Contract № 0236-22-HRR-K

- Provision of Workover Rig

Services

ODS AND RN-BVK HSE PLAN

RN-BVK
ODS ODS RN-BVK
APPROVED
PREPARED BY APPROVAL APPROVAL
BY
Signature
Date 12 Apr 2022 12 Apr 2022
Fahmi A.Taha Vladimir Gheorghe Ural Munirov
Name
Bayzulin Christescu
ODS KRI HSE Head of HSE ODS General
Manager Manager Contract Holder
Designation
CONTENTS
1. INTRODUCTION ................................................................................................................... 3
1.1. HSE TARGETS UNDER TERMS OF THE CONTRACT ..................................................... 3
1.2. POLICY AND STRATEGIC OBJECTIVES ......................................................................... 4
1.3. RN-BVK HSE POLICY STATEMENT ................................................................................. 5
1.4. ODS SUBSTANCE ABUSE POLICY.................................................................................. 6
1.5. HSE STATISTICS REPORTING AND TIME FRAME ......................................................... 7
2. PROJECT OUTLINE ............................................................................................................. 7
3. SCOPE .................................................................................................................................. 7
4. LEADERSHIP AND COMMITMENT ...................................................................................... 8
4.1. SENIOR MANAGEMENT VISIBILITY................................................................................. 8
4.2. ODS 2022 SENIOR MANAGEMENT SITE VISIT AND AUDIT SCHEDULE ....................... 9
4.3. INTERACTION BETWEEN COMPANY AND CONTRACTOR PROCEDURE .................... 9
4.4. SUB-CONTRACTOR MANAGEMENT AND COMMUNICATIONS STRUCTURE .............. 9
5. MANAGEMENT AND ORGANISATION ...............................................................................10
5.1. HSE MANAGEMENT SYSTEM .........................................................................................10
5.2. HSE BRIDGING DOCUMENT ...........................................................................................10
5.3. ORGANIZATION AND RESPONSIBILITIES .....................................................................11
6. RN-BVK GOLDEN SAFETY RULES ....................................................................................15
7. ODS LIFE-SAVING RULES .........................................ERROR! BOOKMARK NOT DEFINED.
8. READINESS TO COMMENCE OPERATIONS .....................................................................22
8.1. HAZARD IDENTIFICATION AND RISK ASSESSMENT ...................................................22
8.2. CONTROL OF WORK (PTW) AND SIMOPS .....................................................................22
8.3 TRAINING AND INDUCTION OF PERSONNEL.................................................................25
8.4 READY FOR START UP ....................................................................................................27
8.5 COVID-19 MANAGEMENT .................................................................................................28
9. HSE ACTIVITIES DURING OPERATIONS ...........................................................................28
9.1. PERSONAL PROTECTIVE EQUIPMENT (PPE) ...............................................................28
9.2. HSE LEADERSHIP............................................................................................................34
9.3. EMERGENCY RESPONSE PLAN .....................................................................................34
9.4. EMERGENCY DRILLS ......................................................................................................35
9.5. HSE INSPECTIONS ..........................................................................................................37
9.6. BEHAVIOURAL BASED OBSERVATION AND INTERVENTION .....................................38
9.7. INCIDENT INVESTIGATION PROCEDURE ......................................................................39
9.8. ROAD SAFETY AND JOURNEY MANAGEMENT ............................................................39
9.9. HEAVY EQUIPMENT MOVEMENT ...................................................................................40
9.10. LIFTING OPERATIONS PLAN ........................................................................................41
10. ODS SAFETY PROCEDURES MANUAL ...........................................................................42
11. ENVIRONMENTAL MANAGEMENT ..................................................................................43
12. HSE MANAGEMENT AUDITING, REVIEW IMPLEMENTATION PLAN.............................43
12.1. HSE MANAGEMENT SYSTEM AND AUDITING .............................................................43
12.2. CONTINUOUS IMPROVEMENT OF HSE PERFORMANCE (HSE IMPROVEMENT PLAN)
.................................................................................................................................................44
13. REFERENCES ...................................................................................................................46
ATTACHMENT 1 – INCIDENT NOTIFICATION AND REPORTING FLOWCHART .................47
1. INTRODUCTION
The HSE plan will provides the reference for all ODS (CONTRACTOR) Integrated Drilling
Operations, to be carried out in safe manner to ensure no damage to people, equipment, environment
and process by preventing possible losses in MIRAWA Oil field which operate under RN-BVK
(OPERATOR COMPANY).
This HSE plan is designed to:
• Provide an overview of how HSE will be managed during the drilling/workover project.
• Address hazard identification, assessment, control and recovery measures for those
operations.
• Demonstrate that hazards associated with a short onshore drilling program in Kurdistan have
been identified and barriers installed and kept effective to prevent escalation to undesirable
consequences.
• Demonstrate the effective interfacing and the definition of responsibilities of the company
HSE management systems of ODS.
• It provided the platform for the integration of the HSE management systems and provides
evidence to management. Implementation will be checked in order to ensure that ODS safety
critical task is informed of its nature.

1.1. HSE TARGETS UNDER TERMS OF THE CONTRACT

ODS target is that no harm comes to any person, and that damage to the environment is minimized,
during any of the activities while workover and testing the MIRAWA 1 well.
There is a duty on all Company and Contractor personnel to ensure that this HSE Plan is
implemented effectively. There must be the intention, in the way that we go about the work at site,
to prevent harm and to keep the risks associated with the work As Low as Reasonably Practicable
(ALARP).
HSE Objectives
▪ Protect personnel from any health hazards that may be associated with the work
▪ Provide accident free environment to ODS and Contractors' employees
▪ Maintain compliance with all the applicable HSE Legal/Regulatory requirements
▪ Improve HSE culture among ODS and Contractors employees
▪ Reduce environmental impacts and improve performance regularly
▪ Pursuing “zero accident, zero injury and zero loss”
▪ Observing safe working procedures and practices.
Proactive KPI’s
▪ 80% annual compliance of training plan
▪ 100% annual compliance of HSE management review meeting
▪ 90% annual compliance of emergency mock drills
▪ 90% annual compliance of HSE inspection and audits
▪ 90% annual compliance of management site HSE walk downs
▪ Closer of all internal/external audit and incident investigation recommendation with in the
stipulated time frame
▪ 90% average spot card reporting by each department from their total staff
▪ 1.5% reduction of consumption

Commitment and Ownership of HSE Goals and Objectives

SMART HSE goals and objectives are aligned throughout the organization down to the field level.
They are visibly demonstrated and are being achieved.
ODS Rig Operation will have pre-determined goals and objectives which may include leading
and/or lagging indicators, covering HSE.

Rig management and senior crew personnel have individually owned HSE targets and time frames.

Input to individual HSE objectives will be sought from those directly involved in their achievement
whenever possible and endorsed by management.
Management will empower all individuals with authority and advise them of their obligation to stop
or intervene in any activity that could potentially harm people, the environment or assets.1.2. POLICY
AND STRATEGIC OBJECTIVES

ODS EHSS Policy – ODS EHSS Commitment

1.3. RN-BVK HSE POLICY STATEMENT
1.4. ODS SUBSTANCE ABUSE POLICY
1.5. HSE STATISTICS REPORTING AND TIME FRAME

Safety statistics shall be gathered on a monthly and weekly basis and reported to the Company by
ODS’s HSE representative.

HSE Statistic Data shall be provided in accordance with Company’s template.

2. PROJECT OUTLINE
Following preparation and planning activities, well operations at MIRAWA-1 Well Pad, will be
conducted in the following phases: All of these phases and their associated activities shall be
covered in one HSE plan.

1. Mobilization: of the Workover unit to site and preparation for operations.

2. Workover, Testing and Completion Operations: includes all and any subsequent Workover,
Testing and Completion operations if required this will also include demobilization of the Workover
unit. This phase commences when the well is spudded.

Simultaneous construction and mobilization operations (SIMOPS) were not planned at the outset
of the project. If any SIMOPS activities are going to take place, then Company SIMOPS procedure
shall be applied to plan relating to simultaneous operations and control of work at site.
The purpose of the HSE Plan is to give detailed guidance with regard to the implementation of the
HSE Management System. This includes stipulating the activities that are to be carried out prior to
start up and on a daily, weekly or monthly basis.

3. SCOPE
This HSE Plan covers the implementation of HSE management all workover related activities
during well operations at Mirawa-1 well pad. This includes all activities related to the mobilization
and subsequent rig up of the workover unit on site, variety of operational task for workover activity
such as:

a. Mobilization/demobilization of the rig, rig associated equipment and camp to/from a

location specified by Company,

b. Rig up/rig down, commissioning / decommissioning the rig, rig associated equipment
and camp on location, at the area suggested by Company

c. Kill the well prior operations start, if required as specified by Company;

d. Re-entry and workover of (a) well(s) to further operations as specified by Company,

i. Contractor shall have available on well location the set of equipment to drill/mill out
cement/bridge plugs according to casing sizes;

e. Remedial works of (a) well(s) as specified by Company,

f. Well testing (dst) of well(s) as specified by Company,

g. Completion of (a) well(s) as specified by Company,

h. Stimulation of (a) well(s) as specified by Company,

 i. Other operations required by Company that may be performed by the rig within the
technical specifications and with the contractor’s personnel given in contract’s section 7
- appendix 1 – workover rig technical specification as well as the HSE work performed
with-in contract’s section 5 – health, safety and environment

j. Services that may be performed by contractor with the use of specialized third party, as
specifically provided for in the contract,

k. Assistance (provide attendance and facilities) to Company's other contractors in per-

forming their services on the rig.

4. LEADERSHIP AND COMMITMENT

4.1. SENIOR MANAGEMENT VISIBILITY
ODS Senior management will allocate the necessary resources, such as time, people and money to
HSE matters which need to be address. Senior all times, leading by example, showing visible
commitment and active participation in achieving continual improvement in ODS QHSE
standards;
ODS Senior Management commitment include:

▪ make regular visits to all operational work areas and sites

▪ Attending Weekly HSE meetings (Action Tracker, Weekly Incident and HSE performance
Review Meeting)
▪ Putting HSE matters high on the agenda of meetings, from the board downwards
▪ Being actively involved in HSE activities and reviews, at both local and remote site
▪ ODS senior management will do Audit and inspection visit each quarter
▪ Personally instigating HSE audits and reviews
▪ Promoting a positive culture at all levels
▪ Recognizing HSE performance when objectives are achieved
▪ Inviting client to scheduled contractor senior management visits.
▪ Visits will include an assessment of the effectiveness of the risk management controls and
barriers in place.
4.2. ODS 2022 SENIOR MANAGEMENT SITE VISIT AND AUDIT SCHEDULE

4.3. INTERACTION BETWEEN COMPANY AND CONTRACTOR PROCEDURE

Interaction between Company and contractor procedure will be followed as per HSE Bridging
Document signed Between RN-BVK and ODS. The document Reference number is RS/ODS –
HSE-BD – 001.

4.4. SUB-CONTRACTOR MANAGEMENT AND COMMUNICATIONS STRUCTURE

ODS have Contractor Management Procedures (Ref# ODS-QHSE-SP-003) where ODS implement
to manage the subcontractor that perform for ODS project or the project that ODS perform as
contractor.
5. MANAGEMENT AND ORGANISATION
5.1. HSE MANAGEMENT SYSTEM

Well Operations in all project phases will be conducted in accordance with:

1. RN-BVK HSE policies and standards

2. ODS HSE policies and standards which part of ODS HSE Management System as broken down
below:
▪ Demonstrated HSE Leadership and Commitment
▪ Health & Safety Management
▪ Environmental Management
▪ Operational HSE Management

In case of conflict, the order of precedence shall be as above, where #1 RN-BVK HSE Policies and
standards precedence overall.

5.2. HSE BRIDGING DOCUMENT

The HSE Bridging Document is encompasses RN-BVK and ODS activities associated with
PROVISION OF WORKOVER RIG SERVICES at MIRAWA, Block 11.

The Bridging Document process does not supersede the independent contractor status of those
working for ODS, or other companies, but provides a baseline / framework whereby all parties can
understand how the facility or site will be operated, efficiently and in accordance with RN-BVK or
the ODS HSE requirements.

The scope of the document will include but not be limited to:
▪ The Contractor’s organization for the work and reporting relationships with the Company
organization.
▪ HSE reporting responsibilities including incident investigation / reporting.
▪ A description of the Contractor’s policies, procedures and systems that will be adopted for the
work to meet the requirements of this plan e.g. Journey Management, Permit to Work, Risk
Assessment etc.
▪ A description of the Company policies, procedures and systems that will be adopted in line of
the Contractor’s if they do not exist or do not meet the requirements of Company HSE policy.

A detailed HSE Plan, Risk Register and Job Safety Analysis Library have been developed as an
outcome of this Bridging Document and will be the key day to day documents to deliver the
expected level of HSE performance.
5.3. ORGANIZATION AND RESPONSIBILITIES

Country Manager
The ODS Country Manager is accountable but not limited to:
▪ Regularly reviews the reports of HSEMS implementation and HSE performance to ensure
its continuing suitability and effectiveness.
▪ Cooperate with Company Project manager on all operational and contractual matters;
▪ Ensure the implementation of HSE Policy;
▪ Allocates sufficient resources for HSE implementation;
▪ Organize and review HSE annual plan and monitor the implementation process.

ODS QHSE Manager

▪ Commit the resources to meet and/or exceed the requirements agreed to in the HSE plan;
▪ Demonstrate the commitment to high HSE standards through regular visits to site during
which he will be involved in audits, Job Safety Analyses, safety meetings.
▪ Cooperate with the Company management to assure compatibility and agreement between
Company and ODS’s safety systems, plans and objectives. Implement programs and plans;
▪ Make certain that all incidents involving injury to persons, damage to property /equipment
or the environment, and those having reported and investigated;
▪ Make suitable arrangements for consultation with ODS line supervisors, employees and
service and subcontractors' representatives on health, safety and environmental matters.
ODS Drilling Superintendent
Liaise directly with the Company Workover Supervisor and he is responsible for HSE management
in the rig site, including below:
▪ Operational hazards are identified, assessed, and appropriately managed using HSEMS of
ODS;
▪ HSEMS are implemented and maintained for all workover activities;
▪ All crew members are trained in correct operating procedures and policies. He is to make a
particular effort to make new crew members HSE conscious and verify their job knowledge;
▪ Equipment is operated within its design parameters, and maintained to operate safely within
design parameters;
▪ Operational and equipment checks are conducted by crew’s pre-tour. Any non-conformance
is noted, prioritised for correction, and communicated to the Company Drilling Supervisor;
▪ Rig Emergency Response Process is operable and tested and all site staff are competent to
perform their assigned duties;
▪ Safety rules and procedures are followed and should transgressions be observed; corrective
action is taken to ensure future compliance.

ODS Toolpusher

The Toolpusher is responsible, for the safe execution of all well work programs issued through the
ODS Drilling Superintendent.
▪ Workover and associated equipment (inclusive of lifting appliances) is inspected and
maintained in accordance with the inspection program and the preventive maintenance
system;
▪ All lifting and rigging practices are conducted appropriately and by competent persons;
▪ Third party equipment is inspected to ensure safe integration of that equipment within
ODS’s operations
▪ Verifies that staff under his authority are knowledgeable of their role and competent to
perform it;
▪ Ensure Workover equipment is maintained in a safe and operable condition;
▪ Hazardous work is performed under the permit-to-work system;
▪ Regularly monitors well conditions by liaising with relevant staff and ensures that proactive
steps are taken to maintain primary well control such as flow check and kick drill;
▪ Encourage all crew members to make HSE suggestions and recognise their ability to
contribute to accident prevention; Encourage crews to participate in the STOP program;
▪ Act as the link between senior and junior rig supervision by attendance at both groups
meetings and disseminating information as appropriate;
▪ Observe well and workover parameters for any abnormal downhole situations, and take
corrective actions in a timely manner;
▪ Coordinate and organize activities of all service companies related to Workover operations;
▪ Carry out periodic formal inspections and ensure correct maintenance of operational and
safety equipment;
▪ Conduct pre-tour meeting and toolbox talks.
ODS HSE Supervisor
▪ The ODS HSE Supervisor reports to the ODS HSE Manager and is responsible for the
supervising and instruction of all the HSE work at the well site:
▪ Be knowledgeable and apply the systems detailed in the HSE Bridging Document, and all
HSE Management System Components;
▪ Insist that safe work practices are observed and ensure that Job Safety Analysis are carried
out for identified hazardous tasks;
▪ Ensures that all persons working onsite have gone through the full induction program, and
that visitors have received safety introduction;
▪ Ensures that the Permit work system is implemented as per its design and Ensures that all
hazardous work is carried out under the permit to work system;
▪ Participates in Job Safety Analysis, daily pre-tour meetings, weekly safety meetings and all
toolbox talks;
▪ Carries out daily informal site safety inspections and weekly formal inspections and initiate
actions to ensure rectification on a timely basis;
▪ Ensures all accidents causing injury to personnel or damage to equipment and all significant
near misses are reported immediately to the Company Workover Supervisor/HSE
Supervisor and that they investigate at the appropriate level.
▪ Conducts the weekly HSE meetings in conjunction with the Company HSE Supervisor;
▪ Ensures that all Material Safety Data Sheets for all products are onsite, and that persons are
briefed prior to handling hazardous substances;
▪ Provides emergency response support, both personally and together with the crews and
conduct exercises on a weekly basis;

Driller/Assistant Driller
As the first line in the supervision of personnel, the Driller's prime objective is to ensure that
instructions are fully understood so that they can carry them out competently and safely. It is
important that the driller ensure that his instructions are understood by the crews. It is his
responsibility to:
▪ Ensure compliance with ODS work procedure for all applicable Workover activities;
▪ Verify that crew personnel are competent to carry out their work and use safe working
practices;
▪ Ensure that the introduction of any consequent changes in procedure should be implemented
with the approval of the Toolpusher and Company Workover Supervisor;
▪ Ensure that all instructions of the Day Toolpusher and Toolpusher concerning work methods
and equipment are carried out;
▪ Ensure that crew members fully understand their duties when carrying out a job;
▪ Take necessary steps to correct hazardous conditions and incorrect practices and check that
protective devices are in good condition and used when needed;
▪ Anticipate hazardous conditions and remove the cause of possible accidents;
▪ Ensure that crew members complete each job in an orderly way and leave no hazardous
conditions behind;
▪ Promptly report any unsafe equipment that cannot be corrected by the Workover crew;
▪ Encourage all crew members to make HSE suggestions and recognise their ability to
contribute to accident prevention;
 ▪ Constantly monitor well conditions and being conversant with COMPANY’s well control
methods and be able to react accordingly;
▪ Ensure proper use is made of the 'Permit-to-work System';
▪ Prepare an adequate tour handover to ensure continuity during shift changes.

Derrickman
Derrickman’s duties include work above the floor level during tripping and tubular connection
activities. He is responsible to:
▪ Inspect and report to the driller the condition of the derrick, condition of the ladder fall arrest
safety line, and the monkey board inertia reel safety line;
▪ Note and report changes in the condition of the derrick or hazards that have developed during
their tours in the morning and evening tour;
▪ Conduct pre-job checks for safety of the derrick and monkey board prior to activities and
conduct weekly derrick inspections;
▪ Handle all various duties above the derrick floor: lubrication of the hoisting equipment,
stringing of lines, minor repairs to the hoisting equipment and derrick, and inspection and
maintenance of all overhead equipment;
▪ Inspects the lanyard and inertia reel fall arrest mechanism prior to use, corrects any
deficiencies immediately;
▪ Never be out on racking fingers when traveling block and hook are passing. Any instrument
used in the derrick for racking or un-racking pipe should have a proper safety line attached
to it.
▪ Prior to each rig up the Derrickman should test the escape device on the ground to be sure
it is in good working condition;

Electrician
Electrician will be responsible for the reliable and safe operation and maintenance of the electrical
systems at the rig and camp site. Ensure that electrical safety precautions are adhered to. Including
but not limited for protective barriers are in place on circuit boards, insulation mats are in place in
the SCR, insulation gloves are used, electrical wiring and grounding systems conform to acceptable
standards and pose no hazards and electrical equipment is maintained in a reliable and safe manner;
▪ Carry out periodic formal inspections and test functions of electrical safety equipment;
▪ Carry out maintenance and routine inspection of electrical machinery and equipment in
accordance with the Planned Maintenance System;
▪ Ensure all isolations to machinery are in compliance with lock out/tag out procedures;
▪ Ensure related workshops, work areas and equipment are always kept clean and tidy
▪ Ensure the Work Permit system is controlled, and adhered to as per the requirements of the
system;
▪ Ensure the safe and efficient functioning of electrical emergency equipment (lights, backup
systems);
▪ Carry out daily site routine safety inspections, note any deficiencies and initiate corrective
actions;
▪ Co-ordinate Job Safety Analysis activities for his area of responsibility;
Mechanic
Responsible for reliable and safe function of rig equipment and the maintenance and repair of any
equipment as per the Preventative Maintenance System. Ensure workshops, work areas and
equipment are maintained in clean and tidy condition. Carry out daily site routine safety inspections
of mechanical rig equipment and initiate actions to correct any deficiencies noted on a timely basis;
▪ Ensuring that all isolations are in place for any energised equipment prior to any mechanical
repairs and/or maintenance;
▪ Carry out periodic formal inspections of process safety equipment on mechanical equipment
and ensure that their function. Any deficiencies should be noted, reported and repaired in a
timely manner;
▪ Co-ordinate Job Safety Analysis activities for his area of responsibility;
▪ Ensure effective communication with electricians and Workover crew regarding repair
and/or maintenance of equipment;
▪ Ensure the Work Permit system is adhered to as per the requirements of the system;

ODS Sub-Contractors and Service Company Employees

▪ Follow HSE Management System and well site rules;
▪ Participate in safety performance reviews with line management;
▪ Follow ODS PTW system and develop work method statements/ Job Safety Analysis for
their scope of work;
▪ Provide when requested representation to all site meetings;
▪ Consult with line management to coordinate work place activities;
▪ Conduct formal & informal work place hazard inspections;
▪ Participate in the ODS Observation and Intervention Program and weekly safety meetings;
▪ Conduct toolbox/pre-start meetings when required associated with the scope of work of their
activities;
▪ At all times, comply with the relevant guidelines formulated and disseminated through
inductions, toolbox meetings and daily site instruction.

6. RN-BVK GOLDEN SAFETY RULES

GENERAL REQUIREMENTS
1. GSR are designed to protect the life and health of Branch, contractor and subcontractors’
employees.
2. GSR are mandatory for Branch, contractor and subcontractors’ employees.
3. Leaders at all levels shall organize and personally control compliance with the requirements
of the GSR by employees of the Branch, contractor and subcontractors.
4. All managers accountable for operations are fully responsible for organization of safe work in
compliance with the requirements of the GSR.
5. Violation of GSR is a disciplinary offense causing disciplinary actions: warning, reprimand,
dismissal (Annex 3).

1. LEADERSHIP

I start the work if:

1. I have identified the existing hazards and have taken actions to avoid/mitigate them;
 2. I know what actions I need to take in case of an emergency;
3. I have had an HSE Induction before the start of the work;
4. I have been trained in HSE;
5. I feel healthy;
6. I am not intoxicated by alcohol, drugs or toxic substances;
7. I have been provided with necessary individual and/or collective protective equipment;
8. I have permits to conduct hazardous works and have been instructed on safety precautions;
9. I have made sure that the hazardous area is marked with warning tape and/or safety signs;
10. I have made sure that there are no people within the work area who are not involved in the
work;
11. I have made sure that the work will be supervised and controlled;
12. I have made sure that the equipment, mechanisms, tools, devices and safety equipment that
may be used for work are fault free.

I am responsible for my own safety and the safety of people around me.
I know that I must not conduct the work in a situation directly threatening my life and health and I
am ready to stop the work.
I take immediate action to stop the work if there is a threat to peoples' life and health.
I work safely and encourage my colleagues to do the same.
2. ISOLATION OF HAZARDOUS ENERGY
Any work may be started only if:
1. All sources of hazardous energy are identified, isolated, de-energized, bled off or discharged;
2. Equipment/machinery are appropriately locked and tagged out with warning safety signs at
the shutdown points.
3. Verification that the system is properly locked out before beginning any work is done.

It is prohibited to disable safety system and fire protection system, remove warning signs, de-isolate
equipment, by-pass or deactivate safety guarding devices until all works on the equipment are fully
completed.
3. WORKING AROUND MACHINERY

Moving (rotating) parts of equipment, apparatus or machinery must be operated under the following
conditions:
1. Safety devices such as barrier guards or guarding devices are installed, safety signs and
warning color in place.
2. There is a possibility to shutdown an equipment / machinery (in any abnormal situations).
3. The equipment shall not in the absence or malfunction of protective devices and units is
prohibited.
It is prohibited to operate the equipment in the absence or malfunction of protective devices.
4. WORK IN A CONFINED SPACE
Works in confined spaces should be performed under the following conditions:
1. There is no acceptable alternative way of performing the work without a person involvement.
2. Containers and equipment are grounded when required.
3. Continuous gas test of the air environment is provided.
4. Standby person and rescuers are assigned and on duty at the entrance to the confined space.
Specific to workplace hazards a personal protective equipment shall be worn when entering any
enclosed space or vessel dependent on the identified hazards e.g. slicker suits, rubber boots, rubber
gloves, eye and respiratory protection.
Where potential exposure to hazardous substances in the vessel is acute, or requires personnel to
wear respiratory protection or where rescue may be difficult, the person/persons shall be provided
with a body harness and lifeline attached, air supplied breathing apparatus or a SCBA.
5. GAS HAZARDOUS WORKS

Work under conditions of presence or possibility of release into the working area of explosive /
flammable or harmful vapors, gases and other substances, as well as working in oxygen-deficient
atmosphere (less than 20%), including work inside apparatus, tanks, cellars, tunnels, trenches, pits
and other similar places shall be carried out under the following conditions:
1. The number of persons performing the work is sufficient for the safe execution and
emergency response, but should not be less than 2 (two) persons.
2. Continuous gas testing must be carried out in the workplace and in the hazardous area.
3. Fit for purpose and checked Respiratory Protective Equipment is used.
4. A harmful and/or explosive and flammable substance (including from related technological
systems), all sources of ignition (in particular, it is prohibited to have mobile phones and other
devices that are not explosion-proof) shall be excluded from the actual work location and
immediate surrounding area.

In case of any abnormal situation, gas-hazardous works must be immediately stopped and workers
removed from the hazardous area.

6. EXCAVATION WORKS

The works which are not related to works in confined space and including digging of holes, trenches
and pits by excavation shall be carried out under the following conditions:
1. Support / shield system or sloping the sides is in place and its stability is monitored.
2. Visual control over the soil stability is provided.
3. All underground utilities (pipelines, electrical cables, etc.) are isolated.
4. At least two (2) persons are engaged to carry out the work.
5. Pits and trenches are safely fenced with warning signs, and signal lighting at night.

It is prohibited to keep the excavated soil (spoils) closer than 0.6 m from the trench edges.
7. HOT WORKS
Works involving open fire, sparking formation, and heating up to the ignition temperature of
materials and structures (welding, gas cutting works, soldering works, mechanical metalworking
with spark generation, use of heat gun, etc.) shall be carried out under the following conditions:
1. The working area is prepared for safe work, and equipped with the primary firefighting
equipment.
2. The working area is protected from external fire hazardous and explosive substances;
3. When required and in accordance with the risk assessment, a gas test of the air environment
in the hot work area is carried out.
A fire watch shall be maintained for at least a half hour after completion of welding or cutting
operations to detect and extinguish possible smoldering fires. Depending on the work done, the area
may need to be monitored for longer (up to 3 or more hours) after the end of the hot work until fire
hazards no longer exist.

8. WORKS AT HEIGHT

Works at height of above 1.8 m should be carried out under the following conditions:
1. The working area has railings, and the ascent and descent to the working area is safe;
2. If there is no railing, workers should use properly checked fall arrest equipment;
3. The surface of the floor of the working platforms excludes slip.

Every work at a height of less than 1.8 m must be carried out after taking the necessary measures to
prevent a fall.
Works at heights are prohibited:
1. At a wind speed of:
▪ 15 m/s and higher for all types of works
▪ 12,5 m/s and higher for manual oil measurement and sampling from tanks
▪ 10 m/s and higher for assembling/ disassembling of structures
2. When icing
3. During a thunderstorm
9. LIFTING OPERATIONS
Lifting operations, with the use of cranes, winches, hoisting appliances, lifting equipment, shall be
carried out under the following conditions:
1. lifting appliances, gears, accessories and equipment have passed thorough examination and
approved for operation.
2. Load weight does not exceed the acceptable safe working load of lifting appliances and lifting
accessories.
3. All safety devices (load moment limiter, level indicators, data loggers) are in operation.
4. All lifting equipment, appliances and accessories are visually examined before each lift,
including safe positioning of the lifting appliances.
It is prohibited:
1. To move load when people are standing under the load.
2. To stand within a fall zone, as well as under the boom when it is raised and lowered.
 3. To move people and loads using lifting appliances not designed for such purposes.
10. ROAD SAFETY
All categories of vehicles should only be operated if the following conditions are met:
1. Vehicles have passed a pre-trip vehicle check and periodic maintenance;
2. Number of passengers and the load do not exceed manufacturer's technical specifications;
3. The vehicle is operated with proper seasonal tires;
4. The seatbelts are fully functioning and worn by the driver and all passengers;
5. Drivers have passed a medical examination, have no medical contraindications, are not under
the influence of alcohol, narcotic (toxic) substances or medications, and do not experience
fatigue.

When operating vehicle, it is prohibited:

To use mobile phone and any other communication devices;

Exceed the indicated speed limits.

In no circumstances will managers and passengers force the drivers to violate driving safety rules.

11. PERSONAL PROTECTIVE EQUIPMENT

Proper use of personal protective equipment is a mandatory requirement for all employees of the
Branch, as well as for contractors and other persons at production facilities.

In cases where the contractor's requirements for personal protective equipment are lower than the
Branch’s requirements, the contractor should adhere to the Branch’s requirements.

The use of personal protective equipment is mandatory when performing work on fire and explosive
production facilities and construction sites.

12. UNEXPLODED ORDNANCE AND MINES

If there is a known existence of Unexplored Ordnance (UXO) or Mines in the area of works or there
is a high probability of their existence, then works should be performed only if the following
conditions are observed:

▪ Work and travel should only take place in areas that are declared safe and duly marked.
▪ Any areas of potential UXO or Mines have been identified, secured and clearly marked in
the field and highlighted on appropriate maps;
▪ The relevant employee, contractor, or subcontractor has been made aware and fully briefed
on the limitations of movement related to the work.
▪ In the event of suspected UXO or Mine being encountered the finder shall:
 Immediately cease work in the vicinity of the UXO or Mine.
 Ensure that no person goes closer than 25 meters to the suspect item.
 No attempt shall be made to disturb, move, or further expose the UXO or Mine.
 Immediately report the discovery of the UXO or Mine to the relevant supervisor,
advising on the location and the best point of access (providing both photograph and
GPS coordinates of the item if possible).
  If machinery or equipment was involved in uncovering the item, it shall be left in
place to prevent the risk of further disturbance;

7. ODS LIFE-SAVING RULES

ODS have 8 Life-Saving Rules focus on the activities which, through rigorous data analysis, have
been shown to result in fatalities most likely. These LSR were align with IOGP Life Saving rules.
Each Rule consists of an icon and simple life-saving actions individuals can take to prevent a
work-related fatality.

The Life Saving Rules set out simple and clear industry safety rules covering activities with the
highest potential safety risk. These rules are created from industry lessons and have been put in
place to ensure consistent behaviours are followed to prevent the kind of incidents that could result
in a serious injury or a fatality. Implementation of these rules is part of Optimum Drilling Services
commitment for continuous improvement in HSE and has a tangible contribution to strengthening
our safety culture.

These rules are summarized below:

8. READINESS TO COMMENCE OPERATIONS
Prior to perform the rig mobilisation operations, a number of requirements must be fulfilled to
demonstrate that the work can be safely executed and identify any gaps and areas of improvement.
This process will make sure both Company and Contractor to have more efficient rig move & rig
up process. And it will facilitate opportunity of pre-identifying of improvement opportunity which
later effect the performance if commission and Workover process.

8.1. HAZARD IDENTIFICATION AND RISK ASSESSMENT

Prior to the commencement of Workover Operations, the Company Workover Supervisor and
Workover HSE supervisor will conduct a Hazard Identification and Risk Assessment meeting with
ODS. This will be a multi-disciplinary meeting and will result in the issue of a Risk Register and
Job Risk Assessment Library for Workover Operations at MIRAWA-1.
The objective is to identify and assess the risks associated with the activities to be carried on
MIRAWA-1 and to develop actions in order to mitigate the risks to an acceptable (ALARP) level.
This will also become a living document which allows it to be revised and updated and ensure that
relevant lessons learned are passed on to any subsequent workover operations.
Where necessary, any actions arising from the risk assessment must be closed and the mitigating
measures in place prior to the commencement of operations.

8.2. CONTROL OF WORK (PTW) AND SIMOPS

During pre-workover operations, ODS has taken overall control of site and implemented a Permit
to Work (PTW) system. On arrival of the first Contractor personnel and equipment at site prior to
establishing their camp and supervision, all Contractors will fall under the direct control of
Company. ODS will put in place their safe system of work, including PTW and associated
procedures / risk assessments, at which time direct control of Contractor’s activities will be
delegated to their senior supervisor at site.
General requirements:

▪ No work may take place under Contractor control until their safe system of work is in place
and agreed with Company HSE Department.
▪ Rig up / down of the Workover rig will not commence until Contractor’s PTW system is in
place.
▪ All other RN-BVK contractors engaged for workover operations at MIRAWA are to follow
ODS PTW system.
▪ Any planned hazardous works in the immediate vicinity of production facility and having
potential adverse impact on production facility shall be communicated and agreed with Area
Authority of Company Production Department. Depend on risk assessment, reviewed by
Workover supervisor and Workover HSE supervisor, Contractor can be requested to obtain
Company’s PTW, to ensure sufficient control over the upcoming operations is established.
▪ If any construction or production activities are planned at MIRAWA while workover
operations are ongoing at the same site, the Company’s SIMOPS procedure will be raised
at site concerning how work will be controlled to prevent any unnecessary conflict or
interference between activities.
ODS PERMIT TO WORK

The Permit to Work System is a communication tool that authorizes a specific work, at a specific
location, for a specific period of time.

A Work Permit is a signed agreement between the issuer and the receiver, which documents the
conditions, preparations, precautions and limitations before work commences.

The Work Permit must identify:

• The work to be done - a brief description of it.

• The location where the work will be done - as specific as possible.
• The hazards involved in the work place like:
− hot work – open flames
− confined space entry,
− mechanicals,
− electrical,
− pressure in lines and vessels,
− toxic or dangerous chemicals,
− explosives,
− radioactive
− drop of heavy or unusual lifts,
− drops due to overhead activities,
− flying particle due to chipping, paint spray, shot blasting, high pressure water jetting,
− Simultaneous operations that has the potential to interfere each other.
• The length of the work - date and time the work will commence and finish.
• The precautions to be taken to do the work - equipment and/or procedures that must be
worn/followed; isolation, ventilation and testing requirements.
All hazards and precautions related to the work have to be determined before the work starts.
The purpose of this procedure is to assess and manage risks inherent to potentially hazardous work on a
ODS facility with a written authorization before any work that might be hazardous to our employees,
contractors, or other parties begin

WORK PERMIT TYPE

There are 7 different Permit to Work (PTW) forms within ODS Integrated Management System, to
manage activities being carried out at the work site.

1. Cold Work
2. Hot Work
3. Explosive Range
4. LEL (Lower Explosive Limit)
5. UEL (Upper Explosive Limit)
6. Confined Space
7. Hazardous Atmosphere

Some specific activities will require more than one permit to be completed and signed before
starting the job.

Example Activity: Cleaning mud pit with high pressure water gun before changing mud type.

This specific activity will require:

▪ Confined Space Entry Permit to work inside the Mud Pit (confined Space).
▪ Cold Work Permit to use the high-pressure water gun.
ACTIVITIES THAT WILL REQUIRE A WORK PERMIT

Work permits are typically required for all non-routine work. Non-routine work requiring a work
permit includes all activities outside the regular operation of the Department/Rig.

Activities that will require a Work Permit:

▪ Entry into a confined space

▪ Hot work in any area except inside welding shop
▪ Any work that directly affects critical safety system
▪ Any construction work, overhauls, or repairs on systems or equipment in classified areas
▪ Work by contractors in classified areas
▪ Hydrostatic or pneumatic-pressure testing
▪ Activities involving radioactive sources such as non-destructive testing
▪ Activities when a known hazard exists, such as isolation or lockout/tagout
▪ Man riding Operations
▪ Special engineered or heavy lifts
▪ Any work the Person in Charge (PIC) determines is non-routine and requires a work permit
▪ Mud Pump maintenance
▪ Working at heights
▪ Handling of explosives
▪ Acid handling
▪ All work on steam lines
▪ Sand blasting during any operation
▪ Scaffold erection
▪ All Pressure Testing of equipment on the rig
▪ Diesel Transfer
▪ Flaring Gas
▪ Well Control Situations
▪ Working in high winds

8.3 TRAINING AND INDUCTION OF PERSONNEL

ODS will implement the ODS training and competency procedure to ensure that the training needs
in the organization are identified and that the training is provided accordingly to all staff whose work
affects QHSE issues and the Competence of Personnel is appraised.

Minimum Training is assigned to all ODS Employees and the other requirements must be assigned
according ODS Training Matrix (see in figure-1) based on a risk assessment for the critical
operations. The required QHSE Certifications shall be assigned maximum within 30 days after the
hiring.
Trainings are categorized as follow:
▪ Minimum Training (Level 0): a basic and general awareness covered during the New
Employee Induction Training – Minimum Training Program.
▪ Training Per Designation (Level 1): complementary training according the Job Designation.
▪ Training Per Specific Role (Level 2): Advanced specific training according to the role.
ODS personnel will have formal training as required by the Contractor’s training matrix which
defines minimum training requirements. Contractor personnel will be audited against this training
matrix prior to commencement of mobilisation operations. Where gaps exist, for Company or
Contractor, a training plan will be created and any missing minimum training required shall be
completed in a time monitored plan.
It is expected that Company personnel will already be assessed competent and have training for
their designated roles.

Nerveless, ODS properly stipulate capacity of personnel who may impact the HSE on education,
training, skills, experience and other aspects, and to ensure that employees have the necessary
awareness and capacity and are competent for tasks and responsibilities. New employed personnel
shall perform job under mentor supervision.
 Fig.1: Training Plan & Training Matrix

SITE HSE INDUCTION

It is ODS HSE Department responsibility to ensure site specific HSE Induction was developed which
cover all Site related hazards, Policies, Company grand rules and golden rules, ER arrangement and
contact numbers, Waste management, and other site-specific information.
Also require that contractors must provide each worker under their control with
appropriate supervision, instructions and information so that construction work can be carried
out, so far as is reasonably practicable, without risks to health and safety, and that this must include
a suitable site induction.
The Contractor’s HSE Supervisor will be responsible for conducting the inductions for Contractor
personnel, Company personnel (including other Company’s contractors working on site) and any
other subcontractor personnel.

Minimum Site Orientation Requirement prior to Access:

▪ All personnel, including Company personnel, will be required to complete the site-specific
induction prior to commencing work at site.
▪ All visitors including Company Personnel, who are not regularly employed at operational
locations will be inducted as a visitor and shall be escorted by their host or their
representative.
▪ Prior to the arrival on site of any associated rig move equipment a pre-start up safety meeting
will be held with all supervisors and personnel who will be working on site.
▪ Security briefing might be required on the request of company (RN-BVK).
DRILLS

The purpose of drills is for all relevant personnel to practice the workings of the various topics in
the Emergency Response Plan (ERP) to ensure competency of responders in the event of a real
emergency response before the commencement of the work.

SAFETY MEETINGS (TBT, PRE-JOB SAFETY MEETING, WEEKLY SAFETY

MEETING)

1. Weekly Safety Meetings for all personnel, with records being kept of attendees, topics discussed,
action items arising, action parties responsible for close out and target date for completion.
The main objectives of the safety meetings will be:
▪ Presentation and discussion of a relevant HSE topic and management methods.
▪ Revising outstanding observation and intervention card and discussing the trend that mark
high. Seeking ways to eliminate any unsafe practices or conditions and avoid damage to the
environment identified through ODS observation card system, inspections and/or
observations.
▪ Obtaining views and encouraging positive contributions from employees and staff.
▪ Conveying safety information and safety matters among the workforce.
▪ Increasing safety, health, and environmental awareness and obtaining commitment to the
safety, health, and environmental program.
2. Pre-Tour Meetings with crews to discuss handover and shift work plan and any expected hazards.
This should be logged, in the daily report. The meeting held by Rig Manager and Tool Pusher,
Company DSV and HSE representatives are available and express their through as well.
3. ToolBox Talks prior to hazardous operations, with all involved personnel, to ensure the job and
its inherent hazards are understood, controls are in place, the tools and work practices are appropriate,
relevant expertise is available, and permit requirements are understood and verified as being in place.

8.4 READY FOR START UP

Prior to commence of work, a number of items must be completed and are listed below.

▪ Authorization to Operate form to be approved and distributed

▪ HSE Plan to be approved and distributed
▪ Update and distribution of Contractor HSE Risk Register
▪ Acceptance of the Contractor’s HSE Plan including procedures and policies.
▪ Availability of Contractor’s designated site supervisor and HSE advisor for full time
supervision of the operation.
▪ Review with Company Drilling Superintendent, Workover Supervisor and Workover HSE
Supervisor of all Company HSE requirements including, but not limited to, HSE
Management System, Contractor’s HSE Risk Register, Contractor’s HSE Plan, Procedures
& Policies, including site specific safety induction.
▪ Presence at site of Contractor Doctor, ambulance and first treatment facilities.
▪ Contractor Journey Management procedures must be implemented and followed.
▪ Bridging Document between Company and Contractor must be in place.
▪ Kick off meeting with all Company personnel and Contractor supervisory personnel to
review HSE requirements, HSE objectives and scope of work for Well operations is to be
completed prior to full mobilisation of personnel to site and prior to spud.
 ▪ Initial detailed safety induction for all Contractor personnel engaged in well operations and
Subcontractor personnel who are not involved into well operation.
▪ Pre-spud safety meeting at site for all supervisors and personnel who will be working on the
site.

8.5 COVID-19 MANAGEMENT

All personnel working at MIRAWA shall adhere to the epidemic control measures specified in this
section.

COMPANY EMPLOYEES

RN-BVK and Mselect employees before arriving to the rig site from Company office shall provide
whether vaccination certificate (not older than 1 year) or negative PCR test (not older than 48 hours).

RN-BVK and MSelect personnel arriving to the rig site from home shall provide negative PCR test
(not older than 48 hours) and be tested by ODS rig doctor using Rapid PCR test.

CONTRACTORS AND THIRD PARTIES

Contractors, OPF staff, drivers arriving to the rig site shall provide negative PCR test (not older
than 48 hours). If PCR cannot be provided, the rapid PCR test can be taken by ODS rig doctor.

ODS CREW CHANGE

ODS personnel crew change should be carried out in accordance with ODS COVID - 19
Management procedure. ODS personnel shall possess a negative PCR test before getting clearance
for work.

MONITORING AND REPORTING OF COVID-19 SYMPTOMS

Each employee shall independently monitor his health and visit rig Doctor if he detects any
symptoms of acute respiratory viral infection or any other signs of infirmity.

Doctor shall test an employee with rapid PCR test and if it is positive notifies Workover Supervisor
and Rig Manager. Infected person shall be isolated in camp or sent home. Employer shall arrange
transportation of employee to his place of residence and ensure that employee is PCR tested in
authorized laboratory and results are submitted to Company HSE Department and Workover
Supervisor.

ODS to ensure the site specific HSE Induction is conducted to all new employees and visitors and
the epidemic control measures are communicated.

9. HSE ACTIVITIES DURING OPERATIONS

9.1. PERSONAL PROTECTIVE EQUIPMENT (PPE)

The purpose is to set ODS guidelines for Personal Protective Equipment (PPE) requirements.
Personal Protective clothing and Equipment (PPE) is intended to shield or isolate personnel from
chemical, environmental and physical hazards.
PPE is supplied by the Company to provide a level of protection for employees while on duty. It
should always be borne in mind that PPE is the last line of protection. PPE is necessary when a
hazard cannot be completely eliminated and we need to be able to adequately protect ourselves.

Personal Protective Equipment in the Operation:

Hard Hat
It is mandatory for all personnel to wear hard hat when not in crew's quarters or in offices, this
applies also to third party personnel.

▪ Hard hats shall be of the type approved by OSHA 29 CFR 1910.135, Occupational Head
Protection Standard, and/or European Union Council Directive 89/656/EEC dated 11.30.1989
and 12.21.1989 of the European Union Council Directive 89/686/EEC, Personal Protective
Equipment Regulation and/or EN 397 local government laws/regulations or standards agencies.
▪ When working at height, care must be taken to ensure that the hard hat is on and secured. A
short lanyard to attach the hard hat to the worker's clothing, or a chin-strap, is recommended.
▪ Metal hard hats and bump caps are not allowed (they are banned on all ODS sites). Neither are
hard hats which have been modified or customized.
▪ A set of approved hard hats will be kept on hand at the workplace, in each crew, for visitors.
▪ Hard hats must be less than two years old.

Full Body Safety Harness, Lanyards and Self Retracting Lifeline Devices
Harnesses, Lifeline, Lanyards and Self Retracting Devices shall be certified type, inspected by the
Company Safety Representative or Job Supervisor, on a monthly period and re-certified as per
manufacturer instructions.

Full Body Safety Harness

▪ A full body safety harness with proper lanyard or fall restrain accessory will be used any time
an employee is exposed to a fall at different level. The level difference is not limited to any
height and the type of fall restrain will have to be considered for each particular job based on
the Job Safety Analysis performed before staring the activity.
▪ Safety Harness shall be of the type approved by OSHA 29 CFR 1926.502, Fall Protection
systems criteria and practices and/or European Union Council Directive dated 24.06.1992, EN
361 EN 358, or local government laws/regulations or standards agencies.
▪ All approved full body safety harnesses will be kept clean, using fresh water only to prevent
corrosion, and inspected regularly for serviceability.
▪ If a full body safety harness is found to be unsafe, it shall be destroyed and discarded
immediately to prevent it from being used in the future.

Self-Retracting Lifeline Devices

▪ Self-Restraining Lifelines (SRL’s), also referred to as Inertia Reels, will be provided in areas
where there are not sufficient tie off points for lanyards. Common applications of this device
are: BOP stack, stabbing board, in mast or derrick, Cement or Chemicals storage tanks, Mixers
and blenders, etc.
▪ SRL’s shall be rated as minimum load capacity of 420 lbs. or 190Kg. so large workers with lots
of gear may find this to be a safe solution.
▪ The internal mechanical working parts shall be protected in a sealed section of the housing to
keep dirt and other crud away.
▪ The standard reserve lifeline retention system keeps several wraps of cable on the drum for
added
Safety Glasses, Goggles and Face Shields
The use of this Personal Protective Equipment will be considered while working with flying
particles, molten metal, liquid chemical, acids or caustic chemicals, chemical gases or vapours, or
potentially injurious light radiation.
It is mandatory for all personnel to wear Safety Glasses when not in crew's quarters or in offices,
this applies also to third party personnel.
Eye and face protection equipment that has been previously used should be disinfected before being
issued to another employee.
Do not wear contact lenses when safety glasses, goggles or face shield are required.
This Personal Protective Equipment shall fall under OSHA 29 CFR 1910.133 and 1926.102, Eye
and face protection and European Union Council Directive 89/686/EEC dated 21.12.1989 or local
government laws/regulations or standards agencies EN 166 approved eye and face protection
standard.
Safety Glasses
▪ Approved safety glasses with side shields that meet ANSI Z87.1 / EN 166. 170.171.172 (or
equivalent international standard), shall be used at all times while on-site.
▪ It is mandatory for all personnel to wear safety glasses at all times, no eye protection is required
in crew's quarters or in offices, unless indicated in the Job Safety Analysis prepared for the jobs
to be carried in those areas. This applies also to third party personnel.
▪ Prescription safety glasses will be provided by the Company when needed or may be purchased
by the employee.

Ear Plugs and Muffs

Proper approved ear protection shall be worn by personnel working for prolonged periods in the
motor rooms or any other areas where there is a noise level above 85 dB A, (such as during
cementing, Frac operations, running in 30" (762 mm) casing operations or others).

High noise areas, as indicated in the Noise Map drawing, shall be marked with warning signs.

Ear Plugs and Muffs shall comply with OSHA 29 CFR 1926.101, Hearing Protection Standards
and European Union Council Directive 89/686/EEC dated 21.12.1989 or local government
laws/regulations EN 352 or standards agencies.

The noise reduction level of the ear plug or muffs, will be chosen during the Job Safety Analysis to
reduce the noise level that personnel are exposed to a value below 85dBA.

As a reference, ear muffs will be preferred over the plugs in those jobs where personnel are
continuously exposed for time periods longer than 30 minutes or where practically applicable. Final
decision will be taken by the Crew Supervisor with the assistance of the HSE rep.

Breathing Apparatus (SCBA)

▪ Breathing apparatus will be readily available at all ODS facilities, will be maintained such that
they are ready to use and will be kept in a sanitary condition.
▪ Rig Manager or Toolpusher will ensure that employees know how to operate self-contained
breathing apparatus (SCBA) equipment. Training will be included as part of drills and safety
meetings.
▪ All SCBA’s will be inspected on a monthly basis and recorded on the ODS Form 01-01-103
F1029 Monthly SCBA Control.
▪ Unless protected by an approved breathing apparatus, no employee shall enter any area where:
▪ A deficiency of oxygen may exist.
▪ The atmosphere may be contaminated by the presence of toxic or flammable gases, vapor or
dust in sufficient quantities.
▪ Before operating in known hydrogen sulfide areas, the Job Safety Analysis will indicate the
number of respiratory protective equipment needed.

Respirators
▪ OSHA 29 CFR 1910.134, Respiratory Protection and European Union Council Directive
89/686/EEC dated 21.12.1989 or local government laws/regulations EN 140 EN 136 or
standards agencies approved respirator masks will be available and used when spray painting,
cementing, mixing chemicals, etc.

Protective Work Clothes (Coveralls – Coats)

The company work clothes standard is comprised of the following major work ensemble categories:
a) Standard Coverall
b) Welder Coverall
c) Coat
It is mandatory for all personnel to wear the company work clothes when not in crew's quarters or
in offices.
a) Standard Coverall
▪ The Standard Oil field service coverall issued to all ODS personnel is made of fabric gabardine,
255 gr/m2 100% cotton 20/1.
▪ The fabric gabardine material shall be treated with a special product to make it repellent to oil,
water and dirt, and guarantee a minimum of 40 washing cycles.
▪ Work clothes will include Reflective Stripes for better personnel identification after daylight.
(See 5.6.1 Reflective Striping)
▪ Zippers will be of Metal type (YKK Brand or similar quality), with protective wind flap and
snap closure.
▪ This standard coverall is for hot/tropical weather operations, or summer season.
▪ In cold weather operations or winter season, the standard coverall will include an internal
insulation to keep personnel warm and comfortable.
b) Welder Coverall
▪ The work clothes issued to ODS welders is standard heavy duty 100% cotton coverall
complying with NFPA 2112, EN 340 and ISO 11611:2007 and ANSI Z49.1 standards.
▪ NO Reflective Stripes in welding work clothes.
▪ Zippers will be of Metal type (YKK Brand or similar quality), with protective wind flap and
snap closure.
▪ This standard coverall is for hot/tropical weather operations, or summer season.
▪ In cold weather operations or winter season, the standard coverall will include an internal
insulation to keep personnel warm and comfortable.

c) Optional Welder Working Cloth

It is accepted as optional for welders to use standard coverall with a welding jacket on top of it.
The welding jacket shall:
- allow freedom of movement.
- protect your arms and neck from radiation exposure and skin burns (caused by ultraviolet
radiation from the arc).
- covers all areas of exposed skin.
- be made of chrome split leather with metal press stud opening.
- button the cuffs, pockets, and collar.
- Have a minimum length of 90 cm.
Coat
In addition to previous working clothes, for cold weather operations or winter season, it is included
a coat.
▪ The Standard Oil field service coat issued to all ODS personnel is made of fabric gabardine 255
gr/m2 100% cotton 20/1, with an internal insulation to keep personnel warm and comfortable.
▪ The fabric gabardine material shall be treated with a special product to make it repellent to oil,
water and dirt.
▪ The Coat will include Reflective Stripes for better personnel identification after daylight. (See
5.5.6.1 Reflective Striping)
▪ Zippers will be of Metal type (YKK Brand or similar quality), with protective wind flap and
snap closure.

Chemical Aprons
It is mandatory for all personnel to wear Chemical Aprons on top of the standard coverall when
handling chemicals or hazardous substances.
Chemical aprons will:
▪ Work Supervisor will choose the proper apron based on the Job Safety Analysis (ODS SMART
01-01-110 Job Safety Analysis) and follow the recommendations indicated in the Material Safety
Data Sheet (MSDS) for the chemical or hazardous substance used. The Data Sheet shall include
as a minimum technical chemical information, including chemical and physical properties, health
effects, exposure limits, and recommendations for medical monitoring, personal protective
equipment (PPE), and control procedures.

Safety Gloves
It is mandatory for all personnel to wear Safety Gloves if hand or any part of the hand is exposed to
a hazard during a specific job.
▪ As a minimum requirement safety gloves will have to accomplish with standard EN 420: 2003,
General requirements for protective gloves or OSHA 3151-12R 2003 Personal Protective
Equipment.
▪ Hazard identification will be covered on Job Safety Analysis (ODS 01-01-110) for each specific
job.
▪ The job Supervisor and the Rig/Unit Manager will select the safety gloves for the activities
performed by her/his Team with the assistance of the QHSE Representative assigned to her/his
Rig/Unit.
• When selecting safety gloves, they will ensure that not only adhere to the above Directive and
relevant safety standards, but also are demonstrably of good quality and fittest for the intended
task.

Safety Footwear
It is mandatory for all personnel to use safety footwear when out of the accommodation area, crew's
quarters or offices. Personnel performing any job within the accommodation area, crew's quarters
or offices, that expose her/his foot to any type of hazard shall wear foot protection (i.e. electrician,
painters, cleaning personnel, catering crew, etc.).
The hazard and the type of Footwear chosen shall be indicated in the specific task Job Safety
Analysis (ODS 01-01-110 Job Safety Analysis).

As minimum requirements safety footwear shall as a minimum:

▪ meet with appropriate OSHA 29 CFR 1910.136, Foot Protection Standards and/or European
Union Council Directive 89/686/EEC dated 21.12.1989 and/or EN 20345 and/or local government
laws/regulations.
▪ have a 200J toecap.

Other characteristics to be considered and specific for each job will include:
a) SB - basic requirements for safety footwear met
b) S1 - basic requirements plus closed and energy absorbing seat region, and antistatic
c) S2 - as S1 plus water penetration and absorption
d) S3 - as S2 plus penetration resistance and cleated sole
S4 - basic requirements plus energy absorbing seat region, antistatic
e) S5 - as S4 plus penetration resistance and cleated sole

PPE Issue and Replacement

▪ PPE will be issued by the Company, free of charge to employees.
▪ These items are the property of the Company and any willful misuse will result in disciplinary
action.
▪ Any item of PPE will be replaced by the Company free of charge upon surrender of the damaged
or worn out PPE.
▪ All Rigs/Units and yards will maintain a “PPE Distribution Records” register (ODS 01-01-105
F001) to monitor usage. Original document once completed shall be sent to HR Department,
and copy kept on the Rig/Unit or Yard.
▪ Rig/Unit Managers are responsible to ensure the PPE Distribution Record register process is
completed.
Rig/Unit Managers are responsible for maintaining an adequate inventory of PPE on hand to meet
the issuing requirements of their operation and to ensure sufficient quantities are on order to
maintain inventory levels.

PPE Care and Maintenance

It is the responsibility of the user to maintain the PPE supplied by the company. PPE should be
inspected prior to use by the employee. PPE will be replaced as per the above table by the company.
PPE should be inspected prior to use by the employee.

Training

Each employee required to use PPE shall be initially trained to know the following:
a) when PPE is necessary;
b) what PPE is required;
c) how to properly put on, remove, adjust, and wear the PPE;
 d) the limitations of the PPE; and
e) The proper care, maintenance, useful life, and disposal of the selected PPE.
The employee must demonstrate an understanding of the training, and the ability to use PPE
properly before being allowed to perform work requiring the use of PPE. Retraining must be
performed.

9.2. HSE LEADERSHIP

Contractor will follow and implement ODS-QHSE-MSM-001_QHSSE IMS Manual and ODS-
QHSE-SP006 Internal Audits Procedure which draw basing line for ODS management how they
will demonstrate effective leadership on their operation site in MIRAWA-1.

Senior management in particular has the responsibility of leading by example by demonstrating

their commitment through their active involvement in achieving continual improvement of QHSE
performance. Demonstration of this commitment will be achieved by the active involvement of
senior management in the following elements of the QHSE Management System within their areas
of control:
▪ Ensuring that the QHSE Management System requirements are established, implemented and
maintained in accordance with ISO 9001:2008, ISO 14001:2004 and OHSAS 18001:2007;
▪ Ensuring compliance with all statutory requirements;
▪ Ensuring compliance with all client requirements;
▪ The setting of targets and objectives, and making all personnel under their control aware of their
responsibilities in the successful achievement of these targets and objectives;
▪ The auditing of the QHSE Management System to ascertain compliance to the above-mentioned
standards;
▪ Ensuring corrective actions are initiated, implemented and completed to rectify all defects
identified from the audit process; and,
▪ Monitoring and reporting of the performance of the QHSE Management System for
management review and the subsequent basis for improvement.
▪ Engagement of workers to solicit constructive feedback
▪ Promotion of an interdependent safety culture
▪ Situational leadership depending on competency levels, cultures and personality types.

9.3. EMERGENCY RESPONSE PLAN

ODS will develop site specific ERP and MERP for their workover operation at Mirvava-1 in place
in accordance with Bridging Document, as well as compliance with the requirements of this
document.
Company Emergency Response Procedures will apply and take primacy over any contractors
Emergency Response Procedures if it becomes clear that emergency situation is escalating and
requiring Company Emergency Response Team responding. Reporting over any operational events
occurred at Company facilities will be according to Company Emergency Response Plan.

The complete ERP and MERP shall be developed and confirmed with the Company before the
commencement of workover operations at MIRAWA-1.

The purpose of an ERP is to plan, in detail, the appropriate and timely response to any significant
undesirable event. It is designed to bring the event under control as quickly and efficiently as
possible thus preventing and reducing further suffering, damage or losses.
ERP’s are directed at the entire worksite, including, but not limited to the well site, campsite and
search area and include:

• Company personnel (includes subcontractors)

• Contractor personnel (includes subcontractors)
• The general public

There shall be individual components to the ERP which address different issues with differing responses.
All the individual components shall be maintained together as one master plan. Items in the ERP will include:

▪ Well kick
▪ Blowout
▪ Rig failure
▪ Fire emergency
▪ Oil and Chemical spill
▪ Hydrogen Sulfide emergency
▪ Evacuation procedure
▪ Medical Emergency Response
▪ Missing vehicle / person procedures
▪ Social & Local Disturbance
▪ Natural Disaster
▪ Evacuation and mustering requirements
▪ Emergency contact list
▪ Incident command structure including reporting responsibilities with related duties
▪ Emergency equipment requirements
▪ Public notification and necessary actions (evacuation / sheltering / care)
▪ Criteria for “stand down” and return to normal activities
▪ Medevac plan in place.
For Emergency contact numbers refer to ERP and MERP.

9.4. EMERGENCY DRILLS

Effective drills address three important objectives:

▪ Demonstrate the crew’s ability to respond to a wide range of emergencies. Drills improve
and develop confidence and help identify those areas where further attention is needed.
▪ Train the crew in both individual proficiency and teamwork necessary to handle anticipated
site-specific emergencies.
▪ Test the emergency equipment.

The drills are directed to all personnel who may possibly be involved in a particular emergency
response.

Drills shall be conducted to cover each item in the ERP.

Responsibilities

Drills will be initiated and supervised by the Contractor site supervisor in cooperation with the
Company Workover Supervisor, Company Workover HSE Supervisor and in coordination with (as
appropriate):
 ▪ Medic
▪ Contractor HSE Supervisors

A timed log of events should be kept by supervisors and observers. These logs should be
consolidated into a drill report used for debriefing and disseminating information on corrective
actions to staff. A copy of the report shall be sent to the base offices of both the Contractor and
Company. Supervisory visits should occasionally include the observation of a drill.

Post drill reports will be completed by the appropriate person mentioned above and submitted to
the Company Workover Supervisor and Company Workover HSE Supervisor.

Training

It is recommended that tabletop exercises and drills be performed by supervisory personnel at the
commencement of operations.

First Aid and Cardio Pulmonary Resuscitation (F/A CPR) – Personnel designated and trained by
the Contractor as emergency medical responders.

Basic and Advanced Firefighting – Personnel designated and trained by the Contractor as
emergency response fire fighters, specifically for the camp.

Equipment Requirements & PPE

Equipment and PPE shall be used as applicable for each of the drill scenarios.

Guidelines

All drills shall be conducted as per the protocols contained in the Contractor ERP in conjunction
with the various Contractor’s’ standard operating procedures for each scenario.

A post drill de-brief shall be conducted with all participants in order to identify opportunities for
improvement for the future.

Drills may be conducted in conjunction with one another. Example: A Fire Drill may include
injuries which require medical attention and medevac.
ODS MIRAWA-1 ER Drill Schedule

ER Drill Timeline
Drills shall be conducted so that all personnel have the opportunity to participate. This may
necessitate several similar drills occurring to cover different shifts.

1. H2S Drill: Once every month for each shift

2. Man Down - Medical Emergency Drill: Once every month
3. Fire Drill: Once every month
4. Spill Drill: Once every month
5. Security drill: Once every month
6. BOP drills: Three every month

9.5. HSE INSPECTIONS

The purpose of workplace HSE inspections is to provide a scheduled systematic approach to

identifying and correcting hazards.
Inspections are directed at some combination of:
▪ Equipment
▪ Management Procedures and processes such as inductions, JSA’s, Tool box talk meetings etc.
▪ Competency evaluations and appraisals.
▪ Designated roles and responsibilities
▪ Specified inspection frequency
▪ Classification of hazards and deficiencies
▪ Follow-up to identified hazards and deficiencies

Daily and pre-job inspections shall be carried out by the personnel using the equipment.
This includes:
▪ Motor vehicles
▪ Lifting Equipment
▪ Rig equipment
▪ PPE

Monthly inspections are carried out by worksite Company supervisors (Workover and HSE) with
assistance of members of the appropriate workforce. Site and camp safety equipment shall be
inspected by HSE Supervisors of the Contractor.
Pre-mobilization inspections shall be carried out under the supervision of Company in cooperation
with the Contractor.
Company may direct external inspectors to perform inspections in cooperation with contract and
service company management.
All inspections shall be documented and sent to the Contractor’s company office as per procedures.
Records shall be maintained at the site offices. All inspections shall be available for review by the
Company representative on site.
HSE inspections shall be conducted on a weekly and monthly basis in accordance with the schedule
below:

9.6. BEHAVIOURAL BASED OBSERVATION AND INTERVENTION

Optimum Drilling Services recognizes that the behaviour of people has a direct impact upon
Service Quality, Asset integrity, Safety, Security, Health and the Environment. There for, ODS is
committed to the empowerment of its employees and contractors to STOP any activity which
threatens the integrity of our Q&EHSS performance and the assets of our Clients and Contractors
and the environment in which we operate. Along with this empowerment comes authority,
responsibility and accountability for the process amongst all our employees.

The purpose of this procedure is to establish a uniform and consistent method for the identification,
evaluation, and intervention of behavioural effects of people within Optimum Drilling Services
business activities, products and services.
The primary focus of the behaviour-based observation system shall be on the Behaviours of
people (actions and attitudes). While unsafe conditions must also be identified and intervention
made, the focus of the behaviour-based observation system is to identify and eliminate hazardous
behaviours before the behaviours create an unsafe condition or lead to an incident.

People-based observations shall be categorized according to the common behaviours noted on

the SCAR Cards Categories:

▪ The Reactions of People;

▪ The Positions of People
▪ Use and Care of Personal Protective Equipment (PPE);
▪ Use of Tools and Equipment;
▪ Use of Standard Operating Procedures;
▪ Environmental Respect.

Similarly, the behaviour-based observation system shall also identify potentially hazardous or
unsafe conditions which may pose a risk to site personnel. The categories used to assess site
conditions shall be described under:
▪ Tools and Equipment;
▪ Structures and Work Areas;
▪ Potential Failure Type
▪ Environment;
The following records shall be maintained by each site in ODS Reporting System:

▪ Site observations;
▪ Action tracking and trending;
▪ Action closeout;
▪ Feedback and communications.
▪ Training

9.7. INCIDENT INVESTIGATION PROCEDURE

Contractor will put in place their ODS-QHSE-SP-11_Incident investigation procedure for ODS
work over operation on MIRAWA-1 Well. Also, Contractor will use RN-BVK Incident Notification
and follow RN-BVK Investigation Procedure in accordance with Bridging Document, as well as
compliance with the requirements of this document.

Contractor will implement Company Incident and operational event reporting flowchart (see
Attachment 1).

9.8. ROAD SAFETY AND JOURNEY MANAGEMENT

Contractor will put in place their ODS-QHSE-SP033 Traffic and Land Transportation Management
Safety Procedure for ODS workover operation on MIRAWA-1 Well in accordance with Bridging
Document, as well as compliance with the requirements of this document.
This procedure has been developed to ensure that all site personnel on the Project are familiar with
the safety procedures while engaged activities like road obstruction/closure related hazards which
may endanger their health and safety.

This ODS procedure applies to all personnel employed by the Contractor including all of their
Sub-contractors on the Project. The control of traffic on-site are important factors in the prevention
of road traffic accidents and an important consideration in the prevention of major accident hazards
on-site. Collisions between moving vehicles, collisions between pedestrians and moving vehicles,
or the impact of a vehicle with stationary plant, vehicles or equipment can lead to physical injuries
and damage or a loss of containment of chemicals.

Contractor shall follow the Contractor Journey Management procedure and ensure compliance
with Company Road Safety Procedure as outlined in the Bridging Document

9.9. HEAVY EQUIPMENT MOVEMENT

Heavy equipment movement is one of the major hazard in workover rig operation. It may lead to
major personal injuries, environmental and equipment damage. There for ODS manage the heavy
vehicle movement via both ODS contractor Management and Road safety and journey management
procedures.
Several conditions can contribute to struck-by injuries and fatalities, including:
▪ Falling materials and loads.
▪ Equipment operator blind spots.
▪ Equipment tip-over or rollover.
Control Measures:
Pre-Planning and Safe Work Practices: When pre-planning your projects, consider these
measures to help reduce the risk of injuries when working around and using heavy equipment:

▪ Use trained and, where required, certified equipment operators and spotters.
▪ Provide heavy equipment hazard awareness and safe work practices training to workers.
▪ Provide a copy of/access to the operating manual for machinery to the operator.
▪ Develop a path site plan for vehicles, heavy trucks and deliveries to help avoid or limit
vehicles and equipment backing up.
▪ Set up a limited-access zone or swing radius around heavy equipment.
▪ Maintain equipment to be in good operating condition.
▪ Before any equipment maintenance is performed, utilize lockout/tagout procedures.
▪ Provide a cab shield or canopy worker protection for top-loading vehicles.
▪ Increase visibility and lighting for night work.
Operator Safe Work Practices: In addition to being trained and familiar with the equipment
being operated, operators can help reduce the risk of injury or fatality associated with heavy
equipment through safe practices.

▪ Be familiar with the equipment and the operator’s manual.

▪ Inspect the equipment at the start of each shift, including the brake system, headlights,
taillights, brake lights, windshield wipers and audible warning devices, such as the horn and
the back-up alarm.
▪ Adjust all side and back mirrors to help compensate for blind spots.
▪ Ensure workers are clear of equipment before operating.
▪ Acknowledge and allow safe passage to workers who alert you that they are approaching.
▪ Avoid operating equipment parallel to slopes or embankments.
▪ Turn off the engine and engage brakes before leaving equipment.
▪ Face the equipment, maintaining three points of contact, while getting on and off the
equipment.
▪ Always wear the seat belt.
▪ Avoid overloading vehicles.
▪ Top loading vehicles must have cab shields and canopy protection.

Additional risks can include contact with overhead energized utility lines by mobile cranes and poor
ground conditions.

9.10. LIFTING OPERATIONS PLAN

Lifting and hoisting operations are one of the major causes of fatalities and serious incidents in
Operations and Production activities. Every type of lift has a set of risks that need to be managed if
the lift is to be undertaken in a safe and efficient manner.
Contractor will put in place their ODS-QHSE-SP-35 Safe Lifting Operations Procedure and PTW
Standard for ODS work over operation on MIRAWA-1 Well to manage all lifting operations. Also,
Contractor will use RN-BVK Order-64_RNBVK_Lifting Operations Procedure_04122020 in
accordance with Bridging Document, as well as compliance with the requirements of this document.
The intent of ODS Lifting Operations procedure is to bring about a significant reduction in lifting
incidents by highlighting the essential principles of safe lifting and encouraging their strict
application to lifting and hoisting operations. Key elements include:
▪ Hazard Identification and Task Risk Assessments must include an individual that fully
understands lifting operations and the specific lift (s) involved in the task concerned
▪ Planning and organization of lifting operations, positioning, marking, inspecting and
examination of lifting equipment, reporting of defects and record keeping
▪ Provision of a safe work environment
▪ Adequate controls and control systems in place for lifting equipment.

Color Coding of Lifting Equipment:

Color coding of Lifting Equipment is widely acknowledged as an industrial best practice for
identifying when lifting equipment is within its certification period and is an effective visual aid
that overcomes language barriers.
In recognition of this ODS will implement the Company (RN-BVK) color code table for 2022. Due
the time frame of project is less than 6 months and the project will start at the end of 2nd quarter of
2022, ODS get approval from company HSE Management to use Yellow color code for period that
they will operate in Mirawa-1. The common color-coding system for lifting equipment shall be
implemented on all Company operated facilities.
10. ODS SAFETY PROCEDURES MANUAL
ODS HSE Manual has been produced to describe how ODS will manage HSE activities in order to
ensure its internal and contractual needs are met such that the Company may assist its clients to
achieve their project oilfield services objectives.

This document has been produced in line with ODS SMART Intergraded Management System
Procedures and has been structured to ensure specific actions are assigned to individuals for
compliance and completion. It is important that each employee understands the goals of the HSE
Manual and the manner in which the Company intends to achieve them.

ODS is committed to ensuring that personnel are adequately trained in order for them to be able to
carry out their duties without risk to themselves, others and the environment in which they work.
This HSE Manual is intended to increase individual awareness, participation and promote
ownership in the safety process with the intention of eliminating all incidents and injuries in the
workplace.

ODS HSE manual has been provided to Company (RS-BVK) which cover below main areas:

1. HSE Manual Description

2. Emergency Training Drills
3. Planned Equipment and Facility Control
4. Monthly HSE Report
5. Personal Protective Equipment (PPE)
6. ODS Observation Card Program
7. Incident Report and Investigation
8. Crane Operations
9. Forklift Operation
10. Job Safety Analysis
11. Handover Report
12. Road Safety Procedure
13. Working at Heights
14. Compressed Gas Cylinders
15. Lifting Equipment
16. Safety Alert
17. Dropped Object Prevention
18. Man-Riding Operation
19. HSE Meetings
20. Radioactive Material Safety
21. H2s Hydrogen Sulphide
22. Waste Management
23. HSE Management Review
24. Simultaneous Operations (SIMOPS)
25. Hazardous Area Classification
26. Spray Painting and Sandblasting
27. Hazardous Material Handling and Storage
28. Pressure Testing
29. Manual Handling
30. Ladders and Stepladders
31. Hammer Union Awareness
 32. Manlift Safety Procedure
33. Short Service Employees
34. ODS HSE Induction
35. Steam Cleaning and High-Pressure Water Jetting
36. Management of Rig-Up and Operation of 3rd Party Equipment
37. Housekeeping
38. Welding, Cutting and Grinding Safety
39. Fire Prevention, Control and Equipment Requirements
40. Hand Tools and Portable Electrical Equipment

11. ENVIRONMENTAL MANAGEMENT

Contractor will put in place their ODS-QHSE-SP-07_Environmental Aspect Management for ODS
work over operation on MIRAWA-1 Well. in accordance with Bridging Document, as well as
compliance with the requirements of this document.

Company will take responsibility for Disposal of household waste (garbage) and sewage from Camp
and Rig Site, and disposal of scrap metal generated by Company during Contractor’s operations

SPILL KITS AND SPILL RECOVERY PROCEDURE

ODS will provide and install right type of spill kit units to critical locations where spill might occur
potentially. Also, ODS will provide training and drill on how ER team will react to all sort of spill
incidents. Moreover, spill kit inspection is part of ODS inspection regime.

12. HSE MANAGEMENT AUDITING, REVIEW

IMPLEMENTATION PLAN
12.1. HSE MANAGEMENT SYSTEM AND AUDITING
Optimum Drilling Services has Integrated QHSE Management System (IMS) which has been
developed to provide detailed information and resources required to effectively manage Quality,
Health, Safety and Environment. All the relevant policies and objectives are defined and clearly
stated. The organizational structure and associated responsibilities for all parts of the business are
highlighted, and the arrangements put in place (e.g. standards, procedures, rules & regulations, etc.)
to ensure that all policies are implemented, controlled, monitored and improved as required.
The implementation of and compliance with the IMS is the responsibility of all personnel. The
manual provides the means of enabling everyone to fulfill that responsibility and meet the specified
QHSE objectives.
The scope of the QHSE Management System covers the organization, responsibilities and
authorities, procedures, methods and the resources to achieve and maintain a QHSE of service in
accordance with the policy and objectives of the company.
The IMS scope will cover all activities of Optimum Drilling Services worldwide which include but
not limited to:
▪ Contracts and Project Planning;
▪ Operations and Field Activities;
▪ Services and workshops;
▪ Logistics and Transport;
▪ Store;
▪ Administration and Finance;
▪ Procurement and Purchasing;
▪ Sales activities
▪ Office Activities and Support.

12.2. CONTINUOUS IMPROVEMENT OF HSE PERFORMANCE (HSE IMPROVEMENT

PLAN)
ODS continually strives to continually the effectiveness of improves HSE & Quality Management
System through the use of EHSS and QMS Policies, QHSE objectives, audit results, analysis of
data, corrective and preventive action and management review. The QHSE objectives are up-
graded gradually on routine basis for improving performance of different departments.

ODS HSE IMPROVEMENT PLAN 2022

12.3. MONITORING: HSE MS AUDIT

INTERNAL AUDITS

The procedure for internal QHSE audits reviews the adherence to, and effectiveness of the overall
company’s QHSE Management System.
Scheduled audits shall be conducted under the direction of the QHSE Management Representative
in accordance with the internal audit operating procedure and internal audit plan. Internal audits
are scheduled on the basis of the status and importance of the activity.
All systems within the QHSE management system shall be audited at least yearly and the audit
shall cover all aspects which influence product and service quality, health and safety of the
employees, and the environment.
Additional audits shall be conducted when significant organizational or procedural changes are
made or as follow-up to verify the implementation of corrective actions and problems that are
identified within the QHSE management system.
Audit results shall be documented, reported and filed along with possible non-conformance and
recommended corrective actions.
Senior management shall review the results and conclusions of internal audit reports, including
non-conformances and the relevant follow-up actions, during management review to ensure
continued effectiveness. The review shall ensure that objectives are being met, defects or
irregularities found, and positive actions taken to rectify any shortcoming.
All personnel involved within internal audits shall be adequately trained as per procedure. Auditors
conducting any internal audits must be independent of the area being audited.
The terms of reference for QHSE Management System audits will be agreed and made known to
both the auditor and the manager of the activities to be audited, and will include:
▪ The objectives and scope of the audit;
▪ The reporting format; and,
▪ A list of recipients of the audit report.
The audit program will specify:
▪ The areas and activities to be audited;
▪ The frequency of audits; and,
▪ The responsibilities for conducting audits.
The audit report will:
▪ Assess overall performance;
▪ Identify any deficiencies;
▪ Make recommendations on corrective actions;
▪ Identify strengths as well as deficiencies; and,
▪ Be written clearly and concisely.
Action plans developed as a result of audit findings will highlight responsibilities, completion
dates and reporting requirements. Follow-up monitoring will ensure that any action plans are
satisfactorily implemented.
CORRECTION, CORRECTIVE AND PREVENTIVE ACTION

This system shall establish the procedural requirement, documented actions and records for the
issue, control and subsequent required actions related to Non-Conformance Reports, Corrective
Action Reports, Preventive Action Reports and Client Complaint Forms.
The Non-Conformance, Corrective Action, Preventive Action and Client Complaint reporting
procedures shall be used as a management tool for the correcting of deficiencies which create
significant conditions adverse to quality.
N.C.R, C.A.R and P.A.R. shall be controlled by the QHSE Management Representative. These
reports shall notify senior management of significant conditions adverse to the quality of products,
workmanship and servicing operations that shall require corrective action implementation.
Significant conditions that shall require the issue of an N.C.R, C.A.R and/or P.A.R may result
from the following:
▪ Internal and external audit findings
 ▪ Management review and quality improvement meeting
▪ Client feedback, complaints or non–conformance
▪ Third party audits
▪ Inspection, testing or maintenance operations
▪ Field operations.
The relevant head shall respond in writing to all N.C.R, C.A.R, and P.A.R.’s. The response shall
comply with the time period specified and it shall indicate the cause of non - conformance, the
corrective action proposed, the action to prevent re-occurrence and the date when such action will
be implemented and completed. All reports shall be verified and approved by the dated signature
of the QHSE or his designee and the relevant head. Prior to the close-out of any reports the QHSE
shall review report to determine whether any necessary QHSE requirements have been actioned
appropriately.
The close-out shall only be transacted when all the stated and approved corrective actions have
been implemented. Original closed out reports shall be kept within the QHSE department and
copies shall be forwarded to the relevant head.
All deficiencies identified through the monitoring and review process will be subject to reactive
corrective actions and proactive preventive actions.
Procedures will be established which:
▪ Identify the root cause of the non-conformance.
▪ Record the findings of investigations.
▪ Define responsibilities for investigations and corrective and preventive actions.
▪ Communicate the findings to all relevant parties.
These procedures will specifically relate to:
▪ Risk assessments.
▪ Incident investigation and reporting.
▪ QHSE Plan implementation.
▪ QHSE inspections and audits.
▪ QHSE Management System audits.
Any proposed corrective/preventive actions need to be reviewed through risk assessment process
prior to implementation.
Any required changes to documented procedures resulting from corrective and preventive actions
will be recorded and implemented.

13. REFERENCES
1. Company HSE Policy
2. Company Golden Safety Rules No. P3-05 I-0016
3. Contractor EHSS Policy - 01 ODS-HG-P-001 EHSS Policy
4. HSE Bridging Document Between RN-BVK -LLC and Optimum Drilling Services - HSE
BRIDGING DOCUMENT_Rev.1 (003)
5. ODS 01-01 HSE Manual -Rev.1
6. ODS-QHSE-MSM-001_QHSSE IMS Manual
ATTACHMENT 1 – INCIDENT NOTIFICATION AND REPORTING FLOWCHART