Manual - Overview

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Date : 01/11/10 Page : : 1 Rev No. : 2 Issue No : 1

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PGEO EDIBLE OILS SDN BHD

OCCUPATIONAL SAFETY AND HEALTH

MANUAL

(OSH MANAGEMENT SYSTEM)





TABLE OF CONTENT

1.0 Company profile & scope - 3 - 4

2.0 Reference - 5

3.0 Terms and definitions - 6 - 8

4.0 OSH management system elements - 9

4.1 General requirements - 9

4.2 OSH Policy - 9 - 10

4.3 Planning - 11 4.3.1 Hazard identification, risk assessment and determining controls - 11 - 15 4.3.2 Legal and other requirements - 16 - 18 4.3.3 Objectives and programme(s) - 19 - 23

4.4 Implementation and operation - 23 4.4.1 Resources, roles, responsibility, accountability and authority - 23 - 29 4.4.2 Competence, training and awareness - 30 - 31 4.4.3 Communication, participation and consultation - 31 - 32 4.4.4 Documentation - 32 - 33 4.4.5 Control of documents - 33 4.4.6 Operational control - 34 4.4.7 Emergency preparedness and response - 35 - 36

4.5 Checking - 37 4.5.1 Performance measurement and monitoring - 37 - 38 4.5.2 Evaluation of compliance - 38 4.5.3 Incident investigation, nonconformity, corrective action and - 39 Preventive action

4.5.3.1 Incident investigation - 39 - 40 4.5.3.2 Nonconformity, corrective action and preventive action - 40

4.5.4 Control of records - 41 4.5.5 Internal audit - 42 - 43

4.6 Management review - 44 - 45





1.0 COMPANY PROFILE

a. Name of Company : PGEO Edible Oils Sdn Bhd

b. Year of established : 1979

c. Registration No : 14202-V

d. Company structure Wholly owned by PGEO Group Sdn Bhd.

e. Location & production office : PLO 338, Jalan Tembaga Dua, Kawasan Perindustrian Pasir Gudang, P.O Box 80, 81707 Pasir Gudang, Johor.

f. Contact & Tel No : 07-268222 (D/L) 07-2514970 (fax)

g. Person In-charge: Badarudin bin Asaari

h. E-mail : [email protected]

i. Managing Director : Yee Chek Toong

j. General Manager : Loh Chee Kheong

k. Nature of Business : Edible oil processing and packaging

l. Total employees : 557 excluding contract workers

m. No of factories (Pasir Gudang) : 2

n. Product market : Mainly export market to India, China, Middle East countries, New Zealand, Russia, Singapore, Pakistan, Japan and European countries.

o. Established product brands : Neptune, Seri Murni, Krystal, Viking, (local and export) Meizan and Simply

p. Category Industry High Risk Industry (under PAGEMA classification)

q. High Risk Plant Extraction Plant, Solvent Plant, Hydrogenation Plant, Boiler operation, Biodiesel Plant and Acid Plant.





1.2 SCOPE

1.2.1 The company recognized that safety, health and the protection of the environment is of prime importance in the management of its business. The achievement of high standards of safety and health consideration throughout all its activities are essential as its results in greater efficiency, better working conditions and enhancement of its reputation as an employer.

1.2.2 Safe and healthy working conditions create an environment from which employer and employee benefit and it is the responsibility of both management and employees to work together to achieve this goal. In its effort to achieve these aims the company is committed to the provision of an adequate level of resources to enable the aims of this policy to be achieved.

1.2.3 A documented OSH Management System manual includes the range of diverse and pertinent information that will aid all levels of management and employees in their daily operations. Emphasis is directed to the continual improvement and the implementation of safe systems of work associated with everyday activity and specific job tasks.

1.2.4 A positive pro-active `OSH culture is the ultimate aim of PGEO EDIBLE OILS SDN BHD, where OSH is manifested in everyday thoughts and action of the entire workforce. An OSH concern makes good business sense and it shall be the responsibility of all employees to conduct good business safely.

1.2.5 The purpose of this manual is to provide guidelines of the companys Occupational Safety and Health Management System to ensure the achievement of continuous improvement. The objectives of the manual are to :

a. Defined basic items of the system to ensure the achievement of objectives and targets,

b. Provide information of the aspects of OSH that will aid all levels of management and employees in planning, implementing auditing management system in order to satisfy company, legal and social obligation,

c. Assist company to implement safe system of work associated with everyday activity and specific job tasks and management systems to enhance companys OSH performance,

1.2.6 This manual is intended to cover all activities carried out by PGEO employees, contractors and visitors associated with the companys activities in PGEO in order to protect them against risks to safety or health arising out of the activities.

1.2.7 Scope of the coverage of companys activities is: a. Manufacture of Steel Drums b. Blending and Packaging of Edible Oils c. Hydrogenation and Refining of Vegetable Oils d. Processing of Vegetable Oils and Oils Seed





2.0 REFERENCE

2.1 BS OHSAS 18001:2007 & MS1722

2.2 Occupational Safety and Health Act 1994 (OSHA 1994)

2.3 Factory and Machinery Act 1967 (FMA 1967)





3.0 TERM AND DEFINITIONS

3.1 Acceptable risk Risk that has been reduced to a level that can be tolerated by organization having regard to its legal obligations and its own OSH policy (ref. 3.16 PGEO OSH policy).

3.2 Audit A systematic examination process, independent and documented process for obtaining `audit evidence and evaluating it objectively to determine the extent to which `audit criteria are fulfilled.

3.3 Continual improvement Recurring process of enhancing the OSH management system in order to achieve improvements in overall OSH performance consistent with the companys OSH policy.

3.4 Corrective action Action to eliminate the cause of a detected nonconformity or other undesirable situation.

3.5 Document Information and its supporting medium.

3.6 Hazard Source, situation or act with a potential for harm in terms of human injury or ill health or a combination of these.

3.7 Hazard identification Process of recognising that a hazard exists and defining its characteristics.

3.8 ill Health Identifiable, adverse physical or mental condition arising from and or made worse by a work activity and or work related situation.

3.9 Incident Work related event(s) in which an injury or ill health (regardless of severity) or fatality occurred or could have occurred.

3.10 Interested party Person or group, inside or outside the workplace concerned with or affected by the OSH performance of company.

3.11 Nonconformity Non-fulfillment of requirement. Any deviation from work standards, practices, regulation management system performance etc. That could either or indirectly lead





to injury or illness, property damage, damage to the workplace environment or a combination of these.

3.12 Occupational safety and health (OSH) Conditions and factors that affect or could affect the health and safety of employees or other workers (including temporary workers and contractor personnel), visitors or any other person in the workplace.

3.13 OSH management system Part of overall management system that facilitates the management of OSH risks associated with the business of the company. This includes the company structure, planning activities, responsibilities, practices, procedures and resources of developing, implementing, achieving, reviewing and maintaining the companys OSH policy.

3.14 OSH objective OSH goal in term of OSH performance that the company sets itself to achieve.

3.16 OSH performance Measurable results of OSH management system related to the companys control of health, safety and environment risk based on its OSH policy, objectives and targets.

3.17 OSH policy Overall intentions and direction of the companys related to its OSH performance as formally expressed by top management. The OSH policy provides a framework for action and for the setting of OSH objectives.

3.18 Preventive action Action to eliminate the cause of potential nonconformity or other undesirable potential situation. There can be more than one cause for a potential nonconformity. Preventive action is taken to prevent occurrence whereas corrective action is taken to prevent recurrence.

3.19 Procedure Specified way to carry out an activity or a process.

3.20 Record Document stating results achieved or providing evidence of activities performed.

3.21 Risk Combination of the likelihood of an occurrence of a hazardous event or exposure(s) and the severity of injury or ill health that can be caused by the event or exposure(s).

3.22 Risk assessment Process of evaluating the risk(s) arising from a hazard(s), taking into account the adequacy of any existing controls and deciding whether or not the risk(s) is acceptable.





3.23 Workplace Any physical location in which work related activities are performed under the control of the company.

3.24 Company PGEO EDIBLE OILS SDN BHD





4.0 OCCUPATIONAL SAFETY AND HEALTH MANAGEMENT SYSTEM ELEMENTS

4.1 General requirements.

4.1.1 A documented PGEO OSH management system shall be establish and maintained in order to achieve objectives and targets based on section 4.2 OSH policy.

4.1.2 Standards related to these elements shall be established and executed as procedures to ensure the efficient and effective implementation of the OSH management system.

4.1.3 The OSH system management framework is constructed and operated as illustrated in figure 1 (OSH Management System Framework)

4.2 PGEO OCCUPATIONAL SAFETY & HEALTH POLICY

OCCUPATIONAL SAFETY AND HEALTH POLICY

The management of PGEO Edible Oils Sdn Bhd is committed in protecting its employees and responsible for the full implementations of the following principles:-

To provide and maintain a clean, safe and healthy working environment at all times.

To identify and correct any potential hazard arising from plant processes and work activities.

To ensure adequate control of occupational safety and health risks, which include communication with suppliers, customers, transporters, contractors and visitors.

To provide adequate instruction, training, supervision and other relevant occupational safety and health information to employees.

To comply with the Act and regulations enforced by the authorities and governing bodies.

To practice a safe working culture.

_______________

Loh Chee Kheong General Manager 3 November 2010

Revision no. 3





4.2.1 PGEOs Occupational Safety & Health Policy (here in after also referred to as OSH policy) provides an overall sense of direction and sets the principles of action relating to OSH which are to integrated into the overall business process throughout PGEO.

4.2.2 It also provides the means of communicating PGEO management objectives and demonstrates the formal commitment of the PGEOs top management towards good OSH management particularly in managing OSH that may affect personnel or impose on the environment as a result of the company business activities.

4.2.3 The OSH policy shall be documented implemented and maintain and communicated to all employees.

4.2.4 The OSH policy is appropriate to the nature and scale of company risk.

4.2.5 It is also includes a commitment to prevention of injury and ill health and continual improvement in OSH management and performance.

4.2.6 The PGEOs OSH policy includes a commitment to at least comply with applicable legal requirements and with other requirements to which the company subscribes that relate to its OSH hazards.

4.2.7 Should provide the framework for setting and reviewing OSH objectives and available to interested parties.

4.2.8 PGEO OSH policy is reviewed periodically to ensure that it remains relevant and appropriate to the company. Other requirements as stated in the OSH policy refers to the following:

a. National and international standard and requirements

b. Guidelines from Malaysian Government

c. Best management practice





4.3 PLANNING

4.3.1 HAZARD IDENTIFICATION, RISK ASSESSMENT AND DETERMINING CONTROL (HIRAC)

Chart 1 : HIRAC Process

RESPONSIBILITY INTERFACE

HOD / SHO / OSH committee

HOD / SHO

SHO - e-mail/memo

HOD / SHO / - on site activity OSH committee

SHO / OSH Committee

SHO

HOD

HOD / SHO

Supporting Doc: Doc. No. OSH - HIRAC/01/08/Rev 2 (No: )

Discussion of HIRAC activities

Classify work activities/process/plant

Announcement of HIRAC activities

Conduct HIRAC

Decide risk category

Prepare recommended Corrective Action request (CAR)

Performance Measurement and Monitoring for CAR

Review CAR





4.3.1.1 Identification of hazards and effects typically requires the application of tools and techniques such as chemical health risk assessment (CHRA), Job safety analysis (JSA) and environment risk & impact assessment.

4.3.1.2 Once the hazards or effects have been identified and assessed, they shall be considered against an OSH risk screening criteria.

4.3.1.3 Screening criteria are values or standards against which the identified hazards or effect can be judge such as engineering standards, environment quality standards and exposure limits.

4.3.1.4 In managing OSH risk, PGEO shall adopt the principle of standard methodology risk to minimize the level of risk as low as reasonable practicable.

4.3.1.5 Using a qualitative and quantitative risk assessment, the assessment risk can be regarded as either acceptable or not acceptable.

4.3.1.5 The basic on how HIRAC can be achieved is as follows:

a. Wherever possible design out risk b. Incorporate risk reduction measure c. Where the risk is clearly intolerable, decide if the continued presence in that area of

workplace is contrary to the company business principles.

4.3.1.6 The hazards and effects register should be reviewed regularly. The period of review may vary depending on:

a. The nature of hazards b. The magnitude of risks c. Changes from normal operation d. New plant or process e. Incident cases

4.3.1.7 The review should also take place if changes within the PGEO organization raise the question on the validity of the hazard identification, risk assessment and risk control (HIRAC) process. Such change may include PGEO expansion, construction, restructuring, re-apportioning responsibilities and changes to methods of working or patterns of behavior.

4.3.1.8 PGEOs shall establish, implement and maintain a procedure(s) for the ongoing hazard identification, risk assessment and determination of necessary controls. The procedure(s) for hazard identification and risk assessment shall take into account:

a. Routine and non-routine activities b. Activities of all persons having access to the workplace (including contractors and

visitors)





c. Human behavior, capabilities and other human factors d. Identified hazards originating outside the workplace capable of adversely affecting the

health and safety of persons under the control of the company within workplace. e. Hazard created in the vicinity of the workplace by work related activities under the

control of the company. It may be more appropriate for such hazards to be assessed as an environmental aspect.

f. Infrastructure, equipment and materials at the workplace whether provided by the company or others.

g. Changes or proposed changes in the company, its activities or material. h. Modifications to the HSE management system including temporary changes and their

impacts on operation, processes and activities. i. Any applicable legal obligations relating to risk assessment and implementation of

necessary controls. j. The design of work areas, processes, installations, new plant & machinery or

equipment, operating procedures and work, including their adaptation to human capabilities.

4.3.1.9 The companys methodology for hazard identification and risk assessment shall:

a. Be defined with respect to its scope, nature and timing to ensure it proactive rather than reactive, and

b. Provide for the identification, prioritization and documentation of risks and the application of controls as appropriate.

c. The processes of assessment within PGEO workplace require the participation of all levels within the PGEOs.

4.3.1.10 For the management of change, companys shall identify the OSH hazards and OSH risk associated with changes in the companys, the OSH management system or its activities prior to the introduction of such changes.





4.3.1.1 Environmental Aspects and Impacts

i) This Environmental Aspects and Impacts element defines PGEO requirement to have a process to determine environmental aspects that have or can have significant impacts to the environment.

ii) This process shall allow PGEO to identify, evaluate and control the aspects and impacts on an ongoing basis and be applicable to all activities carried out throughout all operations by PGEO employees, contractors and visitors associated with the company activities. These shall cover but not limited to:

1. Routine and non-routine activities 2. Potential emergency conditions 3. New process 4. Introduction of new operational procedures 5. Chemicals and material handling 6. Changes or modifications of system and process. 7. Pre-commissioning of equipment, system etc.

iii) The process should take into account the cost and time of undertaking the availability of reliable data and the degree of practical control that PGEO may have over the environmental aspects being considered.

iv) The relationship between environmental aspects and impacts is one of cause and effect as follows:

1. Environmental Aspect refers to an element of companys activities, products that can have beneficial or adverse impact on the environment. For example it could involve a discharge an emission, consumption or reuse of material or the creation of excessive noise.

2. Environmental Impact refers to any change to the environment, whether adverse or beneficial wholly or partially from the companys activities or products.

v) A procedure shall be established, implemented and maintained to identify the environmental aspects of its activities or product that it can control and over which it can be expected to have an influence, in order to determine those which may have significant impacts on the environment.

vi) The aspects related to these significant impacts should be considered while setting specific HSE objective and targets for all work at each section.





vii) All environmental aspects that may arise out of and in the course of the companys activities or products should where relevant consider:

a. Emissions to air b. Release to water c. Waste management d. Use of raw materials e. Other local environmental f. The effects of noise pollution

viii) The process of identifying significant environment aspects is carried out at generic level as described in detail in hazard identification, risk assessment and risk control element.

Supporting Document.

a. Cross reference : Waste management manual Rev 1.





4.3.2 LEGAL AND OTHER REQUIREMENTS

Chart 2: Legal and Other Requirements

Legal

List of Legal And other

Requirements

As above

As above

SHO

OSH Committee

OSH Committee. GM

Identification and accessing of legal requirements & others

requirements

Identify on how to meet the requirement

Objective and Program

Monitor

Check the effectiveness of the implementation

Update Register, Procedure, Work Instruction

Information to affected Department





4.3.2.1 This legal and other requirements element defines PGEOs requirement to understand how its activities and products are or will be affected by Malaysian Acts and Regulations as well as applicable legislation of the country in which the company operates.

4.3.2.2 The requirements also include compliance to International Conventions and Protocols ratified by the Malaysian Government.

4.3.2.3 The compliance of all applicable OSH legislation shall apply for all activities, which includes activities carried out by PGEO employees, subcontractors and third parties associated with the company activities.

4.3.2.4 A procedure shall be established, implemented and maintained for identifying assessing and communicating the Malaysian Acts and Regulations and other relevant legislation that are applicable to health, safety and environment issues related to PGEO activities and products.

4.3.2.5 The Safety and Health Officer (SHO) shall be responsible for identifying the legal and other requirements and shall maintain regular contacts with the relevant authorities and companies with similar business nature within the region to keep fully informed of any changes in Legislation or Codes of Practice which may affect the way the company operates.

4.3.2.5.1 A register of all Acts and Regulations relevant to OSH matters shall be developed and the relevant department within PGEO that to do have legal requirements mapped to their activities and products are responsible to ensure that their activities and products are in compliance to the relevant Legislative Acts regulations and Codes of Practice.

4.3.2.6 The SHO, shall be responsible to initiate the update of the Register of OSH Acts and regulations upon the publishing of any new legal requirements or in the events of amendments of the existing legal requirements.

4.3.2.7 The new identified and updated legal requirements shall be discussed as an agenda in the Management Review to determine its applicability to PGEOs activities and products.

4.3.2.8 The SHO, is responsible to ensure that the latest copy of Legislative Acts, Regulations and Codes of Practice pertaining to OSH are made available.

4.3.2.9 Communication sessions shall be conducted throughout the organisation for all employees. This information will also be made available to the subcontractors.





4.3.2.10 The following applicable Acts and subsequent Regulations shall be referred to and applied in All PGEO operations. The list is however, not exhaustive and is subjected to regular review by the SHO. Below are listed the key government acts and regulations. An expanded definitive list available from the PGEO administration on request.

4.3.2.12 Reference a. Factory and Machinery Act, 1967 (act 139) b. Occupational safety & Health Act (OSHA) 1994 (Act 514) c. Environmental Quality Acts, 1974 and amendments. d. BS OHSAS 18001:2007 & MS 1722 e. International standard (where applicable)





4.3.3 OBJECTIVES AND PROGRAMMES.

Chart 3: Objectives

ACTION RESPONSIBLE PARTY

1) - SHO

NO

- SHO & OSH Committee

YES

2) - GM/MD

3) - HOD

4) - HOD

Planning of overall objectives and target of the works

Discussion & approval from OSH

Approval of overall objective

and targets

Reflection into objectives and targets of each department

Periodical review





4.3.3.1 This element defines PGEOs OSH objectives and provides a framework on how the intents and objectives of the companys OSH policy shall be implemented throughout the employees at each department.

4.3.3.2 When establishing and reviewing its objectives, each division shall consider: a. Legal and other requirements that can be referred to the legal register distributed

to each division. b. OSH hazards and risks that is based on HIRAC register output. c. Technological option. d. Operational and business requirements, and e. The views of interested parties such as PGEOs clients, corporate, etc.

4.3.3.3 The implementation of this OSH policy shall cover but need not necessarily be limited to the following objectives:

4.3.3.4 Employees at all levels shall demonstrate their commitment to OSH policy issues and ensure that these are given priority and not compromised.

4.3.3.5 Appropriate health, safety and environmental hazard identification, risk assessment and risk control systems shall be carried out to eliminate or reduce the risks to a level as low as reasonably practicable.

4.3.3.6 Will comply with all OSH legislation, international conventions and protocols or international standard and best practices.

4.3.3.7 Will implement OSH management programmes to achieve the OSH objectives and targets. E.g: conduct OSH meeting at company and divisional level.

4.3.3.8 Shall monitor and measure OSH performance on a regular basis across the organisation to determine compliance to HSE legislation, PGEOs OSH objectives, targets and plans.

4.3.3.9 Will investigate and analyze all accidents/incidents, near missed, property damaged, dangerous occurrence and non conformance to prevent recurrence by eliminating potential causes of non conformities.

4.3.3.10 OSH records shall be kept in a safe place, readily retrievable and protected from deterioration e.g. accident/incident report, audit report.

4.3.3.11 PGEO shall conduct periodic internal and independent OSH management system audits to verify that the implementation of companys activities conforms to the requirements of the OSH management system.

4.3.3.12 PGEO shall conduct periodic management review of the OSH management system to achieve continual improvement of the companys OSH performance and





to verify that the OSH management system is working as intended throughout the company.

4.3.3.13 The objectives of PGEO OSH management as follows:-

a. To provide and maintain a work environment that is safe and without risk to health for all employees, contractors and others who may be affected by the activities or processes of the company.

b. To avoid all accidents and to ensure that no one suffers ill health as a result of working at PGEO premise.

c. To plan and manage activities so that hazards are assessed and risks eliminated in so far as is reasonably practicable by appropriate protection and prevention measures.

d. To achieve zero (0) accident & illness.





4.3.4 OSH Management Programme (s)

Chart 4: OSH Management Programme(s)

ACTION RESPONSIBLE PARTY

1)

2) - SHO

3) NO

- SHO & OSH YES Committee

4) - GM/MD

5) - HOD

6) - HOD

Company overall objectives and target

Discussion & Approval

Approval of the OSH management Program(s)

Reflection into the OSH management program(s) of each department

Periodical review

Planning of OSH management program(s)





4.3.4.1 OSH management programme(s) element defines PGEO requirement on the creation, documentation and use of the management programmes, which is a key factor to the successful implementation of the OSH management system.

4.3.4.2 The requirement to participate in the OSH management programmed(s), shall apply equally to OSH employees, subcontractors and visitors, associated with the company activities.

4.3.4.2 The programmed(s) shall describe how the organisations objectives and targets will be achieved, including time scales and personnel responsible for delivering the organisations OSH objectives and targets at each relevant level.

4.3.4.3 Prior to implementation of OSH programmed(s), OSH shall carry out proper training to ensure that the requirements of the programme(s) is communicated to relevant personnel. It should also provide for the allocation of suitable resources e.g. financial, human and equipment.

4.3.4.4 The programme(s) shall be reviewed at regular intervals and amended (where necessary) to address changes of modifications in working practices, processes, equipment or material for ensuring continual improvement. New hazard identification and risk assessment exercise should be included in the programme to cater for the changes or modifications.

4.3.4.5 The programme (s) shall be devised for further encourages employees participation in OSH programme(s). This could be done through recognition of their contributions in company publications or through awards programme(s).

4.4 IMPLEMENTATION AND OPERATION

4.4.1 Resources, Roles, Responsibility, Accountability and Authority.

4.4.1.1 Top management of PGEO shall take ultimate responsibility for OSH and OSH management system.

4.4.1.2 The structure and responsibility element defines the salient OSH roles, responsibilities and accountabilities of personnel who manage, perform and verify activities having an effect on the OSH risks of the organisations activities, facilities and processes.

4.4.1.3 Top management of PGEO shall demonstrate its commitment by:

a. Employees at all levels shall demonstrate their commitment to OSH policy issues and ensure that these are given priority and not compromised.





b. Appropriate health, safety and environmental hazard identification, risk assessment and risk control systems shall be carried out to eliminate or reduce the risks to a level as low as reasonably practicable.

c. Will comply with all OSH legislation, international conventions and protocols or international standard and best practices.

d. Will implement OSH management programmes to achieve the OSH objectives and targets. E.g.: conduct OSH meeting at company and divisional level.

e. Shall monitor and measure OSH performance on a regular basis across the organization to determine compliance to OSH legislation, PGEOs OSH objectives, targets and plans.

f. Will investigate and analyze all accidents/incidents, near missed, property damaged, dangerous occurrence and non conformance to prevent recurrence by eliminating potential causes of non conformities.

g. OSH records shall be kept in a safe place, readily retrievable and protected from deterioration e.g. accident/incident report, audit report.

4.4.1.4 PGEO shall conduct periodic internal and independent OSH management system audits to verify that the implementation of companys activities conforms to the requirements of the OSH management system.

4.4.1.5 PGEO shall conduct periodic management review of the HSE management system to achieve continual improvement of the companys HSE performance and to verify that the HSE management system is working as intended throughout the company.





4.4.1.6 Structure & Responsibility

4.4.1.7 Chart 1: Organization Structure

Managing Director

General Manager

Plant Manager

Plant Section Head

Employees

Safety & Health Officer





4.4.1.7 The structure and responsibility element defines the salients OSH roles, responsibilities and accountabilities of personnel who manage, perform and verify activities having an effect on the OSH risks of the organizations activities, facilities and processes.

4.4.1.8 Adequate resources shall be provided to enable OSH tasks to be performed and the documented responsibilities and authorities of personnel clearly communicated to facilitate OSH Management.

4.4.1.9 PGEO organization structure reflects the overall responsibility of companys management for the implementation of the OSH management System within their area of authority.

4.4.1.10 The PGEO organization is headed by Managing Director / General manager who shall have the ultimate responsibility and accountability for all safety and health and the protection of environment throughout PGEO premises.

4.4.1.11 Each department in PGEO is responsible for its OSH implementations and performance. OSH committees therefore have been established at company and department level to provide a framework within which OSH performance can be monitored toward achieving the objectives.





4.4.1.12 Structure & Responsibility - Safety & Health Committee

4.4.1.12.1 Chart 6: Safety & Health Committee

Chairman (Top Management or Appointed Manager)

Management Representatives (Head of Department/Section)

(Drum Plant, Specialty Fats, Consumer Packing, Pump House, Maintenance/Electrical, Security, Store, Extraction,

Refinery, Dry Fractionation, Warehouse, Admin/HR, Operation, Lab, Boiler)

Secretary (SHO)

Employees Representatives

(Drum Plant, Specialty Fats, Consumer Packing, Pump House, Maintenance/Electrical, Security, Store, Extraction,

Refinery, Dry Fractionation, Warehouse, Admin/HR, Operation, Lab, Boiler)





4.4.1.13 Responsibility of Chairman a. Composition chaired by top management or appointed representatives. b. To chaired the OSH Committee meeting quarterly. c. To manage, monitor and evaluate all OSH activities, Policy, objectives and

programmes including the effectiveness of the OSH Management System.

4.4.1.14 Responsibility of Secretary a. Safety & Health Officer (SHO) shall be the secretary of the PGEO Safety &

Health Committee. b. To be responsible for all OSH activities including planning programmes,

strategies and the effectiveness of programmes implementation. c. To monitor progress and review the improvement of objectives and targets.

4.4.1.15 Responsibility of Management Representatives a. To monitor progress and review the effectiveness of OSH programs b. To review strategies and provide direction to raise OSH performance c. Represent management on OSH issue. d. To promote OSH program and activities at their department.

4.4.1.16 Responsibility of Employees Representatives a. The appointed employee at each department / section shall act as the

employees representative and will sit in the OSH committee meeting. b. Appointment of employees representatives is done through voting by

employees at their department/section or appointed by head of department. c. Communicates OSH information to all employees. d. Participate in the meeting. e. Discuss and deliberates OSH related problems and complaints arising from the

employees within own function during meeting. f. Assists their respective department head to coordinate all OSH system related

activities within their function. g. Documents and updates operating work instruction related to OSH system. h. Discuss any OSH problem arising from their function. i. Promotes OSH activities within their function.

4.4.1.17 General Responsibility of OSH Committee a. Implement, guide and monitor all activities and arrangements associated with

the OSH management System within the respective department. b. Review audit reports within the respective department and provide necessary

directives and resources to correct deficiencies for continual OSH improvement c. Set company targets and meet the targets requirement. d. Review major incidents and losses and follow-up recommended action. e. Review major incidents and losses and follow-up recommended action. f. Promote OSH through involvement in training and education programmes g. Develop OSH activity programmes to involve all the members h. Discusses and deliberates OSH procedures and work instructions





i. Review, endorse and assist in the development of OSH rules and safe system of work.

j. Communicate with OSH management committee through the exchange of minutes of meeting.

k. Joint the OSH committee meeting minimum once in three (3) month. l. Carry out and assist SHO to studies on the trends of incidents that occur at place

of work and provide recommendations for corrective actions. m. Review the OSH policy and make recommendations to top management for any

revision. n. Assist SHO to plan, organize and conduct workplace inspection minimum once

in three months. o. Assist SHO to conduct investigation for any case of complaint or incident that

occurred at place of work. p. Conduct internal audits of the OSH system regularly (every 6 months).

4.4.1.18 Responsibility of Employees a. Participates and cooperates for any OSH activities organized by the management. b. Aware of the following: i. General OSH information ii. OSH policy iii. Potential significant OSH risks or hazards of their activities / workplace. iv. Potential consequences of deviation from specified operating procedures and work instructions.

c. The roles and responsibilities of those related to the OSH management of the other personnel are included in the job description and also as stated in the OSHA 1994.





4.4.2 COMPETENCE, TRAINING AND AWARENESS

4.4.2.1 Chart 7: Competence, Training and Awareness Responsibility Interface

SHO/ Security Officer

HOD/Section Head

as above

HR

1. Cross reference to HR Manual. Section 2. 2. On Job Training (OJT)-Form No: SF/ESO/01/10

4.4.2.2 PGEO shall ensure that any person(s) under its control performing tasks that can impact on OSH is (are) competent on the basis of appropriate education, training or experience and shall retain associated records.

4.4.2.3 A competence assurance procedure shall be established, implemented and maintained for ensuring that personnel performing specific OSH critical activities and tasks are competent on the basis of appropriate,

a. Personal abilities and awareness through education b. Acquired knowledge through training c. Skills developed through experience

4.4.2.4 The competence assurance shall be applied to initial recruitments and selection for new activities for PGEO employees.

4.4.2.5 The continuing competency of personnel to perform their duties shall be reviewed regularly and training shall be provided for changing activities and technologies.

Safety Induction

On Job Training (safety matters)

(OJT)

Training evaluation

Update records





4.4.2.6 Managers and supervisors are responsible for ensuring the employees under control are competent to meet their responsibilities and accountabilities by the annual performance appraisal and providing inputs on their training needs to OSH management and HR.

4.4.2.7 PGEO shall identify training needs associated with its OSH risks and itrs OSH management system. It shall provide training or take other action to meet these needs, evaluate the effectiveness of the training or action taken and retain associated records.

4.4.2.7 Training procedures shall take into account differing levels of responsibility, ability, language skills, literacy and risk.

4.4.2.8 PGEO shall established, implement and maintains a procedure(s) to make persons working under its control aware of,

a. The OSH consequences, actual or potential of their work activities, their behavior and the OSH benefits of improved personal performance,

b. Their roles and responsibilities and importance in achieving conformity to the OSH policy and procedures nd to the requirements of the OSH management system, including emergency preparedness and response requirements.

c. The potential consequences of departure form specified procedures.

4.4.3 COMMUNICATION, PARTICIPATION AND CONSULTATION

4.4.3.1 COMUNICATION

4.4.3.1.1 With regard to its OSH hazard and OSH management system, PGEO shall establish, implement and maintain a procedure(s) for:

a. Internal communication among the various levels and functions of the organization. The various means : i. PGEO OSH Committee meeting ii. Departmental Production meeting

iii. New Project meeting iv. OSH induction programme(s) for new employees and contractors. v. OSH refresher programme(s) for employees and contractors vi. Communication and distribution of information through OSH

campaigns, workshops, warta PGEO and companys memorandum. vii. Issuance of PGEO OSH rules and regulations handbook viii. Issuance of lesson learnt from any incidents through internal

communication system, i.e e-mail and briefing to the related employees.





b. All employees shall be represented on OSH matters at the relevant OSH committee. They will be informed as to who is their employee representative and specific management representative.

c. The communication process shall apply for all PGEO employees, contractors and visitors associated with the company activities.

d. The receiving, documenting and responding of the PGEO OSH procedures should also address necessary communications with relevant public authorities regarding emergency planning and other relevant issues.

4.4.3.2 PARTICIPATION AND CONSULTATION

4.4.3.2.1 PGEO shall establish, implement and maintain a procedure(s) for: a. The participation of workers by their: i. appropriate involvement in hazard identification, risk assessments and determination of controls, ii. appropriate involvement in incident investigation,

iii. appropriate in the development and review of OSH policies and objectives,

iv. consultation where there are any changes that affect on OSH system and procedures,

v. representation on OSH matters such as OSH activities, meeting and briefing etc. Workers shall be informed about their participation arrangements including who is their representative(s) on OSH matters.

b. Consultation with contractors where there are changes that affect on OSH system, activities and procedures.

d. PGEO shall ensure that, when appropriate, relevant external interested parties are consulted about pertinent OSH matters.

4.4.4 DOCUMENTATION

4.4.4.1 The documentation element defines PGEO requirement to document and maintain up to date sufficient documentation to ensure that the OSH management system can be adequately, effectively understood and efficiently operated.

4.4.4.2 The PGEO OSH management system documentation shall include the following: a. PGEO OSH policy and objectives b. The description of the scope of the PGEO OSH management system c. The description of the main elements of the PGEO OSH management system and their interaction and reference to related documents





d. The documents including records, determined by PGEO OSH management to be necessary to ensure the effective planning, operation and control of processes that relate to the management of its OSH risks. e. The documented PGEO OSH management system shall be structured into three-tier set of documents comprising:

i. PGEO)s) OSH management System Manual (Overview on the requirements of the standard and supporting procedures) ii. PGEO OSH Procedure Manual iii. PGEO OSH Instruction Manual

4.4.5 CONTROL OF DOCUMENTS

4.4.5.1 The control of documents element describes the requirements on the control and identification of all documents and data containing information of OSH management system and the performance of PGEO OSH activities.

4.4.5.2 A procedure shall be established, implemented and maintained for controlling all internal and external documents and data relevant to the OSH management

c. they can be located d. approve documents for adequacy prior to issue e. review and update as necessary and re-approve documents f. ensure that changes and the current revision status of documents are identified g. ensure that relevant versions of applicable documents are available at points of

use (available and accessible). h. ensure that documents remain legible and readily identifiable i. ensure that documents of external origin determined by the organization to be

necessary for the planning and operation of the OSH management system are identified and their distribution controlled

j. prevent the unintended use of obsolete documents and apply suitable identification to them if they are retained for any purpose.

4.4.5.3 All revisions shall be documented and revision status assigned. The nature of changes to the document shall be identified.

4.4.5.4 Documents shall be reissued after a practical number of changes have been made.

4.4.5.5 All document under routine and non routine condition including emergencies e.g. CSDS, PGEO fire protection system, drawing, instruction etc.

Cross reference to QAM sec 4 control of document.





4.4.6 OPERATIONAL CONTROL

4.4.6.1 The operational control element defines PGEOs requirement to identify those operations and activities that are associated with identified risks and environmental aspects fulfilling its OSH Policy, objectives and targets and conforming to legal and other requirements where control and counter measures need to be applied.

4.4.6.2 The requirements of operations and activities procedures shall be established, implemented and maintained in order to control identified risks to be cover.

a. Overall OSH management system b. Control related to purchased goods, equipments and services c. Control related to contractors and other visitors to the workplace d. Situations where their absence could lead to deviations from OSH Policy,

Objectives and Targets e. Design of workplace, process, installation, machinery, operating procedures

and changes of work activities or modification of work system including their adaptation to human capabilities in order to eliminate OSH risks at their source.

4.4.6.3 All the OSH procedures shall be reviewed regularly for its suitability and effectiveness and identified changes shall be implemented.





4.4.7 EMERGENCY PREPAREDNESS AND RESPONSE (ERP)

4.4.7.1 Chart 8: Emergency Preparedness and Response

Responsibility Activity Interface

SHO/HOD/ - Legal requirements ERP Team OSH Comm.

As above - Emergency Plan - Inventory of Equipment - Inspection Schedule - Inspection checklist - Training Schedule - Drill plan

MD/GM/HOD - emergency plan OSH Comm/ ERP Team

As above - drill & post mortem report

As above - Non-conformance report. - CAR / Preventive Action Plan As above - Drill report Corrective action plan

As above

Recognition - Identification of potential Plant/Area for drill

Readiness - Emergency Plan - Emegency & Equipment - Training & Competency - Practice Drill - Communication

Response - response for selected dept. - response for all dept.

Performance, Measurement & Monitoring

Corrective & Preventive Action

Records

Review





4.4.7.2 PGEO OSH management shall establish, implement and maintain procedures of ERP to:

a. identify the potential for emergency situations b. response to such emergency situations

4.4.7.2 The main requirement of PGEO ERP is to manage an effective response for any incidents and emergency situation which occurring in PGEO premise and also from the neighbors and for preventing and mitigating the likely illness, injury abnd damage that may arise out of or in the course of PGEO activities.

4.4.7.3 The requirement for ERP shall apply for all PGEO activities that include activities carried out by PGEO employees, contractor and visitors.

4.4.7.4 ERP shall address among others with the following areas;

a. Emergency coordination and response between PGEO management, employees and related ERP team & OSH Committee.

b. Communication with local authority or PAGEMA and other relevant parties. i.e neighboring plant, factory and public.

c. Mobilization of company equipments, facilities, personnel and third party resources for emergency support.

d. Provision of personnel rescue, refuge, evacuation and medical treatment. e. Training arrangement for ERP team and for testing the Contingency plan f. Availability of necessary information during emergency .e.g plan layout

drawing, CSDS, procedures, work instruction and contact number. g. Prevention and monitoring environmental impact resulting from the emergency

actions.

4.4.7.5 SHO (with advice from MD/GM/Top management) shall develop and maintain the required ERP to cater for any major risks or emergencies that may occur in PGEO.

4.4.7.6 SHO shall plan, decide and get approval from the top management on the classification of the incident in which category the emergency reaponse plan is to be declared and activated.

(Cross reference: ERP Procedures & Evacuation Manual)





4.5 CHECKING

a. Checking procedures is very important matters in OSH management system. It is a complete continuing process involving checking on the performance, measurement, monitoring and evaluation of the all system.

b. As part of the OSH management system, it is very important that the procedures, activities, records and other related documentation in place and always up to date in order easy to evaluate and review the effectiveness of the system.

4.5.1 PERFORMANCE, MEASUREMENT AND MONITORING (PMM)

4.5.1.1 PMM elements defines PGEOs requirement of identifying key performance parameters for OSH performance across PGEO.

4.5.1.2 The requirements shall apply for all PGEO activities including contractor and visitors.

4.5.1.3 PGEO OSH management shall established, implemented and maintained a procedures to monitor and measure OSH performance on a regular basis as mention below:

a. Both qualitative and quantitative measures, appropriate to the needs of the organization.

b. Monitoring of the extent to which PGEO OSH management meet the achievement of OSH policy, objectives and targets.

c. Monitoring the effectiveness of controls on both safety and health as well as for environment.

d. Provide reactive measures of performance that monitor conformance with the OSH program, control and operational criteria.

e. Provide reactive measures of performance that monitor ill health, incidents (including accidents, near-misses, etc) and other historical evidence of deficient OSH performance.

f. Ensure the sufficient recording of data and results of monitoring and measurement to facilitate corrective and preventive action analysis.





4.5.1.4 OSH performance measuring including the following;

a. HIRAC results. b. Workplace inspection c. OSH auditing d. Spot check on PPE e. Surveys the attitudes towards OSH management system and OSH practices among employees.

4.5.1.5 PGEO OSH management shall established, implemented and maintained the procedures for the calibration of equipment including the following item;

a. list of equipment b. the frequency of calibration c. identify the equipment for calibration and action taken d. record and results e. status of equipment

4.5.2 EVALUATION OF COMPLIANCE

4.5.2.1 PGEO OSH management shall establish, implemented and maintained a procedure for periodically evaluating compliance with applicable legal requirements. It is consistent with its commitment to compliance of OSH policy.

4.5.2.2 PGEO OSH management shall keep records of the results of the periodic evaluations based on the frequency of requirement (by legal) for future reference.

4.5.2.3 The compliance shall be evaluated with other requirements which it enforce by the legal as for comparison. The separate procedure shall be established, implemented and maintained based on the system or process suitability.

4.5.2.4 The compliance shall be evaluated at least once a year.

Supporting Doc: Legal & Other Requirements (Master List) : General Procedure - G.P 29.10





4.5.3 INCIDENT INVESTIGATION, NONCONFORMITY, CORRECTIVE ACTION AND PREVENTIVE ACTION

4.5.3.1 INCIDENT INVESTIGATION

4.5.3.1.1 Chart 9 : Incident Investigation & Reporting Process Flow

Responsibility Incident Interface

Security

Security inform SHO/Admin

To call sub committee Meeting to discuss About the incident

Finding report to GM (Approval)

Legend: *Verbal informing *Informing with accident

investigation form

Independent Panel Meeting / Investigation

Report Finding to Admin Form: IR/SHO/PGEO (Rev 1)

Further investigation by SHO / Safety committee

Section Head/HOD fill up Accident Reporting Form

(form:IR/dept/PGEO (Rev 1)

Section Head report to Dept. head.

Witness/Victim Report to Section Head

Fire & Explosion Chemicals spillage Industrial Accident





4.5.3.1.2 The element of PGEO requirement relating to;

a. the management of non-compliance to the requirements of PGEO OSH management system and the associated procedures. b. the investigation and reporting of incidents including near misses, that may arise out of and in the course of PSEO activities.

4.5.3.2 NONCONFORMITY, CORRECTIVE ACTION AND PREVENTIVE ACTION

4.5.3.2.1 PGEO OSH management shall establish, implement and maintain a procedure(s) for dealing with actual and potential nonconformities and for taking corrective action and preventive action.

4.5.3.2.2 The management of corrective and preventive action shall apply for all PGEO employees and contractor which associated with the company activities.

4.5.3.2.3 The corrective and preventive action shall be implemented to the new or changes hazards or the need for new or change controls, the procedure shall require that the proposed actions shall be taken through a risk assessment prior to implementation.

4.5.3.2.4 Any necessary changes arising from corrective and preventive action in the documented procedure resulting from corrective and preventive action shall be recorded.

4.5.3.2.5 The procedures shall define requirements for :

a. identifying and correcting nonconformities and taking action to mitigate OSH consequences

b. investigating process of nonconformities, determining their causes and taking actions in order to avoid any recurrence

c. evaluating the need for actions to prevent nonconformities and implementing appropriate actions designed to avoid their occurrence

d. recording and communicating the results of corrective actions and preventive actions taken

e. reviewing (follow up) the effectiveness of corrective actions and preventive actions taken





4.5.4 CONTROL OF RECORDS

4.5.4.1 Control of records element defines PGEO OSH management for the maintenance of a system of records to document and demonstrate compliance to the requirement of OSH management system, OHSAS standard and its associated procedures and shall be apply to all PGEO activities & operations.

4.5.4.2 The procedure shall be establish, implemented and maintained to identify, collect, index, compile, file, store and dispose of OSH records and protected against damage, deterioration or loss.

4.5.4.3 Records shall be legible, identifiable and traceable.

4.5.4.4 Below is the list of required OSH records but not limited to the following: a. HIRAC records b. Auditing records c. Workplace inspection records d. Industrial accident and incident reports e. Independent Panel (incident) reports f. Safety & Health meeting minutes g. Medical Health Surveillance records h. CHRA reports i. Audiometric Test report j. Noise mapping records k. Local Exhaust Ventilation (LEV) Reports l. OSH training records (HR) m. Machineries list records

4.5.4.5 The retention time of the document as follows:

No. Documents Year to be keep Action by a HIRAC Record 7 SHO b Auditing Records 7 SHO c Workplace Inspection Records 7 SHO d Industrial Accident and Incident Report 7 SHO e Independent Panel (incident) Reports 7 SHO f Safety & Health Meeting Minutes 7 SHO g Medical Health Surveillance Records 30 SHO h CHRA Reports 5 SHO i Audiometric Test Report 30 SHO j Noise Mapping Records 5 SHO k Local Exhaust Ventilation (LEV) Reports 5 SHO l OSH Training Records (HR) As long as worker

still working HR

m Machineries List Records (Certificate of Fitness)

2 SHO





4.5.5 INTERNAL AUDIT

4.5.5.1 Chart 9: Internal Audit Process Flow

Responsibility Interface

SHO

SHO/Committee Dept. Head

SHO - e-mail/memo

Safety Committee

Audittee/Sec Head HOD

SHO/Safety committee

SHO/Safety - Audit summary Committee NCR

SHO/HOD - NCR/ CAR

SHO/OSH Committee

Reference Doc. 1. CAPAR - Form No: SF/CAR-01 2. Audit Finding Report - Form No: SF/FR-08 (Rev 4) 3. Audit Checklist - Form No: SF/CL-01 (Rev 1)

Procedure

Planning

Conduct Audit

Arrangement

Announcement

Corrective Action Request (CAR)

Audit Checklist

Review

Follow up audit report

Audit Finding report





4.5.5.2 PGEO OSH management shall ensure that internal audits of the OSH management system are conducted at planned intervals to:

a. determine whether the OSH management system is effectives and meet with OSH policy & objectives. b. has been implemented and is maintained. c. Conforms to planned arrangements of OSH management including the

requirements of this OHSAS standard. d. provide information on the results of audits to management.

4.5.5.3 The internal auditing shall be carried out quarterly by the safety committee (internal auditor).

4.5.5.4 The internal auditing shall cover all aspect of safety procedures at each plant/department.

4.5.5.5 SHO is responsible for establishing, maintaining and coordinating the PGEO audit schedules and ensure that the audit conducted according to the OSH audit procedure and process.

4.5.5.6 The internal auditor shall conducting the audits according to the audit procedure .

4.5.5.7 Audit findings and any corrective actions will be communicated to the relevant department.

4.5.5.8 The inter auditor shall report all findings after the audit and report in the safety committee meeting.

4.5.5.9 The auditee is required to assign a guide to accompany the auditor during the audit and cooperate with the requests of the auditor and provide unfettered access to staff, documents and records relevant to the audit.

4.5.5.10 SHO will be communicating the results of audit to top management for acknowledgement and further approval if any.





4.6 MANAGEMENT REVIEW

4.6.1 The top management of PGEO shall review the organizations OSH management system at planned intervals to ensure its continuing suitability, adequacy and effectiveness.

4.6.2 The management review shall include assessing opportunities for improvement and the need for changes to the OSH management system, including the OSH policy and OSH objectives.

4.6.3 All records of the management reviews shall be retained.

4.6.4 The management review shall be carried out by PGEO OSH management committee according to a prepared agenda at least once in six(6) month.

4.6.5 The input to management review shall include the following:

a. Results of internal audits and evaluations compliance with applicable legal requirements and also the effects of changes in legislation and technology.

b. The results of participation and consultation on OSH activities which carried out at PGEO premises (refer to 4.4.3.2).

c. Relevant communication(s) from external interest parties including complaints.

d. The performance of OSH management system of the organization.

e. The extent to which objectives have been met.

f. The status of incidents investigation, corrective actions and preventive action and the current HIRAC process.

g. Follow-up action from previous management reviews (if any).

h. Changing circumstances including developments in legal and other requirements related to OSH.

i. Recommendations for improvement on OSH activities and program and also the current levels of risk and existing control measures.





j. The assessment of the overall effectiveness of implementation the OSH management system within the department.

4.6.6 The outputs from management reviews shall be consistent with the company commitment to continual improvement and shall include any decisions and actions related to possible changes to:

a. OSH performance. b. OSH policy & objectives c. Resources and other elements of the OSH management system

4.4.7 Relevant outputs from management review shall be made available for communication and consultation as per reference on 4.4.3.

Manual - Overview

Documents

solvent plant

hydrogenation plant

biodiesel plant

acid plant

company structure

corrective action

preventive action

company profile scope