EHS Management System Elements

Element 1: Leadership Leadership is that trait in a personality that enables great things to be achieved by others. At Helix Energy Solutions we look to all employees to lead by example for EHS Improvement. Proactive leadership is a necessary and key element for the EHS to succeed. Line management is charged with implementation of EHS processes. EHS professionals provide staff assistance and services to management and employees at all levels to help achieve the EHS objectives.

Element 1: Leadership Value Expectations The EHS Policy Statement endorsed by the Chief Executive Officer is communicated, promoted and supported at every level of the organization. Management and supervision shall demonstrate commitment to EHS objectives through active and visible participation and by allocating sufficient resources. EHS responsibilities, authorities, and accountabilities are clearly defined, communicated and carried out at all levels. EHS performance is a major component of employee, site and business unit performance appraisal process. A system is in place to encourage employee involvement and participation in the EHS MS process. Clear goals, objectives and targets are established for the EHS MS.

Element 2: Hazard Identification Management of hazards in the workplace is the key component for the prevention of incidents or near misses. Value Expectations A system is in place to identify hazards, assess the potential consequences (severity) and probabilities (risk), and implement prevention and mitigation measures. Risk Assessments are conducted periodically by qualified personnel for operations and projects to identify and address potential EHS hazards. EHS assessments are conducted as part of the acquisition or disposal of assets, and EHS hazards are managed as part of equipment or facility decommissioning.

Element 3: Compliance In most cases compliance means conformity with the applicable EHS Regulations from the governmental agencies that govern our business activities, and complying with the EHS specifications of our customers. Value Expectations: A system is in place to ensure that all applicable governing EHS compliance requirements are known, and compliance is incorporated into relevant procedures and programs. Emerging EHS compliance governmental requirements are monitored, and impacts or benefits to company operations are identified. This is primarily accomplished through membership and participation in industry associations.

Element 4: Engineering The best way to cure an EHS problem is to engineer the hazard out of the work process. Value Expectations: Project management systems and procedures are documented, well understood and carried out by qualified personnel. Design and construction of new or modified vessels, facilities or structures are based on approved design standards and practices that meet or exceed applicable regulatory requirements. Quality control and inspection systems are established to verify that vessels, facilities, or structures meet design specifications and that construction is in accordance with the applicable standards.

Element 5: Supply Chain Supply Chain Management (SCM) value expectations within Helix involves the purchasing of goods and engagement of service providers. Value Expecations: The EHS aspects of products and equipment to be purchased are assessed for fitness to purpose. Evaluation and selection procedures for vendor services include assessments of their capabilities to perform work in a manner consistent with the EHS MS. Vendor services carried out at the vendor premises are subject to EHS audits based on the potential risks involved and/or triggering events such as serious incidents, near-misses or fires.

Element 6: Communication No other element is more important than good communication in the prevention of incidents and the safe performance of work. Value Expectations: An EHS Steering Committee and EHS Teams are in place from the executive level to the work site level to openly discuss and action EHS improvements. Minutes of meetings are recorded. Lessons learned from incidents within Helix, from industry associations and from the governing authorities are shared with all work sites and maintained for future reference and training purposes. A process is in place that identifies hazards associated with work tasks, assesses the risk potential, and discusses the necessary precautions to be taken with all concerned personnel. EHS documentation and performance statistics are maintained and distributed regularly via e-mail, memos or newsletters.

Element 7: Management of Change All work sites, vessels, and facilities will be operated and maintained to a level that ensures EHS objectives are met. Value Expectations: A system is in place for managing both temporary and permanent operational changes. This Management of Change (MOC) process involves a designated approval authority, analysis of potential implications and meets the intent of MOC industry practices and applicable regulations. When a plan is developed to complete a task, the hazards have been identified and either eliminated or mitigated. During the course of executing the planned activity, if circumstances change, those personnel undertaking the work develop an alternative methodology for completion. Hazards associated with the alternative process must be identified at the time, and incorporated into all relevant documentation. MOC exercises are conducted quarterly on vessel work sites.

Element 8: Operations All work sites, vessels, and facilities will be operated and maintained to a level that ensures EHS objectives are met. Value Expectations: A system is in place for development and implementation of operating, maintenance and inspection procedures. Operations with a potential higher risk are identified and managed through application of Job Safety Analysis (JSA’s) and the Permit to Work system. Operating procedures are available, revised as required, and interfaces between operations are assessed for potential hazards. Critical alarm, control, and emergency equipment is identified, tested, and under goes preventive maintenance at defined intervals.

Element 9: Human Resources The most valuable asset Helix has are people, relentless effort shall be taken to take care of each valued and significant member of the Helix family. Value Expectations Employees are empowered to take necessary action within their means to eliminate risk in the work place. Education and ongoing skills training shall be provided in order to ensure that employees are competent at their work. A positive behavior modification process will be established throughout the organization that will nurture a positive “Safety Culture” within Helix where the value of safety to each individual is embraced and practiced in all that we do.

Element 10: Emergency Response The values of Helix mandates that when responding to an emergency situation the individual shall be cared for first and foremost, thereafter the company physical assets will be looked after. Value Expectations: At each site an emergency response and crisis management system is in place with plans that are documented, revised to stay current, readily available and communicated to users. There is a program for performing simulations, exercises and drills to verify emergency response plan readiness. A procedure is in place to ensure adequate communications with governmental agencies, medical resources, transportation services, customers, the public, and the media as applicable concerning emergency response.

Element 11: Incident Investigation The main purpose of all incident and near miss investigations is to prevent a similar recurrence. Value Expectations: A system is in place for reporting, investigating, analyzing and documenting all EHS incidents, regulatory compliance incidents, and significant near misses. Incidents report findings are analyzed for root causes and to ascertain where improvements to practices, standards, procedures, or systems are warranted; and used as a basis for further improvements. A process exists to verify that corrective actions, as a result of incident investigations are documented and implemented.

Element 12: Auditing It is important to verify that all components of the EHS MS are functioning in an effective manner and that where non-conformances are identified that they are corrected and documented. Value Expectations: Procedures for audits are developed and implemented to determine if the system meets the EHS objectives and that it is based on a continual improvement cycle. An audit program will be published with audits performed by trained auditors on all sites based on the priority of risks to EHS concerns. Audit findings are analyzed with actions taken to correct non-conformances and close gaps in the system.

Element 13: Management Review In order to close the loop on the continual improvement process, executive management reviews and evaluates the effectiveness of the EHS MS on an annual basis. Value Expectations: Annual reviews will cover audit results, EHS performances related to EHS objectives and targets set. Review findings are documented and actions assigned where desired improvements are identified. A system is in place to ensure resolution of the annual EHS executive review findings.