SAFETY, HEALTH AND ENVIRONMENT Guide for Managers
Our goals are simply stated: no harm to people and no damage to the environment. In pursuit of our goal we are striving to become one of the safest resource companies in the world.
Updated: February 2015 The control version of this document can be referenced at PotashCorp’s intranet site.
POTASHCORP’S COMMITMENT TO Safety, Health and Environmental Performance
POTASHCORP’S SAFETY, HEALTH AND ENVIRONMENTAL POLICY Everybody who works for PotashCorp, anywhere, is responsible for PotashCorp’s Safety, Health and Environmental (SHE) performance and Security. Good SHE performance is critical to the success of our business.
Our goals are simply stated: no harm to people, and no damage to the environment. We will continue to drive down the environmental and health impact of our operations by reducing waste, emissions and discharges, and using energy efficiently. We will produce quality products that can be used safely by our customers. We strive to provide a secure working environment by protecting ourselves, our assets and our operations against risk of injury, loss or damage.
WE WILL: Consult, listen and respond openly to our employees, contractors, customers, neighbors, public interest groups and investors; Work with others – our partners, suppliers, regulators, and competitors–to raise the Safety, Health and Environmental standards of our industry; Actively communicate with the community to maintain public confidence in our commitment to SHE performance; and, Recognize those who contribute to improved SHE performance.
Our business plans and performance goals include measurable SHE targets. We are committed to meeting them.
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Table of contents
PotashCorp’s Commitment to SHE Performance _________________________________________________________________ 3 Introduction _____________________________________________________________________________________________ 6 SHE Expectations ________________________________________________________________________________________ 8
> THE FOURTEEN ELEMENTS OF THE SAFETY, HEALTH AND ENVIRONMENT GUIDE FOR MANAGERS 1.
Leadership and Accountability __________________________________________________________________________ 12
2.
Risk Assessment and Risk Management _________________________________________________________________ 13
3.
People, Training and Performance ______________________________________________________________________ 14
4.
Working with Contractors and Service Providers ___________________________________________________________ 15
5.
Facilities Design and Construction ______________________________________________________________________ 16
6.
Operations and Maintenance ___________________________________________________________________________ 17
7.
Management of Change ______________________________________________________________________________ 18
8.
Information and Documentation _________________________________________________________________________ 19
9.
Customers and Products ______________________________________________________________________________ 20
10. Community and Stakeholder Awareness __________________________________________________________________ 21 11. Emergency Management and Crisis Communications _______________________________________________________ 22 12. Incident Analysis and Prevention ________________________________________________________________________ 23 13. Assessment, Assurance, Compliance Audit and Continuous Improvement _______________________________________ 24 14. Product Stewardship __________________________________________________________________________________ 25
> KEY SHE PROCESSES 1.
Delivering SHE Assurance _____________________________________________________________________________ 27
2.
SHE Risk Assessment and Risk Management _____________________________________________________________ 31
3.
Incident Investigation Guidelines ________________________________________________________________________ 35
4.
Emergency Management and Crisis Communication ________________________________________________________ 40
5.
Incident Flash Reporting ______________________________________________________________________________ 45
6.
Biodiversity _________________________________________________________________________________________ 49
7.
Facility and Product Security ___________________________________________________________________________ 51
8.
SHE Reporting Requirements __________________________________________________________________________ 59
9.
SHE Performance Targets _____________________________________________________________________________ 61
10. SHE Reporting Definitions _____________________________________________________________________________ 63 11. Health Management __________________________________________________________________________________ 74 12. Behaviors __________________________________________________________________________________________ 76 13. Communication of Product Information ___________________________________________________________________ 79 14. Developing Safety Standards __________________________________________________________________________ 84 15. Product Stewardship _________________________________________________________________________________ 88 16. SHE Compliance with Existing and Pending Requirements ____________________________________________________ 91
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Everybody who works for PotashCorp, anywhere, is responsible for PotashCorp’s safety, health and environmental performance. Good SHE performance is critical to the success of our business
> WHAT ARE OUR GOALS? PotashCorp, as the world’s leading fertilizer producer, will be determined and unwavering in our pursuit and attainment of exceptional safety, health and environmental performance. It is our pledge to demonstrate respect for the natural environment and to work to achieve our goals of no harm to people and no damage to the environment. The successful pursuit of our goals will make us one of the safest resource companies in the world.
> HOW DO WE ACHIEVE THEM? All PotashCorp leaders will adopt the PotashCorp Safety, Health and Environmental Guide for Managers and the SHE Expectations. These encompass the complete spectrum of safety, health, and environmental risk management, including security, technical/operational integrity of facilities and equipment, and product stewardship. All facility leaders must communicate the SHE Expectations to their employees and service providers and are accountable for the delivery of SHE performance. Each facility shall have documented systems in place to meet the expectations, striving for “Safe Production” in every activity.
> WHAT IS THE BENEFIT? Effective SHE management will result in improved safety and facility performance and a cleaner environment. Ultimately, this will benefit the well being of our employees, service providers and their families, and our reputation with our stakeholders. Best in class SHE performance will help us maintain a distinctive leadership position in all areas of our business around the world.
> WHAT DOES THE GUIDE FOR MANAGERS PROVIDE? The SHE Guide for Managers provides a broad-based set of expectations integrated into Fourteen Elements of Accountability. The system will help leaders focus their organizations on critical SHE needs, forecast and allocate resources, set direction for SHE activities and consistently deliver improved SHE performance. The SHE Guide for Managers brings together people and integrated processes that meet these expectations while delivering desired, consistent business performance.
> WHO CONTROLS THE SHE GUIDE FOR MANAGERS? PotashCorp’s Senior Management will ensure that these expectations receive full facility support in order to build the SHE Guide for Managers designed around the Plan-Perform-Measure-Improve Model. Facilities have the authority and responsibility to satisfy the Fourteen Elements with processes, programs and systems that demonstrate conformance with the SHE Expectations.
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> HOW WILL WE KNOW THE SHE GUIDE FOR MANAGERS IS EFFECTIVE? Facility and division leaders will assure Nutrient Presidents, Chief Operating Officer and Chief Executive Officer that all relevant processes are in place and working effectively to manage SHE risks. This will be achieved through regular: Risk-assessment and risk-management programs; Peer reviews and self-assessments; and, Reviews of performance indicators against targets. SHE assurance will be regularly discussed between facility leaders and divisional presidents. Internal and external Safety, Health and Environmental Audits will be conducted to provide a review of key internal controls. The Safety, Health and Environment Committee of the Board of Directors will review these audits. A periodic update will be provided to the SHE committee of the board of directors summarizing progress and planned activities.
PotashCorp’s safety, health and environmental expectations
> POTASHCORP’S SHE EXPECTATIONS ARE DETAILED WITHIN THE FOURTEEN ELEMENTS OF THE SHE GUIDE FOR MANAGERS. THE SHE EXPECTATIONS OUTLINE REQUIREMENTS FOR THE MANAGEMENT OF: Occupational health and safety Process safety management Incident prevention Plant and equipment integrity Pollution prevention Environmental Stewardship Energy conservation Product stewardship Sustainable development Employee and facility security
> IN ALL OUR ACTIVITIES AND OPERATIONS, WE WILL: Comply fully with all legal requirements and meet or exceed all PotashCorp Expectations wherever we operate in the world. Provide a secure working environment by protecting our employees, service providers, assets and operations against risk of injury, loss or threats from criminal acts. Ensure that all employees and service providers are well informed, trained, engaged and committed to our SHE expectations. Recognize that safe production and environmental resource protection depends not only on reliable facilities and equipment, but also on competent people and an active SHE culture.
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No activity is so important that it cannot be done safely and without creating undue environmental risk. Regularly provide assurance that the SHE processes in place are working effectively. All PotashCorp employees and service providers are responsible for SHE performance. Facility leaders are accountable for understanding and managing SHE risks and leading with safety. Fully participate in hazard identification and mitigation, audits and assessments of safety, health, environmental and security, product stewardship, and reporting SHE performance results. Maintain public confidence in the integrity of our operations. We will actively communicate and consult with stakeholders outside the company to improve our understanding of our potential, external SHE related impacts. Expect that all employees and service providers recognize the impact they have on our operations and reputation. All service providers must operate to our standards and we will assure ourselves that their management systems and actions fully support our commitment to SHE performance. Actively and diligently pursue our goal to be one of the safest resource companies in the world with a world class environmental vision and performance.
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> ADDRESSING THE SHE EXPECTATIONS IS MANDATORY AT EVERY FACILITY THROUGHOUT POTASHCORP. The relevance, application and degree of implementation within a particular facility will be based on: The operational risk profile; Applicable PotashCorp standards and guidance documents Applicable Local, State, Provincial, National or International regulatory requirements; and, Any voluntary SHE management programs.
Facility leaders are accountable for incorporating appropriate documented systems and processes for each Expectation of the SHE Elements, for ensuring continuing progress toward PotashCorp’s SHE goals, for meeting annual SHE targets and for using the SHE audit system to confirm that these processes are effective. The content, format and terminology of SHE management and audit systems at the facility must be: Compatible with PotashCorp SHE compliance audits and assessments Appropriate to operational risks Compatible with applicable PotashCorp standards and guidance documents Relevant to regulatory and voluntary codes subscribed to by PotashCorp Referenced to all expectations set by this SHE Guide for Managers
At the same time, we will strive to standardize programs, work practices and procedures across similar facilities. At PotashCorp we will promote the transfer, sharing and adoption of SHE best practices
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The Fourteen Elements of the Safety, Health and Environmental Guide for Managers
Each SHE Element is supported by specific SHE Expectations which detail the requirements for the management of the SHE Elements. The Fourteen Elements of the Safety, Health and Environmental Guide for Managers are: 1
Leadership and Accountability
2
Risk Assessment and Risk Management
3
People, Training and Performance
4
Working with Contractors and Service Providers
5
Facilities Design and Construction
6
Operations and Maintenance
7
Management of Change
8
Information and Documentation
9
Customers and Products
10
Community and Stakeholder Awareness
11
Emergency Management and Crisis Communications
12
Incident Reporting, Analysis and Prevention
13
Assessment, Assurance, Audit and Continuous Improvement
14
Product Stewardship
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1. Leadership and Accountability
At PotashCorp our goal is to be one of the safest resource companies in the world with a world class environmental vision and performance. Leaders at all levels at PotashCorp are responsible for leading and engaging the workforce in meeting our Safety, Health and Environmental goals and objectives. Leaders will be held accountable for accomplishing this by clearly defining SHE roles, responsibilities and accountabilities, allocating required resources, measuring, reviewing and continuously improving SHE performance, and by role modeling and exhibiting exemplary SHE leadership behaviors. > EXPECTATIONS 1.1
Leaders model positive SHE behaviors by personal example both on and off the job. They must reinforce and recognize positive behaviors, while engaging in clear, two-way communication with employees and service providers on SHE issues. SHE lessons learned and best practices are shared inside and outside their facility.
1.2
SHE Management Systems are developed, documented, implemented and supported throughout the organization. The SHE Expectations are integrated into business planning and decision-making processes, ensuring that documented systems are in place to achieve them.
1.3
Leaders integrate into their business activities clear, measureable SHE annual targets and objectives.
1.4
Product stewardship is included in the business plan, communicated, budgeted, followed, and maintained appropriately.
1.4
Leaders’ SHE performance is assessed against their annual SHE objectives
1.5
Leaders assess the ability of others to perform their tasks in a safe, healthy and environmentally sound manner. Training needs are evaluated and competent training resources provided as necessary.
1.6
Leaders assess their level of ability with respect to the Leadership Core Competencies and are committed to pursuing ongoing leadership development opportunities and enhancing their capacity for safety leadership.
1.7
Leaders analyze results from the organizational employee engagement survey. Areas for improvement are addressed through the development and implementation of action plans.
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2. Risk Assessment and Risk Management
Management of risk is a continuous process and the cornerstone of all the SHE Elements. We will regularly identify the hazards and assess the risks associated with our activities. By taking appropriate action to manage the risks, we will prevent or reduce the probability and impact of incidents. > EXPECTATIONS 2.1
Leaders put into place and promote the use of processes to identify hazards associated with PotashCorp’s activities, assess risks, control the hazards and manage the risks to acceptable levels. This includes a robust field level hazard assessment process with integrated coaching.
2.2
Existing operations, products, business developments, acquisitions, modifications, new projects, closures, divestments and decommissioning are assessed for potential hazards and risks to employees, service providers, facilities, public, customers and the environment.
2.3
Assessed risks are addressed by appropriate levels of management.
2.4
Risk assessments and risk management/control measures are referenced in project approval documentation.
2.5
Risk assessments are updated at specified intervals and as changes are planned.
2.6
SHE risks are considered in the corporate risk management framework including objectives and targets, reviewed on a regular basis,and updated as required.
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3. People, Training and Performance
Our employees’, contractors, and service providers’ performance is critical to PotashCorp’s success; therefore, our workforce will be carefully selected, trained and their skills and competencies regularly assessed. > EXPECTATIONS 3.1
Employees and service providers must practice, encourage and reinforce safe, healthy and environmentally sound practices.
3.2
SHE roles, responsibilities and accountabilities must be developed and used to define individual performance targets. These are documented and feedback on personal performance is provided annually.
3.3
Training roles, responsibilities and accountabilities must be developed and used to define individual performance targets. These are documented and feedback on personal performance is provided annually.
3.4
Recruitment, selection and placement processes will ensure that employees and service providers are trained, qualified, competent and fit for duty.
3.5
Training provided to our employees and service providers must meet minimum regulatory and company requirements addressing product stewardship issues and must be evaluated to determine its effectiveness and are measurable.
3.6
New or transferred employees, service providers and other visitors shall undergo appropriate site orientation/induction training that covers applicable SHE rules and emergency procedures.
3.7
With employees’ and service providers’ involvement; hazards must be identified, and their risks mitigated.
3.8
Each facility has access to an appropriate level of medical support and resources that promote health and wellness.
3.9
An effective substance abuse prevention policy will be utilized to protect our employees, service providers and facilities.
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4. Working With Contractors and Service Providers
Contractors, Service Providers and suppliers are key to our SHE performance. PotashCorp will assess their capabilities and competencies to perform work on our behalf. We will work together to ensure our SHE expectations are aligned and monitored to ensure they are met. We will ensure our procurement processes assess the ability of contractors to meet our SHE Expectations.
> EXPECTATIONS 4.1
Pre-qualification, selection and retention criteria are established for work performed by service providers, and suppliers, must include a system for selection that assures their compliance with SHE expectations.
4.2
Hazards and risks associated with service providers and procurement activities are identified, managed and communicated.
4.4
Clear deliverables and performance standards are agreed upon and systems are put in place to assure compliance, including appropriate key performance indicators.
4.5
Where applicable, purchased products and services are, verified as meeting national/international safety, health and environmental standards.
4.6
Joint venture and alliance partnerships have appropriate SHE management systems aligned with those of PotashCorp and meet legal compliance requirements.
4.7
Contract Terms and Conditions include provisions for safety and environmental performance.
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5. Facilities Design and Construction
New facilities and modifications to existing facilities will be designed, procured, constructed and commissioned to enable safe, secure, healthy and environmentally sound performance by using recognized standards, procedures and management systems.
> EXPECTATIONS 5.1
Baseline technical and environmental data are collected before the development of any new operation, facility or major modification.
5.2
Facilities are designed and constructed using technology that balances commercial risks and financial benefits. Doing so enables PotashCorp to manage technical risk and minimize air emissions, water and waste discharges, impacts on biodiversity and other environmental impacts, while meeting federal, state/provincial and local SHE regulatory requirements. Where these regulatory requirements are absent or inadequate, standards are set that protect people and the environment.
5.3
Project management systems and procedures address SHE accountabilities are documented and well understood. The designated technical/engineering authority formally approves design, procurement and construction standards. Formal design review, verification and validation studies are carried out based on risk assessment.
5.4
Operational, maintenance and SHE expertise (including security) are integrated at the inception of a project/design stage. Experience from previous projects and current operations are applied. Facility safety managers/coordinators must review and approve all capital project requests.
5.5
Potential hazards are identified and SHE risks (including security) assessed using appropriate risk assessment tools (e.g. process hazard analysis) at specific stages of a project, from concept through to start-up. Risks are mitigated through risk-management techniques.
5.6
Deviations from design standards are identified, managed and approved at an appropriate management level, with the reasons documented and retained. As a minimum, deviations must comply with regulatory standards.
5.7
Quality assurance and inspection systems are in place to ensure that facilities meet design and procurement specifications and that construction is in accordance with approved standards.
5.8
Documented pre-startup reviews are carried out for all newly installed or modified equipment to verify that construction is in accordance with design, all required verification testing is complete and acceptable, and all recommendations/deviations are closed out.
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6. Operations and Maintenance
Facilities will be operated and maintained within the approved design to ensure safe, secure, and environmentally sound performance and in compliance with all applicable laws, regulations and permit conditions. We will strive for “Safe Production” and environmental protection at all times and will not compromise safety or the environment in any of our operations and maintenance activities. > EXPECTATIONS 6.1
Applicable regulatory requirements are met or exceeded and operational/ mechanical, structural integrity is maintained by use of clearly defined and documented Inspection and maintenance systems.
6.2
Key operating, safety and environmental parameters are established and regularly monitored. Employees and service providers must understand their roles and responsibilities to operate within these parameters. Deviations must be documented and approved at the appropriate management level.
6.3
Clearly defined start-up, operating, maintenance and shutdown procedures must be in place, with defined accountability and responsibility.
6.4
Clearly defined parameters for environmental compliance during startup, shutdown and process malfunctions.
6.5
Reliability and availability of protective systems are ensured and documented through appropriate testing and maintenance programs. Temporary disarming or de-activation must be documented and approved by the appropriate management level.
6.6
Risks created by separate work activities that may impact each other must be assessed and the risks managed appropriately.
6.7
SHE impacts associated with emissions, effluents, noise, biodiversity and energy use are minimized.
6.8
Comprehensive waste management programs are in place to ensure that wastes are minimized, re-used, recycled or disposed of appropriately.
6.9
Water management programs are in place to encourage a reduction in usage and increased recycling.
6.10
Decommissioning, remediation and restoration plans are established using risk-based studies for end-of-life equipment/facilities.
6.11
Maintenance and operations of Security Systems must follow the guidance as set forth in the PotashCorp Security Management System to ensure meeting regulatory requirements as well as best practices.
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7. Management of Change
All temporary and permanent changes to organization, personnel, systems, procedures, equipment, products, materials or substances will be evaluated and managed to ensure that resulting safety, health and environmental risks are reduced or remain at an acceptable level. (The evaluation will include determining if permits, permit modifications, or regulatory approval or notification are required.) We will comply with changes to laws and regulations and take into account new scientific evidence relating to SHE effects.
> EXPECTATIONS 7.1
The safety, health, environmental, security, technical and other impacts of temporary and permanent changes are formally assessed, approved and managed.
7.2
Changes in legal and regulatory requirements, technical codes, and knowledge of health and environmental effects are tracked and appropriate changes communicated and implemented. As additional knowledge of health and environmental effects is gained, appropriate steps will be taken to make use of this knowledge.
7.3
Pre and Post-startup reviews are carried out for all newly installed or modified equipment to confirm that construction is in accordance with design, all required verification testing is complete and acceptable, and all approved recommendations/deviations are completed by the designated technical authority.
7.4
Effects of change on the workforce/organization, including training requirements, are assessed and managed.
7.5
The impact of changes in manufacturing processes on product quality is assessed, associated hazards are evaluated and risks are controlled.
7.6
Process changes will be evaluated to determine if government permits or approvals are required. If they are, these will be obtained prior to initiating change.
7.7
The original scope and duration of temporary changes are not exceeded without review and approval.
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8. Information and Documentation
We will maintain accurate information on our operations and products. It will be held securely yet readily available. > EXPECTATIONS 8.1
A system is in place to securely manage drawings, design data and other documentation, including definition of responsibilities for maintaining this information.
8.2
The documents management system will include appropriate security to control access and privacy.
8.3
Applicable regulations, permits, codes, standards and practices are identified. The resulting operating requirements are documented and communicated to the workforce.
8.4
Scope and format of technical documentation will be agreed upon for each facility and will form part of the design input for new facilities and modifications.
8.5
Employee health, medical and occupational exposure records are maintained and controlled through authorized access, confidentiality, and retained per PotashCorp record retention policy.
8.6
An enterprise data base is maintained and regularly updated for recording safety, environmental, and security incidents and near-misses, reporting safety, environmental, and security data and maintaining a record of remedial actions from safety and environmental events.
8.7
A records retention system is in place, which includes a schedule for each category of records for retention, storage, archiving, destruction, and the identification and backup of critical records such as legal documents and computer systems.
8.8
Where required by regulation, documents will be considered “security sensitive Information (SSI)” [per 49 CFR Part 1520] or chemical-terrorism vulnerability Information”(CVI) [per 6 CFR 27.400].
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9. Customers and Products
We will assess, manage and communicate the hazards associated with PotashCorp products. We will communicate up-to-date information to help users and others handle our products in a safe and environmentally responsible manner.
> EXPECTATIONS 9.1
Assessments of new products are conducted prior to marketing or distribution, to identify safety, health, environmental, and security hazards and risks associated with normal use and foreseeable misuse.
9.2
Periodic re-assessments are conducted for all manufactured and re-branded products. This includes a review of any adverse effects reported or experienced by those handling these products.
9.3
New uses or markets for existing products are evaluated to ensure that safety, health, environmental, and security hazards and risks are identified and addressed.
9.4
Records of assessment, background information and conclusions are kept up-to-date throughout the product’s life and retained as appropriate.
9.5
Up-to-date information on safety, health, environmental, and security hazards and risks related to the use, storage, handling, transport and disposal of our products is available to the workforce, customers and others. Safety Data Sheets (SDS), in GHS format, labels and other information are developed and issued to handlers and users in accordance with legislative, regulatory and customer requirements, and as information changes, as well as a triennial review occurs. A system exists to identify and proactively monitor existing and pending requirements.(regulatory requirements and industry codes).
9.6
A system exists to collect and review adverse effects reported or experienced by those handling our products. Causes for concern are identified and appropriate actions are taken.
9.7
An effective recall system exists for products in which a defect could give rise to safety, health or environmental hazards.
9.8
A system is in place to respond on a 24-hour basis to requests for safety, health and environmental emergencies or information regarding products.
9.9
PotashCorp promotes a 4R Nutrient Stewardship Program that helps define fertilizer management practices. The 4R system is based on the concept of matching nutrient supply with crop requirements while minimizing nutrient loss to the environment.
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10. Community and Stakeholder Awareness
We value community awareness and will actively engage in dialogue with our stakeholders to maintain public confidence in the integrity of our operations and products, and our commitment to SHE performance. > EXPECTATIONS 10.1
Open and proactive communications are established and maintained with employees, service providers, regulatory agencies, public organizations, communities, suppliers and investors regarding the SHE aspects of our business
10.2
PotashCorp recognizes and responds to stakeholder SHE-related expectations and concerns about our operations, products and business practices.
10.3
The SHE-related effects of new business development on local communities are openly assessed, communicated and integrated into the business case.
10.4
SHE impacts of any divestments or facility decommissioning will be reviewed, managed and communicated to neighbors and the local community as appropriate.
10.5
PotashCorp periodically issues statements related to its SHE performance and programs.
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11. Emergency Management and Crisis Communication
Emergency Management and Crisis Communications Plans will be maintained by all of our facilities and distribution locations. These plans will identify equipment, training and personnel necessary to protect the workforce, customers, public, environment and PotashCorp’s reputation. These plans will address the phases of prevention, preparedness, response and recovery.
> EXPECTATIONS 11.1
Emergency Management Plans are based on the risks that potentially impact the business, employees, service providers and facilities. These plans are documented, accessible, and clearly communicated and aligned with PotashCorp’s Comprehensive Emergency Management Plan.
11.2
Facilities and equipment needed for Emergency Management and Crisis Communications are identified, tested and available as per applicable regulatory requirements and PotashCorp standards.
11.3
All personnel are trained in their roles and responsibilities, and in the use of crisis management tools and resources in executing Emergency Management and Crisis Communications Plans.
11.4
Annual drills and exercises are conducted to assess and improve emergency response and crisis communications capabilities. Annual drills may include liaison with and involvement of external organizations.
11.5
Periodic reviews and updates are conducted on Emergency Management and Crisis Communications Plans and training requirements.
11.6
Business continuity and recovery systems are identified and incorporated in each facility’s Emergency Management Plan.
11. 7 Senior management is notified of all emergencies that occur, including product-related emergencies that occur in the supply chain.
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12. Incident Analysis and Prevention
Incidents will be investigated, analyzed and reported to prevent recurrence and improve our SHE performance. Our investigations will focus on root causes which are found in system failures. Corrective actions and preventive measures will be used to reduce the likelihood and impact of injuries, environmental damage and material losses.
> EXPECTATIONS 12.1
All safety, health, environmental, technical integrity and security incidents, including near-misses, are investigated, analyzed and openly reported.
12.2
Major incidents are investigated by a multi-function/multi-level team and may include participation and leadership from outside the facility.
12.3
Incident investigations, including development of snap charts, identification of causal factor, identification of root causes and corrective actions are documented and abated in a timely manner.
12.4
Information gathered from incident investigations is analyzed to identify and monitor trends and develop prevention programs.
12.5
Lessons learned from investigations are shared throughout PotashCorp and personnel take appropriate action upon receipt of such information
12.6
Mutual sharing of lessons learned and good practices is encouraged within the mining, energy and chemical industry.
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13. Assessment, Assurance, Audit and Continuous Improvement
We will periodically assess the implementation of, and compliance with, these Expectations to assure ourselves and stakeholders that management processes are in place and working effectively. This will involve both internal and appropriate external audits and assessments. We will use this information to continue to improve our SHE performance and processes. > EXPECTATIONS 13.1
SHE performance indicators are established, communicated and understood throughout the organization. They are regularly used to determine when and what management system changes are necessary. When changes occur in one SHE Element, the impact on the entire management system is evaluated.
13.2
The workforce is actively involved in periodic assessments of the effectiveness of processes and procedures to meet SHE Expectations.
13.3
A system exists to continually improve SHE behaviors through observation, recording, coaching and followup actions.
13.4
A documented audit program exists to periodically evaluate progress toward SHE targets, regulatory compliance and the effectiveness of the facility management system(s).
13.5
Facility management, in co-operation with the audit team, plans audits that are objective and systematic. These are documented and conducted using expertise from both inside and outside PotashCorp.
13.6
Findings from learning processes (e.g. audits, assessments, incident investigations, near-misses, HAZOPS, etc.) are prioritized, tracked to completion and used to systematically improve the SHE Guide for Managers and SHE performance (including emergency response, product stewardship and security).
13.7
The facility leadership team reviews its SHE Guide for Managers to ensure it is continually delivering consistent, desired performance. Based on the review, new risk-based targets are considered and established whenever necessary.
13.8
The facility reports SHE performance data as part of PotashCorp’s SHE reporting requirements.
13.9
A process is in place whereby assurance is regularly provided to the President and Chief Executive Officer demonstrating effective implementation of the PotashCorp SHE Commitment and Expectations. Facilities evaluate their effectiveness against these Expectations.
13.10 The Safety, Health and Environment Committee of the Board of Directors periodically reviews Environmental Audits, facility Safety audits and the status of corporate Safety, Health and Environmental policies, including emergency response, product stewardship and security,
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14. Product Stewardship
This Guide for Managers outlines PotashCorp’s overall commitment for the IFA Protect & Sustain Program, including PotashCorp’s commitment to SHE and security principles. > EXPECTATIONS 14.1
A product stewardship management system is in place to reflect the IFA SHE and security principles as defined in the IFA Protect & Sustain Program that has a strategic focus and includes an assessment and gap analysis, planning and implementation, as well as continual improvement.
14.2
Procedures have been developed to address product development and planning, that include SHE and security risks for the lifecycle of the product that is identified prior to market introduction, and the risk management systems as well as the communication of product information as identified in this guide provide a system to handle these risks.
14. 3 Sourcing and contractor management evaluation is established for supplier selection and management of critical materials and services and contractor management. 14. 4 Management of change procedures exist for changes to our processes, and there are documented procedures for handling of products (including non-conforming or returned/recalled products), and specifications are monitored with regard to product quality and safety requirements that address best management practices. 14.5 The supply chain to the customer ensures that there are procedures to address packaging, blending (where appropriate), storage and transportation. 14.6
The marketing, sales and product use addresses product safety, quality and security, including: advice, training, and agronomic advisory services,
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Key SHE Processes
1
Delivering SHE Assurance
2
SHE Risk Assessment and Risk Management
3
Incident Investigation Guidelines
4
Emergency Management and Crisis Communication
5
Incident Flash Reporting
6
Biodiversity
7
Facility and Product Security
8
SHE Reporting Requirements
9
SHE Performance Targets
10
SHE Reporting Definitions
11
Health Management
12
Behaviors
13
Communication of Product Information
14
Developing Safety Standards
15
Product Stewardship
16
SHE Compliance with Existing and Pending Requirements
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KEY SHE PROCESS 1 Delivering SHE Assurance
Assurance is the process whereby facility managers and nutrient presidents confirm that processes are in place and working effectively in order to manage the key controls for, and major risks to, sustainable business performance. This includes accurate measurement of and continuous reduction of exposure. This process is supplemented routinely by external assessments and audits.
> SHE ASSURANCE ADDRESSES DELIVERY OF: PotashCorp’s SHE Commitment; PotashCorp’s SHE Expectations; and, Legal compliance with SHE rules, regulations and permit conditions.
Our goals and aspirations
Safety, Health and Environment Board Committee regularly reviews SHE progress
What our Managers need to do
Reviews of SHE progress in all facilities
Guidance to managers for consistent SHE actions across PotashCorp
How our risks are changing and how well we are managing them
What could go wrong and how to prevent it
Independent audits of our processes and equipment
How to work safely and effectively
Self-checks – are we doing what we say
Everybody works to consistently deliver improved SHE performance
How well we have performed against our targets
Regular reports about our accidents, injuries, emissions and action plans
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KEY SHE PROCESS 1 Delivering SHE Assurance
> SHE ASSURANCE IS A CONTINUOUS REVIEW PROCESS INVOLVING REGULAR DIALOGUES ABOUT: Supporting internal and external audits, Identifying and managing SHE risks Evaluating SHE performance trends These are documented in a formal SHE Report.
> KEY FEATURES OF SHE ASSURANCE ARE: Management accountability for establishing effective processes to deliver the SHE Expectations Effective review processes involving audits, annual corporate SHE self assessments as well as external audits every two years Plans to improve performance and address areas requiring attention.
> KEY FEATURES ARE SUPPORTED BY: Regular evidence that major risks and key internal controls are being actively managed at the appropriate level Regular evidence of effective implementation of processes and procedures Regular evidence of continuously improving SHE performance
> HOW THE PROCESS WORKS IN PRACTICE: Facility management holds regular dialogues with its Division President about SHE performance trends, progress towards SHE targets and the management of major risks. Facility management commits to assessing and reviewing programs relevant to the risk profile of the activity. The major part of this program involves ongoing assessment. Periodic independent internal and external safety, health and environmental audits and assessments are conducted at regular intervals to provide overview and credibility• Facility management prepares action plans for safety and environmental audits and submits plans to the division president and corporate SHE. These plans are reviewed and tracked to completion. The corporate SHE Department issues guidance on the annual SHE Assurance Report format and the reporting timetable. The Vice President of SHE will annually prepare an overall summary to the Chief Operating Officer outlining achievements and significant areas for action. The report not only documents recent SHE performance, but also outlines future assurance and corrective action plans.
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KEY SHE PROCESS 1 Delivering SHE Assurance
> SAFETY, HEALTH AND ENVIRONMENT COMMITTEE OF THE BOARD OF DIRECTORS The SHE Committee of the Board of Directors monitors PotashCorp's progress in meeting its SHE commitment and its compliance with SHE rules, regulations and permit conditions. The Committee: Periodically reviews the SHE polices of the Corporation and, as appropriate, recommends changes in such policies to the Board of Directors or Management Receives and reviews, not less than annually, written reports from management on the status of compliance with the SHE policies of the Corporation and on compliance with all applicable regulatory requirements Receives and reviews, not less than annually, reports from Management on any material non-compliance with SHE policies of the Corporation or any material non-compliance with any applicable regulatory requirement Reviews other SHE related matters as the Committee may consider suitable or the Board of Directors may specifically direct.
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KEY SHE PROCESS 2 SHE Risk Assessment and Risk Management
Risk assessment is the process of estimating the likelihood of an event occurring, estimating the magnitude of the consequences and making a judgment about the significance and tolerability of the risk. Risk is a function of both likelihood and consequence; both are equally important. Risk management is the systematic application of policies, practices and resources to the assessment, mitigation and control of risk. Residual risk level and cost versus benefit are used to support development of risk reduction options, program objectives and prioritization of issues and resources. Risk management decisions must consider both frequency and consequence. The expected annualized loss (loss x likelihood) should theoretically determine the level of attention which any risk should justify and also the resources devoted to reducing or eliminating it. There may; however, be good ethical or business reasons for being more risk averse in some circumstances. In general; however, a risk-neutral stance should be adopted, (i.e. a $10,000 loss every year may be considered equivalent to a $100,000 loss once every 10 years). The risk management process involves the following activities: identifying areas of concern, hazards and threats; assessing the risks to people, the environment, property and reputation associated with those hazards or threats; evaluating and prioritizing risk elimination/reduction measures; implementing the risk elimination/reduction action plan measures; and, verifying implementation of the risk reduction action plan.
> THREE CATEGORIES OF RISK. SHE Element 2 sets expectations for risk assessment and risk management. A wide variety of techniques and processes are available, appropriate to the circumstances and level of risk involved, and these should be considered in relation to three categories of risk: Business Risk is a term to describe all risks facing business. Typical business risks will be political, financial, competitive, technological, security and SHE-related. Reputation damage is likely in some instances. The facility management team owns the assessment of business risk at its site; however, the management of business risk is shared with appropriate Corporate Departments and typically involves: identification of high level risks – including SHE, product related and security risks which may be further categorized into workplace risks and process/technical as outlined below: use of a risk matrix or formal risk assessment to capture severity and manageability of perceived risk risk management action plans to provide demonstrable assurance that key risks are being managed.
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KEY SHE PROCESS 2 SHE Risk Assessment and Risk Management
Workplace Risk is the risk to workers from safety and health hazards in their normal working activities. Typical consequences may be injury, damage to health or death. Some workplace accidents or incidents may also include property damage and business interruption. Reputation damage and off-site consequences may also be likely in some instances. These risks are often managed directly by individuals or front-line teams and involve: Structured hazard assessment and mitigation process (e.g. Job Hazard Analysis) Formal task risk assessment for routine and non-routine jobs (e.g. safe work plan) Control by standing procedures, permits to work or lockout procedures Informal assessment by individuals prior to or during a task Self assessments to ensure that systems and procedures are working effectively Safety observations Process Safety Management (PSM) where applicable, risk-ranking consequences of various scenarios in Process Hazard Analysis (PHAs) and considering off-site consequences of risks.
Process Risk is the risk due to failure of the performance of process equipment. There are two types of failure that should be considered: Failure of the equipment to deliver business performance (e.g. quality/quantity of output, reliability, energy efficiency). Typical adverse consequences include failure to meet emissions requirements, noise standards or impact of off-specification product. Loss of containment (e.g. risk due to accidental or intentional release of process fluids). Typical effects include toxic clouds, fire, explosion, pollution and off-site consequences.
Process risks are typically assessed by technical specialists or teams and involve: Formal identification, assessment and management of risks involved in a particular project, operation or activity Hazard identification processes such as Process Hazard Analysis (PHA). For example, a Hazard and Operability (HAZOP) study is a hazard assessment technique used during the design or modification stage of plant and equipment Quantification assessment processes such as Quantified Risk Assessment (QRA) High Potential Analysis Fault Tree Analysis Event Tree Analysis Security Vulnerability Analysis (SVA).
> KEY CONCEPTS OF RISK MANAGEMENT Risks may be expressed either qualitatively, (e.g. high/medium/low); or, quantitatively, (e.g. dollars or expected mortality/year).
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KEY SHE PROCESS 2 SHE Risk Assessment and Risk Management
> STRATEGIES FOR RISK MANAGEMENT Strategies must be cost effective; if they are not, the organization could be risk free but may not be competitive. Work across all three categories of risk. Identify and rank major business risks, but remember that basic task assessment in the workplace will not only prevent injury, but may well contribute to the management of major risks. Concentrate on the most reliable controls for long term reduction in exposure. Once the risk has been qualified and the determination is made that the risk is above PotashCorp risk tolerance, action plans are documented and abatement timelines established. Site and senior management track abatement until document closure is obtained. Consideration should always be given to the hierarchy of controls when designing risk management strategies.
Risk communication is an important issue. Social perceptions of tolerable risk are strongly influenced by subjective factors such as whether people feel they are well informed and fairly treated.(treated fairly?) Effective risk communication rests; nonetheless, largely on effective risk management. People don’t want to hear about theory, but rather what is actually being done to manage the risks that concern them. Advice on insurance policy relating to SHE risks should be sought from PotashCorp Risk Management Department
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KEY SHE PROCESS 3 Incident Investigation Guidelines
> PURPOSE It is essential to discover the causal factors (problems) and root causes of incidents so that: Effective corrective actions can be developed, implemented and tracked to completion to prevent the recurrence of the incident ‘Lessons Learned’ can be defined, shared and implemented at other operations where applicable Trends can be uncovered through statistical analysis
> TRIGGER Thorough root cause analyses investigations shall be carried out for the following incident classifications (as defined in SHE Key Process 10): Major Incident Lost Time Injury Modified Work Injury High Potential Incident Environmental Incident Distribution Incident Reliability Incident (as defined by the nutrient President or VP of Operations)
Root cause analyses investigations shall also be carried out for the following incident classifications, where site management determines that the potential outcome was a Serious Injury, Fatality or major loss of property: Recordable Injury First Aid Injury Significant / Transportation Security Incident Near Miss Incident Report Only (no injury) First Alerts (Potash Expansion Projects)
> TIMING OF INVESTIGATION INITIATION Major or high potential incidents occurring at any PotashCorp facility require the initiation of an investigation as soon as possible but not later than 24 hours after the incident. Process Safety Management Incident investigations must begin within 48 hours of the event occurring. All other incident investigations must begin within 48 hours or the next business day. Investigations must be completed within 28 days of the initiating event unless an extension is granted by the Vice President of SHE.
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KEY SHE PROCESS 3 Incident Investigation Guidelines
> INVESTIGATION PROCEDURE It is very unusual for an incident to have a single causal factor or a single root cause. Normally, incidents result from a sequence of events or combination of actions or errors, some going quite far back in time. It is essential to conduct a systematic and thorough investigation, following a consistent methodology, so that the chain of events and causal factors can be identified and analyzed to determine root cause(s). TapRooT® is the PotashCorp standard for root cause investigation. The following are the key seven basic incident investigation steps as defined in the TapRooT® root cause analysis methodology.
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KEY SHE PROCESS 3 Incident Investigation Guidelines
Get Started – Define the team and leader; determine the potential for litigation and if outside experts will be needed. Identify evidence that needs to be collected, interviews that need to be performed and documents that need to be obtained. Determine Sequence of Events – The goal is to fully understand what happened and to collect information about why it happened. Collect the identified information, perform the interviews, and identify additional information to be collected and interviews to be performed. Techniques that can aid in the development of the sequence of events are the Critical Human Action Profile (CHAP), Change Analyses, and Equifactor™. Define Causal Factors – Any problem associated with the incident that, if corrected, could have either prevented the incident from occurring or would have significantly mitigated the consequences. Causal factors are the problems that caused the incident. Identify Root Causes – The most basic cause or causes that can reasonably be identified that management has control to fix and, when fixed, will prevent or significantly reduce the likelihood of the problem recurring. Each causal factor is independently taken through the root cause tree to identify the root cause(s) associated with it. Identify Generic Causes – The systemic cause that allows a root cause to exist. Fixing the generic cause eliminates whole classes of specific root causes. Develop and Evaluate Corrective Actions – The purpose of corrective actions are to change the system that allowed the deviation to occur or put in place a system where one does not exist. They should be developed from a position of – make sure this never happens again...(Can this be restated?) Safeguard analyses can be used to evaluate the strength of existing safeguards and the effectiveness of those new safeguards proposed. Report and Implement Corrective Actions – Documenting the incident investigation is as important as conducting the incident investigation. The report must be of sufficient detail for management to clearly understand what happened and what needs to be done to improve performance. For mitigation recommendations where the potential or actual outcome of the incident is significant, the effectiveness of the corrective actions must be measurable.
> PROCEDURE FOR INVESTIGATION OF DIFFERENT TYPES OF INCIDENTS Incident resulting in a fatality or hospitalization of three or more persons The appropriate Division President or Vice-President, in consultation with the Vice President SHE, will determine if Legal Department participation is required and will appoint a team leader who has sufficient investigating experience, authority and independence from the involved facility. The team leader in consultation with the Division President and Facility Manager will appoint a multi-function/multilevel team, including a corporate SHE team member, a senior TapRoot® trained investigator and, where deemed necessary, other technical experts. Process Safety Management incident The Facility Manager will determine if Legal Department participation is required and will appoint a team leader with sufficient experience, authority, TapRoot® training and independence to be able to objectively lead the incident investigation. The Facility Manager will establish an investigation team that consists of at least one person knowledgeable in the process involved, (including a contract employee if the incident involved work of a contractor) and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.
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KEY SHE PROCESS 3 Incident Investigation Guidelines
All other incidents The Facility Manager will determine if Legal Department participation is required and will appoint a team leader with sufficient experience, authority, TapRoot® training and independence to be able to objectively lead the investigation of the incident. In consultation with the team leader, the Facility Manager will establish an investigation team that has the technical skills and experience necessary to complete the investigation.
> MANAGEMENT REVIEW AND APPROVAL When the preliminary investigation report is completed, facility management will review the findings and recommendations and agree on a corrective action plan. The final investigation report will include an action plan containing management responses to all recommendations, delegation of responsibilities for corrective action and an appropriate time to complete each corrective action.
> INCIDENT ACTION PLANS Each facility must have a process for tracking and measuring timely closure on corrective actions. The corrective actions should be completed as established in the action plan timeline. Whenever a completion date will be missed, the facility must justify and document the due date adjustment on the action plan. An update that shows status of all open corrective actions will be submitted to the Division President quarterly. The Facility Manager will provide the appropriate Nutrient President with assurance that all mitigation items have been completed per the agreed to schedule. Where deemed appropriate due to the serious nature of an incident or criticality of the recommendation, the Facility Manager will provide assurance to the appropriate Nutrient President and Vice President SHE three to six months after implementation of the mitigation, that the intended corrective actions are effective in preventing reoccurrence. The appropriate Nutrient President (or VP of Operations) will notify the site manager of this requirement.
> DISTRIBUTION The final investigation report will be sent to the same distribution list as Flash Reports. (See Key Process 5) PotashCorp facilities should make available the results of incident investigations to all employees.
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KEY SHE PROCESS 4 Emergency Management and Crisis Communication
Clearly defined and well thought out and practiced Emergency Management and Crisis Communications Plans are essential to mitigate the impacts of emergency events. The PotashCorp Emergency Management and Crisis Communications system provides a framework within which corporate, facility, and transportation and distribution plans are aligned and integrated by providing clarity of responsibility and enabling support and backups where needed.
> PRINCIPLES The system includes prevention, preparedness, response and recovery, and applies throughout PotashCorp. In an emergency event, there must be a clearly identified Emergency Management Team Leader at the affected facility and at the corporate Emergency Operation Center (EOC). Each facility will have an Emergency Management Plan and a standalone Crisis Communications Plan. The two plans run parallel and complement each other during an emergency. The Northbrook and Saskatoon Corporate Centers will each have an Emergency Management Plan and Crisis Communications Plan for events that occur at these facilities, and identify that if an event occurs at either facility, the other acts in response to corporate issues such as: – Company-wide issues – Financial performance – Corporate history – Legal – Insurance – Future of the facility The Northbrook Corporate Center Transportation and Distribution Department will have an Emergency Management Plan. The Emergency Management Plans will focus on the emergency itself and the company’s ability to operationally address the emergency event including liaison with external emergency response organizations and making any required regulatory notifications. The Crisis Communications Plans will focus on the media, the community and elected representatives while addressing public communications primarily via the news media, using fully competent spokespersons. The above plans will have clear linkages with each other to ensure that; in each case, roles and responsibilities are delineated inside the two management levels and in the support functions. All plans will be periodically exercised through drills to measure their effectiveness and to provide training for the response organization.
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KEY SHE PROCESS 4 Emergency Management and Crisis Communication
> FACILITY EMERGENCY MANAGEMENT PLAN Each PotashCorp facility, the Saskatoon and Northbrook Corporate Centers, will maintain a facility Emergency Management Plan conforming to PotashCorp expectations and applicable government regulations. This Plan will enable all PotashCorp facilities to prepare for, respond to and recover from an emergency and the associated external issues. The facility Emergency Management Plan will: Contain the facility’s emergency notification procedure including corporate notification Describe the location and requirements for the Emergency Operations Center (EOC) Contain the definitions of the three Emergency Action Levels Identify the major risks potentially impacting business operations and local communities Describe the response and recovery strategies, management organization and the roles and responsibilities of the key personnel Contain external emergency notification procedures, community resources and emergency management organization charts Describe how the facility will liaise with external emergency response organizations and regulatory organizations to manage the impacts of the emergency Link with the Northbrook and Saskatoon Emergency Management Plan to access additional support resources and policy guidance related to response for corporate issues Describe the relationship and coordination between the facility Emergency Management Plan and the facility Crisis Communications Plan At facilities producing hazardous materials, describe the relationship between the facility’s Emergency Management Plan and the PotashCorp Transportation and Distribution Emergency Management Plan Describe the preparedness activities (training, exercises, etc.) that will be undertaken on a periodic basis Ensure that the facility Emergency Response Team is prepared to respond off-site with appropriate equipment and personnel to assist the community in a transportation emergency to protect life and property when requested.
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KEY SHE PROCESS 4 Emergency Management and Crisis Communication
> NORTHBROOK AND SASKATOON EMERGENCY MANAGEMENT PLANS The Northbrook and Saskatoon Emergency Management Plan will address how the Corporate Centers (Saskatoon and Northbrook) will respond to an emergency at any PotashCorp facility, or distribution location. Thus, the Northbrook and Saskatoon Emergency Management Plans will conform to PotashCorp expectations and applicable government regulations to prepare for, respond to, and recover from an emergency and the associated external issues. The Northbrook and Saskatoon Emergency Management Plans will: Contain PotashCorp’s emergency notification procedure Describe the location and requirements for the Saskatoon and Northbrook Emergency Operation Centers (EOCs) Contain the definitions of the three Emergency Action Levels Describe the response and recovery strategies, management organization and the roles and responsibilities of the key personnel involved Contain external emergency notification procedures, community resources and emergency management organization charts Link with the Crisis Communications Plan of the other facility (Northbrook or Saskatoon) and the PotashCorp Transportation and Distribution Emergency Management Plan Establish a Corporate Response Team that will be able to provide on-site recovery support to any PotashCorp facility, transportation or distribution location that is experiencing an emergency Establish the criteria for use of on-site corporate assistance, and the methodology for delivery of the Corporate Response Team to an individual PotashCorp facility or off-site emergency location Describe the preparedness activities (training, exercises, etc.) that will be undertaken on a periodic basis
> POTASHCORP TRANSPORTATION AND DISTRIBUTION EMERGENCY MANAGEMENT PLAN PotashCorp will maintain a Transportation and Distribution Emergency Management Plan conforming to PotashCorp expectations and appropriate government regulation. This plan will enable PotashCorp to prepare for, respond to and recovery from emergencies and associated issues. The Transportation and Distribution Emergency Management Plan will: Contain the Distribution and Transportation emergency notification procedures Contain the definitions of the three Emergency Action Levels Describe the relationship and coordination between the Transportation and Distribution Emergency Management Plan and the Northbrook and Saskatoon Emergency Management Plans and the affected facility Emergency Management Plan Describe the role CHEMTREC provides in emergency response for HAZMAT events Describe the roles and responsibilities of PotashCorp emergency response teams in responding to Transportation or Distribution Emergency events Describe the resources required to support local emergency management agencies in minimizing the impact of a PotashCorp product involved in a transportation emergency Establish the criteria for the use of PotashCorp HAZMAT resources during off-site emergency incidents involving PotashCorp products that could affect the public Describe the preparedness activities (training, exercises, etc.) that will be undertaken on a periodic basis
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KEY SHE PROCESS 4 Emergency Management and Crisis Communication
The Crisis Communications Team is an integral part of the Emergency Management Team and while the two Teams may operate from the same Emergency Operations Centers, having two different operational locations for the two teams may be more consistent to be efficient and to ensure accurate dissemination of needed information. The Crisis Communications Team Leader reports to the Emergency Management Team Leader during an emergency event. The Emergency Management Plan and Crisis Communications Plan designate primary and fully trained alternates for each position. Provision will be made for preparedness activities (training, exercises, etc.) that will be undertaken on a periodic basis throughout PotashCorp.
> FACILITY CRISIS COMMUNICATIONS PLAN Each PotashCorp facility or distribution location will maintain a facility Crisis Communications Plan consistent with the philosophy and approach advocated by PotashCorp. This Crisis Communications Plan will: Contain the facility’s Crisis Communications notification procedure (including notification of senior management in the event of a product-related emergency through the supply chain). Identify primary and alternate spokespersons who are trained for this role. Establish the training requirements for the news media spokespersons, Public Information Officers and Administrative Assistants. Identify where they will meet with the news media and where a family receiving area will be located Establish the guidelines and procedures for writing, obtaining approval and issuing all news releases Contain contact lists for local and regional news media organizations Describe the relationship and coordination between the facility Emergency Management Plan, the facility Crisis Communication Plan and the Northbrook or Saskatoon Corporate aspects of their respective Emergency Management and Crisis Communication Plans
> NORTHBROOK AND SASKATOON CRISIS COMMUNICATIONS PLAN The Northbrook and Saskatoon Crisis Communications Plans will establish the organization, guidelines, logs, contact lists, etc., that will be used in anticipating, developing, approving and issuing news releases, public statements and/or news conferences. The Northbrook and Saskatoon Crisis Communications Plans will: Contain the Northbrook and Saskatoon, as well as, Corporate Crisis Communications notification procedure Identify primary and alternative spokespersons who are trained for this role Establish the training requirements for the news media spokespersons, Public Information Officers and Administrative Assistants Identify where they will meet with the news media and where a family receiving area will be located Establish the guidelines and procedures for writing, approving and issuing all news releases Describe how PotashCorp reputation issues will be addressed How the impact on reputation will be managed during and after the incident Contain contact lists for local, regional and national news media organizations Describe the relationship and coordination between the Corporate Crisis Communications Plan, the Corporate Emergency Management Plan and the facilities Plans
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KEY SHE PROCESS 5 Incident Flash Reporting
> PRINCIPLE Incident flash reporting covers deviations in the safety, health, environment, security, distribution and reliability areas. The aim is to provide management with timely notification of defined events including those that could threaten the operations and reputation of PotashCorp.
> TRIGGER The following incident classifications shall be reported on the Flash Report (as defined in SHE Key Process 10): Major Incident Lost Time Injury High Potential Incident Recordable Injury or Illness Environmental Incident Distribution Incident Reliability Incident (as defined by the Nutrient President or Vice President of Operations) Security Incident Product-Related Incident
The Flash Report is not expected to be a complete account of events or to contain authoritative information on the cause of the incident but instead, to provide the basic facts that are known at the time. Speculation must be avoided. The reporting of a defined event triggers the Root Cause analysis process as defined in Key SHE Process 3. Completed Flash Reports and the subsequent Root Cause Investigation Reports (with the exception of attorney/client privileged documents) are shared throughout PotashCorp so that lessons learned can be applied at all operations. Major Incidents may also require activation or mobilization of the Northbrook or Saskatoon Emergency Management Team or Crisis Communications Team (see Key Process 4).
> TIMING OF REPORTS A Major Incident, Lost Time Injury or High Potential Incident (as defined in SHE Key Process 10) should be reported immediately, or as soon as practicable under the circumstances, to the appropriate distribution identified below. Other recordable injury, environmental incident, distribution incident, product-related, reliability incidents and security incidents must be reported within 24 hours or the next normal business day.
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KEY SHE PROCESS 5 Incident Flash Reporting
> DISTRIBUTION LIST – SHE MAJOR FLASH (LOST TIME INJURY, MAJOR OR HIGH POTENTIAL INCIDENTS) President and Chief Executive Officer Executive Vice President and Chief Operating Officer Division Presidents Vice President, Safety, Health and Environment Operating Division Vice Presidents, General Managers or Directors Sr. Director Safety and Health Directors, Environment Director, Product Stewardship & Security General Managers at all PotashCorp facilities Sr. Vice President, General Counsel VP, Global Risk Management & Internal Audit Corporate SHE personnel Others as deemed appropriate by the VP SHE
> DISTRIBUTION LIST – SHE OTHER FLASH REPORT (ALL OTHER) Executive Vice President and Chief Operating Officer Division Presidents Vice President, Safety, Health and Environment Operating Division Vice Presidents, General Managers or Directors Sr. Director Safety and Health Directors, Environment Director, Product Stewardship & Security General Managers at all PotashCorp facilities VP, Global Risk Management & Internal Audit Corporate SHE personnel Others as deemed appropriate by the Vice President SHE
Distribution lists will be maintained by Corporate SHE department and accessed through company email system.
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KEY SHE PROCESS 5 Incident Flash Reporting
> FLASH REPORT FORMAT The pre-formatted Flash Report in EtQ Reliance Software will be utilized for all reports. All of the required information fields must be addressed. The “Account of Incident” field should: Include all factual information known at the time of the Flash Report. No assumptions or speculation permitted – this report must be entirely factual Answer the who, what, when, where questions Explain what was taking place at the time of the incident The “Immediate Actions Taken to Prevent Recurrence” field should include actions taken to prevent an extension of the original incident and provide assurance that an immediate repeated incident will not occur. Additional corrective measures taken to prevent recurrence will be detailed in the Incident Action Plan resulting from the TapRoot® Investigation of the incident (see Key Process 3) The Flash Report should be sent for distribution through company email via the ETQ Reliance Software.
> NOTIFICATION PROCESS Major or High Potential Incidents: Verbal notification will be provided to the appropriate Division President as well as e-mail notification to the defined distribution list plus other addressees appropriate to the incident, location or site. The notification should be issued by or on behalf of the Facility Manager. Product-related Incidents: Product recalls, process changes that impact the quality of the product or non-conformance to product specifications must be reported as indicated for SHE Other Flash Report Security Incidents: Security incidents should be reported as above. In the event of an incident that may not have been made public (e.g. kidnapping, extortion, product contamination, threat or covert attack against a PotashCorp employee or facility, or any similar incident) the Facility Manager or Facility (Site) Security Officer must communicate immediately with the appropriate Division President privately and securely. The Division President will inform those who need to know or can advise or help. All Other Incidents: E-mail; with accompanying Flash Report to the defined distribution list, plus other addresses appropriate to the incident, location, or facility. The notification should be issued by or on behalf of the appropriate Facility Manager.
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KEY SHE PROCESS 6 Biodiversity
> PRINCIPLE Our Commitment PotashCorp’s approach to biodiversity is shaped by two reinforcing considerations: Our SHE policy commits us to minimize impacts on biodiversity; We are also committed to meeting all federal, state/provincial and local regulatory requirements which often include biodiversity considerations in the permitting process.
> SYSTEMS Mining is a highly regulated industry. It starts with a mining permit, which requires the preparation of an extensive environmental impact statement that explains how we will avoid or mitigate impact on plant and animal species. Public involvement is a part of the permitting process. The result is that the company takes steps to understand, avoid, minimize and mitigate biodiversity impacts throughout the life cycle of its operations. In particular, PotashCorp believes that biodiversity is promoted by enhancing or preserving habitat at and near our operations. The company does everything practicable to minimize negative impacts on the surrounding lands and water, which allows natural biodiversity to continue.
> SPECIFIC ELEMENTS IN OUR APPROACH Biodiversity considerations are factored into PotashCorp’s SHE Guide for Managers. We undertake studies to develop a good understanding of biodiversity around our mine sites. We carry out biology studies that monitor the condition of the flora and fauna, surface water and ground water, etc. In the case where PotashCorp owns the nearby property and leases it back to farmers, we require detailed farm lease agreements to ensure safe and environmentally-friendly farming practices. We work with partners to enhance biodiversity outcomes. We actively support governmental initiatives to promote biodiversity.
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KEY SHE PROCESS 7 Facility and Product Security
> FACILITY AND PRODUCT SECURITY Facilities should consider security actions that are commensurate with the level of security threat posed by their location and the specific products produced. The Risk Assessment and Risk Management Element 2 and Key SHE Process 3 should be utilized to develop appropriate action plans to reduce or eliminate security risks. All facility Managers are required to develop minimum site security provisions to prevent harm to individuals, to avoid business interruption, and to prevent loss of property and information due to theft, vandalism, violence, illegal and disruptive activities by extremist groups, terrorist and other criminal acts against the company. Product stewardship requirements include providing for the security of certain products while en route to the destination and while in storage at the destination. Facilities will implement the PotashCorp Security Management System (SMS) which provides a more uniform and consistent framework for security. The SMS is designed to assist facilities to implement appropriate security measures to meet regulatory requirements as well as voluntary efforts considered as PotashCorp “best practices”. The PotashCorp Security Management System (SMS) The SMS is a written program that provides systematic, documented, and verifiable methodologies for continued compliance with Corporate Security subject matter areas with support documentation that contains security best practices, processes, and guidance to assist in the implementation of effective security programs Leadership Commitment to Security Security Policy Roles and Responsibilities Security Plans and Programs Security Compliance Incident Reporting and Investigations Incident Reporting Investigations Threat Assessment and Security Program Design Basis Company Level Threat Assessments Facility Level Threat Assessments Security Risk Determination Appropriate Assessment Methodologies Risk Assessment Protection of People, Assets, and Information Security Awareness and Education High Risk Personnel Physical Security Controls Intellectual Property and Information Protection Escalating Threat Response Plan
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KEY SHE PROCESS 7 Facility and Product Security
Emergency Management Technical Security Capital Projects and Purchase of a Security System Intrusion Detection System Guidelines Access Control System Operational Guidelines CCTV System Guidelines Anti-vehicle Gate / Barrier Guidelines Program Validation and Continuous Improvement Program Planning Penetration Testing Record Retention Management of Change Separating employees or employees with a Change in Position Change in a Security Focal Point / Facility Security Officer Capital Projects and acquisition of a new security system Changing a security supplier
> EACH FACILITY SHALL IMPLEMENT A SITE SECURITY PLAN. The security plan will be commensurate with the level of security threat posed by the specific products produced or used in the process. The security plan will be developed using the risk assessment and risk management methodology provided in Key SHE Process 2 and consistent with all US, Canadian and International regulations. The following potential sources of loss or disruption should be considered in completing the security risk assessment: Theft, vandalism and break-ins, considering both internal and external threats Theft of confidential business information Sabotage of equipment, utilities and records Infiltration of computerized process control systems and computer systems Product contamination and tampering Bomb threats Terrorist threats to the facility or the industry Demonstrations disrupting plant access and operations Workplace violence and assaults Natural disasters such as earthquakes, hurricanes or tornadoes Any other potential sources of loss or disruption as identified in future regulations
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KEY SHE PROCESS 7 Facility and Product Security
> FACILITY MANAGERS WILL DESIGNATE AN EMPLOYEE AS THE FACILITY SECURITY OFFICER. This person will be responsible for performing the following security management functions: Leading a cross functional team to complete security risk assessments of the facility Preparing and implementing site security action plans consistent with the risk assessment and the requirements contained herein Establishing relationships with law enforcement agencies that are appropriate to the facility security level Developing and managing incident reporting systems and conducting investigations of breaches of company security policy Developing methods to increase employee and contractor security awareness and other training as required by regulations Working with the facility emergency management coordinator to address issues in emergency management and crisis communication planning and execution Periodically reassessing the facility’s security risks and security plan.
> EXERCISING THE FACILITY SECURITY PLAN It must be the responsibility of the Facility Security Officer to ensure that the Facility Security Plan is drilled and/or exercised according to their plan. Exercises must be at least once each calendar year, with no more than 18 months between exercises. Exercises may be: 1. Full scale or live 2. Tabletop simulation or seminar 3. Combined with other appropriate exercises 4. A combination of the above Exercises must test the communication and notification procedures, and elements of coordination, resource availability, and response.
> POTASHCORP SECURITY LEVELS. The Security Measures for each product and each facility should include those provisions that are commensurate with the level of security threat posed by the product produced and by the location of the facility. All facilities and products have been classified into four Security Levels. Each Security Level will have specific security measures applied. The PotashCorp Security Levels are as follows: Level 1 – Fertilizer products which are not inhalation hazards or have no history of criminal misuse, such as Potash, Animal Feed, Phosphoric Acid, UAN Solutions and Aqua Ammonia Level 2 – Fertilizer products with a history of criminal misuse such as Urea Level 3 – Products regulated by USDOT as inhalation hazard such as Anhydrous Ammonia or regulated as a corrosive and has a history of criminal misuse such as Nitric Acid; oxidizers without a history of criminal misuse Level 4 – Products regulated by the USDOT as oxidizers such as solid Ammonium Nitrate
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KEY SHE PROCESS 7 Facility and Product Security
> PERSONNEL SECURITY Employees are one of the most critical assets to improving facility and product security. The site security coordinator should consider the following actions: Encourage employees to report suspicious incidents or events Implement routine security inspections Include security measures and awareness in regular employee/management meetings Have an internal communication system to inform staff of events, facts and trends on security issues Ensure employees are properly trained about security objectives, procedures, employee responsibility and the facility’s security structure [USDOT, USCG, Transport Canada, etc.] Verify employment data and application information prior to hiring employees At the facility entrance, post the names and phone numbers of emergency contact personnel so that the information will be readily accessible in the event of an emergency or to report suspicious activity.
> FACILITY SECURITY MEASURES In developing the security plan, the site security coordinator should consider the measures, listed by increasing security level, to prevent unauthorized access to their facility. Measures applicable to a lower security level will also be applicable to the higher levels. After assessing the security risks, the following measures will be considered for the designated security level: PotashCorp Level One – Facilities Signs to direct all visitors and vehicles to the appropriate entry/exit points Place limits on visitor access; for non-employees, mandatory sign-in access to controlled areas Access control for people and vehicles into production areas, warehouses, utility facilities and offices that contain business information that needs protection that validates who is authorized to remain within the facility A system to verify all visitors and vehicles prior to entering company premises, along with safety and security briefing for all visitors Report any suspicious incidents or individuals to local law enforcement officials Keep and review records of security incidents to identify trends and potential vulnerabilities PotashCorp Level Two – Facilities Establish partnerships with local law enforcement officials, emergency responders and other public agencies; Controlled areas are to be provided with physical barriers capable of keeping unauthorized people and vehicles out, except through designated entrance points Restrict the availability of security information related to the facility and the product handled
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KEY SHE PROCESS 7 Facility and Product Security
PotashCorp Level Three – Facilities Improve perimeter protection (such as clear zones, fences, solid walls, gates to block vehicle traffic and perimeter lighting) around the facility Check adequacy of locks and other protective equipment Restrict access to a single entry or gate and require employees and contractors to display identification cards at all times while on site Conduct security spot checks of personnel and vehicles Increased off-hour protection for controlled areas, such as contract security guard service touring the facility or remotely supervised intrusion alarms Periodically inventory the designated fertilizer products in order to recognize more quickly if a theft has occurred PotashCorp Level Four – Facilities Add security personnel and increase off-hour patrols by security or law enforcement personnel Install additional lighting, alarms or surveillance cameras Ensure that security lighting and emergency security systems are in working order Back-up power systems for controlled areas where operations are critical and for safety systems When storage areas are unattended, secure products in locked buildings or fenced areas and limit access to keys At each National Terrorism Advisory System (NTAS) or Maritime Security (MARSEC) Level, ensure that access control, restricted areas and other security measures are implemented in compliance with Facility Security Plans
> PRODUCT SECURITY MEASURES. Product Security Vulnerability Assessment Triennially, PotashCorp conducts a Product Stewardship Vulnerability Assessment to meet requirements under 49 CFR 172.802. This is an analysis to identify security hazards, threats and vulnerabilities facing a fixed facility handling hazardous materials from malicious acts and to evaluate counter measures to ensure protection of the public, workers, national interests, the environment, and company. Also analyzed are the events that may cause substantial acute consequences including theft/diversion of material; causing the deliberate loss of containment of a chemical, contamination of a chemical, tampering with a product, or sabotage of a system, or an act causing sever degradation of assets, including during transportation. Each facility manager will develop and implement product security measures commensurate with the PotashCorp security level. Measures applicable to a lower level will also be applicable to the higher levels. After assessing the security risk, the following measures will be considered for the designated security level: PotashCorp Level One – Products Driver to provide a valid bill of lading number, identification and commercial driver’s license for review.
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KEY SHE PROCESS 7 Facility and Product Security
PotashCorp Level Two – Products The identity of the carrier and/or driver must be verified, utilizing the bill of lading number and the commercial drivers license and comparing it with a data base of driver photographs Before loading, the driver must confirm the name of the consignee, the destination and the type of product and compare the information to the bill of lading Customers will be given notification that a shipment is being made and that if the product is not received within twenty-four hours PotashCorp requests notification. PotashCorp Level Three – Products Rail Shipments –
Shipments tracked from shipping point to destination to assure no route deviations or unnecessary delay
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All openings on rail cars will have numbered, tamper-evident seals or numbered tamper resistant seals as well as SALCO rings applied to the protective housing [Anhydrous Ammonia]
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Customers are instructed to notify shipping location if tags are missing or broken
Truck Shipments –
The customer will be notified that a shipment is being made
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If stops are necessary, drivers will select locations with adequate lighting on well-traveled roads and check their vehicles after each stop to make sure nothing has been tampered with
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Unattended, preloaded trailers will only be left on secure carrier lots or at other secure locations
PotashCorp Level Four – Products Rail Shipments –
All cargo openings on rail cars will have numbered tamper-resistant seals.
Truck Shipments –
The customer will be notified that a shipment is being made and that proof of delivery will be required upon arrival;
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The driver will be given a proof of delivery report with instructions to provide it to the consignee for it to be faxed back to PotashCorp within 24 hours of shipment;
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The facility will monitor the truck shipment computerized Proof of Delivery log for suspicious shipments;
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Suspicious shipments will be immediately called to the attention of Customer Service for further processing, including notification of State and Federal authorities, and
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Provide security guidance information to drivers;
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No Level Four products will be loaded on a Friday for Monday delivery;
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Carriers will develop communication systems with transport vehicles and operators with primary and backup means of communication between shipper, carrier, law enforcement and emergency response officials. The minimum acceptable requirements are the use of a cell phone (or other communication device) by the driver and their contact with the dispatcher no less than every two hours
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Facilities will record the cell phone number with the shipping documents in order to expedite contact with the driver under suspicious shipment procedures
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When readily available, advanced technologies to track or protect truck shipments en route to destinations should be used. These technologies may include the use of anti-theft devices and satellite tracking or other surveillance systems. 55
KEY SHE PROCESS 7 Facility and Product Security
> RISK BASED PERFORMANCE STANDARDS Facilities will be in compliance and will implement appropriate Risk Based Performance Standards as identified in the Chemical Facility Anti-Terrorism Standards (6 CFR 27) or the United States Coast Guard (USCG) 33 CFR 105 (as appropriate). Feed facilities will; in addition to the regulations as outlined above (if required), also implement the appropriate Safe Feed/Safe Food Initiatives as outline by the American Feed Industry Association (AFIA) or Food Defense requirements as identified in the Food Safety Modernization Act.
> NATIONAL TERRORISM ADVISORY SYSTEM (NTAS) OR MARITIME SECURITY LEVEL (MARSEC) Facilities will be in compliance with the current NTAS or MARSEC (if USCG facility or Transport Canada Maritime facility) and will implement the appropriate measures for the current level.
> TRANSPORTATION SECURITY ADMINISTRATION Facility will report incidents to the Transportation Security Administration and maintain a log for the verbal telephonic reporting as required under 49 CFR 1580.105.
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KEY SHE PROCESS 8 SHE Reporting Requirements
SHE data collected by the Corporate SHE Department is used to: Evaluate monthly, quarterly and annual SHE performance trends for Division Presidents, Corporate Executives and the Safety, Health and Environment Committee Monitor SHE performance against facility and corporate targets Coach facility management, safety and environmental teams to address observed trends. Provide data for PotashCorp’s Annual Report and for the annual Sustainability Report Provide data for investor reports such as Dow Jones SAM, Carbon Disclosure Project and others. Provide reports for senior managers aggregated by Division Evaluate performance against industry and regulatory standards
SHE performance data are submitted and retained by all facilities to include: SHE performance data are reported to the Corporate SHE Department for all operations where PotashCorp has equity and is deemed to have operational responsibility and hence SHE responsibility PotashCorp may expand these reporting boundaries to encompass some operations where PotashCorp has equity, but not operational responsibility At facilities where service providers/contractors are present, data pertaining to service providers/contractors must be included in the facility reports. A sub-group report for phosphate mining operations is required so as to complete quarterly Fertilizer Institute reports.
Timely reporting of SHE data is the responsibility of the Facility Manager: Monthly data must be submitted the following month by the end of the fifth business day Raw data must be collected (number of incidents, hours worked, etc.), and entered into the EtQ Reliance data base system Details on all reportable injuries are entered into the ETQ Reliance database system The following is a partial list of reports that are generated and utilized for monthly data reporting: –
OPSA 0100 Monthly SH & E Incident Summary
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OPSA 0101 Monthly SH & E Injury Report
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OPSA 0101H
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OPSA 0102 Monthly Environmental Report
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OPSA 0107 YTD Injury Frequency
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OPSA 0111 Monthly SH & E SiF Injury Report
Monthly SH & E Hours
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KEY SHE PROCESS 9 SHE Performance Targets
PotashCorp’s Commitment to SHE Performance sets clear expectations “Our goals are simply stated, no harm to people and no damage to the environment.” Annual SHE performance targets are developed and agreed to at all levels within PotashCorp as steps in the progression towards our goals and against which performance is assessed in the short to medium term. In addition to serving as progress measures, there are three other important objectives in setting targets: To communicate expectations To encourage desired behaviors – by reinforcing and/or coaching to achieve desired safe behaviors To demonstrate commitment – both internally and externally. Targets should be specific, measurable, achievable, realistic and timely. Targets can be expressed in terms of: Leading Indicators – activities expected to cause or affect the desired outcomes, (e.g. audits, self-assessments, training, risk assessments or key safety procedure audits completed or action plans completed on time). Lagging Indicators – compliance with all SHE regulations and permit conditions and tangible results indicating improved performance, (e.g. fewer injuries, spills, or near misses)
Leading indicator targets tend to help drive behavior and are; therefore, better used as individual performance targets and at the facility level. Lagging indicator targets help demonstrate commitment and work best with groups and at higher levels within the organization. A combination of leading and lagging indicator targets are essential to focus effort and drive behavior changes. Some SHE targets are communicated externally in the PotashCorp Annual and Sustainability Reports. Others at Division and Plant Site level remain part of the internal performance management system.
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KEY SHE PROCESS 10 SHE Reporting Definitions
The SHE data definitions are common throughout PotashCorp. The definitions can be complex, especially for environmental parameters. Reporting of injuries and illnesses requires good understanding of how to determine: Whether or not an injury or illness is work-related Whether it is an occupational illness, a recordable injury or a first aid treatment.
Definitions for parameters reported in Flash Reports, monthly reports and other key performance indicators (KPI) are included in this Key Process. PotashCorp’s injury and illness definitions are generally based on the US Occupational Safety and Health Administration (OSHA) as found in the document ‘Record Keeping for Occupational Injuries and Illnesses’ (29 CFR Part 1904). The definitions associated with these Key Processes are used to ensure consistent comparability of data from all PotashCorp reporting sites. These definitions may be different from local SHE performance definitions using other guidelines; often required by local regulation or legislation. Some recordable illnesses may be considered an injury for Workers Compensation, but may not be considered a recordable illness for PotashCorp recording purposes.
> EMPLOYEE A person on the payroll of a PotashCorp company.
> THIRD PARTY Any person who is not an employee or nested contractor of PotashCorp as defined in this section.
> POTASHCORP PREMISES A site operated by a PotashCorp company or a marine vessel owned or operated by a PotashCorp company.
> POTASHCORP COMPANY A Company wholly owned by PotashCorp, or a company or joint venture where PotashCorp has greater than 50 percent equity and is responsible for Safety, Health and Environment. Normally this is where PotashCorp is considered to be the operator.
> ESTABLISHING A WORK ‘RELATIONSHIP’ The work relationship is established when the injury or illness results from an event or exposure in the work environment. The work environment primarily consists of: The employer’s premises Other locations where employees are engaged in work-related activities or are present as a condition of their employment.
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KEY SHE PROCESS 10 SHE Reporting Definitions
When an employee is on the employer’s premises, the work relationship is presumed; however, when off the premises the relationship must be established. Travel on Company business is considered work-related. (The work relationship ends when the employee checks into the hotel and resumes when the employee re-enters the work environment.) Travel between temporary or permanent home and work (including personal detour from a reasonable direct route) is not work-related.
However, when an injury or illness occurring in the work environment falls under one of the following exceptions it is not work-related, and therefore is not recordable: The employee was present in the work environment as a member of the general public rather than as an employee. The injury or illness results solely from a non-work-related event or exposure that occurred outside the work environment. The injury or illness results from voluntary participation in a wellness program or in a medical, fitness, or recreational activity, or blood donation, flu shot, etc. The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption. The injury or illness results from the employee’s personal grooming or self-medication for a non-work related condition or is intentionally self-inflicted. The injury or illness is solely the result of the employee doing personal tasks (unrelated to their employment) at the establishment outside the employee’s assigned working hours. The illness is the common cold or flu. The injury is caused by a motor vehicle accident on a company parking lot or company access road while commuting to or from work. A mental illness is not work-related unless the employee voluntarily provides the employer with an opinion from a Licensed Health Care Professional (LHCP) with appropriate training and experience stating the employee has a work-related mental illness.
> MAJOR INCIDENT A Major Incident is an incident, involving any one of the following: A fatality associated with PotashCorp operations Multiple serious injuries associated with PotashCorp operations (one or more individuals admitted to hospital) A major release of a toxic chemical with off-site consequences A community evacuation, shelter in-place, or dislocation or damage to surrounding property Unplanned fall of ground in an active work area (causing injury or damage to equipment or is reportable to the province); Process Safety Management (PSM) incidents (incident, which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace).
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KEY SHE PROCESS 10 SHE Reporting Definitions
> HIGH POTENTIAL INCIDENT AND INCIDENTS WITH POTENTIAL FOR SERIOUS INJURIES OR FATALITES A High Potential Incident is an incident or near miss, where the most serious probable outcome is one or more of the Major Incident categories listed above. This also includes any incident, injury or event where there is the potential for a serious injury or fatality.
> RECORDABLE INJURY (RI) CASE For PotashCorp record keeping purposes, a Recordable Injury (RI) is a new case that results in the following classification: Death or fatality Lost Time Injury (LTI) Modified (or Restricted) Work Activity Injury (MWI) Medical Injury (MI).
RI cases are counted once, in the most severe classification. For example, a MI case recorded in May, which later becomes a LTI in November, will be reclassified as a LTI for May. Similarly, if a classification changes over the span of two calendar years, the classification is changed in the year the work-related injury or illness occurred. PotashCorp records hours worked since the “Last Lost Time Injury”. For these purposes, the time ends and starts again the first calendar day that an injured person is unable to return to work because he/she is unfit to perform any duties regardless of when the injury occurred.
> RECORDABLE FATALITY An employee fatality is deemed reportable as a major incident if the incident is found to be work-related. Fatalities arising, for example, from suicide, inexplicable personal behavior or natural causes would normally be excluded. All fatalities associated with PotashCorp activities are reported within 24 hours through the Incident Flash Reporting Process (Key SHE Process 5). Canadian and US facilities must report as per Provincial/State/Federal regulatory requirements.
> LOST TIME INJURY CASE (LTI) A work-related injury that causes the injured person to be unable to return to work on their next scheduled workday after the day of the injury, because he/she is unfit to perform any duties as determined by a licensed health care professional.
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KEY SHE PROCESS 10 SHE Reporting Definitions
> LIFE ALTERING INJURY Life-altering injury or illness: one that results in permanent or long-term impairment or loss of use of an internal organ, body function, or body part. Examples include, but are not limited to: a. significant head injuries b. spinal cord injuries, c. paralysis, d. amputations e. broken or fractured bones f. serious burns
> MODIFIED (RESTRICTED) WORK ACTIVITY INJURY CASE (MWI) A work-related injury where a licensed health care professional (LHCP) or the employer recommends that the employee not perform one or more of the routine functions of the job or not work the full workday that the employee would have otherwise worked.
> MEDICAL INJURY (MI) A Medical Injury case is a work-related injury that is non-fatal, non-lost time, or non-modified work activity, but requires medical treatment beyond first aid, such as: Any loss of consciousness A physician or other LHCP diagnosed significant injury A fracture or cracked bone Surgical removal of foreign objects A work-related injury resulting in a physician or other LHCP recommending or performing medical treatment beyond first aid, such as: 1.
Prescribing the use of a prescription medication or a non-prescription medication at prescription strength
2.
Administering immunizations, such as Hepatitis B vaccine or rabies vaccine
3.
Applying sutures, staples, (excluding butterfly bandages Steri-Strips or surgical glue unless used in lieu of sutures).
4.
The application of a cast or use of other rigid means of support, such as devices with rigid stays or other systems designed to immobilize parts of the body
5.
The medical removal of foreign bodies from the eye other than by irrigation or a cotton swab.
6.
The medical removal of splinters or foreign material from areas other than the eye by other than irrigation, tweezers, cotton swabs or other simple means
7.
The use of physical therapy or chiropractic treatment prescribed by a doctor and provided by a LHCP
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KEY SHE PROCESS 10 SHE Reporting Definitions
> MEDICAL ILLNESS / MODIFIED WORK ILLNESS/ LOST TIME ILLNESS An Illness case is a work-related illness that requires medical treatment beyond first aid, Illness cases are not included in the calculation of recordable injury frequency rate. The following are considered medical illnesses: Standard threshold shifts in hearing from baseline as determined by licensed health care professional Adverse reaction to a insect bite Heat stress and the administration of intravenous fluids for heat exhaustion Heart Attack or Stroke if determined to be work related Chronic exposure to welding flash Work related cases involving cancer Chronic irreversible disease Cumulative trauma
> FIRST AID CASE The following is a list of treatments considered to be first aid: 1.
Visits to a physician or other LHCP solely for observation or counseling.
2.
The administration of diagnostic procedures; such as x-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes (e.g., eye drops to dilate pupils).
3.
Use of non-prescription medication at non-prescription strength.
4.
Administering tetanus immunizations.
5.
Cleaning, flushing or soaking wounds on the surface of the skin.
6.
Using wound coverings, e.g., bandages, Band-Aids, gauze pads, butterfly bandages or Steri-Strips.
7.
Using hot or cold therapy.
8.
Using non-rigid means of support such as elastic bandages, wraps, non-rigid back belts, etc.
9.
Using temporary immobilization devices to transport accident victims (e.g. splints, slings, neck collars, backboards, etc.).
10. Drilling of a fingernail or toenail to relieve pressure or draining fluid from a blister. 11. Using eye patches. 12. Removing foreign bodies from the eye using only irrigation or a cotton swab. 13. Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means. 14. Using finger guards. 15. Using massage therapy. 16. Drinking fluids to relieve heat stress.
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KEY SHE PROCESS 10 SHE Reporting Definitions
> OCCUPATIONAL ILLNESSES AND INDUSTRIAL DISEASES An abnormal condition or disorder, other than one resulting from an occupational injury, caused by exposure to environmental factors associated with employment. It includes acute and chronic illnesses or diseases, which may be caused by inhalation, absorption, ingestion or direct contact. Chronic conditions should be reported in the period during which the condition was first diagnosed.
> DIFFERENCE BETWEEN OCCUPATIONAL INJURY AND ILLNESS The potential outcome of any ‘insult’ to the body, for example the consequences of a fall or exposure to a hazardous agent, is an adverse health effect. These are differentiated as either an injury or illness/disease for analysis of causal factors. In a working environment, this is determined by the nature of the original event of exposure, which caused the effect, rather than the resulting condition of the affected employee. An injury or illness is an abnormal condition or disorder. Injuries include cases such as, but not limited to, a cut, fracture, sprain or amputation. Illnesses include both acute and chronic illnesses, such as, but not limited to, a skin disease, respiratory disorder or poisoning. Differentiation is not always straightforward and clear definitions are necessary. Some conditions could be classified as either an injury or an illness but not both. For example: Hearing loss resulting from an explosion (an instantaneous event) is classified as an injury, whereas, if it results from exposure to noise over a period of time it is classified as an illness, regardless of whether it is included in local workers compensation coverage; Contact with a hot surface or caustic chemical causing an instantaneous burn is an injury. Sunburn, frostbite and welding flash burns are normally classified as illnesses because they usually result from prolonged or repeated exposure; Tendonitis resulting from a one-time blow to the tendons of the hand is considered an injury, whereas, repeated trauma or repetitive movement resulting in the same conditions is considered an illness; and, Back cases should be classified as injuries because they are usually triggered by an instantaneous event. Classifying back cases as injuries is appropriate not only for cases resulting from identifiable events, but also for cases where the specific event cannot be pinpointed, since back cases are usually triggered by some specific movement (such as a slip, trip, fall, sharp twist, etc.). Such generalizations are necessary to keep record keeping determinations as simple and equitable as possible.
Unlike injuries, illnesses may not be easily recognized and evaluation by trained medical personnel is desirable for confirmation both of diagnosis and attribution to occupational or non-occupational causation. Once a reportable work-related illness is diagnosed, managers are responsible for ensuring that they are reported and recorded per appropriate regulations. Illnesses frequently involve factors such as multiple causation, which are historic exposures totally unrelated to the current working environments and may also not result in time off work or require modified (or restricted) job duties. They may also recur or result in a chronic condition. Occupational illnesses are, therefore, reported only once – at the time of diagnosis or recognition and recorded per appropriate regulation only once.
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KEY SHE PROCESS 10 SHE Reporting Definitions
> DAYS AWAY FROM WORK CASE (DAFW/ DART) This definition is used internally by all facilities to be in compliance with OSHA record keeping rules (US Facilities) or Provincial Department of Labor record keeping rules (Canadian facilities).
> RECORDABLE INJURY/ILLNESS FREQUENCY (RIF) RIF is expressed as the number of recordable injuries and illnesses multiplied by 200,000 hours divided by the actual number of hours worked.
> RECORDABLE INJURY/ILLNESS SEVERITY (RIS) RIS is expressed as the number of calendar days lost from work multiplied by 200,000 hours worked divided by the actual number of hours worked. When totaling days for lost time cases, the day of the actual injury or onset of illness is not counted. The number of days of work missed will be reported monthly for a period of no more than twelve months. Furthermore, for PotashCorp reporting purposes, any days on which the employee would not have worked (i.e. weekends, holidays, prescheduled vacation days, etc.) even though the employee was unable to work, are not counted.
> HOURS WORKED Total hours worked within a reporting unit, including overtime, office staff, part-time employees, apprentices and trainees, and personnel from other PotashCorp sites or centers working within the unit for more than one month.
> NESTED CONTRACTOR (SERVICE PROVIDER) A nested contractor is an employer that operates full time on PotashCorp premises under contract providing personnel or services that directly benefit PotashCorp. Examples of this type of contractor include providers that supplement or make up a facilities work force on a daily basis, such as maintenance and seasonal employees. Their own employer or a PotashCorp supervisor supervises these employees. The nested contractor employee work hours and incidents are indicated as contractor injuries or illnesses and hours..
For PotashCorp contractor injury and illness reporting purposes, the following ‘contractors’ are excluded: Visitors to the site Persons delivering goods, products or materials at a PotashCorp site
Note: US facilities providing direct day-to-day supervision of contractor employees must record contractor incidents on their OSHA 300 Log.
> NON-NESTED CONTRACTOR A non-nested contractor is any non-PotashCorp person who is on PotashCorp premises under contract, for business purposes, or anyone providing materials, personnel, or services that directly benefit PotashCorp and relate to a contract or subcontract. The contract may be with PotashCorp or another contractor who is working on behalf of PotashCorp. For the purposes of this definition, these contractors provide services that are defined in the scope of a project and are finite in length. These contractors provide their own employee supervision.
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KEY SHE PROCESS 10 SHE Reporting Definitions
> DISTRIBUTION INCIDENTS Include transport incidents (all modes) resulting in: Hazardous Material (HAZMAT) event Non-Accident Release (NAR) Any environmental damage from material loss Any property damage exceeding US $50,000.
Incident reports are to be coded to show those incidents occurring during transportation and those occurring at customer premises.
> HAZMAT EVENT Mobilization of facility HAZMAT or third-party HAZMAT team for either on on-site or off-site emergency.
> NON-ACCIDENT RELEASE (NARS) A non-accident release (NAR) is the release of a hazardous material from a transportation vehicle (rail car or truck) that was not the result of the vehicle being involved in a derailment or other accident.
> ENVIRONMENTAL REPORTABLE RELEASE Includes the following categories of incidents: A Federal reportable quantity (RQ) release, whose quantity equals or exceeds the US Environmental Protection Agency’s notification level and is reportable to the National Response Center (NRC); A Provincial (Canada) reportable spill, defined as an unconfined spill (or release) into the environment as per Provincial/State/Federal regulatory requirements. In New Brunswick any spill of significance must be reported. In Saskatchewan, a spill must be reported immediately to the province and requires a written report within seven days. The on-site substances and amounts of the spills consist of: – Gasoline, diesel, process oil or other flammable material greater than 200 litres – Flotation reagents and dedust oils greater than 25 kilograms – Hydrochloric acid greater than 50 kilograms – Salts (potash, tails or brine equivalent) greater than 1,000 kilogram – Halogenated and non-halogenated solvents greater than 25 liters – Polychlorinated biphenyl (PCB) greater than 1 kilogram. A Federal (Canada) reportable environmental spill of: – Polychlorinated biphenyl (PCB) – any amount – Reportable Release of Deleterious substance to fish bearing waters
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KEY SHE PROCESS 10 SHE Reporting Definitions
> ENVIRONMENTAL NON-COMPLIANCE Includes the following category of incidents: An exceedance of a federal, state, provincial or local permit condition or regulatory limit; Failure to comply with a federal, state, provincial or local permit condition; including an omission or failure to report
> ENVIRONMENTAL COMPLAINT An environmental complaint includes a neighbor, employee or service provider complaint to a regulatory agency or to the facility.
> REPORTABLE ENVIRONMENTAL INCIDENT An uncontrolled release, of substances and amounts, into the site’s approved secondary containment areas or to approved waste management systems. In Saskatchewan, the incident must be reported to the province within 72 hours of occurrence; A minor release reportable to a US regulator (but below Federal RQ limits); A State only Reportable quantity (RQ) release; A spill into an approved secondary containment (Canada); A minor permit non-compliance that did not result in any State or Federal response/action; Incidents involving equipment reliability or human error resulting in a potential release;
> REGULATORY ACTION (NOV) Any written regulatory action such as a Notice of Violation (NOV), warning letter, enforcement letter, consents decree, etc.
> STATE RELEASE REPORT A state oil spill, or other release reporting requirement, which is more stringent than or separate from EPA reporting requirements.
> BREACH OF SECURITY A breach of security is an event that has not resulted in a security incident (or transportation security incident (TSI)), in which security measures have been circumvented, eluded, or violated, or suspicious activities that may result in a transportation security incident, and requires reporting to the NRC or the Transport Canada Minister.
> NON-BREACH SECURITY INCIDENT A non-breach security incident means any suspicious act or circumstance that threatening the security of a facility, a port facility, or any vessel / port interface, or any vessel – to –vessel activity.
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KEY SHE PROCESS 10 SHE Reporting Definitions
> SECURITY INCIDENT A security incident is an event resulting in significant environmental damage, transportation system disruption, or economic disruption for a particular area, or loss of life and requires reporting to the NRC or to Transport Canada.
> SECURITY NEAR MISS Simply because an attack or other incident is not carried out successfully does not mean that the incident was insignificant and should not be reported. Whether a “near miss” – that is, an adversarial action that was attempted but not successfully completed – is significant depends on the specific circumstances, such as the desired outcome of the attempt and the motive for the attempt. All security near misses should be reviewed to determine whether or not reporting to DHS, USCG or local law enforcement is justified.
> SIGNIFICANT SECURITY INCIDENT Significant security incidents likely will include incidents that arise based on an intentional threat (i.e. potential attack scenarios) that attempt to or successfully circumvent a security measure and/or a metric of a risk based performance standard.
> SUSPICIOUS ACTIVITY Refers to but is not limited to activity regarding a facility, port facility vessel, person, vehicle, cargo or stores which a reasonability prudent person would consider out of the ordinary or unusual based on the facts or circumstances for the situation.
> RELIABILITY INCIDENT Unplanned Shutdown Unplanned outage to a plant or mine lasting more than 24 hours. The appropriate nutrient President or VP Operations determines if a flash report and root cause investigation are required.
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KEY SHE PROCESS 11 Health Management
Safe and efficient operations depend on people. We must operate our facilities in a way that minimizes health risks to employees, contractors and the community, and encourages our people to adopt a healthy lifestyle. This will enhance operations integrity, our reputation and productivity, and will establish a firm foundation for growth. Health encompasses a ‘spectrum’ of states ranging from the extremes of premature death to optimum health. Good health benefits the individual and plays an integral part in delivering successful business performance by minimizing loss and maximizing gain.
> HEALTH RISK MANAGEMENT – THE ‘BASICS’ Effective health risk management encompasses four key activities: Business Planning Workplace, environmental and travel health hazards are identified, and risks are assessed: For all new operations or modifications to plant or process Before the acquisition of sites, leases, plant or materials Before posting staff to remote, tropical or developing countries Following changes in public and environmental health conditions Health Processes/Programs These should be in place to cover: Medical management – the provision of medical support in the event of injury or illness, and to enable work in specified jobs or working environments; Prevention – the control of workplace health risks to employees and contractors, the control of local public health risks to our employees and contractors, and control of environmental health risks to our neighbors, customers and the public from our operations and products; and, Promotion – activities optimizing the health and well-being of our people. Health programs are risk-based and their nature, scope and extent take into account the type and scale of the operation, the availability of suitable local health services, local hazards, legislation, standards and culture. Health Measurement and Assessment Procedures should be in place to: Report, investigate and document adverse health effects (illnesses) attributed to operations, processes, product or materials, and the working environment; and, Audit, verify and provide assurance of performance against expectations and external benchmarks. Health records are maintained confidentially. Health Performance Improvement A process should be in place to periodically: Assess performance Review health risks Seek continuous improvement
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KEY SHE PROCESS 12 Behaviors
Focusing on behavior does not imply faultfinding with individuals. Behavior is not a simple matter of personal choices. Behavior is affected by many factors, most of which are ultimately controlled by management. Accurately placing blame for at-risk behaviors would be embarrassing and counterproductive. Fixing the problem is the principle that truly prevents accidents. Analyzing how systems affect behavior is a starting point for designing behavior based safety systems that stimulate and reinforce safe behaviors. Designing systems in this way is an ongoing process, adapted to the organization in which the system operates. The design of such systems requires a comprehensive understanding of behavior and a high level of involvement and participation from all levels of an organization. Ultimately, people are safe or at risk by what they do (behavior). Unfortunately, they are often tempted to ignore the need for precautionary action because their experience has taught them they can take risks and not get hurt. The ABC Model of human behavior provides a framework for understanding why people do or do not take certain risks, so that we can design an effective intervention process. Behaviorists call the events that precede behavior, Antecedents (A) and the events that follow the Behavior (B), Consequences (C). Thus the ABC Model.
> THE ABC MODEL Antecedent: A signal, cue or prompt that comes before a behavior and sets the stage for the behavior to occur, (e.g. telephone rings, traffic light turns yellow, boss issues a memo calling for some action). Behavior: An act or actions of an individual that can be observed by others, what a person says or does, (e.g. you answer the telephone, you accelerate through the intersection to beat the red light, you immediately do what the boss’s memo tells you to do). Consequence: What happens to the performer as a result of the behavior, (e.g. talk to a friend, get stopped by a policeman for going through the red light, receive a thank you call from the boss for following instructions). The first step in understanding why someone is engaging in a specific behavior is to identify the precise antecedents that set the stage for that behavior. For example, the antecedent of a telephone call requesting a report and specifying a deadline sets the stage for writing a safety report. A vague request for information might not. Since many antecedents have little impact on our behavior, the next step in understanding behavior is to analyze the consequences that cause the behavior to continue. These might include getting approval for a plan, wasting time, or feeling proud of preventing an accident. Favorable or positive consequences cause a behavior to continue. Unfavorable or negative consequences have the opposite effect on behavior. There are many other facets to consider when using the ABC Model to manage performance. Timing and frequency of consequences must be considered as well, and of course, the delivery of positive consequences requires some thought and skill. Consequences must be clearly associated with the desired behavior or no change will occur. Whether a consequence is positive is determined by the performer, not the person delivering the consequence. Nevertheless, recognizing that behavior is a function of its consequences is a good place to start trying to understand behavior and how you can influence it for the benefit of the organization and the people in it. As previously mentioned, consequences determine whether a behavior will continue, increase, decrease or stop altogether. We often use the term reinforcement when speaking to employees to achieve behavioral change. When you see reinforcement in this context you can be sure that behavior will increase. However there are two categories of reinforcement – positive reinforcement and negative reinforcement.
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KEY SHE PROCESS 12 Behaviors
Positive Reinforcement provides a desirable outcome or consequence. People perform in certain ways because when they do, something occurs which they like. We choose a favorite shirt because when we wear it, we get complimented.
Negative Reinforcement requires the performer to do something in order to avoid something unpleasant. We wear rain gear when it’s raining to avoid getting soaked. We rarely wear it when the sun is shining. Both consequences have a place in life and in business. However, only positive reinforcement causes people to do more than they are required to do. Positive reinforcement is characterized as want to do, and Negative reinforcement is characterized as have to do.
One other type of consequence decreases or eliminates a behavior by providing an undesirable consequence to the performer or by removing something they like.
Punishment is the term used by behaviorists to indicate the delivery of an undesired consequence. When we ran that red light and were stopped and ticketed by the policeman, we received something we didn’t want – punishment. If this occurs frequently, we might actually stop driving through yellow lights. Although negative reinforcement and punishment have their places in the work place, positive reinforcement is the most effective way to improve performance. When people are positively reinforced for working safely, they not only seek more opportunities to work safely, they see safety as a source of job satisfaction rather than another requirement to be met. This produces exemplary safety performance. When we strengthen our use of safe behaviors, we automatically weaken the use of at-risk behaviors and avoid the negative side effects that always accompany any disciplinary process. Of course, it may be necessary to use negative consequences when someone intentionally engages in significant at-risk behaviors. Since discipline can only stop undesired behavior, it is essential to follow up disciplinary action with positive reinforcement for improvement. To support the efforts of identifying behaviors and providing feedback to employees, PotashCorp has trained and certified Internal Consultants that provide ongoing support and guidance to all facilities through workshops, on-site support and Sustainability Reviews to ensure that all processes are consistently applying behavior based safety systems appropriately.
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KEY SHE PROCESS 13 Communication of Product Information
PRINCIPLE As part of the overall commitment to quality and product stewardship, PotashCorp communicates up-to-date information to employees, customers and others who need to handle our products in a safe and environmentally responsible manner.
> SYSTEMS As part of this commitment, PotashCorp has developed several systems to: Address the assessment or re-assessment of products (including when safety tests are conducted for all new, modified, and re-introduced products.) Communicate up-to-date information on safety, health and environmental hazards and risks related to the use, storage (including suitability of the storage to the product as well as management, housekeeping, handling of products and off specs, security and emergency preparedness and safety), handling, transport and disposal of our products to customers, employees and others Address any regulatory changes that require additional testing or updating of product information Collect and review adverse effects reported or experienced by those handling our products Recall products in which a defect could give rise to safety, health or environmental hazards; Respond on a 24-hour basis to requests for safety, health and environmental emergency response or information regarding products Respond to customer complaints related to quality of product. These systems include: Procedures for new products or products being re-evaluated Safety Data Sheet Review Product Recall Procedures Specification Sheet Review
> PRODUCT REVIEW PROCEDURE New Products PotashCorp has developed a Product Request Procedure that includes a Product Request Form. This procedure requires that the person making the request have prior approval from the Vice President of Marketing and the President of PCS Potash, or the President, Phosphate & Nitrogen prior to beginning the process of adding a new product (see Product Request Form). The Product Request Form and Procedures ensures that the need for a new product is determined, and that all documentation is available to the customer upon initial shipment. In addition, if necessary, Agronomic testing would be conducted in conjunction with PotashCorp’s Director, Agronomy. Products being re-evaluated When it is determined that a product will either not be promoted or sold, documentation for Safety Data Sheets, Technical Data Sheets, and Product Information that is provided to customers via the Internet must be reviewed. If a product is no longer promoted but still may be manufactured, documentation is only available on the Intranet as “Not Promoted.” If the product is no longer sold or manufactured, it is available on the Intranet as “Not Sold.” Re-evaluated product requests do not require that a product request form be filled out unless the product has been inactivated for more than a year (see re-introduced products). 78
KEY SHE PROCESS 13 Communication of Product Information
Re-Introduced Products For products that were previously produced and that have been inactivated (for over a year), a procedure is in place to re-evaluate the product prior to reintroduction into the marketplace. This re-evaluation reviews the documentation for Safety Data Sheets, Technical Data Sheets, and Product Information that was provided to customers previously. If a product is no longer promoted but has the possibility that it may be manufactured, historical documentation is evaluated to determine if these specifications and product information are still valid, or need to be tested and updated. Also, often times the processes of production may have changed, and the previous method of production may no longer be utilized. In this event, the product is “re-introduced” and does require that a “Product Request Form” be filled out, and the Product Request Procedure be followed.
> SAFETY DATA SHEET REVIEW PotashCorp continuously and/or routinely monitors possible changes to information that is provided to customers, employees and others on Safety Data Sheets (SDS). In accordance with regulatory requirements under 29 CFR 1910.1200, PotashCorp updates SDSs within 90 days of notification of new and significant information about the hazards. In addition, PotashCorp conducts a thorough review of all SDSs every three years. SDSs for new products are created prior to initial shipment as outlined in the Product Request Procedures. SDSs are provided to customers with the first shipment, or with the first shipment after SDSs have been revised. SDSs are available on the PotashCorp Internet and Intranet and also may be provided to customers or individuals who handle our products.
> SPECIFICATION SHEETS Specification Sheets are reviewed by the Manager, Product Quality and Control. Specification Sheets are updated if changes are made to existing products, and new specification sheets are created for new products prior to initial shipment as outlined in the New Product Procedure.
> PRODUCT RECALL PotashCorp monitors our products to ensure that they meet our specifications. Any products which are outside of our product specifications and guarantees are recalled through our quality program. Individual PotashCorp facilities have developed detailed and specific programs for product recall. When it is determined that a product does not meet our specifications, this is communicated to Facility personnel, Sales and Corporate Product Supply personnel, the Manager, Product Quality and Control, Director, Product Stewardship & Security, and the Senior Director Corporate and Government Relations. In addition, the customer will be notified and advised that the product is subject to a recall and should be removed from sale and returned to PotashCorp. If the customer has re-distributed the product, the customer should cease distribution and recall the product. PCS Sales personnel will notify the customer regarding replacement of the product, and costs associated with the recall.
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KEY SHE PROCESS 13 Communication of Product Information
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KEY SHE PROCESS 13 Communication of Product Information
> PRODUCT REQUEST FORM General Information Person making request Proposed product (chemical name) Product composition (mixtures only) Product origin/plant source(s) Estimated volume (is product seasonal?) Product competitor name and location Target market Is product long term viable? Describe Identified Risks evaluated1?
Customer credit status Distribution Information Method of shipment
truck pipeline rail marine
Product DOT Hazard Class (if applicable) Distribution cost/ton/mile Freight zone (logical) Production Information Estimated production cost per unit Estimated cost to install/modify production, storage, loading facilities Does facility have adequate storage and loading capability? Estimated plant storage capacity
Approval Signature: _____________________________________________________________ Vice President, Marketing Approval Signature: _____________________________________________________________ President (PCS Potash or PCS Phosphate & Nitrogen) 1
See PotashCorp Risk Matrix for Products
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KEY SHE PROCESS 14 Developing Safety and Environmental Standards
> DEVELOPING SAFETY AND ENVIRONMENTAL STANDARDS: SEVEN STEPS OF THE SAFETY AND ENVRIONMENTAL STANDARD DEVELOPMENT PROCESS Step 1: Safety and Environmental risk identification and prioritization Utilize Key Process #2 to identify and prioritize safety risk to identify potential safety standards that may need to be revised or developed. Step 2: Determining the appropriate type of document to be developed When a corporate review of the data from ETQ or corporate safety identifies a risk requiring a standard or procedure, the corporate safety team will determine whether it is a Tier 1 or Tier 2 safety standard. When a site identifies a risk requiring a standard or procedure, they will notify the corporate safety team of their intent to develop a procedure. Before the site develops its own procedure, the corporate safety team determines: 1.
Is this a common risk across many sites, thereby requiring a corporate standard?
2.
Is there already a standard in place elsewhere at PCS that the site can use as a starting point?
Note: Corporate standards may need to be tailored to federal, state, local, and provincial regulations as required.
> POTASHCORP SAFETY & HEALTH DOCUMENTATION HIERARCHY
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KEY SHE PROCESS 14 Developing Safety and Environmental Standards
Step 3: Developing standards and guidance documents Developing new standards and guidance documents Safety Standard Process: Once a requirement is identified for a new corporate standard, then a standard ‘owner’ is identified. Phase 1 of the development process will be for the standard owner to facilitate creation of the proposed standard to a 75% draft. The draft will then be reviewed by the President of Nitrogen and Phosphate, President of Potash, and Vice President SH & E to gain alignment. The standard will then move to phase 2 where the owner will create a committee to support the development and review of the standard. The committee shall include a GM from Potash, Nitrogen, and Phosphate or their designee. The recommended development process will be a face to face meeting to develop the draft, followed by several rounds of syndication and refinement. When the standard is in its final state it must be approved for technical competence by the Senior Director Safety and Health or designee prior to be sent for roll out. The length of the development cycle will be limited to one to three months to ensure a speedy roll-out, and will vary depending on the severity of the risk. Guidance Document Process: Once a requirement is identified for a new corporate guidance document, then a guidance document ‘owner’ is identified. Phase 1 of the development process will be for the standard owner to facilitate creation of the proposed standard to a 75% draft. The draft will then be reviewed by the President of Nitrogen and Phosphate, President of Potash, and Vice President SH & E to gain alignment. The standard will then move to phase 2 where the guidance document owner will create a committee to support the development and review of the guidance document. The committee shall include a GM from Potash, Nitrogen, and Phosphate or their designee. The recommended development process will be a face to face meeting to develop the draft, followed by several rounds of syndication and refinement. When the standard is in its final state it must be approved for technical competence by the Senior Director Safety and Health or designee prior to be sent for roll out. The length of the development cycle will be limited to three to six months to ensure a speedy roll-out, and will vary depending on the severity of the risk. Accountability: The ‘owner’ will be accountable for delivery. He/she will work with a ‘committee’ who will support the development of the standard or guidance document. Implementation is owned by the site leadership team. Deviating from standards and guidance documents Process: There will be an extremely high bar for exceptions from corporate standards and guidance documents. Sites will need to –
apply for exceptions from standard and guidance documents for each job. If the job lasts more than one year, sites will need to reapply for an exception permit for that job on an annual basis.
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Accountability: Exceptions will need to be submitted by the site GM, and approved by the Divisional President and VP SHE.
Note: Templates for standards and guidance documents must be developed to ensure consistency of content and format across documents
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KEY SHE PROCESS 14 Developing Safety and Environmental Standards
Step 4: Introducing new and updated standards and guidance documents Introducing new and updated standards –
Process: All new standards and guidance documents that have been updated will be sent by the VP SHE and –Divisional Presidents. Standards will then be sent by Divisional Presidents to GMs. GMs must physically sign off on all new and updated standards. GMs will then forward the standards to their leadership team and all applicable personnel on their sites. The site will determine if the current site specific Tier 3 safety standard meets the new or updated corporate safety standard or guidance document. The site will insure that personnel, whom the standard applies, are appropriately trained and it is properly documented. New and updated standards will be issued quarterly (unless extremely urgent), to avoid a constant flow of new and updated standards on-site. Where required, training will be developed to support the roll-out of new standards.
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Accountability: Given management support is critical for the ensuring safety on-site; GMs will be accountable for introduction and implementation of standards at their site.
Step 5: Verifying application of standards and guidance documents Ensuring implementation of standards as they are written Process: The COO, Divisional Presidents and corporate safety team will highlight recently introduced and updated safety standards and guidance documents during their quarterly visits. Each site will provide an implementation status to the Division President on an agreed upon schedule. Accountability: The GM is ultimately accountable for implementation of standards at their site, and therefore for conducting the self-audit and following up on its results. There will be a two-part audit process for standards and guidance documents. The first will be a self-audit of all standards and guidance documents, conducted by site personnel once a year. The second will be a comprehensive audit of all standards and guidance documents by either the corporate safety team or a third party. Step 6: Renewal of standards and guidance documents Process: Standard ‘owners’ will lead the process of renewing each standard. A full review of all standards will occur at a minimum every 3 years – the next renewal date will be promptly posted on the front page of each document. Standards may need to be reviewed immediately if there is a serious safety issue identified between renewal dates, or is there is a change on-site. Updated standards should be rolled-out using the same process as new standards. Step 7: Assurance Each existing and upcoming standard and guidance document will have a named ‘owner’ on the corporate safety team. This owner will be accountable for development, implementation and renewal of the document as necessary. The VP SHE will provide annual assurance to the COO and / or Board of Directors that all safety standards and guidance documents are up to date. Standard ‘owners’ provide annual assurance to the VP SHE and site GMs that their standards are up to date.
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KEY SHE PROCESS 15 Product Stewardship
> PRINCIPLE Product stewardship might be described as the “next step” in Safety, Health and Environmental management, a step that broadens SHE Management beyond the facility gate to include wider issues such as procurement, quality, security and transportation / distribution. In many respects, it is about putting into place responsible business management processes across a product’s lifecycle. In this day and age, we can no longer ignore the role that chemicals and fertilizers in particular affect our day to day lives. It is now widely-acknowledged that without fertilizers, mankind would be unable to feed an ever increasing and more demanding population. Moreover, as governments and modern societies become more demanding of business and industry – it is becoming increasingly clear that industry should take a greater responsibility not only for how its products are produced, but also for how they are developed, sourced, stored transported and used. In some parts of the world, these processes are already regulated, while in others their regulation is pending or is currently under review. Nevertheless, global producers, like PotashCorp, can stay ahead of the regulation with proactive product stewardship management. Through the industry-driven IFA ( International Fertilizer Industry Association’s) Protect and Sustain initiative, PotashCorp is committed to address product stewardship management throughout the lifespan of our products.
> SYSTEMS Protect & Sustain is the trademark name for IFA’s Product Stewardship Initiative. By taking measures to ensure PotashCorp products are responsibly-developed, sourced, manufactured, stored, transported and applied, we are demonstrating our commitment to ensure that our products, including fertilizers, and intermediate products are used to the benefit of all and that inherent risk are at least minimized. PotashCorp has recognized, along with other IFA members that the minimization of accidents, waste and product misuse are not just the practices of good corporate citizens, they are also critical to our core business processes. By maximizing efficiency and productivity, while minimizing exposure to incidents and the legal ramifications, is considered and viewed as a central strategy to avoiding potentially crippling future costs. For PotashCorp, our management regularly reviews the objectives of our product stewardship initiatives to ensure overall suitability and effectiveness.
> SAFETY, SECURITY AND SUSTAINABILITY These are the three key objectives of Protect & Sustain: Safety – in the workplace and beyond, into our communities and environment; Security – from product misuse; and Sustainability – through maximizing efficiency and minimizing environmental impact.
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KEY SHE PROCESS 15 Product Stewardship
In 2007, IFA developed a set of guiding principles for Safety, Health and Environmental management. These twelve principles embody the membership’s commitment to responsible and sustainable fertilizer production and use. Throughout this document the IFA SHE Principles have been addressed.
> THE 12 IFA SHE PRINCIPLES In summary, the IFA SHE Principles are: 1.
All members shall demonstrate leadership and management commitment with regards to safety, security, health and environmental issues in fertilizer production, distribution and sales [See Element 1].
2.
All members shall strive for zero harm and adverse environmental impact whilst maintaining a healthy work place for all employees and contractual staff [See Element 3]
3.
All members shall ensure that safety; security, health and environment issues are integrated into their corporate policy and receive the utmost importance and priority [See Element 1
4.
All members shall ensure adequate financial and human resources for continual improvement of safety, security, health and the environment performance [See Element 13]
5.
All members shall comply with local safety, security, health and environmental laws and strive to embrace international laws and best practices as much as possible [See Elements 6 & 7].
6.
All members shall establish and improve their safety, security, health and environmental performance through annual objectives, targets or key performance indicators [See Element 1].
7.
All members shall establish adequate procedures and controls to ensure that safety, security, health and environment are not jeopardized at any time or in any form [See Element 1, Element 3, Key SHJE Process 1 and Key SHE Process 7].
8.
All members shall ensure that all employees and contractual staff have the right competence and are adequately trained and informed about safety, security, health and environment related to their specific activities, and shall encourage the participation of employees and contractual staff for further improvements [See Element 3].
9.
All members shall adhere to the principles of hazard and risk assessment in evaluating all their activities to ensure that safety, security, health and environment standards are continually enhanced [See Element 2 and Key SHE Process 2].
10. All members shall strive to subscribe to safety, security, health and environment management systems that will be subjected to internal and external auditing [Element 1 and Key SHE Process 1]. 11. All members shall voluntarily share information with regards to experiences and lessons related to safety, health and the environment with all employees and contractual staff, and with other IFA members, unless under legal constraints or if the information is of proprietary nature [Key SHE Process 3 and Key SHE Process 5]. 12. All members shall strive to continually promote safety, security, health and environmental matters to enhance the social responsibility and accountability of the global fertilizer industry [Element 1, Key SHE Process 1, Key SHE Process 7].
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KEY SHE PROCESS 15 Product Stewardship
The IFA Protect&Sustain framework could be said to be a logical continuation of the first of the SHE Principles that “all members shall demonstrate leadership and management commitment with regards to safety, security, health and environmental issues in fertilizer production, distribution and sales” [Element 1 and Key SHE Process 1]. In essence, what Protect&Sustain strive towards, is to provide a framework for extending the management of SHE issues beyond the fertilizer production facility and across the full supply chain.
> IFA SECURITY MEASURES IFA recognized the need for addressing security in production, transportation & distribution, storage and trading of fertilizer, as well as recognizing that certain nitrogenous fertilizers can be misused as precursors for making improvised explosive devices and there decided to include in its Product Stewardship certifications levels securityrelated measures to all nitrogenous fertilizers. In an effort to address these issues, IFA identifies in its self assessment framework (“Evaluation Tool”) specific requirements for security measures. PotashCorp addresses these issues in Key SHE Process 7.
> SUSTAINABILITY For PotashCorp, sustainability is a philosophy of nurturing mutually beneficial relationships with our stakeholders to create long-term value. Sustainability supports mutually beneficial relationships with our stakeholders to create longterm value. Sustainability supports our corporate vision; to play a key role in the global food solution while building long-term value for all our stakeholders. We embed our sustainability philosophy in all aspects of our business by: Operating with an understanding of how our strategies, actions and decisions impact the future of our business, the communities where we operate; Managing our resources and our stakeholder relationships with a long-term view, holding ourselves to the highest standards of transparency, integrity and accountability; Following sustainable business practices to gain operating efficiencies, improvement management performance, increase the positive impact of our operations and mitigate risks that could prevent us from accomplishing our goals; Working by our Core Values and related policies and designing economic, social and environmental practices will help us to fulfill our sustainable responsibilities to this generation of stakeholders and those to follow. Related PotashCorp Policies to Sustainability include our: Core Values and Code of Conduct that guides how we do business by defining our priorities and expectations for our employees and business partners SHE Policy that establishes a process and expectation for management employees on matters related to safety, health and the environment, including employee and facility security. Respect in the Workplace Policy that outlines expectations for proper conduct in the workplace and community by employees, supervisors, officers, directors, vendors, customers and agents of PotashCorp
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KEY SHE PROCESS 15 Product Stewardship
As stated previously in Element 9 – Customers and Products, PotashCorp promotes a 4R Nutrient Stewardship Program that helps define fertilizer management practices that should be used for farm fertility programs. In addition, PotashCorp employs a staff agronomist who works closely with industry associations, academic researchers and growers. PotashCorp has played an important role in the development and promotion of the 4R Nutrient Stewardship System – a site specific and science based approach to crop management designed to prevent lake stream runoff and help everyone understand the importance of applying fertilizer correctly. The 4Rs program is a great framework for Best Management Practices (BMPs) for fertilizer application. The goals of fertilizer BMPs are to match nutrient supply with specific crop requirements, and to minimize environmental impact through nutrient losses from the fields. The 4R concept calls for using the “right” fertilizer source, rate, timing and placement of plant nutrients – that is, the combination of nutrients and practices that result in the agronomic, economic, social and environmental benefits favored by the crop grower and his stakeholders. The flexible system, which incorporates proven agronomy research, is designed to both increase crop efficiency and to make clear the link between science and results.
The 4R’s: Right product: Match the fertilizer product to crop need and soil properties, balancing nitrogen, phosphorus, potassium and other nutrients according to soil analysis. Right rate: Match the amount of fertilizer applied to the crop needs; too much fertilizer leads to losses into the environment; too little results in lower yields and crop quality. Right time: Make nutrients available when the crop needs them; controlled release technologies, stabilizers’, inhibitors and product choice can all impact nutrient timing. Right place: Place and keep nutrients where crops can use them, crop, cropping system and soil properties dictate the most appropriate method of application.
Farming is a business. And when making business decisions, farmers need as much information as they can get. That is why PotashCorp has designed a website to help grow crops and bottom lines. The user-friendly eKonomics website features the latest crop nutrition research, the industry’s first Nutrient Return on Investment Calculator, geographic soil test data, commodity future prices, rainfall data, and much more. This information assists farmers in sustaining the soil fertility levels needed to maximize yields and profits.
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KEY SHE PROCESS 16 SHE Compliance with Existing and Pending Requirements
Identification and Review of Existing and Pending Requirements PotashCorp identifies existing and pending requirements for regulations (Federal, State/Provincial or Local) and industry codes by regularly reviewing proposed, pending or published regulations that have been identified as having relevance for PotashCorp and through working with various groups (Canadian Fertilizer Institute (CFI), The Fertilizer Institute (TFI), Association of American Plant Food Control Officials (AAPFCO); ASSE (Association Society of Safety Engineers), Saskatchewan Mining Association (SMA), Saskatchewan Potash Producers Association; ASIS International; National Fire Protection Association (NFPA); and others. In addition, where appropriate, PotashCorp works with the various governmental agencies to assist in the development of regulations and guidance. Utilizing the information that is obtained, PotashCorp develops appropriate guidance or standards, training and audit protocols, as well as determination of criteria for the selection of external auditors. Guidance Documents PotashCorp will, when relevant, create guidance documents or standards to address specific regulatory requirements or industry codes or PotashCorp best practices. It is the responsibility of facility management and employees to utilize the guidance provided to ensure that they are following the guidance or standards to meet regulatory requirements, industry codes or PotashCorp best practices. Training PotashCorp personnel who have responsibility for compliance will coordinate with the Training Department to establish specific training (Tier 1 – All of PotashCorp; Tier 2 – Nutrient; or Tier 3 – Site Specific) for the regulations, industry code or PotashCorp best practice. In addition, individuals who will conduct internal audits will be provided with relevant training on the regulation, industry code or PotashCorp best practice they will be auditing, and audit criteria as well. Audit Protocols PotashCorp personnel who have responsibility for compliance will develop audit protocols to ensure that relevant regulations, industry code or PotashCorp best practices are audited and that compliance is identified. Audit Protocols will be reviewed at a minimum of every three years, and will be updated with any changes to the regulation, industry code or PotashCorp best practice. SHE Compliance Audits and Assessments SHE Compliance Audits and Assessments include internal (conducted by Corporate SHE personnel and selected individuals from other PotashCorp facilities not being audited) as well as external audits (companies with the appropriate skills and knowledge as the area being assessed) and assessments for Safety, Environmental, Security, Emergency Response and Product Stewardship.
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KEY SHE PROCESS 16 SHE Compliance with Existing and Pending Requirements
By design, at any PotashCorp operating facility, internal audits occur at facilities that are not being externally audited. All facilities are audited annually. Internal audit protocols have been developed, and are continually reviewed and updated and are controlled by the appropriate Corporate SHE individual responsible for the area of review. Findings from internal audits and assessments are entered into facility action plans to ensure that areas of concern are addressed. Depending upon the audit / assessment, findings are entered into and tracked
to completion in EtQ1 in a timely manner.
1
If audits or assessments are conducted under “Attorney-Client Privilege” then the findings and action plan may or may not be entered into EtQ. If entered into EtQ, these findings will be limited as to who has access to view. It is the responsibility of the General Manager (Plant Manager) to ensure that all findings are addressed in a timely manner (whether they are entered into EtQ or not). 93
KEY SHE PROCESS 16 SHE Compliance with Existing and Pending Requirements
KEY SHE PROCESS 13 Communication of Product Information 94
Everybody who works for PotashCorp, anywhere, is responsible for PotashCorp’s Safety, Health and Environmental performance and Security. Good
SHE performance is critical to the success of our business.
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