responsible care - Chemistry Industry Association of Canada

RESPONSIBLE CARE®
Verification Report
Nexen Inc.
Canadian Oil and Gas Division
October 4 - 8, 2010
Disclaimer
This report has been produced by a team, convened by the Chemistry Industry Association of
Canada (CIAC), to provide advice to the member-company and assist it in meeting its
Responsible Care® commitments. The material in this report reflects the team's best judgment in
light of the information available to it at the time of preparation. It is the responsibility of the
CIAC member-company that is the subject of this report to interpret and act on the report’s
findings and recommendations as it sees fit. Any use which a third party makes of this document,
or any reliance on the document or decisions made based upon it, are the responsibility of such
third parties. Although CIAC members are expected to share the results of this guidance
document with interested parties, the Association, its member-companies, their employees,
consultants and other participants involved in preparing the document accept no responsibility
whatsoever for damages, if any, suffered by a third party as a result of decisions made or actions
based on this report.
Responsible Care® is a registered trademark of the Chemistry Industry Association of
Canada.
EXECUTIVE SUMMARY
This Responsible Care-in-Place verification was conducted on October 4-8, 2010. The verification was
based on visits to the organization’s head office in Calgary as well as facilities at Fort Assiniboine and
Medicine Hat, Alberta and Fort Nelson, British Columbia. Information was compiled through interviews,
documentation reviews and inspections at these locations. The in-place verification was conducted by a
three person team appointed by the Chemistry Industry Association of Canada (CIAC), supplemented by
four local community members, representing each facility.
The team used the top-down questioning approach described in the “Responsible Care-in-Place Protocol”.
The questions focused on the management processes present rather than detail, and tested for the
existence of effective management systems to ensure understanding of the Responsible Care codes and
ethic. The verification also focused on continual improvement performance objectives and that adequate
levels of resources were available for the Responsible Care commitment.
Based upon this verification the team considers that Nexen Inc. Canadian Oil and Gas Division has
achieved the required standard for Responsible Care In-Place certification, and that the CIAC officially
recognize this verification with an award at the next suitable occasion.
As well as in the body of the report, a listing of Improvement Opportunities and Best Practices is included
in Section 3.
Dave Mack
Verification Team Leader
December 17, 2010
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1.
INTRODUCTION
In this report, comments and recommendations of the verification team are shown in italics.
Any comments on improvements the team considers as value-adding to the organization’s
continual improvement of their management systems are identified as “Improvement
Opportunities”.
Positive comments on performance, which may be considered as being indicative of leading
industry practice or which goes beyond the requirements of Responsible Care-in-Place
implementation, are underlined. These are identified as “Best Practices”
Objective
Each partner company of the CIAC must commit to the guiding principles and codes of
practice of Responsible Care as a condition of partnership in the association.
The Responsible Care-in-Place protocol was developed by the association's members and
others to confirm, for the CIAC and the public, the existence of a satisfactory system or
process which ensures that the guiding principles and codes of practice of Responsible Care
are in place and practised within the organization.
Each partner company must therefore undergo Responsible Care-in-Place verification before
its commitment can be formally recognized as complete.
It should be noted here that "completion" in this sense does not indicate that nothing further
needs to be done, but rather that a key milestone has been reached in a process of continual
improvement.
1.1
Verification Criteria
The six codes of practice of Responsible Care contain altogether 151 individual requirements
which partner companies must meet for Responsible Care to be in place. More information
on what is expected is given in the documents Guidelines for Completion of Responsible Care
Implementation issued on February 20, 1992 and Community Awareness Code Guidelines for
Completion issued on February 25, 1994.
The verification principles are set out in the Responsible Care-in-Place Protocol approved by
the association's board of directors on February 9, 1994 and updated in March 2005. For the
purposes of examination, a portion of the 151 code requirements are sampled in depth. These
items are grouped into seventeen management systems, each of which is examined using a
series of questions. Some of the questions are sent to the company in advance of the
verification visit, so that supporting documentation, etc. can be available for prompt
examination if desired. Additional questions are asked at the discretion of the team during the
visit.
Questions are generally of the following nature:
 does the organization have an effective management system in place to ensure
understanding of Responsible Care?
 what is the process to determine and communicate the acceptable level of
performance?
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


what is the process for assessing the performance of the system and effecting followup to meet or exceed the acceptable level of performance?
what is the process for ensuring up-to-date documentation?
do sufficient resources appear to be, or are thought by employees to be, in place?
The findings for each of the seventeen management systems are described in section 2 of this
report, and include comments derived from the supplementary questions where appropriate.
1.2
The Verification Team
The verification team for Nexen Inc. Canadian Oil and Gas Division consisted of the
following persons:
Name
Dave Mack
Alec Robertson
Keith Purves
James Childs
Mary Anne Lehman
Brenda Doupe
Barry Rudd
1.3
Affiliation
Consultant
Consultant
External Member
Community Representative
Community Representative
Community Representative
Community Representative
Representing
Industry (Team Leader)
Industry
Public & Community at Large
Fort Nelson
Fort Assiniboine
Wetaskiwin/Camrose
Medicine Hat
Process
The verification was conducted by a pre-meeting at the Calgary head office on September 09,
2010, followed by verification team visits on October 4-8, 2010.
1.4
Key organization contacts during the process were as follows:
Name
Aaron Chaffey
Al Seredynski
Location
Fort Assiniboine
Calgary
Bill Arling
Bill Gourley
Blaine Sebry
Calgary
Calgary
Calgary
Bob Cargill
Fort Nelson/Fort Assiniboine
Brent Jessiman
Brian McAusland
Brock Johnson
Bruce Bunting
Calgary
Calgary
Fort Nelson
Fort Nelson/Fort Assiniboine
Cam Foss
Carolyn Kenney
Catherine Hughes
Claire Serdula
Dale Dechief
Medicine Hat
Calgary
Calgary
Calgary
Fort Nelson/Fort Assiniboine
Title
Analyst HSE&SR
COG Production Engineer
(well optimization / workovers)
Manager Environment
Team Lead Social Responsibility
General Manger – Production Operations & RC
Executive Contact
PSM/MOC & Small Project Coordinator (Shale
Gas & CBM Bus. Units)
Regional Manager HSE&SR & RC
Manager Responsible Care
Operations Manager (In-boarding)
Safety / Environmental Coordinator (Shale Gas
& CBM Bus. Units)
Operations Manager
Environmental Engineer
Sr. VP Ops Tech / HR
Environmental Engineer
Operations Manager (Out-boarding)
Nexen Inc. Canadian Oil & Gas Division In-Place Verification
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Name
Darcie Park
Darlene Hanley
Dave Girard
David Guss
Location
Calgary
Calgary
Calgary
Calgary
Title
Manager Sustainability Reporting
Senior Executive Assistant (ISN support)
VP COG HR
Manager Process Safety & Corporate Audit
David White
Eamonn O’Brien
Elizabeth Oldfield
Eric Miller
Garry Mann
Gary Nieuwenburg
Greg Denham
James Duxbury
Jim Shaw
Katrisha Gibson
Kelly Kowalchuk
Kent Wirth
Kevin Bremner
Kirk Albertson
Leanne Sandau
Lisa Graul
Lyle Stang
Lynn McQueen
Lynn McQueen
Marci Marshall
Marie Sopko
Calgary
Calgary
Calgary
Calgary
Calgary
Calgary
Calgary
Calgary
Calgary
Calgary
Calgary
Medicine Hat
Calgary
Fort Assiniboine
Fort Nelson
Calgary
Calgary
Calgary
Fort Assiniboine
Medicine Hat
Calgary
Mark Futrell
Martin Mueller
Marvin Romanow
Nathan Meier
Nyssa Carruthers
Perry Kuzma
Pierre Alvarez
Rick Cloutier
Sandi Mourisseau
Sean Britton
Shad Watts
Shawna McEwen
Medicine Hat
Calgary
Calgary
Medicine Hat
Calgary
Calgary
Calgary
Calgary
Calgary
Fort Assiniboine
Calgary
Calgary
Sheryl Buxton
Shyla O’Connor
Tanis Palmer
Terry Hellman
Trish Cubitt
Warren Korol
Fort Assiniboine
Calgary
Fort Assiniboine
Fort Nelson
Calgary
Calgary
Manager Well Construction
Senior Safety Manager
Analyst Social Responsibility
Sr. VP General Council / Security
General Manager Health, Safety & Environment
Executive VP – Canada
Sr. Abandonment and Reclamation Coord.
Responsible Care Analyst
Mgr. Community Affairs
GM Natural Gas & Power Marketing
VP HSE&SR
Foreman Production Med Hat
Manager Tech Services Supply Management
Foreman Production CBM
Administrative Assistant
Manager Environment
Manger Safety
Analyst Social Responsibility
Analyst Social Responsibility CBM W5
Administration Co-ordinator
Manager Occupational, Health & Industrial
Hygiene
PSM/MOC & Small Project Coordinator
VP & Chief Compliance Counsel
President & CEO
Safety / Environmental Coordinator
Emergency Management Technician
Sr. Staff Advisor Security
VP Corporate Relations
Manager Operations Procurement
Corporate Relations
Operations Manager (In-boarding)
Director CCRA
Analyst – HSE&SR Compliance Systems &
COG Integrity Leader
Administration Co-ordinator CBM W5
Admin Coordinator– Marketing HSE
Administration Co-ordinator CBM W4
Foreman Shale Gas
Admin Assistant COG Production / Operations
Manager Facilities Engineering Shale Gas
(expertise - Cornerstone MS)
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1.5
Nexen Inc. Canadian Oil and Gas Division Background Information
Nexen is a Canadian based energy company with operations around the world, including the North Sea,
the Gulf of Mexico, offshore West Africa, Canada, Yemen, and Colombia. With more than 4,000
employees worldwide, the primary offices are located in Calgary, Alberta, Dallas Texas, Uxbridge and
Aberdeen in the United Kingdom.
The company was formed in Canada in 1971as Canadian Occidental Petroleum Ltd., when Occidental
Petroleum Corporation combined its Canadian crude oil, natural gas, sulphur and chemical operations into
one company.
Nexen operates four distinct divisions (i.e., Synthetic Oil, Canadian Oil & Gas, U.S. Oil & Gas and
International Oil & Gas).
The Canadian Oil & Gas division, the subject of this verification, includes conventional natural gas
production operations in Alberta, Saskatchewan and northeastern British Columbia. There are also coal
bed methane production operations in north central Alberta and shale gas production operations in
northeastern British Columbia.
2.
FINDINGS
The headings which appear below are brief summaries of each topic item rather than the detailed
questions actually used during the verification. For more information on the actual questions and the
verification protocol please contact the CIAC’s Responsible Care office at (613) 237 6215, fax (613) 237
4061
2.1
Set Organization and Responsibilities
2.1.1
Organization and personal involvement - CIAC Executive Contact
Background:
The implementation of Responsible Care has been established as a key objective within the Canadian Oil
& Gas Division of Nexen and is part of the organization’s identity. This is clearly aligned with the
organization’s health, safety, environment and social responsibility key objectives. The Responsible Care
ethic is well understood and guides the division’s day to day functional and business decisions including
relationships with the community.
At the executive level of the organization a clear commitment was evident to the promotion of the
Responsible Care ethic throughout the organization.
The CIAC Executive Contact, who is the General Manager of Production Operations, has related personal
goals in this regard. The Executive Contact plays an active role in monitoring Responsible Care
implementation progress through regular stewardship meetings and day to day involvement.
A functional manager who reports to the Executive Contact has the overall accountability for Responsible
Care implementation. This manager is supported by an individual assigned to oversee the entire
implementation activity, others who focus on specific codes of practice, and an administrator to manage
documentation.
The Executive Contact attends the CIAC Western Leadership Committee meetings.
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Improvement Opportunity:
1) Establish a process to ensure continued promotion and support for Responsible Care
throughout the organization and to sustain the current momentum into the future.
2.1.2
Overall Responsible Care Management System
Background:
A comprehensive health, safety, environment and social responsibility management system has been
established, based upon a plan-do-check-act continual performance improvement cycle.
Planning elements include:
o Legal and other requirements;
o Hazard and Risk Identification; and
o Objectives and targets.
Doing elements include:
o Preventive and protective measures;
o Emergency prevention, preparedness and response;
o Competence and training;
o Communication and awareness;
o Procurement and contracting; and
o Management of Change.
Checking elements include:
o Monitoring and measurement;
o Incident investigation and analysis;
o Internal audits; and
o Preventive and corrective action.
Acting elements include:
o Management review; and
o Continual improvement.
The overall management system has been supplemented by a series of specific operational standards
which address environment, occupational safety, transportation/product stewardship, process safety, and
community involvement, all of which have been clearly cross referenced to the Responsible Care Codes
of Practice.
Although all of these standards have been given a high priority for implementation in all areas, specific
emphasis has been placed on process safety. Given its scope and complexity, a risk based approach has
been used to identify implementation priorities. There is a plan in place to have all aspects of process
safety management implemented in all areas by 2013.
Improvement Opportunities:
i)
Establish and implement a plan and schedule to ensure for timely review and
implementation of new standards in all areas, and their incorporation into local
procedures.
ii)
Expedite implementation of the process safety management program according
to, or earlier than, the current plan to have this completed by 2013.
Best Practices:
i)
The entire Responsible Care management system structure with supporting
standards and procedures, including its roll out and implementation throughout
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ii)
iii)
iv)
2.1.3
the organization, which incorporates a process for end user input to maximize
understanding and acceptance of the standards.
The clear emphasis in the Responsible Care management system, and the
explanation therein, on the plan-do-check-act continual performance
improvement cycle.
The process safety management system currently being implemented.
The “communities of practice” forums where best practices can be shared across
the organization.
Staff responsibilities and performance
Background:
Roles & responsibilities are well defined from the senior management through to the grass roots level.
Through a computerized process referred to as “Performance Excellence and Action through Knowledge”
business goals and objectives are arranged and tracked. These include Responsible Care related
objectives. Each level of management sets their goals and objectives as records in the process. The direct
reporting employees of these managers then set their goals and objectives therein to align with
management. This keeps groups working to the same end.
There is a documented policy for performance and career communication, and there is an incentive bonus
program in place which includes an element of safety and environmental performance. There is also an
employee recognition program in place to recognize those who make significant contributions to the
success of the organization.
Improvement Opportunities:
i)
Follow-up to ensure that all contract operators are receiving performance
evaluations.
ii)
Consider including contract operators in the safety and environmental
performance aspect of the incentive bonus program.
2.1.4
Organization and personal involvement - Site Managers
Background:
The managers of all field production operations report directly to the General Manager of Canadian Oil
and Gas Production Operations, who is also the CIAC Executive Contact.
As well as being responsible for natural gas production, related cost control, and personnel in their
individual business units, those field production operations managers have direct accountability for the
implementation of Responsible Care within their sphere of control. They are supported in this by
divisional and field co-ordinators who focus primarily on all aspects of Responsible Care Code of
Practice compliance.
At the field level of the organizational commitment to the Responsible Care ethic was evident at all
levels.
Improvement Opportunity:
i)
Review the organization’s policy for diversity in the workplace and promote
hiring practices in all areas that are representative of local demographics. It was
observed that field personnel were predominantly male caucasian.
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2.1.5
Employee understanding of Responsible Care
Background:
Through interviews and informal discussions with employees across the organization a good
understanding of the Responsible Care was evident.
Most field employees were able to articulate how the ethic in some way related to their day to day work
activity.
Best Practice:
i)
2.2
The emphasis placed on promoting the understanding of the Responsible Care
ethic and management systems as well as the acceptance of personal
responsibilities and accountabilities for implementation throughout the
organization.
Meet and Exceed Laws and Regulations
Background:
Oil and gas operations are extensively regulated through federal and provincial government agencies.
A cross reference document has been created to ensure that all applicable regulatory requirements are
addressed within the health, safety, environment and social responsibility standards noted in section 2.12
of this report.
A regulatory management process has been established to help staff manage regulations.
Regulatory subject matter experts at both the divisional and field levels of the organization play a key role
in ensuring that changes to the regulations are reflected within the above standards.
New training requirements, inspection, or other criteria resulting from changes to regulations are
identified and implemented.
2 .3
Inform Public, Understand and Respond to Their Concerns
2.3.1
Outstanding charges etc.
Background:
There were no regulatory actions, charges, orders, etc, applicable to the Canadian Oil and Gas Division of
Nexen at the time of the site visits.
2.3.2
Identification of community interests and representatives
Background:
For its coalbed methane operations in central Alberta, two community sectors have been identified. One
of these areas includes the cities of Wetaskawin and Camrose and the village of Donalda. In this area
interface occurs with a group referred as the Wetaskiwin Synergy Initiative which was established to
develop a working relationship between the community and energy companies. The other community
area includes the hamlet of Fort Assiniboine, the east side of Woodlands County and a portion of
Barrhead County. In this area interface occurs with a similar group referred to as the Fort Assiniboine and
Area Multi-stakeholder Alliance.
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For its shale gas operations, the town of Fort Nelson, British Columbia has been identified as the centre
for community outreach activity. The location of shale gas operations is in a remote bush area
approximately 100 kilometres north of the town. There are a number of other companies operating the
area and, along with Nexen, a group referred to as the Horn River Basin Producers Group has been
established to provide a co-ordinated approach to multi-stakeholder communications.
Shallow gas operations are carried out in rural areas around Medicine Hat, Alberta. Although a
formalized community group has not been established for communications, a number of key stakeholders
representing landowners and municipalities have been identified to interface with.
To assist in community outreach activity an external stakeholder grid has been established to effectively
prioritize and graphically illustrate, on one page, all stakeholders and groups within each operating area.
The grid identifies stakeholders by level of interest and influence in the area.
Improvement Opportunities:
i)
Expedite completion and implementation of the aboriginal relationships policy
currently being developed.
ii)
Research how the traditional way of life in the shale gas area might be impacted
especially if the organization expands operations further to the north and west
where several first nations live other than those in the current area of operations.
(Note: Useful information may be find in the document entitled “Fort Nelson
First Nations Submission on EnCana’s Cabin Gas Project Environmental
Assessment”)
Best Practices:
i)
ii)
2.3.3
The entire community outreach program which has clearly established the
organization as a model corporate citizen in the oil and gas industry.
The external stakeholder grid used to determine the extent of site specific
community outreach initiatives.
Process for risk communication and community dialogue
Background:
Initial communication of operational risks (e.g., worst case scenarios) for all new projects occurs through
the regulatory approval process where any member of the public who may be adversely impacted by the
project is required to be informed.
On-going community dialogue occurs through the involvement with identified stakeholders as described
above in section 2.3.2 of this report, and through annual neighbourhood visits from plant personnel,
distribution of informational flyers, etc.
This is supplemented by the distribution of newsletters and brochures.
Improvement Opportunity:
i)
Establish a process to regularly assess neighbour awareness of risks and what to
do in the event of an emergency.
Best Practice:
i)
Community involvement training provided for shallow gas area based field
operators.
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2.3.4
Response to community concerns
Background:
There is a documented public complaints standard in place which defines the minimum requirements to
effectively receive, record, and follow-up on all complaints made by stakeholders.
The organization is open to receiving complaints and encourages stakeholders to use various channels to
address their issues (e.g., communication to field staff in the area, calls of visits to regional offices, or use
of Nexen’s toll-free Community Hotline).
Improvement Opportunities:
i)
Bring additional focus to aligning community expectations with the
organization’s ability to deliver. There is an example in the shale gas area
regarding use of local services and job creation, and in coal bed methane area
regarding elimination of adverse impacts to the entire ecosystem.
ii)
Establish clearer classification criteria for community complaints.
2.3.5
Community awareness along transportation routes
Background:
Impacted stakeholders along transportation routes are provided risk information as outlined within a
documented community involvement management system based upon the plan-do-check-act continual
performance improvement cycle similar to the overall Responsible Care Management System described
in section 2.1.2 of this report.
There is a standard in place to carry out product and route risk assessments through which impacted
stakeholders are identified. Impacted stakeholder information is contained within a computerized
database.
The organization actively participates in CIAC regional TransCAER committee activities including
education programs for community response organizations
2.4
Hire, Train, Assess and Communicate to Employees
2.4.1
Employee orientation, training and performance
Background:
All new employees go through a formal on-boarding process which includes a Responsible Care overview
and site specific orientation.
On-going health, safety, environment and social responsibility training requirements have been identified
for all employees as required. There is a progression system in place for field operators whereby core
mandatory training must be taken and competency must be demonstrated before individuals can progress
to a higher level of operating job function. All training is tracked for completion in a computerized
system.
Performance is addressed as described above in section 2.1.5 of this report
Best Practice:
i)
The electronic system referred to as “SkillsTrak” for training information
gathering, sorting and reporting.
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2.4.2
Communication of hazard and risk information to employees
Background:
Workplace place hazard and risk information is provided through the new employee orientation and
training program described above.
Pre-job hazard analyses are carried out as part of the day to day work permitting process.
On-going information is provided through an internal web site, direct electronic communications and
regular meetings. This includes information on new processes and procedures.
2.4.3
Health monitoring and communication
Background:
An occupational health and industrial hygiene manual has been prepared. This includes occupational
health and hygiene standards and requirements for baseline and ongoing health assessments including
disability management. Baseline workplace hazard exposure assessment has been done in all areas. This
is being followed up through an on-going monitoring program to measure and address worker exposure to
hazards found during the baseline.
Following their baseline health assessment, employees are offered ongoing medical assessments every
two years.
An internal web site has been established to provide employees and their families with a variety of
general health related information and solutions (e.g., physical activity, diet, nutrition, etc.).
Improvement Opportunity:
i)
Ensure that an appropriate level of attention is maintained on addressing low
risk as well as the necessary priority that must be given to the higher health risks,
in on-going workplace hazard exposure monitoring programs.
2.5 Collect Hazard Information and Assess and Minimize Risks
2.5.1
Potential impact of process incidents including worst case scenarios
Background:
Analysis of worst case scenarios occurs through the regulatory approval process for all new projects.
This addresses the potential impact of process incidents both on and off site. All facilities have under
gone this process.
2.5.2
Hazard and risk assessments for existing facilities
Background:
Critical task hazard assessments have been prepared for all operating areas which includes a risk ranking
of potential incidents and controls required to reduce the risk. These assessments will be repeated every
five years.
Baseline hazard and operability studies are being conducted on all major facilities over the next five
years, and there is a plan to carry our quantitative risks assessments for all areas commencing in 2011.
Hazard and operability studies are also carried out on supplier equipment (e.g., well fracing equipment).
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There is also a process in place to carry out critical procedure reviews.
Improvement Opportunities:
i)
Review the current practices for cell phone and radio use while driving and
upgrade as appropriate to reduce or eliminate associated risks.
ii)
Consider the use of global positioning equipment for employees as part of the
working alone procedure to assist in locating anyone who has not checked in
according to procedure.
iii)
Review the effectiveness of the work alone procedure in areas where cell phones
do not function.
iv)
Expedite the completion of baseline hazard and operability studies according to,
or earlier than, the current plan established for the next five years.
v)
Expedite the completion of quantitative risk assessments according to, or earlier
than, the current planned date of 2011.
Best Practice:
i)
2.5.3
The application of hazard and operability studies on supplier equipment (e.g.,
fracing equipment).
Minimization of process risk
Background:
Process hazard assessments are carried out on all new facility projects or where changes are being made
to existing facilities.
Critical operating and maintenance procedures have been developed and are reviewed and verified yearly.
All Safety Critical Equipment has been identified and preventive maintenance plans have been
established.
Compliance with safety critical inspection and preventative maintenance requirements is tracked as well
as where safety critical equipment has been rendered out of service
Best Practice:
i)
2.5.4
The emphasis being placed in the coal bed methane area to manage service rig
safety with respect to rig movement on highways and site preparation for service
work.
Minimization of risk for transportation modes and routes
Background:
There is a transportation standard in place and currently being implemented which addresses product risk
and route assessment. Identified risks are mitigated by the use of alternate routes where possible.
The results of these risk assessments are maintained in a computerized data base.
Risk mitigation measures are included in carrier term agreements to which drivers are made aware.
Improvement Opportunity:
i)
Expedite completion of transporter route risk assessments according to, or
earlier than, the current plan, and input stakeholder awareness requirements into
the annual neighbour visit information database.
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2.6
Identify, Manage and Minimize Emissions and Wastes
2.6.1
Emission and waste reduction objectives
Background:
A documented environmental management system has been established, based upon the plan-do-checkact continual performance improvement cycle similar to the overall Responsible Care management
system described in section 2.1.2 of this report.
A standard describing the process for establishing reduction targets is also in place. The process includes
tracking waste production, water consumption and air emissions, and assembling the data to develop an
air, water and waste baselines for each business unit. Baseline information is used to determine
appropriate reduction targets for each medium. The process also includes for regular review of the targets
to determine if they have been achieved or if they need to be reassessed.
A corporate footprint reduction program was initiated in 2009. By 2011 the plan is to have all related
data into an electronic data base and a reduction plan in place by 2012.
Environmental aspects and impact assessments related to emissions to the air are currently being
performed for all sites and an emissions reduction plan will be in place by 2011.
Water and waste aspects and impact assessments will be done in 2011.
Improvement Opportunities:
i)
Expedite implementation of the environmental footprint reduction program
according to, or earlier than, currently established completion dates for all
media.
ii)
Expedite installation of the vapour recovery facility as currently planned at the
shale gas area Dilly Creek site to reduce flaring.
2.6.2
Health and environmental impact of emissions and wastes
Background:
Members of the environmental function participate in various committees of the oil and gas industry
associations to which the organization belongs. They are also involved with airshed committees in the
various operating zones and industry spill cooperatives.
It is through participation in these groups, where potential impacts of industry activity on health and the
environment are monitored, that the organization maintains an awareness of current issues related to the
oil and gas industry. It also allows for access to industry best practices which can be incorporated into
field operations and contribute to minimizing the potential for adverse impacts.
2.6.3
Waste minimization for new products and processes
Background:
The environmental management system, noted above, includes an environmental planning standard that
states that all design and construction will include consideration for the minimization or elimination of
waste sources at the design and development stage of a project, wherever possible.
2.6.4
Application of hazardous waste management code to co-disposal sites
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Background:
The environmental management system noted above includes a process to review current environmental
practices, which includes waste characterization and disposal locations.
Waste waters from field sites are disposed off at approved deep well injection locations, and other wastes
are disposed of at approved facilities.
2.7
Incorporate Environment, Health and Safety into Design Stages
2.7.1
Environmental impact of new facilities
Background:
A project management framework referred to as “Cornerstone” is currently being developed to direct the
manner in which engineering projects are executed. The framework is being developed in alignment with
the principles of industry accepted good practice in project management for the size and complexity of
projects being executed.
There are 15 areas of attention that must be addressed on projects to facilitate project success. Health,
safety, environment and social responsibility is one of those areas of attention.
Various documents will be published in each of the 15 areas of attention to guide project personnel in
application of project management principles to projects. This includes a for a process hazard analysis to
be conducted for all new projects when necessary.
2.7.2
Buffer Zones
Background:
Buffer zones are determined by regulations and are addressed in applications for a licence to operate a
facility.
Emergency planning zones are also set by regulation based on product and hazard.
Improvement Opportunity:
i)
Consider establishing a specific buffer zone standard which addresses not only
regulatory requirements but also defines a process to monitor and access the
necessary information to proactively address issues related to encroachment of
commercial/residential/institutional developments on existing facility set backs.
2.8
Document of Standards and Procedures
Background:
There is a very comprehensive computerized document management system in place which contains the
overall Responsible Care management system with subsets specifically addressing environment, safety,
transportation/product stewardship, process safety, and community involvement.
Standards and procedures which support the management systems are also included, as well as records
and other related documentation.
Best Practice:
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i)
The hand held electronic activity data collection and scheduling system referred
to as “FieldTrak” which ensures that all critical operating and compliance
activities are identified and carried out according to requirements.
2.9
Provide Information to Second Parties
2.9.1
Supply and receipt of Environment, Health and Safety information to customers
Background:
The natural gas product is directly transported by pipeline to other pipeline operators where it is
comingled with the production from other companies and transported to further destinations.
Through this pipeline system product is sold to a variety of customers throughout North America for the
end use as a source of energy.
Material safety data sheets containing environment, health and safety information are made available to
customers.
2. 10
Assessing Second Parties
2.10.1 Selection of site contractors
Background:
The organization uses an industry wide system managed by a service provider to screen and pre-qualify
all contractors. To maintain their status as an approved supplier of contract services, contractors are
required to continually review their status within the system and remedy any shortfalls with respect to the
criteria set on their levels of health, safety and environment performance.
A contractor scorecard is used and post job evaluations are carried out.
Related documentation and records are maintained in a computerized document management system.
2.10.2 Contractor understanding and compliance with Environment, Health and Safety
instructions
Background:
The requirements for environment, health and safety performance is communicated to contractors through
the prequalification process, the contract, on-going communications, training, assessments, audits and
inspections, and through follow-up relating to any failure identified in the working relationship. There is
a detailed health and safety handbook in place which is also provided to all contractors.
Various checklists are used to carry out and record the above assessments, audits, inspections etc.
2.10.3 Selection and evaluation of hazardous waste contractors
Background:
Within the environment management system there is standard in place to address the selection of waste
contractors.
A defined performance evaluation system is in place, primarily utilizing an oil and gas industry process
meeting CIAC requirements, augmented by in house evaluations.
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2.10.4 Selection and assessment of suppliers
Background:
Key suppliers are managed through a supply management database with regards to prequalifying,
reviewing and continuously improving supplier performance. There is a new supplier evaluation process
in support of this activity.
There is a hazardous product supplier standard in place within the transportation/product stewardship
management system, noted in section 2.1.2 of this report, that requires that supplier self assessments be
completed, reviewed and tracked within the above data base. Full implementation of this standard is set
for 2011.
Improvement Opportunities:
i)
Expedite implementation of hazardous product supplier assessments and followup according to, or earlier than, the current planned date of 2011.
ii)
Implement the supplier assessment process with second party pipeline operators.
2.10.5 Selection and assessment of carriers
Background:
The organization uses the CIAC protocol and the association’s approved external service provider to
screen and pre-qualify all carriers, including waste carriers.
Carrier assessments are performed by employee personnel using an internally developed protocol which
includes CIAC expectations plus specific oil & gas operations requirements. External CIAC evaluations
at 5 year intervals are used to benchmark the process.
This process also applies to carriers of the organization’s waste materials.
Section 2.11 Manage Changes
Background:
There a documented management of change standard in place, and within the currently being developed
project management framework, as previously noted in section 2.7.1 of this report, there is an area of
attention that specifically addresses change management, with respect to ensuring that changes to
equipment, control systems, procedures, etc. do not downgrade their integrity. It includes aspects of
initiation of changes, logging of changes, and the workflow associated with the implementation of
changes.
Improvement Opportunity:
i)
Expedite implementation of the new electronic management of change tool
referred to as “eMOC” to replace the existing manual system.
2.12
Provide Security
Background:
Site security audits and vulnerability assessments are done for all facilities on 2 to 3 intervals, and
appropriate security measures have been put in place commensurate with the results of these audits and
assessments.
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Monthly security information and alerts where warranted are issued based on information from outside
sources.
A security standard is currently being developed to define minimum requirements for facility protection
and sensitive information.
Improvement Opportunities:
i)
Complete and implement the security standard currently under development.
ii)
Give an appropriate level of attention to training contracted truckers in aspects
of security awareness.
2.13
Manage Previous Waste Sites
Background:
A method has been developed for identifying historical waste sites within the current operating areas
which includes accessing government and internal records of reportable spill events.
Once it has been identified that a reportable spill event has occurred on one of the organization’s sites, it
is cataloged in a historical spills data base.
Information from the government reports is used as the criteria for evaluating the significance of the
historic spill site. Spills that involve dangerous oilfield products, large volumes or spills that affected
large areas are prioritized or flagged.
Currently communication is taking place with environmental consulting companies to determine the level
of follow up that is required at this stage. This would typically involve a site inspection to identify any
signs of adverse environmental impact followed by more detailed physical testing if warranted.
Remediation work would then be performed on sites that are determined to have some level
contamination present.
Operations sites in Southern Alberta and Saskatchewan are being reclaimed to specific grasslands status
that originally existed.
2.14
Measure and Improve Performance
Background:
There is a core set of quantitative measures in place that are used to track historical environment, health
and safety related performance in the areas of employee injuries, emissions of air contaminants to the
environment, spills to the natural environment, and the use of water. All of these measures are
benchmarked against the industry as whole through a major oil and gas industry association to which the
organization belongs.
The organization also participates in providing occupational illness/injury, process, and transportation
incident information into the CIAC comparison data base. These are referred to as Safety and Health
Analysis, Recognition and Exchange (SHARE), Process Incident Measure (PRIM), and Transportation
Incident Measure (TIM)
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In 2011 environmental emissions and wastes will begin to be reported into the CIAC environmental data
base referred to as the National Emissions Reduction Master Plan (NERM).
In addition to the above, the organization also tracks complaints from the public related to its operations.
As well as addressing measures related to historical issues, a slate of indicators aimed at preventing
incidents has been established. These are referred to as leading indicators and include completion of
compliance observations, safety critical equipment inspections, employee training, work site inspections,
etc.
Improvement Opportunity:
i)
Expedite implementation of NERM reporting to the CIAC according to, or earlier
than, the current plan to commence in 2011.
Best Practice:
i)
2.15.1
The focus on incident prevention through the use of “leading indicators” which
formally track such aspects as completion of compliance observations, safety
critical equipment inspections, employee training, work site inspections, etc.
Incident investigation
Background:
There is a documented standard in place that addresses incident investigation and reporting. Its purpose is
to set minimum requirements for the reporting and investigation of all occupational health and safety
environment, property/ vehicle damage, process safety, security, and transportation incidents that occur.
All incidents investigations and preventive measure follow up actions required are logged in a specific
data base and remain active in the system until all remedial actions have been satisfactorily addressed.
Within the system there is an automatic process to remind those who have been assigned to carry out the
remedial actions when the targeted completion date has become overdue.
2.15
Manage Emergencies
2.15.1 Ability to respond
Background:
There is an overarching emergency response management standard in place that gives direction to central
management planning and to the field based emergency response plans.
Each business unit has an area specific emergency response plan, each of which takes into consideration
the communities and the various stakeholders in proximity to the operations that could be affected during
an emergency.
Emergency response plans are built on the recognized model, and are a legislative requirement. All
personnel have been trained in various aspects of the incident command system, all personnel designated
to manage emergency operations have been trained accordingly.
Plans are tested on an annual basis through drills and exercises that involve employee personnel, first
responders, municipalities and regulators.
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Improvement Opportunities:
i)
Review the medevac system for the Dilly Creek facility in the shale gas area with
a view to improving the timeliness of same.
ii)
Establish plans for emergency exercises in all areas that include aspects which
would complicate the response (e.g., inclement weather, during the off hours,
road blockages, site inaccessible, loss of communications, equipment not readily
available, etc.)
2.15.2
Integration of site and community emergency plans
Background:
The annual drills noted above which involve first responders, municipalities and regulators is the primary
method of integrating the organization’s and community emergency response plans.
Improvement Opportunities:
i)
Ensure that the incident command system, with respect to response roles and
responsibilities, is applied consistently in all communities. There was one recent
example in the coal bed methane W5 area where the local fire truck entered a
site without permission.
ii)
Expedite completion of an offsite emergency response exercise in the coal bed
methane W5 area according to the current planned date of the fourth quarter of
2010.
2.15.3
Dislocated persons
Background:
Guidance for managing residents who have been evacuated during an emergency is provided in the
individual site emergency response plans, and mock evacuations are tested during emergency response
exercises.
During emergencies that are prolonged, evacuated residents are supported in accordance with the
requirements of a corporate crisis management plan.
2.15.4
Evaluation and correction of emergency systems
Background:
Goals and objectives are set to test each emergency response plan using a variety of methods, such as
table top, field drills, what if scenarios, etc., to ensure the plans achieve the desired result.
Analyses of the test activities are discussed and actions arising from these discussions are entered into a
specific data base for follow-up and resolution, and remain active until all actions have been satisfactorily
addressed. The entries have responsibility assigned and timelines set.
All of these requirements are set out in the emergency response management standard noted above.
2.15.5
Transportation emergency response
Background:
The emergency response management standard, noted above, sets out the requirements for transportation
emergency response planning.
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The organization’s transportation emergency response plan complies with all of the CIAC transportation
emergency assistance planning requirements, and legislated transportation emergency response assistance
plans are also in place where required by the regulations.
2.16
Assisting in Public Policy Development
Background:
This is primarily achieved through active involvement in the Canadian Association of Petroleum
Producers and numerous related committees within this oil and gas industry association.
Representatives also participate in various related CIAC committees.
2.17
Audit and Follow-up
Background:
Annual internal health, safety, environment and social responsibility audits and process safety audits are
carried out.
External audits are carried out by health and safety, environment and energy resources regulators.
Follow up actions required are logged in a specific data base and remain active in the system until all
remedial actions have been satisfactorily addressed.
Improvement Opportunity:
i)
Establish a process for annual attestation to the CIAC by the executive contact,
regarding continued Responsible Care compliance.
3.
CONCLUSIONS and RECOMMENDATIONS
Based upon this verification the team considers that Nexen Inc. Canadian Oil and Gas Division has
achieved the required standard for Responsible Care In-Place certification, and that the CIAC officially
recognize this verification with an award at the next suitable occasion.
Improvement Opportunities and Best Practices as identified in the body of the report are listed below:
Improvement Opportunities:
1) Establish a process to ensure continued promotion and support for Responsible Care
throughout the organization and to sustain the current momentum into the future.
2) Establish and implement a plan and schedule to ensure for timely review and
implementation of new standards in all areas, and their incorporation into local
procedures.
3) Expedite implementation of the process safety management program according to, or
earlier than, the current plan to have this completed by 2013.
4) Follow-up to ensure that all contract operators are receiving performance
evaluations.
5) Consider including contract operators in the safety and environmental performance
aspect of the incentive bonus program.
6) Review the organization’s policy for diversity in the workplace and promote hiring
practices in all areas that are representative of local demographics. It was observed
that field personnel were predominantly male Caucasian.
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7) Expedite completion and implementation of the aboriginal relationships policy
currently being developed.
8) Research how the traditional way of life in the shale gas area might be impacted
especially if the organization expands operations further to the north and west where
several first nations live other than those in the current area of operations. (Note:
Useful information may be find in the document entitled “Fort Nelson First Nations
Submission on EnCana’s Cabin Gas Project Environmental Assessment”)
9) Establish a process to regularly assess neighbour awareness of risks and what to do
in the event of an emergency.
10) Bring additional focus to aligning community expectations with the organization’s
ability to deliver. There is an example in the shale gas area regarding use of local
services and job creation, and in coal bed methane area regarding elimination of
adverse impacts to the entire ecosystem.
11) Establish clearer classification criteria for community complaints.
12) Ensure that an appropriate level of attention is maintained on addressing low risk as
well as the necessary priority that must be given to the higher health risks, in ongoing workplace hazard exposure monitoring programs.
13) Review the current practices for cell phone and radio use while driving and upgrade
as appropriate to reduce or eliminate associated risks.
14) Consider the use of global positioning equipment for employees as part of the
working alone procedure to assist in locating anyone who has not checked in
according to procedure.
15) Review the effectiveness of the work alone procedure in areas where cell phones do
not function.
16) Expedite the completion of baseline hazard and operability studies according to, or
earlier than, the current plan established for the next five years.
17) Expedite the completion of quantitative risk assessments according to, or earlier
than, the current planned date of 2011.
18) Expedite completion of transporter route risk assessments according to, or earlier
than, the current plan, and input stakeholder awareness requirements into the annual
neighbour visit information database.
19) Expedite implementation of the environmental footprint reduction program
according to, or earlier than, currently established completion dates for all media.
20) Expedite installation of the vapour recovery facility as currently planned at the shale
gas area Dilly Creek site to reduce flaring.
21) Consider establishing a specific buffer zone standard which addresses not only
regulatory requirements but also defines a process to monitor and access the
necessary information to proactively address issues related to encroachment of
commercial/residential/institutional developments on existing facility set backs.
22) Expedite implementation of hazardous product supplier assessments and follow-up
according to, or earlier than, the current planned date of 2011.
23) Implement the supplier assessment process with second party pipeline operators.
24) Expedite implementation of the new electronic management of change tool referred
to as “eMOC” to replace the existing manual system.
25) Complete and implement the security standard currently under development.
26) Give an appropriate level of attention to training contracted truckers in aspects of
security awareness.
27) Expedite implementation of NERM reporting to the CIAC according to, or earlier
than, the current plan to commence in 2011.
28) Review the medevac system for the Dilly Creek facility in the shale gas area with a
view to improving the timeliness of same.
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29) Establish plans for emergency exercises in all areas that include aspects which
would complicate the response (e.g., inclement weather, during the off hours, road
blockages, site inaccessible, loss of communications, equipment not readily
available, etc.)
30) Ensure that the incident command system, with respect to response roles and
responsibilities, is applied consistently in all communities. There was one recent
example in the coal bed methane W5 area where the local fire truck entered a site
without permission.
31) Expedite completion of an offsite emergency response exercise in the coal bed
methane W5 area according to the current planned date of the fourth quarter of
2010.
32) Establish a process for annual attestation to the CIAC by the executive contact,
regarding continued Responsible Care compliance.
Best Practices:
1) The entire Responsible Care management system structure with supporting standards
and procedures, including its roll out and implementation throughout the
organization, which incorporates a process for end user input to maximize
understanding and acceptance of the standards.
2) The clear emphasis in the Responsible Care management system, and the explanation
therein, on the plan-do-check-act continual performance improvement cycle.
3) The process safety management system currently being implemented.
4) The “communities of practice” forums where best practices can be shared across the
organization.
5) The emphasis placed on promoting the understanding of the Responsible Care ethic
and management systems as well as the acceptance of personal responsibilities and
accountabilities for implementation throughout the organization.
6) The entire community outreach program which has clearly established the
organization as a model corporate citizen in the oil and gas industry.
7) The external stakeholder grid used to determine the extent of site specific community
outreach initiatives.
8) Community involvement training provided for shallow gas area based field
operators.
9) The electronic system referred to as “SkillsTrak” for training information gathering
sorting and reporting.
10) The application of hazard and operability studies on supplier equipment (e.g., well
fracing equipment).
11) The emphasis being placed in the coal bed methane area to manage service rig safety
with respect to rig movement on highways and site preparation for service work.
12) The hand held electronic activity data collection and scheduling system referred to as
“FieldTrak” which ensures that all critical operating and compliance activities are
identified and carried out according to requirements.
13) The focus on incident prevention through the use of “leading indicators” which
formally track such aspects as completion of compliance observations, safety critical
equipment inspections, employee training, work site inspections, etc.
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4.
OBSERVATIONS FROM THE ORGANIZATION
Nexen COG (Canadian Oil & Gas Division) is pleased with the outcome of our Responsible Care® InPlace Verification. We sincerely thank the verification team for its expertise and commitment during our
first Divisional verification.
Dialogue between our COG Division & Field staff and the verifiers during the verification was very
informative and beneficial.
We would also like to thank Brian Wastle for his inspiring and supporting role and other CIAC staff for
their support along this three year journey.
Our COG Division employees have embraced the Responsible Care® ethic and we remain committed RC
ambassadors to other interested parties within the greater Nexen Corporation and within our Canadian Oil
& Gas industry.
We are dedicated to follow-up with the action items that have been generated by the opportunities
detailed in this initial Verification In-Place report. We are looking to our first Re-Verification in 2013
under the new Responsible Care® Codes of Practice protocol!
Name
Position, Company
Date
Brian E. McAusland
RC Manager, COG HSE&SR, Nexen Inc.
Dec 14, 2010
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CHEMISTRY INDUSTRY ASSOCIATION OF CANADA
Suite 805, 350 Sparks Street
Ottawa (ON) K1R 7S8
T: 613 237-6215 F: 613 237-4061
www.canadianchemistry.ca