- Corporate Responsibility
- Royalty Owners
SWN employs a range of health, safety and environmental (HSE) training and other programs to support our strong safety culture and drive HSE performance. We focused heavily on COVID-19 safety protocols and response in 2020, as we sought to fortify our safety culture by bringing training for COVID-19 protocols into the workplace and engaging our employees to fortify a safe environment at work and at home.
Safety Leadership Training
Despite the challenges of COVID-19, SWN’s hands-on Safety Leadership Training series continued. These hands-on sessions covered skills and keys for leaders in successfully driving HSE performance. Frontline field supervisors for over 300 employees in Drilling, Completions, Facilities and Technology and division operations were trained. Specific topics covered included the importance of setting clear expectations, coaching, instilling accountability to employees and managing high-risk activities. The result of these sessions was better preparedness of frontline leadership to drive and improve SWN’s safety culture and performance.
Behavior-based safety1 plays an important role in our efforts to continuously improve HSE performance. SWN’s STOP® program2 drives behavior by empowering every SWN employee and contractor to directly protect the safety not only of themselves, but also of their co-workers, workspaces and operational sites.
STOP® achieves safety improvements through open communication, immediate behavior correction and the integration of relevant safety-related observations and learnings into the way we carry out our work.
STOP® works by training individuals how to be observant and identify safe and unsafe behaviors and then gives them a mechanism – a “STOP® observation” – to engage immediately in critical conversations about the behaviors they observe. All SWN employees and contractors are engaged in STOP®. Vital to the program is that all observations are made in a spirit of mutual respect and based on the moral and ethical responsibility that we have to care for one another’s safety and well-being. Through STOP®, SWN employees and contractors address and report unsafe behaviors immediately – including through a mobile STOP® application – which initiates appropriate follow-up, including implementing identified process improvements. The program reinforces health and safety as a SWN core value and helps build a culture of HSE excellence by supporting safe behaviors and allowing for the correction of unsafe behaviors before an incident occurs.
Employees are recognized for their participation in the STOP® program through our STOP® Card Recognition program, a way to recognize and reward those who go above and beyond to build, spread and maintain a superior safety culture at SWN. STOP® continues to help us proactively identify and effectively mitigate numerous risks, hazards and risky behaviors in order to protect human health and safety. SWN is using the information gained through STOP® to identify trends and behavior patterns, mitigate risks and prevent incidents before they happen.
Stop-Work Authority, Job Safety and Environmental Assessments and Hazard Awareness Tools
Every individual present at a SWN job site has an obligation to stop unsafe acts. As such, everyone has the full authority and discretion to stop all work on the site immediately – no questions asked – if a safety or environmental risk is perceived. Once work is stopped, the risk may be assessed and either eliminated or mitigated. Our workforce also uses Job Safety and Environmental Analyses (JSEAs) to identify, mitigate and eliminate HSE risks. In 2020, we implemented a “hazard wheel” awareness tool, which helps workers identify potential hazards associated with different tasks and raises awareness to help reduce incidents.
In 2020, we implemented Gold Standard Job Safety and Environmental Assessments (JESAs), enhancing our previous assessment process to help our field personnel uncover more hazards, implement appropriate mitigants and engage all parties to make certain everyone is ready for the task at hand.
Through the Gold Standard JSEA process, tasks and hazard identifications are broken down into specific steps, including:
- The start point and end point of the task are clearly defined.
- The crew performing the task should easily recognize the transition between each step.
- Periodic “pauses” should be provided at appropriate times to review that the task is proceeding in accordance with the plan.
While all relevant employees participate in JSEAs, they are led by specially trained employees who help ensure the gold standard process is followed and who prioritize the identification and mitigation of critical hazards – those that can result in serious injury or fatality – throughout the process.
Workers also use our Hazard Wheel Awareness Tool, which is based on the hierarchy of controls (i.e., elimination, substitution, engineering controls, administration controls and PPE), to uncover a greater percentage of hazards when accessing a job. The Hazard Wheel Awareness Tool provides a systematic way for work crews to assess the hazards related to their work task and helps SWN leadership verify that the hazards associated with any given work task have been addressed.
In 2020, we developed a training video to help support the implementation of our Gold Standard JSEA and the Hazard Awareness Tool:
Safety and Environmental Assurance Champions
SWN’s Safety and Environmental Assurance Champion (SEAC) program rotates experienced safety professionals through our operational divisions and work sites. These Champions assess applicable risks and behaviors and then report back to SWN leadership to share learnings and develop ideas for improvement (e.g., process or equipment improvements, training, etc.).
In 2020, SWN expanded the training and tracking tools for SEACs, including new action trackers that help SEACs ensure key safety actions are implemented.
JSEAs continue to provide direct support in the field, coaching in real time and focusing on higher-risk activities.
Assurance and Assessments
Our HSE assurance process requires regular assessments of SWN’s own and our contractors’ operations, as well as all third-party waste facilities, for both compliance and HSE quality-control purposes. The assurance assessments allow us to standardize and replicate best practices, as well as identify contractors with effective HSE systems. Initial contractor reviews are conducted to prequalify all contractors prior to SWN’s on-boarding process. In 2020, we continued assurance assessments and also leveraged our existing software systems to perform an additional Review and Verification audit on 38 key contractors and perform 131 prequalification reviews. We work with any contractors who are not in full compliance with our standards to help them achieve compliance. See the Contractor Assessment and Selection section for more detail.
SWN uses a comprehensive incident management system to track, analyze, report and follow up on HSE incidents. Corrective measures are identified, implemented and shared to minimize recurrence.
We track and report on near hits, as well as actual incidents, as part of our proactive approach to improving HSE performance, and we share learnings across our own and our contractors’ workforces.
Near hits are reported and analyzed for trends and potential corrective actions. As part of this process, all critical or “high-potential” near hits are designated for formal investigation and analysis, to formulate corrective actions and prevent recurrence. In 2020, 96 near hits were reported and reviewed to improve hazard identification and minimization. For many of these incidents, there was an immediate stand-down held on site to allow for immediate correction of the hazard. Of these 96 near hits, 10 were designated as high-potential near hits that could pose a risk of high-consequence injury.
Recordable incidents are also analyzed by type, so that we can determine the most common recordable incident types and target training for these incident types. In 2020, our recordable incidents broke down by type were:
In 2020, we continued to expand the efficiency and capability of our incident management system to allow for root cause analysis, as well as the ability to assign and track corrective actions, which ensures that preventative measures are closed in a timely manner. This system provides the following benefits:
- It makes it possible to capture real-time data associated with incidents and near hits, including photos and documentation, and to notify leadership each time an event is submitted.
- Inspections are conducted daily on our locations. If a potential hazard or issue is identified, it can be immediately integrated directly in the application, along with suggested action plans. This inspection information is sent with real-time notifications to leadership, outlining the need and plan for corrective action.
- Customized and automated reports and dashboards help advance our analytics and forecasting capabilities.
In 2020, after SWN’s acquisition of Montage, we merged our incident management system with the Montage iScout incident management system database. This merger will provide additional HSE management system capabilities in 2021, including a simplified user interface and mobile application with offline functionality. The merged system also includes the ability to record STOP observations, inspections, JSEAs and team-specific forms and checklists. The system will also be utilized for our training modules and equipment inventory. This merger provides SWN one centralized database to manage and maintain our HSE programs and processes.
Training is integral to any successful HSE program, and we take program execution and participation seriously. In 2020, SWN revamped the training matrix for all employees, taking into account the hazards they face and correlating them to the training needed, to help mitigate those hazards. Some of SWN’s key HSE training programs are as follows.
Training Assurance Program (TAP)
TAP is a required HSE training program for all SWN and contractor employees present in the field. See the ONE Team Culture for more on how we ensure that our contractors meet and uphold SWN’s standards.
In 2020, TAP training was updated to include implementation of a badging program to replace the current hard-hat sticker as verification of completion of the TAP onboarding process. The badging program requires that all contractors obtain a badge, and that they badge in before entering the site. Full implementation will occur in 2021.
SWN and contractor employees working in the field participate in JSEA training workshops to further improve and standardize the JSEA process and enhance risk awareness, identification, mitigation and elimination. In 2020, the workshops were updated to include the Hazard Awareness Tool and discuss the Gold Standard JSEAs, described above.
In 2020, SWN drivers logged approximately 8 million miles on company business. All employees who operate a vehicle for company business must periodically take and pass a driver training course. In addition, SWN invested in an in-vehicle monitoring and real-time feedback system for all SWN vehicles, which allows for immediate behavior modification and notifies SWN management of recurring problems.
Driver safety is an important focus at SWN, and we have some of the safest drivers in the industry, according to the American Exploration and Production Council.3
Short Service Employee Training and Mentoring
“Short service employees,” or field employees who have had less than six months of service with the company or in their job function or role, can pose a disproportionate risk of incidents if they are not properly trained. Our Field Employee Competency Program provides training and mentoring for short service SWN and contractor employees, to help them understand SWN’s HSE culture as well as the company’s expectations and requirements for their role. Each individual in the Competency Program is paired with a more experienced mentor trained in the same job function. At the end of the program the participant must pass a job-specific competency evaluation.
TapRoot Trained Investigations
SWN employees in our operating divisions participate in TapRooT Investigation Training, which provides tools and systems that improve incident investigations. This allows for better identification and understanding of the true root cause of a given incident (including near hits), and helps us capture learnings that can be used to prevent incidents and mitigate or eliminate risks.
SWN has built a foundation of comprehensive engineering standards that guide our design and construction processes. Hazards are “designed out” where feasible, and robust controls are “designed in” where hazards cannot be eliminated. Our quality assurance and quality control processes ensure that all new equipment meets our mechanical integrity and operational requirements and is installed correctly.
To maintain ongoing asset integrity, SWN employs a well-planned maintenance program and proactive risk-based inspections. Heightened focus is devoted to inspections of equipment or sites with higher risks for potential impact to human health and safety and/or the environment. We also use robust processes and administrative controls, such as Management of Change processes and well-documented Standard Operating Procedures.
SWN’s industrial hygiene program seeks to anticipate, recognize, evaluate and eliminate and/or mitigate workplace health risks in the following focus areas.
Preventing Exposure to Silica Dust
We take the following measures to reduce or eliminate worker exposure to crystalline silica dust on SWN operational sites:
- Use of appropriate equipment, including respirators
- Engineering controls and best practices, which are refined and improved through ongoing evaluation
- New sand delivery methods using closed, mobile boxes that can be trucked directly to completion sites
- Use of sand storage silos with built-in dust control, as well as automated sand hoppers, closed cab blenders and improved dust control on sand belts
In addition, we use a proactive medical surveillance program for employees with potential silica exposure that includes maintaining detailed work histories and performing physical examinations, chest X-rays and spirometry.
Managing Naturally Occurring Radioactive Materials
Naturally occurring radioactive materials (NORM) can be found in our operational areas. We have proactively addressed NORM in accordance with applicable federal and state regulations. Well locations at higher risk of accumulating NORM are identified, and detailed NORM management and control plans are developed as required by applicable law. Any services we use to remove or dispose of NORM-contaminated material are conducted by contractors and/or facilities that are properly vetted and approved in accordance with applicable law and the SWN HSE assurance process. See the Environment section for more on NORM.
Protection from Excessive Noise
SWN works to mitigate excessive noise from our operations, and we have stringent requirements for limiting noise exposure. Noise surveys are conducted at least annually to identify high exposure areas and determine employee exposure, and we develop noise protection plans and take other measures to understand and mitigate impacts on local residents. See the Communities section for more on how we mitigate compressor noise.
Emergency Preparedness and Response
SWN works with local emergency responders to develop preparedness, response and business resumption plans for all SWN-operated facilities. Crisis drills are conducted in all of our operating locations, involving local emergency responders as appropriate.
SWN has a Severe Weather Assessment Team that tracks severe weather in our operating areas and prepares emergency response plans for severe weather. The team consists of a representative from each department and is facilitated by HSE. All updates and recommendations are relayed to SWN’s Executive Leadership Team. In 2020, the Team conducted an exercise before the hurricane season to prepare, test and update the emergency response plans for our operating areas that could be impacted by a named storm event.
SWN’s Emergency Mass Notification System gives us the ability to efficiently send and receive critical information through text messages, phone calls and emails. In the event of a potentially hazardous situation, targeted notifications are sent to personnel who could be affected. The system can also be used to assess and confirm the safety status of personnel. In 2020, the system was used to effectively distribute notifications to employees and contractors with important information regarding security, office closures, severe weather threats and COVID-19 protocols.
- "Behavior-based safety" refers to the understanding that operational safety performance is dependent on individual behavior, because the vast majority of safety incidents are caused by behavior-based human error.
- STOP® stands for Safety Training Observation Program. SWN’s STOP® program is based on the renowned DuPont safety program of the same name.
- American Exploration and Production Council, 2020 annual Safety Benchmarking Study (the most recent data available as of publication in May 2021).