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Retention Code:

HSE INCIDENT REPORTING CG01 - CA


ALL-A0A-00-000-HST-0031
Revised: April 2021

Owner: Approved By: Review Frequency:


HSE Systems Manager, Health & Safety Operations Five years or less

This document contains proprietary information belonging to ConocoPhillips Canada. It is intended to govern activities of
ConocoPhillips Canada employees and contractors who perform work at ConocoPhillips Canada worksites. Its most current
version may only be relied upon by those parties who receive a copy provided by ConocoPhillips Canada directly.

About the Document .................................................................................................................................... 4


Purpose ......................................................................................................................................................................................... 4
Scope ............................................................................................................................................................................................ 4

1. General ................................................................................................................................................ 5
1.1. Initial Response and Information ............................................................................................................................ 5
All Events ...................................................................................................................................................................................... 5
1.2. Incident Reporting ................................................................................................................................................... 6
Incident Reporting ........................................................................................................................................................................ 6
Intelex ........................................................................................................................................................................................... 6
Risk Ranking .................................................................................................................................................................................. 7
Incident Owner ............................................................................................................................................................................. 7
Internal Reporting ......................................................................................................................................................................... 8
External (Regulatory) Reporting .................................................................................................................................................... 8
HSE Enforcement .......................................................................................................................................................................... 9

2. Illness and Injury Classification and Clarifications .............................................................................. 9


2.1. Injury and Illness Classifications .............................................................................................................................. 9
Near Miss (NM) ............................................................................................................................................................................. 9
First Aid Case (FAC) ....................................................................................................................................................................... 9
Medical Treatment Case (MTC)................................................................................................................................................... 10
Process Safety Near Miss (PS NM) .............................................................................................................................................. 10
Restricted Workday Case (RWC) ................................................................................................................................................. 11
Lost Workday Case (LWC) ........................................................................................................................................................... 11
Industrial Hygiene Exposure Incident .......................................................................................................................................... 11
Tier 1 and 2 Process Safety Event (PSE) ...................................................................................................................................... 11
Tier 3 Process Safety Event (PSE) ................................................................................................................................................ 11
2.2. Clarifications .......................................................................................................................................................... 11
Administering Oxygen ................................................................................................................................................................. 11
Chipped Teeth ............................................................................................................................................................................. 12
Debris in Eyes .............................................................................................................................................................................. 12
Ergonomic ................................................................................................................................................................................... 12

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Illness .......................................................................................................................................................................................... 12
Insect Bites/Stings ....................................................................................................................................................................... 12
Mental Illness .............................................................................................................................................................................. 12
Pre-Existing Conditions ............................................................................................................................................................... 12
Prescriptions ............................................................................................................................................................................... 12

3. Alberta - Surmont Reporting ............................................................................................................. 13


3.1. Potentially Serious Incidents (PSIs)........................................................................................................................ 13
Reporting Contacts ..................................................................................................................................................................... 13
Potentially Serious Incidents (PSIs) ............................................................................................................................................. 13
3.2. Injuries and Illnesses ............................................................................................................................................. 13
Reporting Contacts ..................................................................................................................................................................... 14
Reportable/Recordable Events ................................................................................................................................................... 14
3.3. Spills and Gaseous Releases .................................................................................................................................. 16
Reporting Contacts ..................................................................................................................................................................... 16
Reportable/ Recordable Events .................................................................................................................................................. 17
3.4. Other Reportable Events ....................................................................................................................................... 21
Reporting Contacts ..................................................................................................................................................................... 21
Reportable Events ....................................................................................................................................................................... 21

4. British Columbia – Montney Reporting............................................................................................. 22


4.1. Injuries and Illnesses ............................................................................................................................................. 22
Reporting Contacts ..................................................................................................................................................................... 23
Reportable/ Recordable Events .................................................................................................................................................. 23
4.2. Spills and Gaseous Releases .................................................................................................................................. 25
Reporting Contacts ..................................................................................................................................................................... 25
Reportable Events ....................................................................................................................................................................... 26
4.3. Other Reportable Events ....................................................................................................................................... 30
Reporting Contacts ..................................................................................................................................................................... 30
Reportable Events ....................................................................................................................................................................... 30

Attachment 1 – Alberta Spill and Release Reporting Guidance.................................................................. 33


Attachment 2 – British Columbia Spill and Release Reporting Guidance ................................................... 36

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Document History

Date Approved by Change Summary


David Reaich • Usability Mapped
• Guidance for regulatory and internal reporting
April 2021 • Addition of process safety event descriptions
• Addition of reportability requirements for gaseous
releases.

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About the Document

Purpose The purpose of this procedure is to define internal and external reporting
requirements for:
• Near Misses
• Injuries and illness
• Liquid and gaseous releases
• Other regulatory reportable incidents

For Emergencies call 911 and/or contact CPC 24 Hour


Emergency Response (800) 661-9525 as appropriate

Scope This procedure applies to incidents/events which occur within ConocoPhillips


Canada’s (CPC) operational control. CPC has operational control when they
have decision authority on HSE-related elements of operation. Operational
Control must be decided early in the procurement phase to ensure the proper
duty and care of our contractors and to accurately capture incidents and
contractor hours.

If an event occurs during an acquisition or divestiture, operational control is


based on closing date (i.e., once transaction is closed then CPC will report for
newly acquired assets and stops reporting for divested properties).

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1. General

1.1. Initial Response and Information

All Events If applicable, respond to any event by:


• Attending to injured persons
• Preventing further injuries
• Protecting property that is endangered because of the incident.

NOTE: Freeze and secure the incident scene unless


otherwise directed by authorities.

Collect all required information as indicated in the table below:

Event Type Information


• Location of the incident
• Site
• Function (e.g., Operations and Maintenance, General
Drilling and Completions)
• Event Type (e.g., incident, near miss)
All Events
• Date and time
• Event description
• Immediate actions taken
• Contractor involvement

• Source of release
Liquid and Gaseous • Material released
Releases • Volume released

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1.2. Incident Reporting

Incident Reporting Regardless of severity, the following incident and near miss types must be
reported internally:
• Environmental
• Injury/Illness
• Process Safety Events
• Vehicle
• Property Damage
• Enforcement
• Community
• Security

NOTE: Reportability thresholds and CPC/COP recordability thresholds


are in the jurisdiction specific sections below. Incidents will be
investigated when required as per the Pre-Incident and Incident
Investigation Procedure.

Intelex Intelex is ConocoPhillips’ HSE data management software. All incidents and
near misses are tracked in the EHS Event Management module:

Pertaining to incident reporting only:


1. Draft report is entered by affected business representative.

Draft report is verified by the affected leadership (Verifier 1) as follows:


Function Incident Verifier

Montney Operations Operations Leader

Surmont Operations Shift Supervisor

CMT Construction Manager


2.
Wells Field Superintendent

Calgary Calgary HSE or REFS

Then by HSE (Verifier 2). Search Location Role: CAN HSE (Intelex), for
Incidents in the Calgary office, Verifier 2 is the H&S office safety
coordinator.

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NOTE: Incidents and near misses must be closed
once corrective actions are complete. An
investigation may be required, see Pre-Incident
and Incident Investigation Procedure for details.

NOTE: Only security incidents that are either


associated with another subevent or are
corporate reportable are entered into Intelex.
All other security events are recorded in D3
Security Management Software.

Risk Ranking All incidents must be:


• Risk ranked by the Incident Owner and HSE
• Risk ranked according to the CPC Risk Matrix Card
• Verified as appropriate in Intelex.

NOTE: The H&S Manager & Functional Manager


are responsible for risk ranking incidents which
require Crisis Hotline Notification.

NOTE: Risk must be accepted according to the Risk


Matrix Card.

Incident Owner An incident owner must be assigned to all events according to the highest risk
rank (actual or potential) and applies to any consequence.

Risk Category Incident Owner

Category IV – High 20-25 President

Category III – Significant 12-16 VP

Category II – Medium 8-10 VP + 1

Category I – II Medium 1-6 VP + 2

The incident owner is responsible to:


• Verify the risk rank is appropriate and incident classification is correct.
• Ensure that regulatory notifications are completed on time.

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• Initiate development of the Learning Plan. See Pre-Incident and
Incident Investigation Procedure for details.

Internal Reporting All incidents:


• Must be immediately reported to the work supervisor and HSE.
• Should be entered in Intelex within 24 hours of occurrence.
The following are considered CPC recordable. Specifics can be found in the
jurisdiction specific sections below.

Incident Type Recordable Consequences

• Medical Treatment Case


• Restricted Workday Case
• Lost Workday Case
Injuries/ Illness
• Fatality
• Industrial Hygiene Occupational
Exposure Incident

Regulatory reportable liquid and gaseous


Environmental
releases

Process Safety Events Tier 1 process safety events

External (Regulatory) External reporting requirements are detailed in the jurisdiction specific sections
Reporting below.

NOTE: All electrical incident regulatory notifications are


handled by the electrical department.

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HSE Enforcement Assessed or paid HSE‐related fines or penalties; government allegations of
violation(s); assessment of a violation by a federal, provincial, local or
municipal agency or entity; and certain self‐disclosed violations. HSE
Enforcement may be a result of either:
• Inspections by regulatory authorities
• Persistent non-compliance raised by a regulatory authority.
See COP HSE Management System Standard - HSE Fines and Enforcement
Actions

2. Illness and Injury Classification and Clarifications

2.1. Injury and Illness Classifications

Near Miss (NM) An event with no consequences, but with other circumstances could have
resulted in fire, injury, property damage, process upset, spill, release, or some
other failure.

First Aid Case (FAC) Injury where treatment is limited to:


• Using non‐prescription medication at non‐prescription strength.
• Administering tetanus (only) immunizations.
• Cleaning, flushing or soaking wounds on the surface of the skin.
• Using wound coverings such as bandages, Band‐Aids™, gauze pads, etc. or
using butterfly bandages or Steri‐Strips™.
• Using hot or cold therapy.
• Using any non‐rigid means of support, such as elastic bandages, wraps,
non‐rigid back belts, etc.
• Using temporary immobilization devices while transporting an accident
victim (e.g., splints, slings, neck collars, backboards, etc.).
• Drilling of a fingernail or toenail to relieve pressure or draining fluid from a
blister.
• Using eye patches.
• Removing foreign bodies from the eye using only irrigation or a cotton
swab.
• Removing splinters or foreign material from areas other than the eye by
irrigation, tweezers, cotton swabs or other simple means.
• Using finger guards.
• Using massages other than chiropractic treatment or physical therapy.
• Drinking fluids for relief of heat stress.

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Medical Treatment An injury or illness involving any treatment other than what is listed as first aid
Case (MTC) treatment. This includes:
• Stitches or surgical/medical glue used to close a wound.
• Prescribed or prescription strength medications.
• Physical therapy or chiropractic treatment prescribed by a physician.
• Application of fiberglass, plaster, or other rigid supports structures.
• Surgical procedures not requiring restricted work or days away.
• IV administration of saline or glucose.

Process Safety Near Entered into Intelex by Operations:


Miss (PS NM) • Process shutdown system trips and activation of safety system that was not
intentional (e.g., fault wire causes plant trip or activation during device testing).
• A frozen or plugged process line that could have led to loss of primary
containment.
• Formation of a hydrate that requires hydrate management.
• Process isolation errors that were caught prior to work execution.
• Performing work on an incorrect line, piece of equipment, valve, etc. that could
have realistically led to loss of primary containment.
• Safety Critical Element Impairment (i.e., bypass forms are not filled out or when a
bypass is not removed when work is complete)
• Anomalies identified on car seal list (i.e., missing car seals, valves car sealed in the
wrong position, engineering car seal errors)
• Engineering design anomalies (system not operating as expected or
documented). E.g., control system programming errors prior to errors resulting in
loss of primary containment, potential for excessive vibrations with observable
damage or potential damage (i.e., loose fittings), anything that should have been
designed out, resistance temperature detector in wrong location.
• Any impairment of relief device discharge path to safe location (flare system
challenges)
• MOC not completed for a MOC covered change that could have led to loss of
primary containment.
• PSV fails to activate when it should have on high pressure

Entered into Intelex by Asset Integrity:


• Asset Integrity inspection results below Tmin or cracking of pressure equipment.
• Relief valve failure to activate within tolerance on demand during operations or
test (entered in Intelex as one entry monthly)

For Wells:
• Safe Operating Limit(s) are defined in the Well Operating Guideline / Well Design
Envelope as “the design limits for the well including allowable pressures and
temperatures, maximum flow/injection rates, etc.” has (have) been executed
• BOP (secondary barrier) is closed in order to raise mud weight (required to
maintain the primary barrier)

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Restricted Workday An injury or an illness that prevents the employee from performing one or
Case (RWC) more of the routine functions of their job or from working the full workday that
he or she would otherwise have been scheduled to work.

NOTE: The day of injury is not considered a Restricted Workday. If the


Injured party cannot return to full duties the next calendar day,
regardless of whether they are scheduled to work, this day is
considered the first restricted day for the count.

Lost Workday Case An injury or an illness in which the employee is unable to or prescribed by a
(LWC) licensed health care provider not to return to work the next calendar day,
whether the employee is scheduled to work that day (day of injury is not
considered lost work).

Industrial Hygiene An event where a worker’s exposure to a chemical or nonchemical agent is


Exposure Incident measured and found to be higher than a corresponding guidance (e.g.,
ConocoPhillips Occupational Exposure Limit) or regulatory standard and the
worker did not have correct protection against that exposure. For guidance and
regulatory standards and exposure event classification, see Industrial Hygiene
Metrics Reporting Procedure. For incident investigation purposes, an exposure
incident is a type of incident.

Tier 1 and 2 Process Defined in corporate Process Safety Metrics Guideline. Aligns with API 754 and
Safety Event (PSE) IOGP 456

Tier 3 Process Safety • Any PSE that does not meet Tier 1 or 2 criteria.
Event (PSE) • A loss of primary containment when any of the below are met:
o Process equipment is the source of release.
o Fresh water is > 60 C
o A PSV relieves to flare or atmosphere (reporting purposes only)
o It involves unplanned venting of blanketed tanks.
o It involves vendor equipment while connected to CPC process
equipment.
o It results in fire from or near process equipment regardless of damage
value

NOTE: PSEs will be risk ranked for all


consequences except business interruption.

2.2. Clarifications

Administering Recordable only when worker is exhibiting symptoms related to breathing.


Oxygen

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Chipped Teeth Recordable as a bone has been chipped or broken.

Debris in Eyes Only recordable if a method more invasive than irrigation or a cotton swab is
used for removal.

Ergonomic Only recordable if work-related and leads to a recordable injury. See section
1.2, Internal Reporting.

Illness Only recordable if the illness is identified by a licensed health care professional
and is suspected to be caused by workplace exposures.

Insect Bites/Stings Only recordable if intravenous saline or glucose is administered.

Mental Illness Only recordable if:


• Determined by a licensed health care professional (e.g., physician,
psychiatrist etc.) and
• The employee chooses to disclose the information to CPC.

Pre-Existing Only recordable if a new treatment is received or a medication dosage is


Conditions changed due to a workplace injury.

Prescriptions If a worker is prescribed prescription strength medication, the incident is


recordable regardless of whether the prescription is filled.

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3. Alberta - Surmont Reporting

NOTE: “CPC”, in and of the below tables indicates recordable events only. Regardless of
severity, all events must be reported and recorded in Intelex.
“CN” indicates when COP Crisis Notification is required. If COP column is checked, Intelex
notification must be made within 2 business days.

3.1. Potentially Serious Incidents (PSIs)

Reporting Contacts Report To Contact Timeline Responsible


Alberta As soon as HSE or delegate
Occupational possible
866-415-8690
Health and Safety
(OHS)

Provide a copy of the incident investigation report to the Director of Inspection


as soon as possible.

Potentially Serious A PSI is any event where a reasonable and informed person would determine
Incidents (PSIs) that under slightly different circumstances, there would be a high likelihood for
serious injury to a person. PSIs are recorded in Intelex as Near Misses.

NOTE: A PSI is not limited to workers and it


does not require the occurrence of an injury.

When determining if an event is a PSI, consider:


• Actual circumstances of the incident
• Hazards present at the time of the incident.
• Appropriate controls in place at the time of the incident
• Slightly different circumstances (timing, distance, body position, etc.)
that may have resulted in a serious injury.
• Similar incidents that have occurred at ConocoPhillips within the past
two years that resulted in injury.

3.2. Injuries and Illnesses

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Reporting Contacts Report To Contact Timeline Responsible
Royal Canadian Immediately VP HSE SD or
Mounted Police delegate
403-204-8900
(RCMP), non-
emergency

Primary: Immediately VP HSE SD or


1-281-293-1746 / delegate
Corporate Crisis 1-281-493-2767
Hotline Alternate:
1-918-661-7888 /
1-918-661-6529

Alberta As soon as HSE, Regulatory


Occupational possible or delegate
866-415-8690
Health and Safety
(OHS)

Alberta Workers With 72 hours of Health Services


Compensation 866-922-9221 occurrence or delegate
Board (WCB)

As per the CPC CPC Chief


Pressure Inspector or
Alberta Boilers
Equipment delegate
Safety Association 780-437-9100
Integrity Manual
(ABSA)
(ALL-A0A-00-
000-FST-0001)

NOTE: ABSA reporting requirements are not


identified in this procedure. Refer to CPC
Pressure Equipment Integrity Manual (ALL-A0A-
00-000-FST-0001)

Reportable/Recordable Review the following reportability criteria following any event.


Events

Regulatory / ConocoPhillips
External

Illness / Injury
RCMP
WCB
OHS

COP
CPC

✓ ✓ ✓ ✓ ✓
Death
CN

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Permanent Disability (e.g., amputation, hearing ✓ ✓
loss, etc.)

First Aid

Any hospital admittance due to a workplace ✓ ✓


injury or illness CN

Hospitalization (more than two days or expected ✓ ✓


duration of more than two)

Loss of Consciousness ✓ ✓

Lost Time/ Workday Injury ✓ ✓ ✓

Incidents resulting in multiple injuries/ illnesses ✓ ✓


to employees, contractors, or the public CN

Medical Aid Expenses (e.g., dental treatment, ✓


prescription medication, etc.)

Medical Treatment Case ✓

Modified Restricted Duties ✓

Over Exposure resulting in disabling or ✓


potentially disabling conditions

Over Exposure events per the COP Occupational ✓ ✓


Health Standard

NOTE: While ALL events are CPC reportable


those checked are considered recordable and
contribute to internal statistics

NOTE: All WCB notifications are completed by


CPC Health Services

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3.3. Spills and Gaseous Releases
See Attachment 1 for Alberta Spill and Release Reporting Guidance.

Reporting Contacts Report To Contact Timeline Responsible

Primary: Immediately VP HSE SD or


1-281-293-1746 / delegate
Corporate Crisis 1-281-493-2767
Hotline Alternate:
1-918-661-7888 /
1-918-661-6529

Verbal Incident Owner


Immediately, or delegate
written within 7
Alberta Energy days of verbal
1-800-222-6514 report.
Regulator (AER)
7-day follow-up
letter for TDG
releases

As per the CPC CPC Chief


Pressure Inspector or
Alberta Boilers
Equipment delegate-
Safety Association 780-437-9100
Integrity Manual
(ABSA)
(ALL-A0A-00-
000-FST-0001)

Environment 1-800-222-6514 Immediately Incident Owner


Canada (EC/CEPA) (same as AER) or delegate

Verify only, Incident owner


1-888-226-883 carrier to report or delegate
*611 events.
Transport Canada
Dangerous Goods N/A N/A
24-Hour
Information

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Reportable/ Review the following reportability criteria following any event:
Recordable Events

NOTE: While all events must be reported, any spill or


release that is regulatory reportable is considered
internally (CPC) recordable.

Regulatory / ConocoPhillips
External

Transport Canada
EPEA (E&P)
Liquid Release

EC (CEPA)

COP
AER

CPC
On-Lease - >2 m3 ✓ ✓

Off-Lease – Any Volume (includes ✓ ✓


transportation incidents)

Pipeline – Any Volume (includes leak or ✓ ✓


break during pressure testing)

Oilfield Wastes – Any Volume ✓ ✓

Class 3 Flammable Liquids – 200 litres ✓ ✓ ✓

Class 3 Flammable Liquids – 200 litres ✓ ✓ ✓

Class 4 Flammable Solids – 25 kilograms ✓ ✓ ✓

Class 5.1 Oxidizing Substances – 50 ✓ ✓ ✓


kilograms or 50 litres

Class 5.2 Organic Peroxides – 1 kilogram or ✓ ✓ ✓


1 litre

Class 6.1 Toxic Substances – 5 Kilograms or ✓ ✓ ✓


5 litres

Class 8 Corrosives – 5 kilograms or 5 litres ✓ ✓ ✓

Class 9 Miscellaneous Products, Substances ✓ ✓ ✓


or Organisms – 25 kg or 25 litres

TDG Class 3 Flammable Liquids (Packing ✓ ✓


Group I or II)– Any Quantity

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TDG Class 4 Flammable Solids (Packing ✓ ✓
Group I or II) – Any Quantity

TDG Class 5 Oxidizing Substances and ✓ ✓


Organic Peroxides (Packing Group I or II) –
Any Quantity

TDG Class 6.1 Toxic and Infectious ✓ ✓


Substances (Packing Group I or II) – Any
Quantity

TDG Class 8 Corrosives (Packing Group I or ✓ ✓


II) - Any Quantity

TDG Class 3 Flammable Liquids (Packing ✓ ✓


Group III) – 30 litres or 30 kilograms

TDG Class 4 Flammable Solids (Packing ✓ ✓


Group III) – 30 litres or 30 kilograms

TDG Class 5 Oxidizing Substances and ✓ ✓


Organic Peroxides (Packing Group III) – 30
litres or 30 kilograms

TDG Class 6.1 Toxic and Infectious ✓ ✓


Substances (Packing Group III) – 30 litres or
30 kilograms

TDG Class 6.2 Toxic and Infectious ✓ ✓


Substances (Category A or B) - Any Quantity

TDG Class 7 Radioactive Materials – A level ✓ ✓


of ionizing radiation greater than the level
established in section 39 of the “packaging
and transport of nuclear substances
Regulations 2015”

TDG Class 8 Corrosives (Packing Group III) - ✓ ✓


30 litres or 30 kilograms

TDG Class 9 Miscellaneous Products, ✓ ✓


Substances, Organisms (Packing Group II or
III, or without packing group) - 30 litres or
30 kilograms

Fluid Release >10 litres from pressure ✓


vessel

Tier 1 or Tier 2 PSE (API RP 754) ✓

Tier 3 PSE if deviation from Safe Operating ✓


Limits

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Liquid hydrocarbon spills (any volume) to ✓ ✓
environmentally sensitive areas, CN
recreational areas or wildlife
habitats/refuges which are likely to attract
media attention or cause closure, stoppage
or re-routing of traffic on public road or
waterway.

Liquid hydrocarbon spills or releases from ✓ ✓


primary containment greater than 100 CN
barrels (15.9 cubic meters)

Hazardous chemical spills or releases from ✓ ✓


primary containment greater than 5000
pounds (2.27 metric tons)

On-shore produced water spills or releases ✓ ✓


from primary containment greater than 100
barrels (15.9 cubic meters)

On-shore produced water spills or releases ✓ ✓


from primary containment greater than CN
1000 barrels (159 cubic meters)

NOTE: ABSA reporting requirements are not


identified in this procedure. Refer to CPC
Pressure Equipment Integrity Manual (ALL-A0A-
00-000-FST-0001)

Regulator / ConocoPhillips
External

Gaseous Release
COP
AER

CPC

Venting 15 e3m3 Cumulative Monthly Volume ✓ ✓


(= 1 CPC recordable event)

Any volume released to ✓


environmentally sensitive areas, CN
recreational areas or wildlife
habitats/refuges which are likely to
attract media attention or cause
closure, stoppage or re-routing of
traffic on public road or waterway.

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Flaring Black Smoke ✓ ✓

30 e3m3 Flare Volume (single event) ✓ ✓

Flaring event > 4 hours ✓ ✓

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3.4. Other Reportable Events

Reporting Contacts See section 3.2, Reporting Contacts.

Reportable Events Regulator ConocoPhillips


/ External

Incident

RCMP
OHS

COP
AER
Collapse of derrick or crane ✓

Explosion – unplanned or uncontrolled (injury or ✓


potential for injury)

Failure of well integrity ✓

Fire – caused by flare or incinerator ✓

Fire – causing loss of 2m3 oil or 30 e3m3 gas or



wellhead damage

Fire – deployment of major fire-fighting



equipment (Oil Sands)

Fire – unplanned or uncontrolled (injury or ✓


potential for injury)

Flood – unplanned or uncontrolled (injury or ✓


potential for injury)

Fire – well, facility or pipeline related ✓

Pipeline incidents (including all contact) – ✓


construction or operations

Pressure equipment incidents (resulting in


property damage or injury)

Structural failure of building or structure ✓


component when necessary for structural
integrity

Off-Site vehicle incident (damage greater than ✓


$2000)

Property damage events likely to exceed $1 000 ✓


000 USD net in estimated damages (example CN
fires, explosions, collisions, acts of nature,
vandalism, theft, etc.)

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Unscheduled HSE related business interruption ✓
that will likely result in $5 000 000 USD or more in CN
estimated losses.

Any situation that should be brought to the ✓


attention of corporate management due to actual CN
or potential impact on the company.

Evacuation beyond the facilities of company ✓


employees or contractor personnel CN

Sheltering-in-place of the public ✓


CN

Mandatory evacuation of the public ✓


CN

Loss of well control that endangers the rig, onsite ✓


personnel, or the environment CN

Serious ranked marine, truck, aviation, rail, ✓


pipeline or other transportation incident involving CN
our products, property damage, spills or releases,
traffic stoppages, evacuations etc.

Acts of terrorism (e.g., bomb threats, sabotage, ✓


kidnapping, employee violence, etc.) CN

Any incident that attracts or could attract media ✓


attention including but not limited to CN
confrontations with anti-industry groups

Multiple complaints of acute illness by third ✓


parties allegedly caused by our operations or CN
products (i.e. calls by more than one individual)

4. British Columbia – Montney Reporting

NOTE: “CPC”, in and of the below tables indicates recordable events


only. Regardless of severity, all events must be reported and
recorded in Intelex.
“CN” indicates when COP Crisis Notification is required. If COP
column is checked, Intelex notification must be made within 2
business days.

4.1. Injuries and Illnesses

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Reporting Contacts Report To Contact Timeline Responsible
Royal Canadian Immediately. VP HSE SD or
Mounted Police delegate.
250-787-8140
(RCMP), non-
emergency

Primary: Immediately. VP HSE SD or


1-281-293-1746 / delegate.
Corporate Crisis 1-281-493-2767
Hotline Alternate:
1-918-661-7888 /
1-918-661-6529

1-888-967-5377 As per the CPC HSE, Regulatory


Pressure or delegate
(online report does Equipment
WorkSafe BC not serve as Integrity Manual
immediate (ALL-A0A-00-
notification) 000-FST-0001)

24 hours – CPC Chief


fatality or Inspector or
Technical Safety 1-866-566-7233 serious damage delegate.
BC or webform. must be
reported
immediately

NOTE: Technical Safety BC reporting


requirements are not identified in this
procedure. Refer to CPC Pressure Equipment
Integrity Manual (ALL-A0A-00-000-FST-0001)

Reportable/ Regulator ConocoPhillips


Recordable Events / External
Illness / Injury
Safe BC

RCMP
Work

COP
CPC

✓ ✓ ✓ ✓
Death
CN

Loss of Consciousness ✓

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Any hospital admittance due to a workplace ✓ ✓
injury or illness CN

Lost Time/ Workday Injury ✓ ✓ ✓

Incidents resulting in multiple injuries/ illnesses ✓


to employees, contractors, or the public CN

Serious injuries including loss of consciousness,


major fractures, respiratory compromise,
amputations, lacerations causing hemorrhage,

penetrating injuries, major burns, traumatic
injuries likely resulting in loss of sight, hearing, or
touch.

Medical Treatment Case ✓

Modified Restricted Duties ✓

Over Exposure resulting in disabling or



potentially disabling conditions

Over Exposure events per the COP Occupational ✓


Health Standard

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4.2. Spills and Gaseous Releases
See Attachment 2 for BC Spill and Release Reporting Guidance.

Reporting Contacts Report To Contact Timeline Responsible

Primary: Immediately VP HSE SD or


1-281-293-1746 / delegate.
Corporate Crisis 1-281-493-2767
Hotline Alternate:
1-918-661-7888 /
1-918-661-6529

Immediately Incident Owner


EMBC 1-800-663-3456
or delegate

Environment 1-800-222-6514 Immediately Incident owner


Canada (EC/CEPA) (same as AER) or delegate

As per the CPC CPC Chief


Pressure Inspector or
Technical Safety Equipment delegate.
1-866-566-7233
BC Integrity Manual
(ALL-A0A-00-
000-FST-0001)

Verify only, Incident Owner


1-888-226-883 carrier to report or delegate
*611 events.

Transport Canada
Dangerous Goods N/A N/A
24-Hour
Information
1-800-226-9600

NOTE: All environmental releases in BC are


reported through the one window EMBC Spill
Reporting Line. EMBC triages the event, which is
then forwarded to both the MOE and OGC for
follow up by the appropriate regulator.

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Reportable Events

Regulator / External ConocoPhillips

Transport
EC (CEPA)

Canada
Liquid Release

(E&P)
EPEA
MOE
OGC

COP
CPC
Hydrocarbons – 100 litres ✓
(contains no toxic materials and
does not impact water way)

Produced/Salt Water – 200 litres ✓


(contains not toxic materials)

Fresh Water – 10,000 litres ✓

Drilling Mud or Invert Mud – 100 ✓


litres

Condensate – 100 litres ✓

Any Other Fluid Which Contains ✓


Toxic Substances – 25 litres

Class 3 Flammable Liquids – 100 ✓ ✓


litres

Class 3 Flammable Liquids – 200 ✓ ✓ ✓ ✓


litres

Class 4 Flammable Solids – 25 ✓ ✓ ✓ ✓


kilograms

Class 5.1 Oxidizing Substances – ✓ ✓ ✓ ✓


50 kilograms or 50 litres

Class 5.2 Organic Peroxides – 1 ✓ ✓ ✓ ✓


kilogram or 1 litre

Class 6.1 Toxic Substances – 5 ✓ ✓ ✓ ✓


Kilograms or 5 litres

Class 8 Corrosives – 5 kilograms ✓ ✓ ✓ ✓


or 5 litres

Class 9 Miscellaneous Products, ✓ ✓ ✓ ✓


Substances or Organisms – 25 kg
or 25 litres

Waste Containing Dioxin – 1 kg or ✓


1 litre

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Leachable Toxic Waste – 25 kg or ✓
25 litres

Waste Containing Polycyclic ✓


Aromatic Hydrocarbons – 5 kg or
5 litres

Waste Oil – 100 litres ✓

Waste Containing ✓
Tetrachloroethylene – 50 kg or 50
litres

Hazardous Waste – 25 kg or 25 ✓
litres

Substance Not Covered by Items ✓


Above (up to Class 3) – 200 kg or
200 litres

Hazardous Substance Release –


Any Volume

TDG Class 3 Flammable Liquids ✓ ✓ ✓


(Packing Group I or II)– Any
Quantity

TDG Class 4 Flammable Solids ✓ ✓ ✓


(Packing Group I or II) – Any
Quantity

TDG Class 5 Oxidizing Substances ✓ ✓ ✓


and Organic Peroxides (Packing
Group I or II) – Any Quantity

TDG Class 6.1 Toxic and Infectious ✓ ✓ ✓


Substances (Packing Group I or II)
– Any Quantity

TDG Class 8 Corrosives (Packing ✓ ✓ ✓


Group I or II) - Any Quantity

TDG Class 3 Flammable Liquids ✓ ✓ ✓


(Packing Group III) – 30 litres or
30 kilograms

TDG Class 4 Flammable Solids ✓ ✓ ✓


(Packing Group III) – 30 litres or
30 kilograms

TDG Class 5 Oxidizing Substances ✓ ✓ ✓


and Organic Peroxides (Packing

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Group III) – 30 litres or 30
kilograms

TDG Class 6.1 Toxic and Infectious ✓ ✓ ✓


Substances (Packing Group III) –
30 litres or 30 kilograms

TDG Class 6.2 Toxic and Infectious ✓ ✓ ✓


Substances (Category A or B) -
Any Quantity

TDG Class 7 Radioactive Materials ✓ ✓ ✓


– A level of ionizing radiation
greater than the level established
in section 39 of the “packaging
and transport of nuclear
substances Regulations 2015”

TDG Class 8 Corrosives (Packing ✓ ✓ ✓


Group III) - 30 litres or 30
kilograms

TDG Class 9 Miscellaneous ✓ ✓ ✓


Products, Substances, Organisms
(Packing Group II or III, or without
packing group) - 30 litres or 30
kilograms

Fluid Release >10 litres from ✓


pressure vessel

Tier 1 or Tier 2 PSE (API RP 754) ✓

Tier 3 PSE if deviation from Safe ✓


Operating Limits

Liquid hydrocarbon spills (any ✓ ✓


volume) to environmentally CN
sensitive areas, recreational areas
or wildlife habitats/refuges which
are likely to attract media
attention or cause closure,
stoppage or re-routing of traffic
on public road or waterway.

Liquid hydrocarbon spills or ✓ ✓


releases from primary CN
containment greater than 100
barrels (15.9 cubic meters)

Hazardous chemical spills or ✓ ✓


releases from primary

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containment greater than 5000
pounds (2.27 metric tons)

On-shore produced water spills ✓ ✓


or releases from primary
containment greater than 100
barrels (15.9 cubic meters)

On-shore produced water spills ✓ ✓


or releases from primary CN
containment greater than 1000
barrels (159 cubic meters)

Regulator Conoco-
/ External Phillips

MOE
OGC

COP
Gaseous Release

CPC
Venting 10 kg or 15 m3 of sweet natural gas with ✓ ✓ ✓
operating pressure >100 PSI (see additional
information below)

Any volume released to environmentally ✓


sensitive areas, recreational areas or wildlife
habitats/refuges which are likely to attract
media attention or cause closure, stoppage or
re-routing of traffic on public road or
waterway.

Flaring ≥100 e3m3 if approved inlet capacity is >500 ✓ ✓


e3m3/d

20% of daily inlet capacity if approved inlet ✓ ✓


capacity is 150-500 e3m3/d

≥30 e3m3 if approved inlet capacity is <150 ✓ ✓


e3m3/d

Report gaseous releases if they meet the above criteria and any of the below:
• Are from a sweet or sour gas pipeline or associated fitting.
• A hazardous/unsafe condition exists (i.e., potential for explosion, fire,
facility shutdown).
• Off-lease odors are evident (through smell or measurement).
• If there has been or if there is potential for public complaints.
• If it takes > 4 hours to gain control (i.e., fitting leak).

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• Total volume vented is equal to or exceed 100 m3/month. Use Ministry
of Finance Forms – BC 19 and BC-20 as appropriate.

4.3. Other Reportable Events

Reporting Contacts See Sections 3.1 and 3.2, Reporting Contacts.

Reportable Events Regulator / Conoco-


External Phillips
WorkSafe BC

Incident
RCMP
OGC

COP

Explosion – unplanned or uncontrolled ✓

Fire – unplanned or uncontrolled (injury or potential for ✓ ✓ ✓


injury)

Fire – well, facility or pipeline related ✓ ✓ ✓

Pipeline incidents – construction or operations ✓

Pressure equipment incidents (resulting in property


damage or injury)

Roads or road structure – significant damage ✓

Security incidents ✓

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Structural failure of building or structure component

when necessary for structural integrity

Off-site vehicle incident (damage greater than $1000) ✓

Spills or releases of hazardous substances which are not ✓


provincially regulated, such as radioactive substances

Major damage to oil and gas roads or road structures ✓

Drilling Kicks – Pit gain of 3m3 or greater, or casing ✓


pressure 85% of MA, or 50% out of hole when kicked,
well taking fluid (LC), associated spill, or general
situation deterioration

Pipeline Incidents, such as spills during construction ✓


phase, exposed pipe caused by flooding, pipeline over
pressure, failure (without release) or any pressure
control or ESD device during operations

Security related issues ✓

Property damage events likely to exceed $1 000 000 USD ✓


net in estimated damages (example fires, explosions, CN
collisions, acts of nature, vandalism, theft, etc.)

Unscheduled HSE related business interruption that will ✓


likely result in $5 000 000 USD or more in estimated CN
losses.

Any situation that should be brought to the attention of ✓


corporate management due to actual or potential CN
impact on the company.

Evacuation beyond the facilities of company employees ✓


or contractor personnel CN

Sheltering-in-place of the public ✓


CN

Mandatory evacuation of the public ✓


CN

Loss of well control that endangers the rig, onsite ✓


personnel, or the environment CN

Serious ranked marine, truck aviation, rail, pipeline, or ✓


other transportation incident involving our products, CN
property damage, spills or releases, traffic stoppages,
evacuations etc.

Acts of terrorism (e.g., bomb threats, sabotage, ✓


kidnapping employee violence, etc.) CN

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Any incident that attracts or could attract media ✓
attention including but not limited to confrontations CN
with anti-industry groups

Multiple complaints of acute illness by third parties ✓


allegedly caused by our operations or products (i.e. calls CN
by more than one individual)

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Attachment 1 – Alberta Spill and Release Reporting Guidance

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Attachment 2 – British Columbia Spill and Release Reporting Guidance

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