Environment, Health & Safety (EHS)
Keeping our people safe and minimising our environmental footprint
- Achieved the lowest Lost Time Injury Frequency Rate (LTIFR) in the Group’s history
- Reorganised the EHS function to reflect Tullow’s new regional business structure, including the recruitment of three senior Regional EHS Managers
- Introduced Tullow Safety Rules
- Undertook a detailed review of EHS KPIs and made some significant changes for 2012 to reflect the changing nature of Tullow’s activities and EHS risks
EHS is a priority in all that we do, based on our desire to ensure we do no harm to our colleagues, our neighbours or the diverse environments in which we work. In 2011, we delivered an excellent EHS performance with our lowest Lost Time Injury Frequency Rate (LTIFR) despite the increasing scale and diversity of our assets and activities.
To ensure we can consistently deliver this superior performance we have continued to enhance our EHS capability through improvements to our EHS resources and reporting structures and with the introduction of new standards. We have reorganised our EHS function to reflect our new regional business structure with the recruitment of three senior Regional EHS Managers. These EHS managers and their Regional Business Managers provide EHS leadership in their area and are the conduit for EHS reporting to the Executive.
We have also implemented a number of new standards and procedures across the business, the most important being the introduction of the Tullow Safety Rules. In addition, in 2011 we set up a strategic EHS Strategy Forum, which includes both Executive Directors and Senior Management, to ensure that we continue to look for new ways of thinking about how to improve EHS performance. The EHS Strategy Forum team has already generated some innovative thinking and ideas of how we can ensure that we maintain a dynamic and fresh approach to EHS.
EHS operators carrying out safety checks on facilities at the Bangora field in Bangladesh.
EHS Key Performance Indicators
We manage our EHS performance through a combination of leading and lagging KPIs. Leading indicators are qualitative and focus on achieving improvements in performance in targeted areas. Lagging indicators show how we have performed based on quantitative data and preset targets.
2011 lagging indicators
In 2011, over 13 million hours were worked across Tullow including a significant number of higher risk activities such as deepwater drilling offshore French Guiana and the ramp-up of production and delivery of oil to tankers from the FPSO in Ghana. During 2010, we held a Group-wide safety stand-down to raise the profile of our performance targets and reaffirm the Group’s commitment to making the safety of people paramount in our operations. We reinforced this in 2011 with the introduction of Tullow Safety Rules. These are a set of requirements designed to manage high-risk activities that have the potential to adversely affect our personnel, surrounding communities and the environment. They were established using industry practices, guidelines and standards and are intended to reinforce Tullow standards and applicable host country regulatory requirements. In 2011, we had an excellent safety performance and achieved our stretch target for LTIFR. We achieved our baseline target for Total Recordable Injury Frequency Rate (TRIFR) and our stretch target for High Potential Incident Frequency Rate (HiPoFR). Full details are outlined in the lagging indicator table below.
|Target||Number of incidents||2011 performance||Status|
<0.76 with a stretch target of <0.5 per million worked hours
<3.0 with a stretch target of <2.5 per million worked hours
<1.2 with a stretch target of <1.0 per million worked hours
Vehicle Accident Frequency rate
<1.0 with a stretch target of <0.8 per million kilometres
Number of loss of containment incidents (Water, diesel oil, chemicals, vapours, gases, etc) > 50lt ≤3 with stretch target of ≤2
In 2011, we did not achieve our Vehicle Accident Frequency Rate (VAFR) which at 1.46, exceeded our target of 1.0. There were 12 recordable vehicle incidents during the year, all in Africa. There were no fatalities, although three were high potential incidents and three caused minor injury. Unfortunately since year-end there has been one third party fatality in Ghana and another third party fatality in Kenya. Full investigations of all incidents have been carried out and a series of key actions are being undertaken as a matter of urgency. In the first instance, an external review of Tullow’s journey management plans and driving policy will be conducted and further driver training will be provided.
We did not achieve our Uncontrolled Releases targets, which was a KPI we introduced in 2011. This KPI reflects the fact that Tullow’s operations are mainly based in sensitive environmental areas and it is important to demonstrate good practice and the integrity of our equipment. In adopting this KPI we have significantly improved our reporting of environmental incidents and as a result we have collected valuable data which will help us improve our processes.
The effect of Uncontrolled Releases to the environment depends on two vital components – the volume released and the receiving environment. For example, while the release of contaminated water is often thought to pose a lower risk to the environment, it may contain oilfield chemicals which could be detrimental. Equally onshore releases can be as damaging as offshore releases both from the perspective of sensitive habitats (ecology and tourism) and the perception of stakeholders to accidental spills or releases; hence the need to have a strong KPI.
In 2011, Tullow had 14 incidents of uncontrolled releases, over four times our target. All of those incidents occurred in Africa, with eight in Uganda and six in Ghana. Over 50% of the incidents related to drilling fluids. While none of the incidents were significant a key focus for 2012 will be integrity management across all our operations, with a particular focus on drilling fluid storage and management in Uganda.
2011 leading indicators
In 2011, we achieved three of our leading indicators, which are outlined below. Activity to improve the management of EHS contractor processes is ongoing, with the recruitment of dedicated supply chain EHS resources planned. We reviewed the independent EHS audit indicator and replaced this with a focus on operating in environmentally sensitive areas, which is increasing every year for Tullow. The management of our environmental footprint and the process we adopt for evaluating our activities in protected/sensitive areas is very important. As a consequence we are developing guidelines for new country entry in 2012, which will be followed as part of New Ventures’ planning processes.
|Implementation of Corporate EHS audit programme and achieve a minimum of six audits 2011||Approved audit plan in place. Six audits completed in 2011.|
|Implement Tullow Safety Rules for all operations||Tullow Safety Rules launched on 1 August 2011. Roll out completed.|
|Develop management of contractor EHS process, incorporating EHS input to contracts, identification of high risk contractors and audit of high risk contracts.||Recruitment planned for specific EHS resources to support contract strategy in Supply Chain Management.|
|Complete independent audit of malaria management policy, procedures and implementation. Agree system improvements and implement by end of Q3 2011.||Audit completed in Corporate offices, Ghana and Uganda. Action plan in place and implementation being monitored.|
|Undertake an independent EHS audit to further identify opportunities to strengthen EHS systems and culture.||This objective was superseded by the work undertake by the new EHS strategy team and was not undertaken as a consequence.|
Historically the Group’s EHS KPIs were defined each year in support of driving improvement in certain areas of EHS performance. Towards the end of 2011, the new EHS Strategy Forum undertook a detailed review to ensure that EHS KPIs reflect the changing nature of Tullow and the critical EHS risks across the business. The objective is to encourage the right EHS and leadership behaviours. In 2012, leading indicators will build on the 2011 performance with a refined focus on action tracking, safety critical equipment, contractor management, toes and EHS leadership. A more significant change was undertaken with lagging indicators because of a concern that these focused too much on statistics and incidents rather than learning and improving. The 2012 lagging indicators have therefore been changed to ensure that we learn from those incidents that could have a significant impact on Tullow’s business including High Potential Incidents, significant spills through uncontrolled releases and malaria management. We will continue to track and report industry standard KPIs as a matter of good practice.