Management and monitoring of industrial and environmental risks
TOTAL’s policies regarding health, safety and the environment
TOTAL has developed a “Safety Health Environment Quality Charter” (refer to point 2. of chapter 7) that sets out the basic principles applicable within the Group regarding the protection of people, property and the environment. This charter is implemented at several levels within the Group by means of its management systems.
Along these lines, TOTAL has developed safety, environmental and quality management systems that it seeks to have certified or assessed (e.g., standards such as the International Safety Rating System, ISO 14001 and ISO 9001).
In most countries, TOTAL’s operations are subject to laws and regulations concerning health, safety and environmental protection to which TOTAL ensures compliance. The main laws and regulations include:
- In Europe: Integrated pollution prevention and control (IPPC) and large combustion plants directives (recast by the Industrial emissions directive (IED)), Seveso directive, pressure equipment directive, water framework directive, waste directive, ETS directive (CO2 allowances), Fuel Directive, Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) and Classification, Labelling and Packaging (CLP) regulations.
- In France: regulations on natural and technological risks.
- In the United States: Occupational Safety and Health Administration / Process safety management of highly hazardous materials (OSHA / PSM), Clean Air Act, Clean Water Act and the Comprehensive Environmental Response, Compensation, and Liablity Act (also known as CERCLA or Superfund).
As part of its policy, TOTAL performs regular assessments, following various procedures, of risks and impacts in the areas of industrial safety (particularly process safety), the environment and the protection of workers and local residents, including:
- prior to approving new projects, investments, acquisitions and disposals (refer to chapter 5, point 1.10.);
- periodically during operations (safety studies, environmental impact assessments, health impact studies and Technological Risk Prevention Plan – PPRT in France);
- prior to releasing new substances on the market (toxicological and ecotoxicological studies and life cycle analyses); and
- based on the regulatory requirements of the countries where these activities are carried out and generally accepted professional practices.
In countries where prior administrative authorization and supervision is required, projects are not undertaken without the authorization of the relevant authorities based on the studies provided to the authorities.
In particular, TOTAL has developed a common methodology for analyzing technological risks that is being gradually applied to all activities carried out by the companies of the Group (refer to chapter 7, point 2.2.3.).
TOTAL develops risk management measures based on risk and impact assessments. These measures involve facility and structure design, the reinforcement of safety devices and environmental remediation.
In addition to developing management systems as described above, TOTAL strives to minimize industrial and environmental risks inherent in its operations by conducting thorough inspections and audits, training personnel and raising awareness among all those involved.
In addition, performance indicators (particularly in the areas of HSE) and risk monitoring have been put in place, objectives have been set and action plans have been implemented to achieve these objectives.
Although the emphasis is on preventing risks, TOTAL takes regular steps to prepare for crisis management based on identified risk scenarios.
The Group has a crisis management process that relies on a permanent on-call system, regular exercises conducted at the industrial sites of its main entities, a benchmark of the best practices of international companies and training courses in crisis management, as well as procedures, emergency booklets and tools that can be used in the event of a crisis.
The organization set up in the event of a crisis is deployed at two closely-coordinated levels:
- at the local level (country, site or entities), a crisis unit is responsible for ensuring operational management and implementations of emergency plans; and
- at the head office level, a crisis unit consisting of a multi-disciplinary team is tasked with assessing the situation and overseeing crisis management. This central unit provides the necessary expertise and mobilizes additional resources to assist the local crisis unit when necessary.
In addition, TOTAL has developed emergency plans and procedures to respond to an oil spill or leak. These plans and procedures are specific to each TOTAL affiliate and adapted to its organization, activities and environment and are consistent with the Group’s plan. They are reviewed regularly and tested through exercises (refer to point 2.2.3. of chapter 7).
At the Group level, TOTAL has set up an organization structured around the Plan to Mobilize Resources Against Pollution (PARAPOL) alert scheme to facilitate crisis management and provide assistance without geographical restriction by mobilizing both internal and external resources in the event of pollution of marine, coastal or inland waters. The PARAPOL procedure is made available to entities of the Group and its main goal is to facilitate access to internal experts and physical response resources.
Furthermore, the Company and its subsidiaries are currently members of certain oil spill cooperatives that are able to provide expertise, resources and equipment in all geographic areas where the Group has operations, including, in particular, Oil Spill Response Limited and Centre for Documentation, Research and Experimentation on Accidental Water Pollution (CEDRE).
Following the blow-out on the Macondo well in the Gulf of Mexico in 2010 (in which the Group was not involved), TOTAL created three task forces in order to analyze risks and issue recommendations. The task forces have now finalized their work and the Group continues to roll out solutions to minimize such risks. Detailed information on TOTAL’s initiatives in the fields of safety and protection of the environment is provided in chapter 7.
TOTAL believes that it is impossible to guarantee that the contingencies or liabilities related to the above mentioned concerns will not have a material impact on its business, assets and liabilities, consolidated financial situation, cash flow or income in the future.
To manage the operational risks to which the Group is exposed, TOTAL maintains worldwide third-party liability insurance coverage for all its subsidiaries. TOTAL also maintains insurance to protect against the risk of damage to Group property and / or business interruption at its main refining and petrochemical sites. TOTAL’s insurance and risk management policies are described in point 5. of this chapter (“Insurance and risk management”).