Kreuz Subsea “QHSE Policy”

Kreuz Subsea and its related companies, operating as Integrated Offshore Subsea Services Providers for the Oil & Gas industry, are committed to conceiving, planning and executing activities and projects, in full accordance with the terms of the definition of “Sustainable Development”:

“Meeting the needs of the present,
Without compromising the ability of future generations to meet their owns needs”

(United Nations World Commission on Environment and Development -96th plenary meeting -11 December 1987)
We consider that we must:

  • Prevent ill-health, injury and pollution
  • Preserve health and well-being of our Team Members, Subcontractors, Clients and Community as well as the Environment. Well-being preservation encompasses safe behavior, fight against drugs, prohibition of alcohol at work, smoking restriction, safe driving practices & conservation of Energy.
  • Identify the needs of our Clients and satisfy them in delivering services and accompaniments perfectly fitted to match the evolutions of their requirements.
  • Assess and Enhance the Competencies of our Team Members, ensuring availability of resources which allow them to develop their individual skills and competencies in order to help perform their work in accordance with this Policy.

 

We give full authority to Companies and third parties personnel who operate on our worksites to intervene when unsafe acts and / or unsafe conditions have been identified, in accordance to the Stop Work Policy and Behavioral Intervention Program.

 

Competencies Assessment and Enhancement”, “Hazard Identification and Risk Analysis”, “Stop-Work”, ‘Management of Change”, “Incident Reporting and Investigation”, “Lessons Learnt”, and “Personal Protective Equipment” are requirements built into our Integrated Management System (IMS).

 

Companies are committed to providing secure arrangements for our personnel, premises, equipment and activities. We shall protect against activities both conscious and negligent which may cause harm to our operations. The Companies’ need for protection shall be met by our adherence to National and International legal requirements that balance the need for protection of employees and third parties.

 

The Chief Executive Officer, assisted by the QHSE Director, shall take ultimate responsibility accountability and authority for establishment, implementation and continuous improvement of our IMS, in compliance with ISO 9001, ISO 14001, OHSAS 18001 Standards, SOLAS, MARPOL, STCW, MLC2006, the respective Flag State Administration, and in accordance with the International Marine Contractors Association (IMCA) guidance, and considering the guidelines provided by the International Association of Oil & Gas Producers (OGP).

 

At offshore worksites, Vessel Masters/Superintendents and/or Offshore Construction Superintendents take responsibility for adherence to this policy and to the entire IMS as a whole.

 

The QHSE Director endorses specific responsibility for ensuring that IMS is established, implemented and maintained in accordance with the international codes and standards mentioned above and for ensuring that audit reports for IMS performance, are presented to CEO and Vice-Presidents for review and approval.

 

Each informed Team Member is expected to give their personal commitment in accordance with this policy.”

Kreuz Subsea “Stop Work Policy”

It is the goal of Kreuz Subsea Group Pte Ltd and its related corporations (“Companies”) to provide a safe working environment at all its work sites. All employees of the Companies shall have the authority to stop any activity that they may deem to be unsafe or pose imminent danger.

 

There shall be no blame or fault put on any worker calling for “Stop Work” even if, upon investigation, the “Stop Work” order was deemed unnecessary. The “Stop Work” order shall be applied in good faith. The individual’s decision to stop work will have the full support of management.

 

All persons regardless of position, seniority or discipline has the right, authority and duty to apply the Stop Work policy if in their opinion or judgment, such an activity is deemed to have the potential to cause harm. As timing is a critical factor there shall be no delay or hesitation by any employee in calling an activity to cease to avoid any potential incidents. Resumption of work shall commence only after a reassessment or risk assessment of the task has taken place and final approval by the person in authority at the worksite.

 

The Companies are founded on the principle of continuous improvement. All aspects of our operations shall be audited to ensure that the principles of “Stop Work” have been enforced to the Companies’ standards and the expectations of those under our stewardship. Channels of communication shall be made available to employees in confidence to ascertain the effectiveness of the stop work policy.

 

As an employee or contractor of the Companies, you are empowered to stop any work that does not comply with this policy, and I, the undersigned, give my commitment to you that there will be no repercussion.”

Kreuz Subsea “Prohibition of drugs and alcohol Policy”

 

“Kreuz Subsea Group Pte Ltd and its related corporations (“Companies”) have recognised the risks involved with drugs and alcohol and have adopted the “Zero-Tolerance” policy for its use and possession when on Companies premises or business.

 

No person, including the Companies employees, contractors and visitors, shall be permitted to enter any work location if they are under the influence of alcohol, illegal drugs or improperly utilised medical drug. Companies reserve the right to perform drug and alcohol testing at any time.

 

Entry into any work location is conditional upon the Companies’ right to search personnel and their belongings for prohibited items. Searches may be conducted by authorised personnel in a private and in as discreet a manner as possible.

 

Being under the effects, in possession or use of any prohibited items, failure to consent to a drug and alcohol test, failure to consent to inspection of person and personal belongings may be grounds for consequence management.”

Kreuz Subsea “Non Smoking Policy”

 

While it is recognised that everyone makes a personal choice whether to smoke or not, medical evidence clearly points out the fact that smoking and second hand smoke can cause irreparable damage to the body.

 

Kreuz Subsea Group Pte Ltd and its related corporations do not allow smoking in any public area, including:

  • Any permanent and/or temporary offices, accommodations or hallways.
  • Common areas such as galley, recreation room, etc;
  • Storerooms or warehouses
  • First Aid Clinics
  • Mechanical or electrical spaces.
  • Any other area designated by the senior person in charge.

 

Where smoking is permitted, it shall be clearly indicated as a designated smoking area.

 

It is the responsibility of employees utilising the designated smoking areas to ensure its general cleanliness and upkeep at all times and to ensure no cigarette butts remain lit, which may lead to a fire.


Special Note: Kreuz Subsea strongly discourages Divers to smoke. Smoking has been proven to be a predisposing cause of Decompression Illness. Reference Study: Buch DA, El Moalem H, Dovenbarger JA, Uguccioni DM, Moon RE. Cigarette smoking and decompression illness severity. Aviat Space Environ Med. Dec 2003;74(12):1271-4.

Kreuz Subsea Teammate’s General Duties and Responsibilities, Personal Commitment

 

“As a Kreuz Subsea Team Member I shall:

  • Comply with Kreuz Subsea Policies and with all relevant statutory regulations,
  • Familiarize myself with Kreuz Subsea procedures, and I shall carry out my activities in accordance with those procedures,
  • Familiarize myself with all information issued by Kreuz Subsea referring to the safe use of equipment, plant and materials,
  • Inform the Supervisors, Safety Representative and/or the Kreuz Subsea QHSE Department of any potential hazards which I have identified during the execution of my duties,
  • Actively participate in the behavioural and hazard observation program of Kreuz Subsea,
  • Actively participate in all QHSE meetings. My attendance is mandatory,
  • Actively participate in training sessions relevant to my job,
  • Maintain my “competencies assessment and enhancement scheme” folder,
  • Maintain, as appropriate to my status, an in date medical certificate for fitness for working offshore and / or for diving,
  • Maintain in-date survival and fire-fighting certificates and any additional requirement, which may be introduced by the company,
  • Provide documented evidence to my immediate work site supervisor of compliance with the preceding paragraph.
  • Ensure the health and safety for me and for any other personnel who may be affected by my acts or omissions at work.
  • Co-operate with other personnel and their supervisors in order to ensure compliance with safe working practices.
  • Ensure that the standard of work of my immediate colleagues complies with the required standards. I have the duty to ensure that I do not:
    • Compromise the safety and integrity of plant and equipment.  o Undertake any task or operation unless I have received adequate instruction and training and have the appropriate tools, equipment and protective clothing.
    • Carry out any tasks or operation in such a manner as may endanger my safety or the safety of others.
  • Take care of my Personal Protective Equipment and carry it with me for each mobilization.

 

Regardless of my position, seniority or discipline, I have the right, authority and duty to apply the Stop Work policy if in my opinion or judgment, such an activity is deemed to have the potential to cause harm. As timing is a critical factor there shall be no delay or hesitation by myself in intervening and in calling an activity to cease to avoid any potential incidents. I shall set an example of safe and excellent behaviour.”

 

“On-the-job” Risk Assessment, Buddy System and Supervision; Personal Commitment

 

“For Kreuz Subsea, the Hazard Identification and Risk Exposure Assessment must remain a CONTINUOUS PROCESS. Following the three levels of “Hazard Identification and Risk Assessment” defined by the Association of Oil & Gas Producer (OGP), an additional level of risk assessment is essential. In short, this fourth level consists in maintaining a continuous assessment / action process while my work is being actually carried-out.

 

While working as a Kreuz Subsea Team Member I have the duty and the responsibility:

  • To identify the changes which occurs within my working environment,
  • To assess the gaps which exist between the expected residual risks and the real situation that I am facing while executing the job / task,
  • To assess the adequacy of the tools, barriers and control defined from the previous risk assessments,
  • If any doubt, to implement the Stop Work Policy AND to immediately inform my Supervisor,
  • If required, to actively participate in the implementation of the Management of Change Procedure.

 

While performing my work, I shall comply with the Buddy System, “Work safely and look out after one another”, to be able to:

  • Immediately alert my Team Mate, in the event of an unsafe act and/or an unsafe condition.
  • Immediately render assistance to my Team Mate in the event of an emergency.”

Fitness to Work Offshore; Personal Commitment

 

“As an offshore Kreuz Subsea Team Member, my mental and physical fitness are essential for my safety and for the safety of my co-workers. Unfit, I represent a hazard for myself and for my teammates.

 

As my employer, Kreuz Subsea is responsible for ensuring that a medical assessment of my fitness to work offshore has been performed. I must have a valid medical certificate provided by a Medical Doctor “Oil & Gas UK registered” (United Kingdom Offshore Oil and Gas Industry Association, trading as Oil & Gas UK).

 

International guidelines do not set any lower or upper age limit for medical fitness to work offshore. However, regardless of my age and considering the scope of work and / or the client’s requirements, the Kreuz Subsea management can require an additional medical assessment of my fitness to work, As a Kreuz Subsea Team Member, I remain personally responsible to:

  • Keep fit throughout the year. I know that smoking, in addition to the well-known adverse effects on the human body, constitutes a risk factor for occupational diseases and long term health impairments.
  • Report a complete and accurate medical history to my medical doctor as the time of medical assessment.
  • Report any temporary unfitness to my Supervisor as a result of illness or accident occurring between medical examinations including illnesses and/or injury occurring on the worksite throughout the project I am working on.
  • Report any treatment/medication taken by me before the project, or on the worksite throughout the project.

 

I am aware of the main criteria for Fitness to Work Offshore, as listed below:

  • No known physical or mental conditions that limits my ability to do the job.
  • No known physical or mental conditions that will jeopardize my safety or the team (e.g. loss of consciousness, orientation, panic attack).

 

If have any doubt about my personal fitness, at any time throughout the project mobilization and execution, then I must immediately inform my supervisor.”

Fitness to Dive; Personal Commitment

 

As a commercial diver, my mental and physical fitness are essential for my safety and for the safety of my co- workers. Unfit, I represent a hazard for myself and for my teammates. Kreuz Subsea is responsible for ensuring that a medical assessment of my fitness to work offshore and fitness to dive as an Offshore Commercial Diver has been performed. I must have a valid Medical Certificate for fitness to work offshore provided after a medical examination performed by a Medical Doctor, Oil & Gas UK registered (United Kingdom Offshore Oil and Gas Industry Association, trading as Oil & Gas UK). I must also have a valid Medical Certificate for fitness to Dive signed by a Diving Medicine Specialist. The IMCA guidance note D 20/01 helps to identify Oil & Gas UK registered Doctors, who are also specialized in Diving Medicine.

 

International guidelines do not set any lower or upper age limit for medical fitness to dive. However, regardless of my age and considering the scope of work and / or the Client’s requirements, the Kreuz Subsea Management can require an additional medical assessment of my fitness to dive, As a Diver, I remain personally responsible to

  • Keep fit throughout the year. I know that smoking, in addition to the well-known adverse effects on my body, constitutes a risk factor for Decompression Illness, for Occupational Diseases and for Long Term Health Impairments.
  • Report a complete and accurate medical history to my medical doctor as the time of medical assessment.
  • Report any temporary unfitness to my Diving Supervisor as a result of illness or accident occurring between medical examinations including illnesses and/or injury occurring on the worksite throughout the project I am working on.
  • Report any treatment/medicament taken on the worksite throughout the project.

 

I am aware of the main criteria for Fitness to Dive, as listed below:

  • No known physical or mental conditions that limits my ability to do the job as a diver (to swim, to communicate, etc.)
  • No known physical or mental conditions that will jeopardize my safety or the safety of my team (e.g. loss of consciousness, orientation, panic attack)
  • No known physical or mental condition that might get worse as an effect of diving (e.g.conditions leading to baro-traumatism)
  • No known physical or mental condition that could predisposes me for occupational illness (e.g. presence of Patent Foramen Ovale).

 

If have any doubt about my personal fitness, at any time throughout the project mobilization and execution, then I must immediately inform my supervisor.”