COMMUNITY AFFAIRS, HEALTH, SAFETY, ENVIRONMENT AND

SECURITY PLAN

AUTHORIZED BY:

____________________

Managing Director/CEO

Issue Date: 15 TH JUNE 2009

Revision Date: ____N/A_____

Revision Level: ____N/A_____

PROJECT TITLE:

CLIENT:

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QUALITY POLICY STATEMENT

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“We are committed to producing high quality steel fabricated products and engineering services that consistently satisfy customer requirements, while

complying with the requirements of ISO 9001:2000 QMS.

We achieve these through the efficient use of resources, confidence building amongst our stakeholders and

continual improvement of the system.”

MD/CEO

HEALTH, SAFETY & ENVIRONMENT POLICY

The company believes that good HSE performance is an integral part of efficient and profitable business management and therefore committed to executing its activities to ensure safe and healthy working environment for all employees and the safety of persons living in the vicinity of the installation. The company’s goal of no major incident in every project will be achieved by maintaining proactive HSE programs designed to prevent Accidents and Incidents. To achieve this, the company is guided by the following principles;

- HSE is of equal importance as other business activities- No activity shall be carried out unless considered safe- Safeguard the health and safety of all employees,

contractors and third parties- Minimize the impact of activities on the environment.- Maintain good relationship with host communities and all

stakeholders.- Enhance security of life and equipment- Belief that “Every job could be safely done” - Effective communication of HSE requirements and results

to all stakeholders- Compliance with all relevant HSE legislations and

requirements.- Continual improvement of the HSE system.

MD/CEO

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TABLE OF CONTENTS

S/N

PAGE

1 GENERAL INFORMATION1.1 Purpose1.2 Scope1.3 References1.4 Acronyms and Abbreviations

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2 RESPONSIBILITY FOR COMPLIANCE 9

3 HSE OBJECTIVES AND PROGRAMS3.1 Objectives and Targets3.2 Our Programs3.3 Community Relations Policy3.4 Health 3.4.1 First Aid 3.4.2 General Rules in an emergency 3.4.3 General Rules for Burns3.5 Safety 3.5.1 Management Responsibility 3.5.2 Fire Fighting Procedure 3.5.3 Hazards 3.5.4 Personal Protective Equipments (PPE) 3.5.5 Factory Safety Rules 3.5.6 Safety on Sites 3.5.6.1 Works Permits and Clients safety requirements 3.5.6.2 The company’s fabrication responsibility 3.5.6.3 Sub-Contractors (Steel Erector responsibility) 3.5.6.4 Workers orientation 3.5.6.5 Personal Protective Equipments (PPE) 3.5.6.6 Lifting and Handling Loads3.6 Environment 3.6.1 Factory Environment 3.6.2 Erection Sites

9991010111111111212121313141415151516161616

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4 HSE PERFORMANCE MEASUREMENT4.1 HSE Metrics4.2 HSE Incentives4.3 Punitive Measures

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5 ACCIDENT PREVENTION AND MANAGEMENT5.1 Accident Reporting and Investigation5.2 Accident Prevention

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6 SECURITY 18

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7 AUDIT, REVIEW AND INSPECTION 19

8 HSE COMMUNICATION 19

9 HSE DOCUMENTATION 19

10 HSE TRAINING 20

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1.GENERAL INFORMATION

1.1 PURPOSE

The purpose of this Health, Safety and Environment plan is to s ensure that we carry out appropriate actions to comply with all applicable regulations governing construction, general industry, and client’s requirements and to provide a standard procedure for all work activities necessary for the enforcement of health and safety policy, for conducting safety audits and reporting to supervision.-Provide a standard method of reporting occupational injury, illness or fatality to client. -Provide a standard method for storage and disposal of hazardous waste in accordance with statutory requirements.-Provide a basic outline for the company and client required employee trainee and documentation.-Provide a basic outline for the establishment of site medical and sanitation facilities and arrangement of outside medical backup.-Provide for basic fire prevention program and ensure that hazardous, flammable and combustible materials are handled and stored in accordance with applicable standards.-Ensure that all required written procedures are in place and conform to all required regulations.-Eliminate or reduce personal injury and damage to properties, materials and equipments.

1.2 SCOPE

The scope of this Health, Safety and Environment manual include; activities within the company’s premises, Erection sites and all other areas where the services of the company are implied.

1.3 REFERENCES

HEALTH, SAFETY & ENVIRONMENT MANUAL QUALITY MANUAL, STANDARD OPERATING PROCEDURE, SITE ERECTION MANUAL CASHES

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1.4 ACRONYMS AND ABBREVIATIONS

ARMECO - AREWA METAL CONTAINERS LIMITED GM - GENERAL MANAGER HOD - HEAD OF DEPARTMENT DCE - DESIGN & COST ENGINEER HSE - HEALTH, SAFETY AND ENVIRONMENT MD/CEO - MANAGING DIRECTOR/CHIEF EXECUTIVE HQA/QC - HEAD, QUALITY ASSURANCE/QUALITY CONTROL` JSA - JOB SAFETY ANALYSIS ALARP - AS LOW AS REASONABLY POSSIBLE CLOs - COMMUNITY LIAISON OFFICERS MSDS - MATERIAL SAFETY DATA SHEET LTI - LOST TIME INJURY QHSE - QUALITY HEALTH SAFETY AND ENVIRONMENT CASHES - COMMUNITY AFFAIRS, SAFETY, HEALTH,

ENVIRONMENT AND SECURITY

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2. RESPONSIBILITY FOR COMPLIANCE

The MD/CEO is responsible for ensuring that the entire workforce of the company and our appointed sub-contractors follow the HSE guidelines.

The HSE Manager is responsible for ensuring that HSE guidelines are followed within the factory.

For projects and erection sites, the site engineer will review the HSE guidelines and adapt to suit present work conditions for Project Safety Plan. The site engineer will also relate with the GM Operations with a view to constantly check the sufficiency of the safety guidelines adopted.

3. HSE OBJECTIVES AND PROGRAMS

This program details the guidelines for ensuring safety of personnel, care of materials, safe handling and operation of equipments, safe working habits and Environmental consciousness or awareness.

3.1 Our Objectives and Targets

Always review and improve on our past Health, Safety and Environment performance

To ensure that all statutory safety requirements relating to the industry are complied with

To prevent accidents at work Reduce work related injuries To develop changes in the attitudes of the employees and obtain their

cooperation for safe work practices Improve in Health and Welfare of our own and subcontractors staff Increase security awareness amongst our own/subcontractors staff Preserve the environmental resources.

.3.2 Our Programs

The following programs are aimed at achieving our objectives and targets.

All staff will undergo induction training on their first day of work. This will be enhanced and reinforced through daily toolbox meetings.

All equipment to be deployed to the project shall be subjected to pre-mobilization process and certified.

All technical personnel on the project shall be certified to possess appropriate professional competence.

All key operations shall be subjected to hazard analysis and appropriate controls shall be implemented during execution.

Plans and procedures shall be put in place to respond to any emergency or loss of control.

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Scheduled audits, inspections, drills for emergency preparedness and other programs as a continuous machinery for identifying hazards, unsafe acts and conditions at the work place shall be carried out.

Rewards and sanctions scheme will be introduced to ensure compliance with safety and health rules, regulations and safe work practices.

3.3 Community Relations Policy

It is the company’s policy to maintain mutually beneficial relationships with host communities.To achieve this goal, the company will cooperate with and work through the site engineer and the CLOs in the local communities to ensure that the local communities are aware of the company activities and to ensure that any conflicts are resolved in a timely manner.

3.4 Health

The Health and Safety at work Act of 1974 (Applicable in Nigeria) require all employers to ensure so far as is reasonably practicable that the Health, Safety and well being are properly preserved and protected. The company will operate a healthy workplace with no health incidents and improve the health awareness of its employees.

This will remain the Watchwords of the company’s management. To achieve personal healthiness, the following shall be observed by all employees on site;

i. Construction materials and equipments shall be appraised to control health risks. Those proven or known to be injurious to health shall be discarded or minimized with the use of MSDS control.

ii. Handling of toxic materials or chemicals may result in serious skin disorder, hence hands must be protected by wearing appropriate hand gloves before handling toxic metals or chemicals.

iii. All overalls or personal clothing must be clean and free from harmful or poisonous substances. If clothes are contaminated, they should be removed and laundered immediately.

iv. Hands should be washed thoroughly after using the toilet.v. Hands should be washed thoroughly before touching anything meant to be

eaten.vi. All wounds or cuts must be reported to the medical personnel or site

engineer who will treat or arrange for treatment appropriately.vii. First aid boxes will be fully equipped and monitored regularly. All medical

and first aid cases will be properly recorded. All illness must be reported to the medical personnel or the site engineer.

viii. All work areas and toilets must be kept clean at all times. Toilets must be swept and washed regularly at convenient intervals. Refuse bins must be located outdoors and covered properly.

ix. There shall be no smoking in the work place, site or office premises.x. Ensure compliance and enforcement of the prevailing alcohol and drug

law.xi. Ensure that all personnel, both in the factory and on site are medically fit.

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3.4.1 First AidThis is the immediate help provided to an injured or seriously ill person before proper medical attention can be reached. This shall be available in the factory and at the site. Only qualified personnel who have received basic training in first aid procedures will administer the first aid.

3.4.2 General Rules in an EmergencyAn emergency occurs when an accident leads to severe bleeding, cuts, fractures, failure to breath, extensive burns, broken bones e.t.c. In the event of any of the above, the following General Rules will apply

i. Find out if the injured is bleeding, stop the bleeding.ii. Find out if unconscious person is breathing, if not start artificial respiration

at once.iii. Do not permit an injured person to sit up or stand until you know how

serious.iv. Do not move injured person until you are sure it can be done safely.v. Do not give liquid to an unconscious person.vi. Keep calm, act quickly, quietly keep by-standers away.

3.4.3 General Rules For BurnsIn the event of burn of any nature;

i. Cut clothing from around burned part, do not pull it.ii. If blisters are present, do not break or prick them.iii. If burned area is large, call a physician immediately.iv. Do not apply substance such as grease or salve on burned area.v. Treat for shock in cases of severe burns.

3.5 SAFETY

All safety policies shall be implemented by all staff and subcontractors and will be enforced by GM Operation and site engineer in conjunction with top management.

3.5.1 Management Responsibility

i. Develop guidance by which a safety program will be carried out in all spheres.

ii. Ensure that all safety policies are understood and carried out by all personnel.

iii. Ensure that safety warning signs and checklist are in placeiv. Ensure that newly hired employees and subcontractors staff undergo

training on safety before commencement of work.v. Analyse new projects and jobs for SAFETY. JSA of all jobs must be

properly documented.vi. Ensure that all personnel in factory and on sites use protective wears

required of them. Personnel must be familiar with equipment or instrument before operating them.

vii. Review safety program periodically.

3.5.2. Fire Fighting Procedure

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In case fire is observed, then the following procedure should be initiated.i. Raise an alarm by shouting “fire, “fire, “fire”. Call fire serviceii. Try to fight fire safely using the available extinguisher, ensuring you have

positioned close to the exit for a quick and safe retreat.iii. Move quickly (not running) to mustering pointiv. Take roll callv. Do not re-enter fire area until told to do so.

Remember life is more valuable than any worldly possessions

3.5.3 Hazards

These are conditions with potentials of causing injuries to personnel, damage to equipment and loss of material. All hazardous areas shall have markings to identify nature of hazards and type of preventive, protection and /or precautionary action required.

Hazard checklist All works shall be examined to see which of the following hazards exist or likely to Occur;

i. Sudden acceleration and motionii. Chemical reactioniii. Corrosioniv. Electrical leakagev. Electrical explosionvi. Electric shockvii. Fireviii. Heat/temperature impact and shockix. Pressurex. Radiation structural damagexi. Stress concentrationxii. Toxicityxiii. Vibration and noisexiv. Power source failure

Corrective measures will be put in place to reduce or eliminate the hazard.

3.5.4 Personal Protective Equipments (PPE)

In addition to all safety measures being observed, there is need to protect the worker from hazardous situation.

The guidelines include;

i. Establish the need for them by operational/professional requirement, previous recorded accidents, safety audit, legal requirements and susceptibility of individuals.

ii. Select equipment based on quality, durability, suitability, non interference and appearance and general compliance to international standards.

iii. Provide equipmentsiv. Enforce their use.

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Notes: o Hard hats should be worn reversed only if they are specifically designed

and approved by the manufacturer for that purpose.o Trouser legs and laces must be tied or taped to avoid tripping hazards.

3.5.5 Factory Safety Rules

In addition to general compliance with Health, Safety and Environment company wide,

The following rules also apply in the factory;

i. All workers must follow instructions. No short cuts. If in doubt, ask.ii. Report immediately any condition or practice that might cause injury to

employees or damage to equipment.iii. Put everything in its proper place. Keep work areas tidy and clean.iv. Use the right tools and equipments for the job and use them safely.v. Any accident involving a person or equipment no matter how minor should

be reported promptly. Get First Aid promptly.vi. Use, adjust, alter or repair equipment only when authorized.vii. Wear approved personal protective equipment/kit as directed. Keep it in

good condition. Eye protection must be worn at all times on jobs or in areas where

danger to the eyes is present. Footwear safety shoes are mandatory for all jobs where heavy

lifting and manual work is carried out. Head protection helmet or hard hat or other headgear must be worn

when on motor bikes or when working with cranes or areas of overhead movement of tools and materials or when specifically required by the safety regulations.

Protective clothing wears e.g. gloves, apron, booths and some specialized clothing equipment must be worn as required.

viii. Avoid distracting others. Do not indulge in horseplay.ix. When lifting, bend your knees, grasp the load firmly and then raise the

load, keeping your back as straight as possible. Get help on heavy loads.x. Obey all rules, signs and instructions.

3.5.6 Safety on Sites Every individual working on sites shall take responsibility for safe work

practices, regardless of job title. SAFETY is everyone’s responsibility.

Before start of work, all workers shall attend a structural steel erection best practice Review for the project.

Weekly safety meetings shall be held and sub-contractor shall be kept informed in writing about discussions and issues that may affect safe erection of steel e.g. weather conditions such as wind, access and site conditions.

3.5.6.1 Work Permits and Client’s Safety Requirements

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Works performed on certain sites require endorsement of work permit by both

parties before commencement while other sites may require validation test by the client to confirm our safety method and work process before

commencement.

This is to ensure that all concerned know the implication of the job at hand as it concerns SAFETY requirements.

Potentially hazardous areas such as; Oil Fields, Petroleum Product and Refining plants, Electrical Distribution system, Toxic Flammable liquid/ gas storage areas require extreme attention to details while filling the work permit.

If conditions are adverse, the work permit will not be signed till conditions improve or adequate safety measures are in place that do not compromise our SAFETY standards.

If during the work, conditions change and become unsafe then the work must stop. While the client’s representative is advised accordingly.

3.5.6.2 The company’s Fabrication Responsibility

The company shall be responsible for:i. Providing detailed connection information to ensure that the structure can

be safely erected.ii. Providing where required, safety attachments or anchor points

3.5.6.3 Sub-Contractor’s (Steel Erector) Responsibility

The steel erector shall be responsible for:i. Ensuring workers are suitably qualified, adequately trained and with

sufficient experience to safely perform the assigned work.

ii. Inform the company about access needs to the site specific work areas.iii. Pre-planning work activities to ensure that workers are not required to

work under unsafe or suspended loads.iv. Developing site specific work instructions and procedures that identify

access and area needs.v. Ensuring that requirements for moving loads over working areas are met.

The erector must comply with the general and specific requirements of lifting and handling loads.

3.5.6.4 Workers Orientation

Prior to starting work, all workers shall attend site orientations and daily Tool Box meetings to be informed of and become familiar with:

Site rules and regulations Erection plan and procedures Equipment to be used Hazard assessment Work area and emergency procedures (including the rescue plan)

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Work areas of other trades and the need to communicate planned work activities them when working in close proximity

Site CASHES meeting will be held with the management once a month. This meeting is exclusive to the Tool box meetings held every day.

3.5.6.5 Personal Protective Equipment (PPE)

See 3.5.4 above

3.5.6.6 Lifting and Handling Loads

Manual handling of loads or materials by workers should be minimized. Sub-contractors must provide, where reasonably practicable, appropriate

equipment to help workers lift, lower, push, carry, handle or transport heavy or awkward loads.

3.6 Environment

In order to ensure that work environment is safe, conducive and preserved both in the factory and sites, the following actions are mandatory.

3.6.1 Factory Environment Clean all work areas before and after work daily. Clean all equipments at regular intervals Arrange properly all materials and tools. Clean roof gutters and factory drainages at regular intervals. Empty waste bins at regular intervals Mow factory lawns at regular intervals Keep grasses low at all times Carry out fumigation against insects, rodents, reptiles and other pests at

regular intervals.

3.6.2 Erection Sites Clean all work areas regularly as required. Store all supplies such as bolts in proper containers and set away from

areas where they can pose tripping hazards. Do not leave loose bolts and nuts lying on steel or on ground. Do not string hoses through high traffic areas or stairs. Instead, hang

hoses up to eliminate the hazard.

4. HSE PERFORMANCE MEASUREMENT

4.1 HSE Metrics

The following statistical records shall be maintained and reported on a weekly basis during project execution and will be documented in the minutes from the weekly review meetings;

.Man-hours Lost time accidents

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LTI frequency Recordable medical treatment cases/frequency rate. Material losses/ damage Environmental incidents Community related disturbances Los time Communication issues First aid cases Hazards Medical or health statistics i.e occupational health

4.2 HSE Incentives

HSE incentive shall be in the form of souvenir to staff and subcontractor’s personnel who participate in achieving nil Lost Time Injury within the schedule period. The type and magnitude shall depend on management decision, to be reviewed upwards when higher LTI free man-hours are achieved.

4.3 PUNITIVE MEASURES

Breach of HSE rules shall be viewed seriously. To this, the following guidelines are set by management to forestall recurrence

First offender – Oral Warning Second offender – Written warning Third offender – Written warning Fourth offender – suspension.

5. ACCIDENT PREVENTION AND MANAGEMENT

It is a known fact that accidents result in suffering, pain and death to victims and their families while the company suffers loss of time, money and materials, machine and equipment damage. Government also incur losses when accident occur at work.

Consequently, it is our desire to prevent accidents in all our operations. No efforts shall be spared in order to achieve this objective.

5.1 Accident Reporting and Investigation

One of the weapons which the company will use in preventing accident is the investigation of any accident that may occur.

The primary purpose of this exercise is to determine the cause(s) and use these facts to prevent reoccurrence. Hence, it is therefore a matter of policy of the company that every employee is expected to report immediately to his supervisor or site engineer any accident which occur to him, his fellow employee or any machine/equipment in his place of work. The supervisor/site engineer in turn is expected to investigate the accident to determine its circumstances. He should correct any unsafe acts that were responsible for the accident. The corrective actions will be discussed with other work groups/areas during the review meeting

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or sooner depending on the severity of the incident and the need for others to learn from it.

Where such cause can not be immediately rectified, he should make recommendations to Management on what measures to be implemented in order to forestall a similar mishap occurring in the future. Employees are mandated to cooperate during the investigation.

5.2 Accident Prevention

Apart from ensuring that all rules and practices aforementioned are properly followed, accidents are also prevented through Job Analysis to uncover potential hazards inherent either in individual jobs or projects to be undertaken. The jobs to be analyzed are broken down into successive steps, potential hazards are identified and ways to eliminate them and prevent accidents are developed.

The accident report is therefore documented for future reference.

6. SECURITY

The company intends to manage security affairs as an integral part of its HSE program and as part of company’s business to eliminate injuries and losses of materials, property of all staff, client, third party and all personnel involved in her activities.

The company will employ adequate number of experienced security guards. Access to project work sites will be controlled to prevent unauthorized entry as follows;

Access will be allowed to only those persons that have official business and possess valid induction badge with valid photo identification badge.

Only staff that has completed the minimum induction safety training would receive access badge.

Security personnel at the work site will be linked by GSM handset. All staff shall be with PPE appropriate for the activities carried out.

7. AUDIT, REVIEW AND INSPECTION

The site engineer will regularly conduct HSE Audits and inspection. These audits shall determine the level of compliance with HSE goals and procedures for the project.

Corrective actions for all non-conformities shall be outlined in the audit report. Serious accidents or incidents will trigger a non-scheduled investigation. It is the goal of the project to close out non-conformities within one week where applicable.

Routine inspections shall be carried out in the course of the project. The inspections shall be in two forms e.g pre job inspection and post job inspection. The inspections shall cover but not limited to the following areas; personal behavior, hazardous area, power tools, hand tools, electrical equipments, hoses and connections, safety slings, housekeeping, PPE and warning lights.

Review of audit findings shall be carried out during HSE meetings. This will be a forum where learning points are communicated to project personnel and used to improve the HSE management of the project.

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8. HSE COMMUNICATION

HSE activities shall be communicated to all site personnel and relevant stakeholder to the project. Communication shall be effected through daily tool box meetings and weekly general meetings.Safety meetings will normally be held regularly based on the project duration and will be chaired by the site engineer. A nominated safety officer shall be responsible for ensuring that minutes are taken of all safety meetings.

9. HSE DOCUMENTATION

All related HSE issues shall be documented and maintained at the site and the company’s office.Documentation and records shall include:

Reports of progress towards meeting objectives and targets Training records. Inspection and review reports Non-conformance and corrective actions Environmental and injury incidents and investigation report. Maintenance records

The project QHSE coordinator is responsible for ensuring compliance with these system and procedures.

10. HSE TRAINING

The workers orientation (3.5.6.4) together with the daily tool box meetings and the weekly general meetings form the core training for the personnel on site.

The site engineer is responsible for identifying further training needs as project progresses and see to its implementation.

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