JTB-RJJ000-S0-PRC-900-00043 HSE Minimum Requirement PDF
JTB-RJJ000-S0-PRC-900-00043 HSE Minimum Requirement PDF
JTB-RJJ000-S0-PRC-900-00043 HSE Minimum Requirement PDF
The purpose of the requirements is to provide the SUBCONTRACTOR with the minimum
requirements to which SUBCONTRACTOR shall comply when conducting work on or in
connection with the project.
SUBCONTRACTOR working on the project shall comply with these requirements and all other
applicable laws including but not limited to labour, environmental, health, and safety standards. If
conflict arises between the requirements and applicable regulatory requirements, the most
stringent shall apply.
SUBCONTRACTOR shall comply with all written or verbal instruction regarding safety and health
issued pursuant to these requirements by CONTRACTOR.
2. SCOPE
As these requirements cannot address every possible condition, work activity or situation which
may arise on site, the SUBCONTRACTOR required and expected to exhibit competence, exercise
best management and safe work practices with regard to health and safety of their workers and
work activities. Omission or failure to mention a specific issue in these requirements in relation to
any activity being conducted on theProject does not relieve the SUBCONTRACTOR from its
obligations under its CONTRACT.
In addition, all requirements stated in this document equally applied to other parties under control
of SUBCONTRACTOR.
The following are the minimum requirements that the SUBCONTRACTOR shall comply with for all
HSE issues relating to work activities associated with their CONTRACT.
Where any situation arises which may require possible deviation from these requirements, it shall
be discussed with and approved, in writing, by the CONTRACTOR representative prior to
commencement of work.
SUBCONTRACTOR shall submit HSE Plan to CONTRACTOR. CONTRACTOR will review and
approve the HSE Plan. The HSE Plan shall be described herein below, but not limited to:
a) Objective
b) Scope of Work
c) Compliance to Regulations
d) Personnel Responsibilities for HSE Implementation
e) HSE Manpower Plan
f) Training Plan (including Short Service Employee (SSE) Program)
g) Personal Protective Equipment and Fire Protection Plan
h) Emergency Preparedness and Response Plan
i) Work Method
j) HSE Program (including HSE awareness)
k) Communication Program (including Management of Change)
l) HSE Reporting System
m) Reward and Punishment Program
n) Hazards and Risks Register
CONTRACTOR will carry a written test and an interview to determine acceptance or rejection of
safety personnel SUBCONTRACTOR. If the SUBCONTRACTOR does not able to meet the
manpower requirement of CONTRACTOR, then CONTRACTOR will supply the manpower, and its
budget will be charged to SUBCONTRACTOR in accordance with CONTRACTOR’s standard.
Certain violations will lead to rejection to HSE SUBCONTRACTOR and the SUBCONTRACTOR
shall provide a replacement in accordance with the rules above to be able to get permission to
work.
Manpower estimation:
HSE SV: Employee = 1: 25
Cost for external competency training (training provided by third party) and health examination /
MCU for workers shall be to SUBCONTRACTOR and / or Sub-SUBCONTRACTOR account.
(Project
Finance
Revision
First Aider
Floor Warden
Document No.
- HSE Manager
JTB Project
Discipline Engineer
Position
Engineering Manager)
Non-Rotator - Jakarta Based
:0
Procurement Manager and
Project
Manager,
Control Manager, Adm. &
Project Management Team
M
M
M
M
M
M
M
HSE Project Induction
Safe Behaviour Training Competency
M
M
M
M
M
M
M
for All
(SBTC)
: S-000-1654-G0043
Mandatory
M
M
M
M
M
M
M
PEKA (Pengamatan Keselamatan Kerja)
: JTB-RJJ000-S0-PRC-900-00043
Personnel
for Certain
Mandatory
Provided by COMPANY (9)
M
M
AT Assessment and Authorization
1
1
1
1
1
M
M
M
M
M
Orientation)
M
M
Permit to Work (PTW) System
M
PPE Awareness
M
M
M
M
JSA & Risk Assessment
M
Food Hygiene
M
Environmental Management System
M
Incident Investigation
M
M
Hot Work
Page 9 of 24
M
M
H2S
Table 3. HSE Training Matrix
M
M
M
M
Scaffolder
Scaffolding Inspection
Certification by MIGAS
Certification by DEPNAKER
Revision
Engineer
instrument)
instrument)
HSE Officer
Site Manager
Document No.
Rotator - Site Based
Lead Engineer
HSE Coordinator
JTB Project
Position
Safety Superintendent
Construction Supervisor /
Work Leader (mechanical,
:0
Superintendent (mechanical,
General / Lead / Construction
M
M
M
M
M
M
M
M
M
HSE Project Induction
Safe Behaviour Training Competency
M
M
M
M
M
M
M
M
M
for All
(SBTC)
: S-000-1654-G0043
Mandatory
M
M
M
M
M
M
M
M
M
PEKA (Pengamatan Keselamatan Kerja)
M
M
Lifting Assessment and Authorization
Scaffolding Assessment and
M
Authorization
: JTB-RJJ000-S0-PRC-900-00043
Personnel
for Certain
Mandatory
Provided by COMPANY (9)
M
M
M
AT Assessment and Authorization
M
M
M
M
M
M
M
M
M
Orientation)
M
M
M
M
M
M
M
M
M
Permit to Work (PTW) System
M
M
M
M
M
M
M
M
M
PPE Awareness
M
M
M
M
M
M
M
M
M
Food Hygiene
M
M
M
M
M
M
M
M
M
M
M
M
Incident Investigation
M
M
M
M
M
M
M
M
M
Hot Work
Page 10 of 24
M
M
M
M
M
M
M
M
M
M H2S
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
Working at Height
M
Scaffolder
Scaffolding Inspection
Certification by MIGAS
Certification by DEPNAKER
Revision
Security
vehicles)
IT Officer
electrical)
Scaffolder
Development
Document No.
Chief Security
Chief Community
JTB Project
Position
Equipment Inspector
Scaffolding Inspector
Supervisor Scaffolding
(lifting, heavy equipment,
:0
(heavy equipment, electrical,
M
M
M
M
M
M
M
M
M
M
HSE Project Induction
Safe Behaviour Training Competency
M
M
M
M
M
M
M
M
M
M
for All
(SBTC)
: S-000-1654-G0043
Mandatory
M
M
M
M
M
M
M
M
M
M
PEKA (Pengamatan Keselamatan Kerja)
M
M
Lifting Assessment and Authorization
Scaffolding Assessment and
M
M
M
Authorization
: JTB-RJJ000-S0-PRC-900-00043
Personnel
for Certain
Mandatory
Provided by COMPANY (9)
M
M
M
M
M
M
M
M
M
M
Orientation)
M
M
M
M
M
M
Permit to Work (PTW) System
M
M
M
M
M
M
M
M
M
M
PPE Awareness
M
M
M
M
M
M
Food Hygiene
M
M
M
Incident Investigation
M
M
M
M
M
M
Hot Work
Page 11 of 24
M
M
M
M
M
H2S
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
Working at Height
Scaffolder
M
M
Scaffolding Inspection
3
4
M
M
M
M
Certification by MIGAS
5
M
Certification by DEPNAKER
Man
Aider
Rigger
Welder
Revision
Mechanic
Pipe Fitter
Electrician
Signal man
Helper, Labor
Document No.
PTW Coordinator
JTB Project
Position
Environmental Coordinator
Painters & Abrasive Blaster
:0
Carpenters / Masonry / Rebar
M
M
M
M
M
M
M
M
M
M
M
M
HSE Project Induction
Safe Behaviour Training Competency
M
M
M
M
M
M
M
M
M
M
M
M
for All
(SBTC)
: S-000-1654-G0043
Mandatory
M
M
M
M
M
M
M
M
M
M
M
M
PEKA (Pengamatan Keselamatan Kerja)
: JTB-RJJ000-S0-PRC-900-00043
Personnel
for Certain
Mandatory
Provided by COMPANY (9)
M
M
M
M
M
M
M
M
M
M Orientation)
M
M
M
M
M
M
M
M
M
M
Permit to Work (PTW) System
M
M
M
M
M
M
M
M
M
M
PPE Awareness
M
M
M
M
M
M
M
M
M
M
Food Hygiene
M
Environmental Management System
M
M
M
Incident Investigation
M
M
M
M
M
M
M
M
M
M
Hot Work
Page 12 of 24
M
M
M
M
M
M
M
M
H2S
M
M
M
M
M
M
M
M
6
M
M
M
M
Working at Height
Scaffolder
Scaffolding Inspection
M
M
Certification by MIGAS
Certification by DEPNAKER
M
M
M
Government and / or Third
Cook
Revision
BATAN)
Surveyor
and Crew
Paramedic
HSE Trainer
Chief Quality
Drivers for LV
Document No.
Catering Crew
JTB Project
Position
:0
Quality Control Inspector (site)
M
M
M
M
M
M
M
M
M
M
M
M
M
M
HSE Project Induction
Safe Behaviour Training Competency
M
M
M
M
M
M
M
M
M
M
M
M
M
M
for All
(SBTC)
: S-000-1654-G0043
Mandatory
M
M
M
M
M
M
M
M
M
M
M
M
M
M
PEKA (Pengamatan Keselamatan Kerja)
: JTB-RJJ000-S0-PRC-900-00043
Personnel
for Certain
Mandatory
Provided by COMPANY (9)
M
M
M
M
M
M
M
M
M
M
M
M
M
M
Orientation)
M
M
M
M
M
Permit to Work (PTW) System
M
M
M
M
M
M
M
M
M
M
M
M
M
M
PPE Awareness
M
M
M
M
M
M
M
M
Food Hygiene
M
Incident Investigation
M
M
M
M
M
Hot Work
Page 13 of 24
M
M
M
M
H2S
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
Scaffolder
Scaffolding Inspection
Certification by MIGAS
Certification by DEPNAKER
M
Government and / or Third
Certification by DEPNAKER
Advanced First Aid & CPR
Certification by MIGAS
Scaffolding Inspection
Basic First Aid & CPR
Working at Height
PPE Awareness
Food Hygiene
Authorization
Orientation)
Scaffolder
Hot Work
(SBTC)
H2S
No Position
47 Drivers for HV M M M M M M M M M
49 Drivers for Ambulance M M M M M M M M M
51 Chief Logistic M M M M M M
52 Warehouse Superintendent M M M M M M M M M M M
Material Control
53 M M M M M M M M M M M
Superintendent
54 Warehouse Man M M M M M M M M
Notes:
1. Required only if the person travel to site;
2. Mandatory only for personnel involved in confined space;
3. Mandatory only for lifting inspector;
4. Mandatory for lifting operator;
5. Mandatory for heavy equipment (excavator, dozer, compactor);
6. Mandatory for helper / labor who assigned as dedicated fire watcher;
7. Mandatory if applicable based on task;
8. Driver stated as a visitor are not required to follow this training;
9. COMPANY only train all of CONTRACTOR personnel (for SUBCONTRACTOR personnel, COMPANY will conduct a Training of Trainer (ToT) to CONTRACTOR HSE Trainer.
Submit an Application
Letter Regarding ID
Badge Request No
Data
Complete
Attachment of Letter:
All personnel, SUBCONTRACTOR, and visitors shall provided PPE that complies with the
minimum requirement and type of PPE to be used at project site area. SUBCONTRACTOR shall
provide sufficient PPE for their personnel with minimum stock for consumable PPE at least for
covering 2 weeks during execution. The standards are following:
Notes:
- SUBCONTRACTOR shall provide eye glasses with clear lense for night shift and working inside
building or vessel;
- Full body harness mandatory at > 1.8 m elevation and must equipped with double lanyard
including shock absorber.
- Approved Permit to Work is required for every work and violation on this requirement will be
impact to termination of Person in Charge (work leader / supervisor / foreman / etc.).
- CONTRACTOR and / or SUBCONTRACTOR's construction and commissioning
Superintendent / Supervisor shall prepare Job Safety Analysis (JSA) and propose Work Permit
before starting the work.
- Approved JSA as CONTRACTOR’s format shall be submitted and presented as requirement of
Permit to Work issuance.
- Approved method statement is required for high risk activities or others that will be defined by
CONTRACTOR.
- Others related documents shall be attached as PTW requirements (such as rigging / lifting plan,
drawing / layout plan, ground disturbance certificate, confined space certificate, etc.).
- Permit to Work and all attachments shall be display at the workplace and in a good
understanding of all workers involved.
- Only competent personnel and assigned person able to operate machinery &equipment proven
by valid Migas certificates no except for rigger.
- Pre-mobilization inspection shall be proposed to CONTRACTOR subsequently gain approval
from COMPANY.
- SUBCONTRACTOR shall propose equipment (include heavy equipment) & vehicles produced
in the last 5 years (starting from 2013).
- SUBCONTRACTOR shall conduct internal inspection afterward routinely inspection by
CONTRACTOR as per scheduled that proven tools, machinery, and equipment are in safe
services and good condition of performing the function.
3.7. Excavation
- Design for excavation > 1.5 m (5 feet) (including protection system) shall be develop by Civil
Engineer.
- Where the trench excavation is benched, the height between benches should not exceed 1.2 m
unless designed by a consultant engineer. The overall width of the benched excavation should
not be less than the safe slope.
- Soil and materials must be kept at least 2 m from the edge of the excavation or transport to
other place to avoid landslide.
- For permanent retaining walls, check the overload capacity first.
- Support systems should only be erected, altered or dismantled by competent workmen under
supervision.
- Safe access must be provided into all excavations by means of ladders, ramps or stairs.
- Access ladders or other means of access should be placed at regular distances (max. 7.5 m)
so that workers only have to travel a short distance to escape if there any emergency situations.
- Access ladders should be placed at least 1 m protruding over surfaces and must be tied off to
prevent any movements.
- Climbing into or out of excavations using the waling and struts is prohibited. In narrow trenches
use vertical ladders.
- Walkways, bridges or ramps with standard guardrails must be provided where workers or
equipment are required to cross over excavations or trenches.
- At the edges of all excavations where a worker fall could occur ≥ 1.2 m, rigid barriers must be
erected or the excavation covered and clearly visible.
- Cylinder gas shall be in an upright position and secure properly with chain.
- Oxygen cilinders in storage shall be separated from fuel-gas cylinders or combustible materials
(especially oil or grease), a minimum distance of 20 feet (6,1 m) or by a non-combustible barrier
at least 5 feet (1,5 m) high having a fire-resistance rating of at least one half hour.
- Flashback Arrestor shall be install in all oxygen, acetylene and LPG Gas Cylinder. Flash back
arresters shall be used at both ends of the hose, ie, immediately after the regulator and
immediately before the torch.
- All gas cylinder shall be provided with cap and sticker which indicate the gas cylinder.
- LPG cylinder including hose shall be met industrial type and safe for use.
- Provide MSDS and fire extinguisher in each work location that involved the use of compressed
gas.
- Cylinders shall be identified by a color code in accordance with respective national standards.
- SUBCONTRACTOR shall provide label for all gas cylinders to indicate the contents of the
cylinder. Label has to be weather proof, readable in English and/or Bahasa in the format of
stencil, sticker, etc.
- Trained and competent person for operate portable electrically powered tools and equipment.
- Electrically powered portable tools and equipment shall be 110 volts center-tapped
- Electrically powered portables tools and equipment with 240 volts is allowed with follows double
insulated and the power source shall be equipped with ELCB 10 milli-amps
- Electrical tools for confined space work usage shall be supplied by DC current, if it’s not
available, AC current shall be equipped with Ground Fault Circuit Interrupter (GFCI).
- Use only tools that are grounded, double – insulated, and approved by Electrical Engineer.
- Do not use tools that spark, smoke or become excessively hot when in use.
- Electrically powered tools shall meet the hazardous zone requirement where applicable.
- All electrical cables and connector must be water proof material and industrial grade (IP 4.4).
Cables shall have NYYHY standard. Socket shall be 3 phase chord.
- All extension cords used must have explosion-proof ends (connectors).
- All “cheater cords” must be less than 2 feet in length with one male explosion-proof end and
one female standard U-ground plug, and must be used only at the immediate location of the
tool or test equipment.
- Sub-CONTRACTOR shall repair or replace defective tools and equipment at Sub-
CONTRACTOR cost.
- Welding machine and Generator Set must be equipped with distribution panel and emergency
stop.
- Distribution panel shall be equipped by MCB and ELCB / RCD.
- Temporary Construction Generator shall be located at appropriate area that not violating
operability of existing plant, in non hazardous area, consider the prevailing wind, and consider
safe distance from nearest hydrocarbon leakage. The running genset shall be monitored by
technician and fire watcher.
- Appropriate protective equipment must be worn at all time when using any tools or equipment.
Wherever required, wear protective equipment; insulated gloves, shock - resistant footwear,
safety goggles, etc.
3.11. Radiography
SUBCONTRACTOR shall ensure that radiography work shall be done in accordance with the
provisions of BAPETEN (BadanPengawasTenagaNuklir) regulations, as follows but not limited
to:
- All radiography equipment including X-rays shall have a valid license issued by BAPETEN.
- Radiography workers shall has received training and legal certification (permit) from BAPETEN.
- Radiography workers shall use the film / radiographic badge or personal dosimeter to control
the radiation exposure.
- Radioactive source must be stored (if not used) in a safe place (in accordance with regulations)
and locked properly. Only authorized personnel who havethe authority to take / check.
- Transportation of radioactive source from the storage to the work location shall meet the
requirements / procedures issued by BAPETEN especially vehicles used shall be equipped with
a radioactive symbol sign. During the transportation, survey meter shall be enabled to ensure
that workers who carry the source are not exposed to radiation levels (should not exceed 20 Sv
/ H).
- Radiography work area shall be provided with radiography / radioactive sign that refer to
international code (clearly visible, in Bahasa is a must, addition others language is optional,
weather proof (paper laminating is not accept)) and SUBCONTRACTOR shall maintain and
replace if damage. This sign also include warning regarding “Radiography Hazards – Prohibited
Area”.
- Radiography work shall also be provided with barricade around the area and standby man to
ensure unauthorized persons enter the area.
- Emergency equipment shall be provided near the work area.
- Radioactive waste shall be restored in a dedicated container and labeled “Radioactive Waste”.
LOTO procedures shall be implemented in the work area to prevent workplace accidents due to
the unintentional operating of the equipment, unintentional opening / closing the valve, working
on a live system, testing of systems / equipment, repairingmachine / equipment, and etc.
Implementation of LOTO procedures are integrated withworking permit system applied in JTB
Project. Related to this procedure, SUBCONTRACTOR associated with LOTO works shall
provide a sufficient amount of equipment such as lock (dedicated lock for LOTO) and tag.
Tag shall be weather proof (paper laminating is not accept) and SUBCONTRACTOR shall
maintain and replace if damage.
- Segregation hazardous solid waste (chemicals contaminated objects), non hazardous solid
waste (domestic waste), metal waste, and hazardous liquid waste (waste of chemical material
used).
- Provide vehicle for waste transportation.
- Provide trash can with criteria as follows:
• Hazardous Solid Waste (Red)
• Non Hazardous Organic Solid Waste (Green)
• Non Hazardous Anorganic Solid Waste (Yellow)
• Metal Waste (Blue)
- SUBCONTRACTOR responsible to manage by proper plan on hazardous waste, periodically
report / manifest shall submit to CONTRACTOR with refer to CONTRACTOR Waste
Management Plan and / or local regulation.
- The storage area shall display the MSDS, equipped with bund wall to prevent the widening of
the spill area, segregated for each type of waste and fire extinguishers (APAR).
- SUBCONTRACTOR shall provide vehicle to transport hazardous waste from workplace to
CONTRACTOR dedicated temporary hazardous waste storage (max store time is 90 days).
- SUBCONTRACTOR shall coordinate with licensed 3rd party to manage all hazardous waste
generated.
- Incompatible waste should be stored separately or in a manner that prevents the event of
mixed up and spill. This requirement can be met i.e. by providing adequate space between in
compatibles or physical separation such as walls or containment curbs.
- Label and symbol shall be unique and patched on each package of waste to describe
information of waste.
- Hazardous materials container / can shall be equipped with the MSDS (Material Safety Data
Sheet) can be obtained from suppliers. MSDS should contain the following information as a
minimum:
• Chemical identification and data
• Fire and explosion (Flash point temperature, flammable limit range, auto ignition
temperature)
• Health aspects (nature of hazards TLV-STEL, TLV-TWA)
• Emergency procedures
• Environmental (emission to atmosphere, spillage, neutralizer procedure, waste disposal)
• Transportation procedure
• Personal protective equipment to be worn
• Storage and spill kit requirements
Document No. : JTB-RJJ000-S0-PRC-900-00043
Revision :0 Page 21 of 24
Contractor Doc. No. : S-000-1654-G0043
- SUBCONTRACTOR responsible to manage construction waste as properly with refer to
CONTRACTOR Waste Management Plan and / or local regulation.
- SUBCONTRACTOR shall create a waste monitoring (volume, waste generated) and minimize
program.
3.14. Inspection
- Pre - Mobilization Inspection. Requirements that must be fulfilled for Pre - Mobilization
Inspection:
• Submission Letter for Pre – Mobilization Inspection
• Copy of SILO
• Copy of SIO
• Equipment (include heavy equipment) & vehicles produced in the last 5 years (starting from
2013)
- Monthly management walkthrough lead by CONTRACTOR Project Manager and attend by
Project Manager, HSE Manager, A&F Manager, QAQC Manager and Construction Manager of
CONTRACTOR and SUBCONTRACTOR
- Weekly safety patrol lead by CONTRACTOR Construction Manager and attend by Construction
Manager, GSI, Chief HSE/ HSE Coordinator of CONTRACTOR and SUBCONTRACTOR
- Daily inspections of work areas, fire extinguishers, heavy equipment (before and after
mobilization to the field), sling and wire rope, machine, scaffolding, etc.
- Unsafe Action & Unsafe Condition report (minimum target per person 5 PEKA / week)
- HSE COMPANY has authority to conduct safety inspection on the project
- Light vehicle shall be equipped with speed sensor, anti-lock brake system, air bag for driver &
passenger, and safety belt for all passengers.
- Workers transport vehicle shall be equipped with seat belt for passenger
- Quarterly inspection mark with color coding system:
• Jan-Mar (Red)
• Apr-Jun (Yellow)
• Jul-Sep (Green)
• Okt-Dec (Blue)
3.15. Reporting
In addition, SUBCONTRACTOR shall prepare all emergency response equipment such as but
not limited to fire extinguishers, first aid kit, etc. The amount of emergency response equipment
shall comply with applicable government regulations
3.18. Campaign
HSE campaign shall be one of the parameter of HSE performance and will be evaluated in audit
of SUBCONTRACTOR’s HSE Performance. The program of HSE campaign shall be put in
SUBCONTRACTOR HSE Plan at least but not limited to:
SUBCONTRACTOR shall provide welfare and security requirements for their workers, at least
but not limited to:
Supplying of food has established for preventive measure to be implemented in order to assure
the safety and suitability of food in controlling the food hazards accordance to HACCP (Hazard
Analysis and Critical Control Point).
a. Valid Laik Hygiene & Sanitasi Jasa Boga Certificate from Dinas Kesehatan Bojonegoro.
b. Food handler hold valid certificate by Dinas Kesehatan Bojonegoro.
c. Food handler stated fit by MCU.
d. Water quality test certificate.
e. Food Storage with temperature control.
f. Adequate PPE for food handler.
g. Disinfectant for food handler, tools and pantry as periodically.
3.21. Audit
The implementation of the work is in accordance with the Project Safety Management Plan at the
work place, in the field or in work location will be monitored and audited by CONTRACTOR in
monthly basis. The score of this audit shall meet minimum 80 of 100.
SUBCONTRACTOR shall attach KPI audit result in monthly progress report to submit invoice.The
consequences to fail the minimum score, will impact to suspension of monthly progress report
approval. The report will be proceed if SUBCONTRACTOR fullfil all of the audit recommendation
and proved by evidences.
SUBCONTRACTOR has obliged to program the audit in weekly basis focusing on working at
height, confined space entry, electrical safety, scaffolding, lifting work and nevertheless others
activities/ works which high possibility lead to incident.
The audit checklist and follow up action on the deviation will be fill in attachment of HSE
Performance Audit.
In order to comply with COMPANY’s ITB, CONTRACTOR will be implement rewards system in
term of appreciation on best HSE contribution & performance to workers and staff level as weekly
and monthly. The detail of program will be explained in Safety Management Plan.
CONTRACTOR and COMPANY has the authority to stop the work if the HSE violation is found
such as unsafe acts and unsafe conditions and has the authority to terminate workers from the
project if already done 2 times violations.