At Comstock, the safety of employees, contractors and the community is not only a priority but a core business value that is part of our culture and is built into every aspect of our operations. This philosophy goes beyond hard-hats, steel-toed boots and other personal protective equipment. It is a conscious commitment to safety that is reflected in the decisions we make every day about how we approach our work.
EH&S Management System

To obtain our goals of operational excellence and an injury free workplace, we have implemented an EH&S Management System as a framework on which to build our success. That framework is comprised of:

  • Policy and procedure outlining how we do our work.
  • Programs to engage employees and drive a proactive safety culture.
  • Employee training to help ensure our employees have the knowledge to perform their work safely.
  • Audit and inspection to verify we are doing what we say we’re doing and to identifying potential improvement opportunities.
  • Targets and objectives for clearly defined deliverables and accountabilities.
  • Data collection to track leading and trailing indicators.
  • Scorecards to measure our success and develop improvement strategies.
Continuous Improvement

Comstock strives to be a leader among our peers in many facets, with safety performance being one of them. We look at where we are today and develop a practical common sense approach to reach our goals of tomorrow.

Proactive Safety and Knowledge Sharing

Comstock fosters a culture of proactive environmental, health and safety leadership among all our staff. Our hazard identification and behavior based safety programs cultivate habits that identify potential safety and environmental hazards before they materialize.

Comstock believes that open communication is a key component to hazard elimination and control. Findings, hazards, root cause and corrective actions are shared across the company. This open communication allows us to prevent similar occurrences in other areas of operation.

Stop Work Authority

At Comstock, any employee or contractor has the authority and obligation to stop work due to unsafe conditions.

Contractor Management

Comstock has teamed up with a third party contractor management service provider to ensure a consistent approach in aligning our expectations with everyone involved in our operations. We hold our contractors accountable to the highest performance standards. Through our contractor onboarding and continuous auditing process, Comstock can assure that contractors on our sites meet our standards of:

  • Employee safety training
  • Safety programs, policies and procedures
  • Injury rates
  • Insurance
  • Master Services Agreement

Comstock uses a third party to monitor contractor compliance status and incident rates. In addition, Comstock tracks onsite contractor incidents internally via our incident management software. We are able to use trailing indicators to work directly with contractors to identify improvement opportunities in their own health and safety programs, procedures and equipment design, among other things.

Employee EH&S Training

Safety training is a vital tool for our employees to conduct their work in a safe and prudent manner. Our specialized instructor-lead and computer based learnings focus on knowledge and retention rather than a simple pass / fail test result.

Comstock uses a combination of in-house instructors, third-party instructors and an online platform to facilitate health and safety training to employees. Job specific training curriculums are developed to ensure relevant topics are delivered to each employee. We also utilize a combination of monthly operations safety meetings, tailgate and pre-job safety meetings to share information across operating areas.

Emergency Response

At Comstock, we take action to prevent incidents before they occur. However, our employees receive annual Hazardous Waste Operations (HAZWOPER) and emergency response training to help ensure they are prepared to respond quickly and effectively to a multitude of circumstances.

2018-2019 Work Related Recordable Injuries TRIR

Comstock believes our EH&S Management System fosters a safe work environment and holds our employees and contractors to the highest standards of personal conduct and safety performance. As a result of our organizational focus on safety, Comstock reported an U.S. Occupational Safety and Health Administration (OSHA) Total Recordable Incident Rate (TRIR) of 0.00 in 2018 and 2019 down from 1.64 in 2017. The OSHA measurement for TRIR represents the number of work-related injuries and illnesses per 200,000 workhours.

Damage Prevention and Community Involvement

Comstock values the safety of the communities we serve and files SARA II reports annually as part of the Emergency Planning and Community Right to Know Act. We also participate in annual meetings with land owners, stake holders, and public officials in proximity to our regulated pipeline systems. These meetings promote safety awareness, allow an opportunity for community questions, and give us on opportunity to meet the people of the communities in which we operate. In these face-to-face meetings with public stakeholders and public officials, we discuss our operations, how to recognize a leak, what to do if a member of the public encounters a leak and how Comstock will respond.

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