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HSE Policies

Levels of Responsibility

There are five (5) recognized levels of responsibility and accountability within any organization:

a) Management;
b) Supervisors;
c) Employees and workers;
d) Contractors and subcontractors; and
e) VIsitors.

As well, there are moral and ethical responsibilities at all five levels, which may in fact transcend the legal. These are individual concerns and are not addressed in this manual. However, the five (5) recognized levels of responsibility within an organization are defined as follows:

a) Management
The management of Fire Creek is responsible for:

• Making funds and processes available to effectively accommodate the Company's Health and Safety needs;
• Ensuring performance and behavior meet the requirements of the Company's Health and Safety program;
• Encouraging employee and contractor involvement in the safety process;
• Ensure all operations including those of contractors and subcontractors meet government safety requirements;
• Ensure all incidents are reported and where necessary, investigated and corrective action is taken to prevent recurrence;
• Ensuring workers are adequately qualified to perform their work;
• Ensuring training needs are identified and met;
• Taking the necessary action to correct any unsafe working conditions brought to their attention by workers;
• Understanding, implementing, and enforcing applicable Act, Regulations, Codes, Codes of Practice, Standard Operating Procedures, and associated Safe Work Programs and Guidelines;
• Providing appropriate supervision at work sites;
• Providing appropriate and well-maintained safety equipment for each task;
• Evaluation and monitoring the Company's Substance Abuse, and Violence/Harassment in the Workplace Program on an ongoing basis; and
• Complete a risk assessment at least every year for all safety sensitive job positions

b) Supervisors
Supervisors for Fire Creek are responsible for:

• Understanding what is expected of them;
• Accountability for all activities within their area of responsibility and job scope;
• Identifying and meeting safety and operational training needs;
• Identifying and correcting hazards and unsafe work conditions;
• Correcting unsafe acts in a proactive, positive manner;
• Understanding, implementing, and enforcing applicable Act, Regulations, Codes, Codes of Practice, Standard Operating Procedures, and associated Safe Work Programs and Guidelines;
• Ensuring appropriate and well-maintained equipment is available and utilized to perform the work activity;
• Meeting regulatory compliance and Company conformance requirements;
• Ensuring workers are informed about job hazards and are prepared to deal with any site specific hazards on the work site;
• Ensuring personal protective equipment (PPE) is readily available at the work site, correctly used, stored, maintained, and replaced when necessary; and
• Reporting all incidents. This may include conducting investigations into the facts leading up to and including the incident, and determining the root cause to prevent a recurrence.

NOTE: FIre Creek provides a wide and varied range of support services to exploration and production clients within the oil and gas industry. In an effort to ensure that these services receive the appropriate level and quality of supervision, Fire Creek has consolidated the services into specific disciplines or trades.

All of the services provided by Fire Creek fall under the disciplines or trades identified as Drilling, Completions, Pipelines and Construction. In an effort to provide a more detailed account of supervisor's responsibilities than provided above, Fire Creek has developed a quick reference list identifying specific elements within this manual that should be consulted for further clarification of those responsibilities specific to the identified discipline or trade.

The quick reference list should be reviewed by respective supervisors on a regular basic, to ensure that they are fully aware of their responsibilities and accountabilities to their employer, and most importantly, those that they supervise.

c) Employees and Workers
Workers employed by FIre Creek are responsible for:

• Adhering to regulations, guidelines, and safety standards as required by government regulatory agencies, and those communicated by management and supervisors;
• Following all appropriate Codes of Practice, Standard Operating Procedures, and associated Safe Work Programs and Guidelines contained in the Fire Creek Health and Safety Manual;
• Reporting and hazardous or unsafe working conditions to their immediate supervisor and, if possible, correcting the unsafe condition;
• Observing activities of fellow employees and contractors to ensure their safety and the safety of those around them, and correcting unsafe acts in a proactive, positive manner to prevent an incident from occurring;
• Refusing to perform work that:
• He or she believes an imminent danger exists to the health or safety of themselves, or their fellow workers, and
• They are not competent to perform.
• Reporting all incidents, injuries, and illnesses to their supervisor;
• Participating in, and using, all training offered by the Company; and
• Using the required personal protective equipment (PPE).

d) Contractors and subcontractors
Contractors and subcontractors responsibilities include:

• Insisting on safe performance throughout their operations by ensuring subcontractors and employees are competent to do their work properly, and are aware of their responsibilities and accountabilities;
• Ensuring and effective health and safety program is in place;
• Ensuring their safety programs and operations personnel comply with contractual and regulatory requirements;
• Providing the time and resources required to enable subcontractors and employees to conduct their activities safely;
• Identifying and correcting hazards, unsafe work conditions, and unsafe acts;
• Ensuring appropriate and well-maintained equipment is available and utilized to perform the work activity;
• Ensuring all incidents are reported and investigated and corrective action is taken to prevent a recurrence;
• Ensuring workers are informed about job hazards and are prepared to deal with any site specific hazards on the work site; and
• Ensuring personal protective equipment (PPE) is readily available at the work site, correctly used, stored, maintained, and replaced when necessary.

e) Visitors
Fire Creek, in view of its liability exposure, observes a policy of "Authorized Personnel Only" at all worksites and for visitors to its offices. It is entirely normal for local residents, other Company employees, contractors, or even stranded motorists to show up at worksites or client facilities from time to time. These individuals should be treated with normal courtesies, and shall be afforded the appropriate level of assistance.

It is the responsibility of the Company employee/worker to ensure all such visitors are not exposed to any unnecessary risk and are safeguarded from danger. Unless the visitor has specific business, entry into a client facility should be restricted as far as reasonably possible. Such care will not only prevent injury to a visitor, but it will also convey the message that Fire Creek has a strong commitment to health, safety and protection of the environment.

Therefore, when visitors attend work sites, they are required to meet the following safety responsibilities:

• Report to the worksite office so their presence is noted and recorded;
• Receive a site specific safety orientation;
• Follow the instructions of the site supervisor or personal escort;
• Wear personal protective equipment (PPE) as and when required;
• Remain in the presence of the site supervisor or personal escort; and
• Check out at the worksite office prior to departing the work site.