PROCEDIMENTO OPERACIONAL

Subcontractors Conditions
Revisão 08

PO_QSA_01_EN
Cópia Não Controlada

1- Objective

To promote safety and environmental conditions, in which LUSOSIDER - AÇOS PLANOS, S.A.
subcontractors develop their activities.

2- Scope

2.1 This regulation fully applies to all subcontractors working at LUSOSIDER, as well as their
own subcontractors, suppliers and employees.

2.2 The subcontractor is responsible for complying with this regulation, and assuring it’s
compliance by its own subcontractors, suppliers and employees.

2.3 LUSOSIDER reserves the right to modify or supplement this regulation at any time, and the
amendments are applicable after written notice to the subcontractor.

3- Responsibilities

The LUSOSIDER nominated responsible for each subcontractor is the ultimate responsible for
the compliance with this procedure.

The Procurement department is responsible for communicating this procedure to subcontractors,

requesting all the necessary documents and forwarding them to the Quality, Safety and
Environment department (QSA), for analysis.

The QSA department is responsible for checking the compliance with this procedure.

4- References

Not applicable.

5- Procedure:

5.1- Legal and Other Requirements

In the case of a contract subject to legal and other requirements, the Procurement
department shall request for compliance evidence.

5.2- Safety and Environmental documentation folder

Before starting any subcontractor’s service at LUSOSIDER's facilities, a folder with

relevant documentation must be delivered, using the document management
platform E-Coordina.

Aprovação:Filipa Martins Data: 17/11/2022 Pág. 1/8

Data de Impressão: 20-12-22
 PROCEDIMENTO OPERACIONAL
Subcontractors Conditions
Revisão 08

PO_QSA_01_EN
Cópia Não Controlada

This folder must contain at least the following information and present this structure:

1. Identification, description and work hours

a. Activity identification
b. Work Schedule (start date, end date, time)
c. Work description, including method

2. Workers identification
a. List of workers
i. name
ii. Identification document number
iii. professional category

3. Hazards and Risks Identification, prevention and protection measures

4. Information and training records

a. Work at height (when applicable)
b. Heavy equipment operation (when applicable)
c. Confined spaces (when applicable)
d. Electric hazards (when applicable)
e. Welding hazards (when applicable)
f. Scaffold assembly (when applicable)

5. Equipment identification
a. Equipment inventory, scaffold included

6. Chemical products and substances

a. Safety data sheets for the chemical products used during the work.

7. Documentation
a. Human Resources:
i. E.U. citizens
1. Workers Identity Card or Passport
2. Model A1
ii. Particular conditions of work accident insurance policy
iii. Work accident insurance payment receipt
iv. Particular conditions of liability insurance policy
v. Liability insurance payment receipt
vi. Copy of the medical fitness record for the workers
vii. Delivery receipt of the PPE (Personal Protective Equipment) required
for the job
viii. Training certificate for heavy equipment operation

b. Heavy equipment:
i. Equipment identification
ii. Equipment insurance
iii. Annual license
iv. CE Certificate (for equipment post 1995)

Aprovação:Filipa Martins Data: 17/11/2022 Pág. 2/8

Data de Impressão: 20-12-22
 PROCEDIMENTO OPERACIONAL
Subcontractors Conditions
Revisão 08

PO_QSA_01_EN
Cópia Não Controlada
v. Periodic inspection report or Tests, according to the DL 50/2005
(Directive 89/391/EEC (89/655/EEC))
vi. Record of last maintenance

c. Environment:
Documents related to legal compliance and others related to Environmental
Aspects and Impacts of the subcontractor’s activity, if identified by him.

LUSOSIDER collects and processes the subcontractor’s workers personal data, in

compliance with current legislation regarding the Promotion of Safety and Health at Work.

The collection and processing of the requested personal data, aims to comply with
LUSOSIDER’s legal obligations, mainly its duty to ensure the safety and health of all
workers, in simultaneous or successive activities in the same workplace, as the responsible
entity.

LUSOSIDER will make every effort to ensure that the mentioned personal data collection
and processing activities are carried out in strict compliance and respect for the personal
data protection legislation.

The presentation of related documentation to the work to be carried out at LUSOSIDER's

facilities must be presented exclusively through the e-coordina document management
platform, and any documentation sent by any other means (eg email) is not
considered valid.

When the works are awarded, the supplier will receive an email informing of the opening of
the document request on the e-coordina platform, and the submission of documents for
validation must then begin. All necessary documentation must be uploaded and validated
the latest 24 hours before the start of work.

On the first day of work, all workers will have an information/awareness training action on
safety and the environment at LUSOSIDER and rules to be respected. The record of this
action (QSA Reception) will be uploaded later in the associated document file, by the QSA
department.

5.3- ELETROMAGNETIC FIELDS

LUSOSIDER assessed the existing electromagnetic fields, in accordance with current

legislation, acknowledging that some equipment presents a value above the limit for
particularly exposed workers, namely those who use active or passive medical implants, as
well as pregnant, postpartum or lactating women.

The places where these equipments are located are duly identified with specific signage.

5.4- PERSONAL PROTECTIVE EQUIPMENT (PPE) TO USE AT THE FACILITIES:

5.4.1- Mandatory personal protective equipment to use inside the facilities

 Safety shoes/boots S3 certified;

 Protective helmet, according EN 397 and/or EN 12492 (work at height);
Aprovação:Filipa Martins Data: 17/11/2022 Pág. 3/8
Data de Impressão: 20-12-22
 PROCEDIMENTO OPERACIONAL
Subcontractors Conditions
Revisão 08

PO_QSA_01_EN
Cópia Não Controlada
 Hearing protectors with minimum attenuation of 26 dB (SNR) (in the marked places);
 Safety glasses or goggles
 Anti-impact goggles or panoramic goggles against liquid chemicals;
 Reflective vest or similar.

5.4.2- Occasional personal protective equipment to use inside the facilities

 Safety gloves;
 Fall protection equipment (safety harness; ropes, etc.);
 other equipment to be defined according to the work to be carried out.

5.5- ENVIRONMENTAL RULES:

 Full compliance of other environmental legal requirements, disclosed by the Procurement

department;

 Burning waste is prohibited;

 It is prohibited to abandon waste, as well as its emission, transport, storage, treatment,

recovery or disposal by entities or in facilities not licensed to carry out waste management
operations;

 Injection of waste into the soil is prohibited

 The waste produced in the activity must be properly separated and placed in the
appropriate containers available at LUSOSIDER, intended for its recovery or disposal. If
applicable, e-GARs must be issued. The contract is only completed after the waste
sorting has been carried out;

 It is prohibited any type of effluent in the rainwater drainage network or other networks,
without proper authorization;

 The use of water and production of wastewater in our facilities is subject to prior
communication and approval by the QSA department;

 The use of hazardous substances or mixtures, as well as their storage in our facilities,
even if temporary, must include means to contain spillage (eg: containment basin);
 The performance of any noisy activity during the night period must be previously
authorized by the QSA department;

 The use of electrical equipment must be done rationally and is subject to prior
communication and approval by the QSA department;

 Compliance with the mentioned and applicable Environmental Rules, regarding de

contract and in accordance with additional legal requirements disclosed by the
procurement department. Possibility of clarification with the Environmental Responsible;

 In any service that implies risk of accidents with environmental impacts (fire, explosion or
spills), immediate prevention and action actions must be taken in the event of an
Aprovação:Filipa Martins Data: 17/11/2022 Pág. 4/8
Data de Impressão: 20-12-22
 PROCEDIMENTO OPERACIONAL
Subcontractors Conditions
Revisão 08

PO_QSA_01_EN
Cópia Não Controlada
accident, using the subcontractor’s own means and if this is not enough, using
LUSOSIDER’s available means;

 Compliance with the Environment rules, communicated at the welcoming training;

 Compliance with the Environmental rules posted at the facilities.

5.6- GENERAL RULES:

 The entry and exit of people is made through Portaria 2, not being allowed entries and
exits to any other location;

 Employees of contracted companies cannot be in places that are not related to the work
they perform;

 O subcontratado obriga-se a identificar o pessoal ao seu serviço nas instalações da

LUSOSIDER através de:

 The subcontractor undertakes to identify its employees at LUSOSIDER's facilities,

through:
o Visible identification card, or;
o Label with the company name on the front of the helmet or;
o Suitable high-visibility work uniform, with the company identification;

 Access to the facilities is authorized by the person responsible for the service;

 If there is a need for vehicles to enter the facilities, it must be sent their registration plates
in advance and they must be parked in the defined places;

 Subcontractor’s vehicles are subject to control of materials and products transported at

the entrance and exit. This control will be carried out on the basis of delivery notes or bills
of landing;

 The speed limit within the facility is 40 km/h for cars, 30 km/h for trucks, 10 km/h for
machinery

 Smoking is prohibited inside industrial plant;

 The consumption of alcoholic beverages inside the facilities is prohibited;

 The BAC (Blood alcohol content) limit is 0.20 g/L, except for annual preventive
maintenance shutdown, where the limit is 0.00g/L. The subcontractor’s employees with
higher values must immediately leave LUSOSIDER facilities and will be conditioned their
future entry into LUSOSIDER's facilities;

 It is not allowed to photograph or film without authorization;

Aprovação:Filipa Martins Data: 17/11/2022 Pág. 5/8

Data de Impressão: 20-12-22
 PROCEDIMENTO OPERACIONAL
Subcontractors Conditions
Revisão 08

PO_QSA_01_EN
Cópia Não Controlada
 The movement of people within the facilities shall always be made in accordance with the
safety rules defined in each site, and the proper circulation paths such as walkways and
stairs must be used;

 All access interdiction signs must be strictly observed;

 The contractor must inform the LUSOSIDER’s contract Responsible or the Safety
Technician of any hazardous substance or preparation that he introduces into the
facilities and must provide the respective MSDS;

 The Subcontractor will immediately communicate to the LUSOSIDER’s contract

Responsible or the Safety Responsible any incidents and/or accidents involving its
workers or other entities subcontracted by him, during the course of work at our facilities.
This communication does not exempt the Subcontractor from the participation, which,
under the terms of the law, it has to make to the competent authorities;

 The working area and other places/facilities used must be left in adequate conditions of
cleaning and storage and without any traces of waste;

 LUSOSIDER will perform Environmental and Safety audits to Subcontractor’s work, with
the purpose of verifying that the Environmental and Safety procedures are being
complied with, reserving entitled to immediately stop work.

5.7- WORKING AREA

5.7.1 “Working area” means the area that, under the terms authorized by LUSOSIDER, is
considered to be affected by the execution of the work carried out by the Subcontractor
and that is occupied by the subcontractor in facilities, accesses, materials, equipment,
machines and vehicles owned or used by him and/or owned or used by its
subcontractors, suppliers and other employees.

5.7.2 The subcontractor must submit the shipyard project he intends to build for prior
authorization by LUSOSIDER. The project should include details on deployment,
facilities and buildings, machinery and equipment, electricity and fuels, health and
safety, waste sorting containers and other necessary for its complete characterization.

5.7.3 The Subcontractor's shipyard facilities must be built in accordance with the regulations
relating to work facilities and legal requirements for health and safety at work. The
authorization referred to in 5.7.2. in no way diminishes the Subcontractor's legal
obligations and responsibilities. The shipyard must be easy to dismantle.

5.7.4 If, for health and safety reasons, LUSODER requires the modification of the
construction site, the resulting costs will be borne by the Subcontractor.
Decommissioning costs of the yard at the end of the period of existence set in the
authorization referred to in 5.7.2. will also be on the behalf of the Subcontractor.

Aprovação:Filipa Martins Data: 17/11/2022 Pág. 6/8

Data de Impressão: 20-12-22
 PROCEDIMENTO OPERACIONAL
Subcontractors Conditions
Revisão 08

PO_QSA_01_EN
Cópia Não Controlada
5.7.5 The Subcontractor is responsible for the safety of people and goods in his site. The
Subcontractor may, if he wishes, ensure the site surveillance, in coordination with
LUSOSIDER’s services and instructions.

5.7.6 Salvo autorização expressa da LUSOSIDER, o subcontratado obriga-se a utilizar todos

os seus meios instalados em estaleiro exclusivamente para os trabalhos por ela
contratados.

5.7.7 Unless expressly authorized by LUSOSIDER, the Subcontractor undertakes to use all
its equipment exclusively for the contracted works.

5.8- SERVICES PROVISION AT LUSOSIDER’S FACILITIES

5.8.1 Workplace Recognition

 The Subcontractor must have prior knowledge of the locations where the works are to be
carried out and become aware of the safety and environmental aspects relevant to the
work execution. It is considered that the Subcontractor, when preparing the execution of
its work and/or installation, assumed this knowledge and analyzed all the risks and
hazards arising from the surroundings (including industrial facilities, geographic and
climatic conditions, etc.).

 The Subcontractor, in order to exempt himself from his contractual obligations or to

support any claim, may not invoke either the specific constraints of the workplaces
considered to be hazardous, or work stops for safety reasons, in normal operation
conditions.

 The Subcontractor must pay particular attention when carrying out work on installations in
operation or nearby. In these cases, it must establish the precise rules for the operation
and/or consignment of the facilities, with LUSOSIDER.

5.8.2 Regulations, Legislation and Standards

 It is considered that the Subcontractor knows and applies all applicable Safety legal
requirements, and it must provide proof of such compliance whenever required by
LUSOSIDER;

 The Subcontractor undertakes to comply with the prevention and safety laws, and to
ensure that its subcontractors and other employees comply with it, as well as the
regulations and standards in force at LUSOSIDER.

5.8.3 Work Execution

 The Subcontractor undertakes to accept the inspection actions carried out by duly
accredited LUSOSIDER’s personnel and to promptly comply with the indications of
correction and/or modification of the works considered to be incorrectly performed;

 The Subcontractor undertakes not to start any work at LUSOSIDER's facilities without
having received the agreement of the person in charge at LUSOSIDER and, where
applicable, without having been assured of the consignment of the installation and
Aprovação:Filipa Martins Data: 17/11/2022 Pág. 7/8
Data de Impressão: 20-12-22
 PROCEDIMENTO OPERACIONAL
Subcontractors Conditions
Revisão 08

PO_QSA_01_EN
Cópia Não Controlada
equipment in which it will intervene and/or that in any way may interfere with the work
execution;

 The subcontractor must designate, for each team working at LUSOSIDER, an element
that is technically and hierarchically responsible and an element responsible for Safety
and Environment. These elements, which may coincide in the same person, will
represent, for the due purposes, the Subcontractor towards LUSOSIDER and the official
bodies.

5.8.4 Health, Safety and Environment

 The Subcontractor undertakes to authorize, without any consideration for the time spent,
the assistance, by the personnel under its responsibility, to the safety and environmental
awareness sessions (complementary to the Subcontractor’s self-training and awareness)
that are considered necessary by LUSOSIDER;

 It is not permitted to sell, enter or consume alcoholic beverages on LUSSIDER's facilities,

whether for own consumption or external consumption;

 LUSOSIDER reserves the right to control, whenever it deems it necessary, the blood
alcohol content level of workers under the responsibility of the Subcontractor, who
undertakes to accept as valid the results determined in the control;

 The Subcontractor agrees promptly and at his expense to replace any worker under his
responsibility that does not comply with the defined blood alcohol content limit;

 It is up to the Subcontractor, in case of prolonged work, to guarantee the daily cleaning of

the workplace.

Aprovação:Filipa Martins Data: 17/11/2022 Pág. 8/8

Data de Impressão: 20-12-22