FITNESS TO WORK STANDARD HSE 0096

1. FITNESS TO WORK STANDARD HSE 0096 AWARENESS TRAINING PH 4506 SEPCo HSE Occupational Health

2. FITNESS TO WORK STANDARD HSE 0096 • This is an Element of Group MHMS (Minimum Health Management Standards) • Implementation is planned to be by end 2003 • This is Applicable to: • All SEPCo employee – by end 2003 • Some elements are applicable to Core Contractors – by end 2003 • Fully applied to Core Contractors - end 2005 • Review/Approval Process: • Drafts reviewed by Legal, Medical, HR, HSE CC, Standards Process Team, P&S, D&C HSE Managers & HSE Network • Endorsed by: HSE CC, PSLT AI, WLT & OM Forum

3. FITNESS TO WORK STANDARD HSE 0096 Key Areas that a Supervisor needs to have a clear understanding are the following: • Jobs with Enhanced Fitness Requirements • Recognizing & Addressing FtW issue at Work • Fatigue management (Working hour limits)

4. FITNESS TO WORK STANDARD HSE 0096 Applicable to List of Requirements Implementation by 1. Medical Questionnaire SEPCo Contractor In place 2005 2. Substance Abuse Test In place In place SEPCo Contractor 3. Required Physical Exam SEPCo Contractor In place 2005 4. Fitness Strength Test SEPCo Contractor In place 2005 5. Jobs w/Enhanced Fitness Requirement SEPCo Contractor end 2003 6. Recognizing & Addressing FtW issues at Work SEPCo Contractor end 2003 end 2003 7. Fatigue Management SEPCo Contractor In place end 2003 8. Return to Work SEPCo Contractor

5. Medical Questionnaire (pre-employment) Human Resource Department to obtain completed medical questionnaire from all prospective employees and get it evaluated and approved by Shell Health Services prior to employment. Applicable to SEPCO Employees FITNESS TO WORK STANDARD - REQUIREMENT 1

6. Substance Abuse Testing (pre-employment and ongoing) Human Resourcesto arrange Substance Abuse Screening Test and get the result evaluated and approved by Shell Health Services: As a routine part of the hiring process. Randomly for existing employees working in positions designated as safety and/or environmentally sensitive, as defined in Shell’s Substance Abuse Policy, Guidelines and Procedures. For employees who are also subject to random testing under Department of Transportation (DOT) and Coast Guard (CG) regulations. Contractorsworking on SEPCo’s behalf have an appropriate Drug and Alcohol policy in place. Applicable to SEPCO & Contractors FITNESS TO WORK STANDARD - REQUIREMENT 2

7. 3. Required Physical Examinations (pre-employment) Human Resources to arrange Physical Examination as part of the pre-assignment or hiring process for all employees and prospective employees slated to work Offshore. Results are evaluated and approved by Shell Health Services. Applicable to SEPCO Employees FITNESS TO WORK STANDARD - REQUIREMENT 3

8. 4.Fitness (Strength) Test (pre-employment) Human Resourcetoarrange a specific fitness or strength test for all prospective employees for Operations Crafts worker jobs. The results of this test to be evaluated and approved by HR under Shell Employment Services guidelines." Applicable to SEPCO Employees FITNESS TO WORK STANDARD - REQUIREMENT 4

9. Jobs with Enhanced Fitness Requirements (Applicable to SEPCO & Contractors) a) Supervisors are required to assure that employees in jobs with regulatory-driven fitness requirements adhere to testing as required (Crane Operator, TLP employee, Pipeline worker) SEPCo Supervisor are responsible for SEPCo Personnel Contract Foreman are responsible for Cont. Personnel FITNESS TO WORK STANDARD - REQUIREMENT 5

10. Supervisorsshould identify situations & tasks that may place unique demands on employees and may raise a fitness to work concern that needs resolving – a proactive approach Examples: Credible scenarios where poor fitness could result in a permanent total disability or fatality or major asset or environment damage: Emergency Response (fire/rescue crew) Use of respiratory equipment in immediately dangerous to life and health (IDLH) atmospheres FITNESS TO WORK STANDARD - REQUIREMENT 5 (Contd)

11. Recognizing & Addressing Fitness to Work Situations(Applicable to SEPCO & Contractors) Supervisors shall address Fitness to Work issues and situations by discussing them with the Health Services, HR & SEPCo HSE (Occupational Health) to ensure that the FtW issue is task related (ADA Compliance). The issue is then discussed with the involved employee and then with the respective Management (Contractor/SEPCo). FITNESS TO WORK STANDARD - REQUIREMENT 6

12. When discussing the issue the following aspects of ‘American with Disabilities Act’ (ADA) should be taken into consideration: ADA prevents us from requiring medical exams and from asking disability-related questions of the general employee population Medical examinations and disability-related questions may be asked on a case-by-case basis in “for cause” situations where the employee’s supervisor has reliable and objective evidence indicating there may be a fitness-related problem with an employee that poses a risk to the employee, co- workers or assets. FITNESS TO WORK STANDARD - REQUIREMENT 6 (Contd)

13. ADA allows us to ask non-disability-related questions e.g.: Can you perform these job functions? How are you feeling? Have you recently consumed alcohol? etc. It also allows us to ask employee to perform tests that are not considered to be medical evaluations, such as a test for drug use or tests of physical agility. FITNESS TO WORK STANDARD - REQUIREMENT 6 (Contd)

14. c)Supervisor shall be aware of situations that indicate that an employee is not Fit for Work. This include: Failure to meet/perform the essential functions of the job or the requirements set forth in this Standard. Physical inability to obtain, or failure to maintain, Helicopter Underwater Egress Training (HUET) certification Physical inability to evacuate per a location’s emergency evacuation procedure, and/or inability to fit or mobilize into an offshore platform’s CPLB or other emergency evacuation equipment. Failure of Respirator Fit Testing for employees whose use of respirators is a required aspect of their job (work in H2S environments, sand blasting, etc.) Inability to perform duties as Fire crew, Rescue team member or other duties placing unique physical demands on the employee. FITNESS TO WORK STANDARD - REQUIREMENT 6 (Contd)

15. ADDRESSING FITNESS TO WORK ISSUE AT SEPCo WORK LOCATION Issue with Potential Threate.g. Worker “X” is significantly overweight and may have difficulty to evacuate the location during an emergency Worker continues to work and evaluation of fitness status is scheduled Contractor Employee** Company Employee Identify Fitness to Work Issue at Work Location“FOR CAUSE SITUATIONS” * Supervisor (SEPCO/Contractor) Consult with Health Services, HR, HSE(OH) to ensure that fitness to work issue is task related and within the ADA’s legal boundaries Discusses with the concerned individual privately and ask the individual to fill the Self Certification of Fitness Form Issue with Imminent Threate.g. evidence that Worker “X” while climbing stairs as part of his/her task felt breathless and dizzy Arrangement forurgentevaluation of fitness status made Communicates Fitness to Work issue to the Contactor Management Note: Cont. Supervisor also informs SEPCo Management Refers Individual to SEPCo Health Services and HR is informed Note: SEPCo Supervisor also informs their Management Health Services evaluates the fitness status (fully fit/ fit with some job modifications/ unfit for current job etc.) and advise Location management / HR Contractor arranges the fitness status (fully fit/ fit with some job modifications/ unfit for current job etc.) evaluation and informs the Location Management of the outcome * FOR CAUSE SITUATION - reliable and objective evidence indicating a fitness-related problem with an employee **Contractor Employee – Those who crew change on a regular schedule (e.g. Core contractor)

16. REQUIREMENT 7 - FATIGUE MANAGEMENT • All individuals shall meet the following requirements for managing the risks associated with Fatigue: • a) Work shall be planned such that no one is scheduled to work for more than 14 continuous hours, including breaks. When unforeseen circumstances require an individual to work beyond this limit the following requirements must be met : Continue

17. Field based individuals with a role that involves task(s) that if performed incorrectly could directly contribute to an incident with a Level 4 or 5 consequences on the Risk Assessment Matrix. Field based individuals assigned to Incident Command System roles that involve tactical decision-making. REQUIREMENT 7 - FATIGUE MANAGEMENT (Contd) 7a Contd. • Supervisors of these individuals may allow a 3-hour extension, after ensuring controls are in place to recognize and manage fatigue • Individuals must immediately notify their supervisor if they anticipate their work will exceed the 3-hour extension. • Extensions beyond 14 hours are limited to 2 consecutive days. • Operations manager/Drilling superintendent approval is required if the “3-hour extension” or “2 consecutive days” limits are exceeded

18. FATIGUE MANAGEMENT REQUIREMENT 7 (Contd) Examples of Tasks with regards to 7a • Crane Operations • Crane Maintenance • Rigging Operations • Control Room Operations • Ballast Control Operations • Confined Space (Competent Person) • Facility Emergency Response • Maintaining Mechanical Emergency Response Equipment • Medic • Maintaining Electrical Hazard Area Equipment • Well Control • Isolating Hydrocarbon Systems (LO/TO) • Marine/Barge Operation • Testing/Setting of PSI and Shut Down Devices/Alarms • Scaffold/Fall Protection Competent Person • Diving • Flange / Tubing Assembly • HLO

19. Individuals, field and office based, not meeting one of the earlier descriptions. REQUIREMENT 7 - FATIGUE MANAGEMENT (Contd) 7a Contd. • are personally responsible for managing the risks associated with prolonged working hours and shall discuss any concerns with their supervisor.

20. REQUIREMENT 7 - FATIGUE MANAGEMENT (Contd) b) The existing schedule of field based individuals (e.g., 7/7, 14/14, 14/7) shall be followed. Extensions shall be minimized and must meet the following requirements: • the individual’s supervisor must ensure controls are in place to recognize and manage fatigue and • the individual may not work more than 28 consecutive days unless approved by the operations manager/drilling superintendent. c) All individuals have a personal responsibility for their health and safety and the safety of others. Therefore, they must report to work rested to prevent fatigue during their planned work schedule for that day

21. Implementation of this requirement is done in a phased manner: First phase to begin on 3- 4 locations by end 2003 Lessons learned will be incorporated during implementation at remaining locations with completion by 06/2004 FATIGUE MANAGEMENT REQUIREMENT 7 (Contd)

22. 8. Return to Work SEPCO Managed Locations: Supervisors to ensure that employees (SEPCo, Contractor) returning from a prolonged injury or illness are fit to return to their normal work duties without posing any undue risks to themselves, their co-workers or to the environment. Employees are required to notify their supervisor of disability-related absences. Locations under Contractor management are expected to have a similar return to work process. FATIGUE MANAGEMENT REQUIREMENT 8

23. Medical Condition & Medication Procedure Employees advised to follow HSE0071 Voluntary Physical Examinations Employees encouraged to utilize Employee Wellness Employees encouraged to utilize available programs FITNESS TO WORK STANDARD - RECOMMENDATIONS

24. FITNESS TO WORK STANDARD HSE 0096 - FAQs Q1. What do you mean by “a proactive approach” to identify situations & tasks that may raise a fitness to work concern that needs resolving? Ansr: Look at work tasks where the fitness of employee is critical to the safety of himself, others, equipment, or environment. (e.g. could this situation or task require a certain level of fitness to accomplish in a sudden emergency – e.g. physically demanding, exposure to toxic substances, etc. Q2. What do you mean by “ensure that the FtW issue is task related (for ADA Compliance) ? Ansr: The “Americans with Disabilities Act” prohibits asking personal disability questions unless there is a cause. Questions should focus on employees ability or physical agility to accomplish required work related tasks. Supervisors may ask employee to complete a Self-Certification of Fitness Form to facilitate specific discussion of the physical activities required to safely perform task. Supervisors shall discuss work situations with Shell Health Svcs., HR & SEPCO HSE (OH) to ensure work issue is task related.

25. FITNESS TO WORK STANDARD HSE 0096 - FAQs Q3. What do you mean by objective evidence to have a “for cause” situation or concern about employee Ftw? Ansr: You have visually observed employee having difficulty performing his/her expected tasks, a co-worker has reported a work place situation that raises a health/fitness concern, the employee reports a fitness concern about performing a specific task. Q4. What happens when a person is designated as “Not Fit For Duty”? Ansr: Shell Medical will assess the fitness of an employee against the requirements of his/her job and the work environment (e.g. ability to evacuate in an emergency situation) to decide whether he/she is fit. In case of ‘unfit status’, the Shell Medical and Human Resources may offer an intervention plan to achieve a “Fit For Work” status. Individual that are unable to achieve “Fit For Work” status may be reassigned to a different job.

26. FITNESS TO WORK STANDARD HSE 0096 - FAQs Q5. As a Work location Supervisor, what happens after I have discussed the ‘Fitness to Work’ concern with the Shell Medical, HSE (OH) and the involved employee? Ansr: If the concern is an ‘immediate threat to life or asset’ (e.g. while climbing the stairs a worker felt dizzy and breathless), the Shell Medical will advise to refer the person for immediate fitness evaluation. In case of a potential threat, the Shell Medical will schedule an appointment for the employee and would inform him/her of the details. Q6. When employees anticipate exceeding 17 hours of work in a work shift they should notify their supervisor. What should supervisor do? Ansr: Plan a work stoppage point to avoid exceeding 17 hours. Plan extra controls for fatigue management on JSA and review with work team prior to exceeding 17 hour work shift.

27. FITNESS TO WORK STANDARD HSE 0096 - FAQs Q7. What are examples of possible controls that could be included in a JSA to address fatigue hazard for some one who has an approved variance to work greater than 17 hours in a work shift? Ansr:Use buddy system or assign extra observer/helper, routine hourly radio check-ins to control room, identify specific tasks that need to wait till next shift, etc. Q8. What are some examples of taking personal responsibility to plan travel to prevent being overly fatigued when beginning/reporting to work? Ansr: Allowing more time to travel to allow frequent rest stops, arriving earlier at destination to allow rest before departure or work, car pooling when possible to share driving duties, etc.

28. FITNESS TO WORK STANDARD HSE 0096 - FAQs Q9. What is individual responsibility to address work related fatigue? Ansr: Each individual has the authority to stop any work/job which he/she feels is unsafe. This includes excessive fatigue of him/herself or co-workers. Knowing when to say “you need to stop and get some rest or sleep”. Q10. What if an employee arrives at work or is about to depart from work and appears to be excessively fatigued to point of concern for his/her safety? Ansr: Field supervisors have the latitude to allow an employee some rest time before starting work if cause was unavoidable. They also have the latitude to order person or work crew to get some rest/sleep without pay if the reason for fatigue was from irresponsible actions or behavior.

29. FITNESS TO WORK STANDARD HSE 0096 - FAQs Q11. “If there is a TRIP, a facility shutdown at the end of a an approved 17 hour shift do I have to call the OM for approval prior to startup? I have everyone including myself working on the heat medium system for 17 hours. At 11pm I shut down work and we all go to bed. At 11:30pm Platform shuts in and it requires several of us to help bring platform back on. It can take as little as 15 minutes to bring a `warm platform’ back to life. The longer we wait the harder it becomes. If I read the standard right, before anyone works I must make sure we have a Safe Work permit, JSA with fatigue management controls and call the Operations Manager for permission."? A: In this situation, the Supervisor doesn’t have to wait till the last moment for Work permit/JSA and OM ‘s permission. These all can be done when he/she is initially approving the 17 hours shift. Knowing well that the crew will be working for 17 hours, one can anticipate events such as emergency shutdown that may occur after the crew has already worked for 17 hours. So the controls to manage fatigue can be arranged in advance. Similarly, the OM can be cautioned of the possible scenario and an advance approval can be sought just in case it is needed.