health, safety and environmental planminexmt.com/plan.pdf · requirements of osha act 2007 and iso...

REV. DATE DESCRIPTION DSGN CHKD APPD

001/17 31-05-17 M.O. Victor S. Karl/D Webber

002/17 04-04-17 M.O. Victor

EMPLOYER : n

PROJECT :

CONTRACTOR :

DESIGNED BY DATE TITLE :

HEALTH, SAFETY AND ENVIRONMENTAL PLAN

M. O. Victor 31-05-2017

CHECKED BY DATE

Karl H. S

APPROVED BY DATE DOCUMENT NUMBER PROJECT NO. REV.

MT-ZI/KPC-5/17/HSE-001 002/17

HEALTH, SAFETY AND ENVIRONMENTAL PLAN

HEALTH, SAFETY and

ENVIRONMENTAL PLAN

DOC NO: MT-ZI/KPC-5/17/HSE-001

ISSUE NO: 001

Code: MT-17/HSE-001A REV: 002/17

i

Table of Contents INTRODUCTION .................................................................................................. - 1 -

General .................................................................................................................................................. - 1 -

Application of HSE management system ......................................................................................... - 1 -

1.4 Abbreviation and Definition ....................................................................................................... - 2 -

Definition of Terms ........................................................................................................................... - 3 -

HSE POLICY........................................................................................................................................ - 5 -

HSE PLANNING.................................................................................................................................. - 6 -

Environmental Aspects and Impacts ..................................................................................................... - 7 -

Significant Environmental Aspect; - ................................................................................................. - 7 -

Legal and other Requirements .............................................................................................................. - 8 -

Objectives and Targets ...................................................................................................................... - 8 -

HSE management programs.............................................................................................................. - 9 -

IMPLEMENTATION AND OPERATION ....................................................................... - 10 -

Organization and responsibility .......................................................................................................... - 10 -

HSE Management representative .................................................................................................... - 11 -

Competence, training and awareness .............................................................................................. - 12 -

Communication, Participation and Consultation ............................................................................ - 12 -

HSE Management System Documentation ..................................................................................... - 13 -

The HSE Manual ............................................................................................................................. - 14 -

Procedures and instructions ............................................................................................................ - 14 -

Project (Site) HSE Plan ................................................................................................................... - 15 -

Control of documents ...................................................................................................................... - 15 -

Control of operations ...................................................................................................................... - 15 -

Emergency Preparedness and Response ............................................................................................. - 16 -

Emergency Response Organization ................................................................................................ - 17 -

Emergency preparedness and response drill ................................................................................... - 17 -

CHECKING ...................................................................................................... - 18 -

Monitoring and measurement ............................................................................................................. - 18 -

Evaluation of compliance................................................................................................................ - 19 -

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Incident investigation ...................................................................................................................... - 19 -

Control of nonconformity ............................................................................................................... - 19 -

Corrective action ............................................................................................................................. - 20 -

Preventive action ............................................................................................................................. - 20 -

Control of records ........................................................................................................................... - 20 -

Internal audit ................................................................................................................................... - 21 -

MANAGEMENT REVIEW ...................................................................................... - 22 -

General ................................................................................................................................................ - 22 -

Review input ....................................................................................................................................... - 22 -

Review output ..................................................................................................................................... - 23 -

7.0 References ........................................................................................................................................................ - 24 -

8.0 Annexes ............................................................................................................................................................ - 25 -

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INTRODUCTION

General MINEX Microtunneling Services ltd. (hereby referred as ...MINEX) Management is

determined to develop the “HSE Management System” minimizing potential risks and

contributing to the sustainable growth and productivity. The Health, Safety and

Environmental Management System (HSE) are integral element for all involved parties

and for the benefit of the public and the success of MINEX. The management will

continue to raise the awareness of the employees for the importance of the HSE

Management system.

1.1.1 The HSE system has been established in accordance with MINEX policy and the

requirements of OSHA Act 2007 and ISO 14001:2015 Standard serving as minimum

requirements.

Application of HSE management system 1.1.2 This HSE Manual is to define the company’s HSE management system, responsibilities

for HSE management and how the HSE Management system is implemented

This manual applies to the following activities during and as applicable

- Basic design

- Detail design

- Procurement of equipment and materials

- Site Mobilization and preparation.

- Supervision service

- Construction activities

- Commissioning and Demobilization

1.1.3 The project deliverables and services required by the Contractor are realized and

delivered by the execution of the project, the business processes can be identified by the

two high level main processes such as below;

The project realization process: Starting with client requirements as a project

input, it delivers the project output through the several project management

sub-processes such as scope, time, cost, risk, quality, safety and etc. from

project initiation to closeout.

The corporate business support process: To manage a company and support

project, there are processes such as human resources, leadership,

information, and etc.

1.1.4 The processes necessary for the realization of the project undertaken are performed

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under the full responsibility of MINEX. If needed some of these processes may be

outsourced.

In case of such, Minex will ensure the activities are performed inconformity to requirements of the

contractor EHS Plan;

- Reviewing and Evaluating the HSE of the subcontractor

- HSE audit to the subcontractors

- Surveillance or inspection to subcontractor’s activities

1.4 Abbreviation and Definition

Those abbreviations and definitions not given herein will be defined according to the

OSHA Act 2007 and ISO 14001:2015

1.4.1 Abbreviation

a. Audit: Internal Audit

b. OSHA: Occupational Safety and Health Act

c. ISO: International Standards for Organizations

d. EMCA: Environmental Management and Coordination Act

e. NEMA: National Environmental Management Authority

f. EIA: Environmental Impact Assessment

g. SEA: State of Environment Assessment

h. MINEX: MINEX Trenchless Co., Ltd

i. HSE: Health, Safety and Environment

j. HSE Inspection

k. HSE Management Program

l. HSE Plan: Project HSE Plan, Site HSE Plan, Site Safety Management Plan,

1. Waste Management Plan, Risk Prevention Plan, Site Environmental

plan.

m. Incident: Accident/Incident

n. TBM: Tool Box Meeting

o. Contractor: Zakhem International Construction Co.

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Definition of Terms

Tolerable Risk; - Risk that has been reduced to a level that can be tolerated by the

organization having regard to its legal obligations and its own HSE Policy.

Continual Improvement; - A process that enhances HSE Management System so as to

entirely achieve the goal of HSE performance according to the HSE Policy.

Hazard; - Potential condition and factor which might come to result in injury/healthy

disorder, property damage, loss of work-site condition or multiple occurrence by.

Hazard Identification; - A process that identifies Hazards existence and regulates the

hallmarks.

Accident;- Unexpected case of severity, healthy disorder, injury, other relevant losses

Incident; - Events in which a work-related injury or ill health or fatality occurred or could

have occurred.

Interested Parties; - Individual or organization affected by HSE performance or the

relevant results.

HSE Objective; - A target that possibly enables to focus on HSE performance.

HSE Performance; - With the measurable results of HSE Management System relevant to

Safety & Health risk and Environmental impact, HSE performance measurement reflects the

effectiveness on organizational risk management. The results under the prospective of HSE

Management enables to measure on organizational HSE Policy, target and other HSE

performance requirements.

Risk; - Combination of Special hazardous loss or possibility of disclosure occurrence or

loss or exposable damage or occupational illness severity.

Environment; - Around circumstance which runs organization with mutual relations

including air, water, soil, natural resource, plant community, animal community, human and

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Environmental Aspect; - Service factors or organizational activities & products able to

communicate with environment.

Environmental Impact; - Environmental change that organizational environmental aspect

brings out favorable or corrupt effect partially or entirely thereto.

Prevention of Pollution; - To reduce environmental impact, that originates from the

process for any types of pollutants or waste existence, elimination or discharge or evasion,

reduction or management, and practice, skills, materials, products, service, or to prevent

contamination by using energy, that includes source reduction or removal, process, products

or service change, effective utilization of resources, alternative material and energy, re-use,

collection, re-cycle, recycling and disposal

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HSE POLICY

1.2 The Management Office and HSE Management representative is responsible for ensuring

that this policy is communicated, understanding, and implemented at all levels of the

organization through Awareness campaign and Training.

1.3 The HSE policy includes a commitment to continual improvement, a commitment to

comply with current applicable HSE legislation and with other requirements to which the

organization subscribes and communicated to all employees with the intent that employees

are made aware of their individual HSE obligations and available to interested parties and

be reviewed periodically to ensure that it remains relevant and appropriate to the

organization.

1.4 The Site Manager is responsible to perform any project according to MINEX HSE policy

and requirements (including the country regulations) and publish HSE policy of site for

employees and interested parties to implement.

1.5 Minex magament shall opt to either implement its own HSE standards or, if the contractor

requires that Minex Impliments its EHS plan, then the Company shall be indemnified from

any outcomes that shall emanate during project execution in regard to the Contractors Plan.

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HSE PLANNING

3.1 Hazard Identification, Risk Assessment and Risk Control

3.1.1 The HSE department shall establish and maintain procedures for the ongoing

identification of hazard, the assessment of risks, and the implementation of necessary

control measures of its activities, facilities that it can control and over which it can be

expected to have an influence, in order to determine those which have or can have

significant impacts on the risk during project execution.

3.1.2 Project Manager shall identify the hazard and assess risk of specific process during

engineering phase based on the contract document. These results shall be used and

reflected in following engineering activities such as selection of construction materials,

handling of hazardous materials, evaluation and selection of subcontractors or suppliers

in accordance with applicable procedures.

3.1.3 Site Manager shall identify the hazard and assess risk of activities and facilities

regarding construction site. Those results shall be used and reflected in following

construction activities such as supervision of construction activities, handling of

hazardous materials, evaluation and selection of subcontractors or suppliers in

accordance with applicable procedures.

3.1.4 When setting the HSE objectives, the results of risk assessments and the effects of risk

controls are considered

3.1.5 The information of the hazard identification and risk assessment shall be kept up to date.

3.1.6 All project teams shall identify hazard and assess risk of its all activities and facilities in

accordance with Job Safety & Environmental Analysis procedures during , construction

and the related services.

3.1.7 The methodology for hazard identification and risk assessment shall

- Be defined with respect to its scope, nature and timing to ensure it is pro-active

prevention rather than follow-up control.

- Provide for the classification of risks and identification of those that are to be

eliminated or controlled by the objective and HSE management program

- Be consistent with operating experience and the capabilities of risk control measures

employed

- Provide input into determination of facility requirements, identification of training

needs and / or development of operational controls

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- Provide for the monitoring of required actions to ensure both the effectiveness and

timeliness of their implementation.

Environmental Aspects and Impacts

3.2.1 The HSE department shall establish and maintain procedures for the on-going

identification of environmental aspects and the implementation of necessary control

measures of its activities in order to determine those which have or can have significant

environmental aspects during project execution.

3.2.2 Project Manager shall identify the environmental aspect and impact of specific process

during engineering phase based on the contract document. These results shall be used

and reflected in following engineering activities such as in (3.1.2.above).

3.2.3 Site Manager shall identify the environmental aspect and impact of activities, product

and services regarding construction site. Those results shall be used and reflected in

following construction activities such in (3.1.2.above).

3.2.4 When setting the objectives, the aspects of these significant impacts shall be considered.

3.2.5 The information of the aspects of significant impacts shall be kept up to date.

3.2.6 All the project team shall review, identify and evaluate the environmental aspects of its

all activities in accordance with Environmental Aspect procedure during the design,

engineering, procurement, construction, and the related services.

Significant Environmental Aspect; -

The process to identify the significant environmental aspects associated with the

activities during operations at site includes;

- Emission to air

- Releases to water

- Waste management

- Contamination of soil /land

- Noise and vibration

- Hazardous material (use of raw materials & natural resources)

- Other local environmental issues.

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3.2.7 Significant environmental aspects and impacts are determined by combination to several

criteria;

- Frequency

- Severity to the environment (with sensitivity of surroundings)

- Operational management

- Compliance with regulations

Legal and other Requirements

Minex will execute its activities under the main contractor’s legal requirements and compliance

which includes but not limited to;

- Contractual agreement.

- Site registration certificate

- NEMA License

- EIA report for KPC Line on replacement project

- National Construction Certificate

- Law and regulations.

- Agreements with our clients or public authorities.

3.2.8 The Project Manager has responsibility to survey and confirm the applicable regulations,

codes and requirements before starting the project.

3.2.9 Relevant information on legal and other requirements should be communicated to all

project personnel and other relevant interested parties.

Objectives and Targets

3.2.10 The Project Manager and Site Manager have responsibilities to establish the project

HSE objectives.

3.2.11 Clearly stated programs for the achievement of measurable objectives and targets for

HSE performance will be established, implemented and periodically reviewed for

improvement. Through this process the following shall be considered;

- Legal and other requirements

- Significant risk and environmental aspects

- Technological options

- Financial, operational and business requirements

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- The views of interested parties.

3.2.12 The objectives and targets shall be consistent with the HSE policy, including the

commitment to continual improvement. More general and detailed objectives at varying

functional levels are contained within applicable procedure.

HSE management programs

3.2.13 A HSE management program will be established and maintained to achieve all the stated

objectives and targets in accordance with HSE Management program.

3.2.14 This HSE management program shall include;

- Designation of responsibility for achieving objectives and targets at each relevant

function and level of the organization.

- The means and time frame by which they are to be achieved.

3.2.15 The HSE management program shall be reviewed on a regular basis

3.2.16 Where necessary at specific project, program shall be amended to address changes to the

activities, products, services, or operating conditions of that project.

3.2.17 The Project Manager and Site Manager have responsibilities to establish the HSE

management program to achieve the project objectives and targets.

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IMPLEMENTATION AND OPERATION

Organization and responsibility

4.1.1 The responsibility, authority and lines of reporting of all staff within MINEX is shown

in Attachment 7.1 MINEX Organization, Project Execution Organization and

Communication

4.1.2 The Management Representative has the entire responsibility and authority to operate

the HSE management system in the organization including the followings;

a) Shall ensure that Company’s HSE Management System is established, executed and

maintained to meet the OSHA 2007 and ISO14001:2015 requirements.

b) Shall conduct a regular analysis on Company’s HSE Management performance

c) Shall be participated in a periodical audit and set-up target for HSE Management

System.

4.1.3 The HSE department Team Head has roles and responsibility for the followings :

a) Performing affairs in accordance with HSE manual and relevant system documents,

legal and other requirements;

b) Project operation and control in order to achieve the company's HSE policy and

objectives;

c) Maintaining and registering HSE regulation and other relevant requirements;

d) Conducting HSE performance development, collection and analysis on all projects

and sites;

e) Developing HSE Training rules and confirming HSE relevant qualification;

f ) Conducting internal HSE audit and corrective action;

g) HSE audit and evaluation on sites and sub-contractors;

h) Providing to request and confirm the corrective action of the existing or potential

non-compliance;

i ) Reporting HSE issues to HSE Management Representative;

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j ) Performing affairs to improve continual HSE Management System;

k) Developing Management Review data;

4.1.4 The Project Manager has roles and responsibility for the followings :

a) Performing affairs in accordance with HSE manual and relevant system documents,

legal and other requirements;

b) Project operation and control in order to achieve the company's HSE policy and

objectives;

c) Maintaining and registering HSE regulation and other relevant requirements;

d) Establishing and implementing HSE objective and targets for project;

e) Providing human resources and monitoring for project;

f) To take corrective action to prevent re-occurrence of non-compliances.

g) Understanding and implementing measures to prevent potential non compliances.

HSE Management representative

4.2.1 The project Manager will nominate the HSE Management Representative, who

irrespective of other responsibilities will ensure that the HSE management system

developed by MINEX is implemented and maintained throughout.

4.2.2 The HSE Management Representative has direct access to the Project Manager for HSE

issues.

4.2.3 The HSE Management Representative shall have a responsibility and authority for

- Ensuring that HSE management system requirements are established, implemented

and maintained in accordance with HSE requirement

- Ensuring that reports on the performance of the HSE management system are

presented to top management for review and as a basis for improvement of the HSE

management system.

- Informing employees about their participation arrangements, including who is their

representative on HSE matters.

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4.2.4 The HSE Management Representative will ensure that all personnel kept informed of

the performance of the HSE Management System and advise them of the need for any

improvements.

Competence, training and awareness

4.2.1 All personnel shall be appropriately trained, experienced and competent staffs are

available for assignment to tasks.

4.2.2 MINEX is committed to training and developing their entire staff to the levels necessary

for them to conduct their tasks competently, safely and in accordance with procedures

and legislation or regulations.

4.2.3 “All staff shall be made aware of the following;”

- The importance of conformance to the HSE policy and procedures.

- The significant environmental aspects, HSE consequences and related actual or

potential impacts associated with their work activities, and the HSE benefits of

improved personal performance

- Their roles and responsibilities in achieving conformance to the HSE policy and

procedures including emergency preparedness and response requirements

- The potential consequences of departure from specified operating procedures.

4.2.4 All staff will receive an adequate induction and training in order to perform the tasks

required of them.

4.2.5 All staff will be regularly evaluated for reviewing their competency and identifying any

training needs and ensuring that recommended training requirements are addressed.

4.2.6 Personnel performing activities affecting a HSE and HSE audit personnel shall qualify

in accordance with a legal and applicable procedure.

4.2.7 Records of training and competence will be kept as part of personnel records.

Communication, Participation and Consultation

4.2.8 All staff shall have authorities and duties to;

- appropriate involvement in hazard identification, risk assessments and determination

of controls;

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- appropriate involvement in an incident investigation;

- involvement in the development and review of HSE policies and objectives;

- consultation where there are any changes that affect their HSE; - introduction on

HSE matters.

4.2.9 Internal Communication and Consultation; - The Project Manager shall establish

clear communication processes at all levels within MINEX and ensure that these

processes are effective via;

- Regular meetings with all staff

- Use of notice boards

- Circulation of MINEX Reports

4.2.10 External Communication; - MINEX will ensure that a process exists for

communication and consult with relevant external interested parties, when appropriate.

This process will cater for;

- Declaring the HSE policy.

- Declaring the significant environmental aspects and risk assessment results and

performances

HSE Management System Documentation

4.2.11 The HSE documentation is established in the following three distinct levels that

integrate the policies, procedures, and working documents:

a) HSE Manual; - The uppermost document of MINEX’s HSE Management System as

a main document that is used for executing HSE Management System(Comply with

OSHA 2007 and ISO 14001:2015)

b) Procedure; - Document that provides information for method to consistently execute

the individual/functional work activities and processes

c) Instruction; - Document that describes the matters needed to particularly declare the

work activities and processes specified in procedure.

d) Technical Criteria/Engineering Standards; - Document that definitely specifies

requirement and criteria to execute technical activities

e) Project HSE Plan (Site HSE Plan); - Document that specifies the processes and

resources of HSE Management System to apply the specific product, project or contr

act

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f) Record; - Document that provides the objective evidence resulting from activities

performed and results achieved.

The HSE Manual

a) The HSE Manual describes the commitments and policies that will be adopted by

MINEX to address the HSE Management system requirements (OSHA 2007 and

ISO 14001:2015) and refers to the processes and procedures required to make the

HSE Management System effective.

b) The HSE Manual will be prepared by the HSE department Head, reviewed by HSE

Management Representative and approved by Project Manager

c) This HSE Manual has been prepared to apply for all the projects. The projects

generally cover the engineering, procurement and construction activities depending

upon the scope of contract concluded with clients.

d) Both the controlled hard copies of this HSE manual and the accessible electronic

copy found on the information system are valid and updated.

e) All MINEX employees are obliged to ensure that all the activities within their

responsibility are in conformity with the principles and requirements described in

this manual and related procedures and instructions.

f) If there is suggestion(s) of any changes or improvements to this manual or HSE

issues, please contact the author of the document or the HSE Manager who will be

delighted to discuss your suggestions and introduce any agreed changes.

Procedures and instructions

a) The procedures and instructions describe the activities related to HSE management

system and provide the details of interaction and sequence for the processes for

implementation of this HSE manual.

b) Instructions provide detailed steps to conduct specific work activities. Work

instructions are prepared as needed to supplement procedure requirements and to

ensure that critical work scopes are carried out in a consistent manner.

c) Technical Standards such as Engineering Standard, Standard Specification and

Instruction are the documents to give guidance to the engineering work.

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Project (Site) HSE Plan

a) The requirements contained in the HSE management system may not address all

system requirements invoked by client contracts, or required by a governing

regulatory agency, for each project.

b) Thus, to define and implement an alternate HSE for specific projects, it may be

necessary to create a Project HSE Plan to specify supplemental HSE management

system requirements, identify supplemental/revised procedures.

c) The Project HSE Plan is applies to activities that affect the HSE management of

projects and services delivered by MINEX.

Control of documents

4.2.12 Document control processes will be implemented to ensure that all pertinent documents

and data relating to the HSE Management System and documents are to, where

applicable;

- approved documents for adequacy prior to issue,

- review and update as necessary and re-approve documents,

- ensure that changes and the current revision status of documents are identified,

- ensure that relevant versions of applicable documents are available at points of use,

- ensure that documents remain legible and readily identifiable,

- ensure that documents of external origin determined by the organization to be

necessary for the planning and operation of the HSE management system are

identified and their distribution controlled.

4.2.13 Changes to documents will be identified.

4.2.14 Review and approval of changes are performed by the same organizations that reviewed

and approved the original documents, or by designated alternate organizations that have

access to the original data.

Control of operations

4.2.15 Operational control of the HSE activities is primarily achieved through the use of

suitably qualified, experienced and supervised staff, properly equipped and carrying out

their duties in accordance with documented procedures and instructions.

4.2.16 All projects are controlled and implemented by the project schedule established to

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identify, plan, and monitor the design/engineering, procurement, and construction

activities, and to report the progress of the project.

4.2.17 The Project Manager closely monitors the status of the project at all levels to ensure that

actual or potential problem area highlighted and addressed. The overall project progress

reports are issued by the Project Manager, the contents of which inform the client and

MINEX management of the time related status of a project.

4.2.18 All health, safety and environmental aspects of the work to be undertaken will be

identified prior to the commencement of the work. Any risks identified during this

process will be eliminated or minimized by the application of predetermined controls.

4.2.19 The Site Manager has the responsibility in conjunction with the Site HSE Manager of

ensuring the correct implementation of the Work Permit System and of checking that the

instructions given on the work permit are adhered to at all times as required by Contract

or legal requirement.

4.2.20 The Project Manager and Site Manager are responsible for running BBS Program

(Behavior Based Safety Program) to prevent any industrial incident and all personal

safety, and the monitoring and results will be reflected in the corrective action and

improvement.

Emergency Preparedness and Response

4.2.21 (“The Head office and Site Authorities in-charge of HSE shall;) The Contractor shall

provide the ERP services and Minex will communicate all the occurrences that may

amount to be a cause of Emergency as the Contractor shall herewith outlay the ERP

Plan. Additionally, the contractor can conduct Emergency drills in effort of improving

response and competence among the Minex Employees.

a) Establish the organizational plan based on risk assessment findings, legal

requirements, past experiences and emergency training results.

b) Ensure that the emergency preparedness and response plan shall contain potential

emergency situations, employees’ role and responsibilities and course of emergency

action to be take;

c) Regularly reviews, revises and maintains the effectiveness of emergency plan.

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Emergency Response Organization

a) Minex shall be subject to the Contractor’s ERP plan and thus shall establish internal

organization to respond the emergency situation.

b) All employees are aware of their roles & responsibilities in-case of an emergency.

Emergency preparedness and response drill

a) The Contractor’s Emergency team can regularly conduct emergency drills to test the

response abilities.

b) The drill results will be analyzed in report formats by the Contractor and issued to

Minex to be communicated to the entire workforce through trainings and TBM.

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CHECKING

Monitoring and measurement

5.1.1 In order to monitor and continually improve the way in which the HSE management

system achieves its policy and objectives, it shall be subject to a number of measures.

These measures shall include;

- Periodic reviews of the HSE management system.

- Degrees of compliance with stated policies and procedures by internal auditing.

Site HSE Inspection

a) The Site Manager is responsible for the site HSE inspection.

b) This HSE inspection will cover all activities being conducted at a works site. The

results of this HSE inspection shall be recorded.

Control of monitoring and measuring devices

a) All equipment used for measurement determining the acceptability of work

performed by MINEX or for use in a HSE monitoring capacity shall be controlled.

The control of such is the responsibility of the construction supervisor.

b) The control shall include:

- The location or whereabouts of equipment being recorded.

- The unique identification and equipment type being used.

- A schedule of Calibration or Testing, including the frequency and calibration/ test

method.

- The degree of accuracy required for use and its acceptable level of error.

c) Records of the control results will be maintained and where any equipment is found

to be in error, the consequence of that error shall be investigated and the appropriate

action taken including prior data taken by the faulty/error equipment.

d) Statutory inspections for safety equipment such as lifting chains, cable/gas detectors,

etc., are controlled to ensure that the necessary inspections or checks are performed

at the specified intervals with qualified inspectors.

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Evaluation of compliance

5.2.1 The HSE department Head shall establish, implement and maintain a procedure(s) for

periodically evaluating compliance with applicable legal requirements.

5.2.2 The HSE Innovation Team Head shall evaluate compliance with other requirements to

which it subscribes. MINEX may wish to combine this evaluation with the evaluation of

legal compliance or to establish a separate procedure(s).

5.2.3 The HSE Department Head shall keep records of the results of the periodic evaluations.

Incident investigation

5.3.1 The HSE Innovation Team Head shall establish, implement and maintain a procedure(s)

to investigate and analyze incidents in order to;

- determine underlying HSE deficiencies and other factors that may be causing or

contributing to the occurrence of incidents.

- identify the needs for corrective action.

- identify opportunities for preventive action.

- identify opportunities for continuous improvement.

5.3.2 The investigations shall be performed in a timely manner. Any identified needs for

corrective action or opportunities for preventive action shall be dealt with in accordance

with the 5.4, 5.5 and 5.6 of this Manual.

Control of nonconformity

5.4.1 MINEX will have documented procedure to specify the actions that need to be taken in

the event that products, services or processes are found to be incorrect.

5.4.2 This procedure shall ensure that whenever products, services or processes are found to

be incorrect the situation is recorded and the fault or problem identified to prevent

inadvertent use or further processing until such time as the situation has been reviewed

and a course of action specified and includes responsibility and authority for followings;

- The handling and investigation of incident.

- Taking action to mitigate any consequence arising from incidents.

- The initiation and completion of corrective and preventive actions.

- Conformation of the effectiveness of corrective and preventive action taken

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Corrective action

5.4.3 The non-conformances occur within MINEX or during the provision of products or

services, appropriate actions shall be specified that will either correct and/or prevent the

recurrence of such events.

5.4.4 Procedures aimed at detecting or recording non-conformances shall contain instructions

to ensure that whenever problems are identified they are investigated and suitable

corrective and/or preventive measures are specified and taken.

5.4.5 When applicable appropriate follow up checks shall also be made to ensure the

corrective action has been taken and is effective.

Preventive action

5.6.1 A prime aim of gathering and analyzing the data shall be to identify the potential for

occurrences of non-conformances or risks within the MINEX’s activities.

5.6.2 When such analysis indicates the need for action to be taken, the action shall be clearly

specified along with the names of those persons responsible for taking the action and the

timescales for achievement.

5.6.3 To ensure that preventive actions are effective, when stating the actions to be taken, the

statements shall also include what further actions may be necessary to review the

situation. Such information shall be submitted to the Management Review.

Control of records

5.6.4 Records of all activities affecting the operation of the HSE management system will be

maintained to furnish evidence of compliance with the HSE management system,

regulatory and contractual requirements.

5.6.5 These records will be controlled in accordance with the Record control procedure which

prescribes the requirements and responsibilities for records legibility, identification,

collection, filing, indexing, storage, distribution, retention, retrieval, and disposition.

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Internal audit

5.7.1 The HSE Innovation Team Head shall ensure that internal audits of the HSE management

system are conducted at planned intervals to

- determine whether the HSE management system; conforms to planned arrangements

for HSE management including the requirements of this OSHA 2007 and ISO

14001:2015, and is effective in meeting the organization’s policy and objectives;

- provide information on the results of audits to management.

5.7.2 Audit program(s) shall be planned, established, implemented and maintained by the

organization, based on the results of risk assessments of the organization’s activities, and

the results of previous audits.

5.7.3 The audits shall be coordinated by The HSE Department Head who will define the

frequency of the audits and adjust the frequency dependent upon the results and findings

to be audited at least once a year.

5.7.4 A suitably trained or experienced auditor who shall be independent of the process,

function or activity audited will conduct the audits.

5.7.5 Audit reports shall, whenever applicable, identify opportunities for improvement in the

processes, products and services provided. Records shall be kept and a summary of them

included as a regular agenda item for each Management Review.

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MANAGEMENT REVIEW

General

6.1.1 To ensure the ongoing effectiveness of the HSE management system, it will be subject

to periodic formal reviews by the Project Manager together with other staff or advisors

considered necessary.

6.1.2 The management review shall be performed periodically at least once a year, in order

that the HSE management system ensures its continuing suitability, adequacy and

effectiveness.

6.1.3 The prime aim of these reviews will be to review data and information relating to the

performance against stated objectives and requirements and identify opportunities for

improving HSE performance.

6.1.4 On conclusion of the reviews the Project Manager shall consider the appropriateness of

all current policies, processes and procedures and recommend any changes considered

necessary.

Review input

6.2.1 HSE Management Representative will produce and agenda for the review. As a

minimum this agenda shall include but not be limited to the following topics;

- Status of actions relating to previous reviews.

- Progress towards or achievement of any previously stated objective or targets.

- Results of all internal and second or third party audits performed since the last

review.

- Incidents and risks assessments (of HSE nature).

- Complaints, concerns and any other documented instances of non-conformance

together with the effectiveness of any corrective actions taken.

- The effectiveness of any preventive actions previously taken.

- Changes to any regulations, legislation, codes of practice or any other document that

has a bearing on the content of the HSE management system or stated objectives.

- The overall effectiveness of training undertaken during the period since the last

review.

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- Suggestions for changes and improvement of the HSE management system.

Review output

6.3.1 The output of the review meetings will be a written report. This report shall contain but

not be limited to the following information ;

- Statements on the effectiveness of the HSE management system, policies and

procedures together with any recommendations for change.

- Any preventive actions considered necessary to avoid the occurrence of non-

conformances or mitigate / eliminate risk.

- Any other actions required as a result of the review together with the names of

persons responsible for taking such actions and the dates by which they should be

achieved.

- Future objectives for the improvement of the HSE management system and

performance.

- Adequacy or need for further resources

6.3.2 The report shall be signed by the Project Manager and circulated to those persons

responsible for the follow-up actions to complete. If required, the report shall be

submitted to other related organization.

6.3.3 As a result of management review, if necessary, HSE management system elements,

policy and objectives can be modified.

6.3.4 Management review results shall be maintained and controlled as records.

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7.0 References This document has been generated with guide lines from approved OSHA Act and thereby the

contents referenced to conform to all requirements and regulatory compliance documents as

listed but not limited to;

i.) The Occupational Health and Safety Act 2007 Kenya

ii.) ISO 14001:2015

iii.) Environmental Management and Coordination Act 1999 – EMCA

iv.) National Profile on Occupational Safety and Health of 2013 - Kenya

v.) International Labor Laws - ILO

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8.0 Annexes

1. MT HSE Procedure Health Management

2. MT HSE Procedure Environmental Management

3. MT HSE Procedure Excavation and tunneling

4. MT HSE Procedure Risk Assessment

5. MT HSE Procedure Job Safety Analysis

6. MT HSE Procedure Confined space Entry

7. MT HSE Procedure Manual Lifting

8. MT HSE Procedure Compressed Air

9. MT HSE Procedure Electrical Safety

10. MT HSE Procedure Concrete and Shot-crete

11. MT HSE Procedure Hazardous Chemicals and Substances

12. MT HSE Procedure Machine, Power and Hand-tools

13. MT HSE Procedure Fuel Handling

14. MT HSE Procedure Security Plan

15. MT HSE Procedure House Keeping

16. MT HSE Procedure Fire Prevention

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