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Life-saving rules

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Life-Saving Rules User Agreement

The user accepts that any use of the OGP Life Saving Rules shall be on an ‘as is basis’ and that the re-

sponsibility for the interpretation and use of the OGP Life Saving Rules lies with the user. In no event

will the OGP or any contributer to the development of the OGP Life Saving Rules (or an affiliate of such

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The user further agrees to only use the OGP Life Saving Icons and specific accompanying wording un-

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OGP Life–Saving Rules

Report No: 459

April 2013 (Version 2)

Acknowledgements

This document was produced by the OGP Safety Data Sub-committee

Revision history

Version Date Amendments

2April 2013Amendments to safety icon deisgns

1February 2012First issued

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1 Introduction

12 The OGP Life-Saving Rules

23 Implementing the OGP Life-Saving Rules

3.1 Fundamental requirements ..................................................................................................................................................................63.2 Life-Saving Rules implementation resources ...................................................................................................................................83.3 Lessons learned in rules implementation ..........................................................................................................................................93.4

Continuous improvement (10)

Appendix A Background and supporting data 11

Historical data review ........................................................................................................................................................................................11OGP fatal incident and high potential event workshop ............................................................................................................................12Development of OGP Life-Saving Rules .......................................................................................................................................................12OGP data analysis ...............................................................................................................................................................................................13OGP Member company rules ..........................................................................................................................................................................14Background ..........................................................................................................................................................................................................15Aims (15)

Appendix B Life-saving rules – implementation case study 15

Impact and benefits (18)

Table of contents

OGP Life-Saving Rules

Please refer to the Life-Saving Rules User Agreement (inside cover of this document) for the conditions of use of the Life-Saving Rules icons and accompanying wording .1 I ntroduction

This document provides a set of life-saving rules which can

be used in the oil & gas industry to mitigate risk and reduce fatalities. Member companies recognise the value of provid-ing clear, simple and consistent communication regarding risks in the workplace and the proper use of barriers and safeguards to protect the workforce. Each OGP Life-Saving Rule in this document consists of a simple icon and descrip-tive text, with additional detailed guidance to explain why the Rule is important and what aspects workers and super-visors should focus on. Each Rule is also linked to controls and barriers which, if used properly, can prevent or avoid fatal incidents.

The OGP Life-Saving Rules are intended to supplement and support existing company management systems, pro-grammes and policies. The Rules focus on modifying worker and supervisor behaviours in the workplace by rais-ing awareness of activities which are most likely to result in fatalities. They also highlight simple actions individuals can take to protect themselves and others.

While member companies can benefit from implementing their own programmes, there is a larger potential benefit to be realised in standardising life-saving rules across the industry. Contractor employees are required to learn dif-ferent rules and procedures for each client, even though the operating practices and risks are essentially the same. Migrating toward a standard set of industry life-saving rules will improve understanding and compliance, particularly in multi-language and multi-cultural settings, with the aim of reducing serious incidents and fatalities. It is recommended that:

? Companies without life-saving rules should consider adoption of these OGP Life-Saving Rules.

? Companies who already have equivalent rules should, at the next revision cycle, consider adoption of or align-ment with the OGP Life-Saving Rules.

? Companies actively support their (sub) contractors in implementing the OGP Life-Saving Rules.This document also provides guidance on roll out approaches that can be used to effectively communicate and implement these Rules.

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2 The OGP Life-Saving Rules

Table 1 contains the eight OGP Core Life-Saving Rules which are most applicable to the oil & gas industry. Table 2 contains ten OGP Supplementary Life-Saving Rules which many companies may find applicable depending on their risk profile.

Table 1: OGP Core Life-Saving Rules

OGP Life-Saving Rules

Please refer to the Life-Saving Rules User Agreement (inside cover of this document) for the conditions of use of the Life-Saving Rules icons and accompanying wording .

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Table 2: OGP Supplementary Life-Saving Rules

OGP Life-Saving Rules

Please refer to the Life-Saving Rules User Agreement (inside cover of this document) for the conditions of use of the Life-Saving Rules icons and accompanying wording .

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3 Implementing the OGP Life-Saving Rules

I t is recommended that companies working in the oil & gas industry adopt the OGP Life-Saving Rules. Analysis of 1,484 fatal incidents reported by OGP member compa-nies over the last twenty years indicates that adoption, con-formance and enforcement of these simple Rules may have prevented many of these fatalities. Each company should consider their operations, activities and high potential event history to determine which Rules will be most effective in reducing risk.

Companies implementing the rules should, at a minimum, adopt the eight OGP Core Life-Saving Rules that corre-spond to 40% of historical fatal incidents reported to OGP. Supplementary Rules can be selected to address particular risk exposure of the implementing organisation.

OGP member companies should actively support their (sub) contractors in implementing the OGP Life-Saving Rules. This standardisation will simplify training and aid compliance and intervention.

I t is important that the Rules are communicated to all workers, preferably as part of each new worker induction, safety awareness campaign, pre-job discussion, etc.

3.1 Fundamental requirements

There are some fundamental requirements that an organisa-tion needs to have in place to ensure the effective implemen-tation of the OGP Life-Saving Rules:

? Work will not be conducted without a pre-job risk assessment and a safety discussion, such as a toolbox talk, appropriate for the level of risk.

? All personnel will be trained and competent for the work they conduct.

? Personal protective equipment will be provided and worn in accordance with the requirements identified by the risk assessment and work-site policies.

? Emergency response plans, developed from a review of potential emergency scenarios, will be in place with suitable and sufficient resources available, before com-mencement of work.

? Everyone is authorised to stop work if they are in doubt about the safety of an activity.

? Peer to peer interventions should be encouraged with regard to compliance with the OGP Life-Saving Rules.

OGP Life-Saving Rules

Please refer to the Life-Saving Rules User Agreement (inside cover of this document) for the conditions of use of the Life-Saving Rules icons and accompanying wording .3.1.1 Personal safety

The implementing company is required to ensure that the necessary personel, training, equipment and resources have been provided in order to support the effective implementa-tion of the OGP Life-Saving Rules associated with personal safety.

3.1.2 Driving

There is an OGP recommended practice on land transpor-tation that addresses both journey management and per-sonal safety requirements. This material should be helpful to organisations implementing the OGP Life Saving Rules related to driving. I t can be downloaded from the OGP website:

? Land transportation safety recommended practice , OGP Report № 365

3.1.3 Site safety

The Life-Saving Rules related to site safety require the implementing company to clearly state the requirements for each of the Rules they have selected, examples include:? designation of authorised smoking areas

? safe working distances from overhead power lines

? Substance misuse: a guide for managers & supervisors in the oil & gas industry , OGP/IPIECA Report № 445

3.1.4 Control of work

OGP has previously produced guidance pertaining to con-trol of work which would be worth consulting for organisa-tions implementing Rules in this category. The material can be downloaded from the OGP website:

? Guidelines on permit to work systems , OGP Report № 189

? Lifting & hoisting safety recommended practice , OGP Report № 376

3.1.5 Authority to stop work

All members of the workforce should understand that they have the responsibility and authority to intervene and stop work if they observe potential or actual non-compliance to these Rules or indeed any other unsafe activity. The intent is to create a safe working environment for every-one. Companies should promote the development of a cul-ture that encourages individuals to intervene and that only allows work to be carried out when there is compliance with the Rules/zero tolerance for non compliance. Proactive intervention may be the last opportunity to prevent a seri-ous injury or fatality. If rule breaking occurs, workers should know that they must notify their supervisor or the person in charge of the work activity (or higher level management) immediately.

The OGP Life-Saving Rules can be grouped into four broad categories.

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3.2 Life-Saving Rules implementation resources

OGP has provided a package of materials to assist companies in the roll-out and implementation of the OGP Life-Saving Rules, please visit: https://www.wendangku.net/doc/f53840776.html,/publications/life-saving-rules.

The Life-Saving Rules User Agreement (inside cover) states the conditions under which the Life-Saving Rules icons and accompanying wording is made available.The materials available at time of publication of this report

are:

applicability of the OGP Life-Saving Rules to historical OGP reported fatal incidents and high potential events.

selecting appropriate life-saving rules for their

organisation.

OGP Life-Saving Rules

Please refer to the Life-Saving Rules User Agreement (inside cover of this document) for the conditions of use of the Life-Saving Rules icons and accompanying wording .3.3 Lessons learned in rules implementation

OGP Life-Saving Rules should be rolled out as a project with the commitment of senior management. Based on the experience of OGP member companies that have imple-mented life-saving rules, it is recommended that the follow-ing steps are taken:

? Conduct a risk assessment of your organisation’s activi-ties and review historical data related to fatalities and high potential events within your own organisation. Compare the rules to the risk profile of your organi-sation and select life-saving rules for initial implemen-tation. This should include the eight Core Rules and some Supplementary Rules that address specific risks in your organisation.

? Develop a business case/change management pro-gramme and discuss with management to ensure com-mitment to implement the selected set of rules.

? Adopt the set of Core Rules (unless your risk assess-ment suggests otherwise) and select Supplementary Rules as applicable.

? Develop a communications and roll-out plan for the implementation of the chosen Rules (stakeholder map-ping, communications plan, accountability and com-pliance strategy in consultation with legal and human resources).

? Develop performance monitoring metrics (KPI s) to determine the level of effective implementation of the Rules (e.g. percentage of training conducted, monitor-ing of rule breaking, review of lagging indicator met-rics, workplace behaviour modification).

? Customise OGP roll-out materials such as the leader-ship and contractor engagement employee packs.

? Monitor performance and report to management with improvement opportunities.

? Review organisational data to determine if additional Rules are required.Appendix B contains a case study on the implementation of life saving rules at an OGP member company.

3.3.1 What is important for leaders

It is important for leaders to know that:

? the OGP Core and Supplementary Life-Saving Rules are linked to the prevention of a majority of fatal inci-dents reported to OGP

? OGP advises the adoption of a set of Core Life-Saving Rules. Member companies can add selected Supplementary Rules to fit their risk profile

? it is good practice to start with a set of Rules to get 100% compliance and develop a culture of ‘this is the way we work’

? leaders show their commitment by monitoring compli-ance and showing zero tolerance for non-compliance ? supervisors/leaders create work conditions so that workers can comply.

3.3.2 What is important for workers

It is important for workers to know:? the meaning of the Rules

? that compliance is mandatory since non compliance can result in a fatality

? that Life-Saving Rules describe actions for the indi-vidual that may be the last barrier to prevent a fatality ? that the Rules enable workers to discuss worksite risks with their supervisors and gives them the authority to stop work.

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1 The life-saving rules are for everyone

The intention is to keep everyone safe by ensuring everyone follows the same life-saving rules. The OGP Life-Saving Rules focus on activities with the greatest potential for seri-ous injuries or fatalities. In those situations, the message to workers should be “if you choose to break the life-saving rule, you choose not to work here”.

2 Avoid the perception that the company is looking to dismiss workers

A frequently asked question is: ‘isn’t disciplinary action against someone a bit extreme for breaking a life-saving rule?’ The commitment to implement life-saving rules is to protect people. Companies can invest a lot of effort in making sure people know the rules. It is better to take disci-plinary action than to allow people to take risks that could result in them hurting or killing themselves or others.

3 Take action any time the life-saving rules are broken

Disciplinary action should follow once an investigation has proven a life-saving rule has been broken, not only when an incident with actual consequences has occurred. Following a thorough investigation, disciplinary action should take into account the risk taken and local employment laws. The intent is to apply consistent disciplinary action that is appropriate to each situation.

4 Encourage open reporting

Stress to personnel that by not reporting rule breaking they choose to make the workplace a more hazardous place for themselves, colleagues and friends. Positively reinforce an open reporting culture and respond appropriately where cases of ‘non-reporting’ are found.

3.4 Continuous improvement

Initial introduction of life-saving rules to the workforce is not enough. A continuous effort is required to drive 100% compliance. Monitoring of life-saving rule breaking will enable identification of which rules need further reinforce-ment, or where controls or work conditions need to be revised to help workers comply. A number of tools exist to continuously improve compliance to the life-saving rules, for example:

? ‘mini’ campaigns, to raise awareness ? retraining of employees and workers ? site visits of leaders

? regular reporting on rule breaking and its causes to management

3.3.3 Accountability and disciplinary policies

Experience from member companies suggests that for a life-saving rules programme to be successful there must be accountability for compliance with the rules and conse-quences for rule breaking or wilful violations at all levels throughout the organisation. It is critical that leaders drive toward a 100% compliance culture. Although this docu-ment does not provide a specific accountability and discipli-nary model, the following key points should be considered:

OGP Life-Saving Rules

Please refer to the Life-Saving Rules User Agreement (inside cover of this document) for the conditions of use of the Life-Saving Rules icons and accompanying wording .Appendix A Background and supporting data

0.00.5

1.0

1.5

2.0

Overall Contractor Company

Figure 1 – Lost Time Injury Frequency

Company and contractor incidents per million hours worked

Figure 2 – Total Recordable Injury Rate

Company and contractor incidents per million hours worked

Figure 3 – Fatal Accident Rate

Company and contractors per 100 million hours worked Historical data review

OGP reported incident data shows that Lost Time I njury Frequency Rates (LTI F) and Total Recordable I njury Rates (TRIR) have decreased significantly over the last 10 years, as shown in Figures 1 and 2.

OGP reported Fatal Accident Rates (FAR) for the same time frame show similar declines at first, but then a slower rate of improvement over the last four years (2007-2010), as shown in Figure 3.

This raises the concern that while, as an industry, we may be getting better at preventing more frequent, less serious incidents, we have not been as successful at reducing the rate of less frequent, more serious incidents.

Note: Of the 90-100 fatalities reported to OGP each year, gen-erally in excess of 70% involved contractor personnel.

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OGP fatal incident and high potential event workshop

Considering the plateau in fatalities and the large percent-age of contractor personnel involved, the OGP Safety Data Sub-Committee (SDSC) sponsored a two day workshop in January 2010. The objective of the workshop was to focus specifically on causes and prevention of fatal incidents and high potential events in the upstream oil & gas industry. The workshop resulted in recommendations to the OGP Safety Committee on actions that could be taken to pre-vent future fatal incidents and high potential events. The workshop involved 38 participants representing 26 OGP member and associate member companies and 3 industry trade associations, participants covered a wide geographi-cal area. Over the two days of the workshop the attendees were provided with information from OGP data along with member company experiences in the form of both presen-tations and a knowledge sharing session. This information was used to set the scene for a series of interactive workshop sessions and panel discussions.

A study was presented on all the fatal incidents from 2005 to 2008 which had been reported by OGP member com-panies. The publically available data had been reviewed for trends related to cause and the use of protective barriers. Some 332 workplace related fatal incidents were analysed, resulting in the following conclusions:

? 83% of threats associated with fatalities analysed were human factors related

? process safety hazards represented only 16% of the fatalities

? skill-based errors were reducing while rule-based errors were increasing

? recommendations were generally aligned with identi-fied inadequate control measures

? the inadequacy of procedural control measures was increasing dramatically. Especially project specific planning and procedures needed to be addressed.

The OGP data study and several other presentations given by representatives of member companies indicated that there were common trends in the causal factors of fatal incidents. The workshop participants concluded that there would be value in having OGP pursue the development of a set of standardised industry life-saving rules. It was agreed that the rules should:

? use simple, standardised icon and descriptive text

? focus on workplace hazards that are most likely to con-tribute to fatal incidents

? build on existing OGP data studies, member compa-nies’ experience, and good practices in other industries ? be used by member companies to build new life-saving rule programmes or enhance existing programmes.Based on the outcomes of the workshop, two SDSC task forces were formed to work on two key deliverables:

? define, analyse and report on ‘causal factors’ for fatal incidents and high potential events

? the development of an appropriate set of recommended life-saving rules A standardised list of ‘causal factors’ were developed and approved by the OGP Safety Committee for inclusion in the 2010 OGP request for safety data. The resulting infor-mation has been published in Safety performance indicators – 2010 data , OGP Report № 455.

Development of OGP Life-Saving Rules

Two approaches were taken in the development of the OGP Life-Saving Rules; the first was an analysis of OGP reported data and the second was to learn from and ensure alignment with member companies that had already developed rules.

OGP Life-Saving Rules

Please refer to the Life-Saving Rules User Agreement (inside cover of this document) for the conditions of use of the Life-Saving Rules icons and accompanying wording .OGP data analysis

The OGP Life-Saving Rules development group conducted a comprehensive review of the data reported to OGP from 1991 to 2010 (inclusive) for fatal incidents and from 2000 to 2010 (inclusive) for high potential events. As the classifications of incidents and events had changed over this time period, the incident descriptions submitted to OGP were also reviewed and reclassified according to the current definitions, as listed below.

Category of event

? Assault or Violent Act

? Caught In, Under or Between ? Confined Space

? Cut, Puncture, Scrape ? Exposure Electrical

? Exposure: Noise, Chemical, Biological, Vibration ? Explosions or burns ? Falls from height ? Overexertion/Strain ? Pressure Release

? Slips and Trips (at the same height)? Struck By

? Water Related, Drowning ? Other

Type of activity

? Construction, Commissioning, Decommissioning ? Diving, Subsea, ROV

? Drilling, Workover, Well Services

? Lifting, Crane, Rigging, Deck operations ? Maintenance, Inspection, Testing

? Office, Warehouse, Accommodation, Catering

? Production Operations –includes normal, start-up or shut-down operations ? Seismic/Survey operations ? Transport – Air ? Transport – Land

? Transport – Water, including Marine Activity ?

Unspecified – Other

Additional 10 rules 30%

No appropriate rule

Core 8 rules

40%Figure 4 – % applicability of rules to fatal incidents

(1991-2010)

Additional 10 rules 26%

No appropriate rule

51%

Core 8 rules

23%Figure 5 – % applicability to high potential events

(2000–2010)

Additional 10 rules 28%

Core 8 rules

32%No appropriate rules

40%

Figure 6 – % applicability of rules to fatal incidents (1991–

2010) and High Potential Incidents (2000–2010)The results of the review indicated common situations where compliance to simple rules could have avoided fatal incidents. This information was used to determine a list of potential rules most relevant to the industry.

A second review of the historical data was then undertaken to ensure the life-saving rules selected corresponded to the acceptance criteria (as determined by the outcome of the workshop), which were:

? identify eight core rules that apply to at least 40% of OGP reported fatal incidents

? identify a larger set of additional rules that apply to at least 60% of OGP reported fatal incidents

? each rule had to include a simple icon and descriptive text

? each rule had to be applicable to individual workers and supervisors, encouraging personal accountability and enabling disciplinary action to be taken at the dis-cretion of the implementing organisation.The results of this second review indicated that failure to follow at least one of the full set of 18 life-saving rules described in this document was a contributing factor in 70% of the 1,484 fatal incidents analysed and 48% of the 1,173 high potential events.

The results show that the aim of having the eight OGP Core Rules applicable to at least 40% of the OGP reported fatali-ties has been met.

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OGP Member company rules

One member company which implemented a set of life-sav-ing rules in 2009 has seen significant decreases in serious incident rates and fatality incident rates which they attrib-ute in part to the new life-saving rules programme. This is consistent with experience reported by other member com-panies.

OGP member companies were asked to submit examples of similar industry rules already in use. These were compared and common themes in graphics, text and implementation approaches were identified.

I nformation was submitted by fourteen companies that had developed their own safety rules. The number of rules varied from 4 to 13 per company, with an average of 10 rules per company. The subject matter of the rules was reviewed to determine the most common themes covered. The most common subjects included (by percentage of companies that covered the subject matter):? permit to work – 86%

? journey management – 86%? mechanical lifting – 71%? working at height – 71%? energy isolation – 57%? confined space entry 50%

? excavation (ground disturbance) – 36%

There were a further 31 hazards which had been addressed by a rule. As the OGP Rules were intended to focus on issues that were most likely to result in a fatality, a review of additional rules in conjunction with the OGP historical data indicated the following should also be considered:? hazardous gas – 21%? alcohol /drugs – 14%? smoking – 14%

The detailed text associated with each of the rules was also reviewed to determine common requirements. Some of the member company rules had been written in such a way as to allow disciplinary action to be taken in the event of a rule not having been complied with; other companies had written their rules in a different style. A decision was taken to ensure that the OGP Rules could be used in conjunc-tion with disciplinary action although whether to follow this option would be left to the implementing company to decide. A case study for the use of disciplinary action in conjunction with rules implementation has been presented within this document for consideration.

There were also a number of different approaches to the development of icons which has resulted in a potentially confusing diverse signage across the industry.

The OGP approach was to try to avoid using text where pos-sible on the icons, to allow the icons to be understandable by workers from all geographic locations and irrespective of their level of literacy. In order to utilise existing familiarity, a decision was made to follow the principles of the ANSI and European Union standard format for safety icons:

? prohibition signs being recognised by a red circle with a cross bar running top left to bottom right with a black symbol on a white background

? mandatory signs (i.e. signs indicate that a specific course of action is required) being circular in shape with the background colour blue with the symbol in white.The icons were then developed in accordance with the needs associated with the findings from the OGP data review.

OGP Life-Saving Rules

Please refer to the Life-Saving Rules User Agreement (inside cover of this document) for the conditions of use of the Life-Saving Rules icons and accompanying wording .

Background

Keeping people safe is a top priority for Shell. The com-pany aims to have zero fatalities and no incidents that harm people, or put neighbours and facilities at risk. This aim is defined as ‘Goal Zero ’ and Shell works to build a culture where every employee and contractor believes this goal is possible.

After reviewing work-related fatalities that occurred between 2000 and 2008, Shell found that a failure to comply with a limited number of safety rules was a sig-nificant factor in the majority of cases. I n response, Shell launched a programme to reinforce what employees and contractors must know and do to help prevent serious injury or fatality. Compliance is mandatory for all Shell employees and contractors while on business or Shell sites.

The 12 Shell Life-Saving Rules were launched in 2009 across the company. They were not new rules but were branded in such a way to increase awareness of the Rules’ ability to pre-vent serious injury and save lives. The Rules are also being better enforced to ensure consequences are applied if rules are broken. For example, if employees break the rules, they may face disciplinary action up to and including termina-tion of employment, while contractors can be removed from site and barred from future work with Shell. The guiding

principle is ‘if you choose to break the rules, you choose not to work for Shell ’.

The programme was based on the successful introduction of active consequence management in the event of a safety rule violation in Shell’s manufacturing business.

The 12 Life-Saving Rules are:

1) Work with a valid work permit when required 2) Conduct gas tests when required

3) Verify isolation before work begins and use the speci-fied life protecting equipment

4) Obtain authorisation before entering a confined space 5) Obtain authorisation before overriding or disabling safety critical equipment

6) Protect yourself against a fall when working at a height 7) Do not walk under a suspended load

8) Do not smoke outside designated smoking areas 9) No alcohol or drugs while working or driving

10) While driving, do not use you phone and do not exceed speed limits

11) Wear your seat belt

12) Follow prescribed journey management plan

Aims

Shell’s Life-Saving Rules aim to help employees and contrac-tors comply with company-wide rules covering the activities of highest safety risk. The programme set out to meet the following objectives:

? achieve zero work-related fatalities and serious injuries caused by non-compliance with the life-saving rules ? improve compliance with safety standards/rules

? achieve a consistent Shell-wide approach to enforcing the rules, within the bounds of local legislation, from July 1, 2009

? contribute to a Goal Zero mindset – a safety culture where believing that no fatalities and no incidents that harm people is possible.The core principles behind the programme were:

? The drive to save lives – preventing those non-compli-ances which result in the most serious incidents.

? The recognition that applying disciplinary actions has a major impact on human behaviour – it is necessary to show that Shell is serious by applying the maximum allowable disciplinary action once a life-saving rule is broken. This means applying the principle if you choose to break the rules, you choose not to work for Shell .

? Transparency, clarity and fairness – communicating the Rules effectively to all employees and contractors, making it clear each violation would be investigated thoroughly, consequences would be applied and that the consequences also apply to those who contributed to conditions for rule breaking.

Communications strategy

Successful implementation of the Life-Saving Rules required change and good project management. Communications and engagement on the Rules started in March 2009, with the Rules fully enforced from July 1, 2009.

The communications objectives stated for the programme include:

? understanding the Rules and their associated conse-quences, specifically: staff acknowledge they understand the rules in at least 75% of countries by May 30, 2009 and at 100% by July 1, 2009

? understanding of roles and accountabilities of imple-mentation leads, leadership, employees and contractors ? staff believe that leaders are role modelling good Life-Saving Rules behaviours and decisions

? compliance with the Rules, as measured quarterly.

Appendix B Life-saving rules – implementation case study

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In the first half of 2009, the Life-Saving Rules were rolled out country by country based on project plans created by Country Coordination Teams. The roll out principle was: ‘Businesses drive, Countries coordinate ’. Within this frame-work, communication in each of the businesses/functions was led by focal points, with co-ordination by region and country hubs. Country communications could tailor local planning by as required, to ensure consistent cross-business delivery within each jurisdiction.

The following principles were used to guide communica-tions activities for the roll out:

? communications is owned and delivered by line man-agement

? must use face-to-face communications to brief employ-ees/contractors on the rules

? consistent set of briefing materials with some leeway to link to local context

? do not allow ‘cottage industry’ in production of collat-eral

? progress of roll-out has to be monitored/checked

? communicate outcomes following breaches (reinforces new approach) as well as celebrating positive safety behaviours/performance.I n the months leading up to the July 1 launch, Shell line managers engaged with those under their supervision to brief them on the Rules. Front line workers had the oppor-tunity to discuss whether the Rules could be implemented in practice or whether there were any blockers. These block-ers were later-on removed where applicable/possible. All employees and contractors had to confirm that they under-stood the Life-Saving Rules before they became effective on July 1, 2009.

Communication to contractor companies

Shell’s contracting companies engaged with their staff on the Rules and were requested to make sure that those work-ing for Shell knew and understood them. Shell’s CEO also personally wrote to the top fifty contracting companies. All contractors were informed about the Life-Saving Rules and by contractual clauses the induction of new contractor workers about the Rules is sustained.

Continuous monitoring and improvements

Rule violations are tracked using existing management information systems and consequences are reviewed at the highest level to ensure that the Rules are applied effectively and that follow up action is taken. Campaigns are organised to focus on those rules which show most violations.

Consequence management

Consequence management and disciplinary action are driven by the legal position and agreements within each jurisdiction. Consider which other representative bodies, including staff councils and unions, should be informed.

Communications timeline

? February 3: CEO message sent to senior Shell leaders introducing the programme

? February 9: Executive Committee note with more detail sent to Country Chairs and all senior leaders ? February: briefing of key facilitators, including HSSE, HR, Communications

? March: briefing of line management/senior manage-ment of top fifty contractors

? March 30: I nternal Life-Saving Rules website live, restricted access

? From March 30 to end June: briefing of all staff and contractors including relevant joint ventures

? July 1: Full implementation of Life-Saving Rules, com-pany-wide