Sample Plan

Gulf Spic Trading & Contracting Company

Doc. No: GS / HSE / Plan / 3745

Dated May ,2008

Project Compliance:

Client: KOC

Project: Installation of Gravity Drain system in GC’s 17,

27 & 28

Rev. No: 1

Page - 1

Safety First. Work Safely. ZERO Accident, No Damage to Property & Environment, No spill our TARGET.

PROJECT SAFETY PLAN

1

H (HSE)

H (HSE)

GM (P)

For Project Management KRISHNAN

Project Manager

Rev

Date

Written by

S.K.Moorthy

Checked by

S.K.Moorthy

Approved by

B.Valavan

Status

Document Revisions



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TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 SAFETY POLICY

1.2 SCOPE

1.3 OBJECTIVE

2.0 HSE ORGANISATION

2.1 ROLES AND RESPONSIBILITY OF HSE

3.0 CODES AND STANDARD

3.1 DISCIPLINARY PROCEDURE / SAFETY VIOLATION NOTICE

4.0 SAFETY MEETING/ TRAINING/ AWARENESS

4.1 WEEKLY MEETING

4.2 MONTHLY MEETING

4.3 SAFFTY TRAINING

4.4 SAFETY AWARENESS & PROMOTIONAL ACTIVITIES



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5.0 INSPECTION AND SURVEYS

5.1 PERSONAL PROTECTIVE EQUIPMENT

5.2 WORK PERMIT

5.3 EXCAVATION AND TRENCHING

5.4 BARRICADING AND SIGNS

5.5 FLAMMABLE LIQUIDS

5.6 CRANE LIFTING

5.7 ELECTRICAL EQUIPMENT

5.8 HOUSE KEEPING .

5.9 SAFETY AUDIT AND INSPECTION

5.9.1 HAZARD AND GENERAL RISK ASSESSMENTS

5.9.2 MEDICAL, HEALTH AND HYGIENE EVALUATION

6.0 INVESTIGATION, REPORTS, DATA AND DOCUMENTATION

6.1 WEEKLY REPORTS

6.2 MONTHLY REPORTS-

6.3 FIRST AID

6.4 ACCIDENT/ INCIDENT AND NEAR MISS INVESTIGATION REPORTING

6.5 ACCIDENTS/INCIDENTS TRENDS AND STATISTICS



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6.6 RECORD AND DOCUMENTATION

7.0 ACCIDENT AND INCIDENT MANAGEMENT

8.0 PERMIT TO WORK SYSTEM

8.1 WORK SITE ACCESS

8.2 PERONAL PROTECTIVE EQUIPMENTS

8.3 SCAFFOLDING WORKS

8.4 LIFTING PLAN/ MECHANICAL ERECTION-

8.5 WORKING IN CONFINED SPACE

9.0 AREA CLASSIFICATION

10.0 RADIOGRAPHY

11.0 SAFE STORAGE AND HANDLING

12.0 TRANSPORTATION, VEHICLE SAFETY AND MATERIAL HANDLING

12.1. LIFTING AND SHIFTING EQUIPMENTS

13.0 ELECTRICAL SAFETY

14.0 CONSTRUCTION SAFETY

14.1 SCAFFOLDING ERECTION



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14.2 WELDING, CUTTING AND GRINDING

14.3 RIGGING PLAN

14.4 EXCAVATION AND TRENCHIG W0RKS

14.5 GRID BLASTING & PAINTING WORKS

14.6 HAND TOOLS AND CONSTRUCTION EQUIPMENTS

14.7 SAFETY IN RADIOGRAPHY

14.8 DEMOLITION UNDER & ABOVE GROUND PIPING & TIE IN

15.0 GENERAL SAFFTY

15.1 ELECTRICAL POWER TOOLS

15.2 PERSONNEL PROTECTIVE EQUIPMENT

15.3 FIRE AND GAS PROTECTION

15.4 SMOKING

15.5 SAFETY IN NOISE POLLUTION

15.6 OFFICE SAFETY

15.7 HOUSE KEEPING

16.0 EMERGENCY EVACUATION PROCEDURES

17.0 SECURITY

18.0 ATTACHMENTS ( FORMS & KOC JSA)



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19.0 ENVIRONMENT MANAGEMENT PLAN

TABLE OF CONTENT

19.1 PURPOSE

19.2 SCOPE

19.3 REFERENCE

19.4 DEFINITIONS

19.5 TYPE WASTE

19.6 PROCEDURE FOR SOLIDE WASTE MANAGEMENT

19.6.1 WASTE SEGREGATION

19.6.2 WASTE PROFILE SHEET

19.6.3 WASTE TRACTING

19.6.4 TRANSPORTATION,TREAMENT AND DISPOSAL

19.6.5 RECORDS

20.0 RESPONSIBILITIES

20.1 WASTE GENERATING DEPARTMENT

20.2 WASTE HANDLING DEPARTMENT



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20.3 PROCESS ENGG. DIVISION-REFINERY

20.4 SAFETY AND FIRE DIVISION-REFINERY

20.5 ENVIRONMENT DIVITION - REFINERY

20.6 LABORATORY

21.0 ENVIONMENTAL COMPLIANCE

22.0 ENVIRONMENTAL RESOURCE DUE DILIGENECE

23.0 ENVIRONMENT RISK ASSESSMENT

24.0 ENVIRONMENT ROLE & RESPONSIBILITIES

24.1 PROJECT MANAGER

24.2 SITE SAFETY SUPERVISOR

24.3 EMPLOYEE

24.4 ENVIRONMENTAL DESIGN & OPERABILITY

24.5 PROCURMENT AND CONTRACT MANAGEMENT

25.0 ENVIRONMENTAL DOCUMENTATION & COMMUNICATION

25.1 ENVIRONMENTAL TRAINING

25.2 ENVIRONMENTAL INSPECTION, ASSESSMENT AND AUDITS



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25.3 ENVIRONMENTAL PERFORMANCE REPORTING

26.0 ENVIRONMENTAL EMISION CONTROL AND NOISE MITIGATION

26.1 EMISION TO ATMOSPHERE

26.2 NOISE MITIGATION

27.0 ENVIRONMENT INCIDENT PREVENTION & RESPONSE

27.1 OIL SPILL CONTROL

27.2 REFUELING OF VEHICLE

27.3 HYDRO TEST

27.4 DUST CONTROL

28.0 WASTE MANAGEMENT

29.0 WATER MANAGEMENT

30.0 START UP AND COMMISSIONIING

31.0 RESTORATION AND CLOSE OUT

32.0 ATTACHMENTS

1. EIA COMPLIANCE CHECKLIST

2. ENVIRONMENTAL PERFORMANCE REPORT

3. ENVIRONMENTAL RISK ASSESSMENT



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4. EH&S HAZARD RISK REGISTER

5. ENVIRONMENTAL AUDIT CHECKLIST

6. HAZARDOUS WASTE MANAGEMENT FLOWCHART

7. NON HAZARDOUS WASTE MANAGEMENT FLOWCHART

8. KOC WASTE PROFILE SHEET

9. WASTE TRANSPORTATION MANIFEST

10. WASTE MANIFEST

11. SOLID WASTE RECIPTION STATION

12. SOLID WASTE TRANSPORTED



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Manpower is one of the greatest assets in the successful completion of our project. They have to perform efficiently but nevertheless, safety in performance is our major concern.

This safety manual has been compiled to make all employees to familiarize themselves with this documents and directives relating to safe practices and emergency procedures.

"ACCIDENTS DONT JUST HAPPEN. THEY ARE CAUSED BY SOME ONE OR

SOMETHING WORKING UNSAFELY Y OR PROTECTED UNSAFELY".

Similarly, safety improvement will not just happen. It happens by the deliberate and conscious effort of each arid every employee. Each employee and sub-contractor is therefore expected to set good example & co-operate whole-heartedly in the promotion of safety & prevention of accidents. They should be personally responsible to create & maintain safe working conditions & practices so as to avoid accidents to themselves & fellow workers.

This manual cannot cover all cautions; therefore make it a habit to avoid unsafe acts & unsafe conditions, which will lead to any possible accidents.

.

Every grade of officer shall do his utmost to impart safety awareness. It is-therefore individuals responsibility, extra assignment and business to enhance safety to achieve " Zero Accident".

1.0 INTRODUCTION



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1.1. SAFETY POLICY:

Gulf Spic HSE policy

Gulf Spic will endeavor by its entire means:

• A visible management to demonstrate commitment to EHS while doing its business.

• A sound health and safety of Individuals employed in the company or others associated with its business by continuous risk assessment and elimination from worksite.

• Protect environment from damage & prevent pollution while carrying out its activities during

the operation.

• Believe that all accidents are preventable.

01.08.2007

General

Manager

(Projects)



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1.1. 1 SAFETY VISION:



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1.1. 1 SAFETY STRATEGY:



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1.2 SCOPE

This document is prepared for implementation of safety in construction works for Gravity Drain System Project for job at GC’s 17, 27 and 28 executed by GULF SPIC.

1.3. OBJECTIVE

> To provide Safely Health Environment System to be followed in the project.

> To know the safety procedures to be adopted in the Construction & Execution.

2.0 HSE ORGANISATION AND RESPONSIBILITIES

The following project organization is implemented regarding HSE Management

Project Manager

Construction Team Safety Officer

Engineer

Supervisors



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2.1. ROLES & RESPONSIBILITIES OF HSE PERSONNEL

The roles and responsibilities of key staff with regards to HSE Management are identified below:

> Responsible for ensuring that the overall Project is executed fully in accordance with applicable

HSE requirements. Specific requirements include:

> Ensuring that adequate resources are assigned to all phases of the project to enable HSE

objectives to be met.

> Ensuring that safety standards of the Client are met in full accordance at all times.

> Ensuring that the project activities are carried out as per the Client's safety requirements.

> Ensuing that the Project HSE Policy, Plants and procedures are established and implemented

> Reporting any incidents to corporate management and to Client/Owner

> Fire Prevention and fire-fighting-in-construction and commissioning operations

> Health and hygiene of the employees

> Environment

> Housekeeping

> Implementation and enforcement of the Site Safety Program at site.

RESPONSIBILITY OF SAFETY OFFICER

The authorities and responsibilities of Safety Officer consist substantially in assisting the management in implementation procedure and coordinating all activities, which provide an effective and usable body of safety procedure and to highlight the safety promotions.



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Shall instruct and brief all personnel's and sub-contractors for safety procedures rules and regulations to be adapted at the sites.

Perform a continuous check to ensure that activities organized by engineers, sub

contractors in accordance with the safety procedures, rules and regulations perform

supervisors.

Review with the Site Managers / Engineers / Supervisors the details of major erection works (lifting of major equipment / work in hazardous area) to ensure that all precautions are considered to maintain safety. Monitor all infringements relating to safety procedures, rules and regulations and inform engineers and supervisors to rectify the unsafe act. /dangerous occurrences and update all safety statistical data.

Perform a continuous check to ensure that proper housekeeping is maintained in all working

area./sites.

Inspect scaffold and scaffold register as required by the factories act. Ensure that

all safety rules and regulations are complied with.

To prepare reports and statistics of accident to determine the safety situation in the site.

SITE SAFETY SUPERVISOR

> Stopping all unsafe acts/dangerous Occurrences of his workers and reporting to the Site Manager/Engineers.

> Ensuring that his workers know and follow company's Safety rules and regulations.

> Maintaining and. inspecting Safety installations, Safety equipments, dangerous signs etc., to

ensure that they are in serviceable and safe conditions.

> Carrying out instructions on Safety as required by the Safety Committee.

> Arranging / display of Safety Sign Boards and /or demarcation signs work Areas etc.

> Maintaining good housekeeping in warehouse yard and worksites.



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> Investigating and reporting all the Industrial Accidents / Dangerous occurrences to the

Site Manager / Engineers and to the Safety Committee.

> Conducting Tool Box Meeting daily. Giving

> Job Safety instructions to his workers.

> To liaise with the Factory Inspectorate, Workmen's compensation department, Insurance firm and the company's lawyer in matters relating to Safety.

> To comply with all company's Safety rules and regulations.

> To protect himself and his colleagues from bodily injuries.

> To report all unsafe acts and conditions to their superiors immediately.

> To seek appropriate First- Aid treatment for all injuries.

> To report all injuries to their irnmediate Supervisor /Safety Supervisor.

> To report immediately when an unusual situation develops which may appear dangerous to them.

> To contact the immediate supervisor when they do not know how to handle a job.

> When they do not understand any instructions given verbally or in writing.

> To utilize all personal protective equipments provided for their safety use.

> To maintain good housekeeping in their work areas and Job Sites.

Each subcontractor is responsible for the preparation and implementation of HSE plan

and procedures for its areas of operations. These will be in accordance with GS

Project HSE Plan, Procedures and Instructions. Each Subcontractor will have staff

WORKER:

SUBCONTRACTORS:



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and resources to ensure adherence to the HSE plan and procedures and will work with

GS to this end, on a day to day basis. All subcontractors will designate a safety

professional to co-ordinate and enforce the HSE program and to support line

management's implementation of the program.

3. CODES AND STANDRADS

Gulf Spic objective is to implement a Zero Lost Time Injury Case Program. GS subcontractor HSE Program complies with the provision of :

> Kuwait and international laws and regulations,

> Client reference documents

> KOC Fire and Safety Regulations / Traffic Safety Regulations

> GS Safety Manual/Handbook

GS shall ensure that regulatory requirements are complied with and that no activities under our responsibility is undertaken without the required official authorization being obtained

3.1. DISCIPLINARY PROCEDURE /SAFETY VIOLATION NOTICE:

> GULF SPIC operates a zero-tolerance policy towards safety rules and regulations. The company expects its employees and subcontractors to fully comply with all safety regulations at all times.

> The Safety Violation Notice is to be used by Supervision to identify observed safety violations to record the observation, and to indicate appropriate correction. It is to be delivered to subcontractor, who refuses. to correct a noted safety violation within a reasonable period of time, and is to be distributed to appropriate individuals and files for important record purposes.



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The company employees, who are found violating the safety rules and procedures, may be subjected to the following disciplinary actions.

Observation Notice

Warning Notice

Loss on one-day salary

Suspension from work for two days

Termination from the project

Warning Notice Loss on one-day

salary Suspension from work for

two days Termination from the

project

Violations that will result in immediate, automatic termination include:

> Consumption of alcoholic beverages during working hours.

> Being under the influence of drugs or alcohol while on any jobsite or any (company)

property.

> Fighting and or assaulting another employee, client or any other person.

> Any willful destruction of company or other property or equipment.

> Possession of a dangerous weapon while on jobsite or company property or any other

location during working hours.

3.1.1 Minor Offence

> First offence

> Second offence

> Third offence

> Fourth offence

> Fifth offence

3.1.2 Major offence

> First offence

> Second offence

> Third offence

> Fourth offence



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> Careless, negligent or reckless use of company equipment, machines, took or vehicles or unauthorized use of equipment.

> This system shall be followed in all cases of safety violations having potential for damage and/or personal injury.

4.0 SAFETY MEETING /TRAINING /AWARENESS

4.1. WEEKLY SAFETY MEETING:

Weekly safety meeting will be conducted with site supervisors and subcontractor and all Health, Safety and Environment aspects will be discussed at this meeting. HSE Representative of Gulf Spic shall be attended HSE weekly meeting conducted by Client / Main contractor.

4.2. MONTHLY SAFETY MEETING:

Monthly safety meeting shall be conducted Gulf Spic with construction manager and HSE Representative, by subcontractor Representative and HSE representative. Site supervisors may be called for meeting, if required. All the Safety, Health and Environment aspects shall be reviewed at this meeting. Written minutes shall be taken and hand over to all participants. A copy of the Minute of Meeting shall always be sent to Client / Main contractor

4.3. SAFETY TRAINING:

> Before starting the job all the employees shall attend Gulf Spic as well as CLIENTS safety Induction and Orientation Training.

> Other special training will be provided as per the requirement. > Our employees will also be sent for the training arranged by the owner and

Main contractor and get benefited.

The Induction Safety shall include:

> Targets in the plant.

> Safety procedures .



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> HSE policy Accesses and circulation inside the plant

> Emergency and First Aid Procedures

> Working procedure and standard

> Lifting tools and tackles

> Personnel Protective Equipments

> Fire prevention and protection Use of personnel protective Equipment

> Work permit system

> Basic Hazard Communication

> Respiratory Protective Equipment

> Fire Prevention and Protection

> Environment Requirement

> Working at Height (fall Protection)

> Electrical safety

� Recall of regulation texts, stairs, scaffolding, hoisting devices, portable tools and gas bottles.

> Disciplinary action and penalty system

> H2S training, Excavation training, incident / accident & near miss Reporting and working with the different tools / electrical device

There will be specific craft training for all the GS employees 8c subcontractors like



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> People Based Safety

> Safety leadership Training

> Safety Task & Risk Reduction

> Job Hazard Analysis

> Scaffolding

> Confined space entry

> Safe working at height

> Heavy equip., & Lifting Tools tackles

> Welding and cutting safety

> H2S & toxic gas Awareness

> Emergency Evacuation plan

> Incident / Accident reporting & investigation

> Breathing Apparatus Usage

For all training activities a written record will be kept of all participants. All participants will

sign this form. GS shall develop training Matrix and Training Schedule

4.0 SAFETY AWARENESS & PROMOTIONAL ACTIVITIES: GS and Subcontractor employees prior to deployment in the field will be made aware of

prevalent danger due to possible presence of explosive device.

> Hazard Recognition

> Fire watch

> Electrical safety



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> GS and subcontractor employees will attend EOD (Explosive Ordnance Disposal)

familiarization programmed conducted by company.

> It is necessary to prevent development poor work habits that always result in an

injury rate increase and a quality and productivity decline

> To this purpose GS and subcontractors shall include in .their Safety Program a

Motivation Plan indented for keeping employees aware of the health, safety, and

environment issues.

> This Motivation Plan will include at least:

> Bulletin board inside and of GS offices to post general information on safety

statistics and notices.

> Safety signs, posters, Warnings, etc.

> Disciplinary actions in case of non - observance of safety rules

> Symbolic award to reward the worker for same performance in the execution of his tasks.

4.5. TOOL BOX TALKS

> Toolbox talks shall be conducted daily and before any work begins for the shift and shall last for at least 5-10 minutes. Safety meeting shall also be warranted once in a week, lasting for .at least 30 minutes.

> Topics that have to be discussed in the toolbox talks and the safety meetings should be

relevant and pertinent to the job being performed.

The briefing should include;

> Identification of relevant hazards

> PPE requirements, safety procedure, Fire Prevention & Protection, Environment,

> Particular safety instructions & guidance



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> Review of lessons learnt from previous incidents

> The subject to be discussed shall be typed, reproduced and when needed appropriated, the craft supervisor shall add relevant topics gathered from his previous experience, lesson learnt etc., in consultation with the safety engineer.

> Meeting should provide employees with the opportunity to ask questions and

suggestions for improvements shall be encouraged.

> The supervisor at a predetermined place and time, using the subject material

provided, should conduct the meeting. .

> The safety Engineer/Supervisor shall attend these meetings to audit and visually

display their support for safety on the job.



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> Employees speaking different languages will be identified and grouped. Information shall be communicated to them accordingly in appropriate language for better communication. .

> The company Safety Engineer/Officer shall hold safety Training for

employees in various topics on loss prevention awareness, periodically.

> The Safety Training shall be documented indicating the names of those trained, the time and date, subject material and name of the safety trainer

5.0 INSPECTION AND SURVEYS:

Daily and weekly Safety Inspections carried out by Gulf Spic SHE Engineer along with Site Supervisor and subcontractor Representatives. Main aim is to detect work area conditions and human attitude that might cause risks. A HSE check list shall be used as guide. The following HSE activities shall .be Inspected and Surveyed.

5.1. PERSONAL PROTECTIVE EQUIPMENT

A hazard assessment will be performed at the beginning of the project and necessary Personal Protective Equipments will be procured and issued to the employees. All will take necessary action for the compliance wearing of PPE.

PPE shall comply with American National Standards Institute (ANSI), British standard / European

Norm (BS/EN), Owner Approved standard.

5.2. WORKPERMIT:

> Proper Work Permits will be obtained prior to performing any work requiring a permit.

> Required Safe Work Plan (JSA) will be prepared and attached with the permit.

> The Permit conditions, the hazards anticipated and mitigation part will be explained to

the crew by the Supervisor daily during Toolbox meeting before starting the job.



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5.3. EXCAVATIONS AND TRENCHING:

Special attention will be given to excavation and trenching work

Proper shoring and access will be ensured. Excavated area will be properly barricaded.

5.4. BARRICADING AND SIGNS:

> Physical barriers will be constructed to give protection against hazards and dangers and hazardous work areas wherever required.

> Barricade tapes will be utilized as a visual warning. ^

> Storage and handling of compressed gas cylinders:

> Safe method of handling and storage of compressed gas and oxygen cylinders will be

ensured.

>Proper instructions and training will be provided to the workers.

5.5. FLAMMABLE LIQUIDS:

> Adequate care will be taken for the storage of flammable liquids.

> Required fire protection and warning signs will be provided.

5.6. CRANE LIFTING:

> Experienced crane operators and riggers will be employed.

> Crane and lifting appliances will be checked for their condition and certification.

> Good rigging procedure will. be followed. Proper pan will be evolved for crane

working near hazardous pipelines.

5.7. ELECTRICAL EQUIPMENT:

> All electrical equipments will be inspected periodically for



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> Proper overload protection,

> Ground continuity

> Interlocks

> Frayed cables / cords etc

The condition of power tools will be checked periodically and defects if any will be attended.

The tools, which could not be repaired, will be removed from service.

5.8. HOUSEKEEPING

> Good Housekeeping improves Safety, prevents accidents.

> "Workers will be insisted to keep their work area clean before they leave.

> Scrap material and debris will be kept away from the work area.

> Proper material storage will be ensured.

5.9. SAFETY AUDIT AND INSPECTIONS:

It shall be an obligation of the Staff Personnel to regularly carry out inspection rounds

to observe the status of Health, Safety and Environmental requirements and measures

on the site. All Safety personnel including subcontractor will make a Safety Audit once

in week / month.

Safety personnel make daily inspection of work area. Job supervisors will also make daily inspection of their work area for correcting unsafe

acts or hazardous condition. Corrective action will be implemented as per audit reports.

GOAL: To prevent unwanted incident (Accident & Near-Miss)

PURPOSE:' To 'increase safety awareness '.

To demonstrate safety commitment of super visor staff and Management.

OBJECTIVE: To identify Unsafe Conditions of each work place.



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To recognize Unsafe Acts of individuals.

"

Safety Audit Sheets are enclosed as Attachment

5.2.1 HAZARD & GENERAL RISK ASSESSMENT EVALUATION.

Risk Assessment / Evaluation includes the identification of activity, potential Hazards,

probability and severity, control and recovery measures as organization, protective equipment

procedures etc.

Gulf Spic will do General Risk Assessment includes the activities performed during:

> Prefabrication and steel Structures Erection

> Scaffolding Erection

> Equipment Erection

> Prefabrication Piping Erection

> Grid blasting Painting Works

> Insulation Works

5.2.2 MEDICAL, HEALTH AND HYGIENE EVALUATION:

Staff will undergo required medical examination prior to mobilization to site, and unfit

staff will not be allowed to travel. Copies of reports of all such medical

examinations are confidential and will be provided on demand to Company's medical

team. Staff will under go the following test B Virus (HBV), Human Immune-

deficiency Virus (HIV) and other blood borne pathogens that employees may

encounter in their workplace.

6.0 INVESTIGATION, REPORTS, DATA & DOCUMENTATION

6.1. WEEKLY REPORTS: All activities will be covered in Monthly reports.



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6.2. MONTHLY REPORT:

Monthly Safety Report containing the following information will be submitted to the main contractor.

> Total man hours

> Details of HSE performance indicators Details of incidents

> Details of training.

> Details of safety violations

> Details of safety audit

> Detail of First Aid

> Accident/ incident trends and statistics.



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> The site will provide adequate first aid facilities together with the appropriate numbers of trained first aid personnel. Vehicle with driver will be also foreseen for transportation of any injured person to the First Aid Station or to the Hospital, if required.

> GS will display signs containing emergency telephone numbers for vehicle, First Aid Treatment, Medical centers, Public Fire brigades etc. in visible locations.

6.4. ACCIDENT/INCIDENT/NEAK-MISS INVESTIGATION AND REPORTING

> GS will implement comprehensive programs for the reporting of all incidents that result in or have the potential to result in injury to people, damage to property, to the environment.' subcontractors will be required to proactively report all such incidents and support GS incident reporting requirements.

> The construction site will maintain adequate records of all first aid and medical treatment cases, and any incident resulting in environmental damage. Any injury, accident or significant near miss involving personnel, equipment or the equipment will be reported immediately to the appropriate supervisor on GS Incident Investigation Report form. GS will provide all information requested by Company representatives and co-operate and assist Company in investigating any incident to the extent required.

> All injuries to employees, which involve hospitalization, required. Statistics will be maintained of all injuries including first aid, medical treatment, lost time cases. All GS Corporate reporting requirements will be followed in addition to KOC reporting requirements.

> I he main purpose of these investigations and reports is to determine the underlying causes of accident or Near - Miss to provide measures in order to avoid recurrence as well as occurrence of a similar incident elsewhere on the project site

6.5. ACCIDENT / INCIDENT TRENDS AND STATISTICS:

Gulf Spic will do accident / Incident Trends and statistics calculation by using the following statistics and terminology

6.3. FIRST AID



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2) Frequency Rate: (FR)

Number of Lost Time Injury Plus Permanent Disabilities (PDC) per each

million

worked hours

It is calculated by using the following formula

LTIR-(Nr of fatalities +PDC+LTI)/(Nr. Of worked hrs) X10000000

3) Severity Rate(SR)

Number of lost workday (LWD) per each thousand worked hours. p •


' 3 SR= LWD/(Nr. Of worked hours) X 10

4) Overall Recorded Accident Rate (TRIR)

Number of Lost Time Injury Plus Permanent Disabilities (PDC) plus Restricted Work

Capacity (RWC) plus Medical Treatment off site (MTC) per each million worked

hours.


6

TRIR= (Nr of fatalities +PDC+LTI +RWC+MTC)/(Nr. Of worked hrs) X 10

6.6. RECORD AND DOCUMENTATION

GS has a system, as part of its Quality system, to ensure that its HSE related documents and records are identified, verified updated and available at work sites. The following records are maintained at job site:

Tool box meetings / safety training / New hire orientation record

Notice on safety violation

Incident investigation report

Near miss / dangerous occurrence / accident report



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Personal injury log

Properly damage loss

Job site inspection report

Walk around inspection report

House- keeping checklist

Safety audit report

Monthly safety report -

Risk Assessment

Job Safety Analysis

7.0 ACCIDENT / INCIDENT MANAGEMENT:

All fatalities, injuries and illness incidents and first aid shall be recorded and reported to

Main Contractor, Gulf Spic will be used personnel injury / vehicle accident

investigation report of KOC Format. If outside medical treatment for a work related

or illness is obtained, the person shall notify

Their Forman/ Supervisor at the start of the next scheduled workday. The date of return

shall be recorded and reported to the Administration and to the HSE Department.

8.0 PERMIT TO WORK SYSTEM

All the activities covered under the scope of work shall be carried out with a valid work permit raised

by the concerned personnel, approved and authorized by the client

The permit system that has been contractually agreed upon shall from the basis for the day-to-day permits requirements

The GS shall ensure that proper Work permits are obtained prior to Commencement of the works. The Work permits system

> Hot works

> Cold works

> Confined Space Entry



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>: Electrical lock -out

> Excavation works

> Heavy equipments& Vehicles entry / Road blockade

> Radiography works

> Entry into restricted area

8.1. WORKSITE ACCESS

Ac the start of the project, a hazard assessment shall be performed to determine any hazards that require the use of PPE. The following shall be a part the hazard assessment as a minimum requirement

> Identification of potential hazards

> Identification of movements (vehicles, machineries, personnel movement etc)

> Identification of sources of noise

> Identification of radiation sources (if any)

> Identification of sources of high Temperatures

> Identification of High elevation works

> Identification of electrical sources and hazards

> Identification of sources for chemical exposures (if any)

> Where hazards exist, type, level of risk, and seriousness of potential for injury for each hazard

shall be studied in detail. Selection of PPE shall be based on the degree of protection required for the

hazard and the protection provided by the PPE set out to meet the client's requirements.

> The hazard assessment must be documented with a written certification. This certification is

maintained by the Project/Site Safety Representative

8.2. PERSONAL PROTECTIVE EQUIPMENTS



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Personal protection shall be as a minimum to cover the following

> All the employees working in the project site shall wear hard hats that are in good condition and

meet applicable regulatory standards.

> It shall be ensured that the hard hats are in good condition and defective ones shall be replaced immediately.

> For areas where the sound level is more than 80 db , personal hearing protection shall be made available to all employees working in that area.

> All the employees shall wear approved safety glasses with side shields for the works in the project site. Additional eye and/or face protection, such as goggles, face shields, and welding shields, shall be required when engaged in specific operations such as welding, burning, grinding, chipping, handling chemicals, drilling overhead, use of powder actuated tools, and pouring concrete etc.

> It shall be ensured that all welders will use filter lenses or plates specified by the applicable regulatory standards with protection on both sides. .

> It shall be ensured that all the employees working in the project site will use safety shoes as per the applicable regulatory standards.

> Additional foot protection like rubber boots will be worn for specific jobs like concrete pouring

etc.

> It shall be ensured that all the employees shall wear hand gloves while handling material that could cause injury or damage to the skin

> Seat belts shall be worn and used by all employees operating or riding in any motor vehicle.

8.3. SCAFFOLDING WORKS

> All the scaffolding works required for the project shall be as per the Clients Standards & KOC standard and ,the same shall be erected by competent scaffolders under supervision of competent scaffolding supervisor.

> GS shall ensure all scaffolding work is performed on an approved Elevated Work Permit and Scaffold Permit signed by the authorized personnel.



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> GS shall ensure all scaffolding are safe, inspected weekly by a competent person and that the scaffolds are properly tagged. It shall be ensured that the scaffolding which is improperly/un tagged and or Unsafe to use shall not be used by the contractor personnel.

> GS will employ competent scaffold builders to erect scaffolds and competent scaffold

inspectors, a scaffolding supervisor scaffolding works.

> GS shall maintain a log and record all scaffolds and inspections. Contractor shall make

inspection records available to Owner upon request.

> The Scaffolds that are erected in-site shall be tagged at all times and the tag shall be any one of

the following

> RED Tag — Red Tagged Scaffoldings shall not be used for working purpose regardless of the

reason.

> GREEN Tag — Green Tagged Scaffolding shall be used for working purpose subjected to

weekly inspection.

> . The Scaffolding, shall be inspected weekly by an approved scaffolding inspector to assure that the erected scaffolding is as per the clients safety requirements

> Scaffolds shall be erected, moved, dismantled, or altered only under the supervision and

direction of a competent person qualified in scaffold erection, moving, dismantling, or

alteration.

8.4. LIFTING PLAN/MECHANICAL ERECTION: .

This section provides guidelines for the steel erection process and the protection of

personnel during steel erection.

GS shall be done Rigging / Lifting studies when Load is:

1) Load above fifty 50 Ton

2) Loads exceeding 75% of crane recommended capacity

3) Operations involving two (2) cranes or more. 4) Proximity of energized aerial lines or equipment. This study shall include: 1) Crane, Lifting mechanisms and jigging equipment



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2) Accurate load drawings (sisz,weight, poisition,center of gravity,slings method)

3) Suplpier Recommendation and Instruction

4) Perior checking of all items, including lifting lugs and shackles.

> GS shall prepare a Safety Action Plan and present it for review at the safety planning meeting.

> GS shall ensure all steel erection work is performed on an approved Elevated Work Permit

attached to a Safe Work Plan. > Prior to the start of steel erection work, a site survey shall be

made to determine risk involved in the works.

> Signs and barricades will be installed at the area where erection is under progress. Sufficient warnings shall be made available in the work area before commencement of the works.

> The structure shall be erected only on surfaces / foundations approved for erection.

> It will be ensured that all personnel involved in the operation will be competent, physically and mentally qualified, trained in the safe operation of the equipment and handling of the loads.

> All the personnel who will be working in the field will be given safety orientation training. Regular toolbox talks will be held at the site, prior to commencement of work

> The location of crane and positioning will be surveyed and marked clearly in the area.

> Level and location of the equipment foundation to be checked and prepared appropriately (with shims) to receive the equipment.

> Proper orientation shall be marked on the equipment that is to be erected

> The entire lifting operation will be under the control of a designated rigging supervisor assisted by a qualified crew.

> Entire operation shall be controlled using visible signals.

8.5. WORKING IN CONFINED SPACE :



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> Vessels, Tanks, pits, Furnace, Sewers, Excavation deeper than 1.2m come under the preview

of confined space .

> The hazards primarily consist oxygen deficiency, Presence of Toxic, corrosive,

Flammable / explosive material, pyrophoric materials, Restricted access, High humidity, Electrical,

static, Radioactive hazards Mechanical hazards.

> Access to confined spaces without prior work permit is strictly prohibited.

> Prior to entry gas test shall done with calibrated Multi-gas detector meter by qualified /

authorized Person

> Concentration of flammable gases /vapors must be below 10% of flammable limit (cold

work) for Hot work-0%

> Concentration of toxic vapors is not higher than half of the maxirnum permissible

Concentration.

> Confined space is made safe for entry by depressurizing, draining, steaming, washing,

ventilating.

> Adequate illumination is provided using 24v hand lamp.

> Confined space trained attendant person mall- be kept outside the man-ways with

attendant sheet and rescue equipment. .

9.0 AREA CLASSIFICATION:

Area can be classified as follows

1) Controlled Area:.

2) Restricted Area

3) Hazardous Area

"Controlled Area" is the entire KNPC premises fenced or otherwise, to which access is

controlled or restricted.

" Restricted Area" is within controlled Area in which entry is permitted only to authorized

person and a valid gate pass is necessary to enter these premises. "Hazardous Area" is the



Dated May ,2008

Project Compliance:

Client: KOC


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area within restricted area where flammable atmosphere is more likely to be present. A

flammable atmosphere is defined as having sufficient concentration of flammable gas, vapor,

mist, or combustible dust, capable of being ignited.

10.0 RADIOGRAPHY:

> The radiography works required for the project shall be performed by Qualified personnel land work shall be carried out in complete compliance with the Clients requirements and governing codes & standards.

> It shall be made as a practice that the Radiography works shall be carried out after the normal working hours so as to minimize the stoppage of other works.

> Prior to the commencement of the radiography 'the necessary work permit shall be raised by a authorized contractor personnel and shall be approved by client's authorized personnel.

> The source employed for the works shall be free from leaks and the contractor shall ensure the soundness of the source to be employed for service.

> Prior to the mobilization of the source to site the contractor shall inform the Client and get the due approval.

> Prior to commencing any radiography the area around the work location will be cleared but for the authorized personnel carrying out the job.

> Barriers, lights and warning signs will be erected a safe distance from where the source is going to be used.

> Safe access and egress must be provided to each work location with adequate lighting to carry out their work safely.

> The radiography works snail be meticulously planned and executed considering

the amount of potential hazard it can cause to the personnel and the environment

11.0 SAFE STORAGE AND HANDLING:

> The cylinder used for the process shall be handled as per the following



Dated May ,2008

Project Compliance:

Client: KOC


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> The storage of oxygen and acetylene cylinders bottles shall be in a sheltered / sun - roofed area, but never inside any building. Gas cylinders shall be store 6m away from any building, the diesel and gasoline storage area.

> Oxygen and Acetylene cylinders shall be stored in separate compartments

> Oxygen and Acetylene" storage signs, "No smoking" , "Authorized person only" signs shall be placed. Fire extinguisher (Class B fire) shall be placed at the out-side of the shelter.

> Open valves on fuel gas cylinders (propane, acetylene, natural gas) a quarter turn only. Open oxygen cylinder valves completely. The valve wrench must be kept in place during use.

> The pressure in the Torch shall be maintained as per the safety norms.

> All compressed gas cylinders should be kept in bottle-carts (trolleys) when transported or in use.

> Compressed-gas cylinders :shall be secured lay a chain a vertical position while in storage, transit or use.

> All hoses, gauges and torches must be inspected regularly.

> Never use oxygen in pneumatic tools to pressurize a container, to blow out lines, or as a substitute for compressed air or other gases.

> Chemicals like paint shall be stored with MSDS in separate shelter and away from the source of heat. .

> Place cylinders and hoses where they are not exposed to spark and slag from a

burning operation.

12.0 TRANSPORTATION, VEHICLES SAFETY AND MATERIAL HANDLING.



Dated May ,2008

Project Compliance:

Client: KOC


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> It shall be ensured that all vehicles and equipments that are to be employed in this project are inspected and tested prior to mobilization of the project and commencement of the works Contractor shall present vehicles to Owner Safety Department for inspection and submit operator' drivers license, registration documents and insurance document tor review.

> The vehicles and the equipment shall be tested as per the Clients requirement, before the commencement of works. (Safety Certificate, Third party Test Certificate will be arranged)

. All defects shall be corrected before the vehicle is placed m service The testing shall be carried out in the presence of a qualified personnel and the result of the testing shall be documented and shall be submitted to the client.

> It shall be ensured that Shoulder harnesses and/or seat belts must be worn at all

times by the driver and all passengers in the vehicle cab.

> All vehicles shall be equipped with a fire extinguisher, red emergency triangles,

flash light, first aid kit and tire inflate-canister.

> Regular vehicles shall be equipped with an audible reverse signal alarm which operates automatically with & all times during backward movement.

> All the other road safety rules & speed limit assigned by KOC authority will be strictly followed.

GSWILL ENSURE THAT TRUCKS & TRAILER WILL NOT BE USED FOR TRANSPORTATION OF PERSONALS AT SITE

12.1.0 LIFTING AND SHIFTINGEQUIPMENT

> All the rigging equipments that are used for the erection works shall be free from defects, in good operating condition and maintained in a safe condition and shall bear the serial number of the manufacturer and the Safe Working Load capacity (SWL.) marked on it. All rigging equipment shall also be accompanied by the manufacturer's certificate indicating the serial number and capacity.

> It -will be ensured that all personnel involved in the. operation will be competent, physically and mentally qualified, trained in the safe operation of the equipment



Dated May ,2008

Project Compliance:

Client: KOC


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and handling of the loads.

> The rigging equipments shall be inspected on a monthly basis and shall be documented and maintained for future references.

> The inspection results / manufacturer's certificates shall be made available to the client upon request..

> Lifting bays used to make lifts will be barricaded at ground level to protect employees from walking under loads. Only inspected rigging equipment that has the SWL indicated on it and with the manufacturer's certification shall be allowed to be used.

> All lifting equipment shall be tested third party inspection prior to start any load

lifting activities.

> GS shall follow the KOC Traffic rule,

> Max. speed for general traffic shall of 40 km/hr while 20 km/hr heavy trail

mobile crane, truck etc.

13.0 ELECTRICAL SAFETY

All temporarily electrical Equipment Shall be installed as per KOC / Main contractor Std. And all temporally electrical Equipment Shall have double ground/earth and earth leakage circuit breaker (ELCB) :

> Before commencement of any electrical works the work involved shall be studied and risk/hazard involved shall be charted out. Electrically Hazardous Task Plan / Permit is to be completed and signed before any work shall be commenced.

> Only qualified persons may work on electric circuit parts or equipment that have not been de-energized and / or perform high voltage tests and shall be Knowledgeable with the proper use of precautionary techniques, personal protective equipment, insulating and shielding materials and insulating tools.

> When work is carried out in the, vicinity of the energized equipments suitable barriers and or rubber and other insulated protective devices shall be used.

� Safety signs safety symbols or tags are to be used (High Voltage, No Smoking, Authorized Person only) where necessary to warn employees about electrical hazards that may endanger them.

� Employees shall be provided with, and shall use, electrical protective equipment



Dated May ,2008

Project Compliance:

Client: KOC


27 & 28

Rev. No: 1

Page - 42


rated for the voltage involved and that is appropriate for the specific parts of the body to be protected for the work to be performed.

� Employees may not enter spaces containing exposed energized parts or work on exposed energized parts, unless adequate illumination is provided that enables the employees to perform the work safely.

� The safe working distances from the energized apparatus shall be ensured and at instances where the above mentioned cannot be fulfilled work shall be carried out after assuring that required personal protection equipments are available on hand.

� Conductive materials and equipment that are in contact with any part of an employee's body shall be handled in a manner that will prevent them from contacting exposed energized conductors or circuit parts. Disconnecting procedure for de-energizing the energized circuit shall be identified and followed during the execution of the project.

� Electrical test instruments and equipment and their accessories shall be rated for the circuits and equipment to which they will be connected and shall be designed for the capacity & the environment in which they will be used.

,

� Test instruments and equipment and all associated leads, cables, power cords, probes, and connectors shall be visually inspected for external defects and damage before the equipment is used. If there is a defect or evidence of damage that might expose an employee to injury, the defective or damaged item shall be removed from service, and no employee may use it until repairs and test necessary to render the equipment safe have been made. The presence of a grounded neutral, ground wire, or other grounded apparatus in the primary area shall be isolated and appropriate rubber or other protective devices to cover such conductors or apparatus shall be ensured. .

� shall be ensured that only approved hot-sticks/ jumpers shall be used to make transformer primary connections and other connections

14.0 CONSTRUCTION SAFETY

14.1.0 SCAFFOLDING ERECTION

> All the scaffolding works required for the project shall be as per the KNPC Fire & Safely Regulations and Clients Standards and the same shall be erected by competent Scaffolders under supervision of competent scaffolding supervisor.



Dated May ,2008

Project Compliance:

Client: KOC


27 & 28

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> GS shall ensure all scaffolding work is performed on an approved Elevated Work Permit and Scaffold Permit signed by the authorized personnel.

> GS shall ensure all scaffolding are safe, inspected weekly by a competent person and that the scaffolds are properly tagged. It shall be ensured that the scaffolding which is improperly/un tagged and or Unsafe to use shall not be used by the contractor personnel.

> GS shall ensure ladders are installed so as to form an angle 75 degree from horizontal and bridge board extended 1m above access point.

> Ladder extension shall be at least 4 lugs overlap and GS will ensure the ladders any damage, painted ladder and wooden ladders.

> GS will employ .competent, ,scaffold builders to erect scaffolds and competent scaffold inspectors, a scaffolding supervisor scaffolding works.

> GS shall maintain a log and record all scaffolds and inspections. Contractor shall make inspection records available to Owner upon request.

> The Scaffolds that are erected in site shall be tagged at all times and the tag shall be any one of the following

> RED Tag— Red Tag shall 'not be used for working purpose regardless of the

reason.

> GREEN Tag — Green Tagged Scaffolding shall be used for working purpose subjected to weekly inspection.

> The Scaffolding shall inspected weekly by a approved Scaffolding Inspector to assure that the erected scaffolding is as per the clients safety requirements

> Scaffolds shall be erected, moved, dismantled, or altered only under the

supervision and direction of a competent person qualified in scaffold erection, moving, dismantling, or alteration.

> All the scafollds above 2m height shall be provided with a work platform with handrail installed at 90cm minimum, toe board and mid-rail

14.2.0 WELDING, CUTTING & GRINDING



Dated May ,2008

Project Compliance:

Client: KOC


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Page - 44


> The welding works shall be carried out after obtaining hot work permit as per clients work requirement.

> For welding that is carried out inside the Plant area, the welding area shall be cordoned off suitably. All the welding works shall be carried out with necessary safety appurtenances.

> Only qualified personnel shall be employed for executing the job. The personnel shall be aware of the Clients safety requirement and shall ensure that safety is not taken to task at any time.

> The following shall be ensured for the welding process

> All work must have an adequate ground.

> Welding rods are not to be left in the electrode holder when in use. Used welding rod stubs/ butts are to be put in hazardous containers.

> All arcs must be shielded in all construction areas.

> Gulf Spic will ensure the provision of Fire extinguishers, water hose, Fire watcher

> Area shall be cleaned 8mts around where welding to be done.

> All machines must be turned off at the end of the shift.

> An approved welding helmet must be worn. Equipped with no less than a no. 10 filter plate, with safety plate on both sides of the filter plate.

> Welders must wear a hard hat with the welding helmet.

> Never perform electric welding from a metal ladder.

14.3. RIGGING PLAN

> It will be ensured that all personnel involved in the operation will be competent, physically and mentally qualified, trained in the safe operation of the equipment and handling of the



Dated May ,2008

Project Compliance:

Client: KOC


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loads.

> The rigging equipments shall be inspected on a monthly basis and shall be documented and maintained for future references.

> The inspection results / manufacturer's certificates shall be made available to the client upon request.

> Lifting bays used to make lifts will be barricaded at ground level to protect employees from walking under loads. Only inspected rigging equipment that has the SWL indicated on it and with the manufacturer's certification shall be allowed to be used.

> All lifting equipment shall be tested third party inspection prior to start any load

lifting activity

> Prefabricated pipes shifted to the pipe rack after prefabrication shall be unloaded by using

crane near the pipe rack on which the pipe is going to be erected and barricaded.

> The scaffoldings shall be erected and made ready in order to carry out the erection and

welding of pipelines in the position

> The pipes shall be .erected one by one over the pipe rack

> The pipes shall be inserted in to the pipe rack with due care considering that the drain and

vents are not hit.

14.4. EXCAVATION & TRENCHING WORKS

> Prior to commencing excavation or trenching, location of all the existing underground

installations (i.e. sewer, telephone, water, fuel, electric and gas lines) shall be thoroughly studied.

> Prior to commencing excavation or trenching Gulf Spic will submit the request for Excavation Notification at least before 3 weeks.

> A detailed soil Investigation shall be carried out by a competent person and the results of the same shall be documented.

> The excavation and trenching works shall be inspected by competent person and necessary safety precautions must be taken based on his recommendations.



Dated May ,2008

Project Compliance:

Client: KOC


27 & 28

Rev. No: 1

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> All the excavation / trenching works shall be carried out only after obtaining the necessary excavation permit as per the Client's requirements.

> It shall be ensured that no works shall be carried out in water filled trenches, works shall be started only after Dewatering operation is started.

> In trenching of more depth ladders, steps, ramps or other safe means of access and egress shall be provided.

> Walkways, ramps or bridges with standard guardrails will be provided at all excavations and trenching where cross over is expected.

> A confined space entry permit shall be taken for work in a trench / pit below 1200mm.

> All the excavated materials shall be disposed off at a minimum distance of 1 meter from the edge of the excavated area or by use of proper retaining devices that are sufficient to prevent materials or equipment from falling or rolling into excavations.

> When mobile equipment of any type is utilized or permitted to operate adjacent to excavations or trenching, suitable barricading shall be. provided before the commencement of the works.

>Employees exposed to vehicular traffic operating in the area of excavation or trenching will be provided with and instructed to wear warning vests or other personal protective equipment marked with or made of reflectorized or highly visible material.

14.5. GRID BLASTING & PAINTING WORKS

> The grid blasting works shall be carried out by qualified and approved personnel

and shall be geared with proper personal protective equipments like coverall closed at the neck, wrist and angles, work gloves Blasting hood/ helmet and anti dust mask for painters as per contamination level.

> Blasting and Painting operation shall be performed as per KOC Fire & Safety Regulation.

> It shall be ensured that all the personal protective equipments employed for the abrasive blasting works shall be inspected-periodically and maintained in a safe and good working condition.

> It shall be ensured that the Blasting equipments shall be inspected periodically and maintained in a safe and good working condition.

> The appurtenances like air hoses, couplings etc that are required for the



Dated May ,2008

Project Compliance:

Client: KOC


27 & 28

Rev. No: 1

Page - 47


blasting works shall be inspected for any defects and defective items shall be rectified prior to usage. Before the commencement of the blasting works the nozzles shall be checked and cleaned.

> The grid blasting operation shall be carried out in separate area inside the project site approved by the client so as to avoid disturbance to personnel who is not involved in said operation.

> The blasting area shall be barricaded properly before the commencement of works.

14.6. HAND TOOLS AND CONSTRUCTION EQUIPMENT:

All hand tools and construction equipments shall be checked prior to start any work GS shall be checked the condition of the tools and equipments once in a month.

14.7. SAFETY IN RADIOGRAPHY:

> The radiography works required for the project shall be performed by Qualified personnel land work shall be carried out in complete compliance with the Clients requirements and governing Codes & standards.

> It shall be made as a practice that the Radiography works shall be carried out after

the normal working hours so as to minimize the stoppage of other works.

> Prior to the commencement of the radiography works the necessary work permit shall be raised by a authorized contractor personnel and shall be approved by client's authorized personnel.

> The source employed for the works shall be free from leaks and the contractor shall ensure the soundness of the source to be employed for service. .

> Prior to the mobilization of the source to site the contractor shall inform the Client and get the due approval.

> Prior to commencing any radiography the area around the work location will be cleared but for the authorized personnel carrying out the job.

> Barriers, lights and warning signs will be erected a safe distance from where the source is going to be used.



Dated May ,2008

Project Compliance:

Client: KOC


27 & 28

Rev. No: 1

Page - 48


> Safe access and egress must be provided to each work location with adequate lighting to carry out their work safely. .

> The radiography works shall be meticulously planned and executed considering the amount of potential hazard it can cause to the personnel and the environment

14.8. DEMOLITION OF UNDER GROUND AND ABOVE GROUND PIPE LINE TIE-IN

> Marking of excavation limits'

> GS shall be arranged Excavation Notification prior to any excavation.

> Barricading shall be done where the excavation to be done

> Providing adequate signs and signals- like Deep excavation, flash lights.

> Providing temporary supports/anchors/ protection.

> Cutting of concrete slab by diamond cutter .

> Breaking of Concrete by suitable means (Jack hammer / Sledge hammer)

> Cold cutting of steel

> Excavation of soil - Hand excavation

> Transfer of excavated soil to designated place within the unit limits

> Transfer of dismantled concrete and steel to the designated place within the unit limits, prior

to transferring it to the marked disposal area;

> Confined space entry permit shall be complied, if the excavation more than 1.2m

deeper.

> Shoring & strutting

> Temporary supports for the underground pipeline and other facilities.

> Marking of the exact location in which the pipe has to be cut an Tie-in

> Removal of the wrapping and coating in the existing pipelines

> Cold cutting will be done and gas test shall be taken to ensure free of any hydrocarbon

presence



Dated May ,2008

Project Compliance:

Client: KOC


27 & 28

Rev. No: 1

Page - 49


> Cutting of the pipeline using Oxy acetylene cutting or using cutting wheel and

shall be complied with hot work permit.

> Dewatering of the water/ fluid draining from the pipeline

> Lifting of the cut portion of the pipeline from the trench by manual means or by using

crane depending upon the requirement and shall be complied with rigging/lifting

procedures.

> Laying of the new pipeline for TIE-IN

> Welding / Jointing of the pipe spool with the existing line as per the applicable

WPS

> Inspection and testing as per the applicable quality plan

> Wrapping & coating of the pipeline as applicable for underground carbon steel

piping

> Backfilling•-

> In-situ casting of RCC as per project procedure

> Restoring the already existing permanent supports in

place.

> Removing of temporary supports

> Above ground piping DEMOLITION and TIE-IN shall be done as above said

procedure expect excavation.

> Scraped pipe/spools shall be shifted then and there immediately.

> House -keeping of the area.

15.0 GENERAL SAFETY:

15.1. ELECTRICAL POWER TOOLS:

All electrical equipments will be inspected periodically for



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Project Compliance:

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Rev. No: 1

Page - 50


> Proper overload protection,

> Ground continuity

> Interlocks

> Frayed cables / cords etc

> Non sparking tools are used hi areas liable to fire / explosion

> Tools are inspected and periodically and damaged tools return to store .The

condition of power tools will be checked periodically and defects if any will be attended.

The tools, which could not be repaired, will be removed from service.

15.2. Personal Protective Equipment:

A hazard assessment will be performed at the beginning of the project and necessary Personal Protective Equipments will be procured and issued to the employees. All will take necessary action for the compliance wearing of PPE. Our policy for any site is to have basic PPE's like safety helmet, safety shoes, safety goggles and coverall for anybody entering the site. We also ensure that , workers are issued job specific PPE like safety harness with life line, welders gloves, gum shoes, cartridge type respirators, self contained breathing apparatus (SCBA)

15.3. FIRE AND GAS PROTECTION:

> GS shall be complied with KOC Fire and Safety Regulation of Hot Work procedures. > The electrode &the ground cables are completely insulated and we ensure that there is no splice

with 3m from die electrode holder.

> Electrodes are remove from the holders when not in use.



Dated May ,2008

Project Compliance:

Client: KOC


27 & 28

Rev. No: 1

Page - 51


> For gas cutting job, the torch is equipped with flash back arrester

> Gas cylinders are kept away from the source of heat and are securely held in upright position

> Valve protection caps shall be provided on cylinders when not in use.

> Welding / cutting jobs are not allowed in areas where flammable gas mixture, heavy dust concentration very apparent

> Welding or cutting / burning of metals having toxic significance such as Zinc,

Lead, Calcium, Chromium is done in open air and welder wears fitted type

respirator 15.4. SMOKING

Smoking in all the places and inside K.OC premises is prohibited and we ensure that workers are smoking in designated smoking shelter.

15.5. SAFETY IN NOISE POLLUTION:

All Noise making equipments like Diesel Generator and Welding generators are well maintained and keeping them away from the workplace an those who are working near the noisy area shall be provided era plug or ear muff

15.6. OFFICE SAFETY:

Gulf Spic site temporary office shall comply with the following rules.

> All electrical cables and equipments used for site office shall be installed as per

KOC Electrical Fire & safety Regulation.

> All Gulf Spic Office staff shall be given training like fire fighting, evacuation

procedure.

> All GS personnel shall be made aware of the location and fire extinguisher,

escape routes, and safety exits.

> Display of Signs will be provided like "No Smoking", "Fire Extinguisher",

"Emergency Evacuation Plan" and related safety posters.

> A first Aid box shall be available in HSE dept. office.



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> All flammable materials like toner for photocopiers shall be stored in minimum quantities in the

shade and away from any flame or heat source.

15.7. HOUSEKEEPING

Good Housekeeping improves Safety, prevents accidents,

> Workers will be insisted to keep their work area clean before they leave.

> Scrap material and debris will be kept away from the work area.

> Proper material storage will be ensured

16.0 EMERGENCY EVACAUTION PROCEDURES

An Emergency Response Plan will be establish with the aim of safeguarding life and

protecting assets and the environment in the event of an emergency situation such as a major fire and Explosion, Toxic Gas Release, Natural events, Loss of Radioactive source. This plan includes:

> Provision of escape routes and assembly points

> Process for raising the alarm

> Standing instructions for dealing with typical emergencies

> Training in use of fire fighting equipment and Escape set

> Mock drill shall be performed quarterly by GS to Monitor the Emergency Preparedness

Gulf Spic and subcontractor employees will follow the below instructions.

> Assembly Point is located-near GS Car shed'

> In case of Fire / Toxic Gas release Raise the Alarm Immediately Proceed to the Assembly

Point



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> Notice the Nearest Exit

> When leaving the Site / Building do not block the Exits

> After you evacuated the Site / Building, at Assembly point you shall Review your

colleagues, report any missing person,

> Wait for further standing instructions and follow.

Your cooperation is recommended and appreciates

EMERGENCY CONTACT NUMBER WILL BE DISPLAYED AS BELOW

> HSE Manager

> Project Manager (GS)

> HSE Engineer (GS)

> Fire No.

> ECCC

> Ambulance

> Refinery Shift Safety Engr.



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17.0 SECURITY

> The main construction areas are inside the security fenced area of an operating plant, with the primary access controlled by CLIENT personnel.

> Only persons holding a valid driving license and vehicle security pass are permitted to drive inside the Plant. Vehicles are not allowed to enter process areas without a valid work permit. Vehicles shall be parked only inside designated lined parking areas.

> GS is responsible for the internal security and protection of their allocated working areas and shall erect adequate security fencing and lighting at their work locations.

> All the construction materials and small components and fittings shall be stored in a secured warehouse or in a fenced lay down area. In general, no material included in the scope of work for construction shall be stored in unfenced and unguarded areas.

> .GS reserve the right, at anytime, to:

> Refuse admittance to the site to any GS or subcontractor personnel without giving reason;

> To carry out searches of GS or subcontractor personnel or vehicles, for possession of drugs

alcohol, weapons, or other banned articles, or for possession of stolen goods;

> To inspect GS or subcontractor vehicles or construction equipment to ensure necessary certification, and to require that uncertified or unsuitable equipment is removed from site.

> No photography by GS or subcontractor personnel is permitted inside the Plant. Any photographic requirements for progress photos, incident reports etc, shall be referred to CLIENT.



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18.0 ATTACHMENTS (FORMS & KOC JSA)



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19.0 ENVIRONMENT MANAGEMENT PLAN

19.1PURPOSE:

To establish and maintain "Waste Management Disposal Procedure" at Project Site of KOC, Kuwait (Job No.3745) to ensure that solid wastes generated are managed with systematic, controllable and accountable manner in order to reduce associated environmental risks to an acceptable level in compliance with applicable K-EPA/ International regulations & guidelines and as per requirement of Safety, Health & Environment Management System (SHEMS) & Environment Management System i.e. ISO-14001, comply with KOC guidelines and fulfill the clauses of HSE Policy of GS.

19.2 SCOPE:

It covers various types of solid and liquid wastes generated at Project Site during construction and commissioning and their management including disposal in environmental friendly manner.

GS and their sub-contractors are responsible to collect, transport and dispose off the excavated surplus soil, unwanted material generated during the project execution at the Municipality approved dump site outside the KOC- premises, by a sub-contractor approved by Environment Public Authority, Kuwait.

They will obtain approval from KOC if disposal of such material has to be done inside the site

GS and their sub-contractors will prevent air, water and soil pollution while working inside KOC during the project execution. They will take all necessary measures to decontaminate and minimize the adverse impacts of the pollution in accordance with Kuwait EPA standards.

GS & their sub-contractors will implement all the recommendations of the final Environmental

impact Assessment study . They will report about monitoring and implementation status of all the

recommendation to KOC. On KOC's approval, they will send this report to Kuwait EPA.

GS will provide adequate training to all employees including subcontractor staff to ensure that the environmental regulations / procedures are followed & implemented at site & help KOC in achieving the endeavor of reducing the environmental impact on site



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19.3 REFERENCE

� Kuwait Environment Public Authority (EPA) Standards & Regulations - Decision Number 210/20

> Department of Transportation-US

> KOC Safety Regulations

> SHEMS Element # 5

> Safety and Security Plan. > HSE Policy of GULF SPIC

> EIA Study for the Project

19.4 DEFINITION

Solid Waste:

Solid Waste is any material, which is no longer of value to its initial user or generator of the waste and has been discarded. Solid Wastes include wastewater, garbage, refuse, sludge, clinical wastes and any other liquid, semi solid or solid materials, which are discarded after having served its intended purpose or are manufacturing by-products. A solid waste is "discarded" when it is released into the ambient environment, disposed off by discharge onto the surface of the ground, or stored in a drum, tank, pit, pond, or container.

Non - hazardous solid Waste:

Non-hazardous solid waste is any non-reactive, innocuous, inert solid; that includes scrap iron, expired cements, paper and cardboard, wood pallets, civil construction debris etc, which have no hazardous effect on the environment or living being.



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Hazardous Wastes:

Hazardous waste is the waste posing potential threats to man or animal's health or the environment in.

general, resulting from industrial, commercial and agricultural activities and from the household

wastes.' Hazardous waste' can be rendered into 'non-hazardous" by selecting a suitable physical or

chemical treatment or a combination of both.

Incompatible Wastes:

Incompatible wastes are those that produce effects, which are dangerous or harmful to personnel or environment when they are mixed with other wastes. The effects include heat or pressure, fire or explosion, toxic dusts, mists, fumes or gases and flammable fumes or gases.

Treatment.

Method or technique used to change the physical, chemical, and biological properties of wastes, handling the wastes, make use of the materials or energy therein, change the hazardous wastes to non or less hazardous wastes for safer transportation, storage and disposal thereof.

Disposal Dump:

Means or Utility used to dispose-wastes in environment friendly methods.

Waste Generating Department (WGD):

Any unit or department, which generates or becomes the main cause for the production thereof or who possesses the same.

Waste Handling Department (WHD)

Any unit or department, which handles or involves in handling/transporting the waste from KOC.

Recycling / Reusing:



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Any solid waste such as catalyst, papers etc. after sorting found to be useful for reusing

again.

Labelling:

Identifying the solid wastes after sorting it and by putting waste in containers with adhering labels to it. This label shows the full name of waste, source of generation and its classification whether it is hazardous or not.

Waste Profile Number:

It is a number created by KOC for easy identification of a waste. The number is

unique for a specific waste.

Waste Transporter:

It is the contractor or concerned KOC department who transports the KOC waste to Waste Management Site for disposal/treatment in compliance with K-EPA regulations.

Waste Management Contractor

It is the contractor who receives/stores/treats/disposes off the KOC waste in compliance with accepted environmental standards and K-EPA regulations. (Kuwait Environment Public Authority)

Waste Disposal Certificate (WDC)

This is a certificate/ computer print out issued by the Waste Management Contractor to ensure that the wastes taken from the waste generator has been disposed off in compliance with accepted environmental standards and K -EPA regulations.

Wastes Transportation Manifest (WTM):

This is the document to be filled in & carry along with while transporting solid waste from any KOC site to Waste Management Contractor's site or to any other disposal dumps. This document gives the details of the waste e.g. source, type, nature, quantity etc.



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19.5 TYPICAL WASTES LIKELY TO BE GENERATED AT KOC PROJECT SITE

a) Solid Wastes;

These will broadly cover the following.

o Cement, Sand, Bricks, Insulation material. Welding rods, Metal Scrap, Contents of Fire Extinguishers,

Canteen wastes, food wastes, Bandages, Cotton, Syringes from First Aid Room, Office Garbage, Broken

glass, Waste Papers, Wood Sacks/ Cartons, Civil Construction debris, empty drums. These are Non-Hazardous

Wastes. GULF SPIC will ensure the following:

o Retrieve any debris from the construction Site resulting from the execution of job on daily basis and shift

to the designated area for its storage.

o No Waste shall be disposed off in the open area resulting from GS scope off work. These are left in a clean

condition.

o All excavated areas are backfield and compacted resulting from GS's Scope of work,

o Meet or exceed the minimum environmental compliance criteria.

o Remove rubbish and waste from camp facilities.

o Provide temporary septic tank and maintain it all the time.

o Oily rags and other cotton clothes used to clean up spills will be taken from work place to the hazardous waste

container placed near the designated area for disposal.

o Grease residue, useless objects to which grease is stuck will be shifted to a suitable hazardous waste container

located near the designated area.

o Sand, soil, crushed stones accidentally polluted or mixed with oil/grease will be removed

from the workplace and taken to the designated hazardous waste storage area in a dedicated container for

disposal.

o Saw dust, grit or any other loose material used for cleaning up oil spillage will be shifted to designated

hazardous waste disposal area for disposal.

o Tins, Buckets containing residual paint, thinner, used paintbrushes, gloves will be shifted to the designated



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hazardous waste area in a dedicated container for suitable disposal,

b) LIQUID WASTES

These will broadly cover the following,

Engine oil, Diesel for D.G.Sets, Toilet Wastes, Sludge, oily Sludge from tank/ vessels

cleaning, waste grease, waste lubricants. These are Hazardous Wastes.

GS will ensure the following

o Construct storm water drains and process drains separately.

o Treat contaminated water and run off from process area and keep it separate from

uncontaminated and non-process water such as storm water run-off prior to discharge offsite.

o Ensure that wastewater treatment facilities are not impacted by flooding,

o Provide kerbing, paving, drains, sumps, cleanout flushing and waste collection system at the terminal,

o Provide fixed and permanent spillage containment and control facilities to preclude

environmentally damaging discharges of products utilized in construction activities & facilities

maintenance processes. Ensure that spillage containment facilities are adequate and meet the

minimum environmental compliance criteria,

o Design and construct the facilities to allow easy access of plant and equipment; the provision of

containing liquid spillage, and general housekeeping purposes; Fixed and permanent facilities to allow

the operating personnel to keep the facilities clean and tidy,

o For hydrostatic testing of pipelines/equipment, minimize the use of corrosion inhibitors, dyes; Use

low toxic chemicals wherever feasible. Provide MSDS for approval prior to the use of such chemicals.

o Reduce water usage by minimizing or recycling wastes wherever practical or feasible, Provide

imperviously lined facilities, spillage containment features and select materials of construction which

prevent the contamination of soils and ground water from chemicals.



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o As a minimum, all hydrocarbon or hydrocarbon bearing tankage storage area and chemical storage area be

suitably lined, consisting of a continuous membrane or concrete or suitable low maintenance material. In

Selecting the lining, bunding, system and materials, due consideration be made to mitigate the effects of

corrosion settlement and changes in ground water levels.

o Provide test / Inspection bore and facilities at project site where imperviously lined facilities are

required to allow monitoring of the integrity of these impervious facilities by operating personnel,

o Provide materials, design and construction of buried services, sumps and buried services, sumps

and buried equipment to prevent leakage and seepage of contaminants into the surrounding soil

and ground water.

.

o 'Provide sufficient lighting to aid in detection of oil spills at night at appropriate areas.

o Establish dedicated areas for the storage of materials and chemicals that are compatible with

surrounding activities.

o Freon or other chemicals used in or tapped from air-conditioning units will be taken and

collected in special tins located at the designated area.

o Used Engine oil will be collected in Dedicated Hazardous waste containers and shifted to

designated area.

o Conduct lab test of the waste as per the schedule approved by client

o Ensure all the hazardous waste is segregated, labeled & stored in designated area for disposal.

C) MONITORING AIR DISCHARGE;

These will broadly cover fugitive emission

GS will ensure the following

• Minimize atmospheric contamination from work area and air intake. Locate exhaust points to

� provide for rapid dispersion of atmospheric emissions.



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� Select Euro Engine for D.G. sets to ensure that all emissions from the exhaust comply with

� guidelines on emissions.

� Carry out workplace ambient air, % VOC & ionizing radiation monitoring as per the

schedule approved by client during all the stages of project including pre-commissioning &

commissioning to ensure that all the pollutants are within permissible limits. Provide

appropriate PPE's to operating staff.

� Utilize Dust Mitigation measures in dry. windy condition.

These include

.

• Spraying of water on all temporary roads at construction site.

• Provide dust masks to all workers at site.

19.6. PROCEDURE FOR SOLID WASTE MANAGEMENT:

Procedure for Solid Waste Management has been outlined as flowcharts given in Annexure-1 & 2 for Hazardous & Non-Hazardous wastes respectively.

19.6.1 WASTE SEGREGATION

Different types of waste shall be sorted & segregated for effective waste management.

Incompatible waste shall be managed so as to minimize cross-reaction or chemical incompatibility with each other to prevent mixing of waste in a manner that will produce dangerous or harmful effects e.g. 'Oxidizers' must be kept away from 'corrosives'.

19.6.2 WASTE PROFILE SHEET (WPS):

GS & their Sub contractors will obtain 'WPS number', which cross-refers to the Waste Profile Sheet for that given waste.

The importance of a WPS number is:



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• It facilitates safe handling and disposal of wastes. . • It acts as a data reference in case of emergencies such as spillage or uncontrolled

release of the waste.

• It is a requirement of K-EPA for off-site disposal of waste.

• It is a requirement of PAI (Public Authority for Industry) in NCC Waste

• Please refer to Annexure - 3 for "Waste Transportation Manifest. Profile Sheet" format.

LABELING'

The outlined procedure for labeling will ensure that any hazardous waste leaving KOC is clearly identified.

To facilitate safe identification of hazardous waste stored at KOC site for subsequent off-site management and disposal; standard waste identification and 'hazard warning' label will be put on each hazardous waste container (e.g. U.S. Department of Transportation 'DOT' labels as already widely used in Kuwait).

GS is responsible for ensuring that comprehensive and accurate identification labeling (as per standard practices) is in place before any transfer of custody of the hazardous waste to any other receiver or storage facility.

Each truckload of hazardous waste shall have'Safety placard'(i.e. Transport Road

Emergency 'TREM' card plus 'DOT labelling or National Fire Protection Association

'NFPA' fire safety hazard warning labelling indicating basic material data and hazard

properties) to ensure that emergency response crews arriving in the case of a road spillage

or similar accident can be aware of immediate risks during an emergency response.

If the hazardous waste is being transported onto public highways, it shall be ensured that TREM/ NFPA road safety placard is used.

19.6.3 WASTE TRACKING

All wastes transported from any KOC site for disposal, whether by flatbed vehicle in containers (drums, bags, bottles, intermediate bulk container, gas cylinder, pallet load, etc.) or in bulk (tipper trailer or dump truck for solids and semi-solids or vacuum tanker for liquids and sludge); shall be manifested



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Hazardous Waste: WTM needs to be filled & carried along with the waste for each vehicle load. Non-Hazardous Waste: A single WTM may be filled for the entire lot (more than a truck), if the entire lot is being moved out on the same day.

Refer Annexure - 4 for "KOC Waste Transportation Manifest".

WTM will Include adequate information of all the wastes carried by the vehicle such as their hazard characteristic (hazardous or non-hazardous), Chemical Names and/or KOC 'Waste Profile Numbers' when available.

Specific name of the waste shall be mentioned against the item#5 "Waste Description" of WTM instead of general name like "Liquid waste" etc.

M/s. NCC (National Cleaning Company), the present contractor provides its own Waste Transportation, Manifest (Refer Annexur-5). The concerned WGD/WHD shall use the NCC manifest* if the waste is to be transferred to PAI site. However, 'KOC Waste Transportation Manifest' shall be

used for transporting wastes to all other sites.

19.6.4 TRANSPORTATION, TREATMENT AND DISPOSAL

All possibilities will be explored to maximize the recycle/reuse/recovery of the waste generated at KOC. Suitable vendors shall be identified for metal reclamation from spent catalysts, oil recovery from oily sludge. Sale of certain wastes e.g. scrap metal shall be continued as being practiced in KOC.

Once the waste is identified, characterized & labeled, it shall be disposed to the appropriate Waste Disposal site by Waste Transporters.

All precautions, should be taken & relevant safety procedures should be followed while handling

hazardous wastes like Asbestos etc. WGD should promptly contact Environment Division-Refineries if any waste requires urgent management action or input to prevent environmental degradation. Urgent action could be



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required in case of leakage from container/vessel; accidental spillage, risk of uncontrolled release or any other factor that leads to

Controlled disposal of the aforementioned wastes shall take priority over the disposal of inert wastes to minimize exposure to hazard risks and effectiveness of waste management resources. WGD is responsible for this prioritization.

The Waste Management Contractor shall acknowledge the WTM for all Hazardous wastes. The original copy to be returned to WGD and a copy of the same shall be forwarded to Environment Division- Refineries.

Pre-treatment shall be done by the Wastes Management Contractor to render selected hazardous wastes into inert./stable and innocuous; prior to land filling.

WHO shall ensure that the Waste Management Contractor certifies that all hazardous wastes have been disposed off in compliance with accepted environmental standards and K-EPA regulations. This certificate issued by WMC shall be called as Waste Disposal Certificate (WDC). A sample WDC is enclosed as Annexure # 6.

In order to have an auditable waste management system, necessary record of documents such as a copy of WTM, WDC etc. shall be maintained by WHO & WGD in line with SHEMS requirements and regulations.

20.0. RESPONSIBILITIES

20.1 WASTE GENERATING DEPARTMENT.

Waste Generating Department shall:

• Follow best management practices to minimize, the generation of waste at source itself.

• Be responsible for the Safety of hazardous or non-hazardous wastes stored in its custody.

• Inform Environment Division-Refineries/, to enable environmental impact analysis, and an assessment of significant environmental aspects for any 'new' waste as and when it arises or may arise.

19.6.5 RECORDS



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• Make its personnel aware o f the hazardous characteristics of the wastes in order to protect manpower, and equipment from losses.

• Fill the KOC/ NCC "Waste Transportation Manifest" from items # 1 to 10 (except item #4) for all the wastes disposed off/ transported.

• Co-ordinate with Environment Division-Refineries to collect and provide a representative sample of any waste requiring analysis.

• Inspect and ensure (in association with Environment Division-Refineries) that Waste Management Contractor is managing the wastes in an environmentally acceptable manner.

• Contact Environment Division-Refineries if any waste requires urgent management action or input to prevent environmental degradation. Urgent action could be required in case of leakage from container/vessel; accidental spillage, risk of uncontrolled release or any other factor that leads to the waste requiring prioritized remedial action.

• Ensure that controlled disposal of the aforementioned wastes shall take priority over the disposal of Inert wastes in order to minimize exposure to hazard risks and maximize effectiveness of wastes management resources.

• Keep record of all the wastes generated from the department for audit. Records of the wastes handled by Admin Services (e.g. paper wastes, catering waste etc.) shall be kept by Admin services.

20.2 WASTE HANDLING DEPARTMENT

E&M Department-Refineries and Technical Services Division - LM (in coordination with Admin & Material Division-LM), are in-charge of routing of most of the wastes to external contractors. However, waste generated during construction/ commissioning of any project is being handled by Projects Department. Paper wastes, canteen wastes & other office wastes are being handled by Admin Services.

WASTE HANDLING'DEPARTMENT (WHD) SHALL:

• Use only K-EPA authorized transporters for transporting "Hazardous Waste".

• In association with WGD, ensure that solid wastes have been properly segregated. Special care should be taken for segregation of incompatible wastes.



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• Ensure that all hazardous wastes leaving KOC is properly labeled.

• Return the original copy of the WTM duly acknowledged by the Waste Management Contractor to WGD for all the hazardous wastes and a copy of the same to be forwarded to Environment Division-Refineries, A copy of manifest also to be kept by WHO as an auditable record.

• Ensure that Waste Transporters:

• Follow "Relevant Safety Procedure" while handling hazardous waste.

• Fill the details against items' ≠4 & ll of' WTM for both hazardous & non-hazardous

wastes.

• Carry the "filled-in" WTM with each truckload of hazardous waste. Also carry the

"filled-in" WTM with each lot of non-hazardous waste

• Ensure that each truckload of hazardous waste shall have 'Safety placard' (i.e. TREM card, 'DOT labeling, or "NFPA fire safety hazard warning labeling indicating basic material data and hazard properties).

• Check/witness the weight of the waste displayed at weighing machine at Waste Management Contractor's Site. In case of hazardous wastes, get the WTM acknowledged by the Waste Management Contractor.

• Obtain WDC on a regular basis from Wastes Management Contractor for all the hazardous wastes disposed/transported and forward the original to WGD and a copy of the same to Environment Division-Refineries.

• Forward tender document/contract agreement related to the following to Environment division for review:

Waste Management, transportation and handling

• Waste 'Auctions' (e.g. Oil sludge, catalyst, contaminated equipment, other waste

• solids and sludge etc.)

• Maintenance and turnaround , contracts involving industrial cleaning and

• hazardous materials handling (including all vacuum tanker service suppliers,



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• catalyst, handling contractors etc.)

• Contact Safety Division-Refineries for MSDS and Safety Procedures for handling any specific hazardous waste like Asbestos, sludge etc.

• Generate a consolidated report of various Wastes disposed off/ transported and

forward the report (in enclosed format -Annexure #7) to Environment Division on

monthly basis. Similarly, Technical. Services Division- LM will collect the data from

all the LM- divisions to. prepare a monthly waste data sheet for LM in a format

enclosed as Annexure -7. A copy of this sheet shall be forwarded to Operations

division for environmental records.

20.3 PROCESS ENGINEERING DIVISION-REFINERIES/ TECHNICAL SERVICES DIVISION- LM & ENGINEERING DIVISION -LM

• Process Engineering Division-Refineries/ Technical Services Division- LM & Engineering Division-LM shall:

• I) Advice practical methods to minimize waste generation at source. • II) Inform and consult Environment Division-Refineries on any process that is likely to generate

additional solid waste*

• III) Explore all the possibilities to maximize the recycle/ reuse/ recovery of the waste generated at KOC.

20.4 SAFETY & FIRE DIVISION- REFINERIES/ F&S SECTION- LM/ INSPECTION & SAFETY DIVISION - PROJECTS DEPARTMENT

• Safety & Fire Division-Refineries/ F&S Section - LM/ Inspection & Safety Division -Projects Department shall:

• Advise on waste container types, labeling and transportation 'placarding' in order to comply with national requirements and accepted standards; and screen transportation activities involving refinery waste Including but not limited to contingency planning, and Road Transport Emergency Data,' TREM' data for road spill incident, and controlled clean-up operations.

• Verify labels and transport placards etc. and inspect the condition of hazardous waste disposal containers prior to the transportation by WHD.

• Provide MSDS of all chemicals/catalysts being used at KOC.



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• Advise WHD on safety procedure to be followed while handling hazardous wastes.

20.5 ENVIRONMENT DIVISION-REFINERIES/ F&S SECTION- LM

Environment Division-Refineries/ F&S Section- LM shall :

• characterize the waste in consultation with WGD & Technical Services Department. And also create WPS for all types of solid wastes generated at KOC in co-ordination with other departments.

• Carry out monitoring of waste management records / procedures on a periodic basis.

• Advise on the hazardous characteristics of wastes and their preferred disposal mechanism, upon request from KOC departments.

• manifest number issued to any department.

• Exercise 'due diligence1 through periodically auditing the Contractor's waste management facilities in order to prevent1 liability issues. Findings' of audit shall be reported to the management.

• Review the terms and conditions of the Service Contracts related to wastes management or environmental services and to advise on environmental impacts, due diligence, best practice, significant aspects and 'environmental liability' Issues.

• Ensure in co-ordination with WHD & WGD that Waste Management Contractor

• Adopts the techniques to ensure that 'best practice' is being followed to minimize liability risks to KOC and ensures that all environmental regulations guidelines and Kuwait Laws are being compiled with.

• Modifies and improves its operational practices and procedures to ensure long-term environmental safety for KOC waste passed into the Contractor's custody, should KOC have concerns or valid engineering and scientific reasons for making such a request.



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• Develop a 'Closure Plan' for managing the environmental effects of wastes arising from the closure of refinery/ LM controlled sites used for waste management, on case-to-case basis.

• Update this procedure based on any change, in the solid waste management practices at KOC or K-EPA regulations or' SHEM ‘s requirements.

20.6 LABORATORY

• KOC Laboratory shall analyze both routine and non-routine waste samples if 'needed based on request from Waste Generating Department/ Environment Division/ Technical Services.

• Gulf Spic will comply with the following Environment Requirements

21.0 ENVRIONMANTAL COMPLIANCE:

• Environment compliance management can be used to ensure the effective

• implementation of environment protection principles. Compliance management • range from providing guidance that promote

• Understanding of environmental requirements across all levels of organization to

• conducting audits of specific jobs to determine the

• Level of compliance and reason for non- compliance

• Environment compliance shall be as follows;

• Implementation of good management practices through planning and

commitment to environmental issues



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• Performing environmental compliance audits to achieve better Environment

standards

• Prevent or minimize all forms of pollution

• Minimize disturbance of the natural environment

• Develop waste management practices based on prevention, minimization or disposal of waste

• comply with all applicable laws , .regulations.., standards and guidelines for the protection of the

environment

• Conducting risk assessment

• Developing and disseminating guidance to the non- Environment Health and Safety

professional.

• Developing and conducting standard and customized training with regard to environmental

obligations

22.0. ENVIONMENT RESOURCES DUE DILIGENCE:

GS will focus on identifying and characteristic significant potential environment, health and safety liabilities 'associated with our work site. Environmental site assessments are typically undertaken in order to further characterize the nature and extent of potential contamination specifically those relating to soil, air, noise and water.

Gs will take the following remedial measures to overcome the environmental liabilities: > Evaluate operation and future needs

> Identify area of concern

> Develop risk scenarios

> Define action to reduce liabilities

GS will ensure proper monitoring of work environment and also put effort to make everyone understand the environmental risk that need to be managed and thus preserve the harmful



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impacts on our health and environment!:

23.0. ENVIRONMENTAL RISK ASSESSMENTS:

> Environmental risk assessment comprises a set of tools for characterizing the likelihood and magnitude of adverse effects to human health and natural resources posed by environmental agents

> Environmental Risk Assessments are a legal requirement for an activity that could potentially cause damage to the environment or to human health . . , .

> Gulf Spic will conduct Environmental risk assessment for various hazardous jobs which will be harmful to environment and human health and Environment risk assessment will be applied to

> Contaminated land issues

> Air quality

> Ecological Risks

> Radiological risks

> Health risk

24.0 ENVIRONMENT ROLES AND RESPONSIBILITIES:

GS will responsible for environmental control on site during the construction period. The roles and responsibilities of key personnel with regards to environ mental management are identified below

24.1 PROJECT MANAGER

> Responsible for ensuring that the over all projects executed fully in accordance with the

environmental requirement.

> Ensuring the environmental standard of the client met in full accordance of the client at all

times > Ensuring the provision for waste disposal in a safe manner in accordance with client

requirement > To lead environmental inspections, assessment and audits in cooperation with HSE

management



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24.2. SITE SAFETY SUPERVISOR

> Ensure that all site personnel have Basic level of environmental knowledge by conducting

environmental induction program

> To conduct all environmental inspections, assessments and audits

> To ensure the housekeeping in the work area is of higher standard

> To cary out environmental prevention and response plan.

> Ensure all preventive measures to minimize air emission and Noise mitigation.

> To report all environmental incidents to the management and to the client.



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24.3 EMPLOYEE:

> The employee shall cooperate in the promotion of safe environment by following

environmental rules and regulation

> Report all environmental incidents to immediate supervisor

> An employee shall not report to work while under the influence of liquor or drugs and no

employee shall carry intoxicating liquid or drugs

> Garbage, kitchen water and other water waste must be deposited in proper receptacles

provided for this purpose

> Employees shall keep their work area clean and tidy

24.4 ENVIRONMENT DESIGN AND OPERABILITY

The contractor shall perform a process HAZOP analysis of the completed design of the Facilities, including all significant Vendor package. The analysis shall be in full compliance with the latest edition of the API Recommended Practices and shall be performed by a team of knowledge personnel in engineering operations, process-design and other specialists as deemed appropriate.

24.5. PROCURMENT AND CONTRACT MANAGEMENT

> GS will ensure the environmental standard of the client met in full accordance of the client

at all times during materials procurement for the project.

> GS QA/QC Dept. shall conform the material quality through Material Test Certificates

MTC produced by material supplier.

> Ensuring the provision for waste disposal in a safe manner in accordance with

client Requirement

> GS shall be managed the contract by well qualified and experienced persons and manpower

25.0. ENVIRONMENTAL DOCUMENTATION & CONTROL

All environmental document will be maintained at the site office include the following:

> Environment management plan



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> List of hazardous material

> Applicable MSDS sheets

> Environmental performance reports.

GS shall communicate the EMS activities by cln^uctttig regular face to face EH&S meeting between GS and Client personnel. These meeting shall be on a weekly and monthly basis. In this meeting shall be discussed and submitted the EH&S performance and statistics monthly basis. Corrective Action shall be taken as per EH&S reports

25.1. ENVIRONMENTAL TRAINING

Gulf spic will conduct environment-training program prior to the commencement of the job. The facilitator will discuss about the environmental hazards and preventive measures in the time of meeting and the training program will be documented

25.2 ENVIRONMENTAL INSPECTIONS, ASSESSMENT AND AUDITS

Gulf spic monitors its environmental compliance on a continuous basis and operates under a environment management system. Regular voluntary internal audits and spot checks are undertaken by GS HSE section. Non-Conformances are managed through an Internal reporting system and corrective action is taken to remedy any such non-confor

During the construction and operation GS HSE person would conduct environmental audits according to the checklist attached with EMP plan

The audit would be based on the available information and observation

25.3. ENVIRONMENTAL PERFORMANCE REPORTING

EPR will be maintained by GS in order to follow-up the environmental compliance which includes the following ;

> Total Number of employees at the site

> Details of waste water generation ; '

> Details solids or semisolids waste

> Details of environmental incident

> Details of environmental awareness and training programs



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26.1. EMISSIONS TO ATMOSPHERE

It is inevitable that construction activities will result in the emission to atmosphere of gaseous wastes such as the combustion products of internal combustion engines. These emissions will be minimized

by the careful maintenance of machineries and vehicles.

Emissions of significant quantities of smoke will not be tolerated. This will be achieved by equipment maintenance, and where necessary the removal of polluting plant from the site. Every effort will be made to minimize any impact from dust during construction activities.

26.2. NOISE MITIGATION

Engineering controls shall be implemented whenever possible to eliminate or reduce employee noise

exposure levels that exceed 80 decibels over an eight-hour time weighted average. Examples of

engineering controls are:

noise barriers/deflectors installed around areas where jack-hammering is in progress to reduce noise

exposure levels to employees working in surrounding areas;

additional insulation installed in partition walls between shops and offices.

Keeping the Noise making Equipment like Diesel generator and Welding generator away from

the work places and Offices.

All GS vehicles and equipments will be properly maintained to reduce unnecessary noise.

27.0 ENVIRONMENT INCIDENT PREVENTION AND RESPONSE

This section summarizes the environmental incident prevention and response generated in course of construction activities and shall be performed in full compliance with the contract.

GS management, staff and personnel have the responsibility to ensure pollution controls practiced on every project. However GS construction team shall ensure to comply with environmental incident prevention and response for construction.

27.1. OIL SPILL CONTROL.



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Gs will comply with the land oil spill control, " Leak and spill reporting".

Any recovered hydrocarbon or Hydrocarbon contaminated material will be properly disposed as per the requirement.

Concreted and bunded shed shall be provided for storage of the Oil and Diesel.

27.2. REFUELING OF VEHICLES

Refueling of equipments and vehicles at the site shall be from proper tankers with distribution nozzles.

27.3. HYDRO TEST

Hydro test shall be in accordance with pipeline hydro test water disposal, Hydrostatic Fluids and Lay-up procedures, Disposal of waste water from cleaning, flushing and hydrostatic test. The hydro tested water shall be collected in drum and Disposed as per the Waste disposal procedure

27.4. DUST CONTROL

Dust Control shall be accomplished by properly wetting all work area prior to commencing of work or other approved measures. Works shall be taken in shaded area according to the climate conditions

28.0. WASTE MANAGEMENT

Assist Contractor personnel and their Sub Contractor in managing. Every effort will be made to minimize the amount of non-reusable waste generated by project activities. This will largely be achieved by careful identification of materials required so as to minimize excess.

The general cleanness of the site and compliance with waste disposal requirements .

outlined will form part of site inspection.

The waste management program is developed for adequate response to potential environmental impact during the construction operations led by GS (Sub contractor) related to the project.

The waste management program is designed as a Project wide reference in effective waste handling & disposal and provides a set of guidelines for general Project use.

The waste management program is based on the following principle:



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> their waste effectively and applicable waste regulations.

> Provide proper guidance for the handling of each waste generated during construction Operations to protect human health and to minimize the impact on the environment.

> Disposal of all waste in a safe manner. > Form a basis for training, evaluation, monitoring and pollution

prevention Program

> Control the amount of waste generated by reducing waste at source through good operating practices and implementing waste reduction principle.

> Recycle, reuse and recovery of waste whenever possible.

> Be periodically reviewed and updated as new practices and options are discovered.

Scrap metal (sheet metals, nails, tins) will be stored in a designated scrap metal container ( e.g.;

a skip)

When the scrap metal container is full, the scrap metal collected will be transferred to an

appropriate disposal site Chemicals used on site will be managed according to their material safety data sheets.

On completion of the construction, all leftover .construction materials will be

Removed from the work area

29.0. WATER MANAGEMENT

Storm water runoff will be controlled ;so, that discharged water quality will meet the quality of the receiving water. Rain water will be diverted as much as possible from flowing across the cleared areas by means of interceptor trenches upstream of the construction or it will be channeled. Interceptor trenches will be designed to minimize erosion. Drainage will be re-routed to the natural drainage system. Sediment retention will be provided, as needed, during construction to reduce or prevent silt transport from the cleared areas to the drainage.

30.0. START-UP AND COMMISSIONING:

GS will provide proper guidance for the handling of each chemicals and equipments during Start -



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up and Commissioning Operations to protect human health and to minimize the impact on the environment by closed venting and draining system. GS will give training to the employees on all part of HSE and awareness of MSDS.



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31.0. RESTORATION AND CLOSE OUT

Site completion will be documented through a final close out report. Final close out report

compliance with clients requirements and provides a consolidated record of all removal and

remedial actions for the entire site. The final close out report describes how the clean up was

accomplished. The site completion will signifies the end of all response actions and will ensure that

the response actions at the site were successes and no further superfund response is required to

protect human health and environment. .

It is. the endeavor of GS to ensure restoration of land surface and landform consistent with the conditions and contours prior to commencement of construction.

After completion of and handing over the project to KOC, GS will demobilize, clear the project site and terminate its operations. Therewith potential impact on the environment will cease to exit.



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32.0. ATTACHMENTS (Environmental Management Plan)



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1.ATTACHMENT

Gulf Spic Contracting company W.L.L

EIA Compliance check list CHECK LIST FOR MONITORING

NOISE LEVEL AT SITE

DATE

NOISE LEVEL

READINGS AT

INITIAL

OBSERVATION

LEVEL

NOISE LEVEL

READINGS AT INTERMITTENT OBSERVATION LEVEL

ACTION TAKEN

REMARKS

PROJECT:

SITE:

REPORT NO:

GULFSPIC

SAFETY ENGINEER/SUP, CLIENT

ENVIRONMENT ENGINEER



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ATTACHMENT - 2

ENVIRONMENTAL PERFORMANCE REPORT

B) Details of Solid / Semisolid Waste.

Hazardous Waste:

Non-HAZ Waste; Food Waste;

C) Environmental Incident:

No. of Incidents

Cumulative^. Incidents

•> Incident Details-

Remarks/ Action Taken

Air Pollution Water Pollution Oil spills Remarks;

D) Environmental Awareness Training to Employees

For(Month-Yr.)

Contractor

Contract / Project

1

No. of Employee

Cont.#

Start Date:

End Date |

Details of Waste Water Generation

For the month (KL) Cumulative Disposal/Discharge Location

Industrial:

Sewage:

Remarks:



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Name of Training Conducted

No. of Employees Covered for the month

No. of Employees covered for the year Remarks

E) Others details if any :

Contract Project Manager HSE Engineer, GS

Signature Signature



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ATTACHMENT – 3

ENVIRONMENTAL RISK ASSESSMENT TABLE

Name of Site:

Prepared by:

Serial

No

Action Environmental Risk Protective

Measures (to

minimize risk)

Emergency / Spill response /

rehabilitation measures



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ATTACHMENT -4

Operational Control Procedures for Significant spects

A Emission to Air

Sr.No Activity Control Procedure

Al

Painting of structures & vessels

Use of PPE by painter, barricades to avoid unauthorized entry


Bl

Hydro testing

The Hydro tested water to be pretreated & sent to KEPA authorized

contractor for disposal if required.

Sr.No

Activity Control Procedure

Cl

Operating printers / photocopy machines

Printer / Photocopy cartridge generated in office to be sent back to

supplier for recycling

C2

Welding activity

Welding electrode, butts ;to be collected & disposed as haz. Waste at designated bin at site ' " Metal scrap/ used grinding wheel to be disposed as non-industrial waste. Required PPE's shall be used for protection against fumes, radiation etc.

C3

Grinding

The metal dust generated due to grinding to be collected and disposed off as hazardous waste. Ensure proper cordoning of area to avoid metal dust generated from grinding to contaminate

the soil. Collection & disposal of metal dust as perprocedures, use of PPE.

C4

Painting of structures / vessels.

B. Water Contamination

C. Land Contamination:



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C5

Civil Work

Contaminated excavated soil & waste asphalt to be handled & disposed as per waste disposal procedure approved by KNPC

C6

Electrical works

Generation of old cut cables, scrap lighting tools to be collected & disposed as per Waste Management Disposal Procedure 01 (WMDP-01)


Dl

Hydro testing

1. Used water to be recycled where feasible. 2. Feasibility of using alternate methods in stead of hydro

testing to be studied.


El

Grit blasting

Barricading shall be done. Use of required PPE for all workers Noise monitoring on periodical basis to check the noise.

Sr.No

Activity Control Procedure

Fl

Radiographic testing

All empty bins of developer, dye etc to disposed off as hazardous waste During radiography, radiation area to be cordoned off, check the radiation at site losing meter, the radiation level outside the barricading must be less than 0.25 mrh. Use of PPE (film badges, dosimeter to be used by person engaged in radiography) & monitor badges.



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ATTACHMENT – 5

ENVIRONMENTAL AUDIT CHECK-LIST SERIAL

NO

DESCRIPTION YES

NO

REMARKS

1 ENVIRONMENT EDUCATION AND AWARENESS

a

Do all site personnel have basic level of environmental awareness

training

b

Is site provided with safety posters to enhance environmental

awareness

c

Do specific craft related course to environment given to the workers.

d

Are employees aware of the MSDS of the hazardous material used in

the work site

2

POLLUTION CONTROL

a

Are appropriate dust suppression measures available

b

Are all vehicles and equipments well maintained in order to avoid oil

spillage and environmental pollution

c

Are proper engineering controls been arranged to controls the dust pollution

d

Are proper preventive measures been taken to avoid noise pollution

e

Are Proper PPE s provided to minimize environmental impact on human health.

f

Are the level of hazardous gas(H2S ) been monitored periodically

g

Are all vehicles and equipments refueled at the proper designated area

Water & waste management

a

Is Potable water available from an existing supply .

b Is Potable water available at different convenient work location



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c

Do all waste water and contaminated water channeled into proper waste water management system

d

Do all sediments from the waste water system disposed at permitted disposal site ' !

e

Are adequate number of waste receptacles available at various location of construction activities

f

Are clear identification been given on the receptacles to recognize hazardous material

g

Are scrap metals stored in a designated scrap container

Are hazardous substances, clean up materiaLtransferred to an

h appropriate disposal site on regular basis

i Are house keeping done for all areas after the completion of work

j

Are portable toilet emptied on regular basis

4 HANDLING AND STORAGE

a

Are handling and storage of hazardous substances been done in accordance with MSDS

b Are hazardous and flammable materials stored in proper identified area

5 SPILLS OF OIL/HAZARDOUS MATERIAL

a

Are accidental spillage / negligent spillage of oil or hazardous substance cleaned up with proper methods

b

Are all equipments provided with water tight drip in order to avoid leak on an impermeable surface

c Are drip trays cleaned up regularly

d Are chemicals collected in drip trays disposed in appropriate manner

e

Are all waste water and polluter runoff from contaminated area channeled into collection sump

6

PERSONAL PROTECTIVE EQUIPMENT

a

Proper helmets provided and used

b

Safety shoes provided and used /undamaged



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c

Boiler suits used / not damaged :

d

Hand gloves proper / not damaged, being used

e

Ear muffs / plugs used wherever necessary

f

Welding PPE used

h Safety glasses/Goggles available and being used for appropriate jobs

7 HOUSE KEEPING

a

Garbage, debris scrap removed

b

Unused scaffolds and their materials removed .

c

Hoses and left-over materials removed

d

Oily rags, lagging, used chemical drums etc. removed

e

Trash bins/drums/other disposal facilities provided

8 HEALTH & HYGIENE

a Drinking water facility proper

b Washing facility proper and sufficient

c

Toilets proper and clean

d

Rest room / shelter clean and hygiene

e Dresses / PPE / Tools kept properly and orderly

f

First Aid Box available with all required .



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Client: KOC


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NON HAZARDOUS WASTE MANAGEMENT FLOW-CHART



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Reports to Management / KOC

ATTACHMENT - 7

KOC WASTE PROFILE SHEET ('WPS')

WPS NUMBER (Allocated by Environment Division)

General information Date of WPS

Dept. Source of Waste Refinery : /other

Dept, Contact Name Location of Waste

Phone #

Contact Person

Name and Source of Waste

1, Name of Waste

2. MSDS available? 3MSDS#? :

4. Describe the process generating waste

Physical Characteristics of the Material

1 . Colour

2. Physical state now Solid? Liquid ? Semi-Solid? Powder? Mixed Phase? Others

3. Odour?

Describe: j . . 1 ,.. ;-., - - . , •

4. Approximate Density?/ specific gravity(If known)

5. Free liquids? Or dry?

Liquids?

Dry?



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pH ? acid? D alkaline? a Neutral? a pH value if representative sample has been tested,

Material Composition (if known)

Range

Minimum% Maximum%

TDS (Water soluble %)

TSS

Alumina / Inert solids

Metals in the material? Yes? % or ppm (if known)

Lead (as TEL, TML, oxides etc)?

Nickel (inc oxides or salts)

Nickel (Inc oxides or salts)?

Cobalt (Inc oxides etc)?

Molybdenum (oxides etc)?

Chrome (or oxides etc)? . .

Vanadium (oxides etc)?

Zinc (including oxides etc)?

Arsenic?

Palladium/platinum? (eq. FCC cat)

Other metals known or suspected?

Environmental hazard characteristics

Toxic? Reactive? Explosive

Corrosive? Irritant? Flammable?

Ignitable? Carcinogenic? pyrophoric?

Radioactive? Shock-sensitive? mutagenic?

Teratogenic? Bio-hazard/infectious? Other?

Sample Plan

Documents

Transcript of Sample Plan