1.0 Scope
Fox EHS will provide and maintain this Program for all personnel who may potentially conduct work in a high-risk region. The High Risk Region Program applies to all employees and contractors who work in high risk regions. Such regions include, but are not limited to, war zones, natural disaster areas, demonstrations, riots and in high risk weather. Affected employees must be familiar with and adhere to the requirements of this document.
2.0 Definitions
Organisation for Economic Co-operation and Development (OECD) definition of conflict-affected and high-risk areas: Conflict-affected and high-risk areas are identified by the presence of armed conflict, widespread violence or other risks of harm to people. Armed conflict may take a variety of forms, such as a conflict of international or non-international character, which may involve two or more states, or may consist of wars of liberation, or insurgencies, civil wars, etc. High-risk areas may include areas of political instability or repression, institutional weakness, insecurity, collapse of civil infrastructure and widespread violence. Such areas are often characterized by widespread human rights abuses and violations of national or international law.
European Union (EU) definition of conflict-affected and high-risk areas: Areas in a state of armed conflict, fragile post-conflict areas, as well as areas witnessing weak or non-existing governance and security, such as failed states, and widespread and systematic violations of international law, including human rights abuses
3.0 Responsibilities
3.1 Department Head
Provide visible guidance and operational leadership for implementing the Environmental, Health and Safety (EHS) management process consistent with FOX’s EHS Policy in all locations and operations.
3.2 Producer / Editor / Supervisor
The Producer acts as the EHS Program Director for the production. In this position, he or she has the overall responsibility for safety program administration and implementation. The Producer is to confer with the Fox EHS Department to address all safety concerns. To help keep the safety program consistent, personnel, cast and/or crew are to consult with the Producer on all safety matters.
3.3 Environmental, Health & Safety Department
The EHS Department is responsible for supporting the production in all EHS related matters. They will work with Production Executives and relevant Supervisors to ensure the safety of all personnel involved in the production.
3.4 Fixer
The fixer acts as the local resource guide for the production. He or she must be knowledgeable of the local customs, culture and geography, in addition to the current social, political and economic climate.
Responsibilities include:
- Provide background on the current state of local affairs.
- Monitor local news outlets and inform the production of relevant information.
- Speak the local language fluently and act as an interpreter if needed,
- Arrange and schedule interviews, and in some cases conduct them.
- Coordinate travel arrangements.
- Warn the production of any dangers.
3.5 3rd Party Safety Contractors and Vendors
In addition to compliance with the employee responsibilities outlined above, contractors and vendors may be asked to assign a representative to monitor compliance with EHS requirements. The Contractor/Vendor’s Safety Representative may be an individual located away from the work site.
Responsibilities include:
- Recommend the need for a Risk Assessment of the High Risk Region
- Developing Health and Safety Plans (HASP) specific the hazards faced by the production.
- Assess work activities to identify hazards and implement controls to minimize risk.
- Investigate all incidents to identify trends and root causes. Recommend corrective or preventive actions to reduce similar incidents from occurring again.
- Communicate with Production Executives and the Producer to continuously improve processes and programs.
4.0 Procedures
4.1 Risk Assessments
Fox engages 3rd Party consultants and subject matter experts to conduct risk assessments. These assessments identify the key risks to personnel operating in hostile regions, and provide mitigation and pre-deployment planning advice to help keep Fox personnel safe. They support the planning and risk management process and provide country and regional risk ratings and analysis. The reports are used to assess security threats and/or gather relevant permits needed to perform work in the area. In addition, the comprehensive risk assessments typically include:
- Evacuation plan
- Location of nearby hospitals, embassy address and points of contact, and
- Communication plan in the case of an emergency event
4.2 Security Monitoring
Fox Global Security Operations Center (GSOC) provides 24/7 monitoring of all Fox operations. If conducting business in high risk regions, the area is escalated to the GSOC and additional support is requested:
- Daily briefing report
- Real-time alerting
- Tracking
- Emergency incident support
- Information management and event response of physical security information and operations information
4.3 Travel Medicine
4.3.1 Pre-travel Physician Consultation
A pre-travel consultation is offered to personnel who are traveling to high risk regions. Key components of the pre-travel consultation include intake questions regarding the traveler’s anticipated itinerary and medical history; immunizations, malaria prophylaxis, traveler’s diarrhea, emergency medical evacuation procedures, injury, and personal protection measures against travel/region-specific risks.
4.3.2 First Aid Training
It is advised that everyone in the production should be at the very least trained in basic first aid. Fox offers First Aid/AED training to all of our employees. Additionally, there should be someone who is qualified to perform additional medical services, such as a medic or EMT locally available during the event/production.
Medical Services should ensure that every crew member has received the appropriate vaccines prior to travel, and that those who take prescription drugs have packed an adequate amount.
4.4 Kits
4.4.1 Medical Kits
Medical kits can be provided and should include:
- Medication such as painkillers, anti-diarrheals, broad-spectrum antibiotics, anti-allergenic and anti-malarial
- Sterile bandages, tourniquets and Band-Aids of different sizes
- Antiseptics
- Adhesive sutures
- Sterile compresses
- Dressings that can be cut
- Emergency scissors
- Gels for burns
- Protective breathing mask and gloves
- Saline solution
- Tweezers
- Instant cold packs
4.4.2 Personal Protective Equipment
Personal protective equipment should include proper protection from safety hazards, physical hazards, ergonomic hazards, chemical hazards, and biological hazards identified in the risk assessment of the high risk region.
4.5 International Support
Fox has a contract with International SOS global risk mitigation programme. In the event of a medical emergency, employees can contact International SOS (ISOS) Our bespoke infrastructure is specifically designed to support you in the management of your health incidents while taking into account the industry regulations you operate in. This infrastructure is comprised of very experienced physicians, emergency specialists, occupational health physicians, registered nurses and case management teams to deal with the complexity and versatility of medical situations
4.5 Incident Reporting and Investigation
Requirements for reporting occupational injuries, illnesses, and accidents can be found in Fox Safety Policy EHS 102, Incident Reporting & Investigation. The supervisor/manager of the injured or ill employee must be contacted immediately. The supervisor or injured employee must call and leave a detailed message on the Employee Hotline (866-FOX- CABLE/866-369-2225, Option 9).
The EHS Department will follow-up with the supervisor or affected employee and perform an incident investigation as needed.
5.0 References
Commission Recommendation (EU) 2018/1149 – The European Commission has published their non-binding guidelines for the identification of conflict-affected and high-risk areas and other supply chain risks under Regulation (EU) 2017/821 of the European Parliament and of the Council: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32018H1149
Heidelberg Conflict Barometer – presence of armed conflict: https://hiik.de/conflict-barometer/current-version/?lang=en
Control Risk Worldmap – security and political risks: https://riskmap.controlrisks.com/-/media/43291d62ec9e4964beb6eb3e3a54a080.ashx
INFORM worldmap – humanitarian crisis (not limited to conflict or security issues): www.inform-index.org/Countries/Country-Profile-Map