are required to be worn by all personnel and visitors at all times except
when in vehicles or office facilities.
3.23 SEAT BELTS
While driving TOPPS Well Service Inc. automotive equipment seat belts are required to be worn
at all times by drivers and passengers, if the vehicles are so equipped.
3.24 SMOKING
Smoking is prohibited within 100 ft of any oil or gas installation except in posted or designated
areas.
3.25 TOOLS
Only tools in good working conditions and design for the particular job being performed shall
be used.

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4.0 SAFETY MEETING AND TRAINING


4.1 GENERAL
Safety meetings will be held monthly, and Safety Trainings will be held occasionally. Safety
Representative, Safety Professional, and occasional employees will conduct these meetings and
trainings.
4.2 RESPONSIBILITIES
Employees Responsibility:
Attend all Safety Meetings and Trainings; conduct a meeting when asked to.
Supervisors Responsibility:
Attend all Meetings and Trainings, conduct meetings occasionally and insure employees are
implementing safety trainings on the job.
Safety Representatives Responsibility:
Hold Monthly Safety Meetings that will education and train employees regarding job safety,
keep attendance record of each employee, provide trainings to insure that all employees
understand safety rules, and keep documents on all Meeting and Training.
4.3 TRAINING
The safety representative is responsible for the Employee Training Program. He will ensure that
all elements specified below are carried out. Prior to starting work each new employee of
TOPPS Well Service Inc. will attend a health and safety orientation and will receive information
and training on the following:
1
2
3
4
5
6
7
8
9
10

An overview of the requirements contained in the Hazard Communication Program.


Chemicals present in their workplace operations
Location and availability of our written hazard communication program,
Physical and health effects of the hazardous chemicals.
Methods and observation techniques used to determine the presence or release of
hazardous chemicals in the work area.
How to lessen or prevent exposure to these hazardous chemicals through usage of
control/work practices and personal protective equipment.
Steps ACCURATE TILE INSTALLERS, INC. has taken to lessen or prevent exposure to these
chemicals.
Emergency procedures to follow if they are exposed to these chemicals.
How to read labels and review MSDS's to obtain appropriate hazard information.
An overview of the Fall Protection Program and Personal Protective Equipment
Program.

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Prior to a new chemical hazard being introduced into any section of this company, each
employee of that section will be given information as outlined above. The supervisor is
responsible for ensuring that MSDSs on the new chemicals are available.
It is the policy of TOPPS Well Service Inc. that the first consideration in the performance of work
shall be the protection, safety and health of all employees. The company has developed these
programs to ensure that all employees receive adequate information relevant to the possible
hazards and dangers that may be involved with the company's operations and processes.
After attending appropriate training, each employee will sign a form to verify that they received
and understood the training, procedures and policies provided by TOPPS Well Service Inc.

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5.0 TAILGATE SAFETY MEETINGS


5.1 GENERAL
Tailgate Safety Meetings is to be held at the job site before any crew begins work. The meeting
will include a briefing on the job(s) to be performed; safety equipment is to be used, etc.

5.2 RESPONSIBILITIES
Employees Responsibility:
Be familiar with every job you are asked to perform by asking question, no question is too
dumb, and be sure you have the correct tools and equipment required. If you are unsure about
the equipment do not execute job.
Each employee is encouraged to give one tailgate meeting per month or rotate as appropriate.
Supervisors Responsibility:
Brief employees on the job(s) they will be performing. Never assume they know it all. Complete
a tailgate meeting form and return it to Administration. Supervisor will check with contract
safety to assure all safety requirements and monitors are inspected up, per OSHA on shore
operations requirements.
Safety Representatives Responsibility:
Ensure employees are documenting tailgate meetings.

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6.0 JOB SITE SAFETY CHECKLIST


6.1 GENERAL
Job Site Safety Checklist shall be completed daily by each crew before, they begin their work.
Every crew should have a checklist in their vehicle and turned into office at the end of their
work day. Each crew shall inspect the job site for health and safety hazards. Any unsafe
conditions should be corrected before work continues.
6.2 RESPONSIBILITY
Employees Responsibility:
Complete Job Site Safety Checklist daily before starting on a job. Report any unsafe conditions
when possible.
Supervisors Responsibility:
Help employees correct unsafe conditions when possible, and make sure employees are
working on job sites where no health or safety hazards exist.
Safety Representatives Responsibility:
Report unsafe conditions and maintain a copy of the document at the office.

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7.0 EMERGENCY PREPAREDNESS


TOPPS Well Service Inc. operations shall be supported by emergency action plans, which are
preplanned responses to emergencies, which may develop during operations that pose higher
than normal risks of fire, explosion, or release of hazardous materials. The plan should be
reviewed and updated periodically. The plan include but not limited to:

1. Accounting for all TOPPS Well Service Inc. employees by Immediate Supervisor.
2. Immediate Supervisor shall assign emergency duties.
3. Notification of:
4. TOPPS Well Service Inc. Office
5. TOPPS Well Service Inc. Office will then notify the Regulatory Agencies.
6. Securing outside services and resources and recourses (mutual aid).
7. Training in Emergency Preparedness.

Employee compliance is a condition of employment. All employees are expected to comply fully
and promptly with instruction under the authority of this program; failure to do so can result in
discipline, up to and including discharge.
For additional information see EMERGENCY RESPONSE PLAN

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8.0 ENVIRONMENTAL, HEALTH & SAFETY POLICY


TOPPS Well Service Inc. is committed to the continuous improvement of environmental, health
and safety performance to help achieve the greatest benefit for the employees and community.
It is our policy to meet and/or surpass all applicable local and Navajo Tribal environmental,
health and safety laws and regulations, and to facilitate full and open discussion to address
responsible standards and practices where laws and regulations do not exist.
8.1 OPERATIONS GOALS
1. Incorporate environmental, health and safety procedures into our core business.
2. Formulate environmental, health and safety components into existing operations and in
the planning, design and construction of new business and decision processes.
3. Institute a system for entire employee involvement in environmental, health and safety
processes.
8.2 COMMUNICATIONS
1. Promote environmental, health and safety awareness among customers and in the
communities where we operate.
2. Provide environmental, health and safety training and promote awareness among all
employees.
3. Cooperate and coordinate, in the spirit of partnership, with local, state, tribal and
federal authorities and other stakeholders on environmental, health and safety matters
and incidents.
8.3 EVALUATION
1. Incorporate significant environmental, health and safety performance metrics into our
existing employee review procedure. Include the achievement of high environmental,
health and safety standards of excellence as a component of the performance review
process for each employee.
2. Perform environmental, health and safety process assessments and independent
compliance audits and implement corrective action. Perform evaluations of incidents
and near misses through formal investigation including the identification of basic and
root causes and steps to prevent reoccurrence of a similar event.
3. Assess environmental, health and safety risks of existing operations, new business
ventures and acquisitions.
4. Each employee is responsible for compliance with this policy and for implementing the
policy within his or her area of responsibility.

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9.0 PERSONAL PROTECTIVE EQUIPMENT (PPE)


9.1 POLICY
Appropriate clothing and all employees, subcontractors, visitors and vendors shall wear
personal protective equipment. Those individuals who do not abide by TOPPS Well Service Inc.
PPE requirement policy shall not be allowed on the work site. All employees shall be
responsible for the enforcement of this policy.
9.2 RESPONSIBILITIES
The company is responsible for ensuring that employees are provided with personal protective
equipment. This equipment shall be provided to protect the employees health. When used, the
equipment must be suited for the purpose intended. It is the responsibility of all supervisors to
see that their employees abide by the personal protective program. (Company will not provide
steel-toe boots, daily work gloves and clothing)
9.3 PROCEDURES
FOOT PROTECTION
Steel-toed footwear with oil resistant soles is mandatory. Safety-toed footwear shall meet
ANSI.1 requirements.
CLOTHING
All employees must wear a sleeved shirt and full-length trousers while on the job site with
company provided Flame Resistant Clothing (FRC). The preferred fabrics are cotton or wool.
Sleeveless shirts, tank tops, muscle shirts, mesh material are prohibited. For further information
on the FRC see Flame Resistant Clothing Program.
HAND PROTECTION
Appropriate hand protection, as required by the specific task, shall be worn. Examples of
appropriate hand protection include:
1. Leather or leather palm gloves when handling wire
rope and barbwire.
2. Impervious gloves when handling acids, caustic,
etc.
3. Cloth gloves for daily work.

HEAD PROTECTION
All TOPPS Well Service Inc. employees shall wear
approved company hard hats meeting ANSI Z89.1
requirements in all working areas except in
designated areas, offices or when employee is riding
in an enclosed vehicle.
EYE AND FACE PROTECTION
1. Spectacle type safety glasses meeting the ANSI Z87.1-1989 shall be worn in all working areas
except offices.

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2. Splash-proof chemical goggles and face shields shall be worn when handling hazardous
chemicals, liquids, powders, or vapors.
3. Safety glasses and face shields shall be worn when performing tasks such as chipping, grinding,
using a jackhammer, etc.
4. Shaded lenses shall be worn when flame cutting or welding.

HEARING PROTECTION
Hearing Protection shall be worn in areas with high noise level above 82 dB. TOPPS Well Service
Inc. shall identify those areas with high noise levels. Hearing Protection must meet ANSI Z24.22
standards.
FALL PROTECTION
Employees shall be required to use appropriate fall protection in those circumstances where
employees are exposed to falls over six feet. This does not apply to normal work platforms
equipped with standard hand rails and toe boards. Full body harnesses and lanyards must be
inspected prior to use and must be removed from service if a fall occurs while they are in use.
BACK SUPPORTS
Back supports will be recommended in any push, and lift situations. Especially when lifting
objects in excess of 50 lbs.

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10.0 HAZARD COMMUNICATION


10.1 GENERAL INFORMATION
TOPPS WELL SERVICE, INC. is committed to the prevention of hazardous material and chemical
incidents that could result in injury and/or illness to any employee or visitor. TOPPS will spare
no effort in providing a safe and healthful work environment for employees and all levels of
supervision will be accountable for the safety of those employees under their direction.
The Occupational Safety and Health Administrations (OSHA) Hazard Communication standard
(29 CFR 1910.1200) is based on the simple concept that employees have both a need and a
right to know the identities and hazards of any chemicals they work with during the course of
their employment. Employees also need to know what protective measures are available to
prevent chemical exposures and how to avoid adverse health effects.
This is our written Hazard Communication (HAZCOM) / Material Safety Data Sheet (MSDS)
Program. Copies of this program will be available on job location and at TOPPS WELL SERVICE,
INC. office for review by any interested employees. We will meet the requirements of OSHAs
Hazard Communication standard as follows:
10.2 CONTAINER LABELING
All Employees will verify that all product containers kept onsite will clearly list contents on the
label:

The identity of the chemical


The name and address of the chemical manufacturer or
distributor
Emergency phone numbers
Warnings about the chemicals specific physical and health
hazards
Signal words such as - DANGER, CAUTION, or WARNING
Procedures, protective clothing, and equipment needed to
work safely with the chemical
First aid instructions
Special instructions concerning children

Valuable information is found on labels. Always read the label before container movement,
handling, or opening.
It is the policy of TOPPS WELL SERVICE, INC. that no container will be released for use unless it
has a complete label. Field Operations Supervisor will ensure that secondary containers, such
as spray bottles, have complete labels. Either (1) a copy of the original manufacturers label will
be made and placed on the secondary container, or (2) the minimal information bulleted above
will be placed on the container in permanent ink.
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If a chemical is removed from its original container, the employee must label it with one of
the following label systems
10.3 LABEL SYSTEMS: COLORS, NUMBERS, AND SYMBOLS
The hazard warnings on chemical labels can appear in words, colors, numbers, or symbols.
These words may give warnings about the chemical:

Carcinogen (causes cancer)


Irritant (irritates the skin or eyes)
Corrosive (burns the skin or eyes)

Signal words may tell how dangerous the chemical is:

DANGER = can cause immediate serious injury or death


WARNING = can cause moderate injury or death
CAUTION = can cause relatively minor injury

Labels can use color to show the type of hazard:

RED = Fire Hazard


BLUE = Health Hazard
YELLOW = Reactivity Hazard
WHITE = Special hazard or protective equipment is
required

Numbers can be used along with colors to show the degree of a hazard:

4 = Extreme hazard
3 = Serious hazard
2 = Moderate hazard
1 = Slight hazard
0 = Minimal hazard

Additional information on a particular chemical can be found on the


Material Safety Data Sheet (MSDS).
10.4 MATERIAL SAFETY DATA SHEETS (MSDS)
Copies of MSDSs for all hazardous chemicals to which employees of this company may be
exposed will be kept at the job location and at TOPPS WELL SERVICE, INC. office. Employees are
encouraged to look-up MSDSs for the chemicals they use. MSDSs will be available to all
employees during all shifts. If an MSDS is missing, or if a new product arrives without an MSDS,
immediately inform Field Operations Supervisor and Safety Personnel so they can call the
supplier or manufacturer.

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The MSDS is an important right-to-know tool. It contains detailed chemical and safety
information. Each chemical in the workplace must have an MSDS that identifies:

The chemical
The chemicals hazard or hazards
The conditions that make it most hazardous
How to protect yourself, other people, and the environment from its hazards
What to do in an emergency involving the chemical.

MSDSs are written and distributed by the chemical manufacturers or importers. They are sent
with the initial shipment of the chemical.
An MSDS contains the information needed to work safely with a chemical. Employees shall
review and become familiar with key terms found on an MSDS
10.5 CHEMICAL IDENTITY
The MSDS tells you what the chemical is, including:

Common and chemical names


Names of any hazardous ingredients
Name, address, and telephone number of the chemical manufacturer, importer, or
other firm that provided the MSDS so additional information can be obtained or they
can be contacted in an emergency.

Also found on the MSDS is a measure of how much of the chemical you can be exposed to
without damaging your health. This may be:

Permissible Exposure Limit (PEL), the maximum air contaminant a person can be
exposed to on a repeated basis without developing adverse effects, as specified by
OSHA regulations; or,
Threshold Limit Value (TLV), the daily air concentration in which the American
Conference of Governmental Industrial Hygienists (ACGIH) believes persons may be
exposed to without adverse effect.

10.6 PHYSICAL HAZARDS


The MSDS tells you if a chemical will:

Catch fire
Explode
React dangerouslyif exposed to air, water, or other chemicals, and what conditions and
substances to keep it away from.

Information alerting you to fire and explosion hazards may include:


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Flash point: Minimum temperature at which a flammable liquid's vapor could catch fire
if it comes in contact with a spark or other ignition source. Lower numbers mean a
greater fire hazard.
Upper and lower flammable or explosive limits (UFL, LFL, UEL, LEL): Minimum and
maximum amounts of vapor in the air that could catch fire or explode if they contact an
ignition source.

10.7 PHYSICAL AND CHEMICAL CHARACTERISTICS


The MSDS lists many chemical properties on how a chemical will behave under different
conditions.

Normal appearance and odor:


Characteristics helpful in recognizing the chemical.
Boiling point:
Temperature at which a liquid boils or changes to a vapor.
Melting point/freezing point:
Temperature at which a chemical changes from solid to liquid or liquid to solid.
Solubility in water:
How much of the chemical will dissolve in water.
Specific gravity:
A mass-to-volume comparison relative to water.
A specific gravity below 1 will float in water, above 1 will sink in water.
Vapor density:
Compares a chemicals vapor density to air density.
A vapor density below 1 will rise in air, above 1 will sink in air.
Vapor pressure:
The higher the number, the faster a chemical evaporates, increasing inhalation
risk.

10.8 REACTIVITY
Identifies conditions that might cause dangerous chemical reactions.

Stability/Instability: Whether a chemical is prone or resistant to breakdown over time;


conditions to avoid (heat, shock, pressure, etc.) to prevent hazardous reactions.
Incompatibility: Specific chemicals, air, or water that could cause a dangerous reaction
with the chemical.
Hazardous decomposition products: Whether the chemicals breakdown or reaction
will create new hazardous products like toxic gases.
Hazardous polymerization: Whether a chemical will react by itself, releasing heat that
could lead to an explosion.

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10.9 HEALTH HAZARDS
Its very important to know what health problems could develop from exposure to a chemical. To
help you understand the results of overexposure, the MSDS explains:

Routes of chemical exposure (inhaling, swallowing, eye, or skin contact)


Type of exposure (acute or chronic)
Specific health effects from exposure (e.g., skin irritation or burns, breathing problems,
reproductive problems)
Organs that might be affected (e.g., lungs or liver)
Whether the chemical may cause cancer (carcinogenic)
Signs and symptoms of exposure (e.g., headaches, nausea, dizziness, rashes).

10.10 AVOID CHEMICAL EXPOSURES


The MSDS also lists medical conditions that could be worsened by exposure to the chemical. If
you have asthma, a heart condition, or any problem thats listed on the MSDS, immediately alert
your supervisor. You may need to take extra precautions to avoid contact with that chemical.
The MSDS also tells what to do if you are overexposed. First aid instructions to follow while
waiting for medical help may include:

Flushing eyes at an emergency eyewash station


Removing contaminated clothing and thoroughly washing skin
Getting to fresh air after inhaling a chemical.

Remember: If you work with chemicals, report any possible overexposure symptoms to your
supervisor immediately!
10.11 PRECAUTIONS AND CONTROLS
An MSDS contains more than warnings. It has instructions and information on ways to reduce
the risk of chemical accidents and health problems from exposure. It may cover:

Personal protective equipment, such as respirators or eye protection


Hygiene practices, such as washing hands after working with the chemical
Engineering controls, such as ventilation
Instructions for handling and storing the substance properly and safely, such as avoiding
heat sources.

Clean up spills and leaks


Put out fires
Dispose of the chemical properly.

10.12 PRACTICE CHEMICAL SAFETY


Before you start any job, use the following safety checklist.
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Look around for anything that could go wrong.


Eliminate the risks before you start.
Check and read labels and MSDSs.
Use the correct personal protective clothing and equipment.
Remove from the work space anything you could trip over or that creates a hazard
ignition sources, reactive chemicals, combustibles, etc.
Be sure equipment is in good working order. If its not, DONT USE IT. REPORT IT TO
YOUR SUPERVISOR.
Dont eat or smoke in the work area.
Use proper ventilation.
Use the right tool or equipment for the job.
Follow Standard Operating Procedures.
Keep focused on what you are doing.

10.13 USE OF PERSONAL PROTECTIVE EQUIPMENT


Different chemicals and jobs require different levels of protection. Select equipment based on
procedures established for your work area. You may have to wear:

Safety glasses or goggles


Face shield
Protective clothing or suits
Gloves
Boots or shoes
Respirators.

10.14 BE PREPARED FOR EMERGENCIES

Know the location and how to use each piece of emergency equipment
Know how to handle a small spill, leak, or fire
Know your evacuation route and where to go in case of an emergency.

10.15 EMPLOYEE INFORMATION AND TRAINING


Prior to starting work, each new employee will attend a health and safety orientation and will
receive information and training on the following:

An overview of the requirements contained in OSHAs HAZCOM standard: 29 CFR


1910.1200.
Chemicals present at TOPPS WELL SERVICE, INC.
Location and availability of our written hazard program.
Physical hazards and health effects of TOPPS WELL SERVICE, INC. Companys hazardous
chemicals.
Methods and observation techniques used to determine the presence or release of
hazardous chemicals in the work area.
How to reduce or prevent exposure to these hazardous chemicals by using engineering
controls, work practices and personal protective equipment.

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Steps TOPPS WELL SERVICE, INC. has taken to reduce or prevent exposure to these
chemicals.
Emergency procedures to follow if an employee is exposed to TOPPS WELL SERVICE,
INC. chemicals.
How to read labels and review MSDSs to obtain appropriate hazard information.

Supervisors are responsible for conducting job specific hazard training on chemicals used by
their employees. After attending training, each employee will sign a form to verify that he or
she attended the training, received our written materials, and understands TOPPS WELL
SERVICE, INC. Companys policies on hazard communication.
10.16 NOTES ON TRAINING:
Hazardous Chemicals List Training shall be provided at the time of initial assignment to
tasks where occupational exposure to a hazardous chemical may take place.
Training shall be repeated whenever a new chemical or a new hazard is introduced in
the work area.
An oral or written test should be established to verify that the employee understood the
training. Training documentation is an optional item OSHA recommends for employer
use in tracking employee training.
Field Operations Supervisor has compiled a list of all the chemicals and products used at TOPPS
WELL SERVICE, INC. Company. This list is kept in the front of the MSDS book. Each chemical
entry on the inventory list has a corresponding MSDS available for providing specific hazard
information and personal protective measures. This list will be updated weekly to remove
chemicals that are no longer in use at TOPPS WELL SERVICE, INC. and to add new products.
10.17 HAZARDOUS NON-ROUTINE TASKS
Occasionally, a TOPPS WELL SERVICE INC. employee may be asked to perform a task that is not
part of their normal job. Before taking on a new task, the affected employee will be given
information by their supervisor about any hazardous chemicals that might be used during the
activity.
This information will include:

Specific chemical hazards;


Protective measures employees can take; and
Measures TOPPS WELL SERVICE, INC. has taken to reduce the hazards, which might
include ventilation, personal protective equipment, use of the buddy system, and
emergency procedures.

10.18 INFORMING CONTRACTORS


It is the responsibility of Field Operations Supervisor to provide contractors with the following
information:

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Hazardous chemicals to which they may be exposed while working at TOPPS WELL SERVICE,
INC. and the procedure for obtaining MSDSs; and
Precautions contracted employees may take to reduce the possibility of exposure by using
appropriate protective measures; and
An explanation of TOPPS WELL SERVICE, INC. Companys labeling system.
It is also Field Operations Supervisor responsibility to identify and obtain MSDSs for chemicals
the
contractor
brings
into
TOPPS
WELL
SERVICE,
INC.
Company.

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10.19 TRAINING RECORD FOR HAZARD COMMUNICATIONS
This is to certify that I have been trained and informed about the hazards and precautions
associated with the use of hazardous chemicals in my work at TOPPS WELL SERVICE, INC.
Overview of the requirements contained in OSHAs HAZCOM standard, 29 CFR
1910.1200.
Locations and availability of TOPPS WELL SERVICE, INC. Companys written hazard
communication (HAZCOM) program and the MSDS book.
Chemicals I am likely to use for my job at TOPPS WELL SERVICE, INC. Company.
Physical properties and health effects of these hazardous chemicals.
Methods and observation techniques used to determine the presence or release of
hazardous chemicals in my work area.
How to reduce or prevent exposure to these hazardous chemicals through control
and work practices and use of personal protective equipment.
Steps TOPPS WELL SERVICE, INC. has taken to reduce or prevent exposure to these
chemicals.
Emergency procedures to follow in the event of a spill or release.
How to read container labels and how to review and interpret MSDSs to obtain
appropriate hazard information.

Employees Name

Date of Training

Supervisor/Trainer

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10.20 HAZARDOUS CHEMICAL LIST

PRODUCT NAME

January 2012

MANUFACTURER

COMMON NAME

WORK AREA(S)
WHERE USED

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10.21 MSDS REQUEST FORM
Date:
(Address of Chemical Manufacturer,)
(Supplier, Distributor of Importer)

Gentlemen:

The OSHA Hazard Communication regulations require all employees to have a Material Safety
Data Sheet (MSDS) for each hazardous chemical, which they use or are exposed to. The rule
also requires chemical manufacturers, distributors, importers and suppliers to obtain or
develop the MSDS. We currently have the following products supplied or manufactured by your
firm which we believe falls under this rule.

We would appreciate your assisting us to comply with the OSHA requirements by providing us
with the necessary MSDS.

Sincerely,
(Supervisors signature)
TOPPS Well Service Inc.

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11.0 ACCIDENT/ INCIDENT REPORTING POLICY


11.1 PURPOSE
To provide guidelines that will ensure TOPPS Well Service Inc. employees, supervisors, and
safety supervisors report and investigate accidents.
TOPPS Well Service Inc. employees and subcontractors shall report all near-misses incidents,
property damage, motor vehicle accidents, environmental incidents and any occupational injury
or illness immediately, no matter how slight, to his/her immediate supervisor. All fatalities life
threatening injuries or potentially seriously accidents or incidents shall immediately be
reported to the Manager. In addition, employees must also notify the Contracting Company
Representative of any accident or incidents that occur while work is being completed on the
Contracting Companies lease.
All incident report forms shall be completed by the immediate supervisor and reviewed by the
safety supervisor for his/her comments regarding prevention of similar occurrences. The
incident form shall then be forwarded to the president and a copy to the Safety Department for
their comments and analysis regarding prevention of the incident reported.
11.2 RESPONSIBILITIES
Employees Responsibility:
Report Accident/ Incident/ Near Miss/ Spill to the supervisor as soon as possible and complete
necessary report form within 24 hours. The employee shall also notify the local company
representative on location or responsible for that jobsite.
Supervisors Responsibility:
Investigate and identify that cause of Accident/ Incident/ Near Miss/ Spill and take necessary
steps to prevent further accidents or loss. Make required reports in accordance with company
procedures within 24 hours. Investigation reports in accordance with company must be
completed. Notify host employee and a written report within 24 hours. Make a verbal report as
soon as possible.
Safety Representative Responsibility:
Provide necessary report forms to employees supervisor and submit complete reports.
11.3 PROCEDURES
Fatalities and Life Threatening Injuries have these additional reporting requirements:
1. Immediate call from the Manager.
2. Written report of all facts known within 24 hours of accident.
3. Update report (written) within 48 hours of accident.
4. Update report (written) within 96 hours of accident
5. Update report (written) one week after accident and weekly thereafter, until closed

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All written reports and updates, related to Fatalities and Life Threatening incidents, are to be
sent to the job site Supervisor; with copies to the Contracting Personnel, safety supervisor,
Immediate Supervisor, and Safety Department.
11.4 TOPPS WELL SERVICE INC. INJURY AND ILLNESS
An employee shall report to his/her supervisor ANY occupational injury or illness sustained at
work, no matter how slight the injury or illness may be. Employee should also report near
misses.
Work site non-serious injuries and illnesses shall be reported immediately upon occurrence if
practical, but not later than 24 hours after the injury occurred of the illness was identified. This
includes first aid of the incidents.
The Supervisor shall conduct an accident investigation and review the circumstances related t
the injury or illness and prepare the appropriate written reports.
Accidents shall be reported timely, completely and factually accurate on appropriate forms.
a). Within 24 Hours on an Injury, Accident, or First Aid Case
b) Complete the Incident form and return to the TOPPS Well Service Inc.
The TOPPS Well Service Inc. Form should be completed and forwarded to the manager after the
investigation is concluded, however this should not take longer than 7 working days. The
Manager, Safety Department, or appointee will administer the following items. The items shall
be attached to the accident report.
Any Doctor Releases and/or Estimates of Damage, or other pertinent documentation. A copy of
the letter offering light duty if applicable.
Employee Warning Notice for progressive disciplinary action (if applicable). When requested, a
copy of the accident report shall be provided to the client. After the Company Officials have
reviewed reports and placed their comments on forms, a copy of the comment section will be
returned to the Manager for review and appropriate action to insure this accident is
communicated to all TOPPS Well Service Inc. employees to prevent possible reoccurrence.
Safety bulletins will be generated for posting in the office as needed by the Safety Department.
11.5 CONTRACTOR EMPLOYEE WORKSITE OCCUPATIONAL INJURY AND ILLNESS
Contractors shall provide the TOPPS Well Service Inc. Supervisor with an immediate verbal
report of any OSHA recordable injury or illness and a written accident/ first report of injury
form by the end of the next business day following the occurrence.
TOPPS Well Service Inc. shall report to their immediate Supervisor any accident/ first report of
injury form by the end of the next business day following the occurrence.
A copy of the contractors accident report shall be provided to the customer.

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11.6 TOPPS WELL SERVICE INC. VEHICLE ACCIDENTS
A TOPPS Well Service Inc. vehicle accident is defined as any injury that results in damage to
vehicles, personal property, or injury to people that involves TOPPS Well Service Inc. owned/
leased equipment or any vehicle in use for TOPPS Well Service Inc. business.
In addition to these guidelines, each Districts own accident-reporting procedures provide
detailed information on handling a TOPPS Well Service Inc. vehicle accident.
A TOPPS Well Service Inc. Vehicle accident shall be reported immediately to the supervisor.
Those of a serious or potentially serious nature shall be reported immediately to the Manager
and in turn the Company Officers and Safety Department. Employees involved in an accident
shall adhere to the following procedures:
1 Aid the injured
2 Call The TOPPS Well Service Inc. Supervisor immediately and local law enforcement if
appropriate
3 Contact the Contractor Representative.
4 Do not discuss the accident with anyone except the police, TOPPS Well Service Inc.
insurance carrier representative, and TOPPS Well Service Inc. Supervisors. Do not make
any statements regarding fault.
5 Get Names and addresses of witnesses, if possible.
6 Obtain name, badge number and work addresses of the investigation police officer.
7 Obtain facts about injured person
8 Obtain facts about property damage
9 Describe and diagram the accident.

The employees immediate supervisor shall investigate accident, gather pertinent facts related
to the accident and prepare proper forms. Copies of these reports, when investigation is
complete shall be forwarded to the Safety Department. The Safety Committee should further
investigate and submit its findings to the Safety Department.
The employee shall be post-accident tested per TOPPS Well Service Inc. Anti-Drug and Alcohol
Plan.
In instances relating to environmental incidents, land owner problems, or other cases relating
to the situation not covered under the normal reporting format, the Incident Form will be used
in conjunction with a supplemental report in memo form outline further details.

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12.0 DISCIPLINARY ACTION


All Employees shall comply with all TOPPS Well Service Inc. safety rules, standards and
procedures. Failure to comply with company safety rules, standards and procedures may result
in progressive disciplinary action up to and including termination.
There are four classifications of disciplinary action. Although TOPPS Well Service Inc.
acknowledges that there are some infractions which require swift action on the part on
management, every attempt should be made to adhere to the progressive steps of the
disciplinary action code.
12.1 VERBAL WARNING
The first classification is a verbal warning. This is usually appropriate after a supervisor has
explained expectations for acceptable behavior through coaching and this has failed to
persuade the employee to chance his/ her behavior. Documentation of the verbal warning will
be included in the employees file maintained by the Administration.
12.2 WRITTEN WARNING
If the employee does not correct his/ her behavior, a written warning will be issued to him/ her
in a meeting with his/ her supervisor. The supervisor should communicate that the employee
has now proceeded to the next level of the progressive discipline policy. The employee will be
given a copy of the warning for his/ her personal use, and the original will be included in the
employees file maintained by the administration.
12.3 WRITTEN NOTICE OF SUSPENSION
Following unacceptable behavior, or repeated offenses, the employee will receive written
notice of suspension. The purpose of suspension is to make sure the employee understands
that further unacceptable actions or behavior will result in discharge. This disciplinary action
should be documented, and a copy should be given to the employee. The original will be
included in the employees file maintained by the administration.
12.4 TERMINATION
An employee will be terminated as the result of a specific behavior, or the final step in the
accumulation of offenses. A document explaining the discharge should be written by the
employees supervisor then reviewed and approved by the next level of management prior to
termination. And original letter explaining the discharge should be given to the employee at the
time of termination. A copy of the letter will be kept on file by the Administration.
Any employee with a question or concern regarding the progressive discipline policy should be
referred to the Owner and/or President.

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13.0 FIRST AID AND CPR


TOPPS Well Service Inc. employees shall become familiar with and be able to demonstrate
proficiency with basic First Aid and CPR procedures.
A minimum of two employees per work unit shall be trained in First Aid & CPR procedures and
receive refresher training on a bi-annual basis.
13.1 PROCEDURES
The definition of First Aid is the immediate and temporary care given to the victim of an
accident or sudden illness until the services of a medical doctor can be obtained. In the absence
of a clinic of hospital near the workplace, personnel shall be adequately trained to render first
aid. There are four cases where first aid shall be applied immediately; when heavy bleeding is
occurring, when breathing has stopped or is impaired, when the heart has stopped, and when
the person has poisoned.
13.2 EMERGENCY TREATMENT
HEAVY BLEEDING
Apply pressure directly over the wound with a cloth par if available, otherwise close the wound
with your fingers or hand to control and stop the bleeding. Keep the victim lying down and
warm with the injury higher than the rest of the body if possible, unless bones are broken.
When an arm or leg has been mangled, crushed, or amputated, or severe bleeding from an
artery is occurring and cannot be stopped by pressure, use a wide piece of cloth applied as a
tourniquet to stop the bleeding.
NOTE: In all cases, get the services of a physician as soon as possible.
Breathing Stopped
When a person has stopped breathing due to lack of oxygen, inhalation of has, vapor, smoke,
by electric shock, lighting, or by downing, move the victim to a fresh air area as soon as it is
determined that it is safe to do so.
When the victim is not breathing because of gas, vapor, or smoke inhalation, put on air
breathing equipment before entering the contaminated area for rescue.
If electric shock is the cause, turn off the electric current prior to rescue, if possible. If the
source of current cannot be found immediately, and the wire is in contact with the victim, do
not touch victim until wire is removed. Remove the wire with a board or wooden pole. Never
touch the wire with your hands.
In the event the victim has drowned, start begin mouth to mouth resuscitation as soon as
possible, place victim on his/ her back, check for any sign of breathing, check the mouth for any
obstruction and feel for any sign of circulation (pulse) by feeling the carotid artery at the neck.
After performing the previous procedures, immediately begin mouth-to-mouth resuscitation or
CPR, following the steps listed in the following procedures.

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Cardiopulmonary Resuscitation
To be performed only by trained qualified
personnel.
Place the victim in a horizontal face-up
position.
Open victims airway using the chin-lift
technique. Take a deep breath, place
mouth over the victims mouth, pinch the
nose, and blow while making sure the chest
rises while you are blowing. Remove your
mouth, then repeat the procedure rapidly
one more time to ensure the lungs are have
a large amount of air.
If a pulse cannot be felt in the neck, then
proceed with CPR.
If you are single rescuer, move down beside
the victims side, place the heel of one
hand over the bottom third of the sternum
(breast bone), place the other hand over
the first, keep your arms straight and
compress the 1 to 2 inches. This well cause artificial beating of the heart and circulation of
blood. Do this procedure at the rate of once per second, 15 times, then move back and give two
breaths by mouth-to-mouth method. Continue these procedures of 15 compressions and two
breaths until help arrives.

Shock
Shock may occur from many causes such as severe
injury, infection, pain, stroke, heart attack, heat
exhaustion, etc.

The SIGNS of shock are: cold and clammy skin with


perspiration on the palms and forehead, a pale face,
shallow breathing, rapid pulse, and the victim will
probably complain of being cold or even have a
shaking chill.
The treatment steps for shock are:
1. Keep the victim in prone position.
2. Jeep the airway open.

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3. Elevate the victims legs if there are no broken bones.
4. Keep the head lower than the trunk of his/ her body if possible.
5. Keep the victim warm; give water, tea, or coffee only if the person is able to swallow.
6. Reassure victim until medical help arrives or victim is transported to an emergency room.
7. If unconscious , leave in recovery position to protect injured from choking

Burns
The first aid-care for burns is to prevent shock, protect the burn area, and control pain.
A minor THERMAL burn may be covered with a clean cloth soaked with water and bandaged
loosely over the burn.
An extensive THERMAL burn should be covered with the cleanest cloth available, moistened
with water, to exclude air. In some locations, Water Jel fire blankets are available for use.
The victim shall be in prone position with his/ her chest fairly lower than the rest of his/ her
body. Transport the victim to a hospital and obtain the
services of a physician as soon as possible.
LPG (liquid Propane Gas) produces a burn by freezing.
Use the same procedures as outlined above for minor
and extensive burns.
A CHEMICAL burn to the skin shall be immediately
flushed with a large quantity of water. Remove clothing
at the same time. A chemical burn to the eyes must also
be flushed with water for at least 15 minutes.
Do not use anything but clean water for flushing. Obtain
the services of a physician as soon as possible for skin or
eye burn.
Insect Bites
A person stung by a wasp, bee yellow jacket, ant, etc. should report to his/ her supervisor.
To reduce pain, ice may be rubbed lightly on the affected area for a short period of time.
Damage to the skin could occur if applied too long. In the event of a venomous insect bite,
apply an ice pack and carry the person to a physician or hospital. When a person is
hypersensitive to insect bites, he/ she should see his/ her doctor and obtain a kit to carry for
use if stung. Fellow employees should be informed of his/ her hypersensitivity to insect stings
so they may help him/ her to an emergency room at a hospital.
Snake Bites
Rattlesnakes, copperhead, cottonmouth moccasin, and coral snake bites are seldom fatal.
Approximately 7000 snakebites occur in the Unites States annually and of this number only

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about 12 prove to be fatal. These are usually children, elderly and those with chronic medical
conditions.
Rattlesnakes, copperhead, cottonmouth moccasin, and coral snake bites are member of the pit
viper family. Normally, these three types of snakes strike. When they strike they usually leave
two puncture wounds where the poison (venom) is injected.
The coral snake has a small mouth which forces it to bite small objects, usually toes and fingers.
The venom of the coral snake is very toxic; however, the coral snake is not aggressive as the pit
vipers.
When a person is bitten, it is imperative that this person or his/ her companion reports the
injury immediately through any means of communication. Give the listener your exact location
and your intention.
The basic first aid for bites from pit vipers consists of the following:
Make positive identification of the snake. If possible, kill the snake and take its body to the
physician.
Reassure the victim and keep him/ her warm, but do not apply heat to the wound. Keep the
victim quiet and calm. Transport the victim to medical facility.
Do not sacrifice safety for speed on the way to medical facility. Do not allow the victim to run. If
alone, walk slowly to your vehicle. Report the injury by radio. Drive slowly toward a main road
or nearest residence and ask for assistance. If with companions, have them carry you to a
vehicle and then proceed to a medical facility or physician.
Heat Exhaustion
The symptoms of heat exhaustion are: a pale clammy skin, a rapid and weak pulse, excessive
perspiration, temperature above normal, cramps in the abdomen or limbs, a headache, nausea,
and weakness.
Prevent shock. Treatment for heat exhaustion is to have the victim lie down with victims
head lower than his/ her body in a cool shaded place, but protect victim from chilling. If the
victim is conscious, he/she may be given only water to drink, and then obtain the services of a
physician.
Heat Stroke
The symptoms of a heat stroke are: flushed and hot skin, a rapid and strong pulse; temperature
about normal, headache, dizziness, nausea, and the victim is often unconscious. This is a life
threatening condition and the victim must be cooled rapidly with cold water over the entire
body. Get the victim to medical care immediately.
Frostbit
The victim feels cold and numb and the frostbitten skin is white and grayish yellow. The
treatment is to take the victim and apply lukewarm water, or use woolen material to wrap
around the frostbitten area until circulation is reestablished. Encourage the victim to exercise
affected parts. Use no other means or methods of treatment. Do not rub the frostbitten area.
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Plant Poisoning
When you have contacted poison ivy, poison oak, or poison sumac, itching, redness, or
blistering of the skin can occur. The treatment is to remove the contaminated clothing so it
does not come in contact with other exposed areas of the body. Wash exposed areas with mild
soap and water and rinse. Repeat this procedure several times and then sponge gently with
rubbing alcohol. If blistering occurs, see a physician.
SWALLOWED POISONS
If it is known that the victim has swallowed gasoline, kerosene, or similar hydrocarbon, do not
include vomiting. In all other cases, induce vomiting by putting a finger deep in the throat of the
victim. Call a physician, emergency room, or Poison Control Center for special advice.
If the Substance is known to be an alkaline corrosive, have the victim drink cup of vinegar. If
the poison is know to be an acid, give the victim baking soda dissolved in water. If the poison is
unknown, prepare a solution of mile and raw eggs or just milk to coagulate the material, and
then induce vomiting.
Get the victim to a physician as soon as possible.
Inhalation of H2S, Poison Gas and Smoke
Rescuers wearing fresh air breathing equipment should remove the victim from the source of
exposure to fresh air environment.
If the victim is not breathing, use mouth-to-mouth resuscitation immediately as previously
detailed in the Cardiopulmonary Resuscitation (CPD) section.
Transport the victim to emergency care as soon as possible.
Blood borne Pathogens (Infectious Disease)
Persons trained in first aid/ CPR will also be trained in avoiding exposure to blood borne
pathogens. Universal precautions shall be taken when there is the possibility of being exposed
to certain types of body fluids from other people.
First aid kits/ body fluid barrier packs shall be available for those providing first aid. These packs
include, but are not limited to, CPR mouth barriers, disposable latex gloves, and face and eye
protection. Bloodborne Pathogens Kits should be available in work vehicles.
Employees who have occupational exposure to blood borne pathogens shall be offered
Hepatitis B vaccinations.
Information regarding availability of medical care should be made available by the employer for
every employee.

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14.0 HYDROGEN SULFIDE (H2S) SAFETY


14.1 INTRODUCTION
Operations involving petroleum, which contain hydrogen sulfide (H2s) may present additional
dangers beyond the hazards associated with hydrocarbons. H2S is a deadly gas. A small quantity
of H2S (1000 PPM), is enough to render a victim unconscious, and to cause death if rescue does
not take place quickly. Although H2S often has the characteristic of rotten egg odor in
small amounts, the sense of smell cannot be relied upon. The gas attacks the nerves in the nose
and destroys the sense of smell within a few seconds. Using the sense of smell to detect H2S is
unreasonable, extremely dangerous, and could lead the victim into a false sense of security.
They may think the gas has dissipated, when in fact; it is already damaging the body.
14.2 SCOPE
These procedures are applicable to all operations where there is the potential for personnel
exposure to H2S. These are minimum requirements for the protection of personnel from the
harmful effects of H2S concentration is equal to or in excess of 5ppm.
14.3 RESPONSIBILITIES
All Aneth point employees are responsible to ensure the requirements of these procedures are
followed for all operations involving potential exposure to H2S. All employees are responsible
for being familiar with these procedures and following the requirements. Supervisors must
ensure all the employees are familiar with the characteristics of H2S, its dangers, applicable
safety procedures, and first aid techniques.
14.4 PHYSICAL CHARACTERISTICS
H2S is highly toxic, colorless, has, heavier than air, often with the odor of rotten eggs. Since H2S
is heavier than air, it is particularly dangerous when it accumulates in low places in the terrain,
in tanks, vessels, and other enclosed spaces. H2S is soluble in liquids. H2S is flammable and it
also forms explosive mixtures in the air.
14.5 TOXICITY
H2S is toxic by inhalation. The effects, depending upon the concentration exposed to, can
include eye respiratory tract irritation, headache, dizziness, nervousness, nausea, pulmonary
edema, bronchial pneumonia, unconsciousness, and death through respiratory paralyses. OSHA
limits an employees exposure to a maximum of 10 PPM, measured at time weighed average
during an eight hour work day (TLV).
14.6 GENERAL PROCEDURES
Area tested to contain a concentration of H2S equal to or in excess of 10 PPM. Wind indicators,
socks and caution signs shall be utilized.
Respiratory protection equipment shall be used in areas where the ambient H2S concentration
is an excess of 10 PPM.
Where operations call for a standby person, he/ she must be equipped with an independent
respiratory protection device and must be in contact (visual or voice) with the person wearing
the respirator and performing the work. The standby person does not have to wear the
respirator, but must have it and other appropriate equipment readily available.
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14.7 FIELD AND PLANT OPERATIONS
Following is a list of nine operations in which individuals are required to utilize positive pressure
respiratory protection, either on line respirators with escape provisions (a 5 min. air bottle) or
self contained breathing apparatus. A minimum of one standby person, equipped with positive
pressure respiratory protection, must be present during these work activities.
Ascending any produced fluid storage tank that may have any H2S concentration of 300 PPM at
or above the opened hatch.
Gauging or otherwise measuring the contents of any produced fluid tank that may have an H2S
concentration of 300 PPM att or above the hatch.
Opening to atmospheric (voiding the sea by means of removing a man way or similar sized
sealing device) any production tank or vessel previously in sour service.
Breaking into any line that has been in sour service, unless the line has been isolated, bled, and
purged.
Entering any vessel or confined spaced which was previously in sour service, unless continuous
interval monitoring indicates that the H2S concentration is 20 PPM or less and the O2
concentration is at/ or above 19.5%
Entering into any area, which the permanent or portable H2S detection is alarming, indicating
H2S in excess of 10 PPM.
Entering into any building or confined space, including ditches and cellars, which contain sizable
spill of produced fluid when the actual concentration of H2S is either unknown or greater than
10 PPM.
Entering into any area where gas is known to be escaping into the atmosphere, when the actual
concentration of H2S gas in concentration greater than 10 PPM. If an operation is undertaken in
which it is unknown as to whether or not there is a reasonable probability of exposure to h2S
gas in excess of 10 PPM then respirators shall be utilized until such time a detector conforms
the concentration is 10 PPM or less.

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15.0 RESPIRATORY PROTECTION


INTRODUCTION
Employees must be protected against exposure to airborne contaminates such as dust, fumes,
mists, gases, and vapors. Where feasible, exposure to these contaminates will be eliminated by
engineering controls (exhaust, ventilation, enclosure, isolation, or substitution of a less
hazardous material). When these controls are not feasible, or whole they are being instituted or
evaluated, respiratory protective equipment devices shall be supplied and utilized for
operations that may cause potential exposure to these contaminates.
SCOPE
This program applies to all operation in which there is the potential for exposure to respiratory
contaminates, and all employees who must utilize respiratory protection equipment
instances other than emergency escape (hereafter refer to as normal operation). This
policy represents minimum requirements is mandated on all company owned, leased, or
operated properly.
RESPONSIBILITIES
Employees are responsible for familiarizing with the respiratory protective program, and the
requirements applicable to their work. The employee is also responsible for utilizing the
appropriate respiratory equipment, maintaining the equipment in a clean operable condition,
and reporting any malfunction on the respirator to their supervision. Receive annual respirator
training, and utilize respirators in accordance with the instruction and training provided.
Supervisors are responsible for determining which operation necessitate the use of respiratory
protective equipment, insuring that all personnel are trained in the respiratory protective
requirement applicable to their jobs, and ensuring that respirators are being utilized properly
and accordingly.
Safety representative will provide respiratory protective equipment that is suitable for the
intended application to protect the employees in the course of work operations.
15.1 RESPIRATORY USE
Respiratory equipment shall be worn when:
1. The oxygen level fall below 19.5% by volume in you work area.
2. Recommended by the MSDS for the chemical being used.
3. The concentration of H2S in ambient air exceeds PPM.
4. Posted at sour tank batteries.
5. Required by your supervisor when working in confined space or in environments with dust,
vapors, gases, or fumes.
6. Only employees who have received training in the use of respiratory equipment shall use it.
7. Respiratory equipment shall be used in accordance with instruction and training given to
employees.

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8. Monitoring for H2S or other chemicals and/ or when determining that the area is safe to return
to normal operations following an emergency.

15.2 SELECTION AND USE


CANISTER TYPE GASCanister masks shall not be used unless approved by the safety department for specific
applications. IN NO CASES SHALL THEY BE USED FOR PROTECTION AGAINGST H2S.
CARTRIDGE TYPE RESPIRATOR
Cartridge type respirators shall be worn only when the MSDS for the chemical recommends its
usage. Consult with the Safety/ Loss Prevention Department for the recommended types and
manufacturers of cartridge respirators.
WORK MASKS
Used for routine maintenance or repair work in atmospheres made hazardous by toxic gas
concentrations or by oxygen deficiency. Your supervisor will determine this, by signs, and by
your own sampling instruments.
The work masks consist of two-fold assembly. The first is a means of utilizing air from a
stationary cylinder, and the second is a small cylinder, and the second is a small cylinder with
enough air for 5 min. to be used for emergency escape use only.
Self contained Breathing Apparatus (SBCA)
A SCBA is a portable air cylinder and mask designed for use in any facility. Only pressure
demand SCBA is approved for use in any facility. The air bottle for SCBA shall be replaced or
refilled as soon as possible after use.
DUST RESPIRATOR
Dust respirators shall be worn when working in dusty environments or when recommended by
the MSDS.
This equipment is only a dust filter. Dust masks shall be used as protection against vapors,
gases, fumes, or smoke. SCCBA should be used or in some cases cartridge respirators can be
used.
15.3 LIMITATIONS AND CAUTIONS FOR AIR SUPPLIED BREATHING EQUIPMENT
The escape cylinder on a work mask has about a five-minute air supply. Never use any
lubrication on any part of the apparatus and always keep all parts entirely free from oil and
grease. Two SCBA(s) must be available if work masks are being used for other than routine tank
gauging. Sufficient help must be present to assist in any emergency, which might arise. Two
back up men shall be present at all times (i.e., during tank vessel entry, breaking out lines, or
valves, etc.).
Back-up personnel is not required during routine tank gauging unless the H2S concentration in
the ambient air exceeds 300 PPM.

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15.4 INSPECTION
Check face piece for a scratched vision and cracked or broken parts. Replace parts if necessary.
Keep all equipment clean and in good condition. Store units in accessible locations, where
possible, store flat in cool dry place. Make sure exhalation valve operates properly when
exhaling.
Check breathing hoses for cracks. Check gaskets. Check for
loose or damaged fittings. Replace parts if necessary. All
sections of the air hose should be coupled together to
prevent debris from entering hose. Check harness straps for
wear, particularly at the buckles and the regulator. Make
sure buckles work freely. Check to ensure the low-pressure
warning is operating. Do not use the unit if low pressure
warning device does not work. Check the regulator to ensure
it is functioning properly.
Check air supplies cylinder to verify they are full. SCBA shall
be checked prior to each use at least once monthly.

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16.0 DRIVING SAFETY


TOPPS Well Service Inc. employees drive a variety of vehicles. The weather conditions under
which our operations are conducted vary from one extreme to the other. TOPPS Well Service
Inc. drivers will comply with all state, federal, and local regulations while driving TOPPS Well
Service Inc. vehicles.
Pay attention to traffic, road conditions, and utilize defensive driving practices. These are some
of the most important considerations when operating vehicles in a safe manner.
16.1 COMPANY RESPONSIBILITIES
Require seat belts be used at all times while on duty, in a company vehicle, or moving vehicle.
Equip all vehicles with approved warning devices for stopped vehicles, in accordance with the
Motor Carrier Safety Regulations of the U.S. Department of Transportation.
16.2 EMPLOYEE RESPONSIBILITIES
Personnel who drive company, rented, leased or personal vehicles while performing work
related activities are required to:
1. Follow state and traffic laws.
2. Be thoroughly familiar with the vehicles operation.
3. Use safe driving practices to prevent accidents and injuries whenever hazardous
conditions exist.
4. The driver and all passengers must wear seat belts at all times while on duty in a moving
vehicle.
5. Be thoroughly familiar with the vehicles operation and periodically check the
condition of the vehicle. Inspect Non-DOT vehicles quarterly using the vehicle inspection
report. Retain copies for one year plus the current year. Follow motor carrier
regulations for DOT vehicle documentation. Each licensed vehicle must have a state
inspection yearly, where required.
6. Check behind the vehicle before backing up to be sure the area is clear. Do not rely
completely upon mirrors. Turn around and look out the back window. If your view is
obstructed, seek out assistance to guide the backing maneuver.
7. Do not keep loose equipment such as tools, boxes in the driving compartments of cars
or trucks. Place them in the truck or separate compartment on a pick up or truck. Do not
place objects on the dashboard.
8. The driver of the vehicle is to use mobile phones or radio transmitters only if the use
does not interfere with the safe operation of the vehicles.
9. All locations shall comply with a back-in policy where practical.
10. Once a vehicle is disabled, place one warning device on the traffic side of the stopped
vehicle within ten feet of the front or rear of the vehicle. Place one approximately 100
feet ahead of the stopped vehicle.
11. Never get under a car or truck that is supported only a tire jack. Use a cribbing or jack
stands that are designed for that purpose.

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17.0 FIRE PREVENTION


TOPPS Well Service Inc. shall provide portable fire extinguishers for employee use. And
educational program shall be provided to employees to familiarize them with the principles of
fire extinguisher use, as well as the hazards associated with the fire fighting.
17.1 PROCEDURES
1. Employees and other shall not smoke or strike matches or lighters where this act may
constitute a fire hazard.
2. Smoke only in an approved area.
3. Avoid smoking or approaching ignition sources when clothing is contaminated with oil
or other flammables.
4. Accumulation of combustible materials constitutes a real fire hazard and must be
avoided where possible.
5. Hot work permits are to be secured prior to welding or burning in or near a hazardous
area.
6. Never leave fire unattended.
7. Use only approved solvents such as Varsol for cleaning. Never use flammables. The use
of gasoline for cleaning is specifically forbidden on all Company property.
8. Before an open flame, such as a welding torch is carried into a confined space, a test
should be made to detect the presence of gas, using an approved type combustible
indicator.
9. All spills of flammable liquid shall be immediately cleaned up and the affected area shall
be isolated from any ignition source.
10. Light bulbs shall not be changed in a hazardous area with the circuit on.
11. Only explosion proof electrical equipment shall be used in areas subject to flammable
vapors.
12. Unauthorized personnel and vehicles shall not be allowed in areas subject to flammable
vapors.
13. All employees shall be trained annually on proper use of fire extinguisher and shall be
documented.
14. On all ovations where flammable vapors are present, leave all possible ignition sources
at designated smoking areas (i.e., lighters, matches, and cigarettes). The use of BIC
lighters is prohibited.
15. Smoking is prohibited inside well site perimeters.
16. Ground cables shall be utilized to prevent a static electrical discharge when applicable.
17. No plastic buckets, nylon clothing, jackets, or coats allowed on location where they may
present a potential hazard.
18. Firefighting equipment is not tampered with and is not removed for other than its
intended purposes.
19. Fire extinguisher and other firefighting equipment are suitably located and plainly
labeled as to their type and method of operation.
20. Used cleaning rags and combustible waste material are kept to a minimum.
21. Access to exits or fire extinguishers are not blocked or obscured by clothing, materials or
equipment.

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22. Well cellars, rig floors and ground areas adjacent to derricks are kept reasonably free
from accumulation of oil, which might create or aggravate fire hazards. Fire protection
and firefighting equipment are maintained in a serviceable condition at all time.
23. Fire protection and firefighting equipment are maintained in serviceable condition at all
times.
Note: All fire extinguishers are maintained, inspected and hydrostatically tested in
accordance with state and federal standards.
24. Carbon tetrachloride extinguishers are not permitted.
25. Natural or liquefied petroleum gas (LPG) is not used to operate spray guns or other
pneumatic equipment.
26. On Well Service locations all unauthorized vehicles will remain outside the guylines.
27. There should be an adequate number of No Smoking signs conspicuously displayed
at each work location.
28. No open flames should be within 100 feet from the well or work location.
29. Equipment shall be rigged with the proper size fire extinguishers.

January 2012

Well Service units

4-30 lbs

Construction equipment

1-20 lbs

Pickups

1-20 lbs

Haul trucks/ Vac-trucks

1-30 lbs

Rubber tire hose/small equipment

1-20 lbs

Cars

1-10 lbs

Well Service Trucks

1-30 lbs

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18.0 FIRE PROTECTION


18.1 INTRODUCTION
Fire protection equipment is located strategically throughout companys facilities and is for
emergency use only. Any unauthorized use of this equipment for any other purpose is
FORBIDDEN. Example: Fire fighting hoses on reels and deluge cars are never to be used for
washing slabs or equipment. These are for firefighting only.
TOPPS Well Service Inc. employees shall only take an active role of fire fighting during the
incipient stage of the fire. And incipient stage fire is defined as a fire which is in the
initial or beginning stage and which can be controlled or extinguished by portable fire
extinguishers or small hose systems without the need for protective clothing or breathing
apparatus. NEVER risk your life to save equipment in a fire. ALWAYS sound an alarm or notify
the proper authorities of a fire BEFORE attacking the fire.
18.2 FUNDAMENTALS OF FIRE EXTINGUISHMENT
Fire Triangle/ Tetrahedron
Heat
Fuel
Oxygen
Chemical

18.3 CLASSIFICATION OF FIRES


Class A:

Ordinary combustible

Class B:
Flammable liquids or gases (cruse, gasoline,
natural gas, etc.)

January 2012

Class C:

Electrical

Class D:

Metal Fires

Class K:

Grease Fires

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19.0 TRENCHING AND EXCAVATION SAFETY


INTRODUCTION
Accidents in excavation and trenching activities cause many fatalities and serious injuries each
year. Unsupported, improperly shores excavation walls can collapse, with little or not warning,
trapping workers below. In addition, financial costs of property damage and work stoppage can
be staggering. Correct pre-planning and execution of excavation procedures will help reduce
these losses. These procedures provide guidance for the safe management of operations
involving excavations and trenching.
SCOPE
This safety procedure applies to all open excavation and trenches made in the earths surface
that are more than four feet in depth.
RESPONSIBILITIES
Supervisors responsibilities for an excavation and trenching activity shall assure this
procedure is followed.
1. Excavations operations will be monitored and controlled by the supervisor to assure
that exaction at compact controlled properties comply.
2. Employees working in excavation operation will follow these procedures and ensure
safeguards are not compromised. They will monitor conditions and report to their
supervisor any unstable or unsafe conditions.
3. Supervisors unsure of soil, other conditions and compliance will assure that no
employee enters the excavation until safe conditions can be assured and obtained
assistance from company safety department.
19.1 GENERAL PROVISIONS
Basic planning requires the understanding of site conditions while each situation is different,
the following must be considered in planning an excavation project:
1.
2.
3.
4.
5.
6.
7.
8.

Traffic along, over and around excavation


Potential vibration sources
Proximity of structures
Soil type and classification
Surface and ground water
Overhead and underground utilities
Expected weather
After considering these factors, the work plan must be developed and communicated to
all involved personnel.

19.2. TRENCHING AND EXCAVATION SAFETY


General surface and underground considerations
Surface objects that could affect employee or excavation safety must be removed, secured or
supported. Surface objects such as buildings, sidewalks, traffic, and excavation materials must
be considered.

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Underground installations must be identified and marked before opening the excavation.
Sewer, telephone, piping, has utilities and electricity is typical underground installations. In the
event that underground installations cannot be positively located, additional precautions are
necessary to protect personnel and structures. Work near and underground installation will be
done by hand until its precise location established.
Open excavation shall have underground installation supported to protect them, or remove to
protect employees.
Access and Egress
Excavation and trenches 4 ft or more in depth require stairways, ladders, ramps, or other
means of access and egress. These provisions are to be provided so that lateral travel by
employees while in the excavation is no more than 25 ft away.
Ramps or runaways will have to be designed and constructed by a qualified person. A person
qualified in structural design will design equipment ramps. Structural ramps will have structural
members that are connected and of a uniform thickness. Cleats or other surface treatments are
required to prevent slipping and tripping hazards.
19.3 Personnel Protection From Surface Hazards
Warning vests and/ or barricades will be used on the surfaces to protect employees exposed to
vehicle traffic.
To avoid employees being hit by spillage or falling material, employees are not permitted under
loads handled by lifting or digging equipment, of or in the close vicinity of any vehicle being
loaded or unloaded.
If vehicles are equipped with proper overhead protection devices, operators shall remain in the
cab while loading or unloading. Otherwise, they must stand clear until the activity is completed
and no further danger exists.
Warning systems are required to prevent equipment from imposing a load on the excavation
sides or proceeding beyond its edge. The warning systems used can be barricades, hand or
mechanical signals, top logs of similar methods to prevent movement beyond a safe limit.
19.4 HAZARDOUS ATMOSPHERE
Testing must be done in excavation where hazardous atmospheric conditions may be possible.
Excavations in old landfill areas and close to where hazardous substances are used or stored
posed typical dangers. Atmospheric testing is to be done before personnel are allowed into any
excavation, over 4 feet in depth, with this potential danger. Repeat testing is required when
conditions change or the potential precautions increases.
No employee is allowed unless proper precautions are implemented into an excavation that
contains less than 19.5% oxygen or flammable vapor greater than 20% LEL.
If controls are used to reduce hazardous atmospheric conditions, periodic retesting is required
to assure conditions remain safe.

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When hazardous atmospheric conditions exist or expected, emergency rescue equipment must
be attended so that a rescue effort can be immediately started. Emergency apparatus, safety
harness with attached line, or basket stretcher.
19.5 WATER ACCUMULATION
Employees will not be allowed to work in excavations with accumulated or accumulating water
unless adequate precautions have been taken to prevent cave-ins.
To prevent drainage into the excavation, surface grades should slope away from the edge or
the excavation. Steps must be taken to prevent water from entering the trench when natural
surface water drainage is disrupted. Diversion ditches, dikes, and sloping grades are acceptable
methods to use.
Water removal equipment used to control or prevent water accumulation must be monitored
to ensure its proper operation.
19.6 STABILITY OF ADJACENT STRUCTURES
The stability of buildings, walls, or other structures affected by excavation operations must be
considered. Supported systems such as shoring, bracing, or underpinning will be provided as
needed.
If the excavation is below the level of the base or footing of any foundation or wall that could
pose a hazard, personnel are not permitted in the excavation except when:
A support system is provided to ensure the safety of personnel
The excavations in solid rock
The registered engineer determines that no employee danger is posed by the structure
19.7 LOOSE ROCK SOIL PROTECTION
Employees shall be protected from fall or rolling excavated or other materials. This protection is
to be accomplished by:
Scaling or removal of loose material, overhangs, and other hazards
Placing and keeping materials and equipment 2 ft from the excavation edge
Providing sufficient restraining devices to prevent material and equipment from rolling or
falling into the trench
A combination of methods
19.8 INSPECTIONS
The excavation, adjacent areas and protective systems must be inspected daily by a
competent person. This inspection is to discover any condition that poses a hazard to the
employees. Cave in conditions, water accumulation, failure of protective systems, hazardous
atmospheric, loose rock, are typical hazardous conditions to be included.
Inspections should be conducted:
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Prior to the start of the shift and as needed through the shift
After every rain/ snow storm or other occurrences that may increase the hazard
If an inspection or observation discovers a hazardous situation, employees will be removed
from the excavation. They will not re-enter until corrective action and the necessary
precautions have been taken.
19.9 FALL PROTECTION
Walkways or bridges will be provided for equipment or employees if they are required or
permitted to cross over excavations. Standard guardrails are required.
Physical barrier protection shall be provided at all remotely located excavation. They shall be
barricaded or covered to prevent employees or others from inadvertently falling into them.
Exploration well, pits, and shafts will be back filled upon completion of the activity.
19.10 CLASSIFICATION OF SOIL
Proper classification of the soil is important to provide adequate protective measure. The
following information is a guide for field classification of soil. More detailed information is a
guide for field classification of soils. More detailed information is found in Appendix of the
Federal Standards.
Definitions Cemented Soil- Has particles held together by a chemical agent. Hand sized samples
cannot be crushed into powder or individual soil particles with finger pressure.
Cohesive Soil- Clay (finely grained soil) or soil with a high clay content which has a high
tendency to stick together. Cohesive soil does not crumble, can be excavated with
vertical side slopes and is plastic when moist. It can be easily shaped into a ball when
moist and rolled into small diameter threads before crumbling. It is hard to break up
when dry and has significant cohesion when submerged.
Fissured Soil- Has a tendency to break along definite planes with little resistance. It is
also soil that exhibits open cracks in an exposed surface.
Granular Soil- Is gravel, sand, or silt with little or no clay content and cohesion. Granular
soil cannot be molded when moist and crumbles easily when dry. Some moist granular
soils exhibit some signs of cohesion, but will crumble easily.
Stable Rock- means natural solid mineral matter that can be excavated with vertical
sides. Rock will remain intact while exposed.
Soil Classification system
Soil types have classifications: Stable Rock, Type A, Type B, and Type C. These classifications are
determined based on the analyses of the properties, performance characteristics, and
environmental conditions.
A competent person according to the following guidelines must classify each soil and rock
deposit encountered in an excavation.
Stable rock is natural solid mineral matter that can be excavated with vertical sides with no
visible cracks and fissures.
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20.0 ELECTRIC SAFETY


Policy
This policy applies to TOPPS Well Service Inc. employees and subcontractors working on or near
any energized installations. Some procedures apply to only qualified employees and are
specifically identified as such. Only employees qualified from their training may work on
exposed energized electrical equipment of 50V or more. Employees must be qualified and must
provide proof of their qualification to the TOPPS Well Service Inc. foreman in charge. All
employees will be trained on Electrical Safety Awareness in accordance with OSHA 1910.
PROCEDURES
The district managers and supervisors are responsible for implementing and enforcing the
Electrical Safety Policy.
Live parts must be de-energized, locked and tagged
(see Lockout and Tagout Policy) before employees
work on or near them. this must be down unless
de-energizing introduces additional or increased
hazards (such as: deactivation of emergency alarm
system, shutdown of hazardous location ventilation
equipment or removal of critical limitations (such
as: testing of electrical circuits that can only be
performed when energized or work on circuits that
form an integral part of a continuous industrial
process in plants that would otherwise require
complete shut down in order to permit work on one
circuit or piece of equipment).
If the exposed parts are de-energized and locked and tagged out as provided in item 2 above, a
qualified employee must use test equipment to test the exposed circuit elements and
determine if any energized condition exists as a result of must be checked for proper operation
immediately before and after the test to ensure reliability.
If the exposed live parts are not de-energized as allowed in item 3 above; safe practices must
be used to protect the exposed employees.
All electrical, wiring, fixtures and cords should be installed and used in accordance with
applicable rules and regulations in NFPA National Electric Codes.

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21.0 LOCKOUT/ TAGOUT POLICY


Policy
Lockout and tagout policy is designed to prevent personal injury and/ or property damage due
to the start up of machinery with electrical, mechanical, hydraulic, and pneumatic energy
sources during maintenance or repair.
Lockout and tagout procedures shall be performed within recognized standards and shall be
monitored by a supervisor. TOPPS Well Service Inc. shall provide lockout/ tagout training on an
annual basis.
Scope
The lockout/ tagout procedures shall be implemented before the commencement of any work
requiring employees to work on or near de-energized circuits parts or other equipment in an
situation where there is a danger of injury due to unexpected energizing or start-up of
equipment.
The lockout/ tagout procedure shall also be implemented in coordination with the appropriate
procedures for safely isolating other energy systems such as process fluids, hydraulic,
pneumatic, thermal, chemical, and mechanical system.
This procedure shall also be implemented when equipment becomes unsafe to operate.
Procedure
1.

General

Prior to working on any energized equipment, the Supervisor or Foreman with assistance of the
operator or maintenance worker shall perform the following operations:
Evaluate each job carefully for potential hazards
Identify actual and potential energy sources involved in the machine or systems to be worked
on.
2.
Lockout
Locks used to prevent energy flow shall be used only for lockout/ tagout
The lock shall be under one persons control at all times. This can be effectively accomplished
by keying each lock differently so that only the employee placing the lock can remove it.
In cases where controls are not capable of being locked, positive means shall be taken to
neutralize the energy source, such as blocking, chaining, or disconnecting the energy source.
All keys used for locking out shall be secured in a lock box, with only one person having the key
to the lock box.
3.

Tagout

Tags shall be used to supplement locks for preventing accidental removal of the isolating device
and to aid in the identification of the lock.
Tags shall have a specific warning, such as Danger- Do Not Operate and shall include the
reason for the tag, the date and signature of the person placing the lock and tag on the
equipment.
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4.

Disconnect Switches

The only safe method to disconnect electrical power from process equipment or machinery
prior t repair or service is by Turning Off the appropriate disconnect switch. The following
procedure shall be followed when operating a disconnect switch.
Identify the appropriate disconnect switch and verify this by using start-stop button.
Read and follow all instructions on the disconnect switch.
Stand to one side of the switch and face away from it to avoid injury if the switch should spark.
Move switch with a smooth, non-stop motion to the disconnect position.
Lock and tag the switch and verify the disconnection by using the start-stop push button.
If a circuit cannot be lock out, it must be de-energized and tagged. If a circuit needs
disconnection or removal of a component to ensure isolation, a qualified electrician shall
perform this work.
5.

Start-Up

All switches, valves, or control points between the isolated energy sources and equipment
worked on shall be in the off position to prevent damage to the equipment when energy is
restored.
The following procedures shall be used when reactivating a system or equipment after repairs
are completed.
Employees must remove only their tag and lock.
The last person to complete his/her work shall be responsible for responsible for notifying the
owners representative that the work is completed.
All parties involved to ensure that the equipment or system is safe to be placed back in service
shall then inspect the job. The tags and locks should then be removed.
6.

Training

All employees who participate in the lockout/ tagout program who may be affected by the
program, must be trained prior to their participation in the program and annually thereafter.
The training should ensure that the purpose and function of this program is understood and the
knowledge and skill require for the safe application, usage and removal of energy controls are
conveyed to the employees.
Training should specifically encompass recognition of hazardous energy sources, type, and
magnitude of energy in the work place, methods and means necessary for energy control and
the purpose and use of the lockout/ tagout program.
Retaining shall be provided whenever there is a change in the lockout/ tagout program and
whenever job changes in equipment types present a new hazard.

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All training must be documented, including date, and employees names attending the
training.
TOPPS Well Service Inc. shall comply with all Federal, State, and local regulations, as well as
customer requirements, which may exceed this policy and procedures.
7.

Isolation of other Energy Sources

The same basic procedure that is used for electrical lockout must be used for isolating
pneumatic, hydraulic, and mechanical energy sources. The primary difference will be means of
isolation.
Pneumatic and Hydraulic Energy Sources
The recommended means of isolation for these energy sources are as follows, in order of
preference:
Blinding- A metal place inserted between gasket pipe flanges to prevent the flow of gas or
liquid in either direction. The blind must be of sufficient strength to withstand any pressure to
which it can be subjected. All blinds must meet applicable design piping standards and codes. A
Blind is recommended to have a T handle long enough to extend at least two (2) beyond
the pipe flanges. One side of the T handle should have a hole for the attachment of a tag
and flag (either bright orange or red in color).
Disconnection- Physically disconnecting, removing part of the system and isolating both ends of
the pipe.
Double block and bleed valve configuration (using a chain and lock to secure valves) is the least
preferred method of isolation. Block valves should seal effectively and be used only to indicate
leakage. Automatic valves should not be used as isolation valves unless they are first rendered
inoperable. Bleed valves should be full-Open valves.
In addition, pressure shall also be released from equipment containing pneumatic or hydraulic
pressure.
Mechanical Energy Sources
The means of isolation can be chains, blocks, or disconnection.
If springs are involved, they shall be release or physically restrained when necessary to
immobilize mechanical equipment.
The use of brakes, for example, on pumping units is not an acceptable means of energy
isolation. The use of blocks, chains, in addition to the brakes, is required.
Note: TOPPS Well Service Inc. will annually inspect the effectiveness

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22.0 CONFINED SPACE ENTRY PROGRAM


22.1 PROGRAM
Every year employees are injured as a result of hazardous conditions in confined spaces.
Approximately 60% of these fatalities are would-be rescuers who enter these spaces in an
attempt to retrieve the fallen individual(s), only to be overcome and become victims
themselves.
As part of routine maintenance activities, many oil and gas industry employees and contractors
are required to enter potentially hazardous enclosed spaces. Confined spaces may have
atmospheric conditions and/or physical hazards present and include: manholes, wet-wells,
vaults, tanks, boilers, silos, bins, pits, sumps, and sanitary and storm sewers. Toxic and/or
flammable gases and vapors may accumulate in these locations as a result of insufficient
ventilation and deficient oxygen levels may be present as the result of corrosion and/or organic
debris digestion. In addition, limited access to these locations complicates the retrieval of
anyone incapacitated.
In accordance with the OSHA standard the regulations listed below provide minimum
requirements for safe entry into these locations:

Permit-required Confined Spaces 29 CFR 1910.146

This manual contains the procedures and practices for safe entry into locations, used in TOPPS
Well Servicing Inc., falling under the above regulations.
22.2 PURPOSE
The purpose of this program is to provide specific procedures/safe work practices for
employees required to enter confined spaces. These procedures/practices will be implemented
in compliance with all applicable state and federal regulations pertaining to confined space
entry. It is the policy of TOPPS Well Service Inc. to take every reasonable precaution to provide
a work environment free from recognized hazards for its employees in accordance with the
General Duty Clause of the OSHA Act (Public Law 91-596 Section 5 (a)(1) and in accordance with
any more applicable specific OSHA standards.
TOPPS Well Service Inc., in accordance with State, Federal and Navajo Nation regulations, has
implemented this program to ensure safe entry into confined spaces. Before entry all potential
hazards must be identified and controlled. A formalized training program has been designed to
enable employees to recognize potential hazards and take the appropriate actions to control
those hazards. For most work operations in oil and gas industry safeguards and controls can be
completed without entry into the location and in such cases the permit system is not required.
However, if entrance into the enclosed space is required to implement hazard controls then the
permit-required confined space program must be used.

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22.3 REQUIREMENT
Any work on job location in confined spaces must be conducted in accordance with the
regulations specific to that location and/or contracting company policy. Employees must
implement the written confined space program that complies with the regulation pertinent to
the areas to be entered. All contractors must provide copies of their written program(s) and
employee training documentation to the contracting shop/department. Contractors are also
responsible to supply all needed equipment to perform safe entry. For permit required
confined entries the contractor shall complete form CS-4 Contractor Debriefing with a
University representative and provide a copy to the University. In addition, contractors are
required to coordinate emergency rescue notification with Purdue Fire Department using Form
CS-2. When a contractor is required to enter or work in proximity to a permit required confined
space, the contracting department will furnish a written copy of the hazards identified in that
space to the contractor.
22.4 OBJECTIVES
The objectives of the Confined Space program at TOPPS Well Service Inc. include:

To comply with all state and federal regulations regarding confined spaces.
To assess the feasibility of reducing the total number of confined spaces.
To limit the number of confined space entries.
To identify, evaluate, and eliminate potential hazards within the confined spaces prior
to entry.
To establish and implement a permit system for entry into confined spaces.
To train employees who may work in confined spaces on proper procedures and entry
techniques.

22.6 SAFETY REPRESENTATIVE / OFFICIAL:


The Safety/Health Representative serves as the first contact for issues concerning the confined
space program. The Safety/Health Representative is responsible for establishing a written
Confined Space Program that includes evaluations of the confined spaces entered by the
employee/contractor. He/she is responsible for establishing and maintaining a training program
that will provide exposed employees with the understanding, knowledge, and skills necessary
for safe and proper work in confined spaces. The Safety/Health Representative shall review the
Confined Space Program at least once per year, and shall revise the program as necessary to
ensure that employees participating in entry operations are protected from confined space
hazards. The Safety/Health Representative is responsible for providing employees with the
equipment required to safely enter confined spaces. The Safety/Health Representative is
available to provide training on proper confined space entry techniques, recommend safety
equipment, and assist in confined space evaluations.

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22.7 AREA SUPERVISORS:
The area supervisor will be responsible for identifying workers that may be expected to enter
confined spaces, ensuring that these workers receive required training before entering the
spaces, and ensuring that their subordinates follow established entry procedures.
22.8 ENTRY SUPERVISORS:
Entry Supervisors are the persons responsible for determining if acceptable entry conditions are
present at the confined space where entry is planned, authorizing entry, supervising entry
operations, and terminating entry when required. Entry supervisors shall be trained on
necessary skills and responsibilities Entry Supervisors for the job site are listed below:
1. Rig Supervisor
2. Rig Operator
3. Safety Representative

22.9 TRAINED AND AUTHORIZED EMPLOYEE AND ENTRANTS


Trained and authorized employee(s) and entrants are responsible for working in and around
confined spaces according to guidelines and work practices established by TOPPS Well
Service Inc. Authorized entrants are also responsible for refusing to work in confined spaces
until an entry supervisor has deemed entry to be safe and has given approval for entry, or if a
hazard is identified while working in the confined space. The authorized attendants shall attend
only one confined space entry at any one time, and shall not perform any other duties.
Authorized Entrants are:
1. Rig Supervisor
2. Rig Operator
3. Trained TOPPS Employee(s)
22.10 TRAINING FREQUENCY
Confined Space training will occur: before initial assignment to jobs that would required entry
into confined spaces; when there is a change in assigned duties; when a change in permit space
operations create a new hazard; whenever an employee deviates from established procedure;
and when inadequacies in an employee's knowledge is identified. The confined space training
will include all Supervisors, attendants, and entrants. Confined space training will establish
employee proficiency in the duties required by the confined space standard. Training
documents will include the employee's name, signature of the trainer, and the dates of the
training.
22.11 TRAINING CONTENT:
The training programs established for TOPPS Well Service Inc. include:
1. Confined space identification
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2. Identification and evaluation of permit space hazards
3. Proper gas meter operation
4. Safe entry techniques
5. Attendant and entrant responsibilities
6. Communication techniques
7. Rescue procedures
8. Ventilation techniques
9. Supervisory responsibilities
10. Permit completion/cancellation techniques
11. Location of permit spaces
22.12 INVENTORY
An in depth inspection of TOPPS Well Service Inc. will be conducted in all areas that
contain potential confined space hazards and entry. A confined space assessment form
(Appendix A) will be used to classify all confined spaces. When performing confined space
evaluations, air monitoring and inspections will be conducted from outside the space. If
evaluations cannot be performed from outside the space, the space will be entered through
permit procedures. If any conflicts arise while determining the areas hazards, then the space
will be considered a confined space.
22.13 RECLASSIFICATION OF PERMIT REQUIRED CONFINED SPACES
When a Permit Required Confined Space is to be reclassified to a non-permit status, the
safety representative will issue a written certification that contains the date, the location of the
space, and the signature of the person making the determination that all hazards have been
eliminated. The certification shall be made available to each employee entering the space or to
that employee's authorized representative. This documentation must be completed each time a
permit-required confined space is reclassified, and remains in effect only as long as all of the
hazards remain eliminated. This reclassification procedure is contained in the confined space
assessment form (Appendix A), of this program.
22.14 PERMIT REQUIRED SPACES
Some confined spaces located at TOPPS Well Service Inc. job site locations that meet the
definition of a Permit Procedure confined space. Permit Required Confined Space (Permit
Space) is defined as a confined space that has one or more of the following characteristics:
1. Contains or has a potential to contain a hazardous atmosphere
2. Contains a material that has the potential for engulfing an entrant
3. Has an internal configuration such that an entrant could be trapped or asphyxiated by
inwardly converging walls or by a floor which slopes downward and tapers to a smaller
cross-section; or
4. Contains any other recognized serious safety or health hazard.

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The information necessary to design a permit for permit required space entry is included in this policy

22.15 PERMIT REQUIREMENTS


The entry supervisor shall prepare an entry permit that contains at least all of the information
listed in Appendix B. The permit shall be made available to all supervisors, entrants, attendants,
authorized employee representatives, and rescue personnel. The permit must remain posted
outside of the permit space entry portal, and remain there for the duration of the authorized
entry. Any changes of personnel (supervisors, attendants, entrants), or testing and monitoring
data shall be added to the permit. At the end of the authorized entry or after entry operations
have been completed, the entry supervisor shall cancel the permit and maintain all cancelled
permits for at least one year. A new and updated permit shall be developed, implemented, and
maintained for each permit space entry.
22.16 POSTING OF CONFINED SPACES
All Permit-Required Confined Spaces that can be readily labeled are posted in a manner
designed to inform employees of the existence/location of the dangerous space. The signs read
as follows:
DANGER!
PERMIT-REQUIRED
CONFINED SPACE
DO NOT ENTER!

If posting danger signs cannot be used to inform the exposed employees, use any other
effective means to warn of the existence, location, and the danger posed by the permit spaces.
22.17 OTHER NECESSARY PRECAUTIONS
If it is concluded that posting and training are inadequate to prevent unauthorized entry into
permit spaces, covers, guardrails, fences, locks or other methods of restricting access shall be
implemented.
22.18 ENTRY PROCEDURES:
Site specific entry procedures have been developed for each confined space entered by TOPPS
Well Service Inc. The site-specific entry procedures are located in Appendix C. The following list
identifies the minimal means, procedures, and practices necessary for safe permit space entry
operations:
1. Identify and evaluate permit space hazards.
2. Control hazards and specify acceptable entry conditions.
3. Allow authorized entrants or employee authorized representative observe monitoring
and testing.
4. Isolation of the permit space.
5. Purge, inert, flush, or ventilate the permit space as necessary to eliminate or control
atmospheric hazards.
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6. Provide barriers to confined spaces that protect entrants from hazards created by
pedestrians, vehicles, or other external factors.
7. Verify that conditions within the permit space are acceptable throughout the duration
of the authorized entry.
8. After authorized entry has concluded, or entry operations have been completed, the
permits shall be cancelled and the permit space isolated from unauthorized entry.
22.19 REVIEW OF ENTRY OPERATIONS AND PROCEDURES
TOPPS Well Service Inc. shall review entry operations, procedures, and cancelled entry permits
at least annually. Additionally, a review shall be conducted if there is reason to believe that the
measures taken under TOPPS Well Service Inc. permit space program may not provide affected
employees with the necessary protection. The review and revisions shall correct any
deficiencies found to exist under the prior entry operations and procedures. Circumstances that
require the review of the permit space program are listed below:
1.
2.
3.
4.
5.
6.

Unauthorized entry of a permit space;


A detection of a permit space hazard not covered by the permit;
The detection of a condition prohibited by the permit;
The occurrence of an injury, or a near-miss during entry operations;
The change in the use or configuration of a permit space; and
Employee complaints about the ineffectiveness of the permit space program.

22.20 CONFINED SPACE EQUIPMENT


When necessary the following equipment will be provided, and properly maintained, at no cost
to the employee. TOPPS Well Service Inc. will ensure that employees required working in or
around confined spaces will properly use the following equipment:
1.
2.
3.
4.
5.
6.
7.
8.
9.

Testing and monitoring equipment;


Ventilation equipment;
Communication equipment;
Personal protective equipment;
Lighting equipment;
Barriers and shields;
Equipment necessary for safe ingress and egress;
Rescue and emergency equipment; and
Any other equipment necessary for safe entry into and rescue from permit spaces

22.21 EVALUATION OF PERMIT SPACE CONDITIONS


When conducting permit space entry operations TOPPS Well Service Inc. will ensure that
the following evaluation of permit space conditions is conducted:
1. Test conditions of the permit space prior to any authorized entry. If the space cannot be
isolated (large size, or portion of continuous system), conduct pre-entry testing as is
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2.
3.
4.
5.
6.
7.
8.
9.

feasible, and maintain continuous monitoring of the areas occupied by authorized


entrants.
Test and monitor the permit space as necessary to ensure that acceptable entry
conditions are maintained during the course of entry operations.
When testing for atmospheric hazards the testing shall be conducted in the following
order:
Oxygen;
Combustible gases and vapors; and
Toxic gases and vapors
Allow authorized entrant or employees authorized representative observes pre-entry
and subsequent testing or monitoring data.
Re-evaluate the permit space if authorized entrant or employees authorized
representative feel that the evaluation of the permit space was inadequate.
Immediately provide each authorized entrant or employees authorized representative
the results of any testing or monitoring.

22.22 CONFINED SPACE HAZARD IDENTIFICATION AND EVALUATION


Confined Space Location Hazard Type(s) Control Measures
1)
2)
3)
4)
5)
6)
7)
8)
9)
10)
22.23 NUMBER OF ATTENDANTS REQUIRED
Acceptable conditions do not exist, and authorized entry is not permitted, unless there is at
least one attendant stationed immediately outside the permit space to be entered.
22.24 MULTIPLE EMPLOYERS/CONTRACTORS
TOPPS Well Service Inc. shall inform all other affected outside employers and contractors of the
permit space locations and permit space hazards at TOPPS Well Service Inc.. All affected outside
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employers and contractors will be educated on the confined space program and confined space
requirements of TOPPS Well Service Inc.. Multiple permit space entries conducted by outside
employers and contractors shall be reviewed and coordinated prior to authorized entry by any
party. TOPPS Well Service Inc. shall not enter into any binding business agreement with
contractors or employers that do not meet the confined space program and training
requirements of 29 CFR 1910.
22.25 RESCUE PLAN:
A rescue plan shall be developed for each type of permit-required confined space at the facility.
Whenever feasible, the rescue plan will specify methods that do not involve entry by rescuers
into the confined space. The attendant and/or the Entry Supervisor are responsible for
preventing unauthorized persons in attempting a rescue inside the confined space.
22.26 RESCUE EQUIPMENT:
All necessary rescue equipment to effectively conduct the rescue shall be provided and in
proper working condition prior to entry into the space.
22.27 RESCUE PRACTICE
At least annually, designated rescuers shall practice making a rescue using either a manikin or
an actual entrant, from a space similar to the one being entered. If the space has not been
entered for more than one year, the rescue practice will be conducted prior to entry.
22.28 RESCUE PLAN AND ENTRY PERMIT
The entry permit shall verify that:
1.
2.
3.
4.
5.

Rescuers have been notified;


Rescuers are physically located so they can affect a successful and timely rescue at
Any point during the entry;
Rescuers have been trained on rescue from the particular space being entered;
All required rescue equipment is immediately available.

22.29 OFFSITE RESCUE SERVICES


Prior to a decision to use an off-site service to provide rescue, verification shall be made that
the off-site rescue services complies with all requirements of this section.

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22.30 CONFINED SPACE EVALUATION FORM


CONFINED SPACES ARE DEFINED AS:
Large enough and configured such that an employee can bodily enter and performed
the assigned work.
Has limited or restricted means for entry or exit.
Is not designed for continuous employee occupancy.
PERMIT-REQUIRED CONFINED SPACES ARE DEFINED AS HAVING ONE OR
MORE OF THE FOLLOWING:
Contains or has a potential to contain a hazardous atmosphere.
Contains a material that has the potential for engulfing an entrant.
Has an internal configuration such that an entrant could be trapped or asphyxiated by
inwardly converging walls, or by a floor, which slopes downward and tapers to smaller
cross-section.
Contains any other recognized serious safety or health hazard.
CONFINED SPACE ASSESSMENT FORM
Name of Evaluator _______________________________
Work Area Assessed______________________________
Date of Assessment_______________________________
Confined Space Determination
1. Area was not designed for continual worker occupancy
YES

NO

2. Area can be bodily entered and assigned work performed


YES

NO

3. Area has limited and/or restricted means of access and egress


YES

NO

If you answered yes to all of the above you have met the criteria of a confined space, and
must proceed to the next section.
Permit-Required Confined Space Determination
1. The area contains or has the potential to contain a hazardous atmosphere
YES

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2. The area contains a material that has the potential to engulf an entrant (water, grain, sand,
etc).
YES

NO

3. The area has an internal configuration, inwardly converging walls or a floor that slopes
downward and tapers to a smaller cross section.
YES

NO

4. The area contains any other recognized serious safety and health hazards (electrical, thermal,
mechanical, physical, chemical, etc).
YES

NO

If you answered yes to any one or more of the above you have met the criteria of a
permit-required confined space. Permit-required spaces must be identified with the
appropriate signs, and implement measures to prevent unauthorized entry (locks, bolts, etc). If
employee entry is required a confined space entry program and training program must be
developed and implemented.
Reclassification of Permit Required Confined Space
A space classified by the employer as a permit-required confined space may be reclassified
under the following procedures:
1. If the permit space poses no actual or potential atmospheric hazards and if all the hazards
within the space are eliminated without entry into the space, and the non-atmospheric hazards
remain eliminated.
2. The employer shall document the basis for determining that all hazards in a permit space
have been eliminated, through a certification date, the location of the space, and the signature
of the person making the determination. The certification shall be made available to each
employee entering the space or to that employees authorized representative.
3. If hazards arise within a permit space that has been declassified to a non-permit space, each
person must immediately exit the space. The employer shall then reevaluate the space and
determine whether it must be reclassified as a permit space.
Classification of Work Space
Permit-required confined space
Non permit-required confined space (does not contain hazards capable of causing serious harm
or death)

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22.31 CONFINED SPACE ENTRY PERMIT

CONFINED SPACE ENTRY PERMIT


There is not a standard format for a Confined Space Entry Permit. It can be formatted using any
method as long as the permit is legible to all exposed employees, can be posted at the confined
space entrance, and contains all of the following information.
All Permit-Required Confined Space Permits shall list the following:
1. The permit space to be entered.
2. The purpose of entry.
3. Date and authorized duration of the permit.
4. Authorized entrants (by name).
5. Authorized entrants (by name).
6. Current entry supervisor (by name). With space for name or initials of original entry
supervisor who originally authorized entry.
7. Hazards of permit space to be entered.
8. Measures used to isolate permit space and eliminate or control hazards before entry.
9. Acceptable entry conditions (site specific).
10. Results of initial pre-entry testing and necessary periodic testing, accompanied by the
names or initials of the testers and date/time of the testing. (Note: When testing for
atmospheric hazards, test first for oxygen, next for combustible vapors and gases, and
then for toxic vapors or gases.)
11. The rescue plan to be used for this space. Verify that all required elements of the rescue
plan are in place.
12. The procedures used to maintain communications between authorized entrants and
attendants.
13. List of equipment required to maintain compliance. (Example: PPE, testing equipment,
communications equipment, alarm systems and rescue equipment)
14. Additional necessary information (site specific) that will ensure employee safety.
15. Any additional permits that have been issued to authorize work in the permit space.
(Example: hot work)

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23.0 WELL SERVICING SAFETY


Well Servicing operations are one of the most hazardous tasks that our employees are exposed
to on a regular basis. Therefore, all TOPPS Well Service Inc. personnel must employ extreme
care when involved in well servicing. A copy of this manual is on the TOPPS Well Service Inc.
service rig. you and your fellow crew members will work the safest if you are physically and
mentally fit and knowledgeable about the job you are performing. Keep all equipment in good
condition, work as a team and follow these recommended procedures, and as always, ask a
supervisor if in doubt.
23.1 BASIC SAFETY EQUIPMENT
UNIT FIRST AID KIT
Each rig shall be equipped with a 24-unit first aid kit and should be inspected monthly and
items missing should be replaced. Replacement items are to be kept in project sites. These kits
should be mounted in the rig doghouse in a visible area.
EYEWASH
Each rig shall be equipped with a 32 oz. Eye wash bottle containing sterile eyewash and
should be mounted in a display board and mounted in doghouse. these should be inspected
monthly and if opened, replaced.
BURN BLANKET
Each rig shall be equipped with a burn blanket and shall be inspected monthly and stored in
doghouse.
GERONIMO
All rigs shall be equipped with a Geronimo escape device and shall be positioned in the derrick
mans work area. This device shall be installed in a or 9/16 line. Line should be
inspected on a daily basis. It should be free of kinks, broken wires, and/ or oil.
FULL BODY HARNESS
Each Derrick shall be equipped with a full body harness. A full body harness should distribute
fall impact over thighs, buttocks, and shoulders. All belts should meet the ANSI A-10-14
standard. The harness should be 2 webbing, 6.000lb tensile strength with a small D ring
at the top of each shoulder for lifting and lowering operations, and a large D ring on the
back for shoulders falls arresting. Full body harnesses are available in several sizes.
LANYARDS
Lanyards should be retaining devices designed to position a man safely at a work area. For most
lifelines or lanyards, nylon rope of diameter should be used. Lanyards snaps should be
double latched, drop forged still, 5,000lb strength, plated to resist corrosion.
Lanyards should be equipped with shock absorbing devices that absorb injurious impact force
by gradually slowing a fall so the forces exerted on the worker is held within general body
tolerance.

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PERSONAL PROTECTIVE EQUIPMENT
This equipment should consist of safety glasses, hearing protection, steel toe boots, hard hats,
back belt, proper clothing, and adverse weather gear.
FIRE EXTINGUISHERS
Each rig shall be equipped with 4-30lb cartridge type fire extinguishers and the crew truck
should be equipped with 1-30lb fire extinguisher. These should be positioned around the well
site in strategic area.
STATIC LINE
A static line should be attached to rig and then to well head to provide a good ground to
prevent static electricity which could cause a possible explosion in a gas environment.
23.2 SWABBING OTHER WIRE LINE OPERATIONS
There should be no person or employee in the derrick, on the deck between the sand drum and
derrick within 10 feet of the well head while the swab line or other wire line is being run in or
out of the well.
All oil should be the type that does not require an employee or person to be near the lubricator
or well head to control the oil saver.
All swab lines, blow down lines or flow lines to pits or frac tanks. These pits or tanks should be
located a minimum distance of 100 from the well, or outstanding guy lines.
On wells where there is a possibility of flow, there should be a lubricator with a full opening
safety valve installed that will allow the removal of the swab or other tools without turning the
well loose to the atmosphere.
Swabbing operations should be restricted to daylight hours if possible. If necessary to swab at
night, sufficient lighting shall be used in the form of light plants and shall be positioned in the
proper place.
Tanks that are being swabbed or flowed in to should have hatches unlatched of open.
When gauging pits or frac tanks, employees shall gauge fluid line and under no circumstances
enter the pit or frac tank to get that gauge
No employee shall stand inside draw works to spool up sand line. If necessary, use hydraulic
jack to get spool level so cable will spool properly.
There should be no radiophone transmitter operated where there is a perforating program in
progress. The perforating company should provided appropriate warning signs. Such signs
should be placed at the entrances(s) to work site(s), at least 200 feet from the operation where
perforating is bring done. The sign should read Warning Perforating in Progress, No Radio or
Phone Transmitters Operated Beyond this point
When pouring rope sockets, the open fire should be outside of guy lines and upwind of well.
Goggles and heavy gloves are to worn when pouring babbit for rope sockets.

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23.3 BLOW OUT PREVENTERS
Employees shall be instructed in the installation proper hookup of hydraulic and manual B.O.P
Unit.
Employees shall also be instructed in the proper way to install B.O.P. rings and how to hammer
up bolts to insure leaks, after bolting up B.O.P. (s) they should be pressure tested.
Company owned B.O.P. shall be stump tested, charted and inspected every 45 days and results
maintained in office.
When installing B.O.P. units on well, they shall use a cable sling with lifting eyes and they shall
be made of the appropriate size and length and cable.
CHAINS SHALL NOT BE USED
On hydraulic blowout preventers the accumulator shall be at least 100 feet from the well head.
All closing units or drive units for the blow out preventer shall be set outside the guy lines.
23.4 PUMPING UNITS
The operator should assure that after the pumping unit is turned off, the master control should
be locked in the off position, the brake set and the means to secure the weights in a safe
manner to prevent any movement of weights and/ or beam. When possible, weights should be
chained in the down position and safety latch kicked in. UNIT SHOULD BE LOCKED OUT AS PER
LOCKOUT/ TAGOUT PROCEDURE.
A wire sling of sufficient strength and size should be used to handle the horses head if
removal or installation is necessary. The head should be haltered or latched after installation in
accordance with manufacturers specifications. CHAINS SHOULD BE AVOIDED FOR REMOVING
AND INSTALLING HEADS.
After the Well Servicing operation is completed, precautions should be taken before engaging
the power source to see that all personnel and equipment are clear of weight and beam
movement.
Employee should not place his/her hand on polish rod between stuffing box and polish rod
clamp under any circumstances.
It is recommended that the stuffing box be pulled to the extreme end of the polish rod before
tailing polish rod out or picking it up to prevent stuffing box from sliding down and smashing
hand.
Make sure all guards and fences are in place.
23.5 PUMPS
All pumps should be equipped with lines and valves of the proper pressure rating and are in
good working order.
All pumps should be equipped with lines and valves of the proper pressure rating and are in
good working order.
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Pump should be located a minimum of 100 ft from the well head and steel line laid to wellhead
and hooked up solid, stake and tie down. AVOID USE OF RUBBER HOSE.
All pumps should be equipped with 1-30-lb. fire extinguisher.
Only qualified employees will be allowed to operate pump.
Pump should never be left unattended when in pumping operation.
Pump lines should be hydrostatic tested annually.
All hammer unions over 4000-lb. pressure rating should be of the rubber seal type.
Pump drivelines should have safety guards installed.
10.

Rubber hoses will not be used in nitrogen operations.

23.6 TANKS
All tanks should be located a minimum of 100 feet from the well head.
All discharge lines should be safely secured. All hoses under pressure should be properly
hobbled.
Discharge line should be located as to discharge water into tanks, not on edge.
All tanks that have mud guns should be equipped with catwalk and safety handrails.
Tanks with fixed mud guns used for jetting should be manned and there should be an employee
stationed at the pump controls to shut down the pressure in the event of an emergency.
Hoses used for jetting operations should be manned and there should be an employee
stationed at the pump controls to shut down pressure in the event of an emergency.
ALL TANKS SHOULD NOT BE ENTERED BY PERSONNEL UNLESS THEY FOLLOW THE PROCEDURES
UNDER CONFINED ENTRY.
23.7 RIG INSPECTION PROCEDURES
Each TOPPS Well Service Inc. employee rig shall be inspected on a monthly basis and copy kept
on file in office. It is recommended that the operator and derrick man perform the inspection.
The AOSC rig inspection form shall be utilized.
23.8 DERRICKS
Each derrick or mast should show name of manufacturer and safe load capacity.
No derrick or mast should be subjected to a compression load greater than the safe load limit
shown on the manufacturer.
Derricks, mast guying and foundations should comply with the standards for guy lines and
anchors.
The guy lines should be properly secured with at least 3 fist grip clamps of the proper size. The
guy lines should be rigged up on a work site unless wind guy anchors have been installed.
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No oil or gas servicing unit should be rigged up on a work site unless wind guy anchors have
been installed.
Wind guys from crown or tubing (racking) board should not be any closer than ten feet from
power lines and in no case should a wind guy be extended about or below a purloin.
Derricks and mast should be equipped with guards which prevent the hoisting lines from
jumping the sheaves during operations or when being raised or lowered from operating
position.
A visual inspection of the service unit should be made by a qualified person before the derrick
or mast is raised or lowered.
A qualified person should be in charge of raising or lowering a derrick.
Before any derrick is raised or lowered, all tools and material not secured to the derrick should
be removed from the derrick.
The derrick is raised or lowered; all tools and material not secured to the derrick should be
removed from the derrick.
Before any load is put on the derrick, all crown guys should be properly tightened and derrick
locks in place.
No employees should be allowed on the carrier when it is being raised or lowered.
Each derrick platform should be constructed, maintained, and secured to the derrick to
withstand the weight of the employees or other stresses, which may normally be placed upon
it.
Fingerboards should be constructed, maintained and secured to the derrick to keep them from
falling if jarred losses or broken.
There should be no opening large enough to permit an employee to fall between the beams or
main supports or framework of the crown.
All derricks should be equipped with locking devices with sufficient strength to prevent the
mast from bending at the hinge points. The rig manufacturers should approve the locking
device. The mast will be locked as soon as the mast is in position and remain locked until the
mast is lowered.
Derrick men on the first ascent into the derrick will visibly inspect locking devices or dogs and
install safety devices if applicable.
Prior to breaking derrick over center, air should be purged from the raising cylinder and the
cylinder properly pressurized.
As derrick is being scoped up or down, operator should inspect cylinder stabilizer for proper
extension and seating.

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If derrick becomes stuck while scoping up or down, operator should immediately scope back up
or down to same position and check for fouled wire line or other obstruction which caused the
problem.
23.9 DRILLINGS/ SANDLINES/ WINCHLINES
A dead-man anchor for lines should be constructed, installed and maintained so that its
strength should be at least equal the working strength of the lines.
All lines should be visually inspected before and during use by a qualified person and a record
made of defects notes. At this time a determination should be made as to whether the lines
should be removed and new line installed. Check rig manufacturer for proper size and length
and construction on rig.
Each rig should be equipped with a hydraulic handling. The use of catheads is prohibited.
23.10 HOISTING BLOCK
All traveling blocks should be properly guarded.
All traveling blocks, elevators, elevator links or similar equipment should be reasonably free of
projecting bolts, nuts, or other parts upon which clothing of workmen may be caught.
All traveling blocks and similar equipment should b inspected and maintained in good working
condition and the applied load should never exceed the manufacturers listing rating.
23.11 WEIGHT INDICATORS
Every well-servicing unit equipped with a reliable weight indicator.
A weight indicator should be safely secured and should be easily visible to the unit operator.
The manufacturers rated load capacity of the servicing unit should not be exceeded. Be certain
proper line charts on weight indicator is used.
23.12 DRAWWORKS
A visual inspection of the drawworks and its working parts should be made each day or tour
before operations being.
All guards and covers should be in place before operations being.
If lubrication fittings are not outside of guards, machinery should be completely stopped and
engine shut off.
When it becomes necessary to remove a guard, the drawworks should be completely stopped
and engine shut off.
All air compressors should have at least one pressure control for proper airflow. Use proper
pins in relief valve.
The safety pressure relief valve on main air tank should be kept in proper working order.
All valves kill switches and other working devices should be kept in proper working order.

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Safety pressure relief valves on hydrostatic lines should never be set higher than the design
rating of the hydraulic system or the manufactures listing ratings of the lines, whichever is less.
The brakes, linkage, and brake flanges on the drawworks should be tested visually and
inspected each day.
The rig operator should not leave the brake without tying the brake down or securing it with a
catch lock.
The rig operator should not leave the brake while hoisting drum working order.
An extension device long enough to prevent employees from coming in contact with line or
drum must be used when guiding lines on drum. Avoid spooling when possible.
23.13 TUBING/ ROD TONGS
Tongs should be inspected to ensure they are in good working order.
Tongs should be equipped with a stiff arm that is attached to the tongs and then to the derrickleg.
In addition to a stiff arm, tongs should be rigged up with a safety cable attached to tongs and
derrick-leg.
The cable that tongs are hung off of should be inspected and slipped.
All hand and head guards should be in good working order ad in place.
The manufacturers recommended backup device should be used. THE USE OF THE PIPE
WRENCHES FOR BACKUPS IS PROHIBITTED.
Hydraulic hoses and fitting should be inspected for condition.
A qualified employee should operate tongs.
23.14 POWER SWIVELS
Power swivels are to be inspected to ensure they are in good working condition.
All swivels shall have a stiff arm, check stiff arm and bolts for a wear daily.
All hoses should be inspected daily and safety hobbled after hooking up to swivel.
Tubing elevators should be tied shut during swivel operations.
All controls should be properly labeled.
Only qualified employees shall operate swivel.
23.15 LADDERS, STAIRWAYS, RUNWAYS, FLOORS AND PLATFORMS
Every scaffold, stage, walkway, working platform, stairway and ladder, whether temporary or
permanent, should be constructed and maintained in a safe condition and should not be
altered or moved while in use.

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Work areas should be clean and free of debris.
Walkway, stairways, and exits should be kept clear to provide unimpeded ingress and egress
except during rig up, rig down and moving.
Safe ingress to and egress from all work areas should be provided.
Every stairway, ladder ramp, runway, floor and platform should be kept reasonably free of
objects and substances which may create slipping or tripping hazard, or prevent/ hinder the
escape of workmen in an emergency.
With the exception of exit and entrance openings and loading and unloading areas, a standard
guardrail with mid-rail and a four (4) inch toe board should be installed at above the found or
another floor or working level. Where guardrails are not feasible, chains, or wipe rope may be
used.
A standard guardrail should not be used for other than personnel protection purposes.
A guardrail used and/ or needed for the purpose or actual or potential containment of
equipment or material should be of such construction and strength as to effectively contain the
full load or stress which may be anticipated to be applied upon it.
Any temporary stabbing board, or other temporary boards, placed in derrick should be securely
fastened.
Every opening in a derrick floor should be removed or guarded when not being used.
The work floor should not be used as a storage platform for equipment or material that is not
required for immediate use.
Ladder platforms should be located at the crown of all rigs requiring crown block servicing or
maintenance during work operations.
23.16 OPERATORS STATION
Operators control panel should be securely locked into position.
All controls should be properly labeled.
Only a qualified employee should be allowed at controls.
Platform shall have handrail and steps in place.
23.17 TUBING BOARD/ ROD BASKET
Tubing board and rod basket should be inspected to ensure they are in the proper position
after each rig up.
Hinges need to be inspected for cracks and signs of fatigue.
Rod Basket should be kept locked in position before pulling rods.
Rod Basket shall have a safety cable in derrick to hook into derrick harness.
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24.0 HOT WORK PERMIT PROCEDURES


INTRODUCTION
The use of heat producing and electrical arching devices in potentially hazardous areas may
create the hazards of fire or explosion in the work area. Potentially hazardous areas are areas
where the fundamental concern is the possibility of explosive or flammable vapors/ liquids/
gases/ materials, or explosives being present in the workplace. Where employees must perform
such work in potentially hazardous areas, a special work authorization must be obtained. This
special authorization is HOT WORK PERMIT.
DEFINITIONS
Hot Work; Any work which creates a potential source of ignition. Examples cutting and burning
open flames, grinding, and other head producing/electrical arching devices.
Hot Work Permit: A written permit authorizing HOT WORK in a specific area or operation.
Designated Hot Work Area: An area that has been set-aside for the purpose or performing HOT
WORK activities. This area may be welding shops, or any specific area, which has been
identified by local management as safe for HOT WORK.
GENERAL REQUIREMENTS
A Hot Work Permit is mandatory for any work involving the use of local ignition
sources
capable of igniting flammable gases, vapors, liquids, material, and explosives when such work is
performed outside a Designated Hot Work Area.
Location of a Designated Hot Work is authorized by local. supervision/management only.
The decision to approve Hot Work Area will be local supervision or a person in-charge that is
designated local supervision.
Hot Work, in which may require inhibition of fire and / or gas detection systems, must be
authorized by the area Operation Supervision.
If it is not possible to execute the Hot Work while the plant or equipment is in operation, it
becomes a shutdown item.
Work can only commence when as approved Hot Work permit has been issued.
All Hot Work Permits are automatically suspended upon actuation of a plant or facility
emergency alarm.
24.1 HOT WORK OUTSIDE A DESIGNATED HOT WORK AREA
1. The hazardous area shall be identified
2. On-site inspection conducted before work commence to determined necessary
safeguard, such as:
3. Removal of combustible material within 35 of the Work Area.
4. No flammable liquids allowed within 35 feet of the Hot Work Area.
5. Covering floor opening where slag or hot metal can fall within 35 of the Hot Work
Area.
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6. Safeguards that can be provided if the 35 feet rules cannot be adhered to during Hot
Work.
7. Special precautions to be observed within the Hot Work area shall be defined,
including any personal protective clothing and equipment necessary.
8. All energized or operational equipment, which may cause a hazardous environment to
the worker. Shall be locked and tagged out before Hot Work are performed.
9. Nearby personnel shall be protected against heat, sparks, slags, cutting/welding fumes,
and ultra violet light.
10. The Hot Work area shall be tested for the presence of combustible gas with an approved
combustible gas detector.
11. Hot Work shall not commence until the work area measures less than or equal to 5% of
the lower explosive limit.
12. A Hot Work permit shall be completed indication the proper precautions have been
taken.
13. Fire watch requirements:
14. When and where a fire watch is required.
15. Duties of fire watch personnel
24.2 FIRE PREVENTION PRECAUTIONS
Cutting or welding shall be permitted only in the areas that are or have been made fire safe.
No welding, cutting, or other Hot Work shall be performed on used drums, barrels, tanks, or
other containers until they have been cleaned thoroughly to eliminate any substance which
when subjected to heat, might produce flammable or toxic vapors.
Any pipeline or connections to the drum or vessel shall be disconnected or blinded. Stopples or
other appropriate inserts should be applied to nozzle or pipe opening where
flammable/combustible liquids or vapors may be present.
All hollow spaces, cavities or containers shall be vented to permit the escape of air or gases
before preheating, cutting, or welding.
24.3 INSTRUCTIONS FOR COMPLETING HOT WORK PERMIT
Local supervision or individual designated by local supervision shall be responsible for
completing, signed and ensuring all required safety precautions have been taken.
The explosively test to ensure all precautions are met must be verified by local Supervisor or
Designee at the timework is to begin. The individual performing this test must indicate the date
and their names. Tests shall be repeated at sufficient intervals of time to ensure that conditions
do not chance making continuation of the work hazardous.
If a fire watch is required during the performance of Hot Work, the fire watch shall be
maintained for at least 30 minutes after completion of the Hot Work to detect and extinguish
possible smoldering fires. The date and time, along with the individuals name performing the
check, should be indicated on the permit.
This permit does not relieve the group doing the work form responsibility of watching for and
correcting any hazard that may develop during the progress of the job.
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25.0 DRIVERS AUTHORIZATION


25.1 PURPOSE
To provide guidelines that will ensure that TOPPS employees who are selected as drivers of
company motor vehicles are physically, mentally and legally able to operate.
25.2 PROCEDURES
1. All Managers shall be responsible for seeing that their district personnel use good judgment
in the selection of employees to be assigned to drive company vehicles, or other motorized
company equipment.
2. Newly hired employees who are to be assigned to drive or operate company equipment shall
be required to have, at a minimum: a valid operator or Commercial Divers License (CDL) from
their state within the USA, or any other equipment operation certifications that may be
required by federal or state regulations. Before being assigned to drive or operate company
vehicles or equipment, a Motor Vehicle Record (MVR ) screen shall be completed to ensure
acceptable motor vehicle driving record histories. The MVR will be maintained on file in the
TOPPS office.
3. All employees assigned to drive company vehicles shall be responsible for its safe operation
and proper maintenance checks.
4. All employees who will be assigned to drive vehicles requiring Commercial Drivers Licenses
(CDL) shall have completed and on file in the TOPPS Office, a DOT Drivers File. The CDL
drivers shall be required to comply with Federal Motor Vehicle regulations. This file must be updated on an annual basis.
5. All employees assigned to drive company vehicles shall be required to notify their Supervisor
or Safety Supervisor with 24 hours of the occurrence of any work or non-work related motor
vehicle citations. Failure to provide notification shall result in forfeiture of privileges to operate
TOPPS vehicles.
6. All employees assigned to drive company vehicles shall be required to notify their Supervisor
or Safety Supervisor within 24 hours of any arrest for drug, alcohol, or firearm violations.
Failure to provide notification shall result in disciplinary action up to and including termination.

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26.0 BLOODBORNE PATHOGEN EXPOSURE CONTROL PLAN


Purpose and Scope
The Bloodborne Pathogen OSHA Standard (CFR 1910,1030) was established to eliminate or
minimize these types of infections at the work site. This program provides control measures
and procedures to be followed at the TOPPS Well Service work site to prevent the occupational
exposure to bloodborne pathogens and other potentially infectious materials.
Besides HBV and HIV, bloodborne pathogens include any pathogenic microorganism that is
present in the human blood and can infect and cause disease in persons who are or may be
exposed to blood containing the pathogen.
This programs covers all TOPPS Well Service employees who my volunteer to render medical
assistance as part of their job. This includes those employees designated by the company t be
responsible for rendering first aid at the work site, for example contract emergency medical
technicians.
26.1 DELEGATION OF RESPONSIBILITY
The management of TOPPS Well Service is responsible for the implementation of this program
and for ensuring its employees follow the procedures outlined in the plan.
26.2 WRITTEN EXPOSURE PLAN
The written control plan for occupational exposure to bloodborne pathogens will be maintained
at each job site. In addition, a copy will be maintained at the TOPPS office.
The plan will be reviewed, at a minimum, on a annual basis for any necessary updates or
changes.
26.3 EXPOSURE DETERMINATION PLAN
The exposure determination is based on identifying those employees who have an occupational
exposure to blood or other potentially infectious materials when performing their job duties.
Occupational Exposure means any reasonably anticipated skin, eye mucous membrane or
other contact with blood or other potentially infectious materials (OPIM) that may result from
performance of an employees duties. The primary factors to consider include:
1. Probability of exposure
2. Potential routes of exposure
The standard requires an analysis of job task so that job duties can classified into exposure
categories without regard to the use of personal protective equipment. The employees in
categories 1 and 2 compromise the job duties who come under the Bloodborne Pathogen
Standard
Not all TOPPS employees are required to administer first aid or CPR. Employees designated to
administer first aid and CPR includes those who voluntarily take on first aid CPR responsibilities
and are available at the work site.

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TOPPS trains many employees in first aid and CPR as part of the companys ongoing safety
program. The company feels that understanding the seriousness of injuries and illnesses and
the use of learned first aid and CPR skills instills a positive attitude regarding working safely.
Under no circumstances will any employee be required to perform first aid or CPR against their
better judgment.
26.4 METHOD OF COMPLIANCE
In general, the best method of ensuring the health and safety for the workers at risk is to
understand and follow the concept of UNIVERSAL PRECAUTIONS as it applies to and
employees work duties. This concept refers to the assumption that all blood and bodily fluids
are contaminated by pathogens. Instruction in Universal Precautions shall take place during
initial training and annually thereafter.
26.5 ENGINEERING & WORK PRACTICE CONTROLS
Hand washing is primarily work practice control. If this is not available or feasible, then
alternate methods, such as antiseptic hand cleaner or antiseptic towelettes will be provided.
Should these alternate methods be utilized, employees will wash their hands or other affected
areas with soap and running water as soon as possible thereafter.
Employees who bring kits for insulin or other required injections shall be instructed to provide
rigid containers for proper needle disposal.
26.6 PERSONAL PROTECTIVE EQUIPMENT
Latex or vinyl gloves shall be worn when first aid treatment starts and until treatment stops.
Employees shall assume all patients may be infectious. Always wear a new pair of gloves before
treating another person.
Gloves, mouth shields, eye wear and protective clothing (where appropriate) shall be present in
conjunction with company first aid kits. This equipment will be utilized whenever there is a
reasonable probability for blood splashed or contaminated body fluids.
26.7 HOUSEKEEPING
Any exposed surface shall be cleaned of gross material and fluids and then wiped clean any
appropriate germicide after any exposure.
26.8 WASTE HANDLING
All medical wastes, blood specimens, and other body fluids shall be placed in containers that
are color coded and exhibit the biohazard symbol. Medical wastes include but are not limited
to: needles, disposable equipment and items such as soiled dressings and disposable gloves.
The disposal containers shall be constructed so they are puncture resistant, leak-proof and
fluorescent orange in color, displaying the biohazard symbol.
Filled biohazard containers shall be stored and lock in a designated area until sent to an
authorized disposal facility. Documentation of all disposal shipments shall be maintained at the
TOPPS Well Office.

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26.9 HEPATITIS B VACCINATION
Hepatitis B vaccination (HBV) will be made available to all Category 1 and Category 2
employees. It shall be offered after the employee has received the required training and within
10 days of assignment, at a reasonable time and place, and under the supervision of a licensed
healthcare provider.
The employee who chooses not to be vaccinated must sign a declination form (see Appendix
III). This shall remain on file at the TOPPS Office. The employee may later opt to receive the
vaccine again at no charge. If at a later date, booster doses are recommended by the United
States Public Health Service (USPHS), they will be offered to the employees at no charge. HBV
shall also be offered to any employee irrespective of designated category or classification who
has been involved in an occupational exposure incident.
Hepatitis B Vaccinations shall also be made available as soon as possible, but in no event later
than 24 hours, to any employee irrespective of job category and to all non-vaccinated first aid
providers who have rendered assistance in any situation involving the presence of blood or
other potentially infectious material (OPIM) regardless of whether of an actual exposure
incident as defined by the standard may have occurred. An investigation report shall be on
file.
26.10 POST-EXPOSURE EVALUATION & FOLLOW-UP
TOPPS will provide a confidential medical evaluation and follow-up subsequent to the exposure
incident. An exposure incident means specific eye, mouth, or mucous membrane contact with
blood or other potentially infectious materials that result from the performance of the
employees duties
In addition, all first aid rendered incidents involving the presence of blood or OPIM must be
reported to the Manager before the end of the work shift during which the incident occurred.
The report shall contain the following elements:
The manes of all first aid providers who rendered assistance, regardless or whether personal
protective equipment was used.
Description of the incident, including time and date.
A determination of whether or not, in addition to the presence of blood or other potentially
infectious materials, an Exposure Incident as defined by the standard occurred. The
determination is necessary in order to ensure that the proper post-exposure evaluation,
prophylaxis and follow-up procedure required by section (f) (3) of the standard are made
available immediately if there has been an Exposure Incident as defined by the standard.
Documentation of the route of exposure and the circumstances under which the exposure
occurred.
Identification and documentation of the source individual, unless this is prohibited by state or
local law.
The report shall be recorded on a list of such first aid care incidents. This report shall be
available to all employees.
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Collection and testing of blood for HBV and HIV serological status as well as other tests as
deemed necessary will be provided the exposed employee at no cost. TOPPS will provide the
healthcare provider a copy of the OSHA Bloodborne Pathogen Regulations, a job description of
the employees duties as they relate to the exposure, and the circumstances under which the
exposure occurred.
Following any medical evaluation, the attending healthcare provider must provide the
employee a written opinion within 15 days. This written opinion shall indicate any limitations of
the employees ability to receive HBV, and that the employee has been informed of the
results of the evaluation. All finding and diagnosis unrelated to the exposure shall remain
confidential with the healthcare provider and the patient and should not be included in the
written report. The report shall be included in the employees medical records.
26.11 FIRST AID CARE INCIDENT REPORTS
The reporting requirements are specific regarding incidents where employees render first aid in
any situation involving the presence of blood or OPIM, regardless of whether or not and
exposure occurred.
The manager must assure that: 1) provisions for a reporting procedure are implemented. 2) a
list of incidents where first aid assistance is rendered is established. 3) all reports of first aid
incidents are recorded on the list.
26.12 MEDICAL RECORDS
All employee medical records shall be kept confidential and secure during the workers
employment plus one additional year on location.
A copy of the employees records may be released to any authorized party with written
consent of the employee.
These records shall be made available upon request to OSHA, NIOSH, and USHHS or their
designee.
26.13 LABELS AND SIGNS
Warning labels shall be affixed to containers of regulated waste, blood, or OPIM. The label shall
include the biohazard logo depicted on OSHA 1910.1030 (g) Communication of Hazard to
Employees.
The labels shall be fluorescent orange with lettering or symbols in a contrasting color.
Individual containers of blood or OPIM placed in a labeled container for shipment, storage,
transport, or disposal do not need to be labeled.
26.14 INFORMATION AND TRAINING
TOPPS will provide training to all affected employees at the following times:
1. Initial Assignment
2. Within 90 days of the standards effective date
3. Training shall include the following elements:

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4. General explanation of the epidemiology and symptoms of bloodborne infectious
disease
5. Transmission route of bloodborne disease
6. Explanation of the Exposure Control Plan
7. Recognition of exposure situations
8. Selection and use of PPE
9. Information regarding HBV vaccine.
10. Procedures in the event of an exposure
11. Post-exposure evaluation and follow-up program.
12. Explanation of signs, labels, and color coding.
Training for all designated first aid personnel shall include:
1. The role of rendering first aid by TOPPS employees.
2. The availability of the full hepatitis B vaccination series to be made as soon as possible,
but in no event later than 24 hours, to all unvaccinated first aid providers who have
rendered assistance in any situation involving the presence of blood or OPIM regardless
of whether or not a specific Exposure Incident as defined by the standard, has
occurred.
3. The specific reporting procedure which insures that all first aid incidents involving the
presence of blood or OPIM will be reported to Manager before the end of the work shift
during which the first aid incident occurred.
CONTENTS OF TRAINING RECORDS SHALL INCLUDE:
1.
2.
3.
4.

Date of training session


Description or summary of training session
Name of instructor
Name of all attendees.

In addition, instruction in Medic First Aid provides important and useful information in the
section Communicable Disease Protection. Instructors shall remind students to wear
gloves when handling or in contact with bodily fluids and to use barriers when performing first
aid/CPR and wash thoroughly afterwards.
Training records shall be maintained and entered in to the applicable training database, to
insure proper documentation.
26.15 AVAILABILITY OF RECORDS
Employees may review their training records during normal business hours and copies will be
provided to them upon written request. Written request will be filed with employees
personal records.

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26.16 BLOODBORNE PATHOGEN EXPOSURE CONTROL PLAN
Category 1
Job duties that routinely involve exposure to TOPPS has not employees whose routine job
blood or Bodily fluids.
duties involve exposure to blood or bodily
fluids
Category 2
Job duties that normally do not involve TOPPS has first aid trained employees who
exposure to blood or bodily fluids, but are may be required to render first aid at a
trained in first aid procedures.
specific site or location due to a lack of
proximate medical care.
Category 3
Employees in this category are not Typical job classifications may include:
exposed to blood or bodily fluids Supervisor, Safety Supervisor, Manager,
because of their job duties but are trained in Safety Department
first aid procedures to enhance the safety
program of the company and to provide
valuable information and/or skills to use at
home and on or off the job.

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27.0 HAZARDOUS WASTE AND OPERATIONS AND EMERGENCY


RESPONSE ( HAZWOPER)
27.1 INTRODUCTION
Hazardous material is a substance (gas, liquid, or solid) that can result harm to people,
property, or the environment. The purpose of this section is to increase the awareness and
describe the actions taken by employees who are likely to discover and respond to hazardous
material releases.
27.2 SCOPE
Training shall be based on the duties and functions to be performed by each responder in an
emergency response. The skill and knowledge levels require for all new responder in an
emergency response. The skill and knowledge levels required for all new responders shall be
conveyed to them through training before they are permitted to take part in actual emergency
operation on an incident. Employees who participate, or are expected to participate,
emergency response, shall be given training in accordance with the following:
27.3 FIRST RESPONDER AWARENESS LEVEL
These are individuals who are likely to witness or discover a hazardous substance release and
who have been trained to initiate an emergency response sequence by notifying the prior
authorities of the release.
27.4 FIRST RESPONDER OPERATIONS LEVEL
These are individuals who respond to releases or potential releases of hazardous substance as
part of the initial response to the site of the purpose of protecting nearby persons, property, or
the environment form the effects of the release. Their function is to contain the release from a
safe distance, keep it from spreading, and prevent exposure. First responders at this level shall
have received at least eight hours of training in addition to an awareness level training.
27.5 HAZARDOUS MATERIAL TECHNICIAN
Hazardous material technician are individuals who respond releases or potential releases for
the purpose of stopping the release. They assume a more aggressive role by approaching the
point of releases in order to plug, patch, or otherwise stop the release of hazardous substance.
Hazardous Materials Technician shall have at lease 24 hours of training equal to operations
level.
27.6 HAZARDOUS MATERIAL SPECIALIST
Hazardous Material Specialist are individuals who respond with and provide support to
hazardous technicians and act as the site liaison with federal, state, local, and other
government authorities in regards to site activities.
27.7 ON SCENE INCIDENT COMMANDER
Incident Commander will assume control the incident scene beyond the fires responder
awareness level. The Incident Commander shall receive at least 24 hours of training equal to
the first responder operations level.
27.8 METHODS TO IDENTIFY HAZARDOUS MATERIALS
1. Observation and Detection Systems
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2.
3.
4.
5.
6.
7.
8.
9.

Company Labeling Systems


Manufactures Labeling Systems
Material Safety Data Sheets
Stationary Process Vessels Major Facilities
Stationary Process Vessels Small Facilities
Natural Gas Separators
Bulk Storage Vessels
Production Tank Batteries

27.9 POTENTIAL HAZARDOUS MATERIALS IN OPERATIONS INCLUDE:


1. H2S
2. Asbestos
3. Crude Oil
4. Natural Gas
5. Produced Water
6. Treating Chemicals
7. Norm
8. Refer to the location chemical inventory for a complete listing of all chemicals utilized at
your location.
27.10 EXPOSURE TO HAZARDOUS MATERIALS
ROUTES OF ENTRY
1. Inhalation
2. Absorption
3. Ingestion
4. Injection
TYPES OF EXPOSURES
1. Acute
2. Chronic
TYPES OF HEALTH EFFECTS
1. Acute
2. Chronic
3. Local
4. Systemic
27.11 EMPLOYEE RESPONSE ACTIONS
Employees should be trained to react properly and quickly in order to minimize injury or
damage to equipment.
FIRST RESPONDER ACTIONS INCLUDE
1. Care for the injured
2. Call for Assistance (Company Representative, Fire Department, etc.)
3. Approach Incident Scene Carefully
4. Identify Hazardous Materials and Take Necessary Precautions
5. Isolate Release
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6. Determine Volume/Quantity of Release
7. Follow Incident Commander Instructions.
PERSONAL SAFETY
Personnel shall not jeopardize their own or others safety to contain a hazardous materials
release.

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28.0 EMERGENCY RESPONSE PLAN (ERP)


Procedures for handling emergencies are absolutely essential to ensure the protection of life,
property and the environment. TOPPS Well Service Inc. has developed this Emergency
Response Plan (ERP) for the company personnel to define the procedures that are to be used in
the event of a well control emergency at the well site.
The equipment and procedures specified in this ERP address various well control scenarios
ranging from routine well control operations to situations involving a total loss of well control
which necessitate the immediate mobilization of intervention equipment and personnel. This
ERP is general in nature and is intended for use within Navajo land operations.
This document is written with service operations as the primary focus. However, it also applies
to work over and production operations. This plan assumes that adequate oil spill contingency
plans are in place and will be implemented in the event of a well control emergency.
The primary objective of the ERP is to establish a process for responding to and safely managing
well control emergencies. This process includes:
1. Protecting the personnel at the site in the event of a well control emergency.
2. Defining the notification protocols at the onset of a well emergency.
3. Preventing further damage or injury while adequate equipment and personnel are being
mobilized.
4. Defining the critical information that is required in order to determine the appropriate
response level and strategies.
5. Organizing personnel and providing guidelines for their roles during the emergency
response and the subsequent management.
6. Pre-selecting sources and developing mobilization plans for personnel, equipment,
materials and services typically required for implementation of well control procedures.
7. Notification of the appropriate regulatory agencies.
28.1 SHUTTING-IN THE WELL
It is very important to shut-in the well as soon as possible when flow is suspected. The
following procedures are standard industry practices for a hard shut-in of the wellbore:
WELL SHUT-IN PROCEDURES
WHILE DRILLING/ON BOTTOM
1. Space out the drill string and sound the alarm
Position the Kelly or top drive so that no tool joints are in the preventers
If possible, have uppermost tool joint at connection height above rotary table/rig floor
2. Shut down the rotary/top drive and the pumps
Stop rotating
Stop the mud pumps
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3. Check for well flow. If well is flowing, continue with next step (4.)
4. Shut-in the well
Close the designated BOP (blowout preventer)
Ensure the choke is closed
Open the choke line hydraulic opening valve
Verify the well is shut-in and the flow has stopped
WHILE TRIPPING
1. Sound the alarm
2. Stab the safety valve on drill string
Make up fully opened safety valve to uppermost tool joint
Close safety valve once properly made up
3. Space out the drill string
Position the drill string so that no tool joints are in the preventers
4. Check for flow. If the well is flowing, continue with next step (5.)
5. Shut-in the well
Close the designated BOP
Close the choke and open the choke line HOV (Hydraulic Operated Valve)
Verify the well is shut-in and the flow has stopped
RESPONSE LEVELS
This section will aid in determining the requirements needed for personnel and material for
different well situations. TOPPS Well Service Inc. personnel should be consulted in the initial
mobilization, but the operator/ contractor personnel and the drilling consulting company
involved in the project should be familiar with the different response levels. Many well control
emergencies are preceded by a period in which, the potential for sudden escalation is high,
even though primary well control is maintained. The actions taken in this period often make the
difference between a well control problem and a well control emergency.
Well control situations involve an infinite number of variables that make precise classification
difficult.
Often, seemingly insignificant event characteristics can have a major effect on the resolution
and potential for escalation of a minor problem. This section attempts to classify various
situations according to the amount of risk involved, the procedures required to deal with the
situation and other experience-based aspects.
There is no attempt to classify the situations according to the probability and/or frequency of
occurrence. The following sections contain specific situations and trigger points that are
viewed as adding significant complications and/or hazards. Each response level has certain
activities associated with it including notification and/or mobilization of specialized personnel,
information to be obtained, equipment requirements and considerations that should be
analyzed.
The levels are intended for use solely as guidelines. It is highly probable that situations could
develop that defy definition via one of the response levels. These situations will require the use
of judgment and experience in order to determine the appropriate actions to be taken.

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Operators/contractors are encouraged to contact well control specialists any time there is a
doubt about the nature of any well control situation.

28.2 LEVEL 1
LEVEL 1 EVENT DEFINED
Level 1 events involve situations that are either common to routine operations or do not pose
significant risk to personnel. In most instances, Level 1 events can be resolved using standard
operating/ drilling procedures, commonly available equipment, personnel and techniques.
Examples of Level 1 events include, but are not limited to, the following scenarios:
1. Well kicks (influxes) of manageable volume and intensity (usually < 1 ppg) that are not
complicated by mitigating circumstances.
2. Mild to moderate loss of circulation.
3. Loss of production tubing integrity resulting in sustained pressure on production casing
< 50% of casing burst rating. Loss of tubing integrity includes failure of wellhead seals
and downhole equipment.
4. Loss of production casing integrity resulting in sustained pressure on intermediate
casing < 25% of casing burst rating. Loss of casing integrity includes failure of wellhead
seals.
5. Minor surface leaks that can be isolated via remote means or accessed and isolated
manually without significant risk to personnel.
LEVEL 1 RESPONSE
Level 1 event should be corrected through the use of standard industry operating/drilling
procedures. Notification of TOPPS Well Service Inc. will be made at the discretion of the
operator/contractor. No specialized equipment or personnel should be required unless the
Level 1 event escalates.
LEVEL 1 CONSIDERATIONS
Weighting materials and mud chemicals should be evaluated for kick circulation
(consider using drillers method if materials are low or if suspected swabbed kick).
Monitor surface equipment during kick circulation in order to quickly identify any leaks.
Monitor pressure on outer casing string during kick circulation in order to quickly
identify pressure communication between the strings of pipe.
Be prepared to immediately close pipe ram if annular begins to leak.
If productive zones are exposed, monitor well closely for signs of flow during circulation
losses.
Small surface leaks that can be isolated should be isolated remotely if possible.
Adequate safety precautions should be in place before approaching even small surface
leaks.
Closely monitor outer casing strings if sustained casing pressure results from tubing or
down hole equipment failures.

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28.3 LEVEL 2
LEVEL 2 EVENT DEFINED
Level 2 events involve circumstances that are not commonly encountered during routine
drilling operations and pose the potential for significant risk to personnel, equipment and/or
the environment.
A Level 2 event may require specialized well control personnel, equipment and/or techniques in
order to be safely resolved. Examples of Level 2 events include, but are not limited to, the
following scenarios:
1. Well kicks complicated by influx size or intensity (under-balance), pipe off bottom,
plugged tubing / drillstring, washout, plugged choke, etc.
2. Severe loss of circulation.
3. Small surface leaks that cannot be easily or safely isolated.
4. Loss of production tubing integrity resulting in sustained pressure on production casing
>50% of casing burst rating. Loss of tubing integrity includes failure of wellhead seals
and downhole equipment.
5. Loss of production casing integrity resulting in sustained pressure on intermediate
casing >25% of casing burst rating. Loss of casing integrity includes failure of wellhead
seals.
6. Loss of protective casing integrity resulting in sustained pressure on surface casing (any
pressure).
LEVEL 2 RESPONSE
Certain Level 2 events can be dealt with according to established procedures; others require
special consideration be given to personnel safety while implementing these procedures as well
as specialized techniques. The ERP should be activated and the appropriate personnel should
mobilize to the company office and well site. The operator/ contractor emergency response
team should remain in operation until the situation is resolved or downgraded to a Level 1
event.
Operator/contractor should contact and advise TOPPS Well Service Inc. at the onset of a Level 2
event. The operator/contractor should consult with the well control specialists/engineers for
advice on safe handling of the situation. Completed well control information forms should be
sent along with any other pertinent and/or related information.
Arrangements for the mobilization of well control specialists/engineers should be made for, at
minimum, two well control specialists/engineers.
These arrangements should be continually updated to ensure the most expedient mobilization
route until the Level 2 event is resolved or downgraded to Level 1. If mobilization of well
control specialists/engineers personnel is not deemed necessary, the operator/ contractors
office should maintain open and frequent communications with TOPPS Well Service Inc.s office
in Montezuma Creek, Utah. Information related to the situation, as well as results of technical
analysis will be conveyed via telephone, fax, email and electronic file transfer as deemed
appropriate.
LEVEL 2 CONSIDERATIONS
Weighting materials and mud chemicals should be evaluated for kick circulation
(consider using drillers method if material supplies are low or if suspected swab kick).
Monitor surface equipment during kick circulation in order to quickly identify any leaks.
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Monitor pressure on outer casing string during kick circulation in order to quickly
identify pressure communication.
Be prepared to immediately close pipe ram if annular begins to leak.
If productive zones are exposed, monitor well closely for signs of flow during circulation
losses.
If the thrust created by the current or anticipated surface pressure acting on the cross
sectional area of the pipe approaches or exceeds an amount equal to the buoyed weight
of the pipe string, the pipe should be secured at the surface. This may require the use of
conventional equipment such as drillpipe clamps, chains and/or cables. The situation
may eventually require the use of slip rams and other measures. The well control
specialists/engineers should be consulted and mobilized if such a situation develops.
Monitor mud/gas separator equipment for signs of overload while circulating large gas
influxes.
Consider mobilizing additional liquid mud and LCM (loss circulation material) if
conventional lost circulation techniques are ineffective.
Consider the possibility of stripping/snubbing of slick BHA (bottom hole assembly)
versus perforating or severing drill collars to accommodate high concentration LCM
placement and/or barite pills, gunk pills, etc.
Evaluate the possibility of casing failure due to wear as a cause of lost circulation. Note
that this could quickly become a Level 3 event if an influx is taken.
Consider using temperature log to determine exact point(s) of losses (ambient
temperature fluid pumped from the surface will enhance identification).
Prepare to deal with gas migration while preparing to strip pipe to bottom (water-based
mud systems).
Annular BOP (blowout preventer) failure can be expected while stripping if closing
pressure is not reduced. Consult with BOP manufacturer for recommended procedures
and practices for stripping.
Improper bleed-off during pipe stripping can lead to underground blowouts or
additional influxes. Review procedures carefully before attempting to strip pipe to
bottom. Allowances must be made for gas migration and influx elongation due to pipe
entry in water-based systems.
If no pressure increase or a transient pressure fluctuation is observed while lowering
pipe (stripping), an underground flow may be in progress. If this is confirmed, a Level 3
event should be declared.
If surface pressures are too high for safe stripping operations (including situations where
the pipe is light), an off-bottom kill should be considered using volumetric and
circulation techniques (i.e., volumetric control until influx is above bit then constant
bottom hole pressure circulation).

28.4 LEVEL 3
LEVEL 3 EVENT DEFINED
Level 3 events present serious and immediate risks to personnel, the environment and assets.
These situations require the immediate application of specialized techniques and welldeveloped safety assessment and hazard mitigation programs. Examples of Level 3 events
include, but are not limited to, the following scenarios:
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1. Surface blowout (drillpipe, BOP, production tree, broach, etc. with or without fire)
2. Underground blowout with insufficient casing set so that the well cannot be brought
under control by pumping heavy mud simultaneously down the drillstring and annulus
using rig pumps
3. Surface pressure beyond the pressure rating of equipment (including tubulars)
4. Other situations that constitute a clear and present danger to personnel, environment
or equipment that cannot be resolved via conventional means. (ex: crowning out)
LEVEL 3 RESPONSE
Level 3 events will warrant the immediate activation of the emergency response plan,
mobilization of well control specialists/engineers from TOPPS Well Service Inc. and other
specialist personnel and equipment. Operator/contractor should contact TOPPS Well Service
Inc. immediately upon the determination of a Level 3 incident. Completed well control
information forms should be sent along with any other pertinent and/or related information.
The activities defined in the intervention action plan section of this emergency response plan
should be initiated immediately. These include, but are not limited to:
Personnel should be accounted for and moved to a safe upwind location.
Medical attention should be provided for any injured personnel.
The well site should be secured.
Further notifications by the operator/contractors incident command structure (ICS)
team.
Notification to local/state/federal authorities.
Information gathering and assessment of the situation should be initiated.
Complete or partial rig evacuation is likely under most Level 3 events. Re-manning of the rig
should be attempted only under the direction of on-site well control specialists/engineers. If
the arrival of the well control specialists/engineers is delayed, such action(s) should be
discussed in detail and agreed upon with the well control specialists/engineers before
attempted by operator/contractor personnel.
The first task will be to determine the critical aspects of the situation, and perform a hazard
analysis and establish safe working principles for the intervention (i.e., hot zones, safe areas,
access control and accounting, emergency evacuation plans, etc.)
A minimum number of personnel will enter the location. A well site command center will be
designated in a safe area and all operations will be directed from it. Restrictions will be placed
on personnel movement between command post and the rest of the location; personnel
accounting procedures will be established to monitor the personnel on location at all times.
Rig evacuation and shut down will render critical equipment unusable. A plan will need to be
developed to identify components that will be required for intervention purposes and to
provide sufficient power. The equipment that may be needed during such an event includes,
but is not be limited to:
Drawworks Top drive
Mud pumps Bop hoists
Air / hydraulic winches Hydraulic chokes
Bop accumulator charge pumps Iron roughneck

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28.5 IMMEDIATE RESPONSE ACTIONS FIELD


While intervention activities will be dictated by an event's severity and magnitude, the
Immediate Response will be consistent and uniform for any event. This action plan does not
intend to replace sound logic or engineering judgment it is a guideline only. Well control
emergencies require common sense and professional judgment on the part of all personnel
involved in the intervention. TOPPS Well Service Inc. cannot and does not guarantee, warrant
or represent the accuracy of, or accept any responsibility for, the use of any information
contained herein.
Evacuate All Rig Personnel
Evacuate rig and move personnel to designated safe area
Account for all personnel
DO NOT re-enter area until authorized
Secure Location
Secure the perimeter to prevent area population, news media, etc. from accessing the well site
area. Seek assistance from the local police/sheriff agency.
Shut Down Fired Equipment
All fired (or non-intrinsically safe) equipment should be shut down as per established rig
contractor guidelines and procedures.
NOTE! The above actions should only be undertaken if they do not involve risk to the safety
of personnel.
Establish Safety Zone
Based on various criteria, the area immediately around the wellhead is designated the hot
zone. Access to the hot zone is strictly limited to well control personnel.
Based on wind and other conditions, the hot zone may change throughout the course of the
event. The boundaries should be closely monitored and changes made accordingly. The safe
zone is located away from the well and has minimal impact from the blowout. The command
center will be located within the safe zone.
The safe zone should have two means of ingress and egress. Between the hot zone and the safe
zone is the warm zone. Access to the warm zone will be monitored and restricted to essential
support personnel only.
Initiate Fire Watch
Identify any engines that may have been left running.
Identify any other possible ignition sources.
Implement Operators Emergency Response Plan
Notify operators office give status of the incident.
Notify TOPPS Well Service Inc. (435.817.7133).
Identify Hazardous Materials on Site
Identify the material and location on the well site of any hazardous material. Present
information to the well control specialists upon their arrival at the well site.
Monitor Well Conditions
Appoint a rig crew member to observe the well from a safe location outside the hot zone and
record all changes in the flow at the wellhead. Recorded changes should include changes in
flow, noise, etc. The collected information will be important to the well control
specialists/engineers in completing their investigation and analysis of the situation.
Implement Pollution Abatement Measures
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Working in the safe zone only, use heavy equipment to establish the safe drainage and storage
of well flow away from the wellhead area.
Prevent any well flow runoff from entering any public ditch, drainage, culvert or septic system,
streams, waterways, roadways, etc.
A fluid containment plan should be discussed with the well control specialists/engineers and
implemented as quickly as possible.

28.6 INITIAL EVALUATION AND INFORMATION GATHERING


Certain information is crucial in developing an effective intervention plan and immediate
response. This duty will fall upon the operator/contractors personnel at the rig. The following
information should be gathered and documented so that it can be passed on to well control
specialists. Well control forms are shown on Appendices for the collection of this information.
Operation at the time of the incident
Last observed pressures
Present configuration of the well bore casing, drill pipe, drill collars, packers, depths,
geology, fluids, etc. at the time of the incident
BOP equipment in use at the time of the incident
position of all rams, subsea BOP pod status, and top drive safety valves, etc
Last known status of wellhead or BOP components
open, closed, locked, damaged, etc
Rig equipment shut-down level initiated, well control actions implemented
Estimate of flow rates and flow characteristics (gas and water)
Extent of damage sustained by the rig
Size and location of any boil at the surface
Other information as dictated by the situation
The information from the initial evaluation will be conveyed to TOPPS Well Service Inc. for
planning purposes and should be included in the permanent records.
In the initial stages, the information will be used to determine the feasibility of a quick
resolution (i.e., pumping kill fluids, bridging agents, etc.) if it exists.
If possible, this should be done before the situation deteriorates, eliminating this type of
intervention.

28.7 IMMEDIATE RESPONSE ACTIONS OFFICE


Upon notification from the field, the incident commander (the person designated to manage
well control emergencies) shall review the information and, if deemed necessary, enact the ERP
which activates the incident command structure (ICS).
A command center should be designated within the operator/contractors office, if possible,
and the designated command staff and operations staff shall meet to review the current
situation and initiate the various assigned tasks and duties.
The operator/contractors office should immediately contact TOPPS Well Service Inc. to discuss
the incident and possible mobilization of well control personnel and equipment.
TOPPS Well Service Inc. (435.817.7133)
Discussion with well control specialists regarding the initial mobilization of equipment and
personnel will be done at this time. A list of all equipment and services ordered should be
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noted. Information regarding the location, route details, trucking or flying time and a full
manifest, etc. will need to be gathered and properly documented.

28.8 INCIDENT COMMAND STRUCTURE (ICS) ORGANIZATION


A well-developed organizational structure is crucial to effective emergency response. The
incident command structure (ICS) is generally adhered to in defining and establishing a
response organization. The ICS defines an organizational framework with designated positions,
staffing of the positions, responsibilities, notification protocols, and lines of authority. The ICS is
activated with implementation of the operator/contractors emergency response plan. A typical
ICS organization for a well control emergency would look similar to the following:
ICS Command
Incident Commander (Operator) Absolute authority and responsible for all emergency
response efforts and reports to Management and Rig Supervisor
Safety Team (Rig Personnel) Responsible for safety of operations and source control team.
Responsible for the site safety plan and enforcement of safety regulations
The ICS Organization is designed to be easily expanded or minimized based on the size and
severity of the event. In smaller organizations, a single person may be responsible for more
than one role within the organization.

28.9 INTERIM ACTION PLANS


The following tasks can be assigned and implemented while waiting on the well control
specialists to arrive at the well site. If there are any questions or concerns, contact TOPPS Well
Service Inc. before initiating any task.
Do not attempt any task that will endanger personnel.
Monitor Well Conditions
Maintain time log as to the wells condition
Secure Location from Public
Set up a no-fly zone
Utilize local police and fire to handle security and traffic
Organize Well Site Layout
Designate the on-site command center
Identify and designate staging area for well control equipment
Establish communications
Identify and Secure Sourcing of Water
Establish storage for water at the well site
Arrange transportation of water to well site; initiate civil work away from wellhead
Establish second point of access to the wellhead
Grade for pollution drainage and containment
Prep staging area and wellhead site
Initiate Safety Measures
Set up gas monitoring system
Identify safety hazards on location

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Initiate development of site safety plan (Wild Well Control will provide assistance in
finalizing)
Secure emergency medical services/med-evac for the well site
Other Considerations
Potential for event to escalate
Protect collateral assets
Evacuation of population
Voluntary ignition of uncontrolled flow.
Special Considerations for Suburban Settings
Air pollution
Gas plume concentration/dispersion
Smoke
Hydrogen sulfide gas (H2S)
Ground pollution
Contamination of local water supply
Contamination of ditches/public drain systems
Ignition
Explosions
Heat radiation
Other wells
Collateral assets (buildings, homes, etc)
Broaching of surface
Utilities
Power lines
Pipelines

28.10 EVACUATION OF AREA POPULATION


Collect critical information; make informed decision as to requirements for evacuation of
population
Once the decision is made, react quickly
Arrange transportation from the area
Identify and secure temporary housing for evacuees
Set up accounts for meals, groceries, medicines, etc.
Designate company spokesperson to assist evacuees
Communicate directly to evacuees at regularly scheduled times
Be prepared to assist evacuees with incurred expenses
Utilize local law enforcement and fire personnel for assistance

28.11 VOLUNTARY IGNITION


Voluntary ignition of a blowout should be considered if:
Immediate threat to human life (H2S gas cloud)
High uncertainty of successful well intervention at surface
Pollution from well flow (oil) is unrestricted and/or threatens environmentally sensitive
areas
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If the following conditions exist, it may not be necessary to ignite. It is essential that all facts be
carefully evaluated and assessed. It is advisable to solicit assistance from the TOPPS Well
Service Inc. as to what should be the course of action.
These additional considerations include:
Minimal threats (remote area, minimal population involvement)
Uncertainty as to whether burning of flow can be sustained
Ignition creates unacceptable threat to other collateral assets
High certainty of successful surface intervention
Other options possible (diverting, isolation, etc.)
The decision to ignite or not to ignite requires quick and thorough assessment of the ongoing
facts at the well site. Due to the many variables and unknowns, assistance from TOPPS Well
Service Inc. must be sought in making the final decision.

28.12 RESPONSE METHODOLOGY OF WILD WELL CONTROL


Intervention activities will be dictated by the event's severity and magnitude. The activities
required to regain control of the blowout well will depend on specific circumstances and will
vary with each scenario. The course of action(s) will be discussed and mutually agreed upon by
the operator/ contractor and the well control specialists/engineers. In summary, the major
activities of a Level 3 blowout and fire usually include:
Assessment/Evaluation An initial assessment or evaluation by the operator/contractor(s) and
TOPPS Well Service Inc. personnel will determine the course of action, which will result in well
control being regained safely in a minimum amount of time. Equipment requirements beyond
those given in the initial response will be identified.
Site Preparation Will involve various civil works designed to prepare the location for
equipment placement, pollution containment and drainage.
Rig-up Firefighting Equipment To establish necessary firewater cover will involve developing
a method of supplying and storing the necessary water volume (frac tanks/trucks, nearby
natural water supplies, earth pits, etc.).
Debris Removal Will involve clearing of equipment and damaged rig components that impede
access to the wellhead. It may require abrasive jet cutting for severing of heavy structural
pieces.
Capping Placement of suitable control device(s) on wellhead. It may require removal of
existing wellhead and installation of a new wellhead to capping.
Preparations for Kill Operations Will proceed along with intervention and capping
operations.
Divert The well may be diverted following capping operations for additional diagnostics work
or until kill operations are initiated.
Kill Operations Appropriate kill operations will commence following capping. Kill operations
will be based on downhole configuration, casing integrity, and on other issues. Options include
shut-in/bullhead, dynamic kill pump operations, snubbing, etc.
Return Well to Normal Operations Will involve repair to wellhead components, casing repair,
etc.
Remediate Location Remove and properly dispose of any pollution on location

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28.13 TYPICAL EQUIPMENT REQUIREMENTS


Heavy Equipment
The heavy equipment typically required during the course of a well control operation is usually
furnished through local suppliers which are already under contract with the Operator. Typical
heavy equipment requirements may include:
Bulldozers, caterpillar D-8 with tail winches
Cranes, 75 125 ton, hydraulic or lattice boom
Track hoe, caterpillar 235, 200 HP, 2 yard bucket
Forklift, caterpillar 966, 30,000 capacity
Air compressor, 185 CFM, 125 PSI, with 150 foot 300 PSI hose
Light towers, self contained, diesel powered
15 20 Frac tanks, 300-500 bbl capacity each for onsite water storage
Specialized Firefighting/Well Control Equipment
Specialized firefighting/well control equipment is usually provided by TOPPS Well Service Inc. In
response to a well control emergency, the following equipment would typically be mobilized
from Montezuma Creek, Utah:
Athey wagon, with various accessories, conventional or hydraulic
Fire pumps, 2,500 4,500 gpm capacity
Fire monitors with portable shields
Hose container with various suction and output hoses
Fuel tank
Blowout tool container, with miscellaneous support tools
Air compressor

28.14 TYPICAL SUPPORT SERVICE REQUIREMENTS


These services are typically required during the course of, or during some phase of, a well
control operation.
Support services are usually furnished through local suppliers, which are already under contract
with the operator. These services should be put on standby notice, but not mobilized until
requested by TOPPS Well Service Inc. Typical support services may include:
High pressure pumping equipment
Drilling fluids specialist/supplier
Wellhead specialist/supplier
Vacuum tank truck services
Welding crews
Roustabout crew, supervisor with five-man crew
Personnel safety services
Medical/medevac services
Wireline logging services, full diagnostic capabilities
Machine shop services
Once the initial assessment and planning is completed, the well control specialists/engineers
will be able to provide the operator/contractor with a more detailed list of the support
equipment and services that will be required

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28.15 SITE SAFETY PLAN


Prior to initiating any well control operation, a comprehensive site safety plan should be
developed and implemented through the safety section of the ICS.
The site safety plan should cover all safety management aspects of the task at hand. It should
be written so that it is flexible enough for modifications and updates to be easily made and
incorporated.
The site safety plan should be comprehensive and include, at minimum, the following elements:
Site description and identification of sites zones
Hot zone
Warm zone
Safe zone
Site hazards
Physical hazards
Chemical hazards
Toxic/gas hazards
Personal protective equipment (PPE) requirements
Site access
Check-in points
Communications
Safety channel designation on radios
Alarms
Emergency medical services
Environmental monitoring services required
Safety meeting schedule
Safety drills

28.16 HAZARD ASSESSMENT


Safe, successful well control operations require risk identification, mitigation and management.
Thus, the primary function of the well control team (intervention and well control operations
unit leaders) will be hazard identification via a thorough assessment of the situation.
There are numerous potential hazards associated with a serious well control situation. The well
control team, under the direction of the well control operations unit leader, will assess the
situation for the following hazards:
Combustible gas accumulation/dispersion
Accumulations of combustible/flammable fluids
Ignition hazards
Explosive materials
Radioactive materials
Over-pressured surface equipment/potential catastrophic failures
Flow lines anchoring, erosion
Leaking flanges
Stability/competency of the sediment surrounding the rig
Potential instability of rig equipment and tubulars
Hydrocarbon inventories and potential hazards associated with production equipment

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The results of the hazard analysis will be incorporated into the site safety plan. Additional
personnel, equipment, services and/or safety procedures/ measures required to deal with the
identified hazards will be specified and submitted to the field operations team leader.

28.17 H2S OPERATIONS


When drilling in areas of known H2S, rig crews should:
Be trained in H2S safety measures
Have the appropriate safety equipment
Use equipment with proper PSL (priority substance listing) rating for H2S service
Any influx into the wellbore (kick) should be assumed to contain H2S. The size of the influx,
amount of under balance, formation character, weather conditions, etc should be considered
when deciding to circulate out or pump away the influx. If the decision is made to circulate out
the H2S kick, clear the rig floor and restricted area of all unnecessary personnel and take the
following additional precautions:
Rope off the rig substructure to include BOPs, choke lines, choke manifold and mud
return areas and identify as restricted area. No one shall enter these areas without
proper breathing apparatus, H2S monitor, and specific approval from the Toolpusher.
Continuously monitor the H2S concentration level in the mud returns.
The drilling supervisor shall alert affected downwind facilities and population.
The drilling supervisor shall implement any other precaution deemed necessary.

When circulating, all personnel involved in the well control operation will mask-up at
least 30 minutes prior to bottoms up. The flow from the choke should be diverted
through the gas buster and the gas should be flared. The mud stream will return to the
active system where any remaining gas can be removed by the degasser and the use of
an H2S scavenger.

28.18 COMMUNICATION/PR PLAN


Media coverage should be addressed as quickly as possible to prevent incorrect information
and minimize any negative impact to the operator/contractor.
The operator/contractors communication officer, as designated in the companys ERP, will be
responsible for all communication with the media. No employee shall make comments, give
interviews, answer questions, etc. to people outside the company.
Any requests for information will be re-directed to the communications officer as designated in
the companys ERP.
Once the facts and information are known and confirmed, the communications officer should
designate a time and place to make a statement on the companys behalf and answer any
questions.
If there are casualties or the event was catastrophic, it is advisable that TOPPS Well Service Inc.
Employee seek legal counsel and the assistance of a professional public relations firm.

28.19 RELIEF WELL CONSIDERATIONS


Relief wells should be considered for the following scenarios:
Successful surface intervention unlikely
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low probability of surface intervention being successful
Surface intervention operations require undue risks for well control personnel
Well flow broaching the surface
Significant pollution or other environmental damage imminent during long-term well
intervention operation
Multiple relief wells should be considered for the following scenarios:
High hydraulic requirements for kill requires multiple wells
High probability of drilling problems in single relief well effort
High degree of uncertainty regarding blowing wells position
Relief wells are typically engineered, planned and initiated with the assistance of the well
control engineers who understand the technical requirements for a successful well kill
operation.

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28.20 EMERGENCY CONTACT INFORMATION


Name / Company

Location

Phone

Montezuma Creek, Utah

435.817.7133

Aneth, Utah

970.396.6891

McElmo Creek

970.396.1448

Navajo Nation Oil and Gas


Company

Montezuma Creek, Utah

435.651.3475

Utah Navajo Health System,


Inc. (Medical Center)

Montezuma Creek, Utah

435.651.3755

Montezuma Creek Fire


Department

Montezuma Creek, Utah

435.651.3351

Red Mesa Emergency Medical


Service

Red Mesa, Arizona

928.656.5540/ 5542/ 5544

Shiprock Emergency Medical


Service

Shiprock, New Mexico

505.368.6175

San Juan Regional Medical


Center

Farmington, New Mexico

505.609.6156

San Juan Regional Air Care

Farmington, New Mexico

1.800.452.9990

Blanding Police Department

Blanding, Utah

435.678.2334

Shiprock Police Department

Shiprock, New Mexico

505.368.1351

Farmington, New Mexico

505.326.5584

Elaine Topaha-Silas, Owner


TOPPS Well Service
Wilson Dee, Superintendent
Resolute Natural Resources
Nate Benally, EH&S Rep
Resolute Natural Resources

Federal Bureau of
Investigation (FBI)

Disclaimer: The availability of the service referenced in this notice is subject to change without notice. This notice and the providing
of this service does not affect the terms, conditions or coverage of any insurance policy and is not a representation that coverage
does or does not exist for any claim or loss under any such policy.
In no event will TOPPS Well Service Inc. or any of their subsidiaries and affiliates be liable in contract or in tort to anyone who has
access to this publication for the accuracy or completeness of the information contained herein nor do they accept any
responsibility for the use of any information or advice contained herein.

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29.0 SPILL PREVENTION, CONTROL AND COUNTERMEASURES


PLAN (SPCC)
As TOPPS WELL SERVICE, INC. uses or stores oil (including water soluble machining oils) it may
be subject to the Spill Prevention, Control and Countermeasure (SPCC) rule enforced and
enacted by the Environmental Protection Agency (EPA). TOPPS WELL SERVICE, INC. provides
drilling services for oil and gas production, and therefore is subject to the SPCC rule.
The Spill Prevention, Control, and Countermeasure (SPCC) rule was originally promulgated on
December 11, 1973 and was revised on July 17, 2002. In December 2006, EPA issued an
amendment to address a number of issues raised by its 2002 rule, including those pertaining to
facilities with smaller oil storage capacities. On December 5, 2008, EPA amended the SPCC rule
again to provide clarity, tailor requirements to particular industry sectors, and streamline
certain requirements while maintaining protection of human health and the environment (73
FR 74236). On November 5, 2009, EPA promulgated revisions to the December 2008
amendments. This rule is effective January 14, 2010. On October 7, 2010, EPA extended the
compliance date for most facilities until November 10, 2011.
TOPPS WELL SERVICE, INC. has developed this manual as an addition to the Environmental,
Health and Safety Manual to outline procedures to prevent spill and the steps required in the
event of an accidental spill or release of crude oil, hydrocarbon condensate, produced water,
drilling mud, hazardous chemicals, or other deleterious substances. The procedures shall be
followed as outlined in this plan but does not necessarily give employees or any person to use
as replacement for sound judgment. This plan should be used as guidelines only in responding
to a spill emergency or prevention of in accordance with Title 40, Code of Federal Regulations,
Part 112 (40 CFR 112), Oil Pollution Prevention Non-transportation Related Onshore and
Offshore Facilities. These regulations require the preparation and implementation of a Spill
Prevention Control and Countermeasure (SPCC) Plan for all non-transportation related facilities
(onshore and offshore) which have discharged or could reasonably be expected to discharge oil
into the navigable waters of the United States or the adjoining shorelines. The regulations
require that owners or operators (including contractor operators) of mobile drilling and
workover rigs must prepare and implement SPCC Plans for each rig. Owners or operators of
onshore drilling and workover rigs should review the regulations and comply with requirements
applicable to their specific operations and use the attached Tier 1 Qualified Facility SPCC Plan.

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29.1 EMERGENCY CONTACT INFORMATION
Onsite Emergency Contact(s)

TOPPS WELL SERVICE, INC.


Elaine Topaha-Silas (Owner)
435.817.7133 /24-Hour Phone
Resolute Natural Resources
Four Corners
1-888-532-5427 /24-Hour Phone
Navajo Nation Oil and Gas
Four Corners
1-800-889-7437 /24-Hour Phone

Emergency Response Contact(s)

Shiprock, NM Police:

505.368.1350 /1351

Cortez, CO Police:

970.565.8441

Farmington, NM Police:

505.334.6622

Air Care 1:

800.452.9990

N.T.U.A (water):

800.528.5011

Poison Control Center:

800.222.1222

N.N. E.P.A.

928.871.7692

U.S. E.P.A.

800.227.8917

Utah Department of
Environmental Quality

800.458.0145

National Response Center

800.424.8802

Local Emergency Medical Facility

Montezuma Creek Clinic


Montezuma Creek, UT
84534

435.651.3291

Material Safety Data Sheets

OFFICE / DOGHOUSE

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29.2 SPILL PREVENTION
HAZARDOUS SUBSTANCE MANAGEMENT
All hazardous substances, including chemical wastes, are to be managed in a way that prevents
release. The following general requirements are to be followed with the company Hazard
Communication (HAZCOM) / MSDS Program.
Container Management:

All hazardous substance containers must be in good condition and compatible with the
materials stored within.
All hazardous substance containers must be accessible and spacing between containers
must provide sufficient access to perform periodic inspections and respond to releases.
Empty hazardous substance containers (drums) must have all markers and labels
removed and the container marked with the word empty.
Any spills on the exterior of the container must be cleaned immediately.
Flammable materials stored or dispensed from drums or totes must be grounded to
prevent static spark.
Do not overfill waste drums. 4of headspace must remain to allow for expansion

Good Housekeeping:

All hazardous substances must be stored inside buildings or under cover;


Store hazardous substances not used daily in cabinets, or in designated areas;
All chemicals that are transferred from larger to smaller containers must be transferred
by use of a funnel or spigot.
All hazardous substance containers should be closed while not in use;
Use drip pans or other collection devices to contain drips or leaks from dispensing
containers or equipment;
Implement preventative maintenance activities to reduce the potential for release from
equipment;
Immediately clean up and properly manage all small spills or leaks;
Periodically inspect equipment and hazardous substance storage areas to ensure leaks
or spills are not occurring;
Use signage to identity hazardous substance storage or waste collection areas;
Keep all work areas and hazardous substance storage areas clean and in good general
condition.

Secondary containment:

Store all bulk chemicals (>55 gallons) within appropriate secondary containment, or any
sized chemical if there is a potential for release to the environment.
Secondary containment should be checked periodically, and any spills identified in
secondary containment must be immediately cleaned up and removed.

Marking/labeling:
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Ensure all hazardous substances, including chemical wastes, are properly marked and
labeled in accordance with all federal, state and local regulations.
Ensure that hazardous substances transferred to small containers are marked with the
chemicals name (example- Isopropyl Alcohol) and hazard (example- Flammable).

29.3 EMPLOYEE TRAINING


All employees must receive periodic training on the proper handling of hazardous substances;
spill prevention practices, and emergency response procedures. Training must include a review
of the spill prevention and emergency response plan, and a review of location and use of
emergency response equipment. Training can be recorded through safety committee
meetings, staff training logs, or other equivalent record keeping.
29.4 HAZARDOUS SUBSTANCE INVENTORY
An inventory must be maintained for all hazardous substance stored in quantity (<55 gallons),
and/or list of locations where non-bulk hazardous substances are stored (flammable lockersshop floor).
29.5 SPILL RESPONSE EQUIPMENT
Spill response equipment must be maintained and located in areas where spills are likely to
occur. Spill kits should provide adequate response capabilities to manage any anticipated spill
or release. The following general requirements are to be followed:

Stock spill cleanup kits that are compatible with the hazardous substances stored on
site;
Locate spill kits in areas where spills are likely to occur (loading docks, chemical storage
areas, locations where hazardous substance are being transferred);
Spill kits should be sized to managing an anticipated release (spill equal to the largest
container);
Emergency response equipment should be inspected periodically to ensure that the spill
kit is complete.

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29.6 SPILL RESPONSE, FIRST AID EQUIPMENT AND FIRE ALARM LOCATION(S):
Locations
Spill Equipment Content / Inventory

29.7 EMERGENCY RESPONSE PLAN


The Emergency Response Plan (ERP) is a specific plan for dealing with emergencies and shall be
implemented immediately whenever there is a fire, explosion, or release of a hazardous
substance that threatens human health or the environment. TOPPS WELL SERVICE employees
are to read and understand all aspects of the ERP developed. The emergency response plan
shall be reviewed and immediately amended whenever:

The plan fails in an emergency;


The facility changes in its design, construction, operation, maintenance, or other
circumstances in a way that increases the potential for fire, explosions, or release of a
hazardous substance;
The list of emergency contacts change; or
The list of emergency equipment changes.

29.8 RESPONSE ACTIONS IN THE EVENT OF A SPILL OR RELEASE


In the event of a hazardous substance spill or release, immediately take the following measures
to keep the spill from entering sewer or storm drains, spreading off-site, or affecting human
health. In all cases caution and common sense must be maintained with the primary goal being
to prevent and/or limit personal injury.
Stop, contain, and clean up the chemical spill if:

The spilled chemical and its hazardous properties have been identified;
The spill is small and easily contained;
Responder is aware of the chemicals hazardous properties.

If a spill or release cannot be controlled or injuries have occurred due to the release the
following procedures should be implemented:
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Summon help or alert others of the release;


Evacuate immediate area, and provide care to the injured- Call EMS;
If potential fire or explosion hazards exist initiate evacuation procedures- Call EMS;
Respond defensively to any uncontrolled spills:
Use appropriate personal protective equipment when responding to any spill;
Attempt to shut off the source of the release (if safe to do so);
Eliminate sources of ignition (if safe to do so);
Protect drains by use of adsorbent, booms or drain covers (if safe to do so).
Notify onsite emergency contact(s);
Notify other trained staff and/or contracting EH&S Representative to assist with the
spill response and cleanup activities;
Coordinate response activities with local emergency personnel (fire department);
Be prepared to provide MSDS information to fire department, EMT, hospital or
physician;
Notify appropriate agency if a release has entered the environment.

29.9 EVACUATION PROCEDURES


In the event of a hazardous substance release that has the potential for fire, explosion or other
human health hazards the following procedures will be implemented:

Facility staff and others will be notified of evacuation


Notification to emergency services will be performed- Call EMS.
Facility staff will follow predetermined evacuation routes and assemble at designated
areas. Evacuation maps must be displayed throughout the facility.
Individuals responsible for coordinating evacuations must confirm if the business has
been completely evacuated.
Facility staff will be made familiar with evacuation procedures during new employee
orientation, and annual trainings thereafter.
Designated emergency response contacts will coordinate all activities with outside
emergency personnel.

29.10 SPILL CLEANUP AND DISPOSAL


In the event of a hazardous substance release spill cleanup materials are to be properly
characterized to determine if it designates as a NNEPA Hazardous Waste. The designated
onsite emergency contact, with the assistance of Utah Departments of Environmental Quality,
Utah Solid and Hazardous Waste Laws and Rules (R315) and Navajo Nation Environmental
Protection Agency.
29.11 REPORTING A RELEASE
If a hazardous substance spill has been released to soil, surface water, drains or air the
following notifications (within 24-hours) must be performed:

Fire Department (any release that poses an immediate threat to human health,
property or the environment):

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US Environmental Protection Agency Region 8 (any release; notification performed


within 24-hours):
Utah Department of Environmental Quality (any release):
Navajo Nation Environmental Protection Agency (any release):
National Response Center (release of oil or fuel to surface water, or a release of a
chemical with an established Reportable Quantity-RQ)

When reporting a release, prepare to provide the following information (use Spill Report Form):

Your name and telephone number from where you are calling;
Exact address of the release or threatened release, if no address available, decried
location using mile makers, county roads, etc. and give detailed map to location
Date, time, cause and type of incident (fire, air release, spill, etc.)
Material and quantity of the release, to the extent known
Current condition of the facility or drilling location
Extent of injuries, if any
Possible hazards to the public health and/or environment outside of the facility.

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29.12 HAZARDOUS SUBSTANCE INVENTORY
Those materials manufactured, stored, used and/or generated as a chemical waste in quantities >55
gallons.

Hazardous Substance

January 2012

Manufacturer

Quantity/Unit of Issue

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29.13 JOB LOCATION SET-UP (TYPICAL)
Include emergency exits routes, fire alarms, fire extinguishers, spill response equipment and first aid
stations (eye wash, first aid kits, etc.)

2- SCBA / Fire Extinguisher

Mud Pit

Well Head
Pipe Trailer

Workover Rig
Mud Pump

2-Fire Extinguishers
First Aid Kit
Spill Response
Equipment
2- SCBA / Fire Extinguisher

Dog House

January 2012

1-Fire Extinguishers
First Aid Kit
Eye Wash Kit
BloodBorne Pathogens Kit

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SPILL REPORT FORM


This form has been developed by TOPPS WELL SERVICE, INC. to assist employees and reporting personnel in gathering, reporting,
and documenting the information most commonly needed in emergency reports. The use of this form is mandatory by company
employees; all other entities are free to use whatever report/data-capture form they deem advisable.
REPORT DATE

INCIDENT DATE

TIME

REPORT MADE / TAKEN BY

REPORTING PARTY (Person name.)

RESPONSIBLE PARTY (Name of owner, operator, etc.)

JOB TITLE

JOB TITLE

COMPANY (Agency, Organization, Home Owner, etc.)

COMPANY (Organization, Home Owner, etc.)

ADDRESS

ADDRESS

PHONE

PHONE

Incident Information

Source / Vessel / Facility NAME

WATERBODY AFFECTED

INCIDENT LOCATION (Geographic/ Lat-Lon / Street Address)

INJURIES (Name / Incident )


PRODUCT(Type of Pollutant, Diesel/Gasoline/Oil/Sewage, etc):

GASOLINE

DIESEL

HEAVY OIL

OTHER (DESCRIBE):

DESCRIPTION OF SUBSTANCE (Color, Density Odor, etc)


SOURCE & TOTAL QUANTITY ABOARD / AT SOURCE
QUANTITY RELEASED

IS THE SOURCE SECURED?


YES
QUANTITY IN WATER

NO

CAUSE OF SPILL

THREATENED AREAS (Environmentally sensitive):


WATER CONDITIONS: 0 1 FT

2 4 FT

CLEANUP CONDUCTED or ONGOING?


YES
NO

January 2012

Greater than WEATHER


4 FT
CLEANUP CONTRACTOR

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30.0 FLAME RESISTANT CLOTHING PROGRAM (FRC)


This program shall apply to all TOPPS Well Service Inc employees and contractors who work on
or near energized lines, flammable or combustible liquids and equipment and during specified
tasks.
Employees working on or near energized lines or flammable liquids or specified tasks shall wear
an outer most layer of flame resistant work wear. All clothing worn underneath the flame
resistant work wear shall be Company approved FR garments provided to the employee.
Workers shall avoid wearing synthetic undergarments such as rayon, polyester, etc. If the FR
undergarments are unavailable then non-melting material fibers such as 100% wool or cotton
will be acceptable. The minimum Arc Thermal Performance Value (ATPV) for a single layer
garment shall be of a hazard risk category 2 ATPV and Energy of Break open Threshold (EBT)
are both Arc Ratings. Arc Ratings are measurements of protection from the thermal energy
generated by exposure to an electric arc. To determine the Arc Rating, fabrics are tested by
mounting fabric on sensor panels and are exposed to an electrical arc under specified conditions
following the ASTM F 1959 Standard.
The Arc Rating is a measurement in calories of the minimum incident energy measured through
the fabric that will cause the onset of a second-degree burn in human tissue. This Arc Rating is
normally expressed as the ATPV and is the point at which the wearer would receive a second
degree burn. Thus, the higher the ATPV is, the more protective the fabric.
However, if the fabric breaks open before enough energy is measured to cause the onset of a
second-degree burn, the result is expressed as the EBT. Obviously, once a fabric breaks open it
no longer protects the wearer. Both the ATPV and the EBT are expressed in calories per
centimeter, squared.
The consumer will see either ATPV or EBT on the manufacturers garment label. Both are
measures of the thermal protection that a worker will have if he/she is exposed to an electrical
arc. All garments purchased through the approved vendor will meet this minimum requirement
that will protect workers from the expected arc exposure in their work environment.
30.1 RESPONSIBILITIES
The Administration Staff shall:
1. Ensure that this standard is communicated to relevant employees.
2. Ensure that any department-specific procedures which may be developed in conjunction
with this procedure are communicated to relevant employees.
3. Ensure that employees required to work with FR clothing are supplied with enough FR
clothing for the specified tasks to safely perform their required duties.
The Supervisor shall:
1. Approve acquisition of FR clothing for employees.
2. Initiate orders through the Area Coordinator or the Safety Section.
3. Arrange for clothing repair when required.
4. Ensure the FR clothing is being worn in a safe and effective manner during all work on or
near energized lines and equipment and all specified duties.
5. Ensure all costs are assigned to the employees appropriate responsibility centers.
6. Annual operating budgets should contain the necessary amounts to cover anticipated
replacements.
The Employees shall:
1. Ensure that they are properly protected during all work on or near energized lines and
equipment and during specified tasks or procedures.
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2. Maintain properly all FRC equipment and clothing
3. Wear equipment and clothing only during working hours
30.2 PROCEDURE
Employees shall wear Company approved flame resistant (FR) clothing when working on
or near energized lines or equipment or in presence of flammable liquids where a significant risk
of flame is present.
For the purpose of clarity, this policy shall apply to the performance of the following tasks:
1. High voltage (> 750v) rubber glove work performed near.
2. Working near or in a High voltage or Medium Voltage area.
3. Working in proximity to energized high voltage equipment where, due to the nature of
the work, encroachment on limits of approach is possible.
4. Working in the proximity of marked off work location at all times
5. Operating load break elbows and working in the high voltage cabinet of an energized pad
mount transformer.
6. Any Hot Work occurrences
7. Any Electrical conduits that have potential to spark
8. Minimum Protection Required (Mandatory)
The minimum protection required for exposed workers will be the wearing of a long sleeved
garment of an approved FR material on the upper torso. It is essential that the outer layer of
clothing be FR material. Burns can be caused by the transmission of heat through an FR material
which is worn under a non-FR outer garment that ignites.
Layering clothing is highly recommended.
While the minimum requirement for protection from electrical arc is a single layer of approved
FR material, optimum protection can be obtained by wearing additional layers of clothing.
A 100 % cotton T-shirt worn under an FR work shirt will enhance the protection provided by
wearing the work shirt alone. Optimum protection would be obtained by wearing multiple layers
(e.g. FR coverall, plus FR work shirt, plus FR Tshirt).
30.3 SYNTHETICS
Items of personal clothing (especially undergarments) made from synthetics such as polyester,
nylon, acetate, rayon, etc. shall not be worn. Synthetics worn under FR clothing can melt onto
the skin as heat passes through the outer garment resulting in serious burns.
Wherever possible, work clothing of natural fiber such as 100% wool and cotton should be worn.
Because of its weight, denim offers reasonable protection and is especially recommended for
workpants.
30.4 BODY HARNESSES AND TRAFFIC VESTS
Research and testing carried out by several major utilities has concluded that body harnesses
when worn over FR rated garments do not affect the performance of the garment and cause no
significant increase in the risk of burn injury.
Traffic safety vests are flammable and must be removed prior to any exposure to electrical flash
or potential liquid ignition.

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30.5 PROVISION OF FR CLOTHING
In an effort to ensure compliance to the above minimum standard TWS will provide, at no cost to
the employee, FR clothing of an approved type.
Given the nature and varying frequency of the exposures to flammable liquids, clothing will be
made available to employees under one of two scenarios based on the nature and frequency of
work exposures

30.6 FREQUENT EXPOSURES


It is recognized that employees who work full time in the job classifications listed below are
exposed to arc flash hazards and flammable liquids on a frequent basis and will be provided with
FR clothing
This clothing will be issued to the employee as personal clothing and shall be maintained by the
employee without abuse.
The following job classifications are designated:
1. Rig Operator
2. FloorHand
3. Part-time Helper
Employees who have been issued FR clothing will be expected to wear this clothing in
accordance with TWS Employee manual and EH&S Manual. Wearing FR clothing will not be
considered mandatory when assigned to work outside Contracting Companies requirements and
where no immediate or long term harm /injury may occur. To determine clothing requirements
on a day-to-day basis employees are expected to use their own judgment based on current work
assignments.
There are many employees infrequently exposed to hazards where FR clothing is required. For
those employees, the proper allocation of FR clothing must be approved by the employees
immediate supervisor. For very infrequent exposure, a pair of coveralls will provide adequate
protection to workers.
Based on the duration of employment, temporary employees may be required to return garments
prior to lay-off. The Supervisor shall make this determination on a case-by-case basis. In any
event, when clothing is issued to temporary employees they should be advised that they may be
required to return clothing on lay-off and/or termination of employment.
While clothing is personally issued to employees for their exclusive use it is still considered
Company property. Major alterations (such as cutting off sleeves) which compromise protection
and removal of the Company Logo (if applicable) are not permitted.
30.7 REPLACEMENT OF FR CLOTHING
The fabrics used in Company issued FR clothing are selected based not only on the protection
they provide but also for their durability. Under normal conditions, the coverall and shirt fabrics
will out wear regular 100% cotton by as much as fifty percent.
Under this program there are no annual allocations for clothing and after the initial issue,
clothing will be replaced when it is worn to the point that it no longer provides the required
protection. A recommended guideline for replacement is to use the same judgment as would be
used for any work clothing (i.e. replace when worn out).
In the event that a garment gets torn or otherwise damaged, employees are responsible for minor
repairs. In the case of serious damage where the protection of the garment might be
compromised, a determination on professional repair and or replacement will be made by the
employees supervisor. Repairs must be completed with FR cotton and material which can be
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obtained through the Safety Representative. If indications of neglect from employee are present,
employee must replace FR clothing at his/her cost.
The following procedure must be used to replace/re-issue FR clothing:
a) Employee brings clothing article to supervisor for inspection and agreement on
replacement of the article.
b) The correct size shall be established and confirmed.
c) The supervisor initiates an order by informing Safety Representative.
d) The order is sentor picked up by Safety Representative.
e) The supervisor issues the garment to the employee in exchange for the worn
article which will be discarded by the supervisor
30.8 CLOTHING ALLOWANCES: Currently TWS does not provide clothing allowances.
30.9 PERSONAL FR CLOTHING
An employee who is required to wear FR clothing and wishes to wear his/her own
FR clothing will be permitted, provided the clothing meets or exceeds the Company standard for
an equivalent garment. This determination shall be made by the Safety Representative on
consultation with the supervisor and the employee.
Employees are cautioned that there are many Flame Retardant standards and while a garment
may bear a label that says Flame Retardant or Flame
Resistant it may not meet the Company. Prior to purchasing any clothing, employees should
check with the Safety Representative for information.

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31.0 GENERAL AND EMERGENCY RESCUE


This section is designed to provide TOPPS Well Service Inc. employees with guidance to
emergency service rescue techniques and with the foundation skills and underpinning
knowledge to perform safe and effective rescues in most situations.
It does not provide detail on equipment, techniques and procedures for special or technical
rescue. These skills are developed with training to the specific situation and require constant
onsite drills to minimize emergency response and doubt.
Some of the techniques described in this section are of an improvised nature and involve the
use of items of equipment such as ladders in other than their normal modes of operation.
These improvised techniques are included, as it is likely that they will have a wide application in
rescue operations during an emergency situation.
Some general rescue operations are considered to be high-risk activities as they involve rescue
operators in potentially life-threatening situations. This is true for both training and operational
situations and it is important to recognize the risks involved, and to learn to identify, risk assess
and control them. Examples of typical risks for rescue operations include slipping, stuck at high
elevations, falling or tripping over debris and equipment, being overcome by fumes from fuel,
other chemicals or environments lacking in suitable breathable air, and other less foreseeable
events.
There are also risks to employees who undertake unpleasant tasks, which may prove to be
stressful, such as accessing the site of a fatality or body recovery.
It is of paramount importance that all who chooses to undertake training and operations
involving general rescue/disaster tasks do so having regard to the foregoing and are suited to
working in this type of potentially hazardous environment.
People involved in all aspects of general/disaster rescue must also recognize the responsibilities
they have to themselves, their team and others involved, including casualties and personnel
from other agencies.
31.1 PURPOSE
The purpose of rescue is to save life and minimize further injury to people and damage to
property.
Common rescue functions are to:
a. Access, and support and remove, trapped people in the course of rescue
operations
b. Assist with the recovery of the dead
c. Provide support on request to other services, authorities or specialist teams.
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31.2 PSYCHOLOGY
Any situation that requires a rescue operation has, by definition, either dangerous or
potentially dangerous elements. Unless an individual faces a dangerous situation, there is
nothing from which to be rescued.
People tend to react differently to danger, but the most general responses are anxiety and fear,
perhaps the most powerful of all emotions. Remember that it is not just the victim who faces
the danger. The rescuer must enter the site of the dangerous situation and face the same
danger in order to rescue the victim.
Dangers are still often present when the main danger has passed. The biggest difference
between the victim and the rescuer is that the rescuer is better able to cope with, or handle,
the situation. The rescuer has the knowledge and the resources to minimize risk and to remedy
the situation.
It is normal to be anxious and feel fear in the face of danger. These emotional reactions are
common to both victim and rescuer. Many other emotional responses may become manifest
during a rescue situationpity, disgust, contempt, pride, concern and many more. These are
often exaggerated beyond all reason by the urgency and pressures of the situation, thus
lowering the efficiency of the overall operation.
The rescuer must be aware of the psychological needs of victims, not just their physical needs,
and be prepared to meet those psychological needs.
31.3 BEHAVIOR
Given the nature of rescue work, it is particularly important that personal conduct does not
aggravate matters. Personal behavior must assist in creating a feeling that the situation is in
competent hands and everything possible is being done to rescue and care for the victims.
Important general areas of conduct or behavior include:
a. AttitudeMaintain a serious, professional attitude to gain confidence and
support. Arrogance and superiority create instant antagonism. Loud talking,
joking and horseplay reduce credibility and create a feeling of resentment and
disgust. They add to the confusion, hinder the work and add to the state of
anxiety of the victims. Rescuers cannot consider themselves professional if they
add to the confusion by loud shouting or frantic gestures.
b. EmotionsEmotions are hard to control in the best of circumstances. In a
disaster, the control of emotions is a very difficult task. Every effort is to be
made to prevent emotions from influencing good judgment and competence.
The rescuer must remain calm and be sympathetic without becoming

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emotionally involved, regardless of the excitement and the severity of the
incident.
c. CourtesyCourtesy, tact and good judgment are vital. To quickly and effectively
complete the rescue task, give courtesy to all concerned.

31.4 RESCUE PLAN


The success of rescue operations depends principally on the team leader conducting a quick
and thorough reconnaissance of the situation and then, through the appreciation process,
developing a workable plan. Outside of Office area, the Rig Operator is considered the team
leader unless otherwise noted.
31.5 THE APPRECIATION PROCESS
1. The appreciation process is a simple method of problem-solving which is effective in
rescue situations. It involves the logical assessment of the situation and the
reconnaissance, and results in the formation of a workable plan. Rescue operators may
use intuition and experience to enhance this decision making tool.
2. The appreciation process has six steps:
a. Define the problemclearly define the problem to be solved or the task to be
accomplished. The problem may be too large or complex to tackle easily, and
may be divided into a number of manageable elements, each with a set aim.
b. State the aimThe aim is a clear statement of what the team has to achieve in
order to solve the problem. The aim must be clear, concise, and achievable and
expressed in positive terms. The aim will form the mission statement in an
operational briefing, and should be as simple as, for example, to rescue the
casualty from the bottom of the lift shaft.
c. Consider the factorsFactors are points relevant to the problem that has to be
solved. Factors to consider in an operational situation may include:
i)
Number and location of casualties
ii)
Time and space
iii)
Topography
iv)
Weather
v)
Available resources, both personnel and equipment
vi)
Support requirements and availability
vii)
Communications
viii)
Logistics, and
ix)
Priority of tasks.
d. Each factor will lead to one or more logical deductions. The leader should be in a
position to say, if this is the casethen
e. Factors in an appreciation may be set out as in the following example:
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i)
ii)

Factor the casualtys legs are trapped under a heavy steel beam.
Deduction The rescue team must use cutting and lifting equipment
to free the casualty.
f. Thoroughly examine each factor and take care not to introduce irrelevant facts
into the examination.
a. Determine courses openIn the courses open segment, consider all
possible courses that will attain the aim and that are practical. Consider only
facts dealt with in factors; do not introduce new material at this stage.
b. Decide on the best courseAt this stage choose one of the possible solutions
developed by the appreciation process. If more than one workable solution is
produced and the best course is not obvious, apply the following criteria:
i)
Risk: Which solution carries the greater risk factor in its
execution, or the consequence of failure?
ii)
Simplicity: Which is the simplest course?
iii)
Time: If urgency is a factor, which course can be completed in
the shortest time?
iv)
Economy: In terms of resources, which solution imposes the
least demand?
c. Planthe plan will result from the choice of the best course open. That is, it
will be the solution with the most advantages and the least disadvantages.
The plan must be simple, and it must relate directly to the aim. When
completed, check the plan against the following test questions:
i)
Is the reasoning sound?
ii)
Is it set out in logical order?
iii)
Is everything in it relevant to the problem?
iv)
Has anything relevant been left out?
v)
Is it free of uncertainties and ambiguities?
vi)
Is it accurate (positions, timings and so on)?
vii)
Has the aim been kept in mind throughout?
viii)
Can the plan achieve the aim?

31.6 RESCUE BY PHASES


A six-phase process provides a systematic means of conducting rescue operations at a structure
collapse scene. These six phases are internationally recognized and have been adopted by
agencies worldwide.
The REPEAT acronym assists response personnel in learning and remembering the six phases of
rescue operations. The six phases are:

Phase 1Reconnaissance and survey.

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Phase 2Elimination of utilities (risk assessment and controls).


Phase 3Primary surface search and rescue.
Phase 4Exploration of all voids.
Phase 5Access by selected debris removal.
Phase 6Terminate by general debris removal.

PHASE 1RECONNAISSANCE AND SURVEY


Upon arrival at an incident scene, it is critical to conduct a thorough reconnaissance and survey.
During reconnaissance, question victims, witnesses, premises owners/occupiers and others
who may be able to provide information such as occupancy of the building, location of victims,
the reason for the collapse and potential hazards etc. Survey involves a visual inspection of the
scene and may identify such things as the type and size of the structure involved, collapse
patterns, hazards and location of victims.
PHASE 2ELIMINATION OF UTILITIES (RISK ASSESSMENT AND CONTROLS)
Phase 2 is one of the most important phases. It can often be overlooked because of the scene
of carnage presented to the initial response personnel. It involves the assessment of risks and
the application of control measures available to rescuers, such as barricading a rescue scene or
shutting off energy services. It is essential that the control of all risks be completed as soon as
possible.
PHASE 3PRIMARY SURFACE SEARCH AND RESCUE
Systematically search surface areas around the collapsed or damaged structures. Attend to and
extricate any injured or lightly trapped surface victims. During the primary surface search,
rescuers may become aware of victims located within potential voids or within damaged
structures. If this occurs, mark and report their locations to enable rescue personnel with
appropriate equipment and training to safely effect rescues.
PHASE 4EXPLORATION OF ALL VOIDS
In this phase, specially trained and equipped rescue personnel explore those places that have
been marked, and all other places where trapped victims might have survived the collapse even
when there is no evidence of the presence of such victims. If possible, use technical devices
and/or canine search teams to verify the location of trapped victims.
PHASE 5ACCESS BY SELECTED DEBRIS REMOVAL
Phase 5 involves the selected removal of debris to access trapped victims. This requires special
rescue personnel and equipment. In general, the victims chance of survival decreases with
each succeeding phase. Many people buried under debris in this phase will be deceased but
explore their positions nevertheless and locate all victims before work starts on Phase 6.
PHASE 6TERMINATE BY GENERAL DEBRIS REMOVAL
Phase 6 involves the use of heavy plant and machinery to remove all of the structure debris in
an attempt to recover and account for all victims. This phase also involves the use of forensic
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processes to identify victims. It is important to note that, unless special orders to the contrary
are given, a rescue operation must be carried on diligently without interruption until Phase 6 is
completed. Every person known or likely to have been in the structure must be accounted for.
It is impossible to tell from an external inspection of a pile of debris whether victims buried in
the debris will be alive or not. Even the most tightly packed debris may be quite loose
underneath and, in fact, experience has shown that this is often the case. In the absence of
specific instructions to the contrary, there should be no relaxation of effort until this phase is
complete, no matter how long the work may take.
31.7 LOCATION TECHNIQUES
Once surface and/or lightly trapped victims are removed, surface search and rescue operations
should focus on searching for, locating and marking positions where contact is established with
victims and where voids that potentially contain victims are discovered.
The techniques used to achieve this include line and hail search, and canine search.
LINE AND HAIL SEARCH
A Go area of the collapse site is selected in accordance with the search priorities that have
been established.
Note: To ensure that no area is left unsearched, mark the search line position prior to any
adjustment. This provides a point to which it should return.
The line and hail search team members
excluding the team leader stand in a
straight line approximately 4 to 6 ft
apart at the edge of the structure
collapse site.
The team leader coordinates the search
from behind the team or from a
vantage point, ensuring he/she can see
all the team members. This ensures the
team leader can listen and watch for
signs of a response as indicated by the
team members. The line of team members is numbered sequentially from the team leaders
left-hand side, starting with number one.

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The team leader gives the order, Quiet
on the site, and instructs team member
number one to commence the search
call.
The first team member calls into the
rubble, Rescue team working above,
can you hear me? The entire rescue
team listens for a response for 15 to 20
seconds. If nothing is heard the team
member shouts, Nothing heard. The
next member in line then repeats the
call. After all team members have called
and there is no audible contact, the team leader instructs the team to advance 3 ft (one step)
into the search area, where the process is repeated.

HEARING A VICTIM
Any team member who hears a call or any
other noise coming from the structure
collapse site must raise an arm until
acknowledged by the team leader. He or she
must then point with an arm fully extended
in the direction he or she believes the noise
is coming from and remain in that position
until otherwise directed by the team leader.
The team leader can then move individual
team members to pinpoint the source of the
noise (that is, vectoring).

CONTACT WITH VICTIM


If contact is established, the rescuer must question the victim if the victim is able to speak. The
questions should focus on receiving information, which will help the team leader to assess the
situation.
Questions should focus on the nature of the victims injury (if any), possible openings in the
vicinity of the victim, the number of other victims trapped in the vicinity, and any other relevant
information. During the assessment the team leader should try to establish if any breaking,
breaching or shoring is required to rescue the trapped victims. If the trapped victims can be
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removed without breaking, breaching or shoring, extricate the victim. If this is not the case,
Special rescue operators will be required to free the trapped victim.
The site team undertaking the line and hail search must mark the position of the trapped victim
using a marking system and leave two team members with the trapped victim to maintain
contact until special rescue workers arrive. Once communication has been established with a
trapped victim, it should be maintained as far as it is practically possible to do so.
The communications will:

Maintain the victims morale


Help them to withstand whatever pain and discomfort they may be suffering (and may
even keep them alive)
Help rescue personnel to work in the right direction (sometimes a difficult task in the
dark), and
Assist the emergency response personnel with information about displacement or
movement in the debris that is likely to cause further injury.

31.8 SAFETY IN TRAINING AND OPERATIONS


The task of rescue involves the training of individuals and teams in a variety of skills, some of
which, unless properly carried out, may well prove dangerous to the individual rescuer, the
team, casualties or bystanders. In all cases, the safety of rescuers is of prime importance.
It is necessary, therefore, particularly in the early stages of training and exercises, to pay a great
deal of attention to safety measures, and to emphasis the need to strictly observe and enforce
these measures.
Note: Carry out all rescue training and operations with due regard to state agency/ Navajo
Nation agency and contracting company protocol, occupational health and safety requirements,
codes of practice and standard operating procedures.
Many of the safety precautions to be observed are merely commonsense. Unfortunately, they
are so basic and simple as to be often overlooked.
31.9 BASIC PRECAUTIONS
Appointed safety officers will conduct any exercise or other activity in the rescue field. Team
leaders and employees on site are responsible for safety at other times. Obey the orders given
by the officer without question or delay, as they are vital to safety.
Regularly and carefully check equipment, both before and after use. Ropes can wear and rot,
batteries can corrode equipment, and machinery can break down. Faulty equipment can cost
lives.

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Immediately label any faulty or suspect equipment and remove for repair or replacement (for
example, the rope which a rescuer did not check and which was damaged may kill someone the
next time it is used).
Protect personnel at risk at heights or depths with properly established and monitored safety
lines and systems.
Wherever possible, adhere to standard techniques and practices in the rescue field.
Never ignore or exceed safety limits and margins. In any rescue technique, safety limits and
margins have been built in to protect the casualty and the rescuer.
31.10 PROTECTIVE CLOTHING AND SAFETY
Each employee is required to wear protective clothing, safety boots, eye protection, and
helmets. Each piece has an obvious safety application and must be properly used.
Wear helmets, in particular, at all times of risk, whether great or small. Helmets are designed to
protect the wearer from a single impact. Never mistreat them by dropping, throwing or sitting
on them, and never leave them exposed on the back window-ledge of cars for prolonged
periods.
Maintain and replace all safety equipment in accordance with the provisions of
State/Territory/service policy and Australian Standards.
31.11 RESCUE/ SAFETY HARNESSES
Personnel working at heights or in similar dangerous environments require the protection and
safety of a harness. A properly fitted climbing, rescue or safety harness is essential. Waist belts
or tie-ins are not acceptable. Use a rated harness attachment and secure the rope or strop to
the harness by this device at the approved point.
Most industrial safety harnesses are not suitable for rescue. They have no dynamic fall arrest
capability, and their attachment points are normally not suited to rescue techniques. They are,
however, acceptable for low-risk static situations.
31.12 RESCUE TECHNIQUES USING NO EQUIPMENT
Clearly understand that the following techniques are for use in an emergency and that seriously
injured casualties should, where possible, be placed on a stretcher.
Conditions such as fire or imminent danger of building collapse may, however, dictate that
removal from the scene is the first priority. In some cases, this may even take precedence over
life-sustaining first aid.
31.13 RESCUE HANDLING TECHNIQUES

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SINGLE-RESCUER HUMAN CRUTCH


For this method to work, the casualty must be conscious and capable of
giving the rescuer some assistance. Figure 7:26 clearly indicates how to
affect the single-rescuer human crutch.
Note the position of the rescuers hands, one holding the casualtys
wrists and the other taking a firm grip of the clothes at the waist on the
far side of the body. The injured side of the casualty should be closest to
the rescuer.

PICK-A-BACK
This is an effective method when conducted correctly and the casualty is
lighter than the rescuer.
When the casualty has been loaded (must be conscious), take care to
ensure the casualty is supported well up on the rescuers hips, with the
body literally draped across the rescuers back.

FIREFIGHTERS CRAWL
This is an invaluable method where a casualty has to be removed from a
burning or smoke-filled building. As shown in Figure 7:28, both rescuer
and casualty have their heads low down where the clearest and coolest
air is to be found if the building is on fire. It is also clear that the entire
weight of the casualty does not have to be supported by the rescuer.
Cross the casualtys hands and tie with a bandage or similar. Vary the firefighters crawl method
according to personal preference. Probably the most effective method is for the rescuer to
place an arm, shoulder and head through the casualtys arms as shown.

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REMOVAL DOWN STAIRS METHOD
This method is used to recover a
heavy casualty down stairs, when the
rescuer cannot use the pick-a-back or
other methods. However, its use
need not be restricted to staircases.
With the casualty lying flat, first tie
the wrists together using a triangular
bandage or similar.
Next, come to the head and lift the
casualty into the sitting position.
Reach through under the casualtys
arms and grasp the wrists. The rescuer is then in a position to drag the casualty backwards and,
if a staircase has to be negotiated, a large measure of support can be given to the casualtys
trunk by the rescuer using a knee to ease over each successive step. Remember that the
strongest part of any staircase is close to the wall.
HELPING A CASUALTY DOWN A LADDER
Take great care when helping a person down a ladder, even if that person is conscious and
uninjured. Keep in mind that many people are unaccustomed to height and may freeze-up or
lose their hold.
a. Take a position, one rung below the casualty, with arms encircling the casualtys
body and grasping the rungs.
b. Keep in step with the casualty, letting the casualty set the pace. Keep knees close
together to ensure support in case the casualty loses hold or becomes
unconscious.
c. Talk to the casualty to help
keep up morale and
overcome fear.
d. If the casualty becomes
unconscious,
let
the
casualty slip down until the
crutch rests on the rescuers
knee. By repeating this
procedure for each step
down the ladder, the
rescuer can lower the victim
to the ground.

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TWO-RESCUER HUMAN CRUTCH
As can be seen, this method is similar to the
single-rescuer human crutch, except that the
casualty is supported on both sides with the arms
of the rescuers crossed over on the casualtys
back and grasping the clothing on the opposite
sides of the body.

TWO-HANDED SEAT
Rescuers kneel on either side of the casualty, get
the casualty into a sitting position, place one arm
under the knees and link up with the hand-towrist grip. They cross their free arms over the casualtys back, where they get a firm grip on the
clothing (Figure 7:32).
The leader gives the normal orders for lifting and lowering.

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THREE-HANDED SEAT
This method gives the casualty good support and is reasonably comfortable for the rescuers. It
has the added advantage that the two-rescue team has a spare hand for steadying.
One rescuer grasps their left wrist with their right hand and the second rescuer places their
hand and wrist as shown in Figure 7:33a. This forms a seat. If the casualty is capable of standing
for a short period,
load the casualty
by placing the
seat under the
buttocks. If not,
the rescuers place
their hands under
the
casualtys
knees first and
then join up. In
either case, the
result should be
as in Figure 7:33b.

FOUR-HANDED SEAT
This is a method where each rescuer grasps their left wrist and joins hands. This provides a
comfortable seat for the casualty and places a minimum strain on the rescuers. However, as
can be seen in Figure 7:34b, the casualty must be sufficiently conscious to hold on.

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THE FORE AND AFT METHOD


This is perhaps the most suitable way in which two rescuers can handle an unconscious
casualty.
Prepare the casualty in the same way as
for the removal down stairs method. That
is, tie the wrists together. The first rescuer
stoops at the rear of the casualty.
Reaching under the casualtys arms, the
first rescuer grips the casualtys wrists. The
second rescuer stoops between the
casualtys legs, grasping the casualty
underneath the knees. Following the
standard lift orders, lift the casualty to the
carrying position (Figure 7:35a). If the
casualty has a leg injury, minimize the
effects of this by having the front rescuer
cross the casualtys legs over and carry the
casualty to one side.
The advantage of this method is that the
rescuer supporting the casualtys feet has
a free hand with which to open doors,
clear debris etc.

It is again stressed that the foregoing one


and two-rescue techniques are generally
confined to emergencies where removal
from the scene is the first priority.

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IMPROVISED SINGLE-POINT LOWER
Use the improvised single-point lower method only when immediate evacuation of a casualty is
imperative due to fire or another emergency combined with a lack of equipment.
Use an 11 mm rescue rope and a casualty support knot or a stretcher for this technique, which
consists of taking two Round Turns around a sound anchor point as a belay. Use two rescuers
wearing gloves and lower the rope hand-over-hand.

31.14 IMPROVISED
There are a number of methods of forming improvised harnesses out of slings. It is mandatory
however that proper instruction be provided in their fitting use.
Improvised rings can take the form of chest or sit harnesses or a combination of both to form a
full body harness can readily be used in lieu of a commercial product.
The Parisian Baudrier illustrated is one form of improvised chest harness in common use. A
standard tape sling of around 2500 cm circumference is taken around the body in the manner
shown and secured with a double sheet bend.
Because of anatomical variations and the range of different vertical activities no one harness
will suit all rescuers or situations. Harness selection is a matter of trying a range of types in a
hanging situation and selecting the most comfortable and suitable.

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Every rescue situation requires special consideration before attempting any type of rescue. The
techniques covered in this section shall be considered as guidance to emergency rescue. If an
employee will be potentially harmed during a recue event, the employee is not authorized to
attempt the rescue. Remember to use caution and sound judgment in every instance.

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32.0 EMPLOYEE SAFETY ORIENTATION


POLICY
All new employees, newly promoted employees, and transferred employees shall complete a
safety orientation prior to their job assignment or reassignment. The Safety Supervisor shall
conduct the safety orientation.
PROCEDURES
Have a discussion of TOPPS Well Service. Safety Policy to ascertain the employees
comprehension of the information in the Policy.
Instruction shall be provided in the correct use o mandatory personal protective equipment
such as steel-toed safety footwear, hard hats, and safety glasses.
Instruction shall be provided in the use of emergency equipment such as fire extinguishers,
first-aid equipment, and water, gel blankets.
A tour shall be conducted of the new employees work area, pointing out specific hazards or
precautions to be taken on the job.
All employees will receive proper employee orientation prior to work assignment.
32.1 EXAMINATION
TOPPS Well Service, is sincerely interested in the safety of all is employees. We try to provide a
safe and healthful work environment. Also, we provide safety training as a means to enable you
to work in a safe and productive manner. Constant reminders will be provided for you to work
safely. If you are not doing your job safely, then you are not doing your job.
The following program is provided to acquaint you with TOPPS attitude toward safety and to
let you know what we expect from you. Read through this orientation questionnaire as you
come upon them. You may refer back to previously read materials to get the answers. When
you are finished, check your answers with answer key in the back.
A. PRODUCTION WITH SAFETY
TOPPS concerned about the safety of its employees. In fact, safety of its employees ranks
above all other concerns. Naturally, production is also a major concern, but TOPPS does not
want production without safety. TOPPS wants you to be both a safe and productive employee,
which means you are aware of and practice its safety rules an regulations as prescribed in
TOPPS safety policy manual. If you are not doing your job safely, then you are not doing your
job.
B. THE ATTITUDE OF A SAFE WORKER
TOPPS want safe workers who are careful to avoid injuring themselves as well as fellow
workers. Remember that TOPPS does not want employees who endanger their own lives as
well as those around them. The most important factor that determines a safe worker is his/her
attitude. Safety in the oilfield is no joke. It is extremely hazardous, as evidenced by the type of
accidents that have occurred in the past. However, regardless of the conditions you face in your
day to day work, you can be safe if you have the proper attitude and think before you act.
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C. TOPPS WELL SERVICE INC BELIEVES the vast majority of accidents are preventable. Every
employee, including management, is responsible for preventing accidents. It is your job to avoid
any unsafe acts and report any unsafe conditions as soon as possible to your supervisor. Unsafe
conditions should also be reported to the Safety Supervisor. Do not overlook any unsafe
condition because it could result in a accident. By reporting and correcting unsafe conditions,
you are not doing your part to ensure a safe environment.
D. DISCIPLINARY ACTION
Compliance with safety rules, regulations and practices are a condition or your employment.
Violators of safety rules, regulations and practices not only endanger themselves and their
fellow employees, but also are subject to disciplinary action. For everyones sake, safety will
not be taken lightly and these rules will be enforced and termination of employee(s) will be
inflicted.
E. PERSONAL PROTECTIVE EQUIPMENT
Personal protective equipment is provided for your protection. Failure to wear this equipment
may result in personal injury to you or others. Remember that you are expected to work in a
safe manner, which includes wearing the proper protective equipment. Employees
cooperation is essential if personal protective equipment is to provide the protection for which
it is designed.
F. HARD HATS
Hard hats are provided to protect you against head injuries and to emphasize safety and to
encourage safe working practices. Hard hats are to worn at all work locations, regardless of the
work involved.
G. EYE PROTECTION
Protective eye and face equipment will be required where there is a reasonable possibility of
injury that can be prevented by such equipment. Check with your supervisor to be sure of eye
protection requirements at your work location. All employees who normally wear corrective
eyewear shall be required to wear either industrial safety eyewear or goggles over their regular
prescription spectacles if their duties expose them to eyes hazards or if they are required to
visit locations where eye hazards exist. If you wear contact lenses and they are required for
medical reasons, chemical splash goggles will be worn at all time. Contact lenses are not to be
worn in known H2S environments.
H. EAR PROTECTION (EAR MUFFS, PLUGS, ETC.)
Ear protections will be worn whenever signs are posted requiring their use. TOPPS will provide
appropriate hearing protection. We encourage hearing protection be worn al all times around
high noise levels while on or off the job.
I. SAFETY MEETINGS
Every employee is required to attend safety meeting when held. Safety meetings are a vital part
of TOPPS overall Accidental Prevention. These meetings serve the following purposes:
1. Identify and correct hazardous conditions in the working environment.
2. Create safety awareness within all employees.
3. Stimulate and maintain interest in accident interest.
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4. Provide an opportunity for each employee to express his/her ideas, which promote and
improve the safety program.
5. Instruct and train employees in safe methods of performing their work.
6. Keep employees informed of accidents and near misses at their locations.
Employee participation is necessary for a successful safety meeting. Dont be shy, your
contribution to this meeting could save anothers life.
J. TAILGATE SAFETY MEETINGS
Tailgate safety meetings are before and during jobs that require special safety considerations or
as a review for routine jobs that present hazards to the employees. A tailgate meeting is simply
an on-the-job safety meeting in which the proper procedures for the job are discussed. Also,
any possible hazards are discussed. A few minutes spent having a tailgate meeting could save
an injury. Tailgate safety meetings should be recorded and sent to the safety department for
review and filing.
K. ACCIDENT AND INJURY CAUSES
Accidents and injuries could be caused by many factors. Bad attitudes, poor housekeeping, lack
of personal protective equipment, carelessness, bypassing safety devices, unsafe work practices
and a lack of knowledge are just a few of the possible causes, Remember, if you have any
questions about a particular job, ask your supervisor. Never perform a job when you are not
aware of the possible hazards that may exist. Unsafe acts can result from a lack of knowledge or
awareness. ASK QUESTIONS!!
L. REPORTING INJURY, ACCIDENTS AND NEAR MISSES
All injuries and accidents, no matter how minor, shall be reported to your supervisor as soon as
possible after the occurrence. An accident report will be filled out whether it is an automobile
or personal injury accident. This will be the responsibility of the supervisor.
M. CONCLUSION
TOPPS Well Service accident history is very low at this time. Our low accident rate is partially
due to the fact that we are trying to ensure a safe and healthful work environment, but the
majority of the credit must be given to your employees who realize the importance of safety
and work accordingly. You are the bottom line in preventing accidents. PLEASE WORK SAFELY
and always Remember Safety TOPPS the List at TOPPS Well Service Inc.

EMPLOYEE NAME (PRINT) _______________________________________________


I HAVE COMPLETED THE EMPLOYEE SAFETY ORIENTATION SECTIONS I AND II, AND I HAVE BEEN
GIVEN A COPY OF THIS POLICY.
Employee Signature______________________________ Date________________________
Supervisor Signature______________________________Date_________________________
Safety Supervisor Signature ________________________________ Date________________

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