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STANDARD OPERATING PROCEDURE

HSE MANAGEMENT SYSTEM


In Compliance with ISO 9001:2015, 14001:2015, & 45001:2018

Document No. SKC-SOP-012


Issue Date 12-Oct-20
Issue No. 03
Revision 01
STANDARD OPERATING PROCEDURE
HSE MANAGEMENT SYSTEM

Contents
1. PURPOSE ....................................................................................................................................................................... 3
2. SCOPE ............................................................................................................................................................................ 3
3. ABBREVIATIONS AND ACRONYMS .......................................................................................................................... 3
4. HSE LEADERSHIP AND ACCOUNTABILITY .............................................................................................................. 3
5. HSE POLICY ................................................................................................................................................................... 4
6. HSE ORGANIZATION AND RESPONSIBILITIES ....................................................................................................... 5
7. MANAGEMENT OF CHANGE ..................................................................................................................................... 9
8. COMPETENCY ASSURANCE ..................................................................................................................................... 10
9. INTEGRITY ASSURANCE ........................................................................................................................................... 10
10. RISK EVALUATION AND MANAGEMENT .......................................................................................................... 10
11. CONSTRUCTION SAFETY PLANNING ................................................................................................................. 16
12. COMMISSIONING SAFETY PLANNING .............................................................................................................. 19
13. START-UP PRECAUTIONS SAFETY PLANNING ................................................................................................. 20
14. HSE DOCUMENTATION ........................................................................................................................................ 21
15. HSE TRAINING ........................................................................................................................................................ 21
16. PERMIT TO WORK SYSTEM .................................................................................................................................. 25
17. PERSONAL PROTECTIVE EQUIPMENT [PPE] ..................................................................................................... 27
18. COMMUNICATION NETWORK ............................................................................................................................ 28
19. HSE MEETINGS ....................................................................................................................................................... 28
20. EMERGENCY EVACUATION PROCEDURE .......................................................................................................... 31
21. FIRE PREVENTION AND PROTECTION ............................................................................................................... 31
22. HSE AWARENESS ................................................................................................................................................... 32
23. MANAGEMENT OF WASTE MATERIALS ............................................................................................................ 32
24. IMPLEMENTATION AND MONITORING ............................................................................................................ 34

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1. PURPOSE
The purpose of this Health, Safety and Environmental Plan is to outline the scope of services and activities
that shall be undertaken in the Project HSE. This document describes Contracting Authority [herein after
referred to as ‘CA’] HSE Plan, CA HSE Management Plan, SKC Engineers and Contractors Private Limited.
[Contractor] HSE Management System, and ensures that all major hazards that could cause harm to people,
environment or assets have been identified, and suitable controls and risk reduction measures are
implemented so that the risk associated to the work is as low as reasonably practicable.

2. SCOPE
This Project HSE Plan is developed, based on the CA’s requirements, and is designed to describe how
Contractor will manage and coordinate their HSE operations during the Engineering, Construction,
Commissioning and Start-up Phase for Project of the Contracting Authority.

3. ABBREVIATIONS AND ACRONYMS


CA Contracting Authority
Contractor SKC Engineers and Contractors Private
Limited
COSHH Control of Substances Hazards to Health
HAZOP Hazard and Operations
SIL Safety Integrity Level
QRA Quantitative Risk Assessment
SIMOPs Simultaneous Operations
HEMP Hazard Effects Management Process
JSA Job Safety Analysis.
PPE Personnel Protective Equipment
PTW Permit to Work

4. HSE LEADERSHIP AND ACCOUNTABILITY


4.1. Contractor will ensure that all Contractor’s personnel are briefed, understand and strictly adhere to CA’s
policies and directives on the health, safety and the environment.
4.2. Contractor will demonstrate leadership and commitment through actively participating in all aspects of
HSE management, supporting open dialogue and by allocating sufficient resources to ensure that the
HSE requirements are met.
4.3. Contractor will ensure that HSE responsibilities, authorities, accountabilities and competencies are
clearly defined, documented, communicated and exercised at all levels.
4.4. Contractor will ensure that individuals and team contributions to HSE performance are recognized and
considered during performance appraisals.
4.5. Contractor will set clear HSE goals, objectives and targets and ensure that performance is evaluated
against them.

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5. HSE POLICY
5.1. HSE Policy Statement
Contractor is committed to achieving the highest level of Health, Safety and Environment [HSE]
Management in all activities and services it undertakes.
To comply with these commitments, Contractor will:
5.1.1. Establish and implement the HSE Management System.
5.1.2. Employ proactive measures on risk assessment and environmental impact assessment, and
establish controls across all of its operations.
5.1.3. Comply with current applicable HSE legislation and welcome the recommendations from
interested parties that will positively contribute to the safety of the Project, the Environment and
the Workplace.
5.1.4. Establish the HSE objectives and periodically monitor HSE performance for continual improvement.
5.1.5. Educate employees and relevant Subcontractors’ personnel in their roles and responsibilities and
train them to be competent for the duty in order to achieve conformance to this policy.
5.1.6. Review on an annual basis and revise this policy as necessary to ensure it remains relevant and
appropriate to all requirements.

5.2. Project HSE Policy Statement


Contractor will prepare, implement and maintain a Project HSE Policy which shall contain a written
statement of policy describing Contractor's HSE Philosophy and Project HSE Objective. It shall be
communicated to all personnel and posted at prominent area. These will be displayed at all contractor
and sub-contractor sites.

5.3. Drug and Alcohol Policy Statement


5.3.1. Contractor shall have the right to prevent entry to the work site of any persons suspected of being
under the influence of drugs and/or alcohol. The introduction of alcohol or illegal drugs on to the
work site shall be strictly prohibited.
5.3.2. Anyone found under the influence of alcohol or drugs shall be removed from site.
5.3.3. All personnel will be advised on this Policy at their induction briefing and that Contractor may carry
out random testing on the personnel on the project.

5.4. HSE Objectives


Contractor will incorporate the following objectives:
5.4.1. Identify all potential hazards associated with the execution of the Project, and to develop
prevention, control and mitigation measures to eliminate or minimize harm to people, damage to
plant or equipment, or adverse impact on the environment.
5.4.2. Encourage the adoption of a positive, proactive, committed HSE culture throughout all phases of
the Project.
5.4.3. Achieve a target of zero fatalities and zero lost time injuries.
5.4.4. Minimize any impact on the natural environment.
5.4.5. Implement a management system with clear health, safety and environmental objectives.
5.4.6. Review the management of HSE throughout the Project duration in order to continuously improve
performance.
5.4.7. Communicate all the above objectives to all personnel in the Project.
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5.4.8. To engineer a safe, reliable, operable and maintainable facility.


5.4.9. To create a work environment that fosters prevention of incidents and delivers a goal of zero harm
to people and property.
5.4.10. To ensure all parties carry out sufficient risk assessments to cover all activities.
5.4.11. Minimize emissions and waste.
5.4.12. Maximize resources and energy.
5.4.13. Demonstrate no harm to the environment.
5.4.14. To meet host Government Legislation.
5.4.15. Management to conduct weekly site walk around to increase visible commitment.
5.4.16. Effective HSE training.
5.4.17. Identification of all hazards.
5.4.18. Openness between CA, Contractor, Sub-contractor and workforce.
5.4.19. Effective and frequent HSE meetings.
5.4.20. Effective Reporting of Near Miss and Unsafe Acts.
5.4.21. Incentives for good HSE performance.
5.4.22. Tools equipment and PPE always fit for purpose.
5.4.23. Emergency Response Plans ensuring all incidents are controlled and have limited impact.
5.4.24. Develop an Environmentally and Socially aware culture.
5.4.25. Effective communication at all levels to promote the ethos of zero harm to people property and
the environment.
5.4.26. Measure HSE Performance relative to continual improvement.
5.4.27. Perform scheduled audits: Internal; External; Corporate; Technical.
5.4.28. The aim of Contractor is to complete the Project achieving the HSE target of zero fire and zero
fatal accidents.

6. HSE ORGANIZATION AND RESPONSIBILITIES


6.1. HSE Organization
Responsibility for HSE permeates to all levels within the organizational structure of the Project, and the
Contractor down to each subcontractor and supplier. Coordination and cooperation between and across
these levels is aided through the use of a site HSE committee comprised of Contractor and subcontractor
site management, field supervision and employees

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Chief Executive
Officer
[CEO]

Senior Manager
Technical

HSE Manager Manager Projects

Project HSE Construction


Site Manager
Manager Manager

Project HSE Officer Project Engineer Site Engineers

First Aid Team Site Supevisors

6.1.1. Project Manager


Has the project responsibility and authority for ensuring that the specific HSE requirements are
identified, defined and fulfilled. These are defined in the project specific HSE plan/process
maps/work methods and procedures. Also he’s responsible for ensuring all of his management
team which includes the Construction Manager, Pre-commissioning Manager and Engineering
Manager, Procurement Manager, is meeting their HSE objectives and for attending on a regular
basis project HSE Committee meetings and recording the findings.
Responsibilities also include:
 Ensuring adequate HSE resources are available to implement HSE on the Project
 Chairs HSE meetings
 Supporting the application of the HSE Management System

6.1.2. Project HSE Manager


The HSE Manager establishes the safety control procedure based on CA’s safety manuals,
Governmental and CA’s requirements to prevent possible accidents arising at site. Safety Officers
will be assigned for safety assurance and control.

The HSE Manager and his staffs will take necessary actions to maintain the facilities in a safe
condition and instruct all site personnel to realize the importance of safety and to observe the
safety rules. The HSE Manager always keeps close working association with the respective
Construction Superintendents and draws their full attention towards accident prevention and safe
working practices. The followings are the few of the specific responsibilities of the HSE Manager.
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 Establishing field safety program.


 Adopting and applying standard safety practices, procedures, techniques and method.
 Establishing field security programs and making every possible arrangement for good
implementation according to the program.
 Conducting initial orientation and regular safety meetings to ensure familiarization of all
concerned party with safety requirements and to maintain safety consciousness and
accident prevention measures.
 Determining the legal requirements for protecting worker and the public from accidents
and health hazards.
 Providing a comprehensive program which will ensure the protection of life and property
and fostering construction efficiency through selective use of safe work practices and
through the establishment and maintenance of safe working conditions.
 Supervising whether the work is performing in accordance with recognized safety
standards, codes, statutory and/or local regulations, which may already exist or may come
into force at later stage.
 Conducting Accident/Incident investigations using Root Cause Analysis.
 Coordinate with CA and Contractor Medical Teams to ensure compliance with expectation.

6.1.3. Site HSE Officer


Coordinates with the Project HSE Manager and reports to the Construction Manager. He is
responsible for reviewing, monitoring, auditing and reporting on the performance of the HSE
activities and performs audits directly or through specialists assigned from the corporate
organization at his request. The Site HSE Manager will coordinate with the Construction Manager,
Construction Supervisors, Quality Assurance and Quality Control to ensure that the work is being
performed as required by the project HSE documents and procedures. Specifically, he will review
and approve method statements and Permit to Work requests. In addition, he is responsible for:
 Ensuring all HSE activities on site are in accordance with this Construction Safety Plan and
the Construction HSE Reference Manual.
 Ensuring all subcontractors/suppliers and visitors on site comply with project HSE
requirements.
 Coordinating with the CA Site HSE Representatives to establish meetings, training,
assessments, etc.
 Ensuring construction activities comply with all Pakistan Legislation.
 HSE training/inductions and awareness training and hazard Identification.
 Ensuring Risk Assessments are carried out for all potentially hazardous activities.
 Notifying directly to the Project HSE Manager any HSE concerns with reporting
responsibility to the Construction Manager.
 Preparing or amending the necessary work methods and procedures for working safely at
site.
 Implementation of the Transportation Policy and Standards
 Ensuring all medical resources is in accordance with project requirements
 Ensuring all Emergency Response planning is in accordance with project requirements and
that ER training is carried out.

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 Develop, maintain and implement site Emergency Response Plan. Also make planning for
emergencies with the Site Manager
 Responsible for accident investigation and reporting
 Reporting site HSE Inputs and statistics to CONTRACTOR Corporate HSE Department on a
monthly basis
 Responsible for site safety, security and labors health
 Application of HSE on site on behalf of the Construction Manager
 Line management of the HSE Department
 Improvement of HSE awareness and culture
 Advice to Construction Manager on HSE issues
 Administration and application of the safety incentive scheme
 Cooperation and coordination with the CA’s Safety Audit
 Review and implement the approved Safety Audit recommendation performed by the CA.
 Conduct scheduled inspections and HSE audits of all work areas and advising managers /
area supervisors on unsatisfactory conditions or practices being observed.
 Develop, maintain and implement site Traffic Plan in coordination with Construction
Manager.
 Shall report administratively to CONTRACTOR HSE Manager and functionally to
Construction Manager

6.1.4. Construction Manager


Responsible for ensuring all construction activities are completed in accordance with the project
HSE objectives and that all of his line management is suitably competent and trained in the same.
He is responsible for ensuring that all managers, supervisors and designated subcontractor
personnel reporting to him attend all required HSE meetings and training and comply with/support
all HSE activities including:
The Construction Manager will also have the overall responsibility for constructability and plot plan
and layout reviews for construction safety aspects. Under his authority, the construction
supervisors will implement the CONTRACTOR HSE policy in the daily activities.
 Promoting the implementation of the HSE Plan by personal example
 Ensuring that safe construction equipment, tools and personal protection equipment and
sufficient facilities for welfare, first aid and sanitation are available and used.
 Applying for Permits to Work
 Instructing the personnel working under their supervision to establish work methods, to
plan the sequence of operations, to outline potential hazards at each stage, and to indicate
precautions to be adopted.
 Checking work methods for newly started and major activities before work starts.
 Creating safety awareness by holding safety meetings and talks

6.1.5. Field Engineers and Supervisors


Field Engineers and Supervisors shall generally assist the Construction Manager/Section Manager
in the execution of their duties. Field engineers and supervisors' general responsibilities include,
but are not limited to:

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 Being familiar with the requirements and recommendations for Safe Working Practices and
Method Statements etc. applicable to their work place and ensure that they are enforced.
 Incorporating HSE instructions into the routine day to day orders and make sure they are
understood and obeyed.
 Preventing site persons from taking unnecessary risks.
 Ensuring that all employees and sub-contractor’s personnel are suitably trained for the
work in which they will be engaged.
 Ensuring that all employees and sub-contractor’s personnel adopt correct HSE precautions.
 Checking that all plant and equipment, including power and hand tools are maintained in
a good condition and remove from use any defective items.
 Maintaining organized tidy and safe working areas.
 Maintaining all welfare facilities in a clean and safe condition.
 Ensuring that all operators/labor are provided with and use approved personal protective
equipment.
 Ensuring that instructions are given in the use of any potentially hazardous materials.
 Discouraging horseplay and take actions against those who consistently fail to take care of
their own Health and Safety and of other persons working with them or in the vicinity.
 Stopping any activity on site if there is an immediate risk of injury to any site personnel, or
the possibility of a dangerous occurrence happening.
 Participate in any accident/incident investigation.

6.1.6. Worker's Responsibility


 Workers shall report to work in a fit and proper condition to perform their job in a safe and
competent manner.
 Workers shall observe and follow all established site HSE rules and safe work practices.
They shall adhere to all work directives and procedures for the tasks assigned [whether
provided orally or in writing].
 The use of personal electronic equipment such as hand phone, radio/tape sets shall be
strictly prohibited at the site.
 Workers can have ‘STOP Work authority’ for each worker if the person observes unsafe
situation.
 Workers shall report immediately any unsafe act or condition observed to a supervisor.

7. MANAGEMENT OF CHANGE
The Contractor continuously manages, monitor and assess changes in designs or procedures that could
potentially affect HSE performance.

Of primary concern to the CA is the possibility of changes being undertaken that impact on hazards and/or
their potential effects. The Contractor’s change procedure shall ensure that any change proposal is reviewed
by the Contractor’s HSE specialists prior to its implementation and the Contractor shall provide the
Contracting Authority with a report of each such change insofar as it is associated with the Contractor’s
performance of the Contract. Any change that involves safety critical equipment shall be referred to the
Contracting Authority Representative for review prior to implementation.

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The Contractor shall implement procedures to cover changes to conditions or processes on each Worksite.
Any change that may affect the health, safety, environment or security at a Worksite shall be covered by a
procedure that ensures that all Personnel at that Worksite are made aware of the implications for their
conduct at the Worksite.

8. COMPETENCY ASSURANCE
The Contractor make provision for ensuring that all Contractor’s Personnel are suitably qualified,
appropriately trained, experienced and familiar with the work they are to perform.

Prior to commencing Work at any Worksite, the Contractor shall demonstrate to the satisfaction of the
Contracting Authority that all of its Personnel have successfully completed essential training to ensure
competence and safe performance of duties appropriate to the parts of the Work being performed.
Prior to awarding any sub-contract, the Contractor shall have a process to assess sub-contractor’s ability to
comply with these HSE requirements and can demonstrate that all sub-contractors are suitably qualified,
appropriately trained, experienced and familiar with the Work they are to perform. Upon request by the
Contracting Authority, the Contractor shall provide evidence of such assessment prior to the bid award. The
Contractor is ultimately responsible for the performance of any sub-contractor and must ensure all sub-
contractors agree in writing to abide by the Contracting Authority’s HSE requirements
.
Contractor identifies inexperienced personnel so that others take precautions in their presence. Any
Contractor personnel with less than six months of service in the same job/position with his/her present
employer will be considered a Short Service Employee [SSE]. The SSE[s] shall have a mentor assigned to the
work site to provide consistent coaching, feedback, and oversight while employees develop skill sets to
conduct their job tasks safely.

9. INTEGRITY ASSURANCE
The Contractor has responsible for assuring the underlying integrity of any equipment or systems developed
and/or used in the Contractor’s performance of the Contract. The Contracting Authority expects that integrity
will be primarily assured by the Contractor’s effective application of internationally recognized codes and
standards and an appropriate quality management system.

10. RISK EVALUATION AND MANAGEMENT


Risk Management shall be performed before any work commences by all relevant project personnel, all
subcontractor organizations and on all worksites where hazards have been identified or potential hazards are
thought to exist.

10.1. Safety Planning and Coordination


The safety planning will start with the mobilization of the Project HSE manager and the preparation of
the Subcontracts packages.

As members are assigned to the HSE Group, they will familiarize themselves with the site conditions and
analyze the construction planning and construction equipment and resources, under the responsibility
of the Project HSE Manager.

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The Project HSE Manager will identify and list:


 The work areas close to the existing facilities and, therefore, requiring work permits.
 Activities requiring a Job Safety Analysis [JSA] and recommendations on how to carry out the
work.
 These lists will be issued for review to CA.
 The results of the safety planning will be published and discussed at the safety meetings, pre-
construction meetings and kick-off meetings with the sub-contractors.

10.2. Hazard Recognition and Control


SKC structured processes to be utilized during the planning and execution phases of the work to identify,
assess, and eliminate / control potential work site hazards includes the following:

 Project HSE Plan


 Site HSE Plan
 Construction Hazard Analysis
 Methods Statements
 Job Safety Analysis

The identification and evaluation of hazards and environmental issues at the various stages of the
Project and the development of control measures is part of the HSE management system.

The Project will use the Site HSE Plan as the basis for site HSE Planning for identified risks/hazards. The
project policy commits all personnel to ensure that prior to starting any task a risk assessment is
completed. The risk assessment has the prime purpose of identifying the hazards associated with the
task, who can be hurt and both that the appropriate controls are in place and the risks are reduced to
as low as reasonably practicable.

As an outcome of the hazard analysis, subcontractors shall be required to prepare JSA that address the
tasks to be performed. Then as part of the two week look ahead, the tasks shall be planned and,
equipment and personnel resources shall be identified and JSA developed.
Thereafter ongoing risk assessment, minimize residual risk, hazard identification and elimination are
achieved at the task level during the construction phase through inspections and audits.

10.3. Construction
10.3.1. Risk Assessment
As for Engineering, the identification, assessment and management process shall be regulated by
specific procedures, developed based on the plant characteristics, location, applicable legislation,
and CA’s requirements, shall apply.

Risk identification, assessment and management in Construction shall be an integral part of the
construction activities, starting from the planning at the Home Office. The following tools shall be
used

 Review of the studies conducted during the engineering phase of the project
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 Participation in the 3D Model Reviews and Building Reviews


 Constructability reviews
 Check lists
 Job Risk Analysis
 Pre-start check list
 Workshops for specific areas of risks or hazards.

Based on the results of this process, the methods of construction and type of equipment to be
used are selected and the documentation to be prepared, identified.

During construction, risk identification, assessment and control shall be regularly carried out as
part of the pre-job risk analysis, and the preparation of method statements. Specific construction
risk assessments shall be conducted by SKC with the participation of CA and Subcontractors for
such items as heavy lift, concurrent construction of different disciplines [e.g., as civil works and
piping] in the same area at different elevations and confined space work.

10.3.2. HSE Management


HSE management and safe working practices to be considered for transition phase since activities
will be occurring without operating facility. That is Construction /Commissioning/ Startup activities
will be going on at the same time.

The Site Manager has responsibility for HSE during the construction phase. He is assisted in the
implementation of HSE by the Site HSE Manager. HSE is everybody’s responsibility and the Site
Manager will ensure that all members of the Project understand their duties.

10.3.3. Identification of Hazards and Effect


The Contractor shall adopt various techniques to identify hazards in construction and completion
phases to assess their likelihood and consequences. The analysis shall be used in implementing
control measures to manage the risk effectively.

Construction site risk will be identified and mitigated in a planned manner that will be established
before commencement of construction work.

Job Safety Assessment and other industry standard methods will be implemented to assess the
hazards and identify the relevant controls required to control the risks.

 Job Safety Analysis [JSA]


 Control of Hazardous Material
 Preparation and implementation of relevant site HSE procedure
 Implementation and monitoring of effective general workplace practices
 Implementation of Permit to Work [PTW] system given by the CA
 Effective site supervision
 Preparation of hazardous chemicals and dangerous goods/materials inventory

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10.3.4. Job Safety Analysis [JSA]


Contractor will perform JSA to analyze the individual steps of a particular job and identify the
hazards and risks involved in each step so as to develop ways to minimize or eliminate them as
below sequence.

 Select the job to be analyzed with consideration of “Frequency of Accident", “Severity


Potential”, “New Work Operation”, “New Job” and “High-rated Job”
 Break the job down into a sequence of steps, each describing what to do.
 Identify Hazards and Potential Accidents which are associated with job step
 Decide what control measures or job procedures are necessary to eliminate or minimize
the hazards.
 Perform education for involved employees and ensuring the implementation of control
measures.

SKC supervisors or Subcontractors will develop and perform a pre-task job safety analysis in order
to set out clear procedures and safety requirements for new activities and those hazardous
activities listed by the Site HSE Manager.

The JSA is a step-by-step analysis of the work to ensure that all the hazards are identified and the
necessary precautions are taken into account to eliminate or isolate the hazards of the work to be
performed.

A standard form will be used for recording the results of the analysis. Depending on the complexity
of the activity analyzed, more than one sheet, additional information and diagrams or Material
Safety Data Sheets [MSDS] may be attached.

The supervisor will present the JSA to the work crew who will carry out the work to ensure that
they understand the risks involved and the work methods to be applied.

10.3.5. Hazards Effects Management Process [HEMP]


 Activities of all personnel having access to the workplace [including Subcontractor, workers,
visitors and CA].
 Facilities of the workplace to be provided by Contractor or others.
 Contractor will ensure that the results of these full and systematic assessments and the effects
of the control measures are considered when setting / reviewing/ revise / updating HSE
objectives.

10.3.6. Control of Substances Hazardous to Health [COSHH]


The control of substances hazardous to health is recognized as a critical element of the safety
program and will be achieved through a combination of hazard communication, establishment of
HSE systems of work and controlled handling and disposal of such substances.

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All activities within the site will be carefully and systematically evaluated for potential health
hazards to provide comfortable working circumstance and the preservation of good Health and
Hygiene Practices.

Methods such as systematic inspections, interviews and questionnaires, and follow up by technical
sampling of the employees on location will assist in identifying and assessing hazards.

A Health Risk Assessment shall be conducted to identify and evaluate the following health hazards:
 Chemical Hazards
 Noise Hazards
 Radiation Hazards
 Illumination Hazards
 Vibration Hazards
 Temperature Extremes
 Ergonomic Hazards

Other surveys will be conducted as necessary.

The health hazard control measures will be established during planning of Plant / facilities and
improved according to necessity during the construction phase.
The principal health hazard controls are:
 Elimination of hazards
 Substitution of safer substances and/or devices
 Engineering control, such as improvement of operation, providing safeguards, ventilation,
etc.
 Administrative control, such as providing proper work procedures, observation of HSE
requirements and rules, etc.
 Ensuring all exposed personnel wear and use proper Personal Protective Equipment

The control system commences at the procurement stage, at which all vendors and Subcontractor
will be required to submit Material Safety Data Sheets for all hazardous substances that they will
be supplying.

Copies of these data sheets [including methods of treatment of injuries sustained by hazardous
substances] will be forwarded to the Site HSE Manager who will retain a master file.

Subcontractor will be required to carry out assessments in co-ordination with the Site HSE Manager
and Field Supervisors [Commissioning Engineers] and in compliance with recognized standards.

Only when all parties are satisfied there are no suitable alternative safer materials, and, that the
control measures are adequate, will the materials be permitted on the worksite and used.

Such control measures will address transport, storage, labeling, packaging, handling, disposal,
personnel protective equipment and emergency procedures and training therein.
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Persons using such substances will be trained/ informed on acquainted with the associated hazards
and the necessary control measures through pre-task instruction and ready availability of method
statements and data sheets.

The hazardous substances covered will also include products from construction processes [such as
welding fumes and solvent vapors].

The disposal of waste material will also be considered, e.g. spent lubricating oil.

Storage of hazardous substances on site will be kept to a minimum, as agreed by the Contractor.

The requirements of Control Procedure of Substances Hazardous to Health [to be developed later]
will apply.

10.4. Environmental
The most effective way to manage the environment is to avoid spillages. Where this is not entirely
possible mitigation measures will be put in place.

The Project HSE Plan contains further details on environmental management needs and will be read in
conjunction with this Construction HSE Procedure.

The Contractor and its Subcontractor will follow Project soil erosion control plans that are in place to
identify and address appropriate erosion control measures.

The Contractor and Subcontractors will comply with CA’s ESIA and will adopt the specific procedures.

10.4.1. Environmental Requirements and Protection


These reports identified the environmental sensitivities and impacts relevant to this Project and to
protect the environment by a hierarchy of measures based on firstly prevention, followed by
mitigation or compensation.
These measures define the environmental requirements.

10.4.2. Impacts and Environmental Assessments


These assessments will be used in the preparation of permit applications for the disposal of
construction wastes, both solids and liquids, and permits related to the disposal of excess soil, to
ensure full control of any environmental impacts, during the construction phase.

10.4.3. Air Emissions


Emissions during construction and commissioning will arise from the vehicles used for
transportation and from the diesel generators.
Dust and noise surveys will be carried out in the vicinity of the construction site. The Contractor
will carry out surveys.
Countermeasures for construction emissions are as follows:
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 All internal combustion engines will be suitably serviced and maintained to reduce
polluting emissions.
 Dust control will be accomplished by properly wetting the work area by water truck, etc.,
prior to commencing the work and/or other approved measures.

10.5. Pre-commissioning and Commissioning


10.5.1. Risk Assessment
The identification, assessment and management process for Engineering and Construction shall
be regulated by specifically developed procedures based on the plant characteristics, location,
applicable legislation, and CA’s requirements shall apply.

Risk identification, assessment and management shall be an integral part of the pre-
commissioning and commissioning activities. Based on the results of this process at the Home
Office, the Pre-commissioning group may propose changes in design [pre-commissioning and
commissioning in, or close to, general construction areas or punch listing in pre-commissioning
and commissioning areas], for example addition of isolation valves. The following tools shall be
used

Review of the studies conducted during the engineering phase of the project, such as QRA
Participation in the 3D Model Reviews
 Constructability reviews
 Check lists
 Job Risk Analysis
 Pre-start Check list
 Job Task Analysis
 Health Risk Assessment
 Workshops for specific areas of risks or hazards
At the Site, risk identification, assessment and control shall be regularly carried out, in particular
for the coordination between the pre-commissioning and commissioning crews and the
construction crews working in, or closed to, areas that have been energized. Specific risk
assessment workshops shall be conducted by SKC with the participation of CA and Subcontractors
for such items as energization of the facilities and introduction of hydrocarbons. The results of the
workshops carried out before the start of construction, i.e., recommendations and action items,
shall be regularly reviewed by the Pre-Commissioning Manager to ensure that the assumptions
made at the workshops on the working areas and the construction schedule are still valid.

11. CONSTRUCTION SAFETY PLANNING


11.1. Crane/Lifting Equipment/Lifting Gear
Risks associated with lifting are significant and, coupled with the considerable scope of such activity,
represent a substantial area of potential loss exposure.

Consequently, the Contractor will utilize stringent control on both the lifts themselves and the hardware
involved.

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Therefore, all cranes, Hiabs, piling rigs, etc., will be inspected, load tested and all certification checked
by the Contractor prior to entry onto the worksite.

The Heavy Lift Supervisor will maintain records of such inspections.

All proposed Subcontractor prior to mobilization would assess crane/lift operators for competency and
ensure that all certification is valid for the equipment being used.

This will comprise the submission of a valid national operator’s license and also the successful
completion of a local competency test.

All lifting equipment to be added to the Contractor’s lifting register and Colour Coded based on 6
month inspections/re-certifications by a competent person.

If successful, operators will only be permitted to operate the equipment for which they have been
assessed.

11.2. Temporary Electrics


Contractor will prepare site specific procedures defining electrical safety requirements and precautions
for those employees working near electrically operated equipment tools, or with cause to work on or
near electrically operated equipment tools, or with cause to work on the construction power supply
system.

11.2.1. Electrical Hazards:


The construction site will present a number of potential hazards from the use of electrical tools
and equipment and the electrical power supply which extends throughout the work site and each
of the working areas.
The hazards from electrical fault or mishap on the construction site are severe and ever present.
They include:

 Electrocution or electrical shock which may kill or cause serious injury.


 Overhead electrical conductors may cause burn injury and ignite flammable materials.
 Switching or sparking of ordinary electrical equipment in flammable atmospheres may
cause fires and explosions, even a small spark from a battery operated appliance may have
sufficient energy as a source of ignition.
 Electrical arcing and flashover from improperly operated switches, etc. may cause burn
injuries.

Accordingly, proper care will be exercised when installing, operating and working around such
electrical equipment and systems on the site.

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11.2.2. Electrical Safety Measures:


The electrical safety procedures to be applied on site and will include training/orientation of both
Safety Supervisors and the work force in the hazards that can be encountered and the safe working
measures needed to protect against injury or damage

11.3. All Vehicles and Traffic Control


Traffic on the worksite will be minimised so as to avoid unnecessary hazards and congestion at the
workplace, with entry onto worksite being controlled via the issue of vehicle passes.

Speed limits will be enforced by the Contractor Security Department.

Specific accesses and egresses for pedestrians will be maintained at all times, as will routings for
emergency vehicles. Any vehicle wishing to block roads for any period of time will first obtain a road
closure permit from the Contractor.

Subcontractor will be made aware of all such closures and heavy equipment routings at Subcontractor
daily HSE meeting.

The Contractor and Subcontractor will develop Road Safety Policies to minimize possibilities of traffic
accidents on the public highway, e.g.:
 Driving times
 Age
 Driving hours
 Route and resting plan

11.4. Welding and Heat Operation


The purpose of this welding and heating operations instruction is to outline the Safety requirements for
managing and controlling operations involving the use of welding equipment on this Project.

The main hazards likely to be encountered during welding and burning processes can be identified as
follows:

 High Temperature causing risk of fire and burns.


 Fumes emitted from the process likely to cause injury to health.
 Radiation causing 'arc eye' and burns.
 Oxygen deficiency or enrichment, particularly within an enclosed space.
 Electric shock
 Explosions during the welding and cutting of drums, tanks or vessels which have contained
flammable materials.

These instructions provide general considerations for the control and use of welding and burning plant
and equipment used on site which is based upon Permit to Work Camps, Offices.

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Fire watchers shall be placed whenever welding or cutting is performed in locations where a risk
assessment shows an increased likelihood.

11.5. Excavation Procedures


Excavation procedures will be developed to address soil classification, benching, shoring, air sampling,
and entry and exit routes, spoils location, and traffic and equipment management.

12. COMMISSIONING SAFETY PLANNING


Commissioning Group will pay particular attention to identify any additional flanging, spading or valve
isolation requirements to ensure the integrity of live systems in an area where construction work is still being
carried out.

Development of diesel and water management plans, and waste disposal procedures will be carried out.

The safety and welfare of the work force and the need to protect equipment must be considered paramount
and highlighted in any work permit that is issued.

12.1. Work Permit Control


12.1.1. Once a system has been handed over from Construction to Commissioning and comes under the
care and custody of Commissioning, the Commissioning Manager will be responsible for issuing
work permits that will govern all activities to be carried out in the areas being commissioned.
12.1.2. A Permit Office will be provided to manage the issue regarding the Work Permits.

12.2. Prevention of Contact

Ingestion Eating and drinking will be only allowed in designated areas.


Measures must be taken to prevent hazardous materials from contacting the skin
and provide first aid or medical treatment in the case of accidental contact. Non-
Skin Contact
porous gloves and goggles are minimum requirements.

All process equipment in accessible areas operating at temperatures above about


70oC is normally insulated to ensure personnel protection. Lines and equipment
Burns in cryogenic service are also insulated for heat retention and for protection against
cold burns. General-purpose gloves will be worn.

Eye irritants can cause permanent damage to the eye very rapidly. All eye injuries
will receive immediate medical attention. Eye wash bottles and water coolers will
be located on plant against recognized approved standards where materials such
Eye Contact as acids, alkalis, amines can be encountered. Safety glasses must be worn and
goggles must be worn on the helmet in all commissioning areas.

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12.3. Maintenance of Safety Equipment


All safety equipment will be checked on a monthly basis and must be maintained in a condition ready
for use.
Fire extinguishers must be checked at monthly intervals and recharged or replaced immediately after
use. All air and water hose equipment must be returned to their original place after use. Access to such
equipment must not be obstructed. When a fire extinguisher is used the occurrence of a fire will be
reported in an incident report.
No work on any live equipment will be done without a properly authorized permit to work issued by
the Commissioning Manager or his designees.

12.4. Housekeeping
Loose materials etc., will never are left in a manner causing a tripping hazard on platforms, access ways,
etc.

Access to ladders and fire escapes must be kept accessible at all times. Waste and refuse must be put
in proper designated areas or containers.

13. START-UP PRECAUTIONS SAFETY PLANNING


13.1. Work Permit Control
All work will have a Work Permit issued by the CA operations. All conditions on the work permit will be
strictly adhered to such as fire extinguishers to be in place and drainage systems covered.
13.2. Emission to Atmosphere
Hot liquids or vapors must never be discharged directly to the atmosphere. All measures must be taken
to prevent or control emissions. Where temporary noise pollution exceeds 75 dBA, temporary silencers
will be used.

13.3. Toxic Gases


Vessels may contain highly toxic gases. Inert gases such as nitrogen pose a particular hazard of
asphyxiation. Extreme care must be taken in the venting purging, cooling and opening of such
equipment.

13.4. Working Practices


13.4.1. No burning, welding, cutting, grinding, or other hot work will be allowed in live areas unless
properly authorized by a permit to work issued by the CA Operation representatives.
13.4.2. No person will be permitted to work within a flammable atmosphere. Where appropriate proof
tested flammable gas detector of calibrated will be employed to minimize the risks from any
leakage by providing adequate warning.
13.4.3. Authorized personnel in compliance with a permit to work will only work electrical equipment on.
13.4.4. Do not use hydrocarbons to clean machinery or for any other cleaning purposes. Use a permitted
cleaning agent instead.
13.4.5. When pressurized systems are to be worked on a procedure with a method statement must
accompany the work permit.
13.4.6. Environmental requirements for collection of cleaning agents to be determined
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13.4.7. Guards around moving shafts or couplings, which have been removed must be replaced when
repair work is completed and before equipment is energized.
13.4.8. During flushing or air blowing, areas where liquids or gases are exiting must be barricaded off and
warning signs, written in English and local languages displayed.

14. HSE DOCUMENTATION


14.1. General
The HSE documentation consists of the following:
 Project HSE Plan, this document
 Confined Space Entry Procedure
 Site Health, Safety and Environment Plan
 Emergency Response Plan
 Environmental Management Plan
 Work at Height Procedure
 Incident Reporting and Investigation
 Occupational Health Policy and Procedure
 Health Risk Assessment
 HSE Schedule and Indices
 Safety Management Plan
 Project HSE Audit Procedure and Plan
 CA Procedures and Requirements. These procedures shall be followed by SKC as per contract
agreement with CA

14.2. Documentation Hierarchy


The hierarchy of the HSE Documentation is as follows:
 Laws and Regulations of Pakistan
 Contract between CA and Contractor
 CA Project Specifications and Mandatory Procedures
 Contractor HSE documentation, plans and procedure
 Project Management Directives
Internationally recognized standards for items that are not adequately covered by regulations or project
requirements

15. HSE TRAINING


15.1. General Information
Contractor will establish and provide the essential resources [human, technical and economic] to ensure
the implementation, control and improvement of the HSE system.

The CA is the main reference for Contractor and subcontractor HSE training requirement.

Therefore, Contractor will establish the necessary means are taken to ensure that any person working for
the Project has, but are not limited to:
 Their HSE functions and responsibilities clearly defined.
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 The necessary experience and information to carry out his functions.


 The necessary means and resources to carry out the work.
 Awareness of the policy and the requirements of the system, the preventive aspects of his work
and consequences of non-compliance with procedures.

15.2. SKC, Subcontractor and Supplier Personnel


All HSE training for construction personnel will be conducted through the following:
 Work-site admission orientation sessions
 Pre-construction meetings for critical activities
 Training and awareness sessions
 Safety meetings

15.3. HSE Induction Training for New Entrants


It is mandatory for all managers and employees of the Contractor and Subcontractor to attend HSE
Induction Training prior to starting their fieldwork.
Without taking this training course, they cannot receive an Identification [ID] card for entry to work on
the construction site.
Prior to the HSE Induction Training, all managerial personnel and employees will submit their “Personal
Information” using the designated form [name, age, gender, profession, physical status, experience,
license or certification, etc.].

For the training of safe work practices, “Safe Work Practices and Equipment Standards”, which will be
developed including the requirements of CA legislations and standards, is available for trainer’s use.

Any Contractor personnel with less than six months of service in the same job/position with his/her
present employer will be considered a Short Service Employee [SSE]. The SSE[s] shall have a mentor
assigned to the work site to provide consistent coaching, feedback, and oversight while employees
develop skill sets to conduct their job tasks safely.

The Induction Training includes individual instruction given to new entrant workers and their supervisors
according to their work categories, as described below, but not be limited to:

15.3.1. General Orientation


All personnel assigned to or visiting the construction site will be given a site induction course and
badge/sticker the first day of work by SKC. This course is mandatory and no entry to the
Construction Site or work will be allowed prior to participation in the Safety Induction.
Outline of the work and the work procedures.
Working Rules:
 Duty hours
 Overtime work
 Transportation
 Prohibition of smoking
 Drugs and alcohol

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 Possession of firearms, etc.


 Participation in the Tool Box Meetings,
 Security rules, including Gate Control,
 Confirmation and registration of worker’s craft certificates or other form of qualification,
 Traffic rules and regulations,
 Outline of Emergency Procedure,
 Work Permit System
 Fire Prevention
 Personal Protective Equipment Requirements and abuse /ineffective use
 Personal Health and Hygiene
 Anticipated environmental problems and their countermeasures,
 Housekeeping requirements
 Avoidance of spillage/contamination, use of drip trays, oil pans,

15.4. HSE Training for Managers and Supervisors


In addition to the Induction Training for new entrants, specific HSE training is given to Contractor and
Subcontractor Managers [Two times per year] and Supervisors [Three times per year] by the Site HSE
Manager or competent persons assigned by Site HSE Manager, the training will cover, but not be limited
to:
 Individual’s roles and responsibilities for HSE management
 Enhancement of HSE awareness [emphasize Line Responsibilities]
 Regular safety activities
 HSE Committee Meeting and other HSE meetings
 Incident Reporting and Investigation
 Environmental Awareness & issues
 Hazard Awareness and Communication
 Light and Heavy Vehicle Daily Check
 Method Statement, Risk Analysis Job Safety Analysis, for permanent and
temporary works
 HSE Management System

15.5. HSE Training for Specific Hazardous Work


Special training will be given by competent persons designated/approved by the Site HSE Manager, to
supervisors, foremen and workers involved in specific hazardous or harmful work, the training will cover,
but not be limited to:
 Handling organic solvents, and toxic and hazardous chemicals
 Handling and storage of radioactive materials
 Work under, over on or near water
 Deep excavation and trenching
 Work in confined areas or narrow spaces
 Rigging, lifting and crane operation
 Erection and dismantling of scaffolds
 Work in or near an existing plant [regardless of whether operating or not]
 Removal of Grating

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 Working at Heights
 Hot works
 Stored Energy

15.6. Fire, Evacuation and First-Aid Training


Fire and First Aid Training, and Evacuation Training will be given to all employees. The competent
personnel designated by the Site HSE Manager conduct this training.

15.7. HSE Training Matrix


Employee training is a key component of any safety program. The matrix provides guidance for SKC
Engineers’ supervisors to identify common employee training requirements. The matrix does not
include every training topic needed. Therefore, if they have duties that are potentially hazardous
supervisors must ensure that appropriate information has been provided. Any time the duties,
equipment and/or processes change, the employee must receive updated training. Training must be
documented and records must be kept for a minimum of three years.

Applies to Required training Class Training frequency

1. All classifications Injury and Illness Prevention Initial hire


Program [IIPP]
Unit emergency plan Initial hire, review when changed
Fire extinguisher use 1
Initial hire
Back Safety Initial hire
2. Users of computers more than 4 hours a Ergonomics Initial hire
day or 20 hours a week
3. Users of chemicals or those who may Hazard communication Within 30 days of hire or the
4. be potentially exposed to them [non- introduction of a new chemical and
laboratory] annually thereafter.
5. Employees performing maintenance Lockout/tag out Prior to working on the equipment
6. on stationary machinery and when procedures change
7. Employees entering trenches, pits, tanks, Confined space entry Prior to entering a confined space or
manholes or vaults or act as an acting as an attendant and annually
attendant thereafter
8. Users of eye, face, foot, hand or hearing Personal Protective equipment Prior to using the PPE
protection
9. Users of fixed industrial or portable Ladder safety Initial hire
ladders
10. Employees exposed to high noise levels Hearing protection Initial hire
11. Users of any type of respiratory Respiratory protection Prior to use and annual refresher
protection
12. Employees who are exposed to human Blood borne pathogens standard Initial hire and annual refresher
blood or blood containing fluids

1
Fire extinguisher training should be made available on a voluntary basis to everyone.
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Applies to Required training Class Training frequency

13. Employees who generate or handle Hazardous waste management Initially2


hazardous waste
14. Employees performing work on any Asbestos management Initial 40 hour training and 8 hours
asbestos containing material annual refresher3
15. Employees working on an unguarded Fall protection Initial hire
surface more than 6 feet off the ground

16. Employees using portable or stationary Tool Safety Initial hire


power tools
17. Users of Radioactive isotopes Radiation Safety Initial hire and annual refresher

18. Operators of forklifts and powered, Training on specific equipment to Before initial use of the equipment
elevated work platforms be used

Supervisors should ensure that all employees receive general and job-specific training prior to initial or new
job assignments. In addition, training is required:

 whenever new substances, processes, procedures or equipment are introduced to the workplace which
may create new hazards.
 when new or previously unrecognized hazards are introduced into the work environment or brought to
a supervisor's attention
 when an employee cannot demonstrate adequate understanding of the safety requirements of a task
All training must be documented and kept in department files for a minimum of three years.

16. PERMIT TO WORK SYSTEM


A permit to work system will be implemented on the Project, to ensure that those tasks attracting elements
of risk will be subjected to thorough and systematic planning and preparation prior to their authorization to
proceed.

The Contractor will continually update the precise scope of the application reflecting the differing needs of
the various construction phases and also the need to interface with the permit to work systems to be
implemented during commissioning and start up.

Notwithstanding this, certain activities mentioned below are required to obtain a Work Permit issued by
Contractor issuers.

 Confined Space Entry,


 Radiography, pneumatic testing,
 Removal of grating and handrails on structures, etc.,
 Electrical work requires to de-energize or isolate electrical equipment/components,

2
Depending on job duties, other requirements may apply
3
Depending on job duties, other requirements may apply
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 Explosive Device, use of cartridge-operated tools,


 Pressurized Testing

The underlying philosophy of the Contractor permit to work system is that Subcontractor task supervisor
receives a permit only after it has been reviewed by The Contractor Discipline Supervisor and approved by
the relevant Area Construction Manager [Commissioning Manager].

Further, the permit program provides a form of method statement, job safety analysis that clearly identifies
measures to be adopted by Subcontractor and his employees.

Only persons who have successfully completed the Contractor permit to work training module will be
permitted to initiate, receive, review or authorize permits.

The system that allows central control and ongoing monitoring of higher risk activities to ensure that activities
are;
i. Authorized by the appropriate site supervisory personnel responsible for the particular area or
for control of hazardous activities,
ii. Carried out by qualified personnel using appropriate safety precautions
iii. Ensures that those activities with potentially hazardous interactions do not take place at the same
time.

16.1. Cold & Hot Work Permit


16.1.1. Cold Work Permit
i. General construction/commissioning work and maintenance not involving the breaking of
containment of hydrocarbon system
ii. Working with radioactive sources: Radiography Certificate also required
iii. Working with nitrogen gas
iv. Excavations: Excavation Certificate also required
v. Working with mineral fiber
vi. Handling or use of hazardous substances
vii. Spray painting/coating
viii. Work affecting the availability of fire and gas detection system, e.g. flammable gas
detection, fire detection and Uninterruptible Power Supplies [UPS]
ix. Work affecting the availability of fire protection gaseous system [CO2]
x. Work affecting the availability of process safety and protection arrangement, e.g.,
Emergency Shutdown Valve [ESDV] systems, blow down and drains systems
xi. Work affecting the internal or external communications systems of the installation/site
xii. Working on computer controlled systems
xiii. Removal of handrails, gratings, hatches and fixed ladders
xiv. Work at height greater than 1.8 meters
xv. Pressure testing of plant and equipment
xvi. Bleeding down vessels to drains or to atmosphere
xvii. Use of equipment or work in Non-Hazardous Zones involving:
a. Dry grit/shot blasting

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b. Cartridge operated tools


c. Use of torque wrenches in Hazardous Zones
xviii. Electric work

16.1.2. Hot Work Permit


i. Work involving naked flame
ii. Welding
iii. Use of portable grinder [electrically and air power]
iv. Use of heat shrink blowers and electric power tools in Hazardous Zones
v. Nitrogen/ Gas leak testing of plant and equipment

16.2. Confined Spaces Permit


A space that is large enough and so configured that an employee can bodily enter and perform assigned
work.
16.2.1. Confined Space permits are required for any confined space entry operations
16.2.2. A confined space is a place, which if substantially [though not always entirely] enclosed, and where
there is a reasonably foreseeable risk of serious injury form hazardous substances or conditions
within the space or nearby. Examples of confined spaces are closed tanks, vessels, sewers,
open-topped tanks, vats, pits, and closed and unventilated or inadequately ventilated
rooms
16.2.3. Some places fall within the definition of a confined space only occasionally, perhaps due to the
type of work to be undertaken e.g. spray painting in a room. Spaces may become confined due
to a change in the condition inside or change in the degree of enclosure or confinement that may
occur intermittently.
16.2.4. An initial gas test must be recorded on the Confined Space permit and must be continuous unless
special dispensation is granted.

17. PERSONAL PROTECTIVE EQUIPMENT [PPE]


An effective PPE program is an essential protection against those hazards, which cannot be engineered out
of the construction environment.

Further, the conformance to the PPE program also provides a valuable indicator of safety attitudes and
behavior of the workforce.

The Contractor and Subcontractor will ensure that all PPE is "fitted" correctly to meet individual requirements.

All PPE will conform to either AS, BS, ANSI or DIN standards when applicable, be suitable for the purpose,
and will be maintained by individuals to ensure that the integrity of such equipment is not compromised.

In addition, such equipment will be provided free issue to all Subcontractors, and replaced as required.

Certain items of PPE will be mandatory and worn at all times whilst on the worksite, these will be:
 Safety helmets
 Safety footwear with steel toecaps
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 Safety glasses with side protection


 Coveralls [minimum 60% cotton or 100% cotton]
 Welders Coverall, Fire retardant

During the Commissioning phase in addition to the mandatory wearing of P.P.E specified in above other
items of appropriate type of equipment required by/for the work will be in use.

Also, any persons working at an elevation of 1.8 meters or above will wear a full-body safety harness with
dual lanyards that will be attached to an adequate load bearing anchor point or lifeline appropriate fall arrest
or on an incomplete structure when working outside handrails.

However, the Contractor stresses that this is a residual form of protection, the need for which will be avoided
wherever practicable by the use of safe working platforms.

18. COMMUNICATION NETWORK


Effective communications are vital to the successful implementation of the health, safety and environmental
plan.

Communications take many forms but their common objective is to improve understanding of health, safety
and environmental matters, thus obtaining the support, co-operation and commitment of all interested
parties.

Contractor will ensure that all of its personnel are able to communicate in a safe, clear and effective manner.
It is imperative that all personnel are given and understand written, visual and oral instruction from
management and supervisors.

Contractor will provide all resources necessary to ensure that communications are understood among all
personnel on any Worksite. Contractor will carefully consider and specify the requirements for
communication between multi-national workforces and ensure that each work crew shall use a common
language or have an in-crew interpreter.

19. HSE MEETINGS


19.1. Monthly Site HSE Committee Meeting
Contractor Project Manager chairs the HSE Committee Meeting with members comprising Contractor
Construction Managers, each Area Construction Managers, Site HSE Manager, all the Subcontractor Site
Managers, HSE Managers, and the CA’s Project Manager, HSE Representatives.

The HSE Committee Meeting will be monthly held throughout the construction and commissioning.

The agenda for the meeting will be structured around the following guidelines:
 Minutes of the last meeting.
 Matters arising timely.
 Incidents and near misses.
 Feedback on incidents.
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 Publicity/promotion/initiatives.
 Monthly look ahead of construction activities.
 Anticipated concerns.
 Interface between Subcontractor.
 Feedback from site personnel.

The minutes of meeting will be prepared by the Contractor HSE staff, and distributed to relevant
personnel of the CA, Contractor and all Subcontractor, and by so doing, communicating HSE issues and
requirements to the workforce will be achieved.

The major objectives of the HSE Committee Meeting are to:


 Ensure that the HSE training programs are implemented and properly carried out to promote
employees’ HSE consciousness and knowledge,
 Enhance and maintain housekeeping and waste disposal to the highest standard.
 Distribute any information and instructions from CA and/or the authorities concerned.
 Debate and confirm Monthly HSE Objectives and Targets proposed by the Contractor Project
Manager.
 Recommend groups and individuals for HSE incentive awards in accordance with the HSE
incentive award scheme.
 Announce Forthcoming changes in the type of work as the Project progress.

19.2. Weekly HSE Coordination Meeting


Contractor and Subcontractor will hold weekly HSE Coordination Meeting.
Participants in this meeting will be:
 HSE Officers and Supervisors
 Subcontractor’s HSE Manager

The purpose of this meeting is to review and coordinate the site activities planned, with the Contractor
and Subcontractor, to discuss general HSE matters, to review and assess HSE inspections outputs, to
discuss the lessons learn from site incident reports and measures take or to be taken to prevent the
recurrence.

HSE requirements and information will be reinforced and reviewed with Subcontractor in this meeting.
The major objectives of the meeting are to:
 Use findings of HSE scoring.
 Discuss HSE topics and any problems observed or anticipated.
 Have each Subcontractor report on the status and performance of HSE activities including HSE
training.
 Report on recent incidents and near misses, and on follow-up actions.

19.3. Weekly Discipline Contractor/Subcontractor Meeting


Each construction area will hold a weekly discipline HSE meeting [more often if required] attended by
all relevant Subcontractor Management and the Contractor supervisor, and chaired by the Contractor
Area Construction Managers responsible for the area.

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Its objectives will include review of recent HSE performance, review of forthcoming key work activities,
recent initiatives, Contractor interfaces, etc.

19.4. Daily Toolbox Meeting


Daily ‘Toolbox Meeting’ will be given at start of each shift, and again just prior to non-routine activities.

HSE Officer will conduct these in a language understood by all members of the workforce and will
address the application of safety rules and procedures to the hazards of current work. Two-way
discussion will be encouraged.

Duration of the team talk will typically be 5 minutes, but particularly hazardous operations may require
extended team talks, for example, confined space entry.

Two-way communication will be encouraged [An interpreter must be present if needed.].

All work crews including supervisors, foremen and workers, will actively participate. Managers will attend
as frequently as possible.

As a continuation of daily talks prior to starting work, Area Supervisor’s [Commissioning Engineer’s]
must hold daily commissioning team talks in order to explain details of Commissioning work to be
carried out in that area and ensure the workforce understands all safety related matters concerning the
work.

A record of the date, the ongoing work, the toolbox topic and attendance will be kept.
The Contractor line management will monitor the meetings on a weekly basis to check their
effectiveness.

Mainly, the working plan and procedures for the day are explained and confirmed including the
following:
 Briefing on topics of HSE meetings, CA’s information, etc.
 Current HSE issues and concerns.
 Anticipated potential hazards and suitable countermeasures.
 Safety instructions for equipment and tools to be used.

Confirmation whether any Work Permits required for the work have been obtained.
 Use of proper personal protective equipment [PPE] and safety devices.
 Information on other work to be conducted in the vicinity of the working area.
 Visual check of the health condition and proper allocation of workers.

19.5. Special Meetings


Additional meetings may be called to address special circumstances, e.g.:
 Work involving novel construction or commissioning techniques.
 Work requiring special instructions and precautions.
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 Visits by HSE or local regulatory authorities.


 Poor performance by specific Subcontractor.
 Feedback of audit findings.
 Reporting the impact on health, safety and environment of any design work concurrent with the
construction phase [i.e. Identifying potential hazards, which were unknown at the contract award
stage.]
 CA interface co-ordination.
 Subcontractor interface co-ordination.

20. EMERGENCY EVACUATION PROCEDURE


All site personnel will be advised of the actions to be followed in the event of fire, gas/toxic release or any
other emergency situation.

Such advice will be given at site inductions and subsequent ongoing safety training sessions.
The procedure will be included in the HSE booklet issued to all employees and will also be published on
notice boards, strategically placed around the site.

Emergency telephone numbers will be listed. A basic map will be provided which shows evacuation routes
and assembly points.

Exercises in each facility shall be conducted at least every quarterly basis [to be discussed with Company to
increase frequency at site] and the observation shall be recorded. The report should be forwarded to the
HSSE Department and any remedial actions required shall be identified.

21. FIRE PREVENTION AND PROTECTION


Whilst the risk of major fire damage in construction, pre-commissioning and start-up areas is considered by
the Contractor to be reasonably minor, [with key risks presented by compressed gas cylinders, painting and
insulation materials and general debris and rubbish], the risk in the camp and office areas is considered to
be high.

In order to prevent such hazards materializing, the Contractor will implement a Project-wide fire
prevention/protection strategy that is characterized by the following general principles:

 Minimal bulk storage on site of flammable substances in appropriate containers


 Isolation of flammables from sources of ignition
 Training in fire prevention and suppression techniques
 Integrity of electrical equipment
 Permit to work control
 Containment of sparks and flames from Hot Works
 Escape route planning
 Restricted smoking areas.

The employment and maintenance of fire extinguishers at strategic locations throughout the.

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Prior to start of Startup, all operational fire protection equipment must be in place.

The fire prevention/protection strategy will include all worksite offices, warehouses, camp, etc., and will be
developed to include commissioning activities.

22. HSE AWARENESS


22.1. HSE Incentive Scheme
The purpose of HSE incentive scheme is one kind of motivation technique for workers at site to promote
individual safety performance, increasing the production and reduce injuries which will be done by
providing individuals with a certain type of awards for good performance.

22.2. HSE Awareness Program


Safety and training materials such as booklets, posters, visual aids, etc. will be suggested by Contractor.
Each subcontractor will be expected to arrange for appropriate materials and should utilize the materials
suggested. Posters of all sizes must be displayed in the appropriate languages at locations throughout
the site.

Site HSE Manager shall maintain the HSE scoreboard and display it at the key location of the project site
facilities. Information of the HSE scoreboard shall be updated on daily basis

Also Site HSE Manager shall arrange to issue HSE flyer for providing details of the site accidents/injuries,
summarizing details and comments to avoid re-occurrence on the project site.

Warning signs will be displayed throughout the site, wherever any hazard warrants their use. Bulletin
boards will be used to advantage in displaying safety posters.

23. MANAGEMENT OF WASTE MATERIALS


The objectives of waste management activities are to:
 Ensure safe and proper segregation, handling, storage, transport and disposal of waste.
 Identify environmental aspects and impacts
 Reduce/minimize the volume of waste or utilize as much as possible for recycle or reuse.
 Reduce/minimize the impact of dust, noise, light, odors, working hours and general disruption on the
local community
 Assess any relevant task to ensure adequate controls are in place to minimize the impact of hazardous
substances on individuals and to protect the environment
 Reduce/minimize the environmental impact of chemicals through correct selection, transportation,
storage, deployment and disposal
 Manage all waste according to the following hierarchy: eliminate where possible, reduce at source,
re-use, recycle and dispose. Disposal shall be in accordance with ‘duty of care’ principles and disposal
records shall be maintained by Contractor and available for audit by CA
 Reduce/minimize any air emission and discharges to water.
All waste management activities will comply with the applicable laws and regulations and the CA’s
requirements.

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23.1. Non-hazardous Waste


Subcontractor are responsible for collection, segregation, recording, transport and disposal of waste to
the location, designated by the CA, where located out of the Contractor asset/boundaries.

23.2. Hazardous Waste


Hazardous substances will be handled, transported and stored at the Contractor designated storage on
site properly.

23.3. Sewage Disposal


The Contractor and Subcontractor will ensure that all sewage from offices, site and camp is treated
properly and follow the local laws and regulations strictly.

The sewage system will consist of sewage underground piping, manholes, lift station pit with pumps,
biological sewage treatment plant and treated effluent underground piping to facilitate sewage
management a bioreactor will be installed for the construction period.

23.4. Worksite Waste


All waste material will be identified and segregated.

Each Subcontractor will be responsible for the provision of such facilities to segregate waste.

An adequate number of skips and bins will be located at key positions on the worksite by Subcontractor
based on their workload.

These items to be disposed of will be clearly identified according to the classification of waste, which
they will generate. Subcontractor will be directly responsible for proper storage of waste in these
containers.

Domestic waste from the temporary facilities etc. on the worksite will be handled in exactly the same
manner as at the Labor Camp.

Hazardous waste will be stored in a closed secure container, clearly marked, with Material Safety Data
sheet, as hazardous material and transported to the Contractor designated on-site storage.

All concrete debris and/or unused concrete will be deposited to an area being located out of the site
designated by the CA.

23.5. Housekeeping
All areas must be kept free from debris and waste material on an ongoing basis. At the end of each
working day a check will be carried out by Subcontractor Task Supervisors to make sure that all waste
material has been gathered and deposed of in the allocated area.

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All empty containers of hazardous material must be removed from the work area as soon as is
reasonably practicable. All empty gas bottles must be returned to their storage area and stored in the
proper manner.

All spillages must be cleaned immediately in accordance with the product manufacturers
recommendations and reported to the Site HSE Manager.

A spillage is an environmental incident and will be reported in the Project Incident Data Base. An incident
report and investigation report will be generated. The Contractor will keep an overview of spillages on
an O/A Plot Plan. All cleaning materials due to solvent content etc. will be treated as hazardous waste
and disposed of as such.

Food consumption will not be permitted on the construction site.

23.6. Waste Collection and Disposal


The Waste Management Plan will be an integral part of each subcontract and will be the responsibility
of Subcontractor.

This will ensure that good housekeeping is practiced and also that collection, segregation, storage and
disposal of waste is properly controlled to minimize the environmental impact of the Project.
Regular waste collections will be undertaken by a specified Subcontractor, who will be approved by the
relevant Authority to carry and dispose of the various types of waste generated.

The waste management co-coordinator of each Subcontractor will prepare a monthly report detailing
the types and quantities of waste removed from site and/or stored on-site during that period.

The Contractor Waste Management Controller will monitor all collection points to ensure that there is
no over-spill or backlog of waste removal. In addition, they will spot check the waste control against its
description on the Manifest before it leaves the site by the appointed transporter.

Disposal by burning will be prohibited without prior permission of the Contractor/CA.

All copies of permits must be retained by the waste disposal coordinator and must be produced on
demand by any authorized authority.

24. IMPLEMENTATION AND MONITORING


24.1. HSE Performance[General]
The Project HSE-MS shall be assessed and evaluated through
 Site Safety Team monthly meetings
 Site safety committee regular meetings
 Verification and review of Project level documentation by Project HSE Manager, or discipline and
personnel nominated by him, prior to issuing the documents to CA for their review.
 CA audits

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24.2. Lessons Learned


SKC shall ensure that lessons learned through the HSE monthly reports, audits and inspections are
incorporated in the HSE-MS and the related documentations are published and explained to the project
personnel and the workforce.

24.3. Safety Performance and Reporting


The Contractor will report to the CA Representative the HSE status of the Work via the monthly report.
The detail level of monthly HSE reporting shall be agreed between the CA Representative and the
Contractor Representative before commencement of any part of the Work.

The Contractor will notify the CA Representative both orally and in writing immediately after discovering,
or receiving a report relating to, any of the following events that may occur:

 The death of any Personnel whilst performing any part of the Work;
 The injury of any Personnel whilst performing any part of the Work where a recordable incident
has occurred;
 Any high potential near miss or accident which has the potential for serious injury or serious
damage to equipment;
 Any release, spill or discharge of a hazardous material associated with the Contractor’s
performance of the Work, which either results in or has potential for significant injury or
environmental damage;
 Any proceedings being commenced or threatened, alleging any failure by the Contractor or any
of its Sub-Contractors to comply with any HSE requirements, irrespective of whether or not it is
associated with the Contractor’s performance of the Contract;

24.4. Documentation
The following reports, information and documentation shall be maintained and timely submitted to CA
for each requirement:
 Daily/Weekly HSE Report.
 Safety Training Records including a List of Recipients.
 Safety Patrol Report.
 Reports of Corrective Actions taken as instructed by SKC.
 Equipment Inspection and Maintenance Records.
 Accident/Incident/Near-miss Report.
 Equipment/Property Damage Report.
 Material Safety Data Sheets [MSDS].
 Work Permit Record.
 Housekeeping and Waste Disposal Records
 Monthly Safety Report
 Driver performance reports
 Action tracking register [ART] summary

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24.5. Incident Investigation and Reporting


Serious incidents and injuries will be immediately reported to the Site Manager and to CA HSE
representative. All incidents in common areas will be reported to CA as per CA Incident Reporting and
Incident Procedure.

All incidents will be investigated by SKC and in the event of a serious accident; SKC and CA will establish
a Committee of Inquiry.

The cause or the chain of events that led to an incident will be determined. Investigations will be
conducted without prejudice and will focus on finding the facts, not faults or placing blame.

The Site HSE Manager will set up an incident reporting and investigation procedure and ensure that
corrective actions to prevent recurrence of accidents are implemented.

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Copyright ©
The copyright of this procedure, together with all confidential information contained herein is the sole property of SKC
Engineers & Contractors Pvt Ltd.

It may be copied in full or in parts only by the Management / personnel and only for the purpose of Company related
activities. Disclosure of any information contained within this procedure to any person [s] outside the employee of company
without written permission of the Chief Executive, Head of Department or the ISO Coordinator is strictly prohibited.

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