Our EHS Policy

SAFETY FIRST — SAFETY FIRST — SAFETY FIRST

Introduction

This Health, Environment and Safety Management Plan (HESMP) defines the health, safety and environment standards and requirements of the Project. These standards and requirements apply to all employees and visitors. All MCES employees are required to comply with the provisions of the plan.

MCES holds all managers and supervisors accountable for understanding and implementing this HESMP. MCES employees are responsible for implementing, monitoring and improving the plan. The HESMP is reviewed for its relevance following health and safety audits; the MCES HES Representative is responsible for undertaking that review.

Health & Safety Policy & Objectives

MCES firmly believes a meaningful HES Plan for the project depends on the leadership and support of management. This support is demonstrated by having in place a Health and Safety policy that includes clear statements of objectives and management commitment. MCES ensures this policy is communicated to all personnel and implemented throughout the Project.

MCES’s vision is to achieve zero incident in all operations of this Project. The safety objectives are used to raise awareness and establish a Health & Safety culture that strives for continuous improvement.

Specific objectives

• To enlist and maintain support for the health, safety and environment objectives of the project at all levels within the organisation.
• To provide and maintain safe systems of work.
• To clearly define areas of Health, Safety and Environment responsibility.
• To identify hazards, assess and control risks, and implement and review Health and Safety procedures.
• To ensure all project personnel complete the Project-specific induction.
• To thoroughly investigate all incidents, including near miss events, to prevent recurrence.
• To involve all levels of the project management team and the workforce in periodic audits and inspections of construction activities.

Drugs and Alcohol in the Workplace

A notice to comply with the MCES Drug & Alcohol Policy is provided to all employees at the commencement of work. MCES has the right to perform reasonable and unannounced searches of personnel at any time while they are at the site of operation. The introduction of alcohol, prohibited and prescribed drugs into the workplace can pose a potential threat not only to the health, safety and wellbeing of the affected person but also to other personnel and members of the public.

MCES will not permit any person, whilst at work, to:

• Be in possession of, be under the influence of, or sell illegal drugs.
• Have on their person, sell, or be under the influence of alcohol.
• Any employee, subcontractor or visitor believed to be under the influence of alcohol or illegal drugs will not be permitted to work until free of such influence.
• Employees taking prescription or non-prescription drugs must report their use to their Manager or the First Aid Office where the use may affect their ability to perform assigned duties.
• A preliminary search of employees associated with accidents, injuries, near misses and mishaps shall be conducted for the presence of alcohol and controlled substances.

For any drug and/or alcohol related problem, treatment and/or counselling is to be sought and the immediate Manager kept informed. It is the responsibility of every employee to ensure the safety of themselves and their fellow employees. Violation of this policy constitutes sufficient grounds for disciplinary action which may lead to dismissal.

References

A listing of all referred Health & Safety Procedures, Safe Work Instructions and Standards documents has been collated and can be found in the Documentation section.

Project Health, Safety and Environment Plan. MCES has in place a Health and Safety Policy Statement, Environmental Policy Statement, Drugs and Alcohol Policy statement and an HSE plan template covering several HSE related issues. A project-specific HES Management Plan was developed and revised on award of contract, in compliance with the requirements of the Client.

MCES operates a safety system providing an integrated, closed-loop approach to safety management, providing for but not limited to:

• Personnel selection.
• Competency and training.
• Health, Safety and Environmental management training.
• Management engaging in discussion with the workforce.
• Hazard identification and risk assessment.
• Emergency preparedness, promoting a proactive attitude towards reduction of “at risk behaviour & actions”.
• Identification and reporting of lead indicators (near misses & corrective actions).
• Incident reporting and investigation, injury management and return to work.

MCES is committed to the preservation of the environment. The basis for managing environmental issues mirrors that for safety — a closed-loop system providing for ongoing review and update using the same management processes. The starting point is the development of environmental hazard assessments identifying mitigation measures prior to the commencement of any activities. Details are addressed in the PHESMP, Project Emergency Response and Evacuation Plan, Project Waste Management Plan and Project Accommodation and Hygiene Plan.

HES Target and Performance Requirement

MCES is committed to achieving the target of ZERO incidents at this Project site. In order to achieve the target, the All Incidents Frequency Rate (AIFR) must be equal to zero, and MCES will comply with other relevant requirements specified in the Contract.

All incidents

All incidents include the following work-related injuries or illnesses:

• First Aid Case
• Medical Treatment Case
• Days Away from Work / Restricted Work Case
• Fatality

The All Incidents Frequency Rate (AIFR) is calculated by the following formula as defined by OSHA:

AIFR = (Total number of Fatalities, Days Away from Work, Medical Treatment Cases, Restricted Work Cases and First Aid Cases in the period ÷ number of hours worked in the period) × 200,000

Definitions

First Aid Case (FAC) A case where no medical treatment was given and restriction of work was limited to the day of the incident.

Medical Treatment Case (MTC) Requires more elaborate treatment than first aid cases. Medical treatment refers to management and care of persons to combat work-related disease or medical disorders, and excludes visits for observation, counselling and diagnostic procedures.

Days Away from Work (DAFW) A case where an employee is away from work for one or more days after the day a work-related injury or illness occurred. Incidents are still considered DAFW even if the first day missed is several days, weeks or months after the incident, or the employee is prescribed days off by a physician and comes to work anyway.

Restricted Work Case (RWC) A case where an employee, because of work-related injury or illness, was assigned to another job on a temporary or permanent basis, or worked at their permanent job but less than a full day, or cannot perform routine functions associated with their permanent job.

Fatality The death of an employee engaged in a work-related activity that results from an incident or exposure in the work environment.

HES Performance Requirements

MCES shall report to the Client any HES incident or near miss with the potential to cause serious injury or damage to the environment, in an appropriate agreed format that facilitates the transfer of information — in the first instance, and as soon as possible after the event becomes known. HES performance data is provided to the Client each week or as required.

Management Commitment

MCES management is committed to the health, safety and welfare of all employees and will demonstrate leadership by achieving the highest possible standards in both occupational and natural environments.

Management demonstrates its commitment to HES management by:

• Conducting a field visit fortnightly (14 days) and completing a field verification activity (inspection, audit).
• Participating in the fortnightly Project HES meeting.
• Leading at least one project safety toolbox meeting per month.
• Making all personnel aware during orientation, toolbox meetings and site visits that any MCES employee has the authority to stop work when an imminent hazard to persons, property or the environment is identified — and executing this Stop Work Authority when an unsafe condition or behaviour is observed.

Employees Commitment

• Ensuring that decisions and practices are consistent with the stated policy and objectives.
• Making adequate resources available.
• Participating in construction hazard workshops and safety reviews.
• Discussing safety with supervisors and employees.
• Visiting all work areas regularly.
• Wearing the correct Personal Protective Equipment (PPE).
• Carrying out safety observations and giving immediate feedback.
• Taking disciplinary action for violations of safety rules.
• Ensuring that safety is not compromised to meet schedule or budget.
• Making safety an agenda item at formalised meetings.
• Holding regular safety meetings (Toolbox and Project Management).
• Reviewing toolbox meeting minutes and ensuring all incidents are reported and investigated.
• Reviewing incident investigations and following up action items.
• Participating in regular inspections and audits.
• Executing Stop Work Authority in the event of unsafe work.

Organisation and Resources

Health and Safety Personnel

MCES engages suitably qualified and experienced personnel to fill the following positions to ensure health and safety issues are prevented and/or managed on the project: HES Representative, HES Supervisor(s), and Paramedic. In addition, suitable candidates from the workforce will be encouraged to be trained as First Aiders to complement the growing ranks of already qualified First Aiders within MCES.

Health, Environment and Safety Budget

An HES Budget is developed to ensure both the corporate and HES objectives of the HES Management System requirements can be achieved. Cost categories include:

• HES personnel.
• Risk management activities.
• Health and safety communications.
• Meetings and training (includes inductions).
• Auditing.
• Safety improvement programmes (includes safety behaviour programme, transport & travel management).
• Personal protective equipment.
• First aid.
• Fire / emergency.
• Equipment and plant safety programme.

Communication and Consultation

MCES recognises that communication is an essential and critical element in managing safety. Daily and monthly meetings are held in a structured manner to communicate issues from and to all levels of the workforce throughout the site. All structured meetings are minuted.

Document Control

The HES Representative establishes a controlled document register for nominated safety documents. The following documents are subject to control:

• Project Health, Environment and Safety Management Plan
• Project Waste Management Plan
• Project Emergency Response and Evacuation Plan
• Project Accommodation and Hygiene Plan
• Material Safety Data Sheets and register
• Incident reports
• Performance indicators and safety performance summaries
• Attendance records
• Induction records
• Hazard reports / Job Safety & Environment Analyses
• Various permits associated with the project
• Plant assessment worksheets
• First Aid Treatment Register (includes medical)
• Fire extinguisher inspection records

MCES has developed the above-mentioned documents, which are in the process of continual improvement. The Project HES Representative shall ensure that:

• Documents are accurate, easy to understand and up to date.
• Documents can be easily retrieved.
• Changes are identified and old documents removed from use.

Job Safety and Environmental Analysis (JSEA)

The HES Representative, in conjunction with the Project Management Team, develops a preliminary Job Safety and Environmental Analysis (JSEA) for the project work activities.

Having performed the JSEA and assessed the risk, control measures are determined. Where possible the risk should be minimised and/or eliminated through changes to the work process. Where this is not practicable, other forms of control may be required. The JSEA is reviewed and addressed at the toolbox meeting with the work crew to adequately manage the hazards and risks associated with the project.

Project Management Meeting

A monthly Project Management Meeting is held where safety shall be the first order of business, covering safety related concerns and updates on accident-incident investigations.

Roles and Responsibilities of Key Project Personnel

Training

The MCES Project Management team has the responsibility to ensure its management, supervisors and employees have the necessary skills and knowledge, and are competent to advise and enforce compliance with this Project HES Management Plan (PHSEMP).

In understanding the requirements for employee selection, competency and training it is important to recognise that almost all personnel involved in construction, operation and maintenance can create a safety hazard if they are not competent, qualified and suitably trained to carry out their role.

MCES employees engaged to work as part of the Project attend the project-specific safety induction before commencing site work. This induction is reviewed and updated to suit changing project conditions. The HES Representative develops and implements induction requirements, and develops a register of inducted personnel. Project management is responsible for ensuring that personnel do not commence field operations until inducted.

All personnel complete an Induction Attendance form prior to the induction. All licences and certificates of competency held must be recorded on that form.

An integral part of the induction process

• Objectives of the project.
• Project safety objectives.
• Emergency response procedures.
• Site-specific hazards.
• Site safety rules.
• Smoking policy.
• Alcohol and other drugs policy.
• Hazard identification and reporting.
• JSEA preparation.
• Toolbox meetings.
• Incident reporting and investigation.
• Site orientation.

Following the main induction all personnel undertake a familiarisation tour of the Project accommodation, where the following is pointed out:

• Emergency procedure and facilities, e.g. First Aid, Fire Extinguishers, Assembly Points.
• Hours of work.
• First Aid Representative.
• Personnel in crew.
• Location of amenities.

Environment Management Plan

Purpose and Scope

The purpose of this Project Environment Management Plan (PEMP) is to:

• Identify all contractual and regulatory requirements and define specific requirements to ensure compliance.
• Present an environmental analysis of construction activities and their potential effects.
• Detail the management strategies to be adopted to minimise the actual and potential environmental effects arising from construction activities and possible (non-routine) contingency events, and provide the necessary procedures for communication, documentation and review of environmental compliance activities.

Effective environmental management is an ongoing process. This PEMP is reviewed whenever new environmental management practices or options are identified. The work is managed under MCES Management systems. MCES is committed to conducting its operations in a manner that protects and responsibly manages the natural environment.

MCES seeks to achieve this objective by:

• Complying with applicable environmental legislation, regulations, construction industry codes of practice and specific contractual requirements.
• Ensuring that all personnel have adequate skills, knowledge and information to carry out their tasks without harm to the environment.
• Conducting all activities in a manner that promotes the conservation of energy and reduces the generation of waste and the discharge of contaminants to the environment.

MCES’s Environmental Policy is generally issued to all personnel via notice boards and through the line manager to key personnel.

Environmental Objectives

The EMP objectives and goals have been developed for the Project to meet the following objectives:

• Minimise the extent and impact of clearing and grading on the site.
• Minimise ground surface and vegetation destruction/disturbance.
• Protect “at risk” species of flora and fauna (if any).
• Maintain access for landholders.
• Maintain security of fencing and utilities.
• Ensure construction activities on the site and the use of access roads etc. off the site of operation are managed so that potential adverse environmental impacts are minimised.
• Prevent breeding of Dengue mosquitoes by preventing accumulation of fresh rain water or run-off water in storage rooms or in any other small pits.

Management Roles and Responsibilities

Sound environmental performance is everyone’s responsibility, including all employees, Senior Management, Managers and Supervisors, who have statutory and moral obligations for providing an environmentally sensitive and responsible working environment with minimal risk of environmental damage, pollution or unintentional waste emissions. All personnel on the project must adhere to the PEMP and related procedures and ensure that all objectives and standards are met or exceeded.

Health and Safety Strategy and System

A planned systematic implementation requires the clear recognition of what is required and when it is required, to establish a measure of achieving the document objectives. These will be achieved by:

• Providing training, information, instruction and supervision to all staff, workers and subcontractors associated with the project.
• Motivating all personnel to achieve best practice through the establishment of consultative and communicative processes and the desire to work in a healthy and safe manner.
• Implementing and maintaining risk management programmes to identify, assess, control and review hazards and control strategies.
• Performing regular inspections and audits using checklists on work functions exposed to hazards associated with equipment, tools, plant, machinery, environment and facilities.
• Analysing available information to establish prevention measures and performing root cause analysis of major incidents.
• Ensuring that people with the appropriate skills are employed.
• Ensuring the dissemination of workplace health and safety procedures, instructions, policies, control measures and rules to all those affected.

Emergency Response Plan

Details on emergency and evacuation process and management are addressed in the Emergency Response and Evacuation Plan (EREP), submitted with the Proposal and subsequently revised on award of Contract. The HES Representative regularly reviews the EREP with scenarios developed with respect to any changing situation.

Relevant information is made readily available. The existing EREP includes:

• Description of how the emergency response is initiated and how emergency teams are activated.
• Specification of command, control and communications arrangements (including MCES, specialist response organisations and statutory authorities).
• Identification of roles and responsibilities of all key personnel involved in, or likely to be involved in, the response.
• Specification of an Emergency Response coordinator.
• Identification of available emergency equipment and personnel trained in its use.

Safety Disputes

In the event of a dispute regarding a perceived safety issue, the method of resolution will initially be by those involved (Worker / HES Representative / Supervisor).

Consultation is a mandatory requirement, with the expectation that the issues are addressed between the person identifying the issue, the HES Representative and the immediate supervisor.

If resolution cannot be reached, it will be documented on a Hazard Report by the HES Representative and referred to the Project Manager for assistance in resolving the issue in accordance with the Client Safety Disputes & Grievance procedure.

Disciplinary Action

Unsafe work practices are addressed by the HES Representative, who provides instruction as to the correct method of work.

Continued or unsafe practices are unacceptable and the following measures will be invoked:

• Counselling by immediate supervisor (with Management/staff as witness).
• Issue of a Written Warning with a further breach.
• Final counselling and Written Warning (with workplace representative in attendance). Major blatant disregard for safety will result in immediate termination.

Dangerous acts · Physical abuse · Disobeying a safety directive

Behavior Based Safety Process

Behavior Based Safety (BBS) is a process that provides the opportunity to move to a higher level of safety excellence by building ownership, trust and unity across the team, and developing empowerment opportunities which relate to employee safety. It addresses the human element of construction work safety in a scientific approach.

A properly designed BBS process involves workers from every level. The atmosphere of trust that results from the non-punitive observation and feedback process leads to more worker involvement. Workers will frequently start asking to be observed, and they will use the feedback to modify their activity to make themselves and their fellow workers safer. As trust increases, the reporting of minor incidents will increase yet severity will decline.

Principles on which the BBS process is built

Line Management Responsibility for Safety The responsibility for safety and the BBS process is shared by management and front-line workers.

Clear Roles and Responsibilities Functions within the BBS process shall be performed at the proper level and shall be updated to fit the purpose.

Competence Commensurate with Responsibilities An effective BBS process shall provide the skills needed to perform the tasks and functions associated with the job in a timely manner.

Balanced Priorities BBS shall provide a consistent stream of safety data that enables MCES to balance safety priorities with operational needs.

Identification of Safety Standards and Requirements Existing safety standards and requirements aid in developing the list of behaviours used in the BBS process.

Hazard Controls The observation process shall provide ongoing monitoring of processes so that Hazard Controls reflect the risks associated with work being performed.

Operations Authorization The BBS process shall help to provide behaviour-related safety information necessary to make informed decisions prior to initiating operations.

All behavioural safety processes have three major components

• Development of a list of at-risk behaviours.
• Observations.
• Feedback.

The process starts with a behavioural hazard analysis to identify at-risk behaviours. These can be determined using accident-incident reports and job hazards analysis. Using the at-risk behaviours, a checklist is then developed to assist in the observation of work behaviour, leading to observation, feedback and continuous safety improvement.

Safe Work Systems

Safe Work Instructions (Safe Work Methods) are developed to provide a standardised approach for the communication and implementation of safety precautions whilst engaged on a specific activity and/or working environment on the project. MCES Management shall ensure that Safe Work Methods and Site Safety rules are adhered to by all Project personnel.

Where Job Safety and Environmental Analysis (JSEA) identifies a requirement for a safety working procedure, the SWI shall be developed and provided as a ‘handout’ at Toolbox or Pre-start meetings. The procedure/instruction shall be reviewed at the Toolbox or Pre-start meeting prior to the work activity commencing.

Safe systems of work on the Project are established and updated throughout the project. Regular review addresses existing safety systems with a view to improvement and reflecting task-specific activities.

JSEA (Job Safety and Environmental Analysis) will be used as a tool to identify hazards and control measures in the establishment of safe systems of work. The JSEA may be subject to review by the Client HES Representative.

For all work which requires a permit, the specific procedure or work instruction being referenced must be identified on the permit, and a JSEA specific to the job must accompany the permit.