SAFETY MANAGEMENT SYSTEM MANUAL

SAFETY

MANAGEMENT

SYSTEM

(SMS)
MANUAL

COPY NUMBER:

HOLDER:

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SAFETY

MANAGEMENT

SYSTEM

(SMS)
MANUAL
THIS DOCUMENT SHALL BE SUBJECT TO FORMAL REVISION
CONTROLS ONLY WHEN OVERSTAMPED “CONTROLLED COPY” IN
RED INK AND THE CONTROL COPY NUMBER IS ENTERED BELOW.

COPY NUMBER:
HOLDER:

THIS DOCUMENT IS THE PROPERTY OF TUBOSCOPE (UK) LTD EASTERN

HEMISPHERE OPERATIONS. IT SHOULD NOT BE COPIED OR REPRODUCED IN
ANY FORM WITHOUT THE CONSENT OF TUBOSCOPE (UK) LTD.

ISSUE STATUS:-

ISSUE EFFECTIVE DATE

A MAY 1998

PREPARED REVIEWED AUTHORISED SIGNATURE DATE

J.H. BULLOCH J.E. BUTTON P.STUART
VICE PRESIDENT

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AMENDMENT RECORD

PAGE NEW
SECTION DESCRIPTION REF. DATE/AUTH
NO REV

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CONTROLLED COPY HOLDERS

Copy/Chart LOCATION
NAME TITLE
Number P Y
0.0 • P. Stuart VP Eastern Hemisphere x
5.0 • C. Harriman Regional Mgr. North Sea x
5.1 • I Newell Ops Mgr Solids Control x
5.2 • R. Samuel Ops. Mgr. Coating / Insp. x
5.24 • J Leggett Operations Supervisor x

11.2 • J. Bulloch QA / Safety Manager Originals

LOCATION KEY:-

P – PORTLETHEN,
Y – GREAT YARMOUTH
• - Denotes Controlled Copy of SMS Manual
Holders of Procedures Manual

Document Control

All of the above noted copy holders shall receive authorised updated
pages from the Safety Manager or designee. The above senior site
managers may also distribute “Controlled Copies” of the SMS manual
within the areas of their responsibilities.

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(I) Amendment Log Sheet

(II) Distribution List
(III) Contents
(IV) Foreword to Safety Management System

1.0 SAFETY MANAGEMENT SYSTEM OVERVIEW

1.1 HS & E Management Philosophy
1.2 Scope of the SMS
1.3 SMS Documentation Structure
1.4 Project Specific Safety Plan
1.5 Performance Monitoring

2.0 HEALTH, SAFETY and ENVIRONMENTAL POLICY OBJECTIVES

2.1 HS & E Policy Statement
2.2 HS & E Objectives

3.0 HEALTH SAFETY and ENVIRONMENTAL RESPONSIBILITIES

3.1 Responsibilities against Policy Objectives
3.2 Responsibilities against job positions

4.0 ORGANISATION for HS & E MANAGEMENT

4.1 Company Organisation
Organisation charts – Appendices 1 to 5

5.0 WORKFORCE INVOLVEMENT in HS & E MANAGEMENT

6.0 ELEMENTS for SAFETY MANAGEMENT

6.1 Personnel Management
6.2 Risk Management
6.3 Communication
6.4 Occupational Health
6.5 Work Procedures and Controls
6.6 Environmental Management
6.7 Contractor Safety Management
6.8 Accident & Incident Reporting & Investigation
6.9 Contingency Planning
6.10 Performance Monitoring

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Tuboscope (UK) Ltd provides an essential support service and equipment supply to
many companies within the Oil and Gas Industry. In providing this service the
company recognises that its operations may involve potential hazards and therefore
it is the primary and continuing policy of the company to identify all such hazards
and, through the implementation of management systems, to reduce the risk to all,
as is reasonably practical.

In meeting this commitment, Tuboscope is aware of its responsibilities to protect

and secure the health and safety of its employees, its sub-contractors and any
persons who may come into contact with the Company during the course of their
activities. In addition we recognise and take fully into account, the effect of our
activities on the environment, in which we live and work.

To provide a structured approach towards achieving our objective, the Company

has developed this Safety Management System (SMS). The term SMS encompasses
all of our activities connected with health, safety and the environment, which
contribute towards the establishment of a “safe system of work”. Legislation and
current industry practise however, necessitates that we re-structure these into an
auditable management system. This document, level 1 of the system, together with
its support documentation provides a single source of reference for all HS & E
related affairs within the Company Divisions as listed below.

Safety must be considered an integral part of the daily responsibility for all
managers, supervisors and employees. Your co-operation and positive contribution
is achieved by your understanding and participation in effectively implementing this
Safety Management System.

SAFETY MANAGER

This manual is applicable to the following Divisions of Tuboscope (UK) Ltd:

Brandt Solids Control Division

Tuboscope Inspection Division
Tuboscope Coating Division

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1.1 HS & E Management Philosophy

The Company strives to achieve a philosophy of continuous improvements in it’s

management of Health, Safety and Environmental Affairs modelled on HS (G) 65
“Successful Health & Safety Management” (see section 1.7 for details).

Successful HS & E Management relies upon the relationship between management

philosophy, policy and objectives, employees and contractors, facilities and
equipment. The Vice President has established HS & E objectives, the intent of
which has been adopted by all of the affected divisions within the Company and
made specific to these divisions. In line with Health and Safety Executive guidance
these objectives are:

• Specific
• Measurable
• Achievable
• Realistic
• Timescoped

The objectives are achieved by implementing the key elements of safety

management, which form the body of the SMS. These, together with the interfaces,
are demonstrated on the figure below. Each division philosophy of continuous
improvement is achieved through the procedures of audit, inspection and
management review which form the control loops essential to identifying areas of
improvement and implementation of the improvement plan.

Management
Philosophy
Policy and Objectives
Personnel Management Operations
Communication Audit Occupational Health
Occupational Health Inspection Environmental Management
Incident Investigation Maintenance

Employees / Hazard Management

Job Procedures Facilities /
Contractors Contingency Planning Equipment

Successful implementation of this philosophy provides the safe system of work which
is inherent in the Safety Management System.

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1.2 Scope of the SMS

The Safety Management System (SMS) is an integral part of the way the Company
carries out its business of providing support services to the oil and gas industry. As
such it is integral with all aspects of Company activity and is allied to the quality
management system.

The Safety Management system Manual (Level 1) provides the policies, objectives,
organisation and responsibilities in addition to an overview of the key elements
established to achieve the objectives. This document is synonymous with the Quality
Manual, the intent being to provide a standardised approach, as far as possible,
between HS & E, it forms the basis for employee instruction to increase the level of
understanding of HS & E affairs. In this way employees are in a better position to
participate in the process of continuous improvement.

Level 2 of the SMS provides the procedures, which make up the key elements of
safety management. The format of the procedures is based on the Quality
Management System to maintain standardisation. Where common procedures exist
within the quality system, they are only referenced in the SMS to avoid duplication.
The procedures define the management standards of who is going to do what and
when. In this way performance monitoring can be established.

Level 3 of the SMS provides the working instructions. These are detailed instructions
to be utilised by employees at the workplace. They are developed in conjunction with
the employees so that maximum benefit can be gained from their experience. In
addition to work instructions are job rules, which are mandatory.

The SMS, used effectively, will enable the Company to maintain and improve its
safety performance and also provide a commercial advantage through which, it can
maintain stability for its workforce.

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1.3 SMS Documentation Structure

The structure of the documentation is based on The Company Quality Management

System.

• Level 1 – Policy, objectives, responsibilities, organisation (QAM ‘B’)

• Level 2 – Procedures (QAM ‘C’)
• Level 3 – Work Instructions (QAM ‘D’)

This is primarily to achieve standardisation but also to facilitate the process of audit.
The concept of the system is that any topic be traceable from company objectives,
through division objectives, to procedures and finally work instructions. In addition
procedures are linked, where appropriate, in a horizontal direction thus ensuring the
system is totally integrated.

The SMS is specific to the referenced divisions of Tuboscope (UK) Ltd and is not
influenced by, or biased towards, any one client.

COMPANY OBJECTIVE
SMS MANUAL
LEVEL 1

LEVEL 2 HS & E Procedures

LEVEL 3 HS & E Working Instructions

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1.4 Project Specific Safety Plan

The Company recognises that effective safety requires that policies, procedures and
work instructions be applicable to the location in which they are to be utilised. In the
majority of cases the Company SMS will suffice. Should client requirements,
operating or environmental conditions indicate that additional procedures are
necessary these will be developed and become project specific safety plans.

These plans effectively form level 4 of the documentation structure and provide a
single source of reference on HS & E affairs for Company personnel at the location.

The origin of such plans is demonstrated below. Initially the Company, together with
the client, will identify the key elements of safety management to be utilised at that
location. The client will specify which of their procedures are mandatory, e.g. Permit
To Work, and the remainder of the document will comprise the Company procedures
drawn from Levels 1, 2 and 3 of the Company SMS.

These documents are controlled in the same way as the Company SMS to ensure
that they are maintained current.

Client SMS

Level 1

Level 2

Level 3

Project Safety Plan

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1.5 Performance Monitoring

In order to ensure the ongoing effectiveness of the Safety Management System, the
company has put in place several control procedures. These are in three groupings
to provide control in the short, medium and long term. Within the SMS, performance
monitoring is a combination of several activities which are specifically undertaken to:

• Demonstrate performance and achievement.

• Measure effectiveness
• Confirm compliance
• Improve the SMS on a continuous basis.

They are based on the management business model shown below, where
performance monitoring is achieved through control – correction – improvement

POLICY AND OBJECTIVES

ORGANISATION, IMPROVEMENT
RESPONSIBILITY, RESOURCE

STANDARDS AND PROCEDURES CORRECTION

IMPLEMENTATION, CONTROL
PERFORMANCE, MONITOR

AUDIT COMPLIANCE

MANAGEMENT REVIEW

The company implements performance monitoring through:

• Statistical analysis
• Inspection
• Audit
• Management Review

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2.1 HS & E Policy Statement

In accordance with the Health and Safety at Work Act 1974 it is the prime objective of
Tuboscope to provide, so far as is reasonably practicable, a safe and healthy work place for
all its employees. To achieve this objective the Company shall develop and maintain safe
systems of work through the implementation of the Safety Management System (SMS). The
system shall be accorded the same status as other management activities within the
Company and adequate resources shall be made available to ensure success.

In accord with legislation, it is the duty of all employees to be aware of, and to conform with
the Company policy, procedures, and work instructions contained within the SMS. In
addition, each Division has a policy of line management responsibility for health, safety and
environmental affairs and hence has assigned specific responsibilities to managers and
supervisors. To ensure that personnel are able to accept these responsibilities the Divisions
shall provide the necessary training and information.

The Company places emphasis on the prevention of all accidents, which may result in injury
to personnel and damage to equipment affecting both the wellbeing of its employees and the
efficiency of its operations. All accidents and incidents shall be investigated dependent on
severity or potential, and be followed up by management to prevent recurrence.

Where the Company employs contractors, every effort shall be made to ensure their
commitment to health and safety and where necessary, that each Division shall impose its
standards on the contractor. The Company shall observe all statutory requirements and work
with government, industry, academic and other professional bodies to promote and improve
standards and codes of practice applicable to its operations where considered necessary.

Protection of the environment is seen as being an integral part of the SMS. The Company
shall take such actions as necessary to avoid damage to the environment through the
implementation of the Environmental Management Plan.

Participation of all employees in the implementation of this policy and the Safety
Management System is seen as the key to success and the Company will strive, through
enhanced co-operation and understanding, to achieve its goal of continuous improvement.

Signed: Date:

Peter Stuart - Vice President, Eastern Hemisphere Operations.

Tuboscope Inc.

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2.2 HS & E Objectives

Tuboscope through commitment to the HS & E Policy and the objectives outlined below,
ensures that the it has in place effective, practical and achievable means to provide for the
health, safety, protection and welfare of employees, contractors, clients and the environment.

The Company shall:

• Comply with all applicable legislation, codes of practice and industry standards.

• Establish procedures and implement work instructions sufficient to avoid injury to

employees and others that may be affected by company operations.

• Establish standards and procedures to minimise harm to employees and others through
occupational health and substance abuse.

• Have in place controls to minimise the impact of the companies’ activities on the
environment.

• Provide properly engineered facilities, plant and equipment and maintain them in safe
condition.

• Employ at all levels, a competent and trained workforce through appropriate

recruitment, selection, training, and when necessary, retraining.

• Provide an effective system of communication throughout the Company and with clients
to ensure active participation in all aspects of Safety Management.

• Develop and maintain effective contingency plans adequate to meet all identified
scenarios.

• Through investigation, follow up, and analysis of incident reports, strive to eliminate
accidents and incidents within the Company’s operations.

• Have in place monitoring and review systems to measure the success of the Safety
Management System and provide for ongoing improvement.

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3.1 Responsibility against Policy Objectives

The following levels in the Organisation are identified as having common

responsibilities against the Policy objectives and are shown on the organisation
charts. These responsibilities are shown below:

3.1.1 Company Management

• To establish the Health, Safety and Environmental Policy of the Company and its
Divisions and to promote its implementation.

• To ensure that adequate resources are made available within the Divisions to
implement the SMS.

3.1.2 Division Management

• To ensure that the operations within their responsibility are conducted in

accordance with the SMS and that plant and equipment is maintained so as to
comply with established standards.

• To ensure compliance with the Company HS & E Policy.

• To support the QA/Safety Manager in the implementation of the SMS.

• To ensure that the causes of any reported accident or incident are investigated,
the cause(s) identified and plans developed to prevent recurrence.

• To set a personal example in demonstrating a concern for safety matters.

• To ensure that statutory requirements are complied with.

• To ensure that satisfactory arrangements exist for effective employee

involvement.

3.1.3 Vice President, Eastern Hemisphere

• Establish the company HS & E Policy and promote its implementation.

• Provide adequate resources to implement the SMS.
• Review the SMS annually and implement change as required.

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3.1.4 QA/Safety Manager

• Manage all aspects of health, safety and environmental protection within the
Company.

• Maintain the Company SMS Manual.

• Co-ordinate new safety procedures as and when required and regularly review
existing procedures.

• Compile and maintain accurate records and statistics on safety matters.

• Regularly visit sites to carry out audits and encourage safety awareness.

• In conjunction with line managers, identify safety and training requirements.

• Maintain regular contact with the clients safety department.

• Maintain regular contact with material and equipment suppliers; so as to be

aware of current trends.

3.1.5 Line Supervision

• To ensure that operations under their control are carried out in compliance with
the SMS.

• To ensure adequate provision of personal protective equipment (PPE) in

accordance with Statutory Regulations, SMS and client requirements.

• To set a personal example in demonstrating a concern for safety matters.

• To carry out, as necessary, the investigation of accidents and incidents.

• To ensure that all-necessary safety inductions are carried out in accordance with
SMS and client requirements.

• To hold Safety Meetings and Toolbox Talks as required by the standard.

• To ensure careful and proper onsite instruction and training is given to personnel
under their direction in the correct operation and maintenance of machinery and
equipment and control of health hazards.

• To ensure that all-necessary health and safety data sheets are made available
and employees understand their content.

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3.1.6 Employees and Contractors

• Make every endeavour to assist in ensuring that the working conditions and
environment are maintained in a safe and healthy condition.

• Act responsibly and take all necessary precautions to protect themselves, their
fellow workers and any other persons who may be affected by their activities from
injury and its potential.

• Ensure that any defects in machinery, tools, equipment, protective measures PPE
are immediately brought to the attention of their Supervisor so that steps can be
implemented to remedy the defect or take the equipment out of service to be
repaired or made safe.

• Report immediately to their Supervisor any unsafe practices and conditions

discovered.

• Co-operate fully in the investigation of an accident or incident.

• Where doubt exists, seek guidance from supervision or management as to the

integrity of procedures, work instructions, plant or equipment.

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ORGANISATION CHART –
TUBOSCOPE (U.K.) LTD – BRANDT, ENACO & TUBOSCOPE
DIVISIONS

1.0 0.0

ACCOUNTS VICE PRESIDENT

2.0 11.0 5.0 6.0 7.0

HEALTH, SAFETY
AND
PERSONNEL ENVIRONMENT NORTH SEA MACHINE LINER
ADMINISTRATION QUALITY REGION SHOP HANGER
ASSURANCE/
TRAINING

11.2 11.1
HEALTH, SAFETY QUALITY
AND ASSURANCE
ENVIRONMENT AND
TRAINING

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Tuboscope Group of Companies Organisation Chart

CHART NO. 5.0

O.C.T.G. Inspection –Vendor Inspection Services –

Coating and Brandt (Solids Control) Divisions
REGIONAL MANAGER
NORTH SEA
DIVISION 5.0

5.1 5.2
SOLIDS INSPECTION OPERATION OUTSIDE
CONTROL AND SUPPORT SALES
COATING

ENGINEERING PORTLETHEN INSIDE BRANDT

MANAGER INSPECTION SALES

SERVICE PORTLETHEN IMPORT/EXPORT INSPECTION

MANAGER COATING CUSTOMS

MATERIALS PORTLETHEN PURCHASING COATING

MANAGER VENDOR
INSPECTION

REFURBISHMENT GREAT YARMOUTH

AQUA CHEM
SUPERVISOR INSPECTION

MANUFACTURING
5.2.4
SUPERVISOR

11.2
QUALITY CONTROL MANAGEMENT SYSTEMS
TECHNICIAN HEALTH, SAFETY AND
ENVIRONMENT

REPRESENTS LINK TO MANAGEMENT SYSTEMS PERSONNEL HAVING DIRECT

REPORT TO VICE-PRESIDENT EASTERN HEMISPHERE OPERATIONS.

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Tuboscope Group of Companies Organisation Chart

CHART NO. 6.0

Machine Shop Division

GENERAL
MANAGER 6.0

PRODUCTION
CONTROLLER

STORES PRODUCTION PRODUCTION QUALITY CONTROL

DISPATCH SCHEDULER CO-ORDINATOR TECHNICIANS
SENIOR TECHNICIANS

11.2

MANAGEMENT SYSTEMS
HEALTH, SAFETY AND
ENVIRONMENT

REPRESENTS LINK TO MANAGEMENT SYSTEMS PERSONNEL HAVING DIRECT

REPORT TO VICE-PRESIDENT EASTERN HEMISPHERE OPERATIONS.

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Tuboscope Group of Companies Organisation Chart

CHART NO. 7.0

Enaco Liner Hanger Division

VICE
PRESIDENT
EASTERN 7.0
HEMISPHERE

TECHNICAL SALES
MANAGER MANAGER

APPLICATIONS WORKSHOP SALES

ENGINEER ENGINEERS

SERVICE
ENGINEERS
11.2

MANAGEMENT
SYSTEMS
HEALTH, SAFETY AND
ENVIRONMENT ADMINISTRATION

REPRESENTS LINK TO MANAGEMENT SYSTEMS PERSONNEL HAVING DIRECT

REPORT TO VICE-PRESIDENT EASTERN HEMISPHERE OPERATIONS.

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Tuboscope Group of Companies Organisation Chart

CHART NO. 11.2

HEALTH, SAFETY AND ENVIRONMENT

Tuboscope (UK) Management System

QUALITY ASSURANCE/
SAFETY MANAGER

5.0 5.2
REGIONAL MANAGER OPERATIONS MANAGER TUBOSCOPE
NORTH SEA COATING/INSPECTION PORTLETHEN
SAFETY COMMITTEE

5.2.4
OPERATIONS SUPERVISOR TUBOSCOPE
INSPECTION DIVISION GREAT YARMOUTH
SAFETY COMMITTEE

5.1
OPERATIONS MANAGER BRANDT
SOLIDS CONTROL DIVISION ABERDEEN
SAFETY COMMITTEE

6.0

GENERAL MANAGER TUBOSCOPE

MACHINING DIVISION DUNDEE
SAFETY COMMITTEE

7.0
SALES MANAGER ENACO
LINER HANGER DIVISION ABERDEEN
SAFETY COMMITTEE

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4.1 Company Organisation

The following organisation charts indicate the organisational levels with reference to
Health, Safety and Environment responsibilities defined in Section 3.1. Where
individuals are assigned specific responsibilities this is noted for ease of reference
and audit purposes.

• Appendix 1 Organisation Chart – Tuboscope (UK) Ltd.

• Appendix 2 Chart Number 5 – OCTG Inspection / Vendor Inspection / Coating /

Solids Control.

• Appendix 3 Chart Number 6 – Machine Shop Division.

• Appendix 4 Chart Number 7 – Liner Hanger Division.

• Appendix 5 Chart Number 11.2 – Health, Safety and Environment.

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5.0 Workforce Involvement

The key to the success of the Company’s SMS is workforce involvement at all levels
within the Divisions. This is achieved not only through daily ad-hoc contact but also
formal methods. The following represent the main areas of participation:

5.1 Safety Meetings

These meetings will be held regularly as defined in the procedure. All available
employees will attend and the agenda is so designed as to encourage participation
from the employees. The intent is that matters of concern can be identified and
feedback provided. When more than one Division occupies the facility, employees
from all Divisions can attend.

5.2 Toolbox Talks

Held prior to or during the carrying out of a job should circumstances change. These
discussion sessions provide the opportunity for employee participation. They are
informal and are conducted by a member of the workforce.

5.3 SMS Procedure Development and Implementation

The importance of workforce involvement in the development of the SMS procedures

is of prime importance. It is recognised that unless procedures are seen to be
credible and practicable then they will not be used and “short cuts” will be the result.
To avoid this, the assistance of the “most appropriate” person or persons in the
preparation of documentation will be enlisted. The definition “most appropriate” will
take into account factors such as experience, skill levels, training levels and proven
competency.

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6.1 Personnel Management

Effective personnel management ensures that, in a systematic manner, the company

employs and utilises the “right man for the job”. This provides for the provision of
effective managers, suitably qualified supervisors and competent employees. In
attaining this status employees must be experienced, well trained and assessed
competent. The following are the procedures utilised by the company to achieve this:

6.1.1 Company Induction

Each employee new to the Company or any Division within the Company receives an
induction. Emphasis is placed upon imparting the critical information required to get
them through the initial employment period in a safe and confident manner.

6.1.2 Personnel Assessment

Each Division operates a procedure for appraising performance on an annual basis.

The objective is to reaffirm objectives, discuss past performance and identify problem
areas.

6.1.3 Job Training Profiles

These are provided for each job within each company and define the training
requirements. They are used to identify shortfall for input to training programmes.

6.1.4 Training Programme

From the personal training profiles, the overall company training needs are identified
and a corporate training programme developed.

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6.2 Risk Management

The Management of Health and Safety at Work Regulations 1992 requires that each
company carries out a Risk Assessment at each location at which they have
employees. This assessment addresses the following:

• The risk to the health and safety of company employees at locations / sites at which
they work.

• The risks to the health and safety of persons, not company employees, who may be
exposed to the work carried out by company employees.

The Regulation requires that the assessment be a systematic general examination of

the work activity and that the significant findings be recorded.

In compliance to this requirement the Company has developed a procedure

comprising the following steps.

• Identification of Assessment Units.

then within each unit –

• Identify activities undertaken.

• Identify the jobs within each activity.
• Identify the risk of each task
- severity of hazard.
- Frequency of occurrence.
- Numbers involved.
- Other tasks affecting.
- Probability of occurrence.
- Controls currently implemented.

• Recommend further controls (if necessary).

When implementing controls, the risks identified will be prioritised so that best use of
resources can be made.

6.3 Communication

Effective communication is seen as the key to the success of the SMS. Each Division
will utilise the methods highlighted below to achieve this, incorporating, maximum
number of employees where possible.

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6.3.1 Safety Meetings

Meetings will be held as defined in the procedure. All available employees will attend
and the agenda be so designed as to encourage participation from the employees.
The intent is that matters of concern can be identified and feedback provided.
Meetings will also be utilised to communicate other health and safety related
information such as the results of inspections and audits. Minutes will be taken and
displayed for reference. When more than one Division occupies the facility,
employees from all Divisions can attend.

6.3.2 Toolbox Talks

Experience shows toolbox talks to be prime contributors to a safe work place. These
take place at the worksite and are conducted by the “person in charge”. They
address how the job is to be completed, it being incumbent upon the “person in
charge” to be confident that all employees in the team are aware of their
responsibilities and that they have the knowledge and skill to complete the job in a
safe manner.

6.3.3 Safety Bulletins

The company is aware of the importance of providing information to employees on

health and safety matters. To achieve this, the Company has established a system of
bulletins issued by the QA/Safety Manager. These are issued on controlled basis
and address legislative requirements, information on incidents applicable to Company
operations, etc. They have a finite life and must be reviewed and/or cancelled
periodically.

6.4 Occupational Health

6.4.1 Personal Protective Equipment (PPE)

In the hierarchy of control measures PPE is considered to be the “last resort” in

protecting personnel against risks to safety and health; engineering controls and safe
systems of work are considered first. The Company provides PPE commensurate
with the identified risk and in compliance with the Personal Protective Equipment
Regulations 1992 covering body, feet, hands, head and ears.

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6.4.2 Control of Substances Hazardous to Health (COSHH)

To comply with the current Regulations each Division has carried out Assessments
utilising the procedure detailed in level 2, and is implementing the additional controls
identified.

6.4.3 Facility Surveys

These are carried out in compliance with the following Regulations and incorporated
with the Risk Assessment process:

• Health and Safety (Display Screen Equipment) Regs. 1992.

• Workplace (Health, Safety and Welfare) Regs. 1992.
• Manual Handling Operations Regs. 1992.

6.4.4 Medical Arrangements

The Company considers this employee care activity as an important issue. There is
an appointed Medical Practitioner who deals with all medical examinations, records
etc. whilst there is a programme of training for appointed First Aiders. All offshore
personnel attend the mandatory courses. The company “Alcohol and Substance
Abuse Policy” is seen as a key proactive tool in employee care, as is the smoking
policy.

6.5 Work Procedures and Controls

Clear, concise, well understood work procedures are an essential element of health
and safety in the workplace. To support the safe execution of these procedures,
control mechanisms must be established.

6.5.1 Work Procedures

For work procedures to be effective and hence utilised by the workforce, they must be
standardised in format, easily accessible, but more importantly, developed in
conjunction with the personnel who are to use them. The Company has established
a procedure, detailed in level 2, which allows for the systematic evaluation of work,
and results in detailed procedures being developed which are “owned” by the
workforce.

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6.5.2 Procurement

The level of risk at a location may be increased considerably by “importing” hazards

associated with goods or equipment. The Company has procedures in place via the
quality management system to minimise such risk. There is an established list of
Approved Vendors to ensure required standards (British, European and International)
and it is against this listing that all purchases are made.

6.5.3 Certification

All equipment utilised in the Company’s operations, requiring to be certified to an

applicable standard is dealt with under the quality management system but is
referenced within the SMS for completeness.

6.6 Environmental Management

Tuboscope recognises and accepts that concern for the environment is an integral
and fundamental part of the Company’s business strategy. It is the intent of the
Company, that in all matters of environmental control it will adhere to, or do better
than, all applicable legislation.

To achieve this intent each Division shall:

• Achieve the environmental objectives.

• Comply with not only current and legislative requirements, but seek continued
improvement of standards and procedures.

• Demonstrate compliance with company objectives and legal requirements.

This is achieved through:

6.6.1 Environmental Management Plans (EMP)

The EMP provides a structure whereby the environmental aspects and considerations
of the company operations are assessed and required action taken.

6.6.2 Environmental Review

These are undertaken on an annual basis to review the level of compliance to the
environmental objectives and to both current and forthcoming legislation.

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6.7 Contractor Safety Management

Each Division, within the Company, requires that contractors working on its behalf
shall:

• demonstrate that they are capable of conducting themselves in a safe and

competent manner.

• apply health, safety and environmental measures fully consistent with those of the
company and achieve comparable levels of performance.

• consistently demonstrate an acceptable standard of safety awareness.

To assess the level of compliance to the above, the Divisions may carry out the
following:

6.7.1 Contractor Assessment

Contractors bidding for work which may present or introduce a hazard to the
Company shall be subjected to the Company Contractor Safety Assessment
procedure. The results of this assessment will be a major deciding factor in contract
award.

6.7.2 Contractor Monitoring and Review

A single assessment is not considered adequate on contracts over 6 months

duration. Importance is placed on periodic monitoring and review at pre-determined
intervals through a contract and on its termination. In this way the company
influences its contractors and builds up a database of contracting companies in
which it has confidence.

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6.8 Accident and Incident Reporting & Investigation

This important tool proactively seeks ways to prevent accidents and incidents
recurring. The objectives of the reporting and investigation procedures are:

• to investigate all accidents and incidents which are reported at a level

commensurate with their potential.

• to utilise the recommendations to prevent recurrence of similar incidents.

• to communicate the findings of investigations to all employees and other

interested parties.

• to identify trends so that appropriate actions can be taken proactively.

• To meet these objectives the Company has established the following:

6.8.1 Reporting Procedure

This provides a standardised format for reporting which facilitates the process of
investigation. The format gathers all the information required by the Company,
legislation and clients. The procedure is used not only at onshore facilities,
Employees involved in accidents or incidents at remote locations shall also complete
the report form as required.

6.8.2 Investigation Procedure

Following the reporting of an accident or incident, it shall be investigated as defined in

the procedure. The level of investigation shall depend on the actual and / or potential
loss identified. Management shall be fully involved and have a responsibility to close
out any recommendations to prevent recurrence as recorded on the investigation
form.

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6.9 Contingency Planning

The Company recognises the need to have in place contingency plans should they be
required.
The following are established:

6.9.1 Emergency Organisation

Clearly defined responsibilities have been laid down for the establishment of an
emergency response team based upon the severity or potential of a reported incident.
These address emergency situations either at the company facilities or at a remote
location.

6.9.2 Emergency Plans

In order to facilitate the process of emergency response, the Company has identified
what are believed to be the emergency scenarios that are most likely to occur. These
are documented and personnel responsibilities assigned. In this way subjectivity at
the time of the incident can be dealt with in the most efficient manner.

6.9.3 Training and Drills

It is recognised that emergency response duty forms only a minor part of an

employee’s normal duties and hence to ensure a competent response when it is
required, training sessions based on selected sections of the Emergency Plans are
held. These range from location fire drills to participating in exercises with clients as
requested.

6.10 Performance Monitoring

This element includes the three control loops from the management model defined in
section 1.0. These are achieved through the following procedures, which together
provide the Company with the ability to continuously monitor its performance in the
field of health, safety and environmental management.

6.10.1 Statistical Reports

These statistics record the occurrence of lost time accidents (LTA) and non-lost time
accidents (NLTA) and incidents (near misses). They are recognised as reactive
indicators.

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6.10.2 Cause Analysis

Stemming from incident reports these indicators provide guidance as to trends and
the causes of incidents and provide indication of the success or otherwise of specific
HS & E campaigns.

6.10.3 Incident Potential

Utilising the Company potential matrix all reported accidents and incidents are
assigned a potential rating. This provides a guide as to what might have happened
had the situation been slightly different.

6.10.4 Safety Management System Audits

Audits are carried out to identify the level of compliance by each Division to the
procedures contained within the Safety Management System. These are formal
audits undertaken scheduled in conjunction with the QA System audits. A pre-defined
checklist and scoring regime may be utilised.

6.10.5 Location Inspections

Inspections are carried out to identify the level of compliance to established standards
connected with plant and equipment. They are based on a predetermined
programme and involve employees at all levels.

6.10.6 Management Review and Improvement Process

This activity closes the management control loop of the Safety Management System
by providing the means for improvement. On annual basis the company
management reviews HS & E performance based on the indicators and defines the
action plan to maintain the continuous improvement process of the SMS.

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