Environment, Health and Safety Management System Guide Santos · superior Environmental, Health and Safety (EHS) performance, in pursuit of our Safety Vision "We all go home from

Santos

Environment,Health and SafetyManagement System GuideVersion 3.1 June 2009

Cover photograph: Fred Hewitt, Maintenance Operator and Darren Maunder, Production Operator, Wallumbilla gas hub, Queensland. Inside photographs: Left panel throughout: Mark Bunker, Production North, Operator Maintainer, Scotia coal seam gas operations, Queensland.Right panel throughout: Section of Adelaide’s River Torrens that has been rehabilitated by Santos volunteers through the Our Patch program.

Santos Ltd ABN 80 007 550 923

Message from the Managing Director

Santos' aspiration is to be a leading Energy company in

both Australia and Asia.To achieve this Santos must deliver

superior Environmental, Health and Safety (EHS)

performance, in pursuit of our Safety Vision "We all go

home from work without injury or illness" and our

Environmental Vision "We will lighten the footprint of our

activities".

The Santos Environment, Health and Safety Management System (EHSMS) outlines the structured approach necessary for

our operations to manage EHS risks and drive EHS improvement in a consistent and systematic manner. Each standard

within the EHSMS defines the requirements of all employees and contractors to achieve this outcome in a clear and

comprehensive manner.

Our challenge is to make our EHSMS work.This requires focus, understanding and active involvement by everyone working

for Santos. Please take the time to understand your responsibility to help deliver Santos’ Safety and Environmental Visions.

> Santos > INTRODUCTION 1

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INTRODUCTION

> EHSMS FRAMEWORK > Santos2

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ABOUT THIS DOCUMENT

What’s inside?

Overview 2

EHSMS Framework 2Overview of the multiple layersthat make up the EHSMS.

Santos EHS Policies 4

Management Standards 6Minimum expectations that Santos applies acrossits entire operations in the management of Santos’environment and health and safety system.

Summary 6

Listing 7

Hazard Standards 38 Specific processes to manage hazards thatunderpin the EHS Management Standards.

Summary 38

Listing 39

Glossary 70Definitions of key terms and abbreviationsused throughout this document.

Overview

This guide has been developed as a stand alone document

to assist with the understanding of the Santos Environment,

Health and Safety Management System (EHSMS). The guide

provides a description of the management system and a summary

of the key requirements for each of the management and hazard

standards making up the EHSMS.

Printed copies of this guide and printable copies downloaded

from the website should be treated as uncontrolled copies.

Constructive comments about this guide are encouraged and

welcomed. Comments should be directed to the EHSMS

Coordinator ([email protected]).

EHSMS Framework

The Santos Environment, Health and Safety Management System

applies to all Santos operations worldwide.

The system framework has been developed to ensure that Santos’

system is compliant with Australian Standard 4801 2000

Occupational health and safety management systems –

Specification with guidance for use, and AS/NZS ISO 14001:2004

Environmental management systems – Specification with

guidance for use.

The EHSMS framework consists of multiple layers, the key

components being management and hazard standards as shown

below in Figure 1.

What is the Santos Environment, Health and

Safety Management System?

The EHS Management System is a company-wide system that

describes the requirements for effective environmental and

safety practice across all of Santos’ activities and operations. The

EHSMS requirements address the management of risk associated

with high frequency, low consequence events (the focus of

traditional EHS management systems) as well as low frequency,

high consequence events which are typically dealt with by a

process safety management system. The application of the EHSMS

enables us to achieve the objectives detailed in Santos'

Environment and Health and Safety policies.

The EHSMS standards can be broken down into two basic areas:

Management Standards and Hazard Standards.

1. Management Standards are documents which define the requirements necessary to ensure that environmental,health, safety and process safety risk is systematicallymanaged.

2. Hazard Standards are documents which detail the controlsrequired to manage the risks of specific hazards toacceptable levels.

Why do we have it?

To provide a clear set of environment, health and safety (EHS)

expectations so that there is a consistent, efficient approach

across the company.

What should I do?

All Santos employees and contractors are responsible

for contributing to a safe and environmentally responsible

workplace. This means conducting our day-to-day activities

according to the EHSMS standards which in part focus on the

continual identification of hazards and implementing effective

risk control measures. Everyone is encouraged to suggest ways to

improve safety and environmental performance at Santos via

toolbox meetings, EHS committee meetings or by contacting

their supervisor, their Health and Safety Representative,

an EHS adviser or Santos' EHSS&IA Department

(see back cover).

> Santos > EHSMS FRAMEWORK 3

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ABOUT THIS DOCUMENT

Figure 1: EHSMS framework

Developed to address unique featuresrelating to the Function or Department

eg Incident Management System,Santos Incident Management Plan,

Safety Leadership Training

System Standards Management & Hazard Standards

Assessmentand Audit

Policy

EHSStandards

CommonGroup Processes

Function & DepartmentProcesses & Procedures

Environment & Safety Tools & Programs(common where possible)

> EHSMS FRAMEWORK4

SANTOS’ EHS POLICIES

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SANTOS EHS POLICIES> Santos

Evolution of the Environment, Health and Safety

Management System

The Environment, Health and Safety Management System

(EHSMS) is a dynamic system which is continually being improved

to ensure it is current and aligned with the changing nature and

demands of our business such as our expanding interest in

offshore developments. This revision of the EHSMS includes the

integration of process safety requirements which now provides a

consolidated framework for the management of process safety

related risk. This initiative provides a systematic approach to

process safety that will enable us to further improve on the

reliability and integrity of our plant and equipment which in turn

will support the ongoing improvement in our environment,

health and safety performance.

Where can I get a copy of a standard?

The EHSMS standards are controlled documents. Controlled

copies of the standards can be found on the Santos intranet, “The

Well”, via the link on the right-hand-side of the front page “EHS

Management System (EHSMS) Index”.

The purpose of the Santos EHS policies is to provide the overall

direction for the EHSMS. The policies demonstrate a commitment

by Santos to strive for EHS performance improvement and

provide a framework for setting the overall EHS and process

safety objectives against which Santos’ performance will

ultimately be measured.

The application of the EHSMS enables Santos to achieve the

objectives in the following EH&S policies.

SantosHealth & Safety Policy

Our Health and Safety Vision:

“We all go home from work without injury or illness”

We believe that: • No business objective will take priority over health and safety. • All injuries and incidents are preventable. • No task is so important or urgent that it cannot be done safely. • Without diminishing management’s obligations, the responsibility and accountability for

health and safety rests with every individual.

At Santos we are committed to conducting our business in a manner that prevents injury orillness to employees, contractors, customers and the public who may be affected by our workactivities. We encourage best practice in health and safety management within this widerSantos community.

To achieve this we will: • Maintain and continuously improve the Environment, Health and Safety Management

System (EHSMS) across the organisation. • Provide a balanced focus on the management of health and wellbeing, personnel and

process safety.• Proactively pursue the identification of all hazards and eliminate or, if not possible,

manage the risk to as low as reasonably practicable. • Consult with and promote active participation of employees in the management of their

own and others’ health, wellbeing and safety. • Require that companies providing contract services to Santos manage their health and

safety in line with this Policy. • Provide resources to achieve a systematic approach to health, personnel safety and

process safety management to ensure continuous performance improvement. • Identify performance measures, set improvement targets, measure and report

performance at all levels.• As a minimum comply with relevant legal and other requirements. • Develop a culture where all employees and contractors are constantly aware of safety

hazards around them and act accordingly at and away from work. • Include health and safety performance in the appraisal of employees and contractors and

recognise accordingly. • Steward the health and safety performance of Joint Venture activities operated by others.

Santos Ltd ABN 80 007 550 923 File No: POLICY P039

David KnoxChief Executive Officer and Managing Director30 August 2008

> EHSMS FRAMEWORK 5

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SANTOS’ EHS POLICIES

SantosEnvironmental Policy

Our Environmental Vision:

“We will lighten the footprint of our activities”

At Santos we are adopting the principles of sustainable development. We recognise ourresponsibility to meet community expectations and we are committed to the continuousimprovement of our environmental performance. We believe that environmental stewardship is both a management obligation and the responsibility of every employee.

To achieve this we will:• Maintain and continuously improve the Environment, Health and Safety Management

System (EHSMS) across the organisation.• Ensure that all employees and contractors receive appropriate training to fulfil their

individual EHSMS and environmental responsibilities. • Proactively pursue the identification of all hazards and eliminate or, if not possible,

manage the risk to as low as reasonably practicable.• Establish annual environmental objectives and targets and implement programs to

achieve them.• As a minimum comply with relevant legal and other requirements.• Ensure that we have the resources and skills necessary to achieve our environmental

commitments.• Incorporate environmental performance in the annual appraisal of employees and

contractors and recognise accordingly. • Implement strategies to minimise pollution, manage waste effectively, use water and

energy efficiently and address relevant cultural heritage and biodiversity issues.• Formally monitor, audit, review and report annually on our environmental performance

and EHSMS requirements against defined objectives.• Require that companies providing contract services to Santos manage their environmental

performance in line with this Policy.• Steward the environmental performance of Joint Venture activities operated by others.

As Chief Executive Officer and Managing Director, I am committed to working with Santospersonnel to ensure that this policy is communicated, understood, accepted and successfullyimplemented by all Santos employees and contractors.


David KnoxChief Executive Officer and Managing DirectorRevision 2

Our Climate Change Vision:

“Santos will lower the carbon intensity of its products”

Climate change is a long-term issue, requiring urgent but informed action to stabilise atmospheric greenhouse gas concentrations. As a global stakeholder in the energy business we recognise that one of our key social and environmental responsibilities is to pursue strategies that address the issue of climate change.

To achieve these commitments we will:

• Continue to reduce the carbon intensity of Santos’ products by focussing on energy effi ciency, technology development and by embedding a carbon price in all activities

• Use energy more effi ciently by identifying opportunities to implement energy effi ciency projects and report their progress

• Examine the commercial development of low emission technologies, including storage solutions, which will contribute towards long-term aspirational greenhouse gas emission reduction targets

• Pursue no fl aring or venting of associated gas, unless there are no feasible alternatives

• Continue to publicly disclose Santos’ greenhouse emissions profi le and carefully examine forecast emissions

• Understand, manage and monitor climate change risk and develop appropriate adaptation strategies for our business

• Assist governments and engage with other stakeholders on the design of effective and equitable climate change regulations and policy

Santos will inform employees about its commitment to climate change and ensure climate change initiatives continue to be implemented. The Santos Board will review progress against this policy quarterly.

David KnoxChief Executive Offi cer

December 2008

SantosClimate ChangePolicy


SANTOS EHS POLICIES> Santos

> MANAGEMENT STANDARDS > SantosSUMMARY

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MANAGEMENT STANDARDS

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PoliciesEHSMS01 Environment, Health and Safety Policies 7

PlanEHSMS02 Legal and Other Obligations 7

EHSMS03 Objectives and Targets 8

EHSMS04 Improvement Plans 8

ImplementEHSMS05 Responsibility and Accountability 9

EHSMS06 Training and Competency 10

EHSMS07 Consultation and Communication 10

EHSMS08 Document and Record Management 12

EHSMS09 Hazard Identification, Risk Assessment 13and Control

09.1 Job Hazard Analysis and Stepback 15

09.2 Hazard Studies 15

09.3 Workplace Inspections 16

09.4 Behavioural Improvement 16

09.5 Environmental Impact Assessment 16and Approvals

EHSMS10 Contractor and Supplier Management 18

EHSMS11 Operations Integrity 19

11.1 Design Basis – Facility and Equipment 19

11.2 Facilities Design and Construction 20

11.3 Pre-startup EHS Review 21

11.4 Structural Integrity 22

11.5 Mechanical Integrity 22

11.6 Ignition Control 23

11.7 Critical Protection Systems 24

11.8 Operating Procedures and Safe Practices 25

11.9 Maintenance 25

11.10 Fire Risk Management 26

11.11 Decommissioning and Abandonment 27

11.12 Operated by Others 28

EHSMS12 Management of Change 29

12.1 Critical Drawings and Control Systems 29

12.2 Vacant 29

12.3 Disablement of Protective Devices (Bridging) 30

12.4 Substitution of Materials and Equipment 30Components

12.5 Acquisition and Divestment of Assets 31

12.6 Management of Personnel Change 31

EHSMS13 Emergency Preparedness 32

13.1 First-Aid and Medical Facilities 33

Monitor and EvaluateEHSMS14 Monitoring, Measurement and Reporting 33

EHSMS15 Incident and Non-Conformance 34Investigation, Corrective andPreventative Action

15.1 Injury Management 35

EHSMS16 Management System Audit and Assessment 36

ReviewEHSMS17 Management Review 37

EHSMS18 Sustainability 37

Management standards are the documents which define the requirements to the systematic management of environment, health and safety hazards.

> Santos > MANAGEMENT STANDARDSEHSMS01 | EHSMS02

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EHSMS01Environment, Health and Safety Policies

Purpose

The policies outline overall environment, health and safetydirection and objectives and demonstrate Santos’ commitment toimproving environment, health and safety performance.

Summary of Key Requirements

> Santos shall develop EHS policies in accordance withrecognised standards.

> All activities conducted by Santos shall conform with the EHSpolicies.

> All activities conducted by contractors or by other companieson Santos’ behalf are to be carried out in accordance withpolicies that are equivalent in intent to the EHS policies and the Environment, Health and Safety Management System.

> EHS policies shall be communicated to all employees and all contractors.

> A review of the EHS policies shall be conducted on an annual basis.

EHSMS02Legal and Other Obligations

Purpose

Understanding legal and other obligations allows management toensure the activities of Santos and contractors comply with EHS andprocess safety legal requirements.


> Compliance with the requirements of the EHSMS should ensurecompliance with the relevant EHS legislation

> Compliance requirements for all levels of responsibility (fromthe Board to employees) are outlined in the EHS ComplianceRoad Map.

> An EHS Legal Obligations Directory summarising EHS lawsrelevant to Santos' operations shall be developed andmaintained at Corporate levels and will:

>> contain references to EHS licences, permits and otherobligations

>> contain references to EHS industry codes, commitmentsand other obligations

>> be readily available to all employees.

> Statutory compliance audits shall be conducted in accordancewith requirements outlined in EHSMS16 Management SystemAudit and Assessment.

> The Santos Leadership Team and the Board shall be informed ofany material change in EHS legal requirements and of anysignificant non-compliance within the business.

> The EHSMS shall take into consideration legislative requirements,relevant industry codes, practices and agreements.

> MANAGEMENT STANDARDS > SantosEHSMS03 | EHSMS04

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EHSMS03Objectives and Targets

Purpose

Objectives and targets are set to measure and drive continuousimprovement in environment, health and safety, and process safety,performance across the company.


> Corporate EHS and process safety objectives and targets shall be drafted in December for the following calendar year by EHSS&IA in consultation with relevant functionalgroups.

> Function, department and site objectives and targets shall beestablished to measure performance and drive improvement inline with Corporate objectives and targets.

> Objectives and targets shall be:

>> Specific: Set at an appropriate level and not too broad or too detailed

>> Measurable: Assessable either quantitatively or qualitatively

>> Achievable: Realistic based on resources and competencies

>> Relevant: Effectively achieves desired result

>> Timely: Realistic time to achieve the change.

> Targets shall be set for a number of EHS and process safetymeasures including both proactive (lead) and reactive (lag)measures.

> Objectives and targets shall be regularly reviewed and progressupdated with consolidated reports being reviewed by SantosLeadership Team and the Board.

EHSMS04Improvement Plans

Purpose

EHS and Process Safety Improvement Plans set out the specificinitiatives, actions and milestones for achieving environment,health and safety and process safety performance objectives andtargets.


> Strategic EHS and Process Safety Improvement Plans (IPs) shallbe developed and maintained in consultation with relevantfunctional groups.

> The Strategic Plans shall include the key EHS and process safety issues (such as plant integrity, implementation ofEnvironment, Health and Safety Management System,leadership and behaviour) and provide a broad framework forachievement of the Corporate EHS and process safetyobjectives and targets. The plan shall detail the following:

>> a statement of the current status and desired long-termobjective

>> annual major milestones to be achieved

>> responsibility for the completion of each milestone.

> EHS IPs shall be developed annually on a calendar year basisfor functional areas as determined by the relevant functions.

> IPs shall detail the actions, responsibilities and timeframes toachieve the Strategic Plans and Functional EHS and processsafety objectives and targets and actions arising fromassessments and audits.

> Santos > MANAGEMENT STANDARDSEHSMS04 | EHSMS05

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> Improvement Plans shall be regularly monitored by linemanagement to ensure that appropriate progress is beingachieved and deviations are addressed.

EHSMS05Responsibility and Accountability

Purpose

Assignment of roles, responsibility and accountability ensuresresources, including human, technical and financial areappropriately used to implement, maintain and improve the EHSMS.


> EHS, including process safety, outcomes are a line managementresponsibility supported by EHS, engineering and othertechnical personnel and EHS committees.

> Organisational structures and position descriptions shall bedocumented to outline the hierarchy of EHSMS relatedresponsibilities, accountabilities and reporting channels.

> Personal EHS and process safety objectives shall be set as acomponent of the performance review process for relevantsalaried personnel.

> Committees shall be established within relevant functions tohelp management oversee the implementation, monitoringand review of the Santos EHSMS.

> Sufficient resources shall be provided by management to:

>> implement improvement plans to achieve EHS and processsafety objectives and targets

>> develop, implement and maintain the EHSMS

>> ensure compliance with relevant legal and othercommitments.

> MANAGEMENT STANDARDS > SantosEHSMS06 | EHSMS07

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EHSMS06Training and Competency

Purpose

Focused training ensures that everyone with responsibilitiesallocated under the EHSMS understands how to fulfil theirresponsibilities and has the necessary skills.


> A training system shall be developed and maintained.

The training system shall:

>> be based on a training needs analysis of EHS statutory andEHSMS requirements

>> provide for appropriate delivery methods to cater forvarying work situations

>> include processes to validate training effectiveness.

> Employees and contractors shall only be permitted to performunsupervised tasks where they have the skills and experienceor competency to perform such tasks without harm.

> All personnel working at or visiting a Santos site or facilityshall undergo an appropriate EHS induction.

> EHS competencies shall be specified in Position Descriptions.

> Employees shall only be appointed to positions where theyhave the required EHS training, experience and competencyrequirements as defined for that position.

> A system shall be developed and maintained to validate thatcontractors have relevant EHS competencies, including thoserequired by statute.

> EHS training records shall be maintained for 40 years.

EHSMS07Consultation and Communication

Purpose

Appropriate consultation and communication processes enableemployees, contractors and external stakeholders to understandand contribute to EHSMS requirements and decisions.


> Consultative arrangements shall be in place to provideemployees, contractors and external stakeholders with an opportunity to contribute to EHS and process safetydecision-making.

> Consultation with employees shall be via EHS Committees andHealth and Safety Representatives.

> Operations that have a significant impact on the localcommunity shall establish consultation mechanisms foraffected groups.

> Consultation with government agencies, authorities and otherorganisations shall be maintained in order to contribute to thedevelopment of public policy, relevant legislation, improvedindustry performance and educational initiatives.

> The Santos EHS Policies, EHSMS Standards, and relevant EHSissues and performance shall be communicated to employeesand contractors. Where required, EHS information shall beprovided in appropriate languages for non-English speakingpersonnel.

> Santos > MANAGEMENT STANDARDSEHSMS07

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Methods of communication include:

>> EHS Committees

>> toolbox meetings

>> Santos EHS Toolbox

>> presentation of EHS KPIs (for example on the intranet, “TheWell”)

>> EHS training

>> EHS notice boards, bulletins and alerts

>> management visits

>> awareness programs and initiatives.

> Monthly workgroup meetings shall be held includingcommunication and discussion of EHS matters at all Santos sites.

> Santos sites shall have EHS Committees to monitor theimplementation of the EHSMS, discuss EHS matters andrecommend to management the means to resolve issues.

> Functions and departments shall hold regular EHS Managementmeetings to monitor the implementation of the EHSMS. Thepurpose of the EHS Management Committee is to provide alinkage between the sites and the Corporate EHS and processsafety objectives and targets.

> Meetings, where appropriate, should start with a discussion ofrelevant EHS issues.

> Daily toolbox meetings shall be held for workgroups including therelevant supervisor, employees and relevant contract personnel.

> Communication with external stakeholders on EHS mattersshall be maintained, both proactively and upon request.

> Regular reporting and notification of EHS incidents, whererequired by statute, shall be reported to the appropriategovernment agency.

> EHS reporting shall be included in the Santos Annual Reportand the Santos internet site, www.santos.com.

> MANAGEMENT STANDARDS > SantosEHSMS08

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EHSMS08Document and Record Management

Purpose

Personnel need access to current, up-to-date versions of all EHSMSdocuments to perform their work. Records also demonstratecompliance with environment, health and safety policy, standardsand attainment of objectives.


> EHSMS documents shall have a nominated Custodianresponsible for the management of the document.

> EHSMS documents shall have a nominated Technical Sponsorwho shall be responsible for the technical content of thedocument.

> The controlled electronic copy of EHSMS documents shall bekept and maintained by the EHSS&IA department.

> Paper–based versions of EHSMS documents shall be marked as“uncontrolled copy” and the user of a printed document isresponsible to ensure that it is the latest version.

> Documents shall be issued in appropriate languages to ensurepersonnel who require access to the information are able toread them.

> Where applicable, work instructions and signs should be in theform of pictures, drawings, colours and other visual means,rather than text.

> EHSMS documents shall be reviewed by the custodian at aminimum of every three years or when triggers for change occur.

> Custodians shall ensure that links to external documents suchas Acts, Regulations, industry codes, standards and guidelinesreferenced in EHSMS documents are current.

> Line managers shall ensure that EHSMS documents are readilyaccessible.

> EHSMS-related documents shall have document controlfeatures to enable users to determine that they are usingcurrent and complete documents.

> Records shall be kept for defined periods to demonstrateconformance with requirements of the EHSMS.

> The asset manager shall ensure that a Plant Dossier is preparedand maintained. Plant Dossier documentation shall beaccessible to potential users.

> New significant process–safety–related information gainedfrom external sources shall be documented and included inrelevant Plant Dossier(s).

> Santos > MANAGEMENT STANDARDSEHSMS09

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EHSMS09Hazard Identification, Risk Assessment

and Control

Purpose

Processes are necessary to systematically identify hazards, assesstheir risk and adopt control strategies to reduce risk to as low asreasonably practicable.


> The overall risk management approach used by Santos shall,unless otherwise stated, be based on Australian StandardAS4360 Risk Management.

> Appropriate hazard identification and risk managementprocesses shall be used for all aspects of our business based onthe following framework:

>> projects

>> acquisitions

>> operations

>> change

>> tasks and jobs.

> The Incident Management System (IMS) shall be used to recordand manage EHS and process safety hazards identified duringdaily activities.

> The Significant Hazard Risk Register (SHRR) shall be used to record and aid the management of risk associated withpotential significant unwanted events that could occur in theworkplace.

> Major Hazards (as defined) shall be managed in accordance

with the requirements of relevant Major Hazard Facilitylegislation for onshore facilities and with the relevant “SafetyCase” legislative requirements for offshore activities.

> Personnel participating in risk assessments, requiring formalrisk acceptance, shall be competent to participate in therisk–assessment process being used.

> Operational risk assessments shall involve representation frompersonnel that are likely to be exposed to the hazard.

> The risk matrix is the primary risk assessment tool and shouldbe used as a risk ranking or screening tool to identify thoseunwanted events which may require a more rigorousrisk–assessment process in particular when conducting processsafety related risk assessments.

> A formal risk acceptance shall be used where:

>> the risk assessment relates to “ongoing” potential or actualunwanted events

>> the risk assessment identifies that the current residual risklevel is two or higher.

> Where a risk assessment (that will require formal riskacceptance) results in a residual risk level of three or higher areview of the risk assessment shall be conducted by anappropriate “subject expert” to determine if the residual riskcan be further reduced.

> A residual risk of five shall be intolerable and levels 2 to 4 shallbe tolerable provided that it has been determined that the riskis as low as reasonably practicable (ALARP).

> Risk assessments and results shall be documented in a manner that enables the information to be kept as a retrievable record.

> MANAGEMENT STANDARDS > SantosEHSMS09 | EHSMS09.1

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> Where it is assessed that a residual risk is not ALARP, a plan forimproving existing and/or creating new risk controls shall beprepared and submitted for approval.

> In assessing risk controls, consideration shall be given to bothpreventive controls (to prevent a breakdown event occurring)and mitigation controls (to minimise the consequences shouldthe breakdown event occur).

> Risk control measures shall be assessed using the ‘Hierarchy ofControl’ approach. Elimination shall be the first (andpreferred) control method to be considered. A number ofcontrol options may be considered and applied eitherindividually or in combination.

> A plan for improving or creating new risk controls (includingany risk–control studies or interim controls) shall be preparedwithin a defined period of time. Actions shall be recorded andmanaged using Incident Management System (IMS).

> Risk controls implemented shall be reviewed to ensure thatthat they have been effective, they have not introduced anynew unintended hazards and that the risk has been reduced toan acceptable level.

> A Significant Hazard Risk Register (SHRR) shall be developedand maintained for defined activities and sites and shallinclude all hazards with an inherent risk score of three orhigher.

> Selected operating facilities shall be subject to Process HazardAnalysis every five years to identify possible unwantedprocess–related events.

> All hazards in the SHRR shall be reviewed periodically to ensure

that the risk controls have achieved, and are continuing toachieve, the intended risk reduction.

> A SHRR shall be prepared as a component of a project.

> The SHRR shall be used to identify major hazards to be includedin the induction of new employees and contractors, and indeveloping annual EHS and process safety improvement plans.

> The SHRR shall undergo a review every five years.

> A custodian shall be appointed to maintain the SHRR.

> A generic office SHRR shall be developed.

Establish the Content

Identify Risks

Analyse Risks

Evaluate Risks

Treat Risks

Com

mun

icat

e an

d Co

nsul

t

Mon

itor

and

Rev

iew

Assess Risks

Figure 2: Risk management process.

> Santos > MANAGEMENT STANDARDSEHSMS09.1 | EHSMS09.2

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EHSMS09.1Job Hazard Analysis and Stepback

Purpose

To define the requirements for identifying, assessing andcontrolling personal risks associated with work activities.


> All personnel who carry out work for or on behalf of Santos infield locations shall, where required, participate in developinga Job Hazard Analysis (JHA) prior to commencing work andshall complete their assigned actions in accordance with theJHA.

> A JHA must be completed prior to performing any task where itis possible that a loss may result and if there is no pre-approvedstandard operating procedure or work instruction thatidentifies the hazards and controls the risks of the task.

> The JHA shall be approved by the permit holder or supervisorof the task prior to work commencing.

> Stepback (as defined) shall be conducted by each individualbefore, during and after any job or task to ensure that it issafe to carry out the work and that no unacceptableenvironmental impact will result.

EHSMS09.2Hazard Studies

Purpose

To detail the requirements for the identification and riskmanagement of environment, health and safety hazards duringproject development.


> Relevant hazard studies shall be conducted at defined pointsduring the life of all projects.

> A hazard study shall be carried out for each facility acquisitionor divestment where required.

> Hazard studies shall be conducted during the operational lifeof a plant including cyclic Process Hazard Analysis for definedsites.

> Hazard Study Leaders shall have appropriate training andexperience and be authorised.

> Copies of records, reports etc. generated through hazardstudies shall be preserved for the life of the facility.

> MANAGEMENT STANDARDS > SantosEHSMS09.3 | EHSMS09.4 | EHSMS09.5

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EHSMS09.3Workplace Inspections

Purpose

Workplaces are inspected regularly to ensure hazards are identifiedand controls are implemented to manage their risk.


> Formal workplace inspections shall be scheduled and carriedout for all areas.

> Annual inspection schedules shall be developed for each workarea.

> A Workplace EHS Inspection Checklist shall be used whenconducting an inspection.

> Corrective action shall be taken to address hazards identifiedthrough workplace inspections.

EHSMS09.4Behavioural Improvement

Purpose

To define the requirements for managing the behavioural aspects ofenvironment, health and safety performance improvement.


> All personnel have a responsibility to:

>> carry out their work in a safe and environmentallyresponsible manner

>> stop inappropriate behaviour when witnessed

>> stop any activity which they believe poses an unacceptablerisk to their or others health, safety or the environment.

> Appropriate behavioural improvement programs shall bedeveloped and implemented.

> Line managers shall provide leadership in the use andconformance with the behaviour improvement program.

> A formalised EHS awards program shall be developed andmaintained to recognise EHS performance and innovation.

> Line management shall recognise and reinforce positivebehaviour.

EHSMS09.5Environmental Impact Assessment and Approvals

Purpose

To ensure that processes are in place to systematically identify andmanage potential environmental and social impacts associatedwith development activities and to obtain all relevant statutoryapprovals.


> The impact assessment processes shall be applied as early as possible in the design and decision–making process andprovide for the involvement and input of key stakeholdersrelevant to the activity.

> Internal and statutory requirements shall be identifiedthrough a review of the EHS Compliance Road Map.

> Santos > MANAGEMENT STANDARDSEHSMS09.5

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> The tenures of land and the rights of legitimate land users shallbe considered and respected when planning any newdisturbance or releases prior to obtaining relevant internal andexternal approvals.

> During the planning phase prior to undertaking any design(new or modifications to existing), an initial planning riskassessment is undertaken of the lifecycle of the activity oroperation, including decommissioning, abandonment andrehabilitation processes.

> Operations or activities undertaken in environmentallysensitive areas will be subject to stringent conditions tominimise environmental impacts. These will depend on thelocation and operation/activity being undertaken. Conditionswill be determined at the project approvals stage.

> Any activity that will disturb previously undisturbed areasrequires scouting prior to any on-ground activity.

> Site scouting documentation together with any requiredEnvironmental Management Plan shall be prepared andsubmitted for internal approval.

> For all projects a Regulatory Approvals Plan must be developedto ensure that all of the relevant approvals processes aremapped out in the project planning phase.

> Initial advice documentation shall be submitted to the relevantauthorities so that they can determine whether furtherenvironmental impact assessment and managementinformation is required.

> Environmental Impact Assessment documentation shall beprepared in close consultation with the relevant project team,be reviewed internally by appropriate managers, approved bythe Chief Environmental and Cultural Heritage Adviser, andsubmitted to the relevant authorities for approval.

> Internal approvals shall be obtained for

>> a new disturbance or activity that releases emissionsbeyond the boundaries of Santos operational areas

>> any material changes to the emissions of an activity thatare released beyond the boundaries of Santos operationalareas

>> any changes to an area of land disturbed

> The relevant Environmental Adviser shall assess the potentialenvironmental impact of new activities and define any specificconditions to be complied with. The relevant EnvironmentalAdviser shall determine the level of approval required,depending on the complexity of the proposal and its proximityto environmentally sensitive areas.

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EHSMS10Contractor and Supplier Management

Purpose

Contractors doing work on Santos’ behalf and suppliers ofequipment, materials and goods are required to have appropriateenvironment, health and safety management systems in place so asto prevent harm to Santos and Contractor personnel, the public, theenvironment and Santos’ business interests.


> Equipment, materials and goods assessed as being a potentialsignificant business risk shall be recorded in a catalogue which shall be used to ensure that appropriateequipment, materials and goods are purchased.

> Safety critical spare parts shall be identified as such in thecatalogue and shall be fully specified and only sourced fromthe approved supplier.

> All catalogued equipment and materials shall be obtained in accordance with the catalogue specifications.

> A quality control system shall be implemented for theprocurement and supply of safety critical equipment and spares.

> A risk assessment shall be conducted to determine the level of EHS assessment required for potential newcontractors and suppliers.

> Where the assessed risk is level 1 and the value of the contractis below $500,000 a capability assurance statement shall becompleted.

> Where the assessed risk level is greater than one or the valueof the contact is more than $500,000 a major contractprequalification shall be completed.

> EHS prequalification may be waived in defined scenarios as per the standard.

> Where a major contract is awarded and the assessed risk levelis greater than one, an EHS Management Plan shall bedeveloped by the contractor, tailored to the scope of work, andbe submitted for approval.

> A Santos Site Representative shall be appointed for a majorcontract to ensure that work carried out by the contractor is in accordance with the approved EHS Management Plan.

> Prior to the commencement of work the contractor shallcomplete the Santos level 1 and appropriate level 2 inductions.The contractor shall then provide to their employees a level 3induction based on their EHS Management Plan (whererequired).

> Contractors shall ensure that, where required, the endorsedEHS Management Plan is fully implemented and maintained forthe duration of the work activity.

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EHSMS11Operations Integrity

Purpose

Process safety management deals with the prevention of majorhazards or catastrophic events that could lead to fatalities, seriousinjury, significant property damage or significant environmentalharm. Systems and tools are required to manage process safetyrisks, as a subset of environment, health and safety management.The emphasis is on maintaining effective lines of defence to preventthe occurrence of and mitigate the consequences of majorunwanted events. Process safety is addressed across the fulllifecycle of assets, from development to operational integritythrough to diligence in abandonment.


> Management accountability for process safety managementrequirements shall be clearly stated. Competent and adequateresources shall be in place to support each element and theoverall system across all Santos–operated assets.

> Performance standards shall be in place to measure the processeffectiveness of process safety management, and reviewed withthe Board annually.

> A process safety triangle analogous to the personnel safety andhealth triangle shall be used to structure EHS reporting,escalation, investigation and safety statistical analysis relatedto process safety.

> Key Performance Indicators for process safety shall be reviewedat least annually by the Board and quarterly by the SantosLeadership Team.

EHSMS11.1Design Basis – Facility and Equipment

Purpose

A detailed description of the facility operating basis, the fluids andchemicals processed within the facility, and the design basis andoperating limits of the equipment involved, along with processes tosupport consistent operation within design limits is required toprovide a basis for all personnel associated with the operation,maintenance or design of a facility to identify, understand andmanage environment, health and safety risks.

These supporting processes include alarm management, operatingenvelopes and control systems.


> Each Facility Design Basis shall detail sufficient information ata facility and at equipment level to establish a clear basis foroperation.

> This information should be the basis for operating procedures,maintenance work, design modifications, training manuals,integrity management plans.

> The information shall be made readily available to all personnelwho design, operate and maintain the facility, and to thoseexposed on a temporary basis such as contractors working onparts of a facility that has specific hazards.

> The Facility Design Basis shall list material safety informationfor all streams, process chemicals and hazardous substanceswithin a facility.

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> Changes to the operating envelope stated in a Facility DesignBasis requires management of change.

> The equipment design record defines whether the equipmentor any components are safety critical and shall includeconditions for which the equipment has been designed alongwith key data.

> Operating Envelope Management should be implemented byplant operators through the use of process control and alarmsystems and plant operating procedures, and by engineersthrough the routine monitoring of key process parameters.

EHSMS11.2Facilities Design and Construction

Purpose

Facilities need to be designed and constructed (for new andmodified facilities) so that they can be commissioned, started upand operated in compliance with applicable legislation and with aslow as reasonably practicable risk of safety, health orenvironmental incidents.


> A documented and formal project management system shall be developed and maintained so that process safety andEHS–related risks are managed as an integral part of projectmanagement through the design, approval, procurement,construction, commissioning and handover phases.

> A project shall be designed and constructed so that newor modified facilities comply with the relevant environmentalregulations existing or reasonably anticipated where Santos

operates (see also EHSMS09.5 Environmental Impact Assessmentand Approvals).

> All projects shall follow either the Santos Quality AssetDevelopment process or the Operations Engineering andReliability Group Project Gating procedure.

> All projects shall follow either the Santos Quality AssetDevelopment process or the Operations Engineering andReliability Group Project Gating procedure.

> A project manager, a commissioning team leader and, whereappropriate, an operations representative shall be appointedfor each project.

> Appropriate hazard studies (at defined stages of projectdevelopment), an Environmental Impact Assessment (whererequired) and any other EHS studies required by the regulatoryauthorities shall be carried out during a project.

> A plant dossier shall be prepared or updated as required and handed over to the asset manager on completion of theproject.

> Facilities design and construction shall be undertaken inaccordance with relevant regulatory requirements, nationaland/or recognised International Standards, and Santos EHSMSand Engineering Standards.

> Projects which involve modifications or expansions of existingplant shall be designed and constructed to the currentrevisions of relevant engineering and community standards.

> All projects shall have a documented project managementsystem so that construction and commissioning are inaccordance with approved standards and procedures.


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> A commissioning plan shall be prepared and shall defineresponsibility for the commissioning operation.>There shall be a formal process of asset handover from theProject Team to Operations.

> Each handover process shall include the transfer of defineddocumentation such as:

>> Significant Hazard Risk Register, Safety Case or equivalent (if required)

>> Legislative Compliance Statement

>> Plant Dossier or updated Plant Dossier.

> Each handover process will also include confirmation that a pre-startup safety review has been conducted:

>> operations integrity measures are in place

>> emergency, operating and maintenance procedures areprovided

>> risk-management recommendations have been addressed

>> training of personnel has been accomplished

>> regulatory and statutory permit requirements are met.

EHSMS11.3Pre-Startup EHS Review

Purpose

Prior to the startup of new facilities, modified facilities or facilitiesthat have undergone intrusive maintenance, a pre-startupenvironment, health and safety review is conducted to ensure thatthe facility can be started up and operated safely and withoutenvironmental harm.


> A pre-startup EHS review shall be conducted and documentedprior to startup of new facilities, significantly modified facilitiesor facilities that have undergone intrusive maintenance.

> The pre-startup EHS review shall be conducted by amultidisciplined team familiar with the operating, mechanical,technical, design and EHS requirements of the facility.

> A review meeting involving all members of the pre-startup EHSreview team shall be conducted on site before startup to assesswhether the project is ready for safe startup.

> The review team shall determine whether work to date issufficient to ensure safe startup based upon review of existingdocumentary evidence (Field Installation Checklist packages,HAZOP reports, commissioning punch-lists etc.) plus their owninvestigations and site inspection of the facility as necessary.

> The review team leader is responsible for ensuring thatoutstanding actions identified in the pre-startup EHS ReviewReport are assigned, and the asset manager is accountable forensuring completion before plant startup.

> Startup of new, modified or intrusively maintained equipmentshall proceed only after a pre-startup EHS review has beencompleted and a review report has been issued, actionsidentified for completion before startup have been completed(unless exceptions have been otherwise endorsed), a pre-startup EHS clearance report has been issued and the assetmanager has approved startup.

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EHSMS11.4Structural Integrity

Purpose

Management processes are required for developing, implementingand maintaining the structural integrity of onshore and offshorestructures and equipment to ensure that they are structurally safeand meet relevant regulatory requirements.


> Integrity Management Plans (IMP) for structures shall bedeveloped as required and shall be periodically reviewed andupdated as specified in the IMP.

> The scope, method and frequency of structure inspections shallbe established either through regulation, or risk–baseddetermination of structural elements.

> Inspection plans shall identify the priority of locations to beinspected, inspection method and inspection schedule.

> An assessment to determine the Fitness for Service (FFS) maybe required during the life of a structure, for example if there achanges in the structure usage is proposed. FFS shall beundertaken by appropriately qualified, competent andexperienced personnel. FSS may use risk based criteria thatconsiders use, location and the consequences of failure.

EHSMS11.5Mechanical Integrity

Purpose

Management processes are required for developing, implementingand maintaining the mechanical integrity of onshore and offshoreassets so that the risk of failure is as low as reasonably practicable.


> Plant, equipment, pipelines and gathering systems shallundergo a periodic integrity assessment which shall bedocumented and audited.

> Mechanical integrity shall be managed in a predictive ratherthan reactive manner over the life cycle of the equipment.

> Maintenance, inspection and monitoring plans and proceduresshall be tailored to specific integrity risks and programs shallbe in place to address risks.

> Equipment and integrity management processes shall meet orexceed statutory codes, regulations and standards.

> Maintenance materials and spare parts for safety criticalequipment shall be sourced from the Original EngineeringManufacturer (OEM) and any variations shall be managedthrough EHSMS12 Management of Change.

> Equipment shall be operated within agreed, documentedparameters which shall be based on the original designpremises.

> A system shall be in place to:

>> provide an overview of the status of asset integrity

>> manage inspection and monitoring programs


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>> manage any defects identified during arising from theprograms and undertake corrective actions.

> An Asset Integrity Management System (AIMS) shall bedeveloped for each operational area or facility and shallprovide a structured framework for integrity management.

> Integrity Management Plans (IMPs) shall be developed fordefined assets. The IMP shall identify the operatingsurveillance, inspection and monitoring requirements andresponsibilities required to support integrity.

> Regular operational surveillance shall be carried out to detectdeterioration so that remedial action, if required, can be initiated at an early stage.

> Assets shall be periodically inspected and, where required,tested to support continued integrity, fitness for service and tomeet statutory requirements.

> Where corrosion monitoring and/or microbiology activitymonitoring systems are installed regular monitoring ofcorrosion rates, microbiology activity, remaining lifecalculations and periodic fitness for service assessment shallbe periodically carried out.

> The performance of the AIMS and IMPs shall be tracked by KPIreports and reported on a regular basis. The effectiveness andcompliance with AIMS and IMPs shall be established byperiodic quality assurance audits.

> Statutory requirements, inspections, maintenance, testing orrisk reviews shall be managed using a notification system.

> A Safety and Operating Plan (SAOP) shall be prepared forpipelines.

> The Plant Dossier shall be used to capture records relating to equipment manufacture, testing, repair or modification,in–service inspection, maintenance, registrations, IntegrityManagement Plans, SAOPs and operating history.

EHSMS11.6Ignition Control

Purpose

Ignition sources are a hazard at locations where explosiveatmospheres may occur so processes are required to identify and eliminate or otherwise control such sources in order to reducethe risk of a fire and/or an explosion to as low as reasonablypracticable.


> Ignition sources shall be identified and eliminated orotherwise controlled at locations where explosive atmospheresmay occur.

> Where ignition sources cannot be eliminated the hierarchy of controls shall be applied.

> Such controls shall be considered during design, and appliedduring construction, routine operation and maintenanceactivities.

> The following potential ignition sources shall be managed:

>> hot surfaces

>> flames, hot gases and sparks

>> spontaneous combustion

>> lightning

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>> workshops, welding shops, portable and temporary huts

>> vehicles

>> mechanical equipment

>> static electricity

>> frictional heat

>> fired equipment

>> combustion engines and air compressors

>> electrical equipment

>> electromagnetic, ultrasonic and optical radiation

>> thermit sparks

>> welding.

> All hazardous area certified equipment shall be maintained to keep certification valid at all times.

EHSMS11.7Critical Protection Systems

Purpose

Critical Protection Systems are a line of defence to preventmechanical or electrical integrity being compromised orenvironment, health and safety incidents escalating so processesare required for the design, assessment, construction, operation,testing, reliability and maintenance of critical protection systems innew and existing facilities.


> Critical Protection Systems (CPSs) shall be designed, installedand maintained to meet functional design intent andProbability of Failure on Demand (PFD) requirements.

> A testing program shall be implemented so that PFDrequirements can be maintained throughout the life of the asset.

> Process streams shall not be introduced to new plant beforethe critical protection systems have been proven andcommissioned.

> Persons operating, maintaining or testing CPSs shall receivesuitable training and be assessed as competent.

> Registers of CPSs shall be developed and maintained.

> Proof testing of CPSs shall be carried out according to a defined schedule.

> The integrity of CPSs shall be maintained by scheduling and carrying out appropriate routine maintenance andinspections.

> Spare parts for CPSs shall be reviewed and any parts identifiedas safety critical spares shall be managed accordingly.

> Records shall be kept by the asset manager of the observedoperation of each CPS, including any plant conditions(demands) which cause the system to be called on to operate,together with each system’s responses.

> Details of any failure to operate as designed shall be reported throughthe Incident Management Plan as a process safety exception.


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EHSMS11.8Operating Procedures and Safe Practices

Purpose

A controlled system of procedures and safe work practices isrequired to be developed and maintained to ensure the safety ofpersonnel during operational and maintenance activities, to protect the environment and the safe operation of plant and equipment.


> Critical and Standard operating procedures shall be developed,implemented and maintained to address operational activitiesthat have the potential to cause adverse impacts on the healthor safety of personnel, the environment or damage to plant orequipment.

> Procedures shall be written in a manner that is easilyunderstood by the end user and such procedures shall bereadily accessible.

> Where a critical or standard operating procedure exists,personnel shall conduct their work in strict accordance withthe procedure.

> Classification of a procedure shall be based on the potentialrisk should the procedure not be followed properly, and thecomplexity of the task.

> A Procedure Custodian shall be nominated for each operationalsite to oversee the preparation of procedures, their approvaland to facilitate appropriate revisions.

> Personnel required to carry out tasks covered by standard or

critical operating procedures shall be competent to completethe task in accordance with the procedure.

> Procedures shall undergo controlled review at defined periodsand in the event of significant changes in process orequipment.

> Sites shall develop and maintain site–related systems and workpractices to ensure the safety of personnel during operationaland maintenance activities including:

>> a Work Permit System shall be maintained for the planning,coordination, authorisation and control of specified workactivities to ensure that work is conducted safely and thatpersonnel, the environment and facilities are protected

>> there shall be a handover process to facilitate the effectivehand over of control of ongoing operations and workactivities between shifts and crew changeover to maintainEHS and business performance

>> standing orders

>> a system for determining personnel present in an operatingplant or production facility.

> Critical operating procedures and safe work practices shall beaudited annually to monitor the level of conformance with therequirements of this standard and effectiveness of training.

EHSMS11.9Maintenance

Purpose

Maintenance specific systems and procedures are required tomanage environment, health and safety risks encountered inmaintenance operational activities.


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> Santos shall develop, document and maintain a Reliability andMaintenance Management System (RAMMS) that identifiesand manages the execution of maintenance work to keepfacilities fit for purpose and meeting regulatory requirements.

> As part of the Maintenance Business Planning Process,EHS–related objectives and targets shall be established each year.

> Maintenance procedures shall be developed and maintainedfor the management of maintenance activities in relation toEHS, quality, administration, personnel, asset managementand work management.

> Job Plans shall be developed for all recurring maintenancework including corrective work, preventive maintenance workand critical function tests.

> Technical instructions shall be provided where additionaldetails associated with job plans or maintenance proceduresare required.

> Each job/work package that requires inspection and testinghold points, as detailed in Standards, Codes or Santosspecifications, shall have Inspection and Test Plans developedfor that particular work.

> A system for planning and scheduling and the management ofmaintenance work shall be implemented.

> A process and plan that identifies integrity and reliabilitymanagement requirements shall be implemented.

> Spares assessed with a level 4 risk or greater shall be flagged

as safety critical spares in the Computerised Asset ManagementSystem (CAMS) and a process for the management of thosespares shall be implemented.

> Control measures as prescribed by the Santos hierarchy ofcontrols shall be implemented for all activities and or tasksthat are assessed as having a risk level of 4 or higher.

> Employees and contractors shall only be directed or permittedto perform unsupervised maintenance tasks where they havethe skills and experience or competency to perform such tasks.

EHSMS11.10Fire Risk Management

Purpose

Processes need to be developed and maintained to ensure that fireand fire–related risks in facilities and buildings are managed.


> Each critical facility shall have a Fire Risk Management Plancommensurate with the nature of the facility.

> All other facilities and buildings have documentation of the fire control and fire protection measures and emergencyresponse procedures including compliance with regulatoryrequirements including regulations, national standards andcodes of practice and Santos EHSMS and engineering standards.

> Fire Risk Management Plans shall include or reference:

>> a listing of all hazardous materials within the boundaries ofthe plant under study, both permanent and temporary

>> a listing of known potential sources of ignition and their


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method of control

>> identification of the basic fire hazards

>> information on fire prevention, detection and protection

>> appropriate representative fire scenarios

>> details of the statutory requirements

>> arrangements for monitoring the performance of the planand the condition of process plant and fire protectionequipment

>> emergency response training requirements

>> arrangements for liaison with external emergency responseagencies

>> a fire risk management improvement action plan

>> fire risk management plans shall be reviewed at least everyfive years and be audited at least every three years.

EHSMS11.11 Decommissioning and Abandonment

Purpose

To ensure that environment, health and safety risks associated withthe decommissioning and abandonment of plant, equipment andfacilities are effectively managed.


> Prior to commencement of decommissioning or abandonmentactivities the scope of work for decommissioning orabandonment shall be developed and agreed with relevantstakeholders.

> The following issues shall be considered in the development ofthe scope:

>> health and safety of future alternative uses of the area

>> current environmental standards of the area

>> cost effectiveness of remediation measures

>> existing and future use of the area

>> extent of decontamination and remediation of underground services

>> current and potential regulatory standards and legislation

>> monitoring system to assess effectiveness of decommissioning or abandonment

>> contracts which are relevant to operating the site.

> Specific requirements in place for abandoning offshorefacilities include: obtaining approvals and a variety of permitsfrom relevant authorities and developing an abandonmentplan.

> In relation to the safety of decommissioning of plant andequipment a management of change proposal shall bedeveloped and submitted to the relevant asset manager forreview and approval.

> On completion of decommissioning, abandonment andremediation, an assessment of environmental and safetyperformance (including an assessment of any residual risk)shall be carried out by a competent person endorsed by theManager EHSS&IA.


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> Where the operation of a pipeline is suspended (non flowingcondition) for an extended period the ongoing suspensionshall be subject to a risk assessment and annual review todetermine if the pipeline should be abandoned.

> Where a pipeline is to be abandoned, an abandonment plan,including an environmental rehabilitation plan shall becompiled, reviewed and approved.

EHSMS11.12 Operated by Others

Purpose

To detail the Santos requirements for stewarding the EHSperformance of joint venture activities operated by others.


> The level of EHS stewardship applied to operators of jointventure activities shall be proportional to the significance of the EHS exposure.

> For all joint venture operations, the Santos Joint VentureManagement Representative shall monitor the EHSperformance of the Operator.

> For joint venture operations where the assessment of the EHSexposure has been determined to be significant, a two–yearlydemonstration shall be provided by the operator of their EHSsystem, their EHS risk profile and how they manage it, howthey manage key process safety related issues and theiremergency response preparedness.

> EHS expectations shall be included in the Joint Venture Agreements.

EHSMS12 Management of Change

Purpose

Processes are required to ensure that when changes are made thatenvironment, health and safety risks and other impacts of changesare identified and appropriately managed.


> All changes within Santos shall be undertaken such that:

>> impacts of changes, including EHS risks, are identified andassessed with control measures appropriately assigned,approved and complete as part of implementation

>> changes are reviewed, approved and communicated prior toimplementation

>> implementation occurs as intended

>> changes are appropriately documented

>> there is a consistent approach to the application of themanagement of change across Santos’ business.

> The Management of Change process shall include the followingsteps:

>> development

>> initiation and documentation

>> registration and tracking

>> risk assessment and nomination of required reviews

>> endorsement

>> technical or specialist and impact reviews

>> implementation plan

>> approval

>> implementation


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>> completion review

>> closeout and recording.

> When change needs to happen more quickly than mightotherwise be anticipated, such as with sudden or unplannedchange, then the change can proceed following an appropriaterisk assessment and management. The retrospective applicationof this standard shall then be applied within 48 hours of making the change.

> Key Performance Indicators (KPIs) shall be established tomonitor the effectiveness and high-level performance of theManagement of Change Standard (EHSMS12) and to drivecontinuous improvement. These KPIs shall be monitoredannually and reported against annual targets as part of theCorporate EHS Improvement Plan.

EHSMS12.1Critical Drawings and Control System Change

Purpose

To describe the requirement for the control and authorisation of changes to existing Piping and Instrument Diagrams and controlsystems.


> This standard is subsidiary to EHSMS12 Management of Changeand the change process is managed in accordance with thatstandard.

> This standard applies to all changes to Critical Drawingsincluding Piping and Instrument Diagrams (P&IDs)and otherControl System drawings:

>> adjustment of Pressure Safety Valve set pressure

>> re-ranging and re-arrangement of instrumentation

>> piping modifications or additions

>> P&ID re-drafting (for clean-up)

>> as-built drawing changes

>> change of valve tag identification

>> connection and disconnection of equipment to datarecording systems

>> changes to hazardous area classifications

>> control system logic changes

>> additions or modifications to underground services

>> change in a control valve size

>> changes typically associated with tie-ins to existing processplant.

EHSMS12.2Vacant

(This standard was incorporated into EHSMS11.8)


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EHSMS12.3Disablement of Protective Devices (Bridging)

Purpose

To ensure that the risks associated with temporarily disablingprotective devices (bridging) are adequately managed such as theongoing safety of personnel, environmental impact and theintegrity of plant and equipment.


> This standard applies to the disablement of protective deviceswhich may involve the temporary overriding, bypassing orremoval of a safety or control system to carry out abnormaloperation, extended maintenance and testing, or constructionand commissioning works.

> This standard does not apply to:

>> startup or operational overrides as identified in facilitiesoperating procedures

>> maintenance overrides, including critical function tests andtrip function tests, applied by software force, key switch ormechanical means of less than four hours applied underWork Permit to allow the testing or repair of equipment.

EHSMS12.4Substitution of Materials and Equipment Components

Purpose

To ensure the risks associated with the substitution of materials orcomponents in plant and equipment are adequately managed andthe changes meet or exceed the performance criteria of the originalplant and equipment.


> This standard applies to changes when substituting alternativematerials or components in the following situations:

>> whenever an identical replacement for a process componentcannot be sourced

>> to enable testing of alternative materials or components,either to overcome problems experienced with originalitems, or to achieve improved reliability, durability oroperability, or other perceived benefits

>> to meet the needs of changed process or operatingconditions.


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EHSMS12.5Acquisition and Divestment of Assets

Purpose

To ensure that environment, health and safety aspects of proposedacquisitions and divestments are fully understood before making adecision to acquire or divest land or assets, companies or otherentities.


> An appropriate EHS, and where relevant, process safetyassessment shall form part of any proposal for acquisition ordivestment of land, permit areas, operating plant, or any otherasset in excess of $10 million or where the potential EHS or process safety risk is assessed as level 2 or higher to ensure thatpotential liabilities have been identified and addressed.

> The EHS assessment analysis and recommendations should be included as part of the Development Committee and Board papers.

EHSMS12.6Management of Personnel Change

Purpose

To identify and manage potential environment, health and safetyrisks associated with changes to organisational structure andpersonnel, and to ensure the adequate transfer of environment,health and safety knowledge during personnel change.


> An assessment shall be conducted to identify the EHS criticalpositions within each department.

> The position description shall note that the position is EHScritical and shall include the necessary skills criteria requiredfor the successful performance of the assigned EHSresponsibilities and accountabilities of that position.

> Categorisation of personnel as EHS critical positions shall besubject to their ability to meet or achieve:

>> the skill, experience and competence criteria as detailed inthe relevant position description

>> relevant regulatory or licensing requirements

>> verification of credentials, appropriate security clearanceand medical screening including drug and alcohol testing.

> The incumbent in an EHS critical position shall ensure that theirreplacement during temporary coverage is equipped to manageEHS requirements of the position during the period of coverage.

> A documented handover process shall be initiated by the incumbentin the EHS critical position to ensure that all EHS requirements forthe incoming employee are understood and effective.


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EHSMS13Emergency Preparedness

Purpose

To ensure that relevant equipment and resources are available andpersonnel are able to effectively respond to any foreseeableemergencies so as to minimise any adverse impact on the safety orhealth of people or the environment.


> Document controlled Emergency Response Plans (ERPs) shallbe developed and maintained for Santos operating sites orpremises and relevant functions to aid in the effective responseto foreseeable emergency scenarios.

> The relevant site and activity Significant Hazard Risk Register(SHRR) shall be used to assist with the validation of the scopeof emergency scenarios covered in the ERP.

> Emergency and incident response plans shall be reviewedannually to validate the adequacy of scope (emergencyscenarios), currency and adequacy of content. In addition,relevant plans shall be reviewed, where improvementopportunities have been identified by post–emergency andincident exercise debriefs.

> A document–controlled Santos Incident Management Plan (SIMP)shall be prepared, distributed and maintained by the managerEHSS&IA to provide additional support and resources in theevent that an emergency is beyond the capabilities of a site.

> Where a contractor will manage an emergency situation at aSantos asset the contractor shall provide an emergency responsebridging document to ensure an effective and coordinated emergency response including when and how the

SIMP shall be activated.

> All operating sites, premises and relevant functions shallprepare and maintain an emergency operations centre (EOC)and identify an alternative site should the EOC be affected bythe emergency.

> Emergency key contact lists shall be developed and regularlymaintained.

> At sites classified as a Major Hazard Facility, the ERP shallincorporate relevant emergency regulatory requirements.

> Personnel shall be competent in their roles defined inEmergency and Incident Response Plans.

> Emergency exercises shall be conducted regularly to test theeffectiveness of plans, competency of personnel and resources.

> Processing facilities shall maintain a system that enables timelyidentification of personnel who are in the facility and who arenot accounted for following an emergency evacuation of thefacility.

> A risk management process shall be used to determine thetype, quantity and location of emergency equipment requiredfor an operational site.

> A review as to the ongoing adequacy of emergency equipmentshall be conducted at operational sites every five years.

> Emergency equipment shall be readily accessible from thesource of the hazard and have appropriate signage and lighting.

> An emergency power supply shall be provided for criticalequipment required in the event of an emergency and toinstrumentation and control systems necessary for safe shut-down of plant.


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EHSMS13.1First-Aid and Medical Facilities

Purpose

To define the requirements for first aid, the provision of first–aidfacilities and the availability of qualified first–aid personnel toensure effective treatment of employees, visitors and contractors.


> All Santos workplaces shall have appropriate first–aid facilitiesreadily available for use which as a minimum shall meetrelevant regulatory requirements.

> The scope of first–aid facilities at a workplace shall be based ona risk assessment which shall consider the:

>> nature of the work

>> size and layout of the workplace

>> location of the workplace

>> number and distribution of workers.

> Sufficient numbers of suitably trained first–aid personnel shallbe available to workers on all shifts consistent with theoutcome of the risk assessment and relevant legislation.

> Sufficient numbers of appropriately stocked and maintainedfirst–aid kits shall be provided at each workplace consistentwith the findings of the risk assessment.

> All Santos field vehicles shall be fitted with a first–aid kit.

> Where paracetamol is kept in first–aid kits, personnel whoneed to take such medication shall self–dispense.

EHSMS14

Monitoring, Measurement and Reporting

Purpose

Collection, analysis and reporting of environment, health andsafety performance data is necessary to establish whether risksassociated with Santos’ operations are being managed, minimisedand where reasonably practicable, eliminated.


> EHS monitoring programs shall be established and maintainedto regularly measure key aspects of Santos’ activities that canhave a significant EHS impact.

> Monitoring programs shall include both direct monitoring of EHS impacts from business activity and monitoring of theEHS management system.

> Personal health monitoring shall be conducted and recordskept where appropriate such as when identified by a riskassessment or when required by legislation.

> EHS monitoring equipment shall be regularly calibrated and maintained to manufacturer’s specifications and recordsretained for five years.

> Each month, EHS data relating to key performance indicatorsshall be collected and collated for relevant functions,departments and work activity, and consolidated for the wholeCompany.


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> To ensure appropriate stakeholders are adequately informed ofrelevant EHS performance a range of EHS reports shall beprepared including:

>> Board reports

>> annual Sustainability Report

>> management reports

>> industry (for example, APPEA) reports

>> statutory reports

>> annual public report.

> EHS data shall be analysed at least annually to identify issuesand areas requiring improvement.

> The manager EHSS&IA shall ensure that EHS reports are readilyaccessible on “The Well”.

EHSMS15Incident and Non-Conformance Investigation,

Corrective and Preventive Action

Purpose

Reporting, investigation and management of corrective actionsassociated with incidents is required to identify the underlyingsystem failures and implement appropriate corrective actions toprevent a recurrence.


> Unwanted events including EHS and process safety incidents,hazards, near misses, property damage, non-conformanceevents and third party complaints shall be managed by usingthe Santos Incident Management System (IMS).

> Employees shall be trained in the use of IMS.

> The normal sequence of events following an incident or nearmiss shall be as follows:

>> immediate control of any hazards and impacts (such asinjuries)

>> report the incident to line management

>> report the incident to authorities (where required)

>> notify other personnel using an IMS notification

>> conduct an appropriate investigation (basic or TapRootinvestigation or equivalent shall be conducted to identify theroot causes)

>> assign recommended actions using IMS

>> ensure agreed actions are completed and update IMS

>> ensure the risk has been reduced to an acceptable level


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>> where relevant update the site Significant Hazard Risk Register

>> share relevant learnings arising from the incident withothers

>> add key learning from process safety incidents or nearmisses to the relevant Plant Dossiers.

> An annual assessment shall be conducted to determine thelevel of conformance with the close out of actions assigned inthe IMS.

> Incidents or near misses subject to a TapRoot shall be reviewedby the relevant Management Committee to assess the quality ofprocess and ensure that findings have been adequatelyaddressed.

EHSMS15.1Injury Management

Purpose

To ensure that there is an effective and equitable injurymanagement system in place for employees who sustain a workrelated injury or illness.


> Not all injured employees will be required to enter into aformalised rehabilitation program or rehabilitation andreturn–to–work plan. The majority of those injured at work willbe restored to full health through normal medical services.

> In the following situations, rehabilitation will be discussed anda rehabilitation program or rehabilitation and return–to–workplan developed:

>> if an employee requests

>> if a medical expert requests

>> where there is any restriction preventing an employee fromperforming normal duties.

> Rehabilitation programs and rehabilitation andreturn–to–work plans will, in general, seek to achieve thereturn to full employment of the employee as soon aspracticable following a work-related injury or illness.

> Should the employee or the supervisor have any issue at anystage of the Rehabilitation/Return–to–Work Plan, theRehabilitation Officer is to be notified immediately andappropriate action will be taken.


> Santos

> MANAGEMENT STANDARDSEHSMS16

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EHSMS16Management System Audit and Assessment

Purpose

Audit and assessment ensures that Environment, Health and SafetyManagement System have been effectively implemented and arebeing complied with, and that the system meets legislativerequirements and defined EHS objectives and targets.


> Relevant Santos functions and sites shall participate in the EHSaudit and assessment program which includes:

>> Assessments of EHSMS implementation:

>>> An annual assessment shall be conducted at definedSantos sites and for selected departments todetermine the implementation status of EHSMSStandards.

>>> An assessment report shall be prepared and providedto each participating site/department and theresponsible line manager.

>>> The assessment reports shall be used when developingthe following year’s site/department EHS ProcessSafety Improvement Plan.

>> Internal EHSMS audits:

>>> An internal EHS and Process Safety audit planprioritised on risk shall be developed and administeredby Corporate EHSS&IA to provide verification ofconformance and effectiveness with the EHSMSStandards.

>>> Audits should be conducted by independent auditors.

>> Statutory compliance audits shall be conducted to determine the status of statutory compliance.

>> EHSMS self-audits:

>>> Functions or Departments are encouraged to self–audit their conformance with the EHSMS using a risk-based approach.

>> EHSMS audits of contractors and non-operated jointventures.

>> Other specialised audits such as issue-specific audits:

>>> In the event of a serious incident, non-compliance or other valid reason an unscheduled audit may beinitiated.

> All audits and assessments shall be scheduled, recorded andmanaged using the Santos Audit and Inspection Manager (AIM).

> Appropriate personnel shall be trained in the use of AIM.

> Audits and assessments shall be conducted in accordance withdetailed in the standard.


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EHSMS17Management Review

Purpose

Periodic reviews of the overall effectiveness of the EHSMS by seniormanagement ensures continual improvement, suitability andeffectiveness.


> Personnel shall advise the manager EHSS&IA, either directly orthrough their supervisor, of any suggestions to improve thesystem. Feedback shall be provided to personnel makingsuggestions.

> An informal review of the effectiveness of the EHSMS shall beconducted at Operations Leadership Committee or similarmeetings.

> A formal review of the EHSMS shall be conducted annually byan appropriate senior management team and the resultscommunicated.

> The formal annual review shall be documented includingobservations, conclusions, recommendations, actions andfollow-up requirements. An action register shall be used tomanage the effective close-out of actions.

EHSMS18

Sustainability

Purpose

To provide guidance on the integration of the principles ofsustainability at Santos, to enhance business and planning throughthe consideration of a comprehensive suite of sustainabilityindicators beyond traditional financial measures.


> All Santos employees and contractors shall ensure that dailyduties are undertaken in a sustainable manner.

> Santos' sustainability performance shall be assessed annuallyusing the sustainability scorecard.

> The Sustainability Framework is designed to be integrated bythe twenty-four sustainability indicator custodians and theirspecialist teams. Sustainability Handbooks have beendeveloped to assist in this process: including data collectionprocesses, key custodian responsibilities, data collectiontemplates, and verification processes.

> Indicator custodians shall establish annual performancetargets.

> Santos' sustainability performance shall be communicatedthrough:

>> The Well

>> Printed reports, such as the annual Sustainability Report

>> Regular meetings with the EHS&S Committee of the Boardand relevant staff members

> The Sustainability Framework shall be reviewed on an annualbasis and updated if required.


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HAZARD STANDARDS

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Health and Safety Hazard Standards

HSHS01 Hand Safety 39

HSHS02 Land Transportation 39

HSHS03 Air Transportation 40

HSHS04 Health and Wellbeing 41

HSHS05 Working in Hot Environments 42

HSHS06 Electrical Safety 43

HSHS07 Working at Heights 44

HSHS08 Chemical Management and 45Dangerous Goods

08.1 Asbestos 46

08.2 Synthetic Mineral Fibres 46

08.3 Benzene 47

08.4 Mercury 47

08.5 Vanadium 48

08.6 Nitrogen 48

08.7 Hydrogen Sulphide 49

HSHS09 Radiation 50

HSHS10 Food Safety 51

HSHS11 Manual Handling and Ergonomics 52

HSHS12 Occupational Noise 52

HSHS13 Working Alone in Remote Locations 53

HSHS14 Legionella 54

HSHS15 Personnel Security 54

HSHS16 Lifting Equipment 55

HSHS17 Personal Protective Equipment 56

HSHS18 Entry to Confined Spaces 57

HSHS19 Excavations 57

Environment Hazard Standards

EHS01 Land Disturbance 58

EHS02 Underground Storage Tanks and Bunds 58

EHS03 Produced Water Management 60

EHS04 Waste Management 62

EHS05 Air Emissions 63

EHS06 Greenhouse Gas Management 64

EHS07 Energy Efficiency 65

EHS08 Contaminated Site Management 66

EHS09 Weed and Pest Animal Control 67

EHS10 Water Resource Management 67

EHS11 Aboriginal Cultural Heritage Management 68(for Australian Operations)

EHS12 Noise Emissions 69

Hazard standards define the requirements for managing the specific risks posed by a hazard.

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HEALTH AND SAFETY HAZARD STANDARDS

HSHS01Hand Safety

Purpose

The purpose of this standard is to detail the requirements to reducethe risk of hand injury.


> Work activities with potential for hand injury shall be assessedin accordance with EHSMS09.1 Job Hazard Analysis andStepback, and by applying the Hierarchy of Control.

> Priority shall be given to engineering out any potential handinjury hazards when designing new plant and equipment.

> Where hand injuries have occurred, attention shall be givenduring the incident investigation process to identify ways inwhich the hazard can be engineered out.

> Hand protection shall be worn by personnel where they may beexposed to hand safety hazards.

> Personnel deployed to field environments shall receiveongoing Santos-endorsed hand safety training.

> Additional awareness sessions should be conductedperiodically during safety meetings, toolbox meetings,job–start meetings and prior to commencing tasks that pose aparticular hand safety risk.

HSHS02Land Transportation

Purpose

To manage the risks associated with land transportation activities.


> All personnel driving vehicles for, or on behalf of, Santos musthold an appropriate current drivers licence.

> Personnel who drive light vehicles on field roads must haveundergone training and hold a current competency certificate.

> Santos sites and contractors shall develop and maintain ajourney management plan which shall include a search andrescue plan.

> When driving, all state and territory road rules shall apply withmaximum speeds of 110 kilometres per hour (or 100 kilometresper hour where signs posted) on sealed roads and 80 kilometresper hour on unsealed roads.

> Additional rules must be followed when driving on field roadssuch as not driving through dust clouds, fitment of dune poles,rollover protection, lights on when driving.

> Detailed controls set out in the standard shall be followedwhen changing wheels and tyres in particular when dealingwith split rims.

> Vehicle recovery procedures shall be developed at sites.

> Vehicles shall be maintained to manufacturer’s specificationsand pre-start and regular inspections shall be carried out.

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> Detailed controls for heavy vehicles shall be followed such asuse of log books, and observing limitations on carrying liquidsin non–baffled tankers.

> Quad bikes to only be used in limited and approved situations.

> Vehicle incidents must be reported and undergo appropriateinvestigation.

HSHS03Air Transportation

Purpose

To manage the risks associated with air transportation activities.


> Aviation activities shall be conducted with aircraft operatorsand aircraft types to standards as detailed in this standard.

> In situations where air travel is required and where operatorscannot meet standards then a risk assessment is requiredwhich must be approved by the relevant Vice President.

> Specialist aviation advisers shall be used in the selection and ongoing auditing of aircraft operators.

> Santos personnel shall not travel in non-Santos charteredflights unless they meet defined requirements.

> Santos personnel can travel in single–engine planes providedthey meet defined requirements.

> Aeroplanes with nine or fewer passenger seats may be flownwith one pilot provided they meet defined requirements.

> Limitations apply to the number and type of staff travelling inthe same plane.

> Hazardous substances can only be carried in accordance withInternational Air Transport Association regulations.

> Fatigue must be considered in driving to or from airports.

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> International air travel shall be carried out in accordance withdefined requirements including immunisations, securityarrangements and emergency evacuation.

> Personnel shall complete Helicopter Underwater EvacuationTraining (HUET) training before flying to offshore facilities.

> Suitable ground support facilities, services and procedures asdefined shall be provided to ensure the safety of personnel.

> Suitable facilities, services and procedures as defined shall beprovided to ensure the safety of personnel where are aircharters are used to support offshore operations.

HSHS04Health and Wellbeing

Purpose

To create an environment where personnel are motivated tomaintain a healthy lifestyle and to manage the risks associatedwith personnel who are not fit for work.


> Personnel are responsible for maintaining their fitness for work.

> Education and awareness programs shall be provided to enablepersonnel to understand and manage their own health andfitness for work.

> Employees shall be provided with access to fitness assessmentsand fitness programs.

> An Employee Assistance Program (EAP) shall be provided toprovide employees access to professional assistance ortreatment to maintain or recover their fitness for work.

> Health assessments shall be provided to encourage employeesto achieve or maintain a fit and healthy lifestyle.

> Contractors are responsible for ensuring they have programs inplace to maintain the health and fitness for work of theiremployees.

> Drug and alcohol testing shall be conducted to monitor theeffectiveness of the proactive fitness for work measures.

> Employees who return a positive drug or alcohol test shall, ingeneral, be supported in modifying their behaviour with theaim of returning them to their job.


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> Santos has a zero tolerance to the sale, possession or use ofillegal drugs on Santos premises, and personnel can expect tobe dismissed if found to have broken this rule.

> Personnel shall advise their supervisor or appropriate medicalpersonnel of any medication being used which may affect theirsafety or performance at work.

> At sites where alcohol is available, procedures shall bedeveloped to encourage responsible consumption.

> Protocols must be followed at authorised functions wherealcohol is consumed.

> All personnel shall be subject to random, pre–employment,for–cause and post–incident alcohol and drug testing.

> Disciplinary action shall apply to personnel who return aconfirmed positive alcohol or drug test.

> Case Management Plans shall be developed for those seekingassistance in returning to work after being found unfit forwork.

> A drug and alcohol review committee shall monitor theeffectiveness of the testing program.

> A comprehensive fatigue management program shall bedeveloped based on employer and employee responsibilities.

> Where food is provided at Santos sites, a range of healthy foodoptions shall be provided.

> Santos shall support personnel who wish to quit smoking.

HSHS05Working in Hot Environments

Purpose

To manage the risks associated with personnel working in hotenvironments.


> In hot environments the risk of heat stress shall be consideredwhen conducting Stepback (as defined) and when developingJob Hazard Analysis (JHA) and operating procedures.

> Heat risk control measures shall include heat acclimatisation,work planning, provision of adequate cool drinking water andother control measures as deemed necessary.

> Heat risk control measures shall, where relevant, be includedin JHAs and operating procedures.

> The risk of heat stress shall be considered when planning forconfined space entry and controls shall be included in the riskassessment and appropriate controls listed on the work permit.

> Personnel shall undergo competency based heat stressawareness training, where relevant, prior to conducting workin field environments.

> Additional awareness training shall be provided to personnelduring high–risk periods of the year.

> Records of heat awareness training shall be kept and madeavailable when requested.

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HSHS06Electrical Safety

Purpose

To manage the risks associated with personnel working on or in thevicinity of electrical equipment.


> Personnel shall be aware of the relevant standards,regulations, procedures, hazards and safety requirements priorto working on, or in, the immediate vicinity of electricalsystems.

> A Hazardous Area Management System shall be developed forSantos facilities to minimise the risk of electrical and relatedwork from igniting potentially explosive atmospheres.

> Earthing, static and lightning protection systems shall beinstalled, tested and inspected in compliance with relevantstandards.

> High voltage regulations shall be developed to manage therisks associated with work on high voltage equipment.

> Work on electrical equipment should be carried out after it hasbeen de-energised and isolated. Where this is not possible suchwork shall only be undertaken by personnel accredited in ‘live’techniques and authorised by the site electrical supervisorfollowing a risk assessment.

> Work on high voltage generation equipment shall only becarried out by personnel competent in high voltage equipmentin accordance with high voltage regulations.

> Temporary electrical equipment shall be installed andmaintained in full compliance with all relevant regulations andstandards.

> A site electrical register of all portable electrical equipmentrequiring inspection and testing shall be maintained.Following testing of such electrical equipment a compliancetag shall be fitted.

> Personnel shall be aware of relevant standards, regulations,procedures, hazards and safety requirements prior to workingon, or in, the immediate vicinity of electrical systems.

> Electrical equipment without a compliance tag shall bewithdrawn from service.

> All mains–powered portable electrical equipment shall, whenconnected by a socket outlet, be protected by a residualcurrent device.

> All electrical work on a Santos site shall be carried out byappropriately competent, qualified personnel.

> All relevant electrical data shall be managed using theTechnical Information Management System.


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HSHS07Working at Heights

Purpose

To manage the risks associated with personnel when working atheights and the risks from objects falling.


> Where work is carried out where a person could fall two or more metres then appropriate controls shall be used to prevent people or objects from falling.

> Prior to working at heights a Job Hazard Analysis (JHA) may berequired.

> Personnel working at heights shall be competent in the use ofthe fall prevention systems and equipment.

> Specified requirements shall be followed to manage the risk ofpersonnel and objects falling.

> Specified requirements shall be followed when conductingroutine and non–routine work on tanks, towers and vessels.

> Work conducted inside vessels shall be treated as non-routineand a JHA shall be conducted.

> Work involving pipe racks as platforms or access ways shall betreated as non-routine and a JHA shall be conducted andspecified requirements shall be followed.

> Work conducted on roofs shall be treated as non-routine, a JHA shall be conducted and specified requirements shall be followed.

> Specified requirements shall be followed for work on fragile roofs.

> Fixed scaffold shall be used when deemed appropriate andlonger term work is anticipated.

> Scaffolders shall hold the relevant certificate of competencyfor the class of scaffold being used.

> Scaffolding shall be conducted in compliance with specifiedrequirements including erection, usage, inspections anddismantling.

> Ladders shall be inspected, used and maintained in accordancewith specified requirements.

> Elevated work platforms shall only be operated by personnelwith a relevant certificate of competency.

> Elevated work platforms shall be inspected, used andmaintained in accordance with specified requirements.

> Workboxes shall be used and maintained in accordance withspecified requirements.

> Fall arrest and fall prevention systems shall be used andmaintained in accordance with specified requirements.


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HSHS08Chemical Management and Dangerous Goods

Purpose

To manage the risks associated with the handling, use and storageof chemicals.


> Santos as a producer of chemicals shall prepare, maintain anddistribute Material Substance Data Sheets (MSDS) for thosesubstances which are assessed as a hazardous substance ordangerous good.

> Santos as a producer of hazardous substances and dangerousgoods shall ensure that they are appropriately contained,packaged and labelled as per regulatory requirements.

> Prior to the purchase of a new hazardous substance ordangerous good a risk assessment shall be conducted (utilisingthe MSDS) and documented by the potential user and this shallbe signed by their manager and then forwarded to the managerEHSS&IA for review and approval.

> On approval of a new hazardous substance or dangerous goodthe MSDS shall be added to Chemwatch and the respective sitemanifest, the MSDS and risk assessment added to therespective site register and relevant Standard OperatingProcedures shall be updated with the required controls.

> A risk assessment shall be conducted on the use of allhazardous substances and dangerous goods and these shall berecorded in the respective site chemical registers and relevantStandard Operating Procedures shall be updated with therequired controls.

> A Chemical Management Coordinator shall be appointed foreach site to fulfil the defined responsibilities.

> Copies of hazardous substance or dangerous goods MSDS andthe risk assessments shall be readily available to employees.

> A site chemical register shall be developed and maintainedwhich shall include a hard copy of the MSDS for all chemicalson site, the identification of hazardous substances anddangerous goods and a hard copy of all associated riskassessments.

> All employees who handle or use chemical substances shallreceive training in understanding and use of material safetydata sheets, including hazards and risk control measures.

> Contractors shall supply MSDSs and risk assessments for allhazardous substances or dangerous goods to the respective sitechemical co-ordinator prior to bringing the substances on site.

> Health surveillance and/or bio-monitoring shall be conductedfor personnel exposed to hazardous substances that may causeserious health effects.

> Records of hazardous substances, with their risk assessed assignificant, and associated monitoring data, shall be stored for40 years.

> Dangerous goods shall be stored and placarded as per detailedand relevant regulatory requirements.

> Dangerous goods shall be transported and stored in a mannerthat prevents the interaction of incompatible goods.

> Controls shall be developed to contain and clean up anyspillage of a dangerous substance.

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> All plant and equipment that may be contaminated with ahazardous substance or dangerous good shall be cleaned as faras practicable before it is sent off site or disposed of.

> A manifest of dangerous goods shall be developed andmaintained at each site as per relevant regulatoryrequirements.

HSHS08.1Asbestos

Purpose

To manage the risks associated with occupational exposure toasbestos.


> The asset manager shall ensure that a systematic assessment isconducted to identify the presence or otherwise of asbestosmaterials at sites under their control.

> At sites where asbestos has been found a person shall beappointed to ensure that the requirements of this standard,relevant to the site, are met.

> An asbestos file shall be maintained at sites where asbestoshas been identified.

> The Asbestos Register shall be readily available to employeesand contractors.

> All asbestos materials shall be suitably labelled.

> Asbestos material detailed in Asbestos Registers shall beinspected annually.

> Personnel working with or using items containing asbestosshall be provided with suitable training.

> The removal and disposal of asbestos materials shall only beconducted by a suitably approved licensed contractor.

> New plant and equipment shall not contain asbestos–basedmaterials.

HSHS08.2Synthetic Mineral Fibres

Purpose

To manage the risks associated with occupational exposure to Synthetic Mineral Fibres.


> The use of Synthetic Mineral Fibres (SMFs) shall be minimised.

> Work involving SMFs materials shall be in accordance with the National Occupational Health and Safety Commission Code ofPractice for the Safe use of Synthetic Mineral Fibres orequivalent.

> With new products, modifications or installations requiring theuse of SMFs, preference shall be given to glass, mineral or rockwool over ceramic fibre.

> All work associated with SMFs must be subject to workplacehazardous substances risk assessments.

> Personnel working with SMFs shall, prior to work beingconducted, be provided with suitable training.

> Where monitoring of SMFs exposure is conducted, records ofthe findings shall be kept.


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HSHS08.3Benzene

Purpose

To manage the risks associated with occupational exposure tobenzene.


> The status of risk posed by benzene shall be determined atsites by the use of atmospheric monitoring in locations wherebenzene vapour could potentially exist.

> At sites where a benzene risk has been established, the plantmanager or superintendent shall maintain a documentedassessment of their site.

> At sites where a benzene risk has been established, the plantmanager or superintendent shall maintain a plan to managebenzene exposure, with the objective of having no exposurelevels above the current NOHSC occupational atmosphericexposure standard or equivalent for benzene.

> A benzene monitoring program shall be developed andmaintained at locations where a benzene risk has been identified.

> An area where there has been an elevated benzene risk foundshall be demarcated by appropriate warning signs.

> Records of personal, area and biological monitoring shall be kept.

> All personnel who may be exposed to benzene shall receivebasic training at the task or job (level 3) induction or jobtransfer in the relevant occupational hygiene principles,applicable exposure limits and the relevant control measures.

HSHS08.4Mercury

Purpose

To manage the risks associated with occupational exposure tomercury.


> Testing shall be conducted on all new wells to determine thepresence or otherwise of mercury.

> The site mercury risk level shall be determined by monitoringand assessment.

> Each site with a mercury risk shall have a current MercuryManagement Plan to manage mercury exposure.

> A risk assessment shall be conducted for each operation,maintenance or inspection activity where personnel have the potential to be exposed to mercury.

> The preventive and mitigation controls developed from the risk assessment shall be integrated into relevant standardoperating procedures and/or relevant JHAs.

> A mercury monitoring program shall be developed andmaintained at locations where mercury contamination hasbeen confirmed.

> Special precautions shall be taken when conducting any type ofheating operation where mercury may be present.

> Areas where mercury has been found shall be demarcated by signs.


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> Special precautions shall be taken when conducting work in confined spaces where mercury could be present.

> Pregnant or breast feeding personnel shall not work in a mercury risk job.

> A bio-monitoring program shall be established for personnelroutinely exposed to mercury or for personnel potentiallyexposed to elevated levels.

> Personnel who may be exposed to mercury shall receive basictraining in relevant occupational hygiene principles andcontrol measures at the level 3 induction and refresher trainingas necessary.

HSHS08.5Vanadium

Purpose

To manage the risks associated with occupational exposure tovanadium.


> A risk assessment shall be conducted and recorded for all workactivities where personnel may be exposed to the substance.

> The risk control measures identified by the risk assessmentsshall be incorporated into relevant Standing OperatingProcedures and Job Hazard Analysis.

> Personnel who may be exposed to vanadium shall receivetraining at the task and job (level 3) induction or job transferin the relevant occupational hygiene principles, applicableexposure limits and the relevant control measures.

HSHS08.6Nitrogen

Purpose

To manage the risks associated with occupational exposure tonitrogen.


> A risk assessment shall be conducted for each operation,maintenance or inspection activity where personnel have the potential to be exposed to potentially hazardous levels of nitrogen.

> Risk controls identified by the risk assessment shall beincorporated into relevant standard operating procedures or Job Hazard Analysis.

> Entry into an oxygen deficient or inert atmosphere shall not bepermitted unless written approval has been obtained from theasset manager.

> Personnel shall not work in an atmosphere where the oxygenlevel is below 19.5% unless they are wearing and arecompetent in the use of appropriate air supplied breathingapparatus.

> A restricted area shall be established around areas wherenitrogen is being used and atmospheric testing shall beperformed to identify the extent and boundaries of therestricted area.

> Permanent or temporary nitrogen connections to processequipment shall be disconnected or blinded when not in use.


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> Warning signs shall be placed at all access points to areaswhere nitrogen is used.

> Personnel should protect themselves from accidental contactwith liquid nitrogen, and where nitrogen is vaporising, andwhere vaporising equipment is in use.

> All personnel who may be exposed to nitrogen shall receivetraining at level 3 induction or job transfer in the hazards of nitrogen.

HSHS08.7Hydrogen Sulphide

Purpose

To manage the risks associated with occupational exposure to hydrogen sulphide.


> A risk assessment shall be conducted and recorded for all workactivities where personnel may be exposed to hydrogensulphide.

> The risk assessment shall consider both health and safetyhazards due to the toxic and flammable characteristics ofhydrogen sulphide.

> The risk control measures identified by risk assessment shall beincorporated into relevant Standard Operating Procedures andJob Hazard Analysis.

> Hydrogen sulphide is also produced by the anaerobic decay oforganic matter such as sewage or oil. Since it is heavier thanair it can reach high concentrations in poorly ventilatedspaces, depressions and wells – risk assessments shall considerthese issues.

> Where there is the potential for hydrogen sulphide to bepresent where work is to be conducted, air monitoring shall beconducted prior to the commencement of the work.

> Where there is the potential for exposure and respiratoryprotection is not in use, personal hydrogen sulphide warningdevices shall be worn or the atmosphere shall be monitored bycompetent personnel.


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> All personnel who may be exposed to hydrogen sulphide shallreceive basic training at the task or job induction or jobtransfer in the relevant occupational hygiene principles,applicable exposure limits and the relevant control measures.

HSHS09Radiation

Purpose

To minimise the risks associated with the handling, use and storage of radioactive substances or use of irradiatingequipment.


> The use or storage of radioactive substances on Santos sitesshall be carried out in accordance with applicable regulations.

> Where contractors use radioactive substances, Santos shallensure that the contractors are in compliance with applicableregulations.

> Santos shall appoint a Radiation Safety Officer (RSO) toprovide sites with guidance on matters in relation toradioactive substances.

> At sites where Santos has radioactive substances or wherecontractors regularly use radioactive substances, a site RSOshall be appointed.

> All new uses of radioactive substances shall be assessed and subject to a documented risk assessment which shall be approved by the Santos RSO and the respective assetmanager.

> Radioactive substances shall be stored, used, handled andtransported in accordance with applicable regulations.


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> Radioactive substances shall be stored in a locked steelcontainer with suitable radiation warning placards andemergency contact numbers.

> Radioactive substances shall be transported in a lockable steelrestraint container with radiation warning placards fitted tothe vehicle.

> Radiation waste and disposal procedures, in accordance withapplicable regulations, shall be included in the RadiationSafety Manual.

> A radiation emergency response plan shall be included in the Radiation Safety Manual.

HSHS10Food Safety

Purpose

To minimise the risk of detrimental health effects from foodsupplied by Santos.


> Remote site catering operations and remote site contractorcatering operations shall be conducted in accordance withrespective food safety plans based on a Hazard Analysis andCritical Control Points (HACCP) process.

> At remote sites where Santos provides the catering, the campmanager is responsible for meeting the requirements of thefood safety plan.

> At remote sites where a contractor provides the catering, the Contractor’s senior site representative is responsible formeeting the requirements of the food safety plan.

> Office catering shall be conducted in accordance with definedrequirements.


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HSHS11Manual Handling and Ergonomics

Purpose

To minimise the risk of injury associated with manual handlingtasks and poor ergonomics.


> Manual handling hazards shall be considered as part of thedesign of new or modified plant and equipment.

> Manual handling hazards shall be considered as part of thedevelopment of standard operating procedures and daily workplanning processes such as Job Hazard Analysis and Stepback.

> A manual handling task assessment shall be conducted where aStandard Operating Procedure or Job Hazard Analysis does notadequately manage the risk of manual handling.

> An ergonomic risk assessment shall be conducted when anemployee relocates to a new work station or where concerns orproblems arise from the layout of an existing workstation.

> Employees shall receive relevant training in manual handlingand ergonomics.

> Contractors shall establish comparable risk control measuresfor manual handling and ergonomic related hazards.

HSHS12Occupational Noise

Purpose

To minimise the risk of noise–induced hearing loss associated withexposure to excessive occupational noise.


> Controls shall be effectively implemented to ensure personnelare not exposed to noise exceeding statutory limits.

> An assessment of noise exposure shall be conducted during thedesign of or modification to plant, prior to purchase of newequipment and at existing facilities where levels may be excessive.

> Results of noise assessments shall be available to employeesand records shall be kept for 30 years.

> Where a noise assessment shows that personnel will beexposed to excessive noise, a risk assessment shall beconducted and controls identified to ensure that personnel areexposed to levels at or below statutory levels.

> Hearing protection devices (HPDs) shall be supplied and usedwhere higher order risk control measures are not reasonablypracticable.

> Signage shall be erected to identify areas of excessive noisewhere the wearing of HPDs is required.

> Training shall be provided to personnel who may be exposed toexcessive occupational noise.


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> Audiometric testing shall be provided to employees who maybe exposed to excessive occupational noise.

> Results of audiometric testing shall be provided to employeesand aggregated results shall be reviewed to assess theadequacy of existing control measures.

HSHS13Working Alone in Remote Locations

Purpose

To minimise the risk to personnel when working alone in remotelocations or when working alone in areas for extended periods oftime where a significant hazard exists.


> Where lone or isolated work is required a documented riskassessment shall be conducted to identify the hazards andcontrols required to manage the risk.

> The results of the risk assessment shall form the basis of a JobHazard Analysis, or for routine tasks, a standard operatingprocedure.

> An isolated worker shall have ready access to first–aidequipment.

> Monitoring and communication protocols shall be included inthe risk assessment which shall include defined requirementsand redundancy where communication is reliant on a radio orphone fixed in a vehicle.

> Where isolated work is required, a search and rescue plan shallbe developed, relevant personnel trained in the requirementsof the plan and copies of the plan shall be kept in vehicles usedby isolated workers.


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HSHS14 Legionella

Purpose

To minimise the risk of personnel contracting Legionnaires disease.


> Each site shall identify and document the presence orotherwise of cooling tower systems.

> Where cooling tower systems are present a documented riskassessment shall be conducted, including specific assessmentsof all risk factors, for each cooling tower system on the site.

> A documented risk management plan shall be developed andimplemented for each cooling tower system based on the riskassessment.

> The risk management plans shall include inspection,maintenance and audit programs and the controlled copy shallbe kept in the relevant Plant Dossier.

> Should there be a high Heterotrophic Colony Count (HCC)result or if Legionella is detected key stakeholders shall beadvised as soon as practicable of the result and actions thatwill be taken.

> New cooling towers shall be constructed and installed to meet relevant regulatory and community standards (in Australia AS/NZS3666).

HSHS15 Personnel Security

Purpose

To manage the security of personnel to ensure their safety, and forthe protection of assets.


> Each facility shall undergo a security risk assessment withconsideration of defined scenarios every two years.

> A site security manual shall be prepared for each facilityclassified as critical.

> Basic defined safeguards shall be included in site securitymanuals.

> Defined security considerations shall be included in the designprocess for operational facilities.

> Security breaches, concerns and incidents shall be recorded.


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> HAZARD STANDARDSHSHS16 | HSH17

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HSHS16 Lifting Equipment and Operations

Purpose

To ensure the safety of personnel during lifting operations.


> The management of lifting operations, including planning,sitting, erection, dismantling, operation, maintenance,inspection and repair of cranes and other lifting equipment,registration of plant, and certification of equipment users andoperators shall be in accordance with the requirements ofrelevant regulations and applicable standards.

> Offshore lifting equipment specifications and activities shall becarried out in accordance with specific requirements due todynamic loading requiring increased safety factors.

> Operators of lifting equipment and riggers shall have relevantcertificates of competency.

> A site register of lifting–related certificates of competencyshall be maintained.

> A system shall be in place to manage defined aspects of liftingoperations.

> Contractors conducting lifting operations shall meet therequirements of this standard.

> An assessment shall be conducted by competent personnelprior to the procurement, hire or use of modified liftingequipment to ensure fitness for purpose and compliance withrelevant regulatory requirements.

> An inspection shall be conducted for compliance withspecification and relevant certification prior to the acceptanceof lifting equipment.

> Details of all lifting equipment shall be entered into a sitelifting equipment register.

> Lifting equipment shall be marked with a unique identificationand its safe working load.

> An inspection, against defined criteria, shall be conductedprior to the use of lifting equipment.

> A preventive maintenance program shall be developed forlifting equipment.

> Each site shall develop a formal inspection and testing programfor lifting equipment.

> Each piece of lifting equipment shall have its own inspectioncheck sheet and inspections and tests shall be conducted bycompetent personnel.

> All lifting operations shall be classified based on risk anddefined criteria.

> A detailed lift plan shall be developed for all heavy andcomplex lifts.

> Forklifts shall be operated in accordance with relevantregulatory and specified requirements.


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HSHS17 Personal Protective Equipment

Purpose

To minimise the risk of injury or illness by defining requirements forthe selection, maintenance and management of Personal ProtectiveEquipment (PPE).


> PPE shall be used when other risk control measures are notreasonably practicable to apply.

> PPE shall meet regulatory and Australian or equivalentstandards.

> Specified minimum PPE shall be worn at Santos field sites.

> Contractors shall provide their own PPE in accordance with therequirements of this standard.

> Employees with a current optical prescription shall be suppliedwith safety glasses made to their optical requirements.

> Where hearing protection is required, a Santos health andsafety coordinator shall identify the options to be worn.

> Where respiratory protection is required, a Santos health andsafety coordinator shall identify the options to be worn.

> Where escape or self–contained respiratory protection isrequired, personnel shall undergo appropriate training prior towearing such equipment.

> Appropriate PPE shall be identified when conducting a JobHazard Analysis and shall be detailed in standard operatingprocedures.

> Areas where PPE is mandatory shall be clearly signposted.

> Personnel required to use PPE shall be provided with training inits use, maintenance and storage.

> Each site shall maintain a maintenance program for PPE.


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HSHS18 Entry to Confined Spaces

Purpose

To ensure the health and safety of personnel required to enter aconfined space.


> Work in confined space shall be minimised by, where possible,eliminating the need for such work during the design of newplant and equipment.

> A confined space risk assessment including emergencyresponse requirements shall be completed by a competentperson prior to the issuing of a confined space work permit.

> The risk of heat stress shall be considered in the riskassessment and special controls adopted where required.

> Atmospheric testing for oxygen and flammable gas shall becarried out prior to and during confined space work.

> Personnel shall complete defined criteria to obtain a SantosConfined Space and Stand-by Person card.

> A stand-by person shall be provided to observe confined spacework when defined criteria are met.

> Personnel working in confined spaces shall have completed anationally accredited confined space course and hold a SantosConfined Space and Stand-by Person card.

HSHS19 Excavations

Purpose

To ensure the safety of personnel involved in the construction orworking near the vicinity of excavations.


> A risk assessment, including addressing defined criteria, shallbe completed prior to trenching or excavation activities.

> A competent person shall be appointed to manage excavationwork.

> Site–specific instructions shall be developed, incorporatingdefined requirements, to manage excavation activitiesincluding locating existing services, daily integrity inspections,access and egress from excavations, barricading andrequirements for entry to excavations.

> Where mobile equipment is used in close proximity to anexcavation an observer shall be used to monitor for signs ofinstability.

> Petrol or diesel powered equipment shall be located outsideand downwind of an excavation.

> Additional defined requirements shall be met whereexcavations exceed 1.5 metres in depth.

> Trenching operations shall cease during the delivery of fuel,gas or chemicals within 20 metres of an excavation.

> Work shall cease and defined criteria followed in the event thatcontamination is located during trenching activities.


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> HAZARD STANDARDSEHS01 | EHS02

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EHS01Land Disturbance

Purpose

To detail the requirements for planning and conducting operationsin a way which avoids or minimises disturbances to land and allowsaffected areas to be restored within reasonable time frames.


> Prior to any new activity which will result in land disturbance, anEnvironmental Impact Assessment shall be completed, unlessthere is already an approved assessment for this activity and landsystem. Many activities are covered by licences and thereforesubject to specified regulatory conditions.

> Land disturbances shall be carried out in a manner thatminimises environmental impact.

> Land disturbance shall be undertaken in accordance with the relevant environmental procedures.

> All nominated land disturbances shall be reported andrecorded on the appropriate disturbance inspection form.

> To ensure cultural heritage sites are not impactedunnecessarily by land disturbance, care must be taken todisturb only the areas previously scouted.

> Rehabilitation should occur within agreed timeframes, as soon as practicable following completion of activities.

> Fences should be designed and installed to be stock proof andin compliance with the Santos stock-proof fencing standard.

EHS02Underground Storage Tanks and Bunds

Purpose

To define the requirements for underground storage tanks (USTs)and secondary containment of substances handled and stored. To minimise the potential for spillage or leakage of chemicals,hydrocarbons or wastewater that could cause significantenvironmental harm.


> All activities and actions carried out by employees andcontractors shall be conducted in a manner that minimises theenvironmental impact of constructing, operating anddecommissioning and rehabilitating USTs and bunds.

> Planning, design and construction of new USTs and bunds shallbe undertaken in accordance with the requirements listed inthis standard and in accordance with EHSMS11.2 FacilitiesDesign and Construction. Principles for design of USTs andbunds should be established as part of the initial projecthazard study.

> For sites with minor storage, e.g. less than 1000L in total, it isgenerally satisfactory to provide alternatives to an engineeredbund.

> The relevant project manager shall ensure that new USTs andbunds are included in the relevant site significant hazard riskregister. The project manager shall ensure that new USTs andbunds are referenced in the relevant Plant Dossier.

> Where USTs are essential, and environmentally hazardoussubstances are involved, the project manager shall ensure that

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they are protected from corrosion. A Corrosion Engineer shallbe consulted when determining corrosion protectionrequirements.

> Stormwater systems for new USTs and bunds shall be designedin accordance with the requirements of this standard,EHSMS11.2 Facilities Design and Construction and relevantSantos engineering design standards, and shall ensure that thepotential for pollution from accidental or intentional upsets tothe stormwater or trade waste systems is minimised.

> The relevant site superintendent shall ensure that operatingand maintenance procedures are developed and available for:

>> draining of stormwater from USTs and bunds

>> emergency collection and clean up of hazardous area spillsinto USTs and bunds

>> inspection, testing and maintenance of system integrityand corrosion protection systems.

> The relevant activity or asset manager shall ensure that bundsare used in accordance with the requirements outlined in thisstandard.

> The relevant site superintendent shall ensure that existing USTsand bunds are included in the Significant Hazard Risk Register.The relevant activity or asset manager shall ensure existing USTsor bunds shall also be referenced in the Plant Dossier.

> If it is determined that permeable bunds will be retained, a risk assessment shall be undertaken to determine theenvironmental risk associated with continuing to use permeablebunds (refer to EHSMS09 Hazard Identification, Risk Assessmentand Control). Acceptance of this risk shall be formally signed offby the relevant activity or asset manager.

> The relevant site superintendent shall ensure that the integrityof these systems is tested and a risk assessment undertaken toassess whether failure could lead to significant environmentalharm. Improvements to an UST or bund shall be included in asite’s EHS Improvement Plan:

>> if existing installations do not comply with current designand operating standards

>> if the inherent risk level has been found to be level 2 or greater.

> Inspection of drip trays shall be carried out at regularintervals. Levels in drip trays shall be maintained at theirminimum, to remove the possibility of overflow during washdown and rain periods.

> For sites with minor storage, such as less than 1000 litres in total, it is generally satisfactory to provide alternatives to a bund.

> Manager maintenance or equivalent shall ensure thatmaintenance procedures are prepared and available for theinspection, testing and maintenance of bund integrity.

> All bunds, tanks and pipework shall be included in operationchecklists and should be inspected regularly for signs ofdamage. To ensure the bund retains its integrity, any defects inthe bund wall or lining should be repaired promptly using theappropriate technique. Damage to the tank or pipe workshould be dealt with immediately.

> Incidents, hazards and near misses involving tank overflowsand high-level alarms, vegetation on bund walls, bund linersexposed, bund walls eroded or leaks or spills inside and outsidebunds shall be reported to the Incident Management System.


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> The relevant activity or asset manager shall ensure thatresponse procedures for leaks or spills of environmentallyhazardous substances from USTs and bunds are included in therelevant site emergency response plans.

> The relevant project manager shall ensure that abandonmentand rehabilitation of USTs and bunds is undertaken inaccordance with EHSMS11.11 Decommissioning andAbandonment.

> The project manager shall ensure that the Chief Environmentaland Cultural Heritage Adviser (or nominee) is consulted priorto undertaking site rehabilitation and has final review,approval and sign-off that rehabilitation meets environmentalrequirements.

EHS03Produced Water Management

Purpose

To define the requirements for minimising environmental impactsassociated with produced water (PW) produced during theextraction, production or processing of oil and gas.


> All new PW management and disposal facilities require internaland regulatory approval prior to operation. Changes toexisting facilities (including but not limited to significantchanges to flowrate, operating conditions, monitoringprograms or new equipment) also require regulatory approval.

> During the planning phase, prior to undertaking any design ofa PW management and disposal facility (new or modificationsto existing), an assessment is required of the options for PWmanagement and disposal.

> An initial scout of the proposed site for a PW management anddisposal facility is required during the planning phase to assess environmental impacts.

> A PW Management Appraisal and Approval Form is required to be completed and approved prior to construction of any PW management and disposal facility. The relevantEnvironmental Adviser shall review the form, prior toendorsement by the Chief Environmental and Cultural HeritageAdviser. New or modifications to existing evaporation pondfacilities also require approval by the Vice President Operationsor equivalent.


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> The relevant Environmental Adviser shall undertake aninspection of any new PW management and disposal facilitiesafter construction is complete.

> Details of any new or modifications to existing PW managementand disposal facilities shall be entered in the PW Managementand Disposal Facilities Register.

> The relevant site Superintendent shall ensure that each PW management and disposal facility has operating andmaintenance procedures in place to ensure that requirementsoutlined in this standard are achieved. Where facilities are notin compliance with the requirements of this standard, a riskassessment shall be undertaken and improvement actionsraised in the Incident Management System via the EHS Toolbox.

> The relevant site Superintendent shall ensure that samplingand analysis of PW during operation and prior to disposal isundertaken in accordance with the requirements specified bythe Chief Environmental and Cultural Heritage Adviser. Theserequirements may include location, methodology, frequencyand analytes.

> If free phase hydrocarbon cover is detected on any evaporationpond, the relevant superintendent shall ensure that anenvironmental incident management report is raised in theIncident Management System via the EHS Toolbox. Free phase hydrocarbon shall be recovered or removed. The relevant site Superintendent shall ensure any beneficial use is ceased until the issue is rectified.

> The responsible manager shall ensure that PW management anddisposal facilities are decommissioned, abandoned andrehabilitated following a decision for final abandonment of thefacility in accordance with EHSMS11.11 Decommissioning andAbandonment. Details shall be entered in the PW Managementand Disposal Facilities Register.


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EHS04Waste Management

Purpose

To define the minimum acceptable standards for wastemanagement activities for Santos operations and activities,including waste generation, transportation and receiving (storageand/or disposal).


> All Santos operations and activities that generate, receive ordispose of waste are required to have an understanding of:

>> the types and quantities of wastes generated and/orreceived and/or disposed of

>> any risks associated with the transporting, handling anddisposal of these wastes

> All activities and actions carried out by employees andcontractors shall be conducted in a manner that minimises theenvironmental impact of the generation, transport, storageand disposal of waste.

> The relevant Environmental Adviser shall liaise with therelevant regulatory authorities on waste management issues.

> The Activity or Asset Manager shall ensure that internal andregulatory requirements relevant to the generation, transport,storage and disposal of waste, in the jurisdiction in which theactivity or asset is located, are identified.

> The relevant Superintendent shall ensure that the wasteinventory records the details of all waste incoming andoutgoing. Waste inventory statistics shall be summarised forreporting purposes at least annually.

> The relevant Environmental Adviser shall develop and maintaina Waste Management Plan Register.

> All Santos operations or activities that generate or receivewaste shall have a Waste Management Plan (WMP) to detail aframework of how waste should be managed.

> The relevant Superintendent shall ensure that a WMP for theoperation is created, implemented and reviewed regularly.

> The relevant Superintendent for any operation or activity thatgenerates or receives waste shall ensure that procedures areclearly documented for all waste management activities andthat these activities are undertaken in accordance with theseprocedures.

> The site Superintendent shall ensure that monitoring of waste(e.g. composition, volume) is undertaken in accordance withrequirements in the relevant WMP and/or LEMP.

> In addition, the Superintendent responsible for a wastemanagement/receiving facility shall ensure that:

>> inspections are undertaken regularly

>> audits are undertaken regularly

>> where a landfill is operated as part of the facility a LandfillEnvironmental Management Plan is prepared and reviewedregularly.

> The relevant Superintendent shall ensure that a WMP isprepared, procedures are clearly documented for all temporarywaste management activities and that activities areundertaken in accordance with these procedures.

> The relevant Superintendent shall ensure that scouting andinternal environmental approval are obtained for new landfills

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and changes to existing landfills require prior toconstruction/modification. In many jurisdictionsproposals/changes also require external regulatory approval.

> The design and construction of new landfills/changes toexisting landfills shall be undertaken in accordance withEHSMS11.2 Facilities Design and Construction.

> The relevant site Superintendent shall ensure that documentedprocedures meeting legislative requirements, includingemergency procedures, are prepared for the transport,handling, treatment and disposal of regulated waste. They shallalso ensure that any contractor/operator that transports,handles, treats and/or disposes of regulated waste isappropriately licensed and complies with the procedures.

> The site Superintendent shall ensure that procedures requirethat certificate returns are made to the relevant authoritiesand copies of completed waste transfer forms/certificates arestored in the Waste Transfer Certificate Register

> As required, the relevant Environmental Adviser orSustainability Adviser will collect and report monitoring andinventory data for external reports, including theSustainability report.

EHS05Air Emissions

Purpose

To achieve compliance with applicable air quality guidelines therebyminimising adverse impacts.


> All new projects and modifications to existing facilities shall beassessed during the design phase for any potential air qualityimpacts.

> Assessment against ambient air quality guidelines may requireatmospheric dispersion modelling by appropriately qualifiedpersonnel using accepted modelling techniques.

> Measures to minimise potential impacts shall be incorporatedinto design and operating controls.

> The final design criteria shall be approved by the relevantenvironmental adviser.

> Exceedences of criteria will require authority notification and actions to minimise environmental harm.

> Facilities will be operated to maintain acceptable levels of pollutants and emissions.

> Santos facilities that trigger thresholds must report theiremissions of National Pollutant Inventory substances annually.

> Odour emissions should be managed to avoid environmentalnuisance.


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EHS06Greenhouse Gas Management

Purpose

To outline the requirements for the accounting, reporting andmanagement of greenhouse gas emissions to meet the goalsoutlined in the Santos Greenhouse Policy.

Santos emits three greenhouse gases as defined by the UnitedNations Framework Convention on Climate Change. These includecarbon dioxide, methane and nitrous oxide.


> Production data (fuel use, flaring and venting loses) shall bemeasured by operations and reported at least annually toCorporate EHSS&IA for greenhouse emissions calculations.

> An annual greenhouse emission profile will be developed on anoperated and equity share basis.

> An annual 15–year emissions forecast will be developed.

> Santos will, where practicable, participate in externalvoluntary greenhouse gas reduction programs.

> Santos will identify and promote opportunities for natural gasto replace higher greenhouse gas emitting fuels and invest inenergy and process research and development.

> Santos will actively pursue an emission intensity reductiontarget (greenhouse emissions per unit of production) of 20% inthe period from 2002 to 2008 using a portfolio approach andreport progress against this target.

> Santos will carefully examine the forecast greenhouse gasemissions and energy use in planned new projects andacquisitions, to ensure emission intensity and energyefficiency levels are consistent with Santos’ Greenhouse Policygoals.

> Performance against these commitments will be reviewed andreported via the annual Sustainability Report.


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EHS07Energy Efficiency

Purpose

To define the requirements for managing energy use.


> The quantity of energy used (fuel use, flaring and ventingloses) to operate Santos facilities will be measured, recordedand reported on a routine basis.

> Santos operations will develop energy efficiency plans withsite–specific targets for all major assets and maintain a listwith details of potential and current energy efficiency projects.

> Progress against these energy management plans is to beassessed and reported to EHSS&IA on an annual basis.

> In accordance with the Department of Industry, Tourism andResources’ Energy Efficiency Opportunity legislation Santos isrequired to undertake an energy assessment of its operationsevery five years. This assessment must include quantitativeenergy use and an energy balance. The scope of the assessmentmust include at least 80% of energy use and all sites using over0.1 petajoule. The assessment must identify energy efficiencyprojects with a financial payback of up to four years and detailSantos’ plan to implement these projects.

> Santos is required to report publicly on the outcomes of itsenergy assessments, which will be published via the annualSustainability Report. Public reporting must outline the periodto which the report relates, a brief description of the coverage

of the assessments, a summary of the opportunities identifiedand the business response to those opportunities, and astatement by the Chief Executive Officer.

> Facilities management are required to monitor and reportenergy use for office buildings over 2,000m2.


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EHS08Contaminated Site Management

Purpose

To define the requirements for the protection of health and theenvironment, where contamination has or may have occurred.


> Clean-up of oil spills shall be undertaken in accordance withAppendix B Guidelines for Oil Spill Clean-up.

> Where a potentially contaminated site has not had aContaminated Site Assessment conducted, it is a requirementthat a Contaminated Site Review be performed. The reviewshould investigate and record information relating to past andpresent activities which have released hazardous substancespotentially impacting health and/or the environment basedsoil or groundwater contamination levels.

> A Contaminated Site Assessment must be conducted if theContaminated Site Review finds information which indicatesthat:

>> the soil and/or groundwater may have been contaminated

>> the nature and extent of the suspected contamination maypose a significant risk to human health or the environment

>> the contamination has resulted from activities controlled bythe company and may extend to groundwater and/or intoan area which is not owned by the company

>> the area is subject to acquisition, divestment or acceptanceor termination of a lease

>> the relevant statutory authority has validly directed that aquantitative assessment be performed.

> The Contaminated Site Assessment will determineInvestigation Levels (ILs) for the site.

> If contamination is in excess of ILs, then a risk assessmentshall be undertaken to assess whether the site contaminationidentified in a Contaminated Site Assessment poses an actualor potential risk to human health and/or the environment (onor off site).

> Where the outcome of the risk assessment indicates anunacceptable level of risk, a contaminated Site ManagementPlan shall be developed, which shall include at a minimum:

>> details of reporting requirements and a stakeholdercommunications plan

>> planned remediation activities.

> Contaminated materials are to be disposed of in accordancewith the site Waste Management Plan.


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EHS09Weed and Pest Animal Control

Purpose

To detail the requirements for avoiding weed and pest animalspread through Santos activities and how suitable controlmechanisms can be identified and implemented.


> The weed, pest and animal status (including the potential forintroduction and spread of declared, prescribed, prohibitedand important weeds) of existing and proposed operationalareas should be established in consultation with the ChiefEnvironmental and Cultural Heritage Adviser and contact withthe relevant authority.

> For each existing or proposed operational area, the need for aWeed and Pest Animal Management Plan shall be determined.

> Where required a Weed and Pest Animal Management Plan shallbe developed in consultation with the Chief Environmental andCultural Heritage Adviser.

> Where there is a significant risk of introducing or spreadingdeclared, prescribed, prohibited or important weeds throughthe movement of vehicles and machinery, all vehicles andmachinery shall be cleaned at an appropriate washdownfacility in accordance with appropriate washdown procedures.

EHS10Water Resource Management

Purpose

To ensure the protection from degradation and the sustainable useof watercourses, lakes, springs, overland flows, underground waterand other natural ecosystems associated with these water resources.


> Surface and ground water resources and the associated naturalenvironment shall be included in planning of new or amended disturbances to enable the protection and sustainableuse of the resource.

> Legislation, and local and regional water resource planning, shallbe considered prior to undertaking development, new or modified operational activities, or harvesting surface or ground water.

> All necessary approvals, licences, permits and certificates requiredby regulatory authorities shall be obtained prior to extracting orinterfering with surface water or groundwater.

> The quantity of water extracted shall be minimised where practical,and the quality and quantity monitored.

> Disposal of all potentially contaminated wastewater shouldconsider the waste management hierarchy and shall be conductedin a manner which prevents the degradation of waters and land.

> For new operational and facility areas a StormwaterManagement Plan shall be prepared.

> For existing operational and facility areas a risk assessment shallbe undertaken to determine the requirement for a StormwaterManagement Plan.


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EHS11Aboriginal Cultural Heritage Management

(for Australian Operations)

Purpose

To ensure that processes are developed, implemented and assessedto prevent impact to aboriginal cultural heritage from Santosoperations within Australia and to ensure that all relevant statutorycultural heritage requirements are complied with.


> All activities carried out by employees and contractors shall beconducted in a manner that avoids any possible damage ordisturbance to cultural heritage sites.

> Formal Cultural Heritage Agreements have been negotiatedwith some Aboriginal groups, Where Cultural HeritageAgreements are not in place, engagement with Aboriginalgroups will be in consistent with legislative requirements andthe Santos Aboriginal Engagement Policy (AEP).

> Where Cultural Heritage Agreements are required to bedeveloped, the Chief Environmental and Cultural HeritageAdviser/Team Leader Cultural Heritage and a representative ofthe Legal Department shall negotiate with the relevantAboriginal peoples.

> Cultural Heritage Agreements with Aboriginal Stakeholdersshall be drafted, executed and initially distributed by arepresentative of the Legal Department and only at thedirection of the Chief Environmental and Cultural HeritageAdviser.

> The Chief Environmental and Cultural Heritage Adviser shallensure that a CHMP Field Operations Document is prepared forareas and activities based on the requirements of theAgreement or CHMP and that the CHMP Field OperationsDocument is made available to field staff and site-basedcultural heritage monitors and officers.

> Selection of cultural heritage monitors undertaking culturalheritage site clearances is to be managed through the CulturalHeritage Support Officer.

> Once on site, the cultural heritage monitors and officers shallundergo location and site–specific EHS inductions.

> Prior to the commencement of Surface Disturbance Activitiesthe relevant project manager shall ensure that the relevantinternal and statutory requirements are met.

> The relevant project manager shall ensure that a completedand approved "Request for Cultural Heritage Clearance Forms"is obtained before any Surface Disturbance Activity cancommence.

> It is recommended that Santos and contractor employeesresponsible for managing or undertaking surface disturbanceactivities or cultural heritage clearances should not start workunless they have received Santos endorsed competency basedAboriginal cultural heritage training within the previous year.

> Assessment of the Aboriginal Cultural Heritage competencyand attendance at and content of training sessions shall bedocumented and recorded.

> The relevant project manager shall ensure that all identifiedcultural heritage sites are reported internally.


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> The relevant project manager shall ensure that completedforms are forwarded to the Cultural Heritage Support Officer.

> Where required by law, the Chief Environment and CulturalHeritage Adviser or delegate shall report cultural heritage sitesto the relevant government body(ies).

> All documentation and correspondence relating to Aboriginalsites, objects, remains and traditions should be endorsed withthe following words: "Confidential: This document containsinformation relating to Aboriginal sites, objects, remains ortraditions, and must be kept confidential. Disclosure of thisinformation may be a criminal offence and may also offendAboriginal tradition."

EHS12Noise Emissions

Purpose

To define the requirements for managing noise emissions fromSantos operations that may result in adverse impacts on thesurrounding environment.


> All operations are required to identify major sources of noisegenerated during all stages of the operation includingexploration, construction, development, production anddecommissioning, and consider the potential for noise levels toimpact on external stakeholders, including stock and wildlife.

> A Noise Management Strategy must be developed where it hasbeen identified that noise levels associated with Santos’operations have the potential to affect external stakeholdersor exceed regulatory requirements.

> Baseline surveys, including background level monitoring, shallbe undertaken in order to establish acceptable limits inaccordance with legislative requirements.

> The potential for offshore seismic and drilling noise toadversely impact on marine species, particularly cetaceans,must be reviewed prior to any proposed activity.

> Complaints shall be registered in the Santos ComplaintsRegister.


> Santos

GLOSSARY

> GLOSSARY > Santos70

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Accountability

ALARP

Conformance

Compliance

Contractor

Control Measure

Improvement Plan

EHS

EHS Objective

EHS Policies

EHS Targets

EHSMS

EHSMS Assessment

EHSMS Audit

EHSMS Performance

Emergency Response

This glossary defines the key terms and abbreviations used throughout this guide to the Santos

Environment, Health and Safety Management System.

Answerable for the outcomes and therefore takes the credit or consequences. Accountability cannot be delegated.

As Low as Reasonably Practicable. A level of risk that is below the intolerable level, and either the cost of further risk reductionis disproportionate to the benefit gained or where the solution is technically impractical to implement.

Meeting applicable requirements of the EHSMS.

Meeting the requirements of applicable legislation.

An individual, company or other legal entity contracted to carry out work for, and on behalf of Santos, including self-employed persons and sub-contractors.

A process, policy, system, device, practice or other action that either acts to minimise the risk of an unwanted event occurringor reduces the consequence of the unwanted event should it occur.

A document used to detail and monitor actions required to achieve defined objectives and targets.

Environment, health and safety.

A description of a performance goal aimed at meeting EHS policy requirements.

Written statements by the company of its commitment, intentions and principles in relation to its overall EHS performancewhich provide a framework for the setting and execution of its EHS objectives.

A quantified outcome of an EHS or process safety objective.

Environment, Health and Safety Management System. The EHSMS is a company-wide system that describes the requirementsfor effective environmental and health and safety practice across all of Santos’ activities and operations.

A documented, independent, systematic assessment conducted to gauge implementation status of relevant EHSMS standards.

A systematic and documented verification process of objectively obtaining and evaluating evidence to determine whether anorganisation’s EHSMS conforms to the EHSMS audit criteria set by the organisation, and for communication of the results ofthis process to management.

Measurable results of the EHSMS, related to an organisation’s control of its EHS aspects, based on its EHS policy, objectives and targets.

Actions taken at the site of a major incident to preserve lives, the environment and property.

GLOSSARY

> Santos > GLOSSARY 71

EH

SMS

Stan

dar

ds

Environmentally Hazardous Substance

Environmentally Sensitive Area

Hazard

Health Monitoring

IMS

Incident

Interested Parties

Legal Requirements

Line Management

Lost Time Injury (LTI)

Major Hazard

Medical Treatment Injury

Near Miss

Process Safety

Produced Water

Substance that has the potential to cause environmental harm such as oil, diesel, chemicals, condensate, biocide, corrosioninhibitor, contaminated waste water.

Areas where the environment may be adversely impacted easily such as surface or groundwaters, marine environment,wetlands, gibber plains.

A hazard is a source of energy that has the potential to cause harm, ill health or injury, or damage to property, plant or theenvironment.

The monitoring (including biological monitoring and health assessment) of a person to identify changes in the person’s healthdue to exposure to a hazard.

Incident Management System. The Santos electronic information management system used to report and manage EHSincidents, near misses and hazards.

Any unplanned event resulting in or having a potential for injury, ill-health, environmental damage or other form of loss.

Individual or groups concerned with or affected by the safety or environmental performance of Santos operations.

All laws, regulations, conditions of permits, licences, approvals and rules of conduct established by national, state or localgovernment authorities.

Management with direct responsibility and accountability for all aspects of activities, operations, products and services,including environment, health and safety.

Work-related injury resulting in one or more complete shifts away from work.

A source of potential harm or a situation with a potential to cause a fatality.

Work-related injury requiring specified treatment.

An unplanned event that did not result in injury or property damage but which, when formally assessed, had the potential tohave done so.

The identification and elimination of hazards associated with facility operations, that could otherwise lead to a major catastrophic event following loss of containment and ignition.

Water produced in conjunction with oil and gas extraction (produced formation water – PFW) and/or water produced duringprocessing.

GLOSSARY

> GLOSSARY > Santos72

EH

SMS

Stan

dar

ds

Property Damage

Record

Responsibility

Risk

Risk Assessment

Risk Management

Shall

Should

Significant Hazard Risk Register (SHRR)

Stepback

Strategic EHS

Target

Work Permit

UST

Workplace Assessor

The actual damage or loss of property or other resources during the normal activities associated with the operation of a Santos site, including damage or loss sustained to property owned or operated by third parties such as contractors, sub-contractors or visitors.

EHSMS–related documents stating results achieved or providing evidence of activities performed such as training records,equipment inspection record.

An undertaking to see that activities are carried out. Responsibilities can be delegated.

The chance of something happening that will have an impact upon the environment or health or safety. It is measured in terms of consequences and likelihood.

The process used to determine risk management priorities by evaluating and comparing the level of risk against predeterminedstandards, target risk levels or other criteria.

The systematic application of management policies, procedures and practices to the tasks of identifying, analysing, assessing,treating and monitoring risk.

Used in the EHSMS where a requirement in a standard is mandatory and is a minimum requirement.

Used in the EHSMS where a requirement in a standard is preferred or recommended.

A consolidated site and activity register of significant potential unwanted events with their assessed inherent risk, risk control measures and residual risk level.

An informal (non-documented) process of thinking about and mentally planning the steps involved in managing the hazards that may be faced in doing a job by “engaging the mind before the hands”.

A strategic document used to detail critical issues that Santos is planning to achieve typically within a three–to–five yearImprovement Plan period.

Detailed performance requirement, quantified where practicable, applicable to the organisation, that arises from the EHSobjectives and that needs to be set and met in order to achieve those objectives.

A document that details the work to be done, the precautions to be taken, and specifies all work conditions.

Underground Storage Tank. USTs include all underground hydrocarbon and chemical storage tanks, septic tanks and sludge pits.

Person holding a current recognised certificate of competency to conduct workplace competency assessments.

Head Office

Santos CentreGround Floor, 60 Flinders StreetAdelaide South Australia 5000

Telephone 08 8116 5000Facsimile 08 8116 5050

www.santos.com

Further Information

Contact the EHSS&IA DepartmentTelephone +61 8 8116 5360 or +61 8 8116 5705Facsimile +61 8 8116 5518

Visit the EHSMS section of “The Well”. Home > Environment, Health, Safety, Sustainability & Indigenous Affairs > EHSMS

ENVHS P001 June 2009

Santos

Printed on recycled paper

Printed in Australia on paper containing 80% post-consumer recycled fibre and 20% totally chlorine-free pulp from

sustainable plantation forests. The manufacture of this paper is externally certified to the ISO 14001 Environmental

Management System, complying with International Standards. Water is mostly recycled through manufacturing and

waste is treated to strict local standards. The paper has full Chain of Custody Certification by the Forest Stewardship

Council and is recyclable and biodegradable.

BLEACHING PROCESS

ECOENVIRONMENTAL

MANAGEMENT SYSTEM

EMSWOOD FIBRE FROMSUSTAINABLE FOREST

C E RT I F I C AT I O N

ISORECYCLED CONTENT

Santos