Offshore Drilling Contractors - 6(06 &RPSOLDQFH0DQXDO ... Macondo...2015/06/23 · 6.8 Marine Compliance Procedures (HQS-OPS-PR-06) • Section 2 Subsection 10, Installation-Specific

Title:

SAFETY AND ENVIRONMENTAL MANAGEMENT SYSTEM (SEMS)

COMPLIANCE MANUAL

Revision Status:

Level: L2A Classification: Policies and Requirements Manual Number: USA-HSE-PP-03 Issue Number: 01 Revision Number: 01 Revision Date: June 23, 2015

Transocean NONCONTROLLED

15.a.1(CD) Safety and Environmental Management System (SEMS) Compliance Manual-06.23.15 (unredacted)

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Table of Contents

Section 1 ........................................................................................................... Introduction Subsection 1 Introduction

Section 2 ........................................................................................................ Requirements Subsection 1 Access to External Codes, Practices and Standards Subsection 2 Management of Change - REMOVED Subsection 3 Operating Procedures Subsection 4 Training and Compliance Subsection 5 Maintenance, Inspection and Testing Subsection 6 Audit and Verification Subsection 7 Safety Case Subsection 8 Management System Development and Review Subsection 9 Safety Violation Reporting

Section 3 ..................................................................................................................... Annex Subsection 1 Instructor Qualifications Subsection 2 SEMS and RP 75 Requirement Mapping Table Subsection 3 Critical Systems

Section 4 ................................................................................................ Document Control Subsection 1 Document Control Page/Table of Revisions

Iss 01 / Rev 01 Hard copies are not controlled Page 1 of 1 Rev Date: June 23, 2015 SEMS Compliance Manual


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Introduction

Section 1 Subsection 1

1 OUR VISION

In order to achieve our vision of an incident-free workplace all the time everywhere, Transocean needs to ensure consistent implementation of its Company tools and processes. The health and safety of our workforce is paramount, followed by the protection of the environment in which we work and the integrity of assets. To support the achievement of this vision, Transocean has developed a series of management system manuals, tools and processes to ensure our people live and work in a safe environment.

The Transocean Company Management System (CMS) lays the foundation and expectations of how the Company manages its business functions. Within the CMS, we have a core of management system manuals and supporting materials that lay out the policies and requirements as they relate to Health, Safety and Environment.

2 SAFETY AND ENVIRONMENTAL MANAGEMENT SYSTEMS (SEMS) COMPLIANCE MANUAL (USA-HSE-PP-03)

This Level 2 manual details how the Company establishes, implements, maintains and improves its Safety and Environmental Management System Program on installations in the waters of the United States.

This manual is a living document and depends on input from the end user to ensure it is modified or updated as necessary. Please do not hesitate to provide feedback using the Management System Feedback Process.

DISCLAIMER

Where a masculine or neutral pronoun is used in this manual, it includes both males and females.

Where the term “Company” is used, it refers to Transocean Ltd. and its subsidiaries.

These policies and requirements are subject to change by the Company at any time for any reason. Past policies and procedures and the Company’s interpretation of such shall have no bearing on the Company’s current policies and requirements contained herein. Any deviation from current policies is not tolerated and the failure to comply with such policies may be grounds for disciplinary action. Finally, these policies and requirements are not intended to, and do not, create an employment contract between the Company and any employee.



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Access to External Codes, Practices and Standards


1 POLICY

A system must be in place to ensure all employees have access to applicable external codes, practices and standards.

2 PURPOSE

The purpose of this policy is to ensure employees who, in the course of performing their job functions, are provided access to applicable industry codes, practices and standards.

3 SCOPE

This policy covers all Company personnel that work at any Company Installation in the waters of the United States.

4 REQUIREMENTS

Company personnel as required by their job description may require access to external codes, practices and standards to perform their job functions. Many codes and standards are available on the internet at no cost. However; the Rig Manager may purchase necessary codes, practices and standards in hard copy or electronic license for use on the installation.

All employees requiring access to external codes, practices and standards may contact Corporate Engineering or visit the Industry Regulations and Standards page under the Corporate Engineering webpage on RigCentral for information on accessing the Company’s document library.

5 RESPONSIBILITY

5.1 Rig Manager

• Ensure offshore personnel have access to the necessary external codes, practices and standards needed for the fulfillment of their required job duties.

6 REFERENCES

6.1 Job Descriptions



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Management of Change Section 2 Subsection 2

REMOVED – Refer to Performance and Operations Policies and Procedures (HQS-OPS-PP-01), Section 2 Subsection 7 Rig Modification Request (RMR).



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Operating Procedures


1 POLICY

All installations must develop and implement equipment operating procedures that provide instructions for conducting safe and environmentally sound activities during well construction operations.

2 PURPOSE

The purpose of this policy is to ensure that procedures are developed and implemented such that personnel required to perform activities may do so in a safe and efficient manner.

3 SCOPE


4 REQUIREMENTS

In addition to Company requirements specified in the management system documents referenced in heading 6 of this subsection, the following requirements are intended to enhance the Safety and Environmental Management System (SEMS) program.

Systems and equipment that are required to have documented operating procedures as a condition of the Classification Society, Flag State or Costal State must be operated in accordance with those procedures. Procedures must be reviewed to ensure they are relevant and accurate.

4.1 Operating Limits

All equipment must be operated within the safe operating limits where defined.

4.2 Missing or Inaccurate Systems and Equipment Information

All systems and equipment required to have documented operating procedures must also have accurate design, operating and where applicable, safety information. These may be in the form of piping and instrumentation diagrams, system schematics, user manuals, or other relevant documentation required by the Classification Society, Flag State or Coastal State.

In the event required documentation is missing, replacement information must be obtained from the original equipment manufacturer (OEM) or, if unavailable from the OEM, a Request for Engineering Assistance (REA) must be raised to have the engineering department assist with the development of required documentation.

Documents developed with engineering assistance must include a hazards analysis and consideration of previous equipment operating experience as part of the development process.



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4.3 Review of Operating Procedures

All operating procedures required by the Classification Society, Flag State or Coastal State must be reviewed for relevancy and accuracy when a change is made to the equipment or operation. The interval between reviews must not exceed five years.

5 RESPONSIBILITY

5.1 All Systems and Equipment Operators

• Understand the systems and equipment-specific operating instructions and limitations. Ensure systems and equipment are operated safely and within operating limits where defined.

• Report to the Rig Manger any missing information required by Classification Society, Flag State or Coastal State regulations or necessary for the safe operation of systems or equipment.

5.2 Rig Manager

• Ensure the appropriate information is available to personnel required to operate installation systems and equipment.

6 REFERENCES

6.1 Governing Principles (HQS-CMS-GOV)

• Element 6, Asset Management and Asset Integrity

• Element 7, Operational Performance

6.2 Performance & Operations Policies and Procedures (HQS-OPS-PP-01)

• Section 2 Subsection 1.1, Well Construction Planning

6.3 Jackup and Barge Field Operations Procedures (HQS-OPS-PR-03)

6.4 Midwater and Harsh Environment Field Operations Procedures (HQS-OPS-PR-04)

6.5 Deepwater Field Operations Procedures (HQS-OPS-PR-05)

6.6 Well Control Handbook (HQS-OPS-HB-01)

6.7 Maintenance Procedures (HQS-AMM-PP-01)

• Section 4, Planning and Scheduling

• Section 5, Execution

• Section 8, Resources



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6.8 Marine Compliance Procedures (HQS-OPS-PR-06)

• Section 2 Subsection 10, Installation-Specific Operating Manual



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Training and Compliance


1 POLICY

All employees will successfully complete the training required for their current position. This includes training required as per the Transocean Worldwide Training Matrix, Unit, regulatory and Customer requirements.

2 PURPOSE

The purpose of this policy is to ensure that Company personnel meet the Company’s acceptable standards of competency. Competency is a combination of knowledge, skills, abilities and behavior necessary to perform a task or function in a work setting to achieve a defined performance standard.

3 SCOPE


4 REQUIREMENTS

In addition to Company requirements specified in the management system documents referenced in heading 6 of this subsection, all Company personnel who lead, facilitate or instruct training classes on behalf of the Company, must meet the qualification criteria defined in this policy.

4.1 Instructor Qualifications

Instructors must be appropriately trained to lead training courses or assess the training or competency of offshore employees. Instructors are qualified by acquiring the necessary relevant industry experience, undergoing instructor assessments when required, being authorized by the appropriate Company authority, and where required, the completion of specialized training specific to the course(s) they instruct such as:

• Facilitator’s courses

• Train-the-Trainer courses

• Industry-recognized instructor training

• Regulator-recognized instructor training

Where training courses are developed internally to meet specific Company goals, trainer qualifications must also be developed.



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Training and Compliance


4.2 Verification of Instructor Qualifications

A list of training programs administered by the Company and the qualifications required to lead instruction of those programs is contained in Annex 1. Company Training Managers must verify the qualification of Company Instructors prior to their facilitation of the training.

5 RESPONSIBILITY

5.1 Company Instructors

• Complete the appropriate pre-requisite qualifications for a specific training course prior to facilitating training.

• Maintain evidence of the appropriate instructor qualification.

5.2 Training Manager

• Verify the qualification of Company employees facilitating training courses as documented in Annex 1.

6 REFERENCES


• Element 4, People

6.2 Human Resources Policies and Procedures (HQS-HRM-PP-01)

• Section 6 Subsection 1, Required Training

• Section 6 Subsection 5, Training Development

6.3 Health and Safety Policies and Requirements (HQS-HSE-PP-01)

• Section 4 Subsection 1, Training

6.4 Emergency Management Procedures (HQS-HSE-PR-01)

• Section 3 Subsection 2, Emergency Response Drills

6.5 OJT System Overview



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Maintenance, Inspection and Testing


1 POLICY

Maintenance activities must be conducted in a standardized manner and must meet the requirements of the Transocean Computerized Maintenance Management System (CMMS).

2 PURPOSE

The purpose of using a standardized CMMS is to:

• Ensure that our equipment meets the performance and safety standards required by Transocean and by the applicable flag, state and other regulatory authorities

• Ensure that our equipment is maintained in a consistent manner across the fleet

• Maintain and ensure the long-term preservation of our Installations and equipment in the most cost-effective manner

• Facilitate the training and work of our maintenance staff on the Installations by providing standard processes and procedures and facilitate their mobility across different Installations.

• Provide a path for lateral learning and continuous improvement.

3 SCOPE


4 REQUIREMENTS

In addition to Company requirements specified in the management system documents referenced in heading 6 of this subsection, the following requirements are intended to enhance the Safety and Environmental Management System (SEMS) program. Where these requirements differ from the management system requirements referenced in paragraph 6, these requirements must be followed.

Systems and equipment identified in the Computerized Maintenance Management System (CMMS) by the system and component identifiers listed in Annex 3 must be maintained, inspected and tested according to the requirements below.

4.1 Frequency of Inspection and Testing

The equipment and systems identified in Annex 3 (which prevent or mitigate uncontrolled releases of hydrocarbons, toxic substances, or other materials that may cause environmental or safety consequences) must be inspected and tested in accordance with the manufacturer’s recommendations. Inspections and tests may be performed more frequently if determined necessary by operating experience. Where the manufacturer’s



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requirements are inconsistent or do not exist, Transocean’s SPM Blueprint Process will be applied to develop standard requirements.

4.2 Correction of System and Equipment Deficiencies

If a system or piece of equipment identified in Annex 3 and subject to the requirements in heading 4.1 is operating outside of the manufacturer’s recommended limits, the system or equipment must be taken out of service at the first safe opportunity. The system or equipment must be repaired or replaced and tested to ensure it operates within the recommended limits prior to entry back into service.

4.3 Reference Material to Develop Maintenance Plans

When creating or modifying Maintenance Plans, the following sources of documentations will be used to determine the Plan content that will deliver the desired maintenance strategy:

• Original Equipment Manufacturer recommendations

• Equipment Alerts (internal and external) / Product Information Bulletins

• Equipment failure experiences

• Change requests recommendations from the field

• Risk-based assessment of criticality

• FMEA (Failure Mode and Effects Analysis)

• Class and Flag requirements

• Legislation

• Operation driven requirements

• Accepted standards and codes

5 RESPONSIBILITY

5.1 Maintenance Supervisor

• Ensure the CMMS inspection and testing plan frequencies for system and equipment identified in Annex 3 and subject to the requirements in heading 4.1 meet at a minimum the frequency recommended by the manufacturer.

• Ensure equipment deficiencies on systems and equipment listed in Annex 3 are corrected prior to further use.

5.2 OIM

• Verify the effective implementation of these requirements.



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6 REFERENCES


• Element 6, Asset Management and Asset Integrity

6.2 Performance and Operations Policies and Procedures (HQS-OPS-PP-01)

• Section 5 Subsection 2, Maintenance Strategy

• Section 5 Subsection 3, Maintenance Information and Records

• Section 5 Subsection 4, Maintenance Planning, Coordination and Review

6.3 Maintenance Procedures (HQS-AMM-PP-01)



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Audit and Verification


1 POLICY

A system must be in place to verify compliance with, and measure the effectiveness of, the Company Management System through audits and assessments.

2 PURPOSE

The purpose of this policy is to define the requirements for verifying compliance with, and measuring the effectiveness of, the Company Management System (CMS).

3 SCOPE


4 REQUIREMENTS

In addition to Company requirements specified in the management system documents referenced in heading 6 of this subsection; the following requirements are intended to enhance the Safety and Environmental Management System (SEMS) program.

4.1 General

Management System Audits are performed at defined intervals to ensure all of the elements of 30 CFR 250 Subpart S – Safety and Environmental Management Systems (SEMS) and API RP75 have been properly implemented and maintained.

The requirements of SEMS and RP75 as well as the management system requirements that fulfill them are detailed in the table contained in Annex 2 of this manual.

4.2 Audit Plan

Prior to an audit, a written audit plan is developed. The plan includes the following elements to the extent they are applicable to the specific audit:

• Audit objectives and scope

• Audit criteria

• Identification of the audit team

• Identification of the locations and areas to be audited

• Identification of the program elements to be audited

• Procedures to be used in the audit

• Confidentiality requirements



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• Report contents and format, expected date of issue and distribution of the audit report.

4.3 Audit Report

The topics to be addressed in the audit report are those determined in the audit plan and the audit findings. The audit report must be dated and signed by the audit team. Audit reports will be made available to the regulator upon request.

Information in audit reports includes, but is not limited to:

• Identification of the facilities audited

• Identification of the program elements audited

• Summary of objectives and scope of the audit

• Criteria against which the audit was conducted.

• Period covered by the audit and the date(s) the audit was conducted

• Identification of the audit team

• Statement of the confidential nature of the contents

• Distribution list for the audit report

• Summary of the audit process, including any obstacles encountered

• Audit findings and conclusions, such as whether the program element(s) is properly implemented and maintained

5 RESPONSIBILITY

5.1 Management System Auditor

• Incorporate the requirements under heading 4 into all management system audits conducted on installations in the waters of the United States.

5.2 Operations Director

• Ensure the management system requirements detailed in Annex 2 are included in the audit criteria for Management System Audits conducted on all installations in the waters of the United States.

6 REFERENCES


• Element 9, Sub-element 1 Audit

• Element 9, Sub-element 6 Corrective and Preventive Action



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6.2 Audit and Compliance Policies and Requirements (HQS-CMS-PP-01)

• Section 1, Management System Audit

• Section 5 Subsection 1, Classification of Audit Findings



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Safety Case


1 POLICY

A system must be in place to identify and manage Major Hazards.

2 PURPOSE

The purpose of this policy is to ensure that all Major Hazards are identified, and the associated risks are effectively managed.

3 SCOPE


4 REQUIREMENTS

In addition to Company requirements specified in the management system documents referenced in heading 6 of this subsection, the following requirements are intended to enhance the Safety and Environmental Management System (SEMS) program.

A Major Hazard Risk Assessment (MHRA) is to be completed by a team comprised of personnel with knowledge of the operation and the risk management process. (Note: not all team members must have competency in both, but both competencies must be adequately represented.)

The team must collect information regarding the installation and its operations. The usual sources for this information include, but are not limited to:

• The Company Management System

• The Design and Construction documentation for the installation

- Marine Operations Manual

- General Arrangements

- Hazardous Area Plan

- Firefighting Plan

- Other Diagrams and Drawings

• Installation Emergency Response Plan

• Compartment Surveys

• Installation MRSPs and RRPs

• Any Non-compliances issued related to the management of major hazards



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Safety Case


• Existing MHRAs or Safety Cases for the vessel

These sources of information will be referred to throughout the Hazard Identification and Risk Assessment process.

A hazard checklist is used to determine what hazards are applicable to a specific installation. For the purposes of a Transocean MHRA, the Company used a checklist from ISO 17776, “Petroleum and natural gas industries – Offshore production installations – Guidelines on tools and techniques for hazard identification and risk assessment”, with some business-specific additions. A template hazard checklist has been developed for various rig types. The template hazard checklists are available from the USA Operational Integrity Advisor.

5 RESPONSIBILITY

5.1 USA Operational Integrity Advisor

• Ensure all collected information and the hazard checklist is used in the hazard identification and risk assessment process.

5.2 Rig Manager

• Ensure the Safety Case conforms to these requirements prior to approving.

6 REFERENCES


• Element 2, Planning and Risk Management


• Section 2 Subsection 32, Major Hazards and Other Risk Assessments



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Management System Development and Review


1 POLICY

Change to the Company Management System is formally captured, reviewed, communicated and executed through the System Management and Review Team (SMART) process.

2 PURPOSE

The purpose of this policy is to ensure changes to the Company Management System are clearly understood by people at each level by:

• developing people’s ownership and commitment to the change

• giving people the opportunity to understand what expectations are required

• sharing and capturing lessons learned to develop and execute change effectively

• enabling change to be efficiently managed and implemented utilizing available resources

3 SCOPE


4 REQUIREMENTS

In addition to Company requirements specified in the management system documents referenced in heading 6 of this subsection; all employees, on and offshore, must participate in the implementation and improvement of the Safety and Environmental Management System (SEMS).

4.1 Implementation

All employees must actively participate in the implementation of the SEMS program by completing required SEMS training, being familiar with Company requirements related to the SEMS program, and where required, completion of any Self-Verification items required to ensure the SEMS program elements are appropriately implemented.

4.2 Feedback

The method for providing feedback on any management system requirement, including elements specific to the development, implementation and improvement of the SEMS program is the SMART module in the Global Management System (GMS).

Employees without direct access to GMS who wish to submit feedback must be provided access through their department supervisor.



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Management System Development and Review


5 RESPONSIBILITY

5.1 All Company Personnel

• Complete any required training related to the implementation and maintenance of the SEMS program.

• Actively participate in the implementation and improvement of the SEMS program by understanding and complying with requirements and providing feedback through SMART.

5.2 OIM

• Ensure all employees are provided access to GMS for providing feedback through SMART if requested.

5.3 Rig Manager

• Ensure all offshore employees understand their role in the development, implementation and improvement of the SEMS program.

5.4 Operations Director

• Ensure all onshore employees understand their role in the development, implementation and improvement of the SEMS program.

6 REFERENCES


• Element 9, Sub-element 8, Management System Document Review

6.2 Audit and Compliance Policies and Requirements (HQS-CMS-PP-01)

• Section 2, Self Verification and Division Verification


• Section 2 Subsection 27, HSE Meetings



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Safety Violation Reporting


1 POLICY

The Company requires that its employees comply with its Code of Integrity.

2 PURPOSE

The purpose of this policy is to educate and inform employees what the Company requires as minimum standards for ethics business conduct.

3 SCOPE


4 REQUIREMENTS

In addition to Company requirements specified in the management system documents referenced in heading 6 of this subsection, all employees covered by this policy have the right to report to the Bureau of Safety and Environmental Enforcement (BSEE) unsafe working conditions or actual or possible violations of Safety and Environmental Management System (SEMS) requirements as detailed in 30 CFR 250.1933 and 250.193:

Any person may report to BSEE any hazardous or unsafe working condition on any facility engaged in OCS activities, and any possible violation or failure to comply with:

• Any provision of the Act1,

• Any provision of a lease, approved plan, or permit issued under the Act,

• Any provision of any regulation or order issued under the Act, or

• Any other Federal law relating to safety of offshore oil and gas operations.

To make a report, a person is not required to know whether any legal requirement listed above has been violated.

Reports should contain sufficient credible information to establish a reasonable basis for BSEE to investigate whether a violation or other hazardous or unsafe working condition exists.

To report hazardous or unsafe working conditions or a possible violation, contact BSEE by:

• Phone – 1-877-440-0173 (BSEE toll-free Safety Hotline)

• Internet – www.bsee.gov

• Mail – U.S. DOI/DSEE, 1849 C Street NW., Mail Stop 5438, Herdon, VA 20240 Attention: IRU Hotline Operations



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http://www.bsee.gov/

Safety Violation Reporting


• Include the following items in the report:

• Name, address, and telephone number should be provided if you do not want to remain anonymous;

• The specific concern, provision or Federal law, if known, that a person violated or failed to comply with; and

• Any other facts, data, and applicable information.

When a possible violation is reported, BSEE will protect a person’s identity to the extent authorized by law.

5 RESPONSIBILITY

5.1 All Personnel

• Understand your rights under 30 CFR 250.1933 and 250.193 to report any violation or perceived violation of a SEMS requirement to BSSE in accordance with this policy.

5.2 OIM

• Ensure the information in this policy is adequately communicated to all personnel and posted in a visible location accessible by all personnel.

6 REFERENCES


• Element 1, Sub-element 5, Integrity


• Section 1 Subsection 2, Organization Roles and Responsibilities

• Section 2 Subsection 3, Time Out for Safety

• Section 2 Subsection 30, Incident Reporting

__________________ 1 Act as used in 30 CFR 250.193 refers to the Outer Continental Shelf Lands Act (43 USC Chapter 29, Subchapter III)



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Annex 1 - Instructor Qualifications


1 INSTRUCTOR QUALIFICATIONS

COURSE TITLE INSTRUCTOR TRAINING REQUIREMENTS

COMPREHENSIVE STABILITY - (WW-MR-I-STB)

Barge supervisor or Chief Mate license with minimum of five years of relevant industry-specific experience.

Must have co-facilitated a minimum of three stability classes with an authorized instructor and evaluated as competent

Must be approved by the Manager of Corporate Marine Support to facilitate stability courses

DP LESSONS LEARNED - (WW-MR-I-DPLL)

Certified DPO with minimum three years DPO experience or an Industry professional with a minimum of seven years of relevant experience.

Must have co-facilitated a minimum of three DP Lessons Learned sessions with an authorized DPLL instructor and evaluated as competent

Must be approved by the Manager of Corporate Marine Support or Engineering Manager of DP, Instrumentation & Controls to facilitate DPLL sessions

DRILLING PRACTICES - (WW-DL-I-DPR)

Minimum 5 years combined offshore experience as Driller or Toolpusher

Education level minimum of high school graduate/GED equivalent recipient

Knowledge of technical calculations required for safe drilling operations

Basic computer skills

MAJOR EMERGENCY MANAGEMENT (MEM) - (WW-SF-I-MEM)

SQA A1 Assessor Certificate

IADC WellCAP FUNDAMENTAL LEVEL WELL CONTROL - (WW-DL-I-WCF)

IADC Accredited Instructor Certificate

IADC WellCAP SUPERVISOR LEVEL WELL CONTROL - (WW-

IADC Accredited Instructor Certificate

Iss 01 / Rev 00 Hard copies are not controlled Page 1 of 2 Rev Date: December 10, 2013 SEMS Compliance Manual


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Annex 1 - Instructor Qualifications


DL-I-WCS)

CRANE COMPETENCY ASSESSMENT PROGRAM - (CC-SF-I-LOP)

Authorized Onshore C-CAP Assessor (Copy of 2 previous performance appraisals, Assessor Registration and Quality Statement, 2 Day Assessors Training Course, 5 Day IADC Well CAP Facilitators Course, Copy of Resume, Crane Competency assessment completed on the candidate and 3 completed assessments verified by a Company approved assessor).

DRILLER CAP Onshore - (Conventional = CC-DL-I-DCP-COC) or (Cyber = CC-DL-I-DCP-CYOC)

Authorized Onshore D-CAP Assessor (Copy of 2 previous performance appraisals, Assessor Registration and Quality Statement, 2 Day Assessors Training Course, 5 Day IADC Well CAP Facilitators Course, Valid Well Control Certificate, Copy of Resume, Drillers Competency assessment completed on the candidate and 3 completed assessments verified by a Company approved assessor).

Subsea Supervisor Competency Assessment Program S-Cap Offshore Assessor.

Authorized Offshore S-CAP Assessor (A minimum of 10 years in offshore drilling operations or equivalent. Must have experience of 5yrs in a Subsea supervisor position. Must have 2 previous appraisals to fully satisfactory or greater. Completed WWT matrix for subsea position, Assessor Registration and Quality Statement, 2 Day Assessors Training Course, Valid Assessor certification* (ongoing), Valid Well Control Certificate, Copy of Resume, Subsea engineer Competency assessment completed on the candidate and 3 completed assessments verified by a Company approved verifier).

Dynamic Positioning Operator Competency Assessment Program DP-Cap Offshore Assessor.

Authorized Offshore DP-CAP Assessor A minimum of 10 years industry experience operations or equivalent. Must have 3 - 5 yrs. experience as Senior DPO. Must have Unlimited Nautical Institute DP Certificate. Must have 2 previous appraisals to fully satisfactory or greater. Completed WWT matrix for Sr. DPO, Assessor Registration and Quality Statement, 2 Day Assessors Training Course, Valid Assessor certification* (ongoing), Copy of Resume, DP Competency assessment completed on the candidate and 3 completed assessments verified by a Company approved verifier.



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Annex 2 - SEMS and API RP 75 Requirement Mapping Table


1 SEMS / API RP 75 REQUIREMENT MAPPING TABLE

30 CFR 250 Subpart S (SEMS) API RP 75 Transocean Document Reference

§250.1900 §250.1900 (a) §250.1900 (b) §250.1901 §250.1901(a) §250.1901(b) §250.1902 §250.1902(a) §250.1902(a)(1) §250.1902(a)(2) §250.1902(a)(3) §250.1902(a) 4) §250.1902(a)(5) §250.1902(a)(6) §250.1902(a)(7) §250.1902(a)(8) §250.1902(a)(9) §250.1902(a)(10) §250.1902(a)(11) §250.1902(a)(12) §250.1902(a)(13) §250.1902(a)(14) §250.1902(a)(15) §250.1902(a)(16) §250.1902(a)(17) §250.1902(b) §250.1902(c)

1.1 1.1.1 1.1.2 1.2 1.2.1

Transocean maintains controlled copies of management system documents in eDocs. All locations have access to eDocs through the Company’s intranet site. Where applicable, hard copies of controlled documents are also maintained. Company Management System Policies and Procedures (HQS-CMS-PP-02): Section 5 Subsection 2 Management System Document Structure. Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Mapping Table

§250.1909

1.2.2 1.2.2(a)

Transocean maintains controlled copies of management system documents in eDocs. All locations have access to eDocs through the Company’s intranet site. Where applicable, hard copies of controlled documents are also maintained. Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Mapping Table

§250.1909(a) §250.1909(b) §250.1909(c) §250.1909(d) §250.1909(e)

1.2.2(b) 1.2.2(c) 1.2.2(d) 1.2.2(e) 1.2.2(f)

Governing Principles (HQS-CMS-GOV): Introduction. Preface. Element 1 Management Leadership and Commitment. Element 9 Sub-element 5 Analysis and Review. Company Management System Policies and Procedures (HQS-CMS-PP-02): Section 5 Subsection 2 Management System Document Structure. Section 5 Subsection 3 Document Control. Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 1 Subsection 2 Organization, Roles and Responsibilities. Section 2 Subsection 27 HSE Meetings. Environmental Policies and Requirements (HQS-HSE-PP-02): Section



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1 Subsection 3 Roles and Responsibilities. Section 4 Subsection 3 Green Teams.

§250.1909(f) 1.2.2(g) Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 1 THINK Process. Section 2 Subsection 22 General Safe Work Practices. Section 2 Subsection 31 Incident Investigation. Section 2 Subsection 32 Major Hazards and Other Risk Assessments. Section 4 Subsection 1 Training. Environmental Policies and Requirements (HQS-HSE-PP-02): Section 2 Subsection 2 Environemntal Aspects and Impacts. Section 5 Subsection 1 Environmental Training and Awareness. Human Resources Policies and Procedures (HQS-HRM-PP-01): Section 6 Training. Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Section 2 Requirements. Alaska Environmental Guidance Document (USA-HSE-PR-02) US Environmental Guidance Document (USA-HSE-PR-03)

N/A 1.2.2(h) Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 1 Subsection 1 Introduction. Global Supply Chain Procedures (HQS-OPS-PR-02): Section 7 Vendor Record and Vendor Performance Management.

§250.1909(g) 1.2.2(i) Performance and Operations Policies and Procedures (HQS-OPS-PP- 01): Section 2 Subsection 7 Rig Modification Request (RMR). Section 2 Subsection 8 Request for Engineering Action (REA). Certificate and Survey (HQS-OPS-HB-03) Marine Compliance Procedures (HQS-OPS-PR-06): Section 1 Subsection 2 Items Requiring Corporate Engineering Review or Approval. Section 2 Subsection 3 Annual Safety Inspection (Flag Administration). Section 2 Subsection 4 Marine Integrity Review. Upgrade and Repair Projects Stage Gate Process (HQS-OPS-HB-07) Environmental Policies and Requirements (HQS-HSE-PP-02): Section 2 Subsection 1 Registers of Environmental Legislation and Other Requirements. Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Section 2 Subsection 3 Operating Procedures. Section 2 Subsection 5 Maintenance, Inspection and Testing. Maintenance Policies and Requirements (HQS-AMM-PP-01)



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Alaska Environmental Guidance Document (USA-HSE-PR-02) US Environmental Guidance Document (USA-HSE-PR-03) Installation Specific Operating Manual

§250.1909 (h) 1.2.2(j) Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 1 THINK Process. Section 2 Subsection 32 Major Hazards and Other Risk Assessments. Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Section 2 Subsection 7 Safety Case. Upgrade and Repair Projects Stage Gate Process Handbook (HQS-OPS-HB-07) Performance and Operations Policies and Procedures (HQS-OPS-PP-01): Section 2 Subsection 7 Rig Modification Request (RMR). Section 2 Subsection 8 Request for Engineering Action (REA).

§250.1909(i) 1.2.2(k) Human Resources Policies and Procedures (HQS-HRM-PP-01): Section 6 Training. Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 4 Subsection 1 Training.

§250.1909(j) 1.2.2(l) Audit and Compliance Policies and Requirements (HQS-CMS-PP-01): Section 1 Management System Audit. Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Section 2 Subsection 6 Audit and Verification.

N/A 1.2.2(m) Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 1 Subsection 1 Introduction. Environmental Policies and Requirements (HQS-HSE-PP-02): Section 1 Subsection 1 Introduction. Alaska Environmental Guidance Document (USA-HSE-PR-02) US Environmental Guidance Document (USA-HSE-PR-03)

1.2.2(n) Governing Principles (HQS-CMS-GOV): Element 4 Sub-element 6 Human Factors. Performance and Operations Policies and Procedures (HQS-OPS-PP- 01): Section 2 Subsection 7 Rig Modification Request (RMR).

N/A 1.2.3 1.2.3(a) 1.2.3(b) 1.2.3(c) 1.2.3(d) 1.2.3(e)

Governing Principles (HQS-CMS-GOV): Introduction. Element 1 Management Leadership and Commitment. Element 9 Sub-element 4 Performance Monitoring. Element 9 Sub-element 5 Analysis and Review. Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 1 General. Section 2 Subsection 26 HSE Information.



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Environmental Policies and Requirements (HQS-HSE-PP-02): Section 1 General. Section 6 Subsection 1 Internal and External Communications. Alaska Environmental Guidance Document (USA-HSE-PR-02) US Environmental Guidance Document (USA-HSE-PR-03)

N/A 1.2.4 1.2.4(a) 1.2.4(b) 1.2.4(c)

Governing Principles (HQS-CMS-GOV): Element 1 Sub-element 4 Communication. Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 26 HSE Information. Environmental Policies and Requirements (HQS-HSE-PP-02): Section 6 Subsection 1 Internal and External Communications. Alaska Environmental Guidance Document (USA-HSE-PR-02) US Environmental Guidance Document (USA-HSE-PR-03)

N/A 1.3 1.3.1 1.3.1.1

Audit and Compliance Policies and Requirements (HQS-CMS-PP-01): Section 3 ISM Code and Requirements.

N/A 1.3.1.2 Environmental Policies and Requirements (HQS-HSE-PP-02): Section 2 Subsection 2 Environmental Aspects and Impacts. Alaska Environmental Guidance Document (USA-HSE-PR-02) US Environmental Guidance Document (USA-HSE-PR-03)

N/A 1.3.1.3 1.3.1.3(a) 1.3.1.3(b) 1.3.1.3(c) 1.3.1.3(d)

Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 19 Hazardous Material. Section 2 Subsection 23 Hydrogen Sulfide.

N/A 1.3.1.4 Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 19 Hazardous Material.

N/A 1.4 N/A 1.5

1.5.1 1.5.2 1.5.3

Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Section 2 Subsection 1 Access to Codes, Practices and Standards. Environmental Policies and Requirements (HQS-HSE-PP-02): Section 2 Subsection 1 Registers of Environmental Legislation and Other Requirements. Certificate and Survey (HQS-OPS-HB-03) Marine Compliance Procedures (HQS-OPS-PR-06) Alaska Environmental Guidance Document (USA-HSE-PR-02)



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US Environmental Guidance Document (USA-HSE-PR-03)

§250.1910 (a) §250.1910 (b) §250.1910 (b)(1) §250.1910 (b)(2) §250.1910 (b)(3)

2.1 2.2 2.2.1 2.2.2 2.3 2.3.1 2.3.2 2.3.3 2.3.4 2.3.5

Health and Safety Policies and Requirements (USA-HSE-PP-01) Environmental Policies and Requirements (HQS-HSE-PP-02) Performance and Operations Policies and Procedures (HQS-OPS-PP- 01): Section 2 Subsection 7 Rig Modification Request (RMR). Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Section 2 Subsection 3 Operating Procedures. Performance and Operations Policies and Procedures (HQS-OPS-PP- 01): Section 2 Subsection 7 Rig Modification Request (RMR). Section 2 Subsection 8 Request for Engineering Action (REA). Section 5 Subsection 12 Equipment Standards (EST) Management. Section 5 Subsection 13 Engineering Technical Standards (ETS) Management. Certificate and Survey (HQS-OPS-HB-03) Upgrade and Repair Projects Stage Gate Process Handbook (HQS-OPS-HB-07) Marine Compliance Procedures (HQS-OPS-PR-06) Alaska Environmental Guidance Document (USA-HSE-PR-02) US Environmental Guidance Document (USA-HSE-PR-03) Installation Specific Operating Manual

§250.1911 §250.1911(a) §250.1911(a)(1) §250.1911(a)(1)(i) §250.1911(a)(1)(ii) §250.1911(a)(1)(iii) §250.1911(a)(1)(iv) §250.1911(a)(2) §250.1911(a)(3) §250.1911(a)(4)

3.1 3.2 3.2.1 3.2.2 3.2.2(a) 3.2.2(b) 3.3 3.3.1 3.3.1(a) 3.3.1(b) 3.3.1(c) 3.3.1(d) 3.3.1(e) 3.3.1(f) 3.3.2 3.3.2(a) 3.3.2(b) 3.3.2(c) 3.3.2(d) 3.3.2(e)

Governing Principles (HQS-CMS-GOV): Element 2 Sub-element 2 Planning. Element 2 Sub-element 3 Hazard Identification and Risk Assessment. Element 2 Sub-element 4 Risk Management. Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 32 Major and Other Workplace Hazards. Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Section 2 Subsection 2 Management of Change. Section 2 Subsection 7 Safety Case. Performance and Operations Policies and Procedures (HQS-OPS-PP- 01): Section 2 Subsection 7 Rig Modification Request (RMR). Section 2 Subsection 8 Request for Engineering Action (REA). Section 3 Subsection 5 Simultaneous Drilling and Production Operations. Marine Compliance Procedures (HQS-OPS-PR-06): Section 1 Subsection 2 Items Requiring Corporate Engineering Review or Approval.



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3.4 3.5 3.6

Installation Specific Safety Case IADC Health, Safety and Environmental Guidelines for Mobile Offshore Drilling Units.

§250.1911(b) §250.1911(b)(1) §250.1911(b)(1)(i) §250.1911(b)(1)(ii) §250.1911(b)(1)(iii) §250.1911(b)(2) §250.1911(b)(3) §250.1911(b)(4) §250.1911(c)

N/A Governing Principles (HQS-CMS-GOV): Element 2 Sub-element 2 Planning. Element 2 Sub-element 3 Hazard Identification and Risk Assessment. Element 2 Sub-element 4 Risk Management. Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 1 THINK Process. Section 4 Subsection 23 Customer and Subcontractor Personnel and Equipment. Section 4 Subsection 1 Training. Human Resources Policies and Procedures (HQS-HRM-PP-01): Section 6 Training.

§250.1912(a) §250.1912(a)(1) §250.1912(a)(2) §250.1912(a)(3) §250.1912(a)(4) §250.1912(a)(5) §250.1912(b) §250.1912(c) §250.1912(d) §250.1912(d)(1) §250.1912(d)(2) §250.1912(d)(3) §250.1912(d)(4) §250.1912(e) §250.1912(f)

4.1 4.2 4.2(a) 4.2(b) 4.2(c) 4.2(d) 4.2(e) 4.2(f) 4.2(g) 4.2(h) 4.2(i) 4.2(j) 4.2(k) 4.2(l) 4.2(l)(1) 4.2(l)(2) 4.2(l)(3) 4.2(l)(4) 4.2(l)(5) 4.2(l)(6) 4.2(l)(7) 4.3 4.4 4.4(a) 4.4(b) 4.4(c) 4.4(d) 4.4(e) 4.4(f) 4.4(g)

Governing Principles (HQS-CMS-GOV): Element 2 Sub-element 5 Management of Change. Element 4 Sub-element 2 Changes to Personnel Assignments. Company Management System Policies and Procedures (HQS-CMS-PP-02): Section 5 Subsection 5 Management of Change. Performance and Operations Policies and Procedures (HQS-OPS-PP- 01): Section 2 Subsection 7 Rig Modification Request (RMR). Section 2 Subsection 8 Request for Engineering Action (REA). Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 4 Management of Change. Human Resources Policies and Procedures (USR-HRM-PP-01): Section 2 Subsection 4 Personnel Management.

§250.1913(a) §250.1913(a)(1) §250.1913(a)(2) §250.1913(a)(3) §250.1913(a)(4)

5.1 5.2 5.2(a) 5.2(b) 5.2(b)(1)

Responsibilities within Transocean’s Management System are addressed at a high level in each of the Manuals (beginning sections), as well as within the individual policies and procedures in greater detail. Reporting relationships are not specified in the rig organization chart and the details are captured in the job



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§250.1913(a)(5) §250.1913(a)(6) §250.1913(a)(8) §250.1913(a)(10) §250.1913(a)(11) §250.1913(a)(12) §250.1913(b) §250.1913(c) §250.1913(d) §250.1913(e)

5.2(b)(2) 5.2(c) 5.2(c)(1) 5.2(c)(2) 5.2(d) 5.2(d)(1) 5.2(d)(2) 5.2(d)(3) 5.2(d)(4) 5.2(d)(5) 5.3

descriptions. Performance and Operations Policies and Procedures (HQS-OPS-PP- 01) Performance and Operations Policies and Procedures (HQS-OPS-PP- 01): Section 2 Subsection 7 Rig Modification Request (RMR). Section 3 Subsection 5 Simultaneous Drilling and Production Operations. Maintenance Procedures (HQS-AMM-PP-01): Section 5 Execution. Jackup and Barge Field Operations Procedures (HQS-OPS-PR-03) Midwater and Harsh Environment Field Operations Procedures (HQS-OPS-PR-04) Deepwater Field Operations Procedures (HQS-OPS-PR-05) Marine Compliance Procedures (HQS-OPS-PR-06) Well Control Handbook (HQS-OPS-HB-01) Global Vendor Quality Policies and Procedures (HQS-GVQ-PP-01): Section 3 Material/Service Nonconformance. Section 5 General Equipment Requirements. Section 7 Quality Plans. Section 8 Vendor QA/QC Inspector Surveillance Process. Global Supply Chain Procedures (HQS-OPS-PR-02 ): Section 9 Global Quality Management Marine Compliance Procedures (HQS-OPS-PR-06): Section 2 Subsection 10 Installation Specific Operating Manual. Upgrade and Repair Projects Stage Gate Process Handbook (HQS-OPS-HB-07) Health and Safety Policies and Requirements (USA-HSE-PP-01) Environmental Policies and Requirements (HQS-HSE-PP-02) Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 1 THINK Process. Section 2 Subsection 3 Time Out For Safety. Section 2 Subsection 6 Permit to Work. Section 2 Subsection 20 Hazardous Materials. Section 2 Subsection 21 Dress Requirements and Personnel Protective Equipment. Section 2 Subsection 32 Major Hazards and Other Risk Assessments. Section 3 Subsection 1 Medical Care and Documentation. Section 3 Subsection 4 Respiratory Protection. Environmental Policies and Requirements (HQS-HSE-PP-02): Section



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2 Subsection 2 Environmental Aspects and Impacts. Section 3 Subsection 6 Waste. Security and Emergency Management Policies and Requirements (HQS-HSE-PP-03): Section 3 Emergency Response. Medical Protocols (HQS-HSE-PR-02): Section 6 Environmental Emergencies. Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Section 2 Subsection 3 Operating Procedures. Alaska Environmental Guidance Document (USA-HSE-PR-02) US Environmental Guidance Document (USA-HSE-PR-03) Installation Specific Operating Manual Installation Specific Emergency Response Plan Installation Specific Safety Case IADC HSE Case Hazard Register Operator Drilling Permit

§250.1914 §250.1914(a) §250.1914(b) §250.1914(c) §250.1914(c)(1) §250.1914(c)(2) §250.1914(c)(3) §250.1914(d) §250.1914(d)(1) §250.1914(d)(2) §250.1914(d)(3) §250.1914(d)(4) §250.1914(d)(5) §250.1914(e) §250.1914(e)(1) §250.1914(e)(2) §250.1914(f) §250.1914(g)

6.1 6.2 6.2(a) 6.2(b) 6.2(c) 6.2(d) 6.2(e) 6.3 6.4

Governing Principles (HQS-CMS-GOV): Element 5 Service Provider Management. Element 7 Sub-element 6 Safety and Environment. Health and Safety Policies and Requirements (USA-HSE-PP-01) Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 6 Permit to Work. Section 2 Subsection 7 Energy Isolation. Section 2 Subsection 8 Energy Sources. Section 2 Subsection 9 Confined Space Entry. Section 2 Subsection 10 Hot Work. Section 2 Subsection 11 Control of Work Planning. Section 2 Subsection 12 Lifting Equipment and Operations. Section 2 Subsection 13 Hands Free Lifting. Section 2 Subsection 14 Work Platforms. Section 2 Subsection 15 Lifting of Personnel. Section 2 Subsection 16 Restricted Access Zones. Section 2 Subsection 20 Hazardous Material. Section 2 Subsection 22 General Safe Work Practices. Section 2 Subsection 23 Customer and Subcontractor Personnel and Equipment. Section 2 Subsection 25 HSE Orientation. Section 2 Subsection 26 HSE Information. Section 2 Subsection 27 HSE Meetings. Section 2 Subsection 33 Electrical Safety. Environmental Policies and Requirements (HQS-HSE-PP-02): Section 3 Subsection 6 Waste. Lifting Operations (HQS-HSE-HB-01)



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Performance and Operations Policies and Procedures (HQS-OPS-PP-01): Section 2 Subsection 1.1 Well Construction Planning. Section 2 Subsection 11 Contract Management (Post Award). Section 6 Subsection 4 Transocean Interface Document Guideline. Global Supply Chain Procedures (HQS-OPS-PR-02): Section 5 Vendor Contracting and Contract Management. Section 7 Vendor Record and Vendor Performance Management. Section 9 Global Quality Management. Jackup and Barge Field Operations Procedures (HQS-OPS-PR-03) Midwater and Harsh Environment Field Operations Procedures (HQS-OPS-PR-04) Deepwater Field Operations Procedures (HQS-OPS-PR-05) URP Stage Gate Process (HQS-OPS-HB-07) Alaska Environmental Guidance Document (USA-HSE-PR-02) US Environmental Guidance Document (USA-HSE-PR-03) Audit Standard Format Checklist / Report (HQS-GVQ-PP-01-FM04) Master Services Agreement (HQS-OPS-PR-02 FM 3.13)

§250.1915 §250.1915(a) §250.1915(b) §250.1915(c) §250.1915(d)

7.1 7.2 7.2.1 7.2.1(a) 7.2.1(b) 7.2.1(c) 7.2.1(d) 7.2.2 7.2.1(a) 7.2.1(b) 7.2.1(c) 7.2.1(d) 7.2.1(e) 7.2.1(f) 7.3 7.4 7.5

Governing Principles (HQS-CMS-GOV): Element 4 Sub-element 1 People Management Strategy. Element 4 Sub-element 3 Personnel Competence. Element 4 Sub-element 4 Training. Element 5 Service Provider Management. Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 4 HSE Management of Change. Section 2 Subsection 19 Emergency Response. Section 2 Subsection 23 Customer and Subcontractor Personnel and Equipment. Section 2 Subsection 24 Hydrogen Sulfide. Section 2 Subsection 25 HSE Orientation. Section 2 Subsection 29 Transport of Personnel. Section 4 Subsection 1 Training. Environmental Policies and Requirements (HQS-HSE-PP-02): Section 5 Environmental Training and Competency. Security and Emergency Management Policies and Requirements (HQS-HSE-PP-03) Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Section 2 Subsection 3 Operating Procedures. Section 2 Subsection 4 Training and Competence. Section 3 Subsection 1 Instructor Qualifications.



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Performance and Operations Policies and Procedures (HQS-OPS-PP- 01): Section 2 Subsection 7 Rig Modification Request (RMR). Global Supply Chain Procedures (HQS-OPS-PR-02): Section 5 Vendor Contracting and Contract Management. Well Control (HQS-OPS-HB-01): Section 1 Subsection 2 Well Control Procedures. Section 1 Subsection 4 Training Requirements. Section 4 Subsection 2 Well Control Drills. Master Services Agreement (HQS-OPS-PR-02 FM 3.13) Human Resources Policies and Procedures (HQS-HRM-PP-01): Section 2 Subsection 1.3 Issuance of Job Descriptions. Section 2 Subsection 2.1 Employee Personnel Records. Section 6 Training.

§250.1916 §250.1916(a) §250.1916(b) §250.1916(c) §250.1916(d) §250.1916(e) §250.1916(f) §250.1916(g) §250.1916(h) §250.1916(i)

8.1 8.2 8.3 8.4 8.5 8.5(a) 8.5(b) 8.5(c) 8.5(d) 8.6 8.6(a) 8.6(b) 8.6(c) 8.6(d) 8.6(e) 8.6(f)

Governing Principles (CMS-HQS-GOV): Element 6 Asset Integrity and Asset Management. Performance and Operations Policies and Requirements (HQS-OPS-PP-01): Section 2 Subsection 1.1 Well Construction Planning. Section 2 Subsection 1.2 Well Related Equipment Installation and Operation. Section 2 Subsection 7 Rig Modification Request (RMR). Section 2 Subsection 8 Request for Engineering Action (REA). Section 3 Subsection 6 Well Testing / DST. Section 5 Subsection 13 Engineering Technical Standards (ETS) Management. Maintenance Procedures (HQS-AMM-PP-01) Global Vendor Quality Policies and Procedures (HQS-GVQ-PP-01): Section 3 Material/Service Nonconformance. Section 5 General Equipment Requirements. Section 7 Quality Plans. Section 8 Vendor QA/QC Inspector Surveillance Process. Global Supply Chain Procedures (HQS-OPS-PR-02): Section 5 Vendor Contracting and Contract Management. Section 7 Vendor Record and Vendor Performance Management. Section 9 Global Quality Management. Well Control (HQS-OPS-HB-01): Section 9 Subsection 6 Well Control Equipment Testing Requirements. URP Stage Gate Process (HQS-OPS-HB-07) Maintenance Equipment Standards (HQS-OPS-EST) Master Services Agreement (HQS-OPS-PR-02 FM 3.13) Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 23 Customer and Subcontractor Personnel and Equipment.



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Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Section 2 Subsection 5 Maintenance, Inspection and Testing. Human Resources Policies and Procedures (HQS-HRM-PP-01): Section 2 Subsection 1.3 Issuance of Job Descriptions. Section 2 Subsection 2.1 Employee Personnel Records. Section 6 Training.

§250.1917 §250.1917(a) §250.1917(b) §250.1917(c) §250.1917(d) §250.1917(e) §250.1917(f) §250.1917(g)

9.1 9.1(a) 9.1(b) 9.1(c) 9.1(d) 9.1(e) 9.1(f) 9.1(g)

Governing Principles (HQS-CMS-GOV): Element 7 Sub-element 2 Pre-Start Up Review. Performance and Operations Policies and Procedures (HQS-OPS-PP-01) Upgrade and Repair Projects Procedures (HQS-OPS-PR-07) URP Stage Gate Process (HQS-OPS-HB-07) Health and Safety Policies and Requirements (USA-HSE-PP-01) Environmental Policies and Requirements (HQS-HSE-PP-02) Jackup and Barge Field Operations Procedures (HQS-OPS-PR-03) Midwater and Harsh Environment Field Operations Procedures (HQS-OPS-PR-04) Deepwater Field Operations Procedures (HQS-OPS-PR-05) Marine Compliance Procedures (HQS-OPS-PR-06) Maintenance Procedures (HQS-AMM-PP-01) Well Control (HQS-OPS-HB-01) Security and Emergency Management Policies and Requirements (HQS-HSE-PP-03) Human Resources Policies and Procedures (HQS-HRM-PP-01): Section 6 Training. Installation Specific Operating Manual Installation Specific Emergency Response Plan Installation Specific Safety Case



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§250.1918 §250.1918(a) §250.1918(b) §250.1918(c)

10.1 10.2 10.3 10.3(a) 10.3(a)(1) 10.3(a)(2) 10.3(a)(3) 10.3(b) 10.3(c) 10.4

Governing Principles (HQS-CMS-GOV): Element 3 Emergency Management & Business Continuity. Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 19 Emergency Response. Section 2 Subsection 25 HSE Orientation. Section 2 Subsection 29 Transport of Personnel. Section 4 Subsection 1 Training. Environmental Policies and Requirements (HQS-HSE-PP-02): Section 3 Subsection 8 Emergency Preparedness and Response. Section 5 Environmental Training and Competency. Security and Emergency Management Policies and Requirements (HQS-HSE-PP-03): Section 3 Emergency Response. Well Control (HQS-OPS-HB-01): Section 1 Subsection 2 Well Control Procedures. Section 1 Subsection 4 Training Requirements. Section 4 Subsection 2 Well Control Drills. Section 7 Well Control Complications/Emergency. Human Resources Policies and Procedures (HQS-HRM-PP-01): Section 6 Training. Installation Specific Emergency Response Plan Installation Specific Safety Case Marine Compliance Procedures (HQS-OPS-PR-06): Section 3 Subsection 6 Emergency Drills and Exercises.

§250.1919 §250.1919(a) §250.1919(a)(1) §250.1919(a)(2) §250.1919(a)(3) §250.1919(b) §250.1919(b)(1) §250.1919(b)(2) §250.1919(b)(3)

11.1 11.2 11.2(a) 11.2(b) 11.2(c) 11.3 11.3.1 11.3.2 11.3.3

Governing Principles (HQS-CMS-GOV): Element 8 Incident Reporting, Investigation and Analysis. Company Management System Policies and Procedures (HQS-CMS-PP-02): Section 5 Subsection 4 FOCUS Process. Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 31 Incident Investigation. Section 2 Subsection 5 FOCUS Process. Section 2 Subsection 26 HSE Information. Section 2 Subsection 27 HSE Meetings.

§250.1920 §250.1920(a) §250.1920(b) §250.1920(b)(1) §250.1920(b)(2) §250.1920(b)(3) §250.1920(b)(4) §250.1920(b)(5) §250.1920(b)(6) §250.1920(c) §250.1920(d)

12.1 12.1(a) 12.1(b) 12.1(c) 12.1(d) 12.1(e) 12.2 12.2(a) 12.2(b) 12.2(c) 12.2(d)

Governing Principles (HQS-CMS-GOV): Element 9 Sub-element 1 Audit. Although this is an operator requirement TOI uses independent Auditors during ISM external audits and part of the ISM audit looks at our SEMS. Audit and Compliance Policies and Requirements (HQS-CMS-PP-01): Section 1 Management System Audit. Section 3 ISM Code Requirements. Section 5 Subsection 1 SMART Feedback Process.



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12.3 12.4 12.4(a) 12.4(b) 12.4(c) 12.4(d) 12.4(e) 12.4(f) 12.4(g) 12.4(h) 12.5 12.6 12.7 12.7(a) 12.7(b) 12.7(c) 12.7(d) 12.7(e) 12.7(f) 12.7(g) 12.7(h) 12.7(i)

Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Section 2 Subsection 6 Audit and Verification.

§250.1921 §250.1921(a) §250.1921(b) §250.1921(c)

N/A Not necessary to include this in a document.

§250.1922 §250.1922(a) §250.1922(a)(1) §250.1922(a)(2) §250.1922(b)


§250.1924 §250.1924(a) §250.1924(b) §250.1924(b)(1) §250.1924(b)(2) §250.1924(b)(3) §250.1924(b)(4) §250.1924(b)(5) §250.1924(c) §250.1924(c)(1) §250.1924(c)(2) §250.1924(c)(3)


§250.1925(a) §250.1925(a)(1) §250.1925(a)(1)(i) §250.1925(a)(1)(ii) §250.1925(a)(2) §250.1925(b)


§250.1927 N/A Not necessary to include this in a document.



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§250.1927(a) §250.1927(b) §250.1927(c) §250.1928 §250.1928(a) §250.1928(b) §250.1928(c) §250.1928(d) §250.1928(e) §250.1928(f) §250.1928(g) §250.1928(h)

13.1 13.2 13.3 13.3(a) 13.3(b) 13.3(c) 13.3(d) 13.3(e) 13.3(f) 13.3(g) 13.3(h) 13.3(i) 13.3(j) 13.3(k) 13.3(l) 13.4 13.4(a) 13.4(b) 13.4(c) 13.4(d) 13.4(e) 13.4(f) 13.5 13.5(a) 13.5(b) 13.5(c) 13.5(d) 13.5(e) 13.5(f) 13.5(g) 13.5(h)

Governing Principles (HQS-CMS-GOV): Element 9 Sub-element 9 Controlled Documents. Element 9 Sub-element 10 Records Management. Company Management System Policies and Procedures (HQS-CMS-PP-02): Section 5 Subsection 1 System Management and Review Team. Section 5 Subsection 2 Management System Document Structure. Section 5 Subsection 3 Document Control. Information Technology Policies and Requirements (HQS-IT-PP-01): Section 3 Subsection 1 Records and Information Management. Records Retention Schedule (RRS-01) Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 5 Subsection 2 Record Keeping and Retention. Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Section 2 Subsection 8 Management System Development and Review.

§250.1929 N/A

§250.1930(a) §250.1930(a)(1) §250.1930(a)(2) §250.1930(a)(2)(i) §250.1930(a)(2)(ii) §250.1930(a)(2)(iii) §250.1930(b) §250.1930(c) §250.1930(d) §250.1930(e)

N/A Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 3 TimeOut For Safety.

§250.1931 §250.1931(a) §250.1931(b) §250.1931(c)

N/A Health and Safety Policies and Requirements (USA-HSE-PP-01): Section 2 Subsection 3 Time Out For Safety. Marine Compliance Procedures (HQS-OPS-PR-06): Section 3 Subsection 1 Designation of OIM and PIC.



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§250.1932(a) §250.1932(b) §250.1932(c)

N/A Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03) Section 2 Subsection 8 Management System Development and Review.

§250.1933(a) §250.1933(b)

N/A Safety and Environmental Management System (SEMS) Compliance (USA-HSE-PP-03): Section 2 Subsection 9 Safety Violation Reporting.



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Annex 3 – Critical Systems


1 CRITICAL SYSTEMS

Well Control System System Component Description WCS ACUM Accumulators WCS ANNU Annular WCS BOLT Riser Bolts WCS BOPB Lower Double Lower R/H Bonnet WCS BOPR Lower Double BOP WCS BOPP Control Pod WCS BOPS BOP #1 Stack/Frame WCS COPU BOP HPU WCS CABL Electrical Cabling WCS CONN Connector WCS CTRU Controls/Control Panel WCS DGAS D/gasser WCS DICH Diverter Handling Tool WCS DIVT Diverter WCS FJRA LMRP Subsea Flex Joint WCS GCYL Gas Cylinder WCS HOSE Hose WCS INST Instrumentation WCS MANI Manifold WCS MTR Motor WCS PIPE Pipework WCS PMP Pump WCS PRV Pressure Relief Valve WCS RISA Riser Adapter WCS TANK Tank WCS TJT Riser Telescopic Slip Joint #1 WCS UMB Umbilical Cables WCS UPS Uninterrupted Power Supply WCS VLV Valve WMAC GCYL Gas Cylinder

Fire Fighting Systems System Component Description

FFS FEXT Fire Extinguisher FFS FS Fire Suppression FFS FSTA Fire Stations FFS MON Fire Monitors FFS MTR Motor FFS PIPE Pipework FFS PMP Pump



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Annex 3 – Critical Systems


FFS PRV Pressure Relief Valves FFS TANK Tank FFS VLV Valve FFS BCHG Emergency Fire Pump Battery Charger FFS GCYL Cylinder FFS MON Fire Monitors FFS MANI Manifold

Fire & Gas Systems System Component Description

FGDS ALRM Alarm FGDS CTRU Controls/Control Panel FGDS FDET Fire Detection Zone FGDS GDET Gas Detection Zone FGDS PGD Portable Gas Detector FGDS BCHG Battery Charger



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SAFETY AND ENVIRONMENTAL MANAGEMENT SYSTEM (SEMS) COMPLIANCE MANUAL, USA-HSE-PP-03TABLE OF CONTENTSSECTION 1 INTRODUCTIONSUBSECTION 1 INTRODUCTION

SECTION 2 REQUIREMENTSSUBSECTION 1 ACCESS TO EXTERNAL CODES, PRACTICES AND STANDARDS1 POLICY2 PURPOSE3 SCOPE4 REQUIREMENTS5 RESPONSIBILITY5.1 Rig Manager

6 REFERENCES

SUBSECTION 2 MANAGEMENT OF CHANGESUBSECTION 3 OPERATING PROCEDURES1 POLICY2 PURPOSE3 SCOPE4 REQUIREMENTS4.1 Operating Limits4.2 Missing or Inaccurate Systems and Equipment Information4.3 Review of Operating Procedures

5 RESPONSIBILITY5.1 All Systems and Equipment Operators5.2 Rig Manager

6 REFERENCES

SUBSECTION 4 TRAINING AND COMPLIANCE1 POLICY2 PURPOSE3 SCOPE4 REQUIREMENTS4.1 Instructor Qualifications4.2 Verification of Instructor Qualifications

5 RESPONSIBILITY5.1 Company Instructors5.2 Training Manager

6 REFERENCES

SUBSECTION 5 MAINTENANCE, INSPECTION AND TESTING1 POLICY2 PURPOSE3 SCOPE4 REQUIREMENTS4.1 Frequency of Inspection and Testing4.2 Correction of System and Equipment Deficiencies4.3 Reference Material to Develop Maintenance Plans

5 RESPONSIBILITY5.1 Maintenance Supervisor5.2 OIM

6 REFERENCES

SUBSECTION 6 AUDIT AND VERIFICATION1 POLICY2 PURPOSE3 SCOPE4 REQUIREMENTS4.1 General4.2 Audit Plan4.3 Audit Report

5 RESPONSIBILITY5.1 Management System Auditor5.2 Operations Director

6 REFERENCES

SUBSECTION 7 SAFETY CASE1 POLICY2 PURPOSE3 SCOPE4 REQUIREMENTS5 RESPONSIBILITY5.1 USA Operational Integrity Advisor5.2 Rig Manager

6 REFERENCES

SUBSECTION 8 MANAGEMENT SYSTEM DEVELOPMENT AND REVIEW1 POLICY2 PURPOSE3 SCOPE4 REQUIREMENTS4.1 Implementation4.2 Feedback

5 RESPONSIBILITY5.1 All Company Personnel5.2 OIM5.3 Rig Manager5.4 Operations Director

6 REFERENCES

SUBSECTION 9 SAFETY VIOLATION AND REPORTING1 POLICY2 PURPOSE3 SCOPE4 REQUIREMENTS5 RESPONSIBILITY5.1 All Personnel5.2 OIM

6 REFERENCES

SECTION 3 ANNEXSUBSECTION 1 ANNEX 1 - INSTRUCTOR QUALIFICATIONSSUBSECTION 2 ANNEX 2 - SEMS AND API RP 75 REQUIREMENT MAPPING TABLESUBSECTION 3 ANNEX 3 - CRITICAL SYSTEMS

SECTION 4 DOCUMENT CONTROLSUBSECTION 1 DOCUMENT CONTROL PAGE/TABLE OF REVISIONS