ConocoPhillips
2006 Sustainable Growth Report2006 Sustainable Growth Report
Minimize Environmental Impact

Health, Safety and Environment Policy, Management System and Audits

A comprehensive Health, Safety and Environment (HSE) policy (http://www.conocophillips.com/sd/hse) underpins our determination to continuously improve health and safety performance and environmental stewardship. Everyone in ConocoPhillips has a duty to comply with the policy, which applies to all company-owned and -operated locations.

The policy sets the foundation for our companywide HSE programs. It also requires contractors and suppliers to manage HSE in line with our standards. We audit our facilities against the HSE policy at least once every five years, with large, complex facilities audited more frequently. Corporate auditors performed 47 HSE compliance audits and 17 management system audits in 2006, covering more than a quarter of our assets. Individual sites also performed their own HSE and management system self-assessments.

If any gaps in performance against HSE policy standards are found, businesses must develop a corrective action plan within 60 days. The corporate HSE audit group reviews and approves plans and tracks them to completion.

The corporate HSE audit group also conducts operational readiness reviews for selected new exploration and production assets to help ensure that they will be commissioned and operated correctly, that the work force has been properly trained and that effective inspection and maintenance programs are in place.

In 2006, we introduced a new system in which HSE regulatory compliance is audited simultaneously alongside management system procedures. Evaluating procedures and practices at the same time gives a better measure of HSE management effectiveness. At major operating facilities, the combined approach is conducted on a three-year cycle, with health and safety procedures and compliance audited in year one and environmental procedures and compliance in year two. The third year is devoted to continuing to close gaps. The system will be extended in 2007 to cover all company-operated refineries and most other major operating facilities worldwide.

We use a companywide compliance verification process to capture audit action items, risk assessments, process hazard analyses and incident investigations. All business managers must certify annually their compliance with regulatory requirements and company standards, and that adequate action plans exist for any corrective actions. The system is designed to drive all identified risk issues and HSE-related issues to conclusion.

In 2006, we benchmarked our corporate HSE auditing program against EPA audit standards, International Organization for Standardization (ISO) and Eco-Management & Audit Scheme (EMAS) guidelines, and our own internal procedures. Ten of the 11 elements assessed met or exceeded these standards. Measures have been put in place to address the one area of noncompliance, which related to training “guest” auditors participating in the program who are employees with specific expertise in the area being addressed, but who are not full-time auditors.

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