SAFETY, HEALTH, ENVIRONMENT AND PUBLIC AFFAIRS POLICY
It is the Policy of Sublime Exploration & Production Company Ltd (SEPCO) to:
- Vigorously pursue Oil and Gas Exploration and Production,
- Remain committed to avoid of all work injuries, and/or any other persons who may at any time be affected by company activities,
- Conduct it operations in a manner that provides optimum protection to the Environment in which these operations are conducted to ensure sustainability.
- Ensure harmonies existence between SEPCO neighbours and stakeholders.
In order to achieve the above objectives, the Management ensures that:
- The Company SHEPA Policies form an integral part of Line Management Objectives and are essentially part of individual responsibility of each employee. Line Management Objectives for Oil and Gas/Exploration and production.
- The company’s SHEPA Polices must be communicated to all employees, contractors and all others who may involve in the company operations.
- The company will provide training, keeping employees and contractors formed about all possible hazards associated with contractors informed about all possible hazards associated with company activities. All employees and contractors must be fully committed in these matters and use their common sense and knowledge to help achieve these goals.
- Each employee or contractor or any concerned person is responsible for compliance with the company SHEPA Polices and the laws Regulations of the Federation of Nigeria. No employee or contractor must knowingly violate the company’s SHEPA Polices.
- The ultimate responsibility for personal Health and safety lies with each employee.
- The senior Management of SEPCO accepts the ultimate responsibility for safety, health, Environment and Public Affairs therefore expects each and every employee to be equally committed to achieving these laudable goals.
The Medical officer or Nurse attached to Company Facilities shall conduct Weekly Health and Hygiene Inspection of Kitchen, Mess, Living Quarters, Convenience as well as food storage facilities and general cleanliness in such installation / facility.
STRATEGIES FOR ENVIRONMENTAL MANAGEMENT
- SEPCO shall establish an Environmental affairs unit in the Safety, Health, Environmental and Public Affairs Section for the day-to-day implementation and administration of the Environment Management Policy.
- SEPCO shall engage the services on a full-time basis of an employee who shall be named the SHEPA Officer who shall report to the Health, Environment and safety Manager.
MONITORING, EFFLUENT LIMITATIONS AND STANDARDS FOREXPLORATION AND DEVELOPMENT OPERATIONS
SEPCO shall ensure that effluent discharges do not causeany hazards to human health and living organisms and do not impair thequality to use adjacent surface waters, land and groundwater.
The following shall not be discharged directly or indirectly into inlandwaters(Fresh or Brackish), Swamp, Coastal and offshore waters:
- Drilling mud/fluids
- Spent drilling mud/fluids
- Drill Cuttings
- Well treatment wastes
- Deck drainage or residues from water and oil based mud from drilling activities.
The dumping and discharge of dredge spoil into river shall be controlled by SEPCO, shall ensure the quality of the aqueous effluent of the treated wastes from drilling and production operations satisfies the applicable DPR regulations.
Compliance monitoring shall be carried out to ensure those applicable environmental regulations, whether government imposed or company’s self-compliance, guidelines, standards and limitations are complied with and that management policy and the environment management system are adhered to. The compliance monitoring will address the following:
- Any significant change to the biological chemical and physical characteristics of the recipient environment
- Inventory of gaseous emissions
- Determine long term impacts
- Determine the effectiveness of the mitigation measures
- Finally, determine impact to environment, of charges resulting from the modification and upgrading of SEPCO facilities.
The environment components will include:
- Air quality (Recipient Medium)
- Water quality (Recipient Medium)
- End- of- pipe effluent from available waste treatment facilities.
SAMPLING AND ANALYSIS
Sampling shall be taken once a week and reported each calendar month. SEPCO shall co-operate with the regulating bodies (DPR and FMENV) on the issuance of a certificate of sampling on random basis when necessary. The following parameters shall be monitored pH, Temp, Oil& Grease Salinity, Cod, Turbidity, TSS, TDS, TDS, BOD, DO, Heavy Metal and other Toxic (notably phenolics) Residential chlorine. Faecal Coliform.
SEPCO shall comply with the maximum permissible effluent discharges.
Sampling shall also be collected once in a month at about 500 meters upstream and downstream from the point of discharge and promptly analyses. All existing point sources of produced formation water/oily wastewater shall be registered with the DPR and permit for discharge into offshore waters shall be obtained.
ENVIRONMENTAL REVIEW AND AUDITING
The environment review process which shall be carried out annually provides an assessment and evaluation of environment performance during the operations, development, upgrading and abandonment of SEPCO facilities.
The environment audit/review should;
- Evaluate line management, plan operations, monitoring programme, data collection procedures, environmental action plans, and QA/QC programmes.
- Identity current and potential environment problems
- Recommend improvement of the operations
- Evaluate company policy
- Evaluate compliance with regulatory requirements
AIR POLLUTION MONITORING
SEPCO shall include as part of its annual Environmental Audit and inaccordance with DPRand FMENV Standards, an impact statement on the Air recipient by providing data on airquality indices which shall include: Temperature, Radiation, Nox, Sox, THC, VOC, Co, Co2. Noise, Particulate.
ENVIRONMENT IMPACT ASSESSMENT
SEPCO shall carry out annually an environmental impact assessment of its operation on seabed and flora and fauna including social economics within the boundary of its concession.
The quality of the produced water and oily waste waters from production, terminal and exploration operations shall comply with DPR guidelines.
PUBLIC AFFAIRS POLICY:
The SEPCOPublic Affairs policy is to assure of a peaceful and beneficial coexistence with neighbours and the environment.
In this regard,SEPCO shall:
- Comply with all safety, health and environment laws regulation, guideline and standards required for their operation in Nigeria.
- Follow relevant standards, good engineering practices and principles of risk management to ensure that safety, fire health and Environment protection activities are conducted responsibly.
- Encourage employees to initiate and maintain an open dialogue within the company regarding safety, Fire, Health, Environment and public Affairs matters.
- Conserve company and natural resources by careful management of emissions discharges, waste generation.
- Maintain a product warship programme by taking the appropriate steps to document the health effects of product which SEPCO handles in its operation. SEPCO shall inform employees, contractors, distributors customers and the public with regards to proper handling, use and disposal of these products.
- Employees of SEPCO shall be responsible for compliance with all corporate policies, procedures, practices and laws applicable to their assigns duties. It is the responsibility of line management to communicate this policy to their respective employees and to establish programmes as necessary to ensure implementation of this policy.
- Identify with all stakeholders in its area of operation
- Be prepared to offer reasonable assistance to neighbours whenever deemed appropriate
- Be prepared to participate in community activities whenever feasible.
- Be prepared to offer employment in the operational area whenever feasible.
NO CASH COMPENSATION POLICY
It is SEPCO’s policy not to provide pecuniary assistance to its neighbours on environmental matters. Rather, it is the policy of SEPCO to compensate the environment when unavoidably impacted.
NON-APPROVED CONTACT POLICY
At no time should any employee or contractor have contact with Community or stakeholders other than those approved in writing by the Managing Director of the SEPCO.