Health & Safety

We accomplish our objectives for responsible operations through our comprehensive environmental, health and safety (EHS) program. Our EHS management system enhances our ability to achieve our vision by establishing a corporate governance framework for EHS compliance. Led by a team of experienced professionals, our EHS department partners with all operations of the company to support and enhance our activities. Our EHS team works closely with operations to ensure regulatory compliance and performs functions related to employee and stakeholder education, preparedness planning, program assessment and reporting, and state and federal agency reporting. Through management leadership and employee participation, our EHS programs help us to:

Our EHS program and management system cover all elements of our operating lifecycle, from exploration and pre-drill site assessments, through to decommissioning and reclamation.

Our program supports the management of various environmental risks including:

• Management of produced water
• Groundwater protection
• Air quality
• Greenhouse gas emissions
• Land protection (including biodiversity protection)
• Waste management

Underlying references for our EHS management system include American Petroleum Institute (API) Consensus Standards, Occupational Safety and Health Administration (OSHA) standards and regulations, the American National Standards Institute and ASTM International.

Milch Engineering encourages the professional development of our Environmental, Health and Safety team by promoting the attainment of nationally or state recognized accreditations, such as the Certified Safety Professional (CSP) from the Board of Certified Safety Professionals, Registered Environmental Manager (REM) from the National Registry of Environmental Professionals, Professional Engineers (PE) and Professional Geologists (PG) from the applicable certifying state agencies.

Environment, Health & Safety Committee (EHS)

An integral component of our EHS program is the Environment, Health & Safety (EHS) Committee of our Board of Directors. This committee is one of the few in our industry to focus solely on environmental, health and safety matters at every regular board meeting and underscores our commitment to ensure that Cabot is a leader in our peer group in responsible, sustainable operations. The EHS Committee was originally formed in 1991 as the Safety & Environmental Affairs Committee, renamed in 2020 as the EHS Committee, and provides oversight of the Company’s environmental, health and safety programs and our continued commitment to sustainable operations. The EHS Committee meets on a quarterly basis to review:

• The Company’s climate change and sustainability policies and programs and public disclosures relating to the same;
• Compliance with laws, regulations, policies, programs and practices with regard to environmental, health and safety matters;
• Responses to releases, investigations, notices of violations and civil actions;
• The Company’s safety program, including reports of incidents, statistics and actions or investigations by any governmental body;
• Responses to pending legislative and regulatory efforts related to the environment, health and safety that are likely to significantly affect the Company’s business;
• Environmental, health and safety and initiatives and training designed to improve the Company’s performance; and
• Performance trends associated with motor vehicle accidents; first aid cases; days away, restricted and transferred (DART); OSHA recordable cases; notices of violations; greenhouse gas emissions; releases; or other environmental incidents.

Milch Engineering has a strong safety culture that emphasizes personal responsibility and safety leadership. Milch Engineering employees and contractors at all levels are expected to do everything reasonable and practical to protect personnel, property, and the environment.

We provide the necessary resources to employees to perform their jobs safely, effectively and efficiently. Through formal training and on-the-job mentoring, we educate our employees about potential hazards associated with the job, equip them with the tools to assess and mitigate those hazards, and empower them to make the best decisions that will keep themselves and their coworkers safe.

We hold monthly safety meetings to provide required Occupational Safety and Health Administration (OSHA) training and refresher courses, as well as to promote industry best management practices and address local needs. For example, Milch Engineering subscribes to the American Petroleum Institute (API) Compass online platform which provides employees with access to API consensus standards and recommended practices. These documents are shared across the enterprise to ensure all employees have the most up to date standards and practices. Monthly field safety meetings also cover pertinent issues such as fatigue, control of hazardous energy, hazard communication, hot work, confined spaces, and distracted driving, among other topics.

Milch Engineering also holds quarterly contractor meetings to discuss EHS performance metrics and trends, risk mitigation and lessons learned. We frequently invite subject matter experts and local regulatory agencies to present on EHS related topics. The sharing of these lessons learned with our contractors provides knowledge to prevent similar incidents from reoccurring, thus creating a safer work environment for all.

Stop Work Authority

Milch Engineering conducts all our operations under a Stop Work Authority (SWA) program that empowers employees to stop work if they discover a dangerous condition or other serious EHS hazard. All Milch Engineering employees and contractors have the authority and obligation to stop any task or operation where concerns or questions regarding EHS hazards may exist. Once a SWA is in effect, work cannot resume until all stop work issues and concerns have been adequately addressed. Milch Engineering will not tolerate any form of retribution or intimidation directed at any individual or company for exercising their authority as outlined in this program.

With many specialized services occurring on site, contractors are a critical part of the Milch Engineering workforce. Our expectation is that contractors will operate under the same high standards as Milch Engineering employees. Our contractor safety program includes screening, contractual obligations, on-site education, and ongoing monitoring. All of Milch Engineering contractors execute a Master Service Agreement (MSA), which contractually obligates them to review and comply with Milch Engineering Contractor Responsibilities section of the EHS Manual. The MSA also requires contractors to report immediately to Milch Engineering all details of any near miss, injury, illness, property damage and/or environmental impact and to cooperate fully in all remedial activities in order to restore and protect the environment.

As many of our contractors work on-site side-by-side with Milch Engineering employees, we track contractor safety and environmental incidents and collaborate with contractors toward the elimination of future incidents. We also invite contractors to participate in quarterly safety meetings and share best practices to improve the overall safety and environmental outcomes for all operations.

Third-Party Audits/Inspections/Enforcement

In many of our drilling, completion, and production operations, we use third-party safety and environmental specialists to assist site personnel with monitoring activities and to minimize the risks associated with our activities. These specialists provide guidance on Job Safety & Environmental Analyses (JSEAs), waste management, materials handling, fluids transfer and numerous other tasks to assess and minimize the safety and environmental risks of ongoing activities. We also utilize inspectors in other areas of our operations, including stimulation activities using hydraulic fracturing, to verify contractor compliance with recognized industry best practices and federal and state regulatory requirements. If warranted, we conduct verification inspections and take all necessary corrective actions.

Industry Leading Safety

All contractors chosen to work for Milch Engineering are required to participate in the ISNetworld contractor verification program. This industry leading safety verification process allows us to screen contractors based on their safety performance in relation to their peers. Our master service agreements with our contractors require contractors to provide their employees with appropriate safety equipment and training, as well as to adhere to all applicable environmental and safety regulations.

As part of Milch Engineering commitment to providing a safe operation, a number of contractors are selected every year to complete a verification and review process administered by ISNetworld. This process consists of contractor employee interviews and contractor management interviews, which are designed to identify gaps in the contractor’s EHS program. Based on these reviews, ISNetworld develops action items and works with the contractor to verify completion of those items.

Many of the risks associated with oil and natural gas operations can be managed effectively through process safety controls and emergency response planning. These efforts are in place to protect the safety of our employees, contractors and communities.

Process Safety

To significantly enhance the information available to our operators and supervisors, Milch Engineering has automated most well pads and equipped them with remote shutdown capability. These safety features provide our operators access to real-time facility data and improve response times.

Emergency Response and Community Safety

We have emergency response plans in place for all areas of our operations, based upon the Incident Command System (ICS) adopted by all levels of government as well as many private sector companies. Two examples of emergency response plans in place for our operations are our Preparedness, Prevention and Contingency (PPC) and Emergency Response Plan (ERP). The primary purpose of these plans is to establish a response that is efficient, coordinated and effective, while delivering the necessary protection to our employees and contractors, the community and the environment in which we work. We conduct training and drills on a regular basis with our personnel to ensure the readiness and preparedness of our response personnel.