Health, Safety and Environmental Programs

Birchcliff is committed to continually evolving and improving its health and safety program (the “H&S Program”) and its environmental management program (the “EM Program”) and to conducting its activities in a manner that safeguards its employees, contractors, representatives, the public and the environment where Birchcliff operates. Birchcliff’s executives, managers, employees and others engaged on its behalf are responsible for upholding the requirements of its H&S and EM Programs.

Pursuant to the H&S Program, Birchcliff maintains a safe work environment with policies, standards, training, operating procedures, safety equipment and emergency response procedures that meet or exceed governmental regulations and industry recommended practices. Employees and contractors on Birchcliff’s worksites are required to follow all health, safety and environmental rules and procedures outlined in the H&S Program and to participate in pertinent health and safety training.

Birchcliff’s EM Program focuses on minimizing the environmental impact of its operations while meeting regulatory requirements and corporate standards. The EM Program encompasses a number of different corporate programs, including with respect to site planning and construction, surface water release, fugitive emissions management, abandonment and suspension, remediation and reclamation, naturally occurring radioactive materials and the management of vegetation, storage, waste and spills.

Emergency Response Plan

Birchcliff maintains an emergency response plan. In order to best prepare for emergencies, Birchcliff typically conducts annual full-scale emergency response plan exercises, with additional tabletop emergency response exercises conducted throughout the year. Following the annual exercises, debriefs are conducted with participants to identify key learnings that can be incorporated, thereby increasing Birchcliff’s level of preparedness. Birchcliff also typically provides annual training for key responder roles.

Alberta Certificate of Recognition (COR) Safety Program

Birchcliff participates in Alberta’s COR Safety Program and has received and maintained a COR certification since 2011. This certification demonstrates that the employer’s health and safety management system has been evaluated by a certified auditor and meets provincial safety standards, as established by Alberta Occupational Health and Safety. Birchcliff’s H&S Program is audited externally every three years by an independent auditor and internally every year by a certified auditor.

Asset Integrity

Birchcliff works diligently to maintain the safety and integrity of its facility and pipeline infrastructure and maintains two separate integrity programs: a pressure equipment integrity program and a pipeline integrity program. Birchcliff’s asset integrity group manages its pressure equipment integrity program in compliance with the Alberta Boilers Safety Association requirements and its pipeline integrity program in compliance with the requirements of the Alberta Energy Regulator. These programs are audited internally on an annual basis by a qualified professional and externally on a periodic basis by an independent auditor to evaluate their effectiveness and are updated based on the findings from such audits.

Birchcliff’s Chief Inspector and asset integrity group make use of databases and associated work tracking systems to ensure that all integrity tasks (inspections, pigging, etc.) are scheduled and completed according to the requirements set forth in Birchcliff’s programs.

Environmental Assessments and Audits

Environmental assessments are typically undertaken for new projects or when acquiring new properties or facilities in order to identify, assess and minimize environmental risks and operational exposures. Birchcliff conducts audits of operations to confirm compliance with internal standards and to stimulate improvement in practices where needed. Documentation is maintained to support internal accountability and measure operational performance against recognized industry indicators to assist in achieving the objectives of its policies and programs.