FITNESS TO WORK STANDARD

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FITNESS TO WORK STANDARD HSE 0096
AWARENESS TRAINING PH 4506
SEPCo HSE Occupational Health
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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, PS, DC HSE Managers
  HSE Network
• Endorsed by HSE CC, PSLT AI, WLT OM Forum

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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)

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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
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FITNESS TO WORK STANDARD - REQUIREMENT 1

• 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

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FITNESS TO WORK STANDARD - REQUIREMENT 2

• Substance Abuse Testing (pre-employment and
  ongoing)
• Human Resources to 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 Shells
  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.
• Contractors working on SEPCos behalf have an
  appropriate Drug and Alcohol policy in place.
• Applicable to SEPCO Contractors

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FITNESS TO WORK STANDARD - REQUIREMENT 3

• 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

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FITNESS TO WORK STANDARD - REQUIREMENT 4

• 4. Fitness (Strength) Test (pre-employment)
• Human Resource to arrange 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

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FITNESS TO WORK STANDARD - REQUIREMENT 5

• 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

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FITNESS TO WORK STANDARD - REQUIREMENT 5 (Contd)

• Supervisors should 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

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FITNESS TO WORK STANDARD - REQUIREMENT 6

• 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).

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FITNESS TO WORK STANDARD - REQUIREMENT 6 (Contd)

• 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 employees
  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.

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FITNESS TO WORK STANDARD - REQUIREMENT 6 (Contd)

• 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.

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FITNESS TO WORK STANDARD - REQUIREMENT 6 (Contd)

• 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 locations
  emergency evacuation procedure, and/or inability
  to fit or mobilize into an offshore platforms
  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.

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ADDRESSING FITNESS TO WORK ISSUE AT SEPCo WORK
LOCATION
Identify Fitness to Work Issue at Work
LocationFOR 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 ADAs legal boundaries
Discusses with the concerned individual privately
and ask the individual to fill the Self
Certification of Fitness Form
Issue with Imminent Threat e.g. evidence that
Worker X while climbing stairs as part of
his/her task felt breathless and dizzy
Arrangement for urgent evaluation 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
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
Health Services evaluates the fitness status
(fully fit/ fit with some job modifications/
unfit for current job etc.) and advise Location
management / HR
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)
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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
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REQUIREMENT 7 - FATIGUE MANAGEMENT (Contd)
7a Contd.

• 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.

• 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

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FATIGUE MANAGEMENT REQUIREMENT 7 (Contd)
Examples of Tasks with regards to 7a

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• 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

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REQUIREMENT 7 - FATIGUE MANAGEMENT (Contd)
7a Contd.

• Individuals, field and office based, not meeting
  one of the earlier descriptions.

• are personally responsible for managing the risks
  associated with prolonged working hours and shall
  discuss any concerns with their supervisor.

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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 individuals 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
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FATIGUE MANAGEMENT REQUIREMENT 7 (Contd)

• 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

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FATIGUE MANAGEMENT REQUIREMENT 8

• 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.

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FITNESS TO WORK STANDARD - RECOMMENDATIONS

• Medical Condition Medication Procedure
• Employees advised to follow HSE0071
• Voluntary Physical Examinations
• Employees encouraged to utilize
• Employee Wellness
• Employees encouraged to utilize available programs

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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.
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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.
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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.
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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.
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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.
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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 1130pm
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 doesnt 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.