INCIDENT REPORTING AND FOLLOW-UP STANDARD Mandatory

Incident Investigation And Follow-Up Procedure Specification

Incident Investigation and Follow-Up Procedure

Purpose
 To ensure that all incidents, near misses and hazardous situations are reported, investigated and
analyzed to identify where management controls have failed and to make recommendations to restore,
or identify new controls.
 To ensure dissemination of lessons learned and prompt actions to correct the situation and prevent
recurrence both locally and at other locations.

Who is this for?

 Directors, Asset Managers and Supervisors;
 HSE Professionals;
 Contractors
 Employees

Scope
The scope of this Procedure is the reporting, classification, investigation and follow-up of all incidents,
including near misses and potential incidents. Follow-up includes notification, analysis, recommendations,
implementation of actions arising from the investigation, dissemination of learning.

Requirements for Incident Reporting, Investigation, and Follow-Up – All incidents

Nr. Task Accountable Timing after

incident
Make the site safe and initiate emergency response in line with Worksite Immediately
local requirements in cooperation with Emergency Coordination Supervisor
1.1
Team. Collect immediate eyewitness statements, facts and
photographic evidence of the circumstances, where possible.

1.2 Inform Site/Activity Owner about an incident Worksite 1 hr

Note: Supervisor
All injuries resulting in medical treatment or worse, spills without
secondary containment and High Risk Incidents shall be also
reported directly to Sakhalin Energy (SE) HSE General Manager
before Fountain notification.
All violations of the SE Life Saving Rules (LSR) shall be entered
as incidents into Fountain.
Potential incidents (including unsafe acts and conditions)
with significant risk (potential consequence rated 4 or 5 on risk 24 hrs
assessment matrix) or high learning value shall be entered into
Fountain.
"Minor" potential incidents shall be recorded in the appropriate 72 hours
local system such as a Observation and Intervention cards or
HAZID Cards and/or reported to a supervisor / HSE officer for
learning.
All external parties (including Authorities, Lenders and
Shareholder) shall be notified in consultation with the SE HSE
General Manager.

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 INCIDENT REPORTING AND FOLLOW-UP STANDARD Mandatory

Incident Investigation And Follow-Up Procedure Specification

Nr. Task Accountable Timing after

incident
1.3 Make a preliminary assessment of actual severity and potential Site/Activity 24 hrs
risk using the “Risk Assessment Matrix” (RAM). For assessment Owner with
of risk, firstly assign a potential consequence severity and then (executor)
estimate the likelihood of such consequences using the definitions
in the matrix. Use the Shell Performance Monitoring and SEIC HSE
Reporting (PMR) Specification for details on incident classification General
including whether it is work related. All incidents should be treated Manager
as work related unless decided otherwise. (contributor)
Note:
The final classification of an incident with people or environmental
consequences is determined by the SE HSE General Manager.
For injurious incidents, both the Corporate Health and Safety
Managers shall be consulted on the incident classification.
Investigation of Acute and Chronic Occupational Illnesses shall be
conducted in compliance with the Investigation of Occupational
Illnesses Specification
For classification of LSR incidents use the User Guide for LSR
RAM assessment.

1.4 Enter an initial incident report into the Fountain Database; Incident 24 hrs
The following incident classifications shall not be entered into Owner
Fountain without approval from the Asset Manager and HSE
General Manager (or their delegates) -
Mark of Actual impact as 4 or 5
Potential of an incident on the RAM as RED
API Process Safety Incident flag
Note:
For Incidents associated with transportation of goods the Incident
Owner is the Site or Contract Holder and should be investigated
by Site personnel, with involvement of a representative from the
supplier e.g. Logistics or Materials Management Department.

1.5 Select an investigation team depending on the incident risk rating: Incident 24 hrs
Low: Worksite Supervisor, HSE Adviser, Contractor Owner
Representative. (executor)
Medium: Site/Activity Owner, HSE Adviser, Contract Holder /
Contractor Representative. For potential LTI’s the CEO will Site/Activity
appoint a CED Sponsor for the investigation. Owner
High: CED representative as team leader, HSE Adviser, Contract (contributor)
Holder, Contractor Senior Management, accredited Tripod BETA
Facilitator, subject matter experts, External authorities (Labor SE HSE
Inspection, Rostechnadzor, etc.) – consult C-HSE Department for General
guidance. Manager
(contributor)

1.6 Assign Investigation Team Leader and plan investigation in line Incident 24 hrs
with Terms of Reference for Significant and High Risk Incident Owner
Investigation (Appendix 4) or Terms of Reference for Medium Risk
Incident Investigation (Appendix 5) depending on the incident
classification.

RESTRICTED Document 0000-S-90-04-O-0020-00-E Appendix 2, Revision 01 Valid from 01.10.2011 to 01.10.2016

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 INCIDENT REPORTING AND FOLLOW-UP STANDARD Mandatory

Incident Investigation And Follow-Up Procedure Specification

Nr. Task Accountable Timing after

incident
1.7 The Investigation Team Leader shall organize regular Investigation 3 weeks
coordination meetings with the Investigation Team Members to Team Leader
control the investigation process: (executor)
Update on current status of investigation;
Maintain clear understanding of the required deliverables and key Incident
milestones e.g. start, interim report and final report; Owner
Validate of all findings; (contributor)
Conduct underlying cause analysis session; (Tripod BETA for
selected Medium Risk, Significant and High Risk Incidents);
Issue a final incident investigation report;

1.8 Investigate incident to determine the underlying causes, using a Investigation 3 weeks
methodology appropriate to the incident severity. Ensure action Team Leader
items address all immediate causes and main underlying causes:
Ensure action items are SMART (Specific, Measurable,
Achievable, Realistic and Time bound);
State recommendations that are not directly related to the incident
chain of events in a separate paragraph of the incident
investigation report;
Ensure that the report contains as a minimum: Place, time, date,
description of the incident, Actual and Potential Consequences,
Details of barriers, barrier failures, and action items to prevent
reoccurrences.
All Medium and High risk incidents require an investigation report.
For Medium risk incidents the report details shall be
commensurate with the risk and complexity of the incident. SE HSE
For High Risk Incidents and incidents with actual damage RAM3+ General
a report may be disclosed externally to Lenders and Shareholders Manager
(on request) in accordance with the Methodology for Classifying
and Remediating Incidents and Breaches, therefore they shall be
approved by the Incident Owner and the HSE-General Manager
(or designate)
Note:
For investigation materials / specific tools use Sakhalin Energy
HSE web page or contact Corporate Safety Manager.

RESTRICTED Document 0000-S-90-04-O-0020-00-E Appendix 2, Revision 01 Valid from 01.10.2011 to 01.10.2016

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 INCIDENT REPORTING AND FOLLOW-UP STANDARD Mandatory

Incident Investigation And Follow-Up Procedure Specification

Nr. Task Accountable Timing after

incident
1.9 Arrange incident review: Incident 30 days
Challenge and test investigation team to ensure all active and Owner
underlying causes are identified; (executer)
Determine appropriate lateral learning method to ensure that all
key personnel are adequately informed to prevent a recurrence; SE HSE
Confirm actions and action parties. General
The nature of this review depends on the incident risk: Manager
(contributor)
Low: As a minimum, discuss with the line manager.
Medium: (and Low with significant learning): Discuss in a Review
Panel chaired by the Incident Owner. Site/Activity
Owner
High: Significant incidents, (and those selected by the HSE
(contributor)
General Manager: Reviewed by the HSE Management Committee
chaired by the CEO.
Investigation
Team Leader
(contributor)

1.10 In case of Medium and High Risk Incidents to restore the Incident 60 days
compliance with Sakhalin Energy HSE Standards Owner

1.11 If compliance with Sakhalin Energy Standards cannot be restored Action 14 days
within the initial period, provide the Intercreditor Agent and the Parties 5 days
Phase 2 Senior Lenders with the Remedial Action Plan through C-
HSE (HSESAP Corporate Focal Point).
For Low Amber incidents
For High Amber and Red incidents

1.12 Enter investigation report into the Fountain Database; Incident 30 days
Owner

1.13 If there is significant learning for the organization, disseminate SE HSE 50 days
learning across SE Assets and where required to Shareholders. General
Manager
(executer)

1.14 Disseminate learning from incident investigations within Sakhalin Incident As per
Energy. Owner agreed dates
(executer)

1.15 Complete all remedial actions from the incident and provide a Action 12 months
quarterly update on their status to the Lenders. Parties and
Fountain
Focal Point

RESTRICTED Document 0000-S-90-04-O-0020-00-E Appendix 2, Revision 01 Valid from 01.10.2011 to 01.10.2016

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 INCIDENT REPORTING AND FOLLOW-UP STANDARD Mandatory

Incident Investigation And Follow-Up Procedure Specification

Specific Requirements for Incident Reporting, Investigation and Follow Up - Significant and High
Risk Incidents

Nr. Task Accountable Timing after

incident
2.1 Send Incident Notification Form to required Shareholders and SE SE HSE 24 hrs
Management via email: General
UI Incident Notification Template Manager

2.2 In case of Medium Risk incidents (RAM 4,5) and High Risk SE HSE 5 days
Incidents notify Loan Compliance Team via e-mail: (SEIC Loan Assurance
Compliance SEIC-FD-CO) who are responsible then to notify the Manager
Intercreditor Agent and the Phase 2 Senior Lenders.

2.3 In case of a suspected work related fatality, arrange an initial SE CEO 1 week
meeting / teleconference with Shareholder Representatives

2.4 Analyse significant and high potential incidents using Tripod Beta SE Safety 1 month
methodology. Manager
Prepare a draft investigation report, draft Significant Incident
Review Briefing Note and supporting Learning from Incidents
Alert. These documents should be written in English and Russian.

Note:
Extensions shall be approved by the SE CEO or his delegate.

2.5 Review and approve the materials from previous step in a meeting SE HSE 2 months
involving the: General
SE CEO Manager
SE HSE General Manager
Shareholder Representatives

2.6 Arrange, prepare and conduct a Significant Incident Review (SIR) SE HSE < 3 months
meeting with the: General
SE CEO Manager
SE HSE General Manager
Shareholder Representatives
Confirm the final classification of the incident at the SIR meeting
Note:
The need to hold a SIR meeting for a High Potential incident is at
the discretion of the SE CEO.

2.7 Enter SIR actions into Fountain Impact. Incident 1 week after
Owner SIR

2.8 Submit a follow-up report to the TCM, which describes the status SE HSE 12 months
of actions and the results of (self-) assurance on gap closure. General
Enter report into FIM. Manager

2.9 Complete actions within 12 months of the incident. Action Parties 12 months
2.10 Enter a close-out report explaining how corrective actions have Incident 12 months
been implemented into the Fountain Database. Owner

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 INCIDENT REPORTING AND FOLLOW-UP STANDARD Mandatory

Incident Investigation And Follow-Up Procedure Specification

Activity/Responsibility Matrix (Low Risk Incidents)

Key Definitions

EXE Execute (executing), Performing a task

CON Contribute (contributory), Contribute to a task
CHK Check (controlling), Check, verify results
i Receiving information

Activity Fountain
Site/Activity Incident Local HSE Investigation
Task definition Worksite administrator Others
Owner Owner officer Team
Supervisor

Initiate emergency response,

1 collect initial facts and eye- EXE
witness statements. i i i

Preliminary assessment of
2 severity, risk and RAM EXE CON
classification. i i i

Register incident in Fountain

3 EXE
database. i i i i i

Confirm Incident Owner and

determine level and type of
4 CON EXE CON
investigation. Appoint i
Investigation Team.

Investigate, analyse findings,

5 CON CON CON CON EXE
identify underlying causes.

Define findings and

6 recommendations, propose CON CON CHK CON EXE
actions and action parties.
i

Disseminate learning points

7 EXE CON
within asset. i

Ensure effective
8 implementation of agreed CON EXE CON
actions. i i

Check close-out of action

9 EXE CHK
points i i

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 INCIDENT REPORTING AND FOLLOW-UP STANDARD Mandatory

Incident Investigation And Follow-Up Procedure Specification

Activity/Responsibility Matrix (Medium Risk Incidents)

Activity SE HSE Fountain

Site/Activity Incident Local HSE Investigation
Task definition Worksite General administrator Others
Owner Owner officer Team
Supervisor Manager

Initiate emergency response,

1 collect initial facts and eye- EXE
witness statements. i i i

Preliminary assessment of
2 severity, risk and RAM EXE CON
classification. i i i

Register incident in Fountain

3 EXE
database. i i i i i i

In case of Medium Risk

incidents (RAM 4,5) and High
4 EXE
Risk Incidents notify Loan
Compliance Team
Confirm Incident Owner and
determine level and type of
5 CON EXE CON CON
investigation. Appoint i
Investigation Team.

Investigate, define findings,

6 CON CON CON CON EXE CON
identify underlying causes.

Analyse findings, develop

7 recommendations, propose CON CON CHK CON EXE CON
actions and action parties. i

8 Incident Review CON EXE CON CON

Disseminate learning points

9
within asset
EXE CON
i
Disseminate learning points
across SEIC assets and EP
10 EXE
projects, if there is significant i
learning for the organization
Enter final investigation
report, approved corrective
11 EXE
actions, and action parties i i i i i
into Fountain database

Ensure effective
12 implementation of agreed CON EXE CON
actions. i i

Check close-out of action

13
points
EXE CHK
i i i

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 INCIDENT REPORTING AND FOLLOW-UP STANDARD Mandatory

Incident Investigation And Follow-Up Procedure Specification

Activity/Responsibility Matrix (Significant and High Risk Incidents)

Activity SE HSE Fountain

Site/Activity Incident Local HSE Investigation
Task definition Worksite General administrator SEIC CEO Others
Owner Owner officer Team
Supervisor Manager

Initiate emergency response,

1 collect initial facts and eye- EXE
witness statements. i i i

Preliminary assessment of
2 severity, risk and RAM EXE CON
classification. i i i

Register incident in Fountain

3
database.
EXE
i i i i i i i
Send Incident Notification to
Shareholders, Loan
4
Compliance Team and SEIC EXE
Management (within 24h.)
Meeting/Teleconference
with Shareholder
5
representative CON CON EXE
(In case of a suspected work related
fatalities)
Confirm Incident Owner and
determine level and type of
6
investigation. Oppoint
CON EXE CON CON CON
i
Investigation Team.

Investigate, define findings,

7
identify underlying causes.
CON CON CON CON EXE CON

Analyse findings, develop

8 recommendations, propose CON CON CHK CON EXE CON
actions and action parties. i
Submit a draft investigation
report, Draft SIR Briefing
9
Note and supporting LFI Alert CON CON EXE
i
to Shareholder rep.

Significant Incident Review

10
Panel
CON EXE CON
i i i i

Submit a follow-up report to

11
the Shareholder rep. EXE CON
i i

Disseminate learning points

12
within asset EXE CON
i i
Desseminate learning points
across SEIC assets and EP
13
projects, if there is significant
EXE
i i
learning for the organization
Enter final investigation
report, approved corrective
14
actions, and action parties
EXE CON
i i i i i
into Fountain database

Ensure effective
15 implementation of agreed CON EXE CON
actions. i i i
Enter a close-out report
explaining how corrective
16
actions have been EXE CHK CON
i \

i i
implemented into Fountain

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