CM-SA-001 Procedure for The Implementation of the Environmental, Health and Safety (EH&S) Program

Table of Contents

1. Purpose
2. General
3. Responsibilities
4. Procedure
5. Flowchart
6. References
7. Attachments

1. Purpose

This procedure describes the implementation of the General Environmental, Health & Safety (EH&S) Program in Company operations.

2. General

The General EH&S Program, EH&S policy, the detailed EH&S organization and responsibilities are described in ref. 6.1

3. Responsibilities

3.1 General

The Manager of Safety has prime responsibility for:

• development and monitoring of the documented General EH&S Program;
• ensuring that all the EH&S programs are maintained and implemented;
• reporting to Company’s Management on all matters of importance relating to EH&S;
• issuing of guidelines and directives concerning all matters relating to EH&S;
• keeping abreast of developments in the industry in the field of EH&S;
• auditing of the EH&S performance of the Enterprise Assistance Services and project taskforces when appropriate.

The Manager of Safety is supported in the execution of his tasks by the functional Department Managers.

The functional Department Managers' duties and tasks with regard to EH&S comprise:

• monitoring the implementation of the EH&S Programs;
• the maintenance and updating of applicable EH&S procedures, guides and standards;
• ensuring that EH&S procedures, guides and standards are implemented;
• ensuring that all personnel are made aware of their responsibility towards EH&S;
• ensuring that means and opportunities are provided to personnel for training in safety, first-aid, fire fighting etc.

3.2 Office EH&S Operations

3.2.1 The Chief Enterprise Assistance Services ("Hoofd Bedrijfshulpverlening") is responsible for:

• the maintenance, updating and implementation of procedures in order to safeguard the well being of staff in any Home Office calamity;
• the maintenance of contacts with local authorities with regard to safety, health sanitation and housekeeping.

3.2.2 The Manager Facilities & Services is responsible for:

• the composing, implementation, maintaining and updating of safety, health, sanitation and housekeeping procedures and rules for the Home Office.

3.2.3 The Manager of Human Resources is responsible for:

• the composing, implementation and maintaining of the ARBO Beleidsplan.

3.3 Project EH&S Operations

3.3.1 The Project Manager has the ultimate responsibility for:

• the translation of the Project's EH&S Program into the project.

The Project EH&S Engineer (when assigned to a project) is responsible for:

• establishing a Project H.O. EH&S Plan;
• monitoring and coordi­nating the implementation of the Project H.O. EH&S Plan and maintains an interface with the Manager of Safety.

The Project Construction Manager has the prime responsibility for:

• safety at site;
• establishing a Site EH&S Plan.

The Site Safety Manager is responsible for:

• assisting in the establishment of a Site EH&S Plan and to coordinate and monitor all aspects of EH&S at site and to provide all field management, the construction super­visors and the commissioning engineers with advice and guidance, while maintaining an interface with the Project EH&S Engineer and the Manager of Safety.

All Construction Supervisors are directly responsible for:

• the implementation and execution of the Site EH&S Procedures.

4. Procedure

4.1 The Office EH&S Program

The Office EH&S Program covers:

a. ARBO Beleidsplan (ref. 6.4)

b. Enterprise Assistance Service Program (ref. 6.2)

The Manager of Human Resources shall maintain and coordinate the ARBO Beleidsplan including coordinating all ARBO law requirements.

The Chief Enterprise Assistance Service shall maintain and coordinate Company Enterprise Assistance Service Program.

4.2 The Projects EH&S Program

4.2.1 General

The Projects EH&S Program covers:

a. Engineering EH&S Program (ref. 6.5)

b. Field Construction EH&S Program (ref. 6.3)

The extent of the application of the Projects EH&S Program shall be determined and specified by the Project Manager.

In principle, a Project H.O. EH&S Plan (see 4.2.2) and a Project Site EH&S Plan (see 4.2.3) shall be prepared as separate documents. These documents shall be written into or shall be attachments to the Project Procedure and Execution Manual (PPE Manual), ref. 6.8 and/or a separate Construction Procedure and Execution Manual (CPE Manual).Alternatively, the Project Manager may decide to include the project specific EH&S requirements in the appropriate section(s) of the PPE Manual.

The Project Manager may, dependent on project requirements, assign and delegate responsibilities to a Project EH&S Engineer for all H.O. EH&S related matters and/or a Site Safety Manager for all aspects of EH&S at the construction site.

4.2.2 Project H.O. EH&S Plan

The Project EH&S Engineer, in conjunction with the Project Manager and the Manager of Safety, shall, based on the "Engineering EH&S Program" (see 4.2.1.a) establish a Project H.O. EH&S Plan (ref. 6.10), which may include:

• the contractual split of responsibili­ties between Client/Licensor/Company of all EH&S related aspects of the home office work;
• the statutory and contractual EH&S rules, regulations and standards to be used;
• the type, scope and depth of the EH&S studies to be made;
• a reference to the planned design reviews (ref. 6.6);
• the safety audit plan (ref. 6.7) including:
• audit requirements (type and depth)· audit scope and its objectives
• audit schedule
• audit procedure/questionnaires
• the identification of EH&S requirements in procurement instructions, such as safety in pre-assembly yards, in vendors' workshops etc.

The Project EH&S Engineer furthermore shall monitor the imple­mentation of the Project H.O. EH&S Plan, coordinate the safety review work and maintain the central project EH&S file (ref. 6.9).

4.2.3 Project Site EH&S Plan

The Project Construction Manager in conjunction with the Project Manager, the Site Safety Engineer and the Manager of Safety shall suitably limit, revise or extend the "Field Construction EH&S Program" (see 4.2.1.c) as the Project Site EH&S Plan which comprises the following elements:

• the definition of the contractual responsibilities with regard to EH&S;
• the applicable EH&S regulations;
• the first-aid and local medical facilities and special medical control program;
• the fire-fighting and emergency requirements;
• environmental aspects;
• the safety training (induction, toolbox, etc);
• the procedures for safety inspections;
• the safety equipment and protective clothing requirements.
• the accident reporting and record keeping.

Ref. 6.11 gives a typical outline of such a Project Site EH&S Plan.

The Site Safety Engineer furthermore shall monitor the implementation of the Project Site EH&S Plan and maintain the central project site EH&S file (ref. 6.9).

4.2.4 Approval

The Project H.O. EH&S Plan and the Project Site EH&S Plan shall be reviewed by the appropriate Department Managers and be approved as per ref. 6.8. These documents shall be included or properly referred to in the PPE Manual and/or a separate CPE Manual (ref. 6.8).

The sections on EH&S matters in the PPE (and/or CPE) Manual, written in the absence of a Project H.O. EH&S Plan and/or a Site Safety Plan (see also 4.2.1), shall be approved as for the Project Proce­dure and Execution Manual (ref. 6.8).

5. Flowchart

6. References

7. Attachments

None.