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Document No: Section 15 Page 1 of 8Written By: Richard Brand Approval Date: 12/15/08Approved By: Steve Findley Revision Date: 10/20/20Revision No.: 3 Effective Date: 10/20/20A printed document is for reference only and not controlled.15.0 Offshore Operations15.1 Offshore SafetyWorking offshore involves many of the same hazards as working onshore, plus additionalhazards that are specific to the offshore environment. Some of the additional hazardsinclude marine debris, procedure for checking in at shore base, personal floatationdevices, swing ropes, personnel baskets, transportation by helicopters or boats, andemergency evacuation from an offshore facility. Employees who will be performingwork over or near water where the danger of drowning exists are not permitted to workalone at any time.Employees working offshore over or near water must be adequately trained as requiredby API RP T1 (Orientation for first time offshore personnel) in their responsibilitiesand safe work practices associated with this task. The training will include the PECOffshore Module which includes Maritime Security and Safety & EnvironmentalSystems. The HSE Administrator shall post training attendance records in theemployee’s attendance file. All offshore training will be kept in the centralemployees’ training files located in the Safety Department and/or on ComplianceWire.In addition, employees will take the “Technical Resource Services (TRS) WaterSurvival / Multi-Seat Triton HUET Simulator Training / Swing Rope / PersonalBasket” training in Broussard, Louisiana. Employees will be trained on proceduresfor water safety, the types of personal flotation devices, not to jump into the waterunless that is the only means of evacuation. This training is in accordance of APIRP T-7 (Training for Personnel in Rescue of Persons in Water), API RP T-4(Training of Offshore Personnel in Non-Operating Emergencies), and API 75(Safety and Environmental System for Offshore Operations and Assets.Employees working offshore will also take the Offshore Operators Committee(OOC) “Marine Trash and Debris” slide presentation training which is required tobe taken annually. This training is located on Compliance Wire.15.2 Offshore PreparationWhen preparing to go offshore, be prepared to stay longer than anticipated due to jobproblems or weather conditions that could arise. Pack enough clothing, personal items,and medications for the duration of your stay and possibly longer. It is more difficult toget these items offshore than on land. In addition, make sure you have all the requiredPPE such as hardhat, safety glasses, steel toe shoes, FRC, PFD, and gloves.Requirements for work clothes and personal protective equipment at specificlocations must be described to affected company workers. With the increasedsecurity required to go offshore, it is necessary to always have your driver’s license and

Document No: Section 15 Page 2 of 8Written By: Richard Brand Approval Date: 12/15/08Approved By: Steve Findley Revision Date: 10/20/20Revision No.: 3 Effective Date: 10/20/20A printed document is for reference only and not controlled.PEC photo ID card. An additional document that may be required is a copy of your birthcertificate and the Transportation Worker Identification Credential (TWIC) card.15.3 Environmental RegulationsThe 2010 Deepwater Horizon tragedy in the Gulf of Mexico has a profound impactacross the United States and led to a series of major reforms within the Departmentof Interior.The Department of the Interior’s (DOI), Bureau of Ocean Energy Management,Regulation and Enforcement (BOEMRE) which was the federal agency responsible foroverseeing the safe and environmentally responsible development of energy and mineralresources of the U. S. Outer Continental Shelf (OCS) changed in 2011.In October of 2011, those reforms resulted in the creation of the Bureau of Safetyand Environmental Enforcement (BSEE) which is now charged to vigorouslyenforce offshore safety and environmental regulations, as well as promote a cultureof safety, environmental stewardship, and resource conservation.By establishing BSEE, the U.S. Government severed the safety and environmentalenforcement responsibilities which are now BSEE’s jurisdiction, from the revenuegeneration and management authority vested in two separate Department ofInterior agencies, Bureau of Ocean Energy Management (BOEM) and Office ofNatural Resources Revenue (NRR).The Department of the Interior’s Bureau of Ocean Energy Management (BOEM)manages the responsible development of America’s offshore energy and mineralresources. The bureau promotes energy independence, environmental protectionand economic development through responsible, science-based management ofenergy and mineral resources on the U. S. Outer Continental Shelf (OCS).The Outer Continental Shelf is defined as all submerged lands seaward and outsidethe area of lands beneath navigable waters. Lands beneath navigable waters areinterpreted as extending from the coastline 3 nautical miles into the Atlantic Ocean,the Pacific Ocean, the Arctic Ocean, and the Gulf of Mexico excluding the coastalwaters off Texas and western Florida. Lands beneath navigable waters areinterpreted as extending from the coastline 3 marine leagues into the Gulf of Mexicooff Texas and western Florida.Included in BSEE, Safety and Environmental Management Systems (SEMS) is anontraditional, performance focused tool for integrating and managing offshoreoperations. The purpose of SEMS is to enhance safety of operations by reducing thefrequency and severity of accidents.

Document No: Section 15 Page 3 of 8Written By: Richard Brand Approval Date: 12/15/08Approved By: Steve Findley Revision Date: 10/20/20Revision No.: 3 Effective Date: 10/20/20A printed document is for reference only and not controlled.There are four principal SEMS objectives:1. Focus attention on the influences that human error and poor organization have onaccidents.2. Continuous improvement in the offshore industry’s safety and environmentalrecords.3. Encourage the use of performance-based operating practices.4. Collaborate with industry in efforts that promote the public interests of offshoreworker safety and environmental protection.Materials, equipment, tools, containers, and other items used in the Outer ContinentalShelf Region that are of such shape or configuration that they are likely to snag ordamage fishing devices shall be handled and marked as follows:A. All loose materials, small tools, and other small objects shall be kept in a suitablestorage area or a marked container when not in use.B. All cable, chain, or wire segments shall be recovered after use and securely storeduntil suitable disposal is accomplished.C. Skid-mounted equipment, portable containers, spools, reels, and drums shall bemarked with the owner’s name before use or transport over offshore waters.D. All markings must clearly identify the owner and must be durable enough to resistthe effects of the environmental conditions to which they may be exposed.E. MMS PINC G-252 stipulates that the above markings cannot be made with chalk,grease pencil or crayon, parking pens, non-waterproof decals, or water based paints.In complying with the BSEE, 30 CFR Part 250 Subpart O, FESCO, Ltd. has the 30 CFRPart 250 Well Control and Wireline and Production Safety Program Subpart “O”Training Plan in place. Each district working offshore has a copy of the plan at theirdistrict offices in the HSE Manual. The plan has been developed to ensure the FESCOemployees engaged in Offshore Well Servicing and Production understand and canproperly perform their assigned duties. The training consists of T-2 Production SafetySystems training and T-6 Well Servicing-Wireline Operations training from an accreditedInternational Association of Drilling Contractors (IADC) School with WellCAPcertification.Refer to the FESCO, Ltd. 30 CFR Part 250 Well Control and Wireline andProduction Safety Program Subpart “O” Training Plan; Safety Program 17.3In addition, BSEE requires that all employees working offshore view the training film“Think About It” and/or “Marine Debris”.

Document No: Section 15 Page 4 of 8Written By: Richard Brand Approval Date: 12/15/08Approved By: Steve Findley Revision Date: 10/20/20Revision No.: 3 Effective Date: 10/20/20A printed document is for reference only and not controlled.15.4 ShorebaseEmployees that are going offshore to do job tasks such as catching samples should parkin the designated contractor area at shorebase and report to the transportation building. Itis forbidden for company employees to take firearms, illegal drugs, and/or alcoholicbeverages onboard helicopters, vessels, shore bases, and offshore jobsites. You mustcheck in with security and a dispatcher to supply your identification, your company’sname, the name of the customer you are working for, your weight and the weight of yourbaggage, and notify them if you are carrying any hazardous materials.Once you have checked in, you will be instructed to go to a waiting area. Be sure that ifyou smoke, to smoke only in designated smoking areas. If there is a company orientationvideo, be sure to watch it.Transportation offshore will be either by helicopter or boat.HelicopterSmoking is not permitted on a helideck or in the vicinity of helicopter operations!The helicopter pilot is responsible for the safe operation of the aircraft and has theauthority to issue directives to company employees. The pilot’s authority includesdirectives regarding manifest and weight procedures, the processes for safeembarking and disembarking, the use of approved personal flotation devices, seatbelts, luggage and cargo, pollution prevention, rules of safe conduct in flight, andemergency procedures both in flight and during landing operations.Be careful when boarding a helicopter. A member of the flight crew, the helicopterlanding officer (HLO) or a qualified platform escort must escort passengers at all timeswhile on the helideck. Always make eye contact with the pilot and do not proceed untiltold to do so. Be aware of the tail and main rotors of the helicopter.Passengers shall ensure that all personal gear such as caps, hats, gloves, etc. in thevicinity of helicopter operations is properly stowed inside a bag or container. Hard hatsand boots may be securely strapped to the exterior of a bag or container. Keep any itemthat is longer than four feet in the horizontal position in order to keep it out of the mainrotor. When approaching the helicopter, keep low in a crouched position. The baggagecompartment will usually be on the side or rear of the helicopter.If personal protective equipment is required to be worn in or around helicopteroperations, the personal protective equipments must be secured to the individual by anapproved strap or method.When on the helicopter, sit in your assigned seat and fasten you seatbelt. Your personalfloatation device and hearing protection should be worn the entire flight.

Document No: Section 15 Page 5 of 8Written By: Richard Brand Approval Date: 12/15/08Approved By: Steve Findley Revision Date: 10/20/20Revision No.: 3 Effective Date: 10/20/20A printed document is for reference only and not controlled.Passenger use of cell phones is not permitted and cell phones must be turned off andstowed during the flight.BoatAll vessel captains shall possess current licenses as issued by the property authority tonavigate any vessel.The boat captain is responsible for the safe operation of the aircraft and has theauthority to issue directives to company employees. The captain’s authorityincludes directives regarding passenger manifest procedures, safe loadingprocedures, use of Coast Guard approved personal flotation devices, seatingarrangements, luggage, cargo, pollution control, smoking, safe conduct duringtransit, safe disembarking procedures, the safe use of the swing ropes and personnelbaskets, the handling of materials, and emergency procedures to be followed. Thevessel captain has the authority to refuse passage to anyone considered an unsafepassenger. The captain has the authority to require that seatbelts be worn when available.When boarding a boat, be sure to put on your workvest or other personal flotation device(PFD). The vessel captain shall refuse to allow persons not adhering to the personalfloatation device rules to board the vessel. Report to the cabin and sign the manifest assoon as you board. The captain of the boat is in command of the vessel. All passengersshould remain seated and fasten seat belts inside the cabin while vessel is underway,docking or leaving port. The vessel’s safety rules include mandatory requirements thatpassengers do not smoke, do not throw anything overboard, and assist in keeping thevessel clean and orderly.Any hazardous materials must be properly identified, classified, named, packaged,marked, labeled, and manifested. If these requirements are not met, the vessel captainhas the full authority to refuse transportation of hazardous materials.At some shorebases and/or offshore facilities, you may transfer from the dock or platformto the boat by climbing over the stern or side of the vessel. If this is the case, the boatmust be secured to the dock. Both of your hands must be free for climbing and 3-pointcontact must be maintained as you climb. Always select footings and handholds that aresolid and secure. You must also have your personal flotation devices on.When required to take FESCO equipment offshore, pre-plan job and discuss issues thatmay be encountered when loading the equipment onto a barge. The topics that should becovered are: the different loading docks and their facilities; the loading ramp’s size,position, configuration; tide in reference to ramp angle; the need for spotter; barge sizeand position; equipment weight, length, ground clearance; and what to do in case of aspill.

Document No: Section 15 Page 6 of 8Written By: Richard Brand Approval Date: 12/15/08Approved By: Steve Findley Revision Date: 10/20/20Revision No.: 3 Effective Date: 10/20/20A printed document is for reference only and not controlled.If FESCO employees are required to assist in loading, all personal protective equipmentsuch as hard hat, steel-toed boots, safety glasses, FRC and PFD should be worn.15.5 Offshore FacilityDuring the normal docking routine when you arrive at the offshore facility, the crew boatoperator will have a trained deck hand to assist in securing and tying off the boat. Usethree point contact stepping off the boat. If for some reason a FESCO employee is askedto tie off a boat, be aware of pinch points between the boat and the dock with the risingand falling of the boat due to sea conditions.At other times, you may need to use a swingrope or a personnel basket to get off andagain when you reboard the vessel for the trip home.You must decide if you will use the swingrope. A personal flotation device must beworn. Transfer should be made when the boat is at its highest position or rising in theswell. Never swing when the boat is in the trough of a swell. Remove all jewelry orother items that might be caught in the swingrope and never attempt to carry anything.Inspect the swingrope and test it by giving it several hard pulls before using it. Grasp theswingrope firmly with both hands and position the rope to the side of your body.Transfer by swing rope should be avoided in high seas and during hours of darkness. Ifanyone should fall into the water, immediately sound the call, “man overboard”, whichwill expedite the notification of the captain. Swim away from the rear of the boat toavoid getting caught in the boat’s propellers.A personnel basket and crane is another device used to transfer personnel between boatsand platforms. A personal floatation device must be worn. Personnel transferring shouldposition themselves on deck, clear of the descending basket. The crane operator or riggerwill signal when to approach. Small, light luggage, PPE, tools, etc. can be put in thepersonnel basket net. No more than the rated number of individuals should ride thebasket at any given time. Firmly grasp netting with both hands at or just above shoulderheight or higher. Place feet on the basket ring with knees slightly bent for lift off. Holdon tightly and keep your back straight. Just prior to basket touch down, take one foot offthe ring and extend it. When the ring touches down, place the foot extending backwardsonto the deck or platform to maintain balance. Once the basket has been placed on thedeck after the transfer, step off and remove items from inside the basket.Upon arrival at offshore facility, report to the person in charge for check-in. During yourcheck-in, you will be given site-specific safety orientation. The orientation will coveremergency procedures and alarm signals, emergency evacuation instructions and survivalcapsule or life raft information, location of station bills, exits, emergency and safetyequipment.

Document No: Section 15 Page 7 of 8Written By: Richard Brand Approval Date: 12/15/08Approved By: Steve Findley Revision Date: 10/20/20Revision No.: 3 Effective Date: 10/20/20A printed document is for reference only and not controlled.15.6 Personal Flotation Devices (PFD)Personal flotation devices are vital to your safety in the water. Employees working overor near water shall be provided with a U. S. Coast Guard approved life jacket or buoyantwork vest when the danger of drowning exists. There are two types of PFDs, “Type I”and “Type V”. When properly secured, the “Type I” will give you the most buoyancyand keep your head out of the water, even if you are unconscious and in heavy swells. A“Type V” PFD is a light weight PFD designed to be less restrictive to arm movementsand is often referred to a workvest. It is meant for short term use and to add nominalbuoyancy. Employees shall inspect buoyant work vests or life jackets for defects whichcould alter their strength or buoyancy prior to and after each use. Defective units shallnot be used.15.7 Additional Safety EquipmentRing buoys with at least 90 feet of line and spaced no further than 200 feet apart shall beprovided and readily available for emergency rescue operations. In addition, at least onelifesaving skiff shall be immediately available when employees are working over oradjacent to water. Employees should work with the operator to assure this safetyequipment is available.15.8 Safety During Equipment Rigup and OperationA Safety Meeting and a Behavioral Job Safety Analysis (BJSA) is required to becompleted and signed by all employees that will be working over or near water before thework may begin.When on deck, FESCO personnel will always wear FESCO uniforms and the appropriatepersonal protection equipment such as PFD, hard hat, steel-toed boots, eye and hearingprotection, etc.When spotting equipment, delegate a person to communicate with the crane operator.Always use tag lines when transferring equipment. Be aware of crane loads and stayaway from suspended equipment.Be cautious of slippery surfaces and do not carry more weight than you are capable ofhandling. Always use two people, if needed and take your time.Flaring gas and burning oil during production testing is the most critical aspect ofproduction testing off shore.Never go out on the burner without having someone watching. Always wear your PFDand a strobe light when you go out on the burner. Take in account the wind speed andwear your fall protection when working above 6 feet in height.The water radiation shield will be in service using water supplied by the rig when gas oroil is being burned to keep the burner cool.

Document No: Section 15 Page 8 of 8Written By: Richard Brand Approval Date: 12/15/08Approved By: Steve Findley Revision Date: 10/20/20Revision No.: 3 Effective Date: 10/20/20A printed document is for reference only and not controlled.If the wind changes direction and fire is being blown back onto the burner, the alternateburner will be used or the well shut in immediately. Significant damage will result if thefire is allowed to blow back onto the burner. Post a person to monitor the burner flare ifit is not visible by the testing crew. The wind can change direction and blow the flareback onto the burner boom damaging it or other structures.Check all emergency shutdown devices on equipment before starting any operation.Keep all unauthorized personnel away from FESCO equipment and lines during testing.Communications is essential. Always know where other FESCO personnel are at alltimes.