Health and Safety
The wellbeing of employees and contractors is of extreme importance to Nostrum, and we promote an active health and safety culture within the Company. QHSE training and procedures are rigorous and are promoted to an international standard.
1.Personal Safety
2022 Key Performance Indicators
Indicator | Measure | Target |
---|---|---|
Lost Time Injuries | 12 month Rolling Frequency | 1.0 |
Total Recordable Incidents | 12 month Rolling Frequency | 2.0 |
Road Traffic Incidents | 12 month Rolling Frequency | 0.8 |
HSE Stop cards | Number or cards | 1000 |
Progress against 2022 targets
Nostrum has seen a significant improvement in its lost time incidents (LTIs) and road traffic incidents (RTIs) in 2022 by recording zero incidents for both Nostrum’s and contractors’ operations. Total recordable incidents rate in 2022 was 1.56 incidents per million man-hours, representing a 35% decline against 2021.
For the fourth consecutive year the Group and its contractors had zero fatalities across its operations.
Nostrum notes that its activities are potentially hazardous. The Group’s management, employees and contractors are trained to understand that no accidents are inevitable as we strive to culture an environment where safety consciousness and mitigating actions are such that zero incidents are possible and achievable. For all incidents we follow our incident investigation procedure based on the “five whys” and “why tree” methodology to determine the root causes, and apply SMART principles to mitigate future risks.
Safety performance
Total Recordable Incidents Rate
incidents per million man-hours
Lost Time Incidents Rate
incidents per million man-hours
Road Traffic Incidents Rate
incidents per million km driven
HSE Leadership, Communication and Awareness
In addition to the 2022 initiatives outlined above, Nostrum also introduced the following communication and awareness initiatives:
- Daily safety awareness pop-up windows on each individual computer screen at first log-in each day.
- HSE posters published at all locations.
- Issuance of monthly QHSE reports to communicate HSE performance.
The revised and updated HSE procedures are regularly communicated to all employees to highlight the implemented changes.
HSE Golden Rules
In order to effectively manage the “Golden Rules”, Nostrum applies rigorous consequence management which means that we take a risk based approach to guide people and leaders through the processes required when they witness or have reported to them inappropriate behaviour in the workplace. For serious violations of safety rules, staff or contractors risk immediate dismissal. For that purpose, consequence management is split into two categories. The more serious category which results in immediate dismissal is applied in case of alcohol / drug abuse. Less severe cases, such as safety belt violation, results initially in a warning followed by dismissal if a repeat violation is observed.
Golden Rules
- Seatbelts must always be worn by the driver and all passengers
- Do not exceed the speed limit and reduce speed for impaired road conditions
- Do not use phones or operate devices while operating a motor vehicle
- Alcohol and drugs of any kind (excluding approved medicines) are forbidden
- Where required work with a valid permit
- Obtain authorization before entering a confined space
- Confirm that hazardous energy sources have been isolated, enclosed and tagged
- Obtain authorization before overriding or disabling safety controls
- Never walk under a suspended load
- Protect yourself against a fall when working at heights
Hazard Observation Cards
As part of promoting safety culture among our employees and contractors, Nostrum continues to implement a hazard observation card process. This initiative has been launched in 2019 when all employees and contractors were encouraged to report any unsafe conditions observed in the workplace. This helps to ensure that our employees and contractors are always mindful of safe working conditions and continuously help to improve the safety of our operations.
We set ourselves a KPI for 2022 to issue at least 1,000 Hazard Observation Cards. Of this amount at least 500 should have been issued by more than 60% of Nostrum employees and at least 500 cards by the four largest Nostrum contractors based on contract value. In 2022, Nostrum and our contractors’ personnel issued 1,746 hazard observation cards, representing eight times growth as compared to 2019 amount when the initiative was started. In 2023 Nostrum is planning a new step in building an HSE culture by implementing an Intervention culture across Nostrum and Contractor personnel.
Hazard observation cards in 2019 – 2022 (units)
In-house HSE training and examination process
Since 2020, Nostrum conducts in-house HSE training and examination designed to improve the HSE competencies of both Nostrum and contract personnel performing safety-critical activities. To facilitate this, Nostrum acquired an industrial safety accreditation which allows the Group to conduct in-house HSE training and examination in areas such as industrial and labour safety. The Group employees are continuously trained in labour safety, industrial safety and H2S rules. During 2022 715 employees took advanced HSE trainings.
In-house HSE trainings
2. Process Safety
In 2022, there were no Tier 1 or Tier 2 process safety events registered at Nostrum’s production facilities. As defined by the American Petroleum Institute, a Tier 1 and Tier 2 safety incident is an unplanned or uncontrolled release of any materials, including non-toxic and non-flammable materials, from a process that results in one or more of the following consequences:
- An employee, contractor or subcontractor incurs days away from work, injury and/or fatality,
- A hospital admission and/or fatality of a third party,
- An officially declared community evacuation or community shelter put in place, including precautionary community evacuation or community shelter in place, and;
- Fire or explosion damage of at least US$100,000.
The selection of appropriate maintenance strategies and the classification of equipment as safety critical or non- critical, is based on the impact that such equipment failure has on safety. Nostrum employs a specific safety critical equipment maintenance program whereby resources are allocated in order of priority with the critical systems taking precedence.
Vessel and Flowline inspection programme
All vessels and main flow lines were inspected according to international and RoK standards at the frequencies described (2, 5 or 10 years). No defects were identified during the internal and external inspections. From 2023 onwards, all vessels and flow lines will require yearly inspection but this can be done externally without necessary shutdowns as was the case for internal inspections. The inspection will be focussed on wall thickness and, as such, provides the same information as before.
3. Contractor Management
We require our contractors and suppliers to work to the same high standards as our employees, therefore effective contractor selection, communication and training in our safety culture and practices as well as strong monitoring are essential to maintain the high level of safety embraced by Nostrum.
Manhours worked in 2022 | Percentage of total |
---|---|
Nostrum employees: 1,012,351 | 39.5% |
Contractors: 1,551,461 | 60.5% |
In 2022 we continued with our contractor HSE management implementation and performed seven external contractor HSE management audits and two internal management system audits to test compliance with our HSE management system.
Review audits and bi-annual HSE performance meetings with our key contractors were also conducted in 2022.
Nostrum seeks to promote safe behaviour among its contractors and has established a wide range of methods to ensure that operations at facilities are carried out in full compliance with local legislation as well as Nostrum rules and regulations. In addition to the measures already discussed. Nostrum continues to use the hazard observation cards initiative introduced in 2019.
Annual Contractor HSE Forum dedicated to Golden Rules compliance was conducted in October 2022. General directors and HSE Representatives from main contractors attended the forum to share their HSE performance results with Company’s Management.
In our operations there are several stages to ensure contractor compliance with HSE spanning from pre-contract award to contract close-out with significant roles for the contract owner, contract holder, contracts and procurement and HSE staff.
This process is more fully described below:
Pre-Award
Stage 1 – Vendor Qualification
To be a qualified bidder, vendors must meet our Qualification standards, which includes five fundamental HSE criteria. This process is meant to help us select those vendors that both adhere to and support our basic HSE culture.
Stage 2 – Scope of Work preparation by contract holders
Our procurement group has developed a standard checklist which is used by contract holders in compiling specifications for scope of work/services. This checklist includes HSE issues identified by contract holders as mandatory and which must be complied with by the selected contractor. The depth of these questions depends on the complexity and risk profile of the services to be provided with more comprehensive questioning of potential contractors that would be engaged in safety critical operations or where the HSE risk is considered high. HSE risk ratings (ranging from high to low) are assigned to all services to be tendered. The contracts and procurement department ensures all these requirements are properly addressed in the Invitation to Tender (ITT) Package.
Stage 3 – Tender
Our standard ITT Package includes:
- Tender Evaluation Questionnaire, with appropriate HSE related questions depending on the HSE risk rating;
- Standard Model Contract with HSE Schedule. Tenderers must confirm in writing their acceptance of the terms of this Schedule when submitting their Tender Proposal, otherwise they are automatically disqualified;
Stage 4 – Contract execution
The selected contractor signs the contract which incorporates a HSE Schedule as an integral part.
Post-Award
Stage 5 – Contract Performance
The contract holder, with support of HSE representatives, is responsible for the management of HSE performance of the Contractor.
All new contractors start their engagement with Nostrum with kick-off meetings organized by the contract supervisor and supported by HSE representatives at which Nostrum’s expectations are explained in detail. Further topics of discussions are clear identification of KPIs related to HSE, introduction of HSE responsible staff from both sides, and induction into the Company’s procedures and regulations.
4. Emergency response
In 2022, no industrial accidents or oil spills were recorded at Nostrum’s operations. The Company has established and successfully exercises an emergency response system and undertakes measures to prevent oil and oil product spills.
Emergency response and accidents preparatory activities
The Company has emergency response plans to enhance our ability to respond rapidly to unforeseen events to maintain business continuity and minimise negative impact on people, the environment, our physical assets and our reputation.
The plans are communicated to the workforce and response personnel receives training to ensure they are competent to carry out their emergency roles. We continue to ensure asset integrity and control operations to effectively manage all significant risks during all stages of the operations.
Specifically, in 2022 Nostrum revised and agreed with emergency services all Emergency Response Plans (hereinafter – ERP) for hazardous production facilities. Under the plans, an emergency training of personnel has been conducted on a quarterly basis in order to prevent accidents and emergencies as well as to train personnel in emergency response in case of their occurrence according to ERP emergency scenarios at all hazardous production facilities. In 2022, we maintained emergency response training and exercises involving credible emergency ERP scenarios at all hazardous production facilities.
Hazardous production facilities at Nostrum include:
- Oil Terminal and Transfer Point in Beles
- CF-Rostoshi Oil Trunk Pipeline
- CF-ICA Gas Trunk Pipeline (GTP Orenburg-Novopskov)
- OTU and gaslift system
- CGTU-1,2 and LPG -1,2
- Well Operations and gathering system
- GTU-26
- MTS and RPMS
- Waste disposal area
- GTU-3 and LPG-3
During the training drills at the facilities, the composition of the emergency operations center (EOS) was determined to organize and coordinate possible emergency prevention and responses to accidents, as well as to ensure fire safety. During the quarterly drills held at the facilities – EOS, the whole range of issues related to accidents and emergency prevention and elimination procedures were considered.
The overall control of all emergency drills was overseen by the Field Director, who is also responsible for the implementation of industrial and fire safety measures.
We believe that these actions help maintain the proper level of skills and competencies among employees and
executives and ensure compliance with legal requirements and corporate standards.
The overall control of all emergency drills was exercised by Field Director, who is also responsible for the implementation of industrial and fire safety measures.
Oil spill prevention
The Group strives to have zero operational spills. Nostrum continues to undertake initiatives to prevent and reduce spills that include drills and training teams, timely maintenance, repair and replacement of equipment, monitoring of problem areas, etc.
Oil Spill Response Plan
We continue to enhance our spill response capabilities and, during 2022, we revised, designed and implemented the Oil Spill Response Plan (“OSRP”) within the Company’s production facilities.
This plan sets our response strategies and techniques, available equipment, and trained personnel and contracts and includes the following measures:
- signal receiving action plan for a facility,
- notification procedure for Company’s subsidiaries, state bodies and local authorities,
- responsibility allocation for rescue units organization and management, and;
- measures to be taken to ensure people’s safety and other actions.
According to this plan, to prevent oil spills in 2022, three drills were held at the Terminal and oil pipeline with the participation of contractor Ansar-S-Group LLP including deployment of equipment for collecting spilled oil, both from the ground and on the water surface. The workforce of Fire brigade of the Ansar-S-group LLP (at the terminal) trained using their practical knowledge in operating oil collection equipment for further disposal. The drills are conducted every quarter, where the results are summarized and the best response options are developed.
In addition, an annual preparation of hazardous sections of pipelines for autumn-winter season and spring floods is made, especially in areas located in a possible flooding area. Monitoring of their condition is organized by the contractors – Nysan Korgau and Ansar-S Group.
The OSRP gives substantiation of a possible emergency level, analyzes scenarios of their occurrence and development, and also makes a forecast of possible consequences for production facilities associated with accidental oil spills.
Introduction of emergency response plans and OSRP for Nostrum’s production and engineering personnel is documented in the briefing log at the workplace against signature. The facility supervisor and an engineering manager define responsibility for the due and correct preparation of ERPs. In addition to OSRP, compliance with safety requirements is controlled on a regular basis. In case of non-compliance has been identified, corrective and preventive action plans are developed and implemented.
Contained and non-contained oil spills
In 2022 there were no oil spills. A table below shows data for 2019-2022:
Period | Contained oil spills | Non-contained oil spills | Volume of the oil spills in cubic meters | Note |
2019 | 0 | 1 | 0.045 | In February 2019 there was minor fuel spill to the ground when LPG truck tipped over. The leak amounted to 45 litres of diesel to the ground. |
2020 | 1 | 0 | 0.05 | There was an oil spill inside the pump station of the Terminal without leak to the open ground surface. |
2021 | 0 | 0 | ||
2022 | 0 | 0 | ||
Total | 1 | 1 | 0.095 |
Boosting readiness of emergency rescue teams
To respond to emergencies, Nostrum established emergency rescue teams (hereinafter – the ERT), where 120 employees on a voluntary basis (60 people in each shift), were engaged to ensure the safety of the production facilities and in 2022 regular drills with ERT staff were conducted as per Site Specific Emergency response plans.
To maintain and conduct emergency rescue operations, the Company has permanent contracts with the professional ERT – Ak-Beren LLP (gas rescue service) and Ansar-S-Group LLP (firefighters-rescuers). Ak-Beren, a professional blowout elimination service, is responsible for accident prevention at oil and gas wells, which is fully compliant with the requirements for oil, petroleum product, and other hydrocarbon spill response. Materials and equipment available to the emergency response and rescue teams are certified and compliant with all requirements. In 2022, this service included preventive works to train its gas rescuers and voluntary teams of Nostrum.
A high degree of readiness for the ERT is supported by regular drills and training, as well as theoretical knowledge. Drills and trainings are held on a quarterly basis. Special attention during the ongoing emergency drills was given to those facilities where gas and oil contain hydrogen sulfide. The drills in 2022 were conducted according to updated and approved ERPs. Commanders of voluntary rescue and fire teams were additionally trained under the training program for unit commanders to maintain levels of skills and competence, particularly in relation to safety-critical roles.
The non-government fire service of Ansar-S-Group LLP, which had a service agreement with Nostrum in 2022, was also involved several times in emergency response in Baiterek during the elimination of the consequences of spring floods and summer steppe fires at the request of akims and local executive bodies. Thus, Nostrum provides assistance to the administration and residents of Baiterek on an ongoing basis.
Organization of communication with contractors on emergency response and prevention of possible emergencies
A significant part of preventive and emergency organization is performed by contractors for Nostrum. In order to ensure a high level of preparedness for emergency response, all drills and trainings were made with participation of the following organizations:
- Ansar-S-Group LLP – fire prevention;
- Ak-Beren LLP – blowout prevention, gas and hydrogen sulfide hazards;
- Nysan-Korgau – the organization of access control and protection of an accident zone from unauthorized persons.
HSE personnel assigned to each hazardous facility, perform permanent control over work plans implementation by contractors as well as requirements of industrial safety standards. To achieve this, the Company uses checklists containing the entire range of issues under consideration – starting from document maintenance to work quality and safety. HSE Department organizes regular control field inspections at production facilities.
The control teams include representatives responsible for occupational health, safety and emergency response.
- The most pressing issues are discussed with all contractors and facilities, a joint work on quality improvement of safety methods is organized on a permanent basis.
- Representatives of contracting organizations participating in all emergency drills regularly held by Nostrum, have an opportunity to master up-to-date methods of emergency rescue operations and develop common rules for solving emerging problems taking into account available information on best practices in oil and gas industry.
Alert system for employees and communities located near the Chinarevskoye Field
The Company is constantly improving internal procedures aimed at alerting and preventing emergency response cases, thus in 2022 the Company created and maintained alert systems at Nostrum production facilities. The duty dispatch service promptly transmits information about the occurrence of accidents and emergencies to EOS-1 and EOS-2 (office) to notify the management of the Company and government agencies.
In the event of emergency, at the first level of emergency response, first of all, regular employees and contractor personnel located at Nostrum production facilities, as well as emergency response teams involved in the accident response are first notified. High priority rescue and evacuation activities are performed to protect them. Territorial executive authorities (akimats) are notified of an accident in accordance with the notification scheme in case of a threat of the spread of adverse factors.
In the event of major accidents, operational teams of the second level are organized in the company’s office in Uralsk. If necessary, the evacuation of personnel of the emergency facility and communities in a zone of possible hazard is organized.
Firefighting activities arrangement
The Company systematically arranges operational control over compliance with industrial safety requirements, internal audits of the management system, conducts analyses of and processes the results of incidents and inspections, develops and monitors the implementation of corrective and preventive actions.
All Nostrum facilities at Chinarevskoe Field and Terminal are fire and explosion hazardous. Therefore, fire safety rules were developed for all facilities and controls over compliance with the rules are in place. These activities include:
- obligatory preventive inductions, fire safety training, control by line supervisors and responsible persons over the performance of work,
- inspection of Ansar-S-group by an authorized body and fire inspectors,
- project expertise as to compliance with fire safety requirements during the reconstruction and technical upgrade of production facilities,
- timely maintenance and function control of systems and fire protection means of facilities (by contractor – Batys Energon LLP), and;
- continuous control of serviceability of fire- and explosion-hazardous process equipment and compliance with process flow charts.
Civil defense and emergency prevention measures
In 2022, in line with RoK legislative requirements, Civil Defense Plan annexes were revised. A civil defense for personnel training was organized in the Company’s offices. A special tactical exercise was conducted with the office staff on emergency evacuation from the building in case of fire and the provision of medical assistance. In 2022, in accordance with the order of the West Kazakhstan Emergency Situations Department, 160 civil gas masks GP-7 with “Breeze” filter boxes were purchased for all office staff.
In 2022, the West Kazakhstan Emergency Situations Department held inspections of the Chinarevskoye field and the office on fire safety, civil defense and emergency situations and no violations were found. During the field inspection on fire safety, 26 violations were identified, 25 of which were eliminated, one violation of fire-retardant treatment of metal structures at GTU-3, that was identified, will be addressed in April 2023.
2023 targets and initiatives
Indicator | Measure | Target |
Lost Time Injuries | 12 month Rolling Frequency | 0.85 |
Total Recordable Incidents | 12 month Rolling Frequency | 1.9 |
Total Recordable Incidents | 12 month Rolling Frequency | 0.75 |