CLIENT
CLIENT
: ZCL CHEMICALS LTD.
PROJECT DESCRIPTION: API MANUFACTURING FACILITY UNIT- IV
DOCUMENT NAME: PROJECT HEALTH SAFETY AND RISK MANAGEMENT PLAN
AND PROCEDURES
DOCUMENT NO.
: P363-DOCZ-HSE-PP-5000_Rev
Aevitas Pharmagro PROJ. NO.: P363
ZCL Chemicals Limited.
1806/807, 215, Atrium,Chakala, Andheri-Kurla Road,Andheri(E),
Mumbai - 400 059. India.
APPROVAL AND AUTHORIZATION
REVISION DETAILS
INDEX
1. 0INTRODUCTION6
2. 0SCOPE7
3. 0PRINCIPLES OF HEALTH SAFETY AND ENVIRONMENTAL
MANAGEMENT8
4. 0HSE POLICY AND OBJECTIVES9
5. 0ROLES AND RESPONSIBILITIES13
6. 0Statutory Requirement19
7. 0Subcontractors Management20
8. 0RISK ASSESSMENT PROCESS22
9. 0PRE-EMPLOYMENT MEDICAL SURVEILLANCE 24
10. 0ORIENTATIONS AND MEETINGS 25
11. 0HSE COMMUNICATION27
12. 0HEALTH AND SAFETY MEETINGS28
13. 0HEALTH, SAFETY AND ENVIRONMENTAL INCIDENT INVESTIGATIONS
AND REPORTING30
14. 0INSPECTIONS35
15. 0EMERGENCY RESPONSE PLAN (ERP)38
16. 0SITE ACCESS AND SECURITY40
17. 0RECORD KEEPING REQUIREMENT43
18. 0MANAGEMENT OF CHANGE45
19. 0MANAGEMENT REVIEW47
20. 0WORK PROCEDURES48
A.1HOUSEKEEPING50
A.2COMPRESSED GAS CYLINDERS52
A.3PERSONAL PROTECTIVE EQUIPMENT (PPE)53
A.4HAZARDOUS MATERIALS MANAGEMENT57
A.5Machine Guarding60
A.6Working at Height61
A.7EQUIPMENT MAINTENANCE AND INSPECTION63
A.8VEHICLE AND MOBILE EQUIPMENT SAFETY64
A.9HAND AND POWER TOOLS67
A.10TRIPPING, SLIPPING AND FALLING HAZARDS71
A.11MANUAL LIFTING SAFETY73
A.12HAZARD IDENTIFICATION - BARRICADES AND WARNINGS74
A.13SAFE WORK PERMIT SYSTEM76
A.14TAGGING AND LOCKOUT79
A.15CONFINED SPACE ENTRY84
A.16ELECTRICAL SAFETY88
A.17OPERATING NEAR ELECTRICAL LINES90
A.18OPERATION AND INSPECTION OF CRANES AND HOISTS92
A.19USE AND INSPECTION OF RIGGING96
A.20ELEVATING WORK DEVICES98
A.21LADDERS, SCAFFOLDINGS AND FLOOR OPENINGS102
A.22WELDING, GRINDING AND CUTTING SAFETY105
A.23EXCAVATION, trenching AND SHORING SAFETY108
A.24FLAMMABLE AND COMBUSTIBLE LIQUIDS116
A.25HOT WEATHER118
A.26FIRE SAFETY121
A.27FIRE EXTINGUISHERS122
A.28PRESSURE TESTING124
A.29CHEMICAL CLEANING126
A.30RADIOACTIVE MATERIALS127
A.31EXPLOSIVE BLASTING130
A.32WILDLIFE SAFETY137
A.33INCLEMENT WEATHER138
1. 0 INTRODUCTION
This Project HSE Management Plan and Procedure summarizes the
applicable health and safety regulations and procedures for the ZCL
Chemicals API Manufacturing Facility Project. It will be
periodically reviewed and updated in order to be adapted to changes
that arise in the Project. Any infringement of the provisions of
this Plan will result in disciplinary measures up to and including
expulsion from the Project site.
The Plan is not exhaustive therefore, all Aevitas Pharmagro
employees, client representatives, Contractors, suppliers,
personnel and visitors must be familiar with the applicable legal
requirements that are not explicitly mentioned in this document. In
case of divergence between the requirements of the Project Health
Safety and Risk Management Plan and the applicable local
legislation, the stricter requirement will apply. When a reference
to a standard is mentioned in this Plan, an equivalent standard may
be substituted.
The fundamental objective of this Plan is to eliminate hazards
to the health, safety and physical integrity of workers.
It outlines the measures to be implemented, programs to be set
up and human resources to be deployed in order to prevent
incidents.
Consequently, incident prevention on the Project site will be a
priority not only during the construction period, but also during
all other phases of the Project.
This Plan will help us achieve the Projects ZERO INCIDENT
objective. Note that information concerning this Plan will be
communicated to Contractors or subcontractors during bid
solicitations and will be appended to contract documents.
This Plan is a tool that will be disseminated widely on the
Project. All Contractors, suppliers, personnel and visitors must
comply with its requirements, in order for the Project to be
carried out safely and without incidents. In case of a dispute,
Aevitas Pharmagros Plan will take precedence over all Contractor
Health, Safety and Environment Plans.
2. 0 SCOPE
The Aevitas Pharmagro management team is committed to a healthy
and safe working environment. The success of the Health, Safety and
Environment Program depends on its implementation at every level
throughout the organization and all personnel engaged in every
project, facility and office. Experience shows that sound accident
prevention techniques and principles result in a healthy, safe and
productive workplace. To ensure the realization of this objective,
this Project Health and Safety Risk Management Plan and Procedure
is established to provide awareness and participation by all
persons.
Prior to commencement of any work, all Aevitas Pharmagro
employees, staff, management, its subcontractors, and their
supervisors shall review and understand the contents of this Plan.
The use of this manual will promote safety and environmental
compliance as well as provide a consistent approach to achieving
injury/incident-free performance.
All Sub-contractors will be responsible for safe work practices
and conditions of their employees and subcontractors, and will
ensure that the work does not result in hazards to themselves or to
others. Every worker on at all sites will be required to adhere to
the procedures and safe practices as defined by this Project Health
and Safety Risk Management Plan & Procedure.
The overall goal of this plan is to maintain quality and
integrity in all facets of construction, operation, and all other
activities while maintaining the health and safety of all clients'
personnel and the protection of property and environment.
This will be achieved by adopting policies of accident/incident
prevention as follows:
1. Eliminating unsafe conditions. Accidents are caused by unsafe
physical condition of equipment or mechanical, electrical exposure
to the working environment.
2. Minimization of unsafe acts by providing competent
supervision to ensure that workers use proper techniques and
methods.
3. Taking advantage of every opportunity to correct unsafe acts
or conditions before an injury occurs.
4. Avoiding, minimizing the negative impacts of actions on the
natural environment.
5. Ensuring compliance to regulatory and industry standards.
3. 0 PRINCIPLES OF HEALTH SAFETY AND ENVIRONMENTAL
MANAGEMENT
3.1 The Sub-Contractor has overall responsibility for the
health, safety and environmental elements under its control in
accordance with Aevitas Pharmagro's Project Health Safety and Risk
Management Plan and Procedures. This responsibility will be
maintained throughout its association with Aevitas Pharmagro.
3.2 The Sub-Contractor's health, safety and environmental
program and its implementation will meet or exceed industry
standards and the requirements of all governing regulatory
bodies.
3.3 Copies of its Health, Safety and Environment Program will be
made available to the Aevitas Pharmagro's Management team including
their field supervisory staff, HSE personnel, and any
Sub-Contractors for reference and implementation during their scope
of work.
3.4 The Sub-Contractor will have its current safety and
environment programs and historical performance records evaluated,
and shall submit a written commitment to such objectives along with
its bid submittal, if any.
3.5 The Sub-Contractor will be responsible to advise all its
personnel and subcontractors of the project's safety and
environment goals, policies, requirements and procedures in all
orientation sessions. This will be a mandatory precedent before any
person commences employment or visit at project site.
3.6 Each employee is responsible for his/her own safety and the
safety of co-workers by following safe work procedures, and by
reporting sub-standard acts and conditions to their immediate
supervisor. Every worker has the right to refuse to perform work
that he/she considers has unsafe conditions no penalties will apply
for refusing to work in unsafe conditions.
3.7 Aevitas Pharmagro and Sub-Contractor management personnel
will promote assist and participate in safety meetings, audits and
reporting to reinforce the importance of safety and environment on
the project site.
4. 0 HSE POLICY AND OBJECTIVES
4.1 Specific Policy Regarding Occupational Health and Safety on
Construction Sites
This specific policy issued by Aevitas Pharmagro constitutes the
minimum requirement in occupational health, safety and
environmental matters and applies to the Project Construction site
in Ankaleshwar, Gujarat. This specific policy constitutes the
minimum requirement in such matters and applies to all construction
sites. It is the object of a specific prevention program.
The safety of workers and other participants on Aevitas
Pharmagro construction sites is a priority objective and takes
precedence over any other activity or consideration.
On its construction sites, Aevitas Pharmagro aims at eliminating
the very causes of dangers to workers health, safety and physical
integrity.
Risks will be identified and managed by focusing on behaviors,
perceptions and skills that will achieve growth and make the
project safer.
Risks will be mitigated at the most fundamental level in project
design, infrastructure, construction and operations. Any one risk
could result in several different outcomes with incidents being
only one of the possibilities.
Safety on construction sites is everyone's business: Aevitas
Pharmagro, Contractors, Subcontractors, the Project Manager,
worksite supervisory personnel, security personnel, the workers
themselves and the organizations representing them.
Aevitas Pharmagro has identified measurable objectives which are
specific and will be subject to periodic review to ensure
continuous improvement. The following are the established Project
health, safety and environmental objectives to which all the
Project's participants will subscribe and strive to achieve:
1. Zero fatalities.
2. Zero lost time incidents (injuries and work-related
illnesses).
Aevitas Pharmagro Management is committed to providing active
leadership and full support in order to develop and maintain an
industry-leading health, safety and environmental programs.
It is in the best interest of all parties to consider health,
safety and the environment in every activity. Commitment to health,
safety and the environment is an integral part of our organization,
and we expect the full collaboration of all employees.
N.T. Balraj
February12st, 2015
With regard to occupational health and safety matters on
worksites where Aevitas Pharmagro has a mandate, the Contractor
agrees to a minimum involving the follow-up and following
reports:
1. A written report on the nature of worksite risks and the
identification of means for eliminating them, plus the
identification of the manager in charge.
2. A monthly report on the frequency and seriousness indications
from the worksite.
3. A report relating to every serious or fatal accident
including the circumstances surrounding the accident, causes as
identified and recommendations for avoiding a repetition of such an
accident.
The Contractor is directly liable for the performance of its
contract where safety is concerned.
The Contractor agrees to provide itself with the means and
instruments enabling it to apply this policy on worksites; such
means may include, among other things, contractual provisions or
other means such as inspections, safety committee, etc.
The Contractor shall ensure that the organization of work on
worksites and the methods and techniques in use are safe and do not
prejudice the health of anyone.
In particular, the Contractor shall ensure the proper upkeep of
the worksite and the providing of adequate sanitary facilities.
The Contractor shall ensure that the emission of a contaminant
or other hazardous substance on the construction site does not
prejudice the health or safety of anyone working on such site.
The Contractor shall ensure that worksite personnel have
received adequate training and information regarding:
1. Risks arising from the work.
2. Means for avoiding a risk.
3. On-site First Aid services.
Each Contractor or Subcontractor, whose indication of frequency
or indication of seriousness is deemed to be unacceptable, may be
required by Aevitas Pharmagro to submit a recovery plan aimed at
eliminating the life or health threatening risks for anyone on its
worksite. It shall then immediately apply this recovery plan to the
worksite.
4.2 Smoking policy
The Aevitas Pharmagros Project site is a non-smoking site except
for areas designated for smoking. Smoking is prohibited in all
vehicles and mobile equipment on site. Smoking is only permitted in
designated areas provided with fire extinguishers, appropriate
receptacle with caution board Please Stub Cigarettes / Bidees
before throwing. Smoking-related waste and located a minimum of 50
meters from any potential hydrocarbon source or flammable material.
Disposable lighters and self-striking matches are banned from the
project site.
4.3 Health Safety and Environment Objectives
The following are the established project health and safety
objectives to which all the project's participants will subscribe
and strive to achieve:
1. No fatalities.
2. Zero lost time incidents (injuries and work-related
illnesses).
3. Minimum medical treatments and First Aids cases.
4. Continuing reduction of incidents which could lead to any of
the above.
5. No spills or environmental releases/impacts under their or
Aevitas Pharmagro's control or authority.
6. All wastes disposed of in full compliance with prevailing
legislation, Aevitas Pharmagro and/or ZCL Chemicals and Applicable
Local rules and procedures.
7. Minimize wastes whenever possible and feasible through
adherence to good engineering practice and sound environmental
practices.
4.4 Sub-Contractor's Health & Safety Program
The Sub-Contractor will submit a copy of its written health,
safety and environment program and policies prior to the start of
any work. These programs shall comply with all prevailing
applicable legislation and be approved by the Corporate Health and
Safety Manager.
All Sub-Contractor's health, safety and environmental programs
shall include the following elements:
1. A written health, safety and environment program document
that includes the procedures and policies for effective health,
safety and environmental management.
2. A current statement of HSE Policy signed by senior
management.
3. A written health, safety and environment program document
that includes specific policies and procedures for effective HSE
management.
4. Implementation of the program with consideration for other
contractors.
5. Convening regular site safety meetings and pre-work employees
orientations.
6. Posting safety bulletin boards, signs and posters when
approved by Aevitas Pharmagro and/or client/owner.
7. Promoting a consistently respectful, interested and
enthusiastic attitude towards Aevitas Pharmagro's Project Health
and Safety Risk Management Plan.
8. Ensuring that its supervisors are competent.
9. Performing inspections and audits where specified by
prevailing legislative jurisdiction and/or Aevitas Pharmagro's
Project Health and Safety Risk Management Plan and correcting all
unsafe working conditions that are identified.
10. Installing and implementing adequate fire prevention
equipment and procedures.
11. Provision of appropriate First Aid facilities, equipment and
certified personnel sufficient treat its employees.
12. Provision of transportation to medical center's (doctors,
clinics, hospitals, etc.) when required legislatively or
contractually.
13. Applying adequate prevention measures and procedures against
spills and other workplace hazards.
A copy of the Sub-Contractor's safety statistics for the
previous five years shall be included with the Contractor's health,
safety and environment programs. It shall include all recognized
statistical (Worker Compensation, etc.) information that is
applicable in the region where the project is being performed.
5. 0 ROLES AND RESPONSIBILITIES
5.1 Aevitas Pharmagro Project Manager
The Project Manager shall be responsible to:
1. Facilitate the implementation of Health and Safety processes,
procedures and activities;
2. Ensure appropriate Health and Safety standards are developed
and implemented;
3. Ensure project risks assessments are conducted;
4. Participate in investigations and ensure implementation of
corrective actions following major accidents;
5. Ensure all necessary layers of protection required are
provided to reduce risk to an acceptable level;
6. Ensure sufficient Health and Safety resources allocation;
7. Ensure training requirements are fulfilled;
8. Conduct observations while visiting site;
9. Attend Health and Safety meetings and ensure corrective
actions implementation if deemed necessary;
10. Participate in the implementation of the Emergency Response
Plan;
11. Review Health and Safety monthly reports and ensure
correctives actions implementation;
12. Monitor the progress of Health and Safety activities and
processes.
5.2 Aevitas Pharmagro Construction Manager
The Construction Manager shall be responsible to:
1. Ensure site-specific Health and Safety programs including
training and communication programs are elaborated prior to onset
of works;
2. Ensure compliance to projects policies, procedures and
activities;
3. Inform quickly the ZCL Chemicals representatives and local
authorities of any incident;
4. Review incident reports and ensure correctives actions
implementation;
5. Monitor the progress of Health and Safety activities and
processes;
6. Review the monthly Health and Safety report and implement
corrective actions;
7. Conduct observations when visiting site;
8. Participate in the implementation of the Emergency Response
Plan;
9. Ensure an induction training session is provided to all
workers arriving at the site, that they are informed of the site
particularities and the Health and Safety Program;
10. Ensure subcontractors submit corrective actions whenever
required to;
11. Ensure Aevitas Pharmagro personnel are knowledgeable of the
Health and Safety Program;
12. Setup subcontractors Health and Safety reviews;
13. Implement emergency response plan and coordinate
activities;
14. Ensure subcontractors are committed to their site-specific
Health and Safety program and to the Aevitas Pharmagro Health and
Safety program;
15. Ensure Health and Safety contractual obligations are
met;
16. Attend Health and Safety meetings and ensure corrective
actions implementation;
17. Ensure subcontractors, undertake the required actions to
implement this Health and Safety program at their expenses;
18. Take appropriate actions in case of non-compliances;
19. Ensure coordination of various works in order to eliminate
hazardous situations that could result from the interaction of
several subcontractors;
20. Ensure risk assessments are conducted and implement the
necessary layers of protection required to ensure risks are reduced
to an acceptable level;
21. Ensure each subcontractor attend a kick-off meeting prior to
mobilization;
22. Ensure active participation and involvement of all
workers;
23. Participate in incident investigations;
24. Implement site access through a security system;
25. Ensure coverage as per requirements in case of overtime,
working alone, high risk works, works on more than one work
shift;
26. Conduct monthly Health and Safety performance assessments of
subcontractors;
27. Conduct Health and Safety performance assessment at contract
closeout for each subcontractor;
28. Ensure subcontractors submit remediation plan in case of
sub-standard Health and Safety performance;
29. Ensure that first aid kits and provisions are provided by
each subcontractor.
5.3 Aevitas Pharmagro Health, Safety and Environment
Manager/Engineer
The Health, Safety and Environment (HSE) Manager/ Officer
reports to the Aevitas Pharmagro Corporate Health and Safety
Manager, and implements and administers Aevitas Pharmagro's Project
Health and Safety Risk Management Plan at project sites. He
provides the Construction Manager and Sub-Contractors with guidance
and advice to achieve the project's health, safety and
environmental objectives.
The specific function of the Aevitas Pharmagro HSE
Manager/Engineer is as follows:
1. Monitor and report on compliance with Aevitas Pharmagro
Project Health and Safety Risk Management Plan by all
Sub-Contractors and their personnel at sites.
2. Maintain knowledge of current governing regulations, codes
and practices, and inform the Construction Manager whenever
revisions to the site-specific Aevitas Pharmagro Project Health and
Safety Risk Management Plan are required.
3. Ensure that the Sub-Contractor's health, safety and
environmental procedures are incorporated into the Aevitas
Pharmagro Project Health and Safety Risk Management Plan and
Procedures.
4. Ensure that the Contractor supplies, maintains, operates and
locates all safety, first aid, medical and fire-fighting equipment
in accordance with legislated requirements. Confirm that the
Contractor has reliable emergency medical transportation
available.
5. Ensures undertaking of, or conducts investigations and
reviews of all incidents such as accidents, incidents, health
exposures, disabling injuries, and fatalities, and produce
investigation reports for circulation to the required
authorities.
6. Ensure that all personnel employed on a project comply with
the applicable regulations, and maintain a co-operative working
relationship with the relevant officials.
7. Prepare and file all HSE reports related to the project as
required by ZCL Chemicals /legislation, and immediately transmit
copies of such reports to the Client (if required), Construction
and Project Manager as well as the Corporate HSE office.
8. Diligently record, file and keep safe all reports, including
those required by governing regulatory agencies, until the end of
the project, and then archive same with other project
documents.
9. Ensure that the Sub-Contractor's HSE
representative/Supervisors conduct daily toolbox safety meetings
with their crews.
10. Conduct job specific HSE training programs for workers and
staffs.
11. Conduct periodically Site HSE Meeting with subcontractor and
maintain the record of it.
12. Ensure that the Sub-Contractor and its subcontractor/s
provide health and safety induction/orientation sessions for all
their personnel and visitors.
13. Provide a supply of safety and personal protective equipment
for Aevitas Pharmagro personnel, and ensure that it is properly
utilized and maintained. Maintained record of it.
14. Carry out Job Safety Analyses (JSA) with subcontractor and
update accordingly and maintain copies for records.
15. Carrying out Risk Assessment (RA) with subcontractor and
update accordingly and maintain copies for records.
16. Inspection of all electrical, mechanical, vehicles and
lifting equipments and maintained record of it.
17. Review daily site health and safety inspection and
reporting. Monitor as appropriate.
18. Issuance of stop work instructions when safety conditions
require such action.
19. Provide assistance to contractors in the implementation of
the Aevitas Pharmagro Project Health and Safety Risk Management
Plan.
20. Initiate site-specific HSE reports as required and transmit
copy of report to Client (if required) and Corporate HSE
Office.
21. When applicable, monitor all aspects of traffic safety
concerning staging, diversions, illumination, signals, and
temporary signs/road markings. Maintain communications with
relevant authorities.
5.4 Aevitas Pharmagro Engineers/Supervisors
1. Participate in risks review sessions and ensure that control
measures are implemented;
2. Conduct planned HS inspections as required;
3. Participate in incident investigations;
4. Participate in Health and Safety meetings;
5. Ensure workers attend a Health and Safety induction training
session prior to onset of work;
6. Ensure workers training and certification requirements and
certification are met;
7. Ensure disciplinary measures follow-up and documentation;
8. Ensure proper reporting of workplace hazards;
9. Ensure an effective implementation of corrective actions.
5.5 Sub-Contractor Site HSE Representative
The subcontractor safety representative shall be responsible
to:
1. Ensure implementation of Health and Safety Program;
2. Ensure non-compliances and unsafe conditions are readily
addressed;
3. Assist incident investigations to determine root causes and
ensure implementation of corrective actions;
4. Ensure workers are properly using the correct Personnel
Protective Equipment (PPE) and safety devices for the work being
performed, and that they are properly trained in the use of their
tools/equipment and PPE.
5. Perform inspections on service ability of PPE, tools and
equipment of work area;
6. Provide industrial hygiene and work environment monitoring
including noise and air quality as required;
7. Conduct Emergency response drills;
8. Ensure that compliant firefighting equipment is installed and
workers have been trained in their proper use;
9. Set a good example for workers by enforcing safety,
industrial hygiene and environmental rules, regulations and
standards;
10. Monitor and report daily to Aevitas Pharmagro and HSE
Manager/Engineer on the subcontractors Health and Safety
activities;
11. Participate in the Health and Safety Committee if
required;
12. Conduct meetings to explain the safety measures associated
with daily tasks and discuss Health and Safety information as
issued by the Aevitas Pharmagro HSE Manager / Officer;
13. Ensure liaison with other subcontractor representatives and
monitor their practices where they interface;
14. Ensure that First Aid / Medical facilities are equipped /
staffed in accordance with legislated requirements.
15. Encourage safety suggestions from the workers.
16. Ensure prompt incident reporting and first aid
assistance;
17. Provide HSE training to workers and staff as required.
18. Instruct workers on safe work practices and associated
hazards;
19. Provide and maintain HSE records.
5.6 Sub-Contractor Supervisors
The specific safety- and environment-related functions of the
Sub-Contractor's supervisors and foremen will include the
following:
1. Set a good example for workers by enforcing safety,
industrial hygiene and environmental rules, regulations and
standards.
2. Instruct workers under their supervision on safe work
practices, and the hazards associated with the assigned tasks at
commencement of each work assignment.
3. Ensure that workers are properly using the correct personal
protective equipment (PPE) and safety devices for the work being
performed, and that they are properly trained in the use of their
tools and equipment. Perform frequent checks on serviceability of
all personal protective equipment (PPE) and tools/equipment.
4. Lead in the investigation of Sub-Contractor's accidents to
determine all the facts necessary to take corrective action.
5. Conduct daily "tool box" talks to explain the safety measures
associated with the tasks for the day, and discuss safety
information that is issued by the Sub-Contractor's site safety
representative and the HSE Manager/Engineer. Encourage safety
suggestions from the workers.
6. Ensure that workers report all incidents/accidents, and
ensure that prompt First Aid is administered to injured
workers.
7. Conduct, document and implement Job Safety Analysis (JSA) and
relevant requirements of same.
5.7 Workers
Any worker on site shall be responsible for:
1. His own safety and the safety of co-workers by complying to
safe work procedures;
2. Be on guard at all times to prevent against his own safety
risks, or putting others who might be working nearby at risk of
bodily injury;
3. Use available PPE and protection devices;
4. Report any unsafe conditions and near misses to immediate
supervisor;
5. Maintaining his work area clean and uncluttered;
6. Complying with danger indications and signs;
7. Refuse to undertake a task if he does not know the risks
associated with it and for which he considers as unsafe
conditions;
8. Refuse to operate equipment without proper training;
9. Be familiar with the HSE Program objectives, policies and
procedures;
10. Be familiar with all safety information provided to him
through posters, information bulletins and other means;
11. Request explanations to his immediate superior for measures
and/or HSE directives, when necessary;
12. Participate in training as required;
13. Actively participate in meetings and sign attendance
records.
6. 0 Statutory Requirement
Aevitas Pharmagro will ensure that at all times the Applicable
Statutory Requirements shall be complied. A dedicated focus will be
given to:
1. Indian Factory Act, 1948
2. Gujarat State factory act 1948 and rule 1963.
3. Building and Other Construction Workers Act, 1996
7. 0 Subcontractors Management
7.1 General Requirements
The Aevitas Pharmagros criteria will be outlined for procurement
of materials, equipment and services. All work undertaken,
equipment and materials by suppliers and vendors shall meet the
Aevitas Pharmagro criteria. Health and Safety will be of primary
consideration in contract awards, construction planning and
execution.
Accordingly, each subcontractor:
1. Is directly liable for the performance of its contract where
Health and Safety are concerned;
2. Agrees to provide means and instruments in order to apply
this Health and Safety Program;
3. Ensure that the organization of work on site, methods and
techniques in use are safe and do not endanger anyone;
4. Will be held accountable for all Health and Safety elements
under his control throughout the life cycle of the project;
5. Will meet or exceed construction industry standards,
requirements of Local Regulatory Bodies and Aevitas Pharmagro
Health and Safety program;
6. Will be assessed based on their historical performance
records over the last 3 years;
7. Will be advised of the ZCL Chemicals project goals, policies,
requirements and procedures;
8. Ensure that the mandatory HSE orientation will be carried out
prior to onset of employment on site;
9. Ensure each worker is responsible for his own safety and that
of co-workers by following safe work procedures;
10. Ensure effective reporting of all unsafe conditions to the
immediate supervisor;
11. Shall not apply penalties if a worker refuses to work in
unsafe conditions;
12. Management representatives will promote, assist and
participate in safety meetings, audits and reporting;
13. Shall submit a recovery plan aimed at eliminating risks upon
Aevitas Pharmagros request.
Whenever its performance are deemed to be unacceptable. Each
subcontractor shall submit a site specific Health and Safety
Program consistent with requirements of this Program and inclusive
of the following items:
1. Procedures applicable to its specific activities and policies
for effective management;
2. Implementation of the program with consideration to other
site subcontractors;
3. Convening of regular site safety meetings;
4. Strategic communication (safety bulletin boards, signs and
posters);
5. Promotion of a consistently respectful, interested and
enthusiastic attitude towards the Health and Safety;
6. Provision of competent safety supervision of all workers;
7. Inspections, audits, corrective actions of all unsafe working
conditions;
8. Provision of appropriate first aid kits, equipment and
certified personnel;
9. Installation of adequate fire prevention equipment, related
procedures and training;
10. Assume a charge back for transportation to a medical
facility upon Aevitas Pharmagro request.
Each subcontractor will ensure that the training requirements of
the Health and Safety Program are assessed according to the scope
of work during the pre-qualification process.
Subcontractors will be expected to provide their own training
matrix to meet the Health and Safety program requirements before
onset of work.
The training assessment will be based on:
1. Work at height;
2. Confined spaces entry;
3. Safe work permit;
4. Safe blinding;
5. Lock Out Tag Out;
6. Excavation;
7. Scaffold erection;
8. Temporary Electrical Lines and Connections;
9. Other Aevitas Pharmagro requirements.
8. 0 RISK ASSESSMENT PROCESS
8.1 Project Risks and opportunities
High-level risks are identified by a multidisciplinary team
composed of Aevitas Pharmagro, Granules-Omnichem representatives
and Subcontractors representative. Risks are listed in a risk
register which provides details such as, owner, activity, risk
level, control measures and action plans.
For every work package, risk identification and assessment shall
be documented in a risk Register.
8.2 Control Measures
Throughout the projects life cycle, Aevitas Pharmagro will
privilege these risk mitigation methods to obtain an
As-Low-As-Reasonably-Practical (ALARP) level:
1. Elimination this is the most effective control method. In
many cases, the risk can be designed-out or designed-in safety;
2. Substitution involves replacing the hazard or process with a
safer one, e.g., replacing toxic solvents with detergents;
3. Redesign done where the processes can be redesigned to reduce
or eliminate risk, e.g., modifying the exhaust system to reduce
noise;
4. Separation the hazard from the person involves isolating the
hazard from the person or the person from the hazard;
5. Defining safe behaviors list the safe behaviors required to
execute the work properly, including conducting pre-start checks,
etc.
6. Administrative measures JSA, Safe Work Permits, developing
written step-by-step safe work procedure for the hazardous
tasks;
7. Personal Protective Equipment (PPE) PPEs shall be used where
the hazards are in place.
8.3 Risk Assessment
Hazards related to activities and risk associated with it shall
be assessed and relevant control measure will be implemented. Risk
Assessment of specific activities shall be done by the team of
subcontractors supervisors, Aevitas Pharmagro Construction Manager,
HSE Manager/Engineer and Supervisors and worker representative.
Record of Risk Assessment shall be kept throughout the project life
cycle.
The Risk Owner, risk Custodian and any other specialists (as
required) review the risks at different frequencies depending on
its level prior to implementation of control measures:
1. HIGH and VERY HIGH risks are reviewed on a monthly basis;
2. MEDIUM risks are reviewed every 2 months;
3. LOW risks are reviewed every 3 months.
8.4 Job Safety Analysis (JSA)
The purpose of the JSA is to assess and control risks associated
with construction activities. It is also a tool to plan the job
safely. Supervisors perform JSAs along with input of employees in
the work activity and the support of HSE personnel.
A JSA has to be performed for any activity listed in the Risk
Register prior to starting a new activity on site or when changes
occur (new product, material, work organization, etc.). As long as
the JSA reflects the current job, it shall be valid up to a month
but reviewed and communicated weekly.
8.5 Work Permit System
Safe work permits are required for the following activities but
not limited to:
1. Critical lifts;
2. Hoisting personnel;
3. Blasting;
4. Working with motorized aerial platforms;
5. Temporary structures related to high risk activities (swing
staging, suspended work platform, etc);
6. Road closure;
7. Working near high voltage and power/electrical lines;
8. Chemical cleaning and air blowing;
9. System(s) testing, radiography;
10. Demolition (structural);
11. Excavation;
12. Lock-out and tag-out;
13. Hot work;
14. Confined space entry.
9. 0 PRE-EMPLOYMENT MEDICAL SURVEILLANCE
All workers including temporary workers shall be gone through
Pre-Employment Medical surveillance. Each sub-contractor shall
arrange this program for their workforce. Worker having any
deficiency or disability shall not be deployed to critical
activities. Record of medical surveillance shall be maintained
throughout the project life cycle.
10. 0 ORIENTATIONS AND MEETINGS
10.1 Pre-Construction Safety Meeting with Sub-Contractors
The Sub-Contractor will attend a Pre-Construction Safety Meeting
prior to the starting work at the work site. The following
personnel, as a minimum, will attend any portion of the meeting
dealing with HSE issues:
1. Aevitas Pharmagro Construction Manager.
2. Aevitas Pharmagro Health, Safety and Environment
Manager/Engineer.
3. Sub-Contractor's Home Office Project Manager or
equivalent.
4. Sub-Contractor's Senior Site Representative.
5. Sub-Contractor's Safety Representative/s.
10.2 Site Safety Induction/Orientation
The Sub-Contractor shall provide health and safety orientation
for all its employees and subcontractors.
This orientation is a prerequisite to entering the site to work,
except to those persons entering the site as a Visitor (Visitors
must be accompanied by a designated, orientated project person, and
will abide by the project safety regulations).
Workers who have attended the Sub-contractor's site safety
orientation session shall be given an identification card (or hard
hat decal) which will be retained by the employee and shall be
produced on demand while on the work site.
During the orientation, the Sub-contractor will provide all
additional company or contract specific information to their
employees.
The safety orientation will include a review of the
following:
1. ZCL Chemicals goals, objectives and policies;
2. Obligations and duties as per local legislation;
3. Health and Safety responsibilities;
4. Site layout and site access;
5. Communication and meetings;
6. Safe Work Procedures.
7. Vehicle/equipment operation and safety.
8. First aid procedures and medical facilities;
9. Work Permit System;
10. Incident reporting requirements;
11. Fire prevention and equipment;
12. Emergency response and muster points;
13. Personnel protective equipment (PPE);
14. Training and Certification;
15. Hazardous materials handling;
16. Housekeeping;
17. Specific work procedures and inspections;
18. Drug and Alcohol Policy;
19. Health and Safety incentives and collective rewards.
20. Other site rules and regulations.
The safety induction/orientation will be conducted in the
morning, and workers will be allowed to proceed to their work place
afterwards. In no event shall any worker commence work prior to
having undergone orientation.
All workers who attend the induction/orientation session will be
required to sign an attendance sheet and record of attendance shall
be maintained throughout the project life cycle.
11. 0 HSE COMMUNICATION
11.1 Safety Bulletin Board
Aevitas Pharmagro will install safety bulletin boards on site,
displaying safety notices, Emergency Response Plan, phonebook,
minutes of safety meetings, Safety alerts and any other pertinent
safety information. The subcontractors shall install safety
bulletin boards near their working areas and keep all postings
current and up to date.
11.2 Lessons learned
All lessons learned and high potential near misses will be
communicated to the workforce by means of Toolbox meetings.
11.3 Emergency Contact Numbers
Emergency Contact Numbers shall be displayed at conspicuous
location of site. The emergency contact numbers shall include:
Local Police Station
Fire Station
Nearest Hospital
Ambulance
Safety Manager/Engineer
Construction Manager
First Aiders
Emergency Rescue Team Members
11.4 Assembly Point
Assembly point/points shall be identified at project site.
It shall be away from Hazardous Material Storage.
It shall be near to the exit gate of Project site.
It shall have capacity of accumulating maximum number of
workmen.
Fire Extinguishers should be provided at assembly point.
12. 0 HEALTH AND SAFETY MEETINGS
12.1 Tool Box and Pre-job Safety Meetings
A "tool box" meeting is a short meeting held by Subcontractors
Site HSE Representative and each supervisor at the start of each
shift to discuss with personnel the work of the day including
special procedures, any potential hazards, all safety issues
relating to the work, and any matters raised by the workers. Daily
"tool box" meetings will be recorded in bullet format and an
attendance record must be signed by all present.
Where a critical task is planned, a pre-job meeting will also be
convened. Attendance should be limited to the workers on the task,
their immediate supervisor(s), and safety personnel as required. A
Job Safety Analysis (JSA) will be initiated, reviewed and then
presented to the crew before each critical task begins.
The Aevitas Pharmagro HSE Manager/Engineer will advise and
attend the meeting. He shall receive copies of Sub-Contractor's
minutes and attendance records.
12.2 Health and Safety Committee
Aevitas Pharmagro and the Sub-Contractor will form a Joint
Health and Safety Committee. The Committee will be Lead by Aevitas
Pharmagro HSE Manager/Engineer. Representative from workers shall
also include in committee.
12.3 Health and Safety Committee Meeting
Safety meetings on a project are an essential tool in continued
development of a mutual understanding of Health and safety
objectives, programs and issues.
The Safety Committee meets twice in a month to review all
health, safety and environment related matters. Aevitas Pharmagro's
HSE Manager/Engineer will prepare the agenda, with input from
attendees. The Minutes of Minutes shall be distributed to all the
attendees and also displayed in local language at Safety Bulletin
Board.
Attendees will include:
1. Aevitas Pharmagro HSE Manager/Engineer.
2. Aevitas Pharmagro Construction Manager.
3. Sub-Contractor's representative(s).
4. Sub-Contractor's site HSE representative(s).
5. Workers representative(s).
Committee members will be conducting a joint work site
inspection (Weekly Safety Walk Around) once before each regular
meeting. Representatives from various areas and disciplines are to
be included as required. The committee is not a policy making body
but the normal divisions of authority should be respected.
It has responsibility to:
1. Promote collaboration between subcontractors and workers;
2. Receive suggestions and complaints from workers, workers
representatives, union, association and subcontractors;
3. Analyze notices and inspection reports;
4. Analyze incident trends and near misses reports;
5. Transmit any requested information;
6. Notify members at least 48 hours prior to the meeting;
7. Ensure communication of the meeting minutes on the site
bulletin boards in local language;
8. Support implementation of the Aevitas Pharmagro HSE
Program.
Recommendations from the committee are expected and management
will respond to the committees recommendations without delay.
12.4 Subcontractors Performance Review
During the construction coordination meeting, Aevitas Pharmagro
will assess and document the Subcontractors HSE monthly
performance. The Subcontractor achieving the best overall score is
designated as the Subcontractor of the month.
Participants at this meeting shall be:
1. Aevitas Pharmagro Construction Manager;
2. Aevitas Pharmagro HSE Manager/Engineer;
3. Subcontractors Supervisors.
At the end of each contract, Aevitas Pharmagro will assess and
document the subcontractors HSE overall Performance.
12.5 End-of Project Evaluation Meeting
Upon completion of the construction and pre-commissioning
execution phases, ZCL chemical and Aevitas Pharmagro shall meet and
review the safety performance of the project. This meeting will be
documented with lessons learned and recommendations for future
projects.
13. 0 HEALTH, SAFETY AND ENVIRONMENTAL INCIDENT INVESTIGATIONS
AND REPORTING
All health, safety and environmental incidents will be
investigated and reported for the following purposes:
1. To meet the requirements of the prevailing legislation (e.g.,
Directorate of Industrial Safety and Health (DISH), etc.). The
Aevitas Pharmagro HSE Manager/Engineer will keep copies of all
reports on file.
2. To ensure that workers affected receive the benefits to which
they are entitled.
3. To provide information that may be useful in preventing
similar occurrences elsewhere.
13.1 Incident Definitions
1. Fatality
A fatality is a death of a worker on the project or at the
workplace resulting directly from an occupational illness or
occupational injury. All fatalities will be classed in a separate
category on the accident statistics (zero severity).
2. Critical Injury
A critical injury is one of a serious nature that:
a. Places life in jeopardy;
b. Produces unconsciousness;
c. Results in substantial loss of blood;
d. Involves the fracture of a leg or arm but not a finger or
toe;
e. Involves the amputation of a leg, arm, hand or foot but not a
finger or toe;
f. Consists of burns to major portion of the body; or,
g. Causes the loss of sight in an eye.
13.2 Environmental Discharge
An environmental incident involves spillage of 25L or more of
contaminants and may impair environmental quality. Any incident
which requires reporting to regulatory authorities is by definition
an environmental incident, regardless of the quantities
involved.
13.3 Occupational Injury
An occupational injury results from a work-related accident or
exposure on the project or at the workplace that requires "first
aid" or "medical aid" treatment (see following definitions for
both).
13.4 Occupational Illness
An occupational illness results from an exposure to a chemical
or physical agent on the project or at the workplace that causes
illness that requires first aid or medical aid treatment.
13.5 First Aid Case
Any one-time treatment and subsequent observation of minor
scratches, cuts, burns, splinters and so forth. This treatment is
considered first aid even though provided by a physician or
registered medical professional personnel.
13.6 Medical Aid Treatment Case
A medical aid case is any occupational injury/illness that
involves neither lost workdays nor restricted workdays but which
requires treatment by a physician or licensed health care
professional at the physician's office or at a clinic or a
hospital.
13.7 Lost-time Injury
A lost-time injury is an occupational injury or illness which
renders the affected worker unable to report for work for more than
the scheduled two days following the injury. For example, a worker
is injured at work on a Monday and is off work the following two
days - Tuesday and Wednesday and returns on the Thursday, the same
week, would not constitute a lost time injury.
13.8 Lost time Day(s)
Lost time day(s) are the day(s) counted as a result of the
injured worker, who is rendered unable to work following (the two
day recover period post accident are not counted) and only day(s)
counted are for the time the worker is off. Unscheduled work days
(i.e. Saturdays and Sunday) are not counted as lost time days.
1. All lost workdays and restricted days associated with a lost
time case are assigned to the calendar year and month in which the
accident occurred. Reasonable estimates may be made as a final
record to close out fiscal year statistics.
2. If a case involves medical treatment or loss of workdays
prior to termination or layoff, then the case and days are entered
appropriately as a medical aid or lost-time injury. The recording
of days against the case stops as of the date of termination or
layoff even though the employee may not be released for full
duty.
13.9 Restricted (Modified) Work Cases
A restricted work injury is an occupational injury or illness
where the worker returns to work and conducts a task that is within
his post accident physical capacity. Restricted work cases are
classified as a medical aid cases.
13.10 Reporting Standards
Any incident which had the potential to cause serious injury.
Fatalities will be classified in a separate category, which will
not be included in the injury severity calculations.
1. Lost Time Injury Frequency Rate is calculated by multiplying
the number of Lost Time Injuries by 200,000 and dividing that
result by the number of work hours expended during the time period
of the report.
Number of Lost Time Injuries * 200,000
Number of hours worked
2. Injury Frequency Rate is calculated by multiplying the number
of Lost Time Incidents and Medical Aids by 200,000 and dividing
that result by the number of work hours expended during the time
period of the report.
Number of Lost Time Injuries * No. of Medical Aid Cases *
200,000
Number of hours worked
3. Injury Severity Rate is calculated by multiplying the total
number of workdays lost to injury and illness by 200,000 and
dividing that result by the number of work hours expended during
the time period of the report.
Number of Days Lost * 200,000
Number of Hours Worked
4. First Aid & Medical Aid Log is maintained by Aevitas
Pharmagro and the Contractor's Medical Attendant for all treatments
administered to site personnel for on-site and off-site treatment
respectively throughout the project.
13.11 Occupational Health, Safety and Environmental
Reporting
Serious accidents and injuries are required by legislation to be
reported to the authorities. The HSE Manager and the Sub-Contractor
will research the reporting requirements at the start of the
project, and prepare a procedure on the reporting of serious
accidents and injuries.
Examples of accidents or injuries that must be reported
include:
1. An injury or accident that results in death.
2. An injury or accident that results in a "critical injury"-
viz., one of a serious nature that:
a. places life in jeopardy
b. results in unconsciousness
c. results in substantial loss of blood
d. involves the fracture of a leg or arm
e. involves amputation of a leg, arm, hand or foot
f. consists of burns to a major portion of the body
g. causes the loss of sight in an eye.
3. An unplanned or uncontrolled explosion, fire or flood that
causes a serious injury or that has the potential of causing a
serious injury.
4. The collapse or upset of a crane, derrick or hoist.
5. Any environmental incident above/beyond the legislatively
established threshold level or that established by the client or
Aevitas Pharmagro. There are additional reporting requirements with
respect to other categories of incident, inclusion of prescribed
information and/or professional engineer's report, etc. Such
prescribed (by Regulation) reporting requirements shall continue to
remain the responsibility of the Sub-Contractor involved.
Aevitas Pharmagros Project Management Team shall complete the
Preliminary Incident Report for critical injuries, lost time
injuries, fatalities and environmental discharges and submit to the
Manager Corporate H&S and/or Manager Corporate Environment
within four hours of the incident.
13.12 Reporting Initial Occurrence (First Aid)
Any occurrence of injury or illness reported to a First Aid
station, to supervision or to a medical treatment centre will be
recorded in detail in the Contractor's First Aid Treatment Log.
Entries in the logbook will be by the Trained First Aider (Medical
Aid Attendant), or the designated First Aid Representative of the
Sub-Contractor and the information will be kept confidential. First
Aid Treatment Books of all Sub- Contractors are subject to audit by
the Aevitas Pharmagro HSE Manager/Engineer.
13.13 Reporting Medical Aid
Any occurrence that becomes a Medical Aid Case will be recorded
on a Medical Aid Treatment Log maintained by the Sub-Contractor. A
copy will be provided to the Aevitas Pharmagro HSE
Manager/Engineer.
All Sub-Contractors are required to promptly advise the Aevitas
Pharmagro HSE Manager/Engineer and Construction Manager of the
occurrence of a Medical Aid case.
In addition to being recorded on the Medical Aid Treatment Log
the Medical Aid case will be investigated by Aevitas Pharmagro, and
the Sub-Contractor will complete an Accident Investigation
Report.
13.14 Reporting Lost Time Accident
When an employee experiences an injury or work-related illness,
the employee has the right to be examined by a doctor. Should the
employee choose not to be so examined, the Medical Aid Attendant
may require such an examination in any event, if it is felt to be
necessary.
In the event the doctor determines the employee should take time
off work in addition to the day after the accident occurred, the
accident becomes a Lost Time Accident (LTA). Lost Time Accidents
require the completion of at least the following forms:
1. Preliminary Incident report to be issued to Corporate within
four hours by PM Team.
2. The medical doctor completes the appropriate Worker's
Compensation form(s) promptly following his examination, diagnosis,
referral, and/or treatment of the worker.
3. The Sub-Contractor (employer) is responsible for filing the
Employer's Report of Accident and Illness (normally within 72 hours
of the Lost Time Accident occurrence). A copy of this report will
be filed with the Aevitas Pharmagro HSE Manager/Engineer.
Each LTA will be reviewed with the Sub-Contractor's senior site
management representative and the Aevitas Pharmagro HSE
Manager/Engineer within 24 hours of the occurrence. All LTA's will
be reported by the Aevitas Pharmagro HSE Manager/Engineer to the
Construction Manager, and will be recorded on the Lost Time
Accident Report that is submitted on a monthly basis (whether lost
time accidents occurred during the month or not).
13.15 Monthly HSE Statistics Reporting
1. Sub-Contractor Reporting
Each month (no later than the 2nd working day of the following
month) the Sub-Contractor will submit to the Aevitas Pharmagro HSE
Manager/Engineer a Sub-Contractor's Monthly HSE Report detailing
lost time accidents, Medical Aids, First Aids, near misses, lost
work days, man-hours worked, and mobile equipment incidents.
2. Aevitas Pharmagro Reporting
Following receipt of the HSE statistics from the
Sub-Contractor/s the Aevitas Pharmagro HSE Manager/Engineer will
compile the Monthly Safety Statistics Summary, and submit it to the
Construction Manager by the 3rd working day of the month following.
Details of all lost time accidents, Medical Aids, First Aids, near
misses, lost work days, man-hours worked, and mobile equipment
incidents will be attached, as well as steps that were taken to
prevent further recurrences.
Additionally, minutes of all safety meetings and inspections, a
summary of all significant safety achievements and individual
Sub-Contractor statistics reports will be attached. Subsequently,
Monthly HSE Report (all sub-contractors) shall be transmitted to
Corporate HSE Office.
14. 0 INSPECTIONS
Aevitas Pharmagro will perform frequent safety and housekeeping
inspections (formal and informal) of the Sub-Contractor's work
storage areas and equipments with the inspection checklists. These
inspections are in addition to the safety and housekeeping
inspections that the Sub-Contractor will perform, and do not
substitute the Sub-Contractor's inspections.
The Sub-Contractor will be advised of any infraction and/or
potentially unsafe condition, and will take corrective action
immediately, where possible. If immediate corrective action is not
possible, the hazard(s) will be properly barricaded and identified
as "unsafe" until proper corrective action can be taken.
Aevitas Pharmagro's HSE Manager/Engineer will follow up on all
infractions to ensure that corrective action is taken promptly. The
Construction Manager will formally advise the Sub-Contractor if
action is not taken promptly on any unsafe condition - this may
result in work stoppage or other action against the
Sub-Contractor.
14.1 Weekly Safety Walk Around
It is a planned inspection carried weekly with active
participation of following personnel:
1. Aevitas Pharmagro HSE Manager/Engineer.
2. Aevitas Pharmagro Construction Manager.
3. ZCL Chemicals Management Representative.
4. Sub-contractor/s Management Representative.
5. Workers Representative.
In this inspection the personnel will decide one area of site
for inspection. These inspections identify any unsafe condition and
act, any specific hazard, safety requirements or any other safety
issues and accordingly recommend the best practice. Report of
weekly walk around will be distributed to all the attendees.
14.2 Pre-Inspection Procedure
1. Be familiar with the work locations;
2. Be prepared to review Incident Logbook to identify incident
trends;
3. Review previous inspection reports with the intention of
reviewing problem areas;
4. Develop a checklist of commonly reported hazards from
previous site inspections;
5. Identify safe work procedures and planned work
activities;
6. Identify activities that are high risk for injury using the
risk register;
7. Ensure inspections are given adequate time to carry out an
effective inspection.
14.3 Inspection Procedure
The procedure for conducting a planned safety inspection is as
follows:
1. Take the time to observe the activities and use the
checklist.
2. Take immediate corrective action where there is an imminent
danger;
3. Record all existing unsafe acts or conditions;
4. Verify that previous recorded hazards have been
corrected;
5. Identify corrective action required for each unsafe act or
condition;
6. Identify personnel responsible for each corrective action and
assign a date/time for completion.
14.4 Health safety and Environment Audit Program
The primary objective of a Safety Audit is to verify that HSE
plan is being properly and effectively implemented. It will also
identify any shortcomings in each program and provide
recommendations to make improvements.
Monthly Internal Audits of varying degrees of detail will be
implemented on the project.
Internal Audits will be initiated by Aevitas Pharmagro's HSE
Manager/Engineer and will be carried out in consultation with a
Subcontractor's site HSE representative.
Copies of all audit documentation will be transmitted to Aevitas
Pharmagro's Construction Manager and Subcontractor
representative.
Corporate audits will be conducted every three months by Aevitas
Pharmagro Corporate HSE Manager.
14.5 Performing the Audit
The concern will be clearly outlined and corrective action will
be recommended. Corrective action will include the activity
required for resolution to the problem, the individual responsible,
the time allotted to correct the situation, and suggestions for
preventing recurrence of the problem in the future.
14.6 Audit Follow Up
The Sub-Subcontractor's senior management representative is
ultimately responsible for the implementation of all corrective
actions recommended in the Audit Finding Reports. At an appropriate
time, Aevitas Pharmagro's HSE Manager/Engineer will inspect the
site to ensure all corrective action has been satisfactorily
performed, will sign-off the Audit Finding Report(s) accordingly,
and will complete the audit plan and report.
14.7 Health and Safety Incentive Program
Aevitas Pharmagro strongly supports the subcontractors
incentives program and initiatives. In addition to that Aevitas
Pharmagro will implement an incentive program providing positive
reinforcement and benefits for safe behavior on site.
14.8 Subcontractor Performance Review
Based on their monthly performance record, a subcontractor will
be identified as subcontractor of the month. The winning
subcontractor will be communicated throughout the site along with
pictures with Aevitas Pharmagro management representatives.
15. 0 EMERGENCY RESPONSE PLAN (ERP)
15.1 Subcontractors ERP Requirements
Subcontractors shall be using the guidelines of Aevitas
Pharmagro ERP requirements to implement their own site specific set
of procedures. Minimal expectations are:
1. Support Aevitas Pharmagro in case of ERP activation;
2. Train their personnel on ERP procedures, policies and
reporting requirements;
3. Assign trained personnel for emergency response:
a. Communication
b. Firefighting equipment
c. Decontamination
d. First aid and high angle rescue procedures
e. Incident investigation and critical procedures
4. Carry out area quarterly drills and debriefing sessions;
5. Maintain daily worker list to be used in the event of an
evacuation;
6. Inform employees of the designated mustering points;
7. Assist with notification, First Aid, securing of site, as
indicated by the designated site Emergency Coordinator, Fire Safety
Coordinator;
8. Maintain workplace to reduce fire or spills and ensure safe
evacuation;
9. Carry out documented weekly inspections for all emergency
equipment with corrective actions if applicable;
10. Install signs for clear and effective localization of
portable extinguisher and hoses;
The ERP includes alert process, chain of communication, and
general procedures for the following occurrences:
1. Medical emergencies and rescue;
2. Evacuation;
3. Explosion, fire, smoke;
4. Extreme weather conditions;
5. Spills;
6. Bomb and telephone threats.
Subcontractors shall develop specific ERP related to their
activities and provide emergency equipment and resources.
15.2 Emergency Procedures
All Contractors emergency procedures will be approved by Aevitas
Pharmagro prior to site implementation. Each site Sub-Contractor's
site emergency procedures will be posted in a conspicuous manner
and in local language, at appropriate locations nearest to his
scope of work, and protected from the weather. A current copy of
the Sub-Contractor's emergency procedure should be available for
reference.
16. 0 SITE ACCESS AND SECURITY
Security personnel will ensure a 24/7 coverage and do inspection
rounds across site.
16.1 Workers Access
All workers will enter and exit the site by designated access
points only. Site access will be monitored using Identity card
system which will be provided by respective contractor.
Subcontractors shall implement their own control process to
ensure their daily man count is accurate and take into account
workers on sick-leaves and away from work.
One time visitor will not be require Health and Safety
induction/orientation if they are escorted by an oriented
person.
16.2 Identification
Upon successful completion of the orientation training,
sub-contractor shall provide Identity cards to workers. ID card
shall be return upon employment termination. It is mandatory for
all workers to bring in ID card when accessing the site
Visitors will be given a temporary (1 day validity) visitor ID
card that shall be worn at all time of visit and returned at the
end of the visit.
16.3 Authorizations
Site tours shall be authorized by the Aevitas Pharmagro
Construction Manager. The use of photographic equipment on site
shall be authorized by the Aevitas Pharmagro Construction
Manager.
16.4 Vehicles Access
1. All work related vehicles accepted on site shall meet safety
standards including:
2. Audible back-up alarm.
3. Have seat belts;
4. 2 KG fire extinguisher;
5. First aid kit;
6. Display the vehicle pass at all times.
16.5 Traffic and parking safety
The benefit of this practice is that you can drive away forwards
after work with a full field of vision and not be caught unaware by
some other driver or pedestrian who is also rushing to get
home.
To promote safe-driving practices, Aevitas Pharmagro strictly
implemented speed limits are imposed at all site work areas, paved,
unpaved and temporary access roads. The speed limit is:
10 kph
Overtaking is strictly prohibited.
All vehicles must give way to police, ambulances and emergency
vehicles like fire, safety and security during emergencies.
Reverse-in parking practice shall be implemented by all
personnel using the site parking lot. This practice allows
personnel to drive away forwards with a full field of vision and
not be caught unaware by other driver or pedestrian.
The following practices shall be treated as Site Traffic
Violation and Security Violation
Notice will be issued for each violation:
1. Using mobile phone whilst driving;
2. Not wearing seatbelt whilst driving;
3. Ignoring security guards instruction and not stopping when
required to do so;
4. Driving without valid driving license;
5. Car unattended while engine is running;
6. Parking in unauthorized parking place;
7. Driving aimlessly or recklessly;
8. Overloading and inadequate seating arrangements;
9. Poor maintenance of vehicles;
10. Vehicle registration not matching with license plate
number;
11. Misuse of vehicle passes - pass number and plate number not
matching;
12. Cutting corners;
13. Parking in any manner to obstruct the traffic flow / leaving
broken down vehicles unattended in the sites;
14. Failing to give signals (indicators);
15. Exceeding the designated speed limit;
16. Overtaking;
17. Ignoring traffic signs;
18. Crossing road intersection without stopping;
19. Carrying passengers in vehicles not designed to carry
passengers or without seating arrangements and hardtop roofs;
20. Driving without head-lights (day and night);
21. Embarking and disembarking passengers or materials whilst
the vehicle is in motion;
22. Offering lifts to unauthorized person;
23. Not slowing down and stopping at the security gates or check
points;
24. Ignoring others right of way;
25. Driving under the influence of alcohol or drugs.
16.6 Heavy, Mobile and Lifting Equipment
Subcontractors shall provide a valid copy certifying that all
equipment (owned or rented) to be
mobilize on site has been inspected by a competent person to the
Aevitas Pharmagro HSE Manager / Engineer before utilization. Each
subcontractor shall certify that all mobile, heavy and lifting is
compliant to Gujarat Factory Rules, 1950. Certification shall be in
the prescribe Form No. 37.
Supplemental documents and/or dated periodic inspection records
shall also be handed out to Aevitas Pharmagro upon arrival on site
and made available at all times during mobilization. Daily logbooks
shall be kept for each equipment and be available upon request.
Lifting equipment shall have a load chart and display its maximum
capacity.
17. 0 RECORD KEEPING REQUIREMENT
17.1 Record Maintenance
The ZCL Chemicals Project, subcontractors and consultants shall
maintain detailed records and statistics relating to Health and
Safety, Security and Emergency Preparedness in accordance with due
diligence requirements and to assist in monitoring the
effectiveness of the Health and Safety Program.
Records will be retained to ensure data are:
1. Retained;
2. Accessible;
3. Maintained and traceable.
17.2 Record Retention Duration
The following shall be used as a guideline for record retention
duration:
1. Ten Year Retention
a. Kick-Off meetings records
b. Toolbox meetings records
c. Health and Safety Committees minutes and inspection
reports
d. Task specific safety meetings
e. Emergency drills and simulation reports
f. Planned Inspection reports
g. Job Hazard Analysis
h. Work Permits
i. Safe Work Procedures
2. Twenty Year Retention
a. Aevitas Pharmagro meetings Records
b. First aid reports
c. First aid treatment records and logbooks
d. Incident investigation reports
e. Records of emergencies
f. Inspection reports;
g. Compliance and audit reports
3. Permanent Retention
a. Workers orientation records;
b. Scaffolding and temporary structures records and
certification (high-risk activities);
c. Rigging equipment inspection records and certification;
d. Heavy and mobile equipment certification and inspection
records;
e. Specialty trainings records;
f. Medical and industrial hygiene surveillances records;
g. Records of safety violations;
h. Records resulting from Refusal to Work.
18. 0 MANAGEMENT OF CHANGE
18.1 Policy
Management of Change (MOC) is the process of ensuring strict
control and communication of any potential change to project
specifications, standards, procedures, controlled design documents,
materials, equipment, execution plans, or commercial contracts. As
a minimum the following aspects will be addressed:
1. To control change consistent with regulatory
requirements;
2. To ensure that all aspects of change are properly registered,
documented, tracked and communicated to the project team in a
concise and controlled manner;
3. To ensure a change is not proposed or implemented unless
there is a basis around improving safety, operability,
maintainability, legal, or environmental/regulatory/ community, and
to document the same;
4. Assign appropriate levels of approval for changes.
A risk assessment shall be performed prior to implementation of
any change to ensure that it does not introduce risks to people,
property and surroundings. This exercise must take into
consideration both planned and unplanned changes and sudden or
gradual changes.
All areas of potential change must be considered:
1. Equipment, processes and lay-out;
2. Operation and maintenance procedures;
3. Design, construction, repair and maintenance;
4. Materials used and inherent properties;
5. Organizational structure and responsibilities;
6. Personnel training or competency requirements;
7. Personnel changes.
18.2 Responsibilities
The management of change process shall involve Aevitas Pharmagro
representatives, subcontractors supervisors, workers and ZCL
Chemicals representatives.
18.3 Records
Changes shall be documented and include the following
information:
1. Reasons for the proposed change;
2. Risk assessments;
3. Authorization and date;
4. Checklist prior to implementation;
5. Any other relevant documentation and drawings.
19. 0 MANAGEMENT REVIEW
A management review will be held twice a year and/or upon
completion of any portion of the project to assess any gap in
regards to projects goals, objectives and performance during the
period of review.
The list of participants includes but is not limited to:
1. Aevitas Pharmagro Project Director
2. Aevitas Pharmagro Project Manager
3. Aevitas Pharmagro Construction Manager
4. Aevitas Pharmagro HSE Manager/Engineer
5. ZCL Chemicals representatives.
20. 0 WORK PROCEDURES
20.1 Common Hazards
1. Oxygen deficiency or noxious gases in confined spaces;
2. Carbon monoxide exposure caused by engines running inside
enclosures;
3. Toxic gas emissions caused by use of fuel fired heaters with
inadequate ventilation;
4. Release of solvent vapors while using waterproof glues and
paints;
5. Inhalation of, or skin contact with, paints, varnishes and
coatings particularly those which are urethane or epoxy-based;
6. Inhalation of hazardous dusts occurring from sand blasting
and rock drilling activities;
7. Exposure to airborne zinc (symptoms of Metal Fume Fever)
caused by cutting or burning galvanized metal;
8. Chemical burns caused by skin contacts with lime, wet
concrete, cement products and acids;
9. Noise-induced hearing loss caused by worker exposure to
prolonged excessive noise.
10. Poor air quality, complicated by temporary construction
enclosures (proper planning and consideration of equipment types,
enclosure size, air changes and ventilation will prevent most air
quality problems);
11. Collapse of stored or stacked materials due to improper
chocking;
12. A load may shift on a truck during transit and collapse when
the tie-downs are released;
13. Ergonomic hazards related to the work environment and use of
equipment and machinery.
14. Subcontractors shall remain aware of these aspects of
occupational health and safety, implement risk control measures and
provide the required protective devices for the protection of the
worker.
20.2 Job Safety Analysis (JSA)
Subcontractors that are assigned critical tasks must complete a
job safety analysis before carrying out the work. Such analyses
must be done when activities are performed on the work site as per
risk assessment section of this HSE Program.
Job safety analyses will be completed by the Aevitas Pharmagro
HSE Manager/Engineer, sub-contractors HSE representative and
supervisor / foreman in conjunction with the workers. The goal is
to not only inform all workers involved and to make them aware of
the risks associated with a critical task, but also to find
appropriate measures of protection to prevent any hazards.
The following situations qualify as a critical task:
1. Tasks that can create a serious accident if it is not
executed properly;
2. New tasks that workers are not familiar with;
3. Tasks that require a large number of people;
4. Tasks with a high risk of hazard due to the nature of the
work;
5. Changes to any aspect of the work:
6. Unforeseen changes to the work estimate;
7. Significant changes to the work environment;
8. Unforeseen changes to the work team structure.
20.3 Procedures
The Aevitas Pharmagro HSE Manager/Engineer, sub-contractors HSE
representative and supervisor/foreman break down the task into
steps, in order to highlight the critical elements for each
one.
For each step, the supervisor and his team will identify the
associated risks. The objective here is to assess what elements
could pose as a hazard to the workers. Such hazards include:
1. Physical: lighting, noise, falls, etc.
2. Ergonomic: body position, material transportation, etc.
3. Chemical: paints, acids, solvents, gas emissions, etc.
4. Biological: viruses, insect bites, etc.
5. Psychosocial: fatigue, worked hours, experience, etc.
Once the risk level is known, the team member will decide if
such a risk is acceptable, and will identify any necessary measures
to reduce the risk and proceed with the task. In the case where the
team member determine that a task has an unacceptable risk level,
they must decide on the mitigation measures to be taken to complete
the task safely. Where necessary, it is important that the
supervisor establishes additional mitigation measures to ensure
that everything is in place to prevent any hazards while the
critical task is carried out.
Once all the risk assessment process has been realized, the
supervisor and his team have to determine the most adequate
mitigation measure. If the risk cannot be completely eliminated,
they must decide whether the risk can be reduced by:
1. Engineering measures (guarding, ventilation, etc.);
2. Administrative measures (procedures, work instructions,
etc.);
3. Personal protection equipment (PPE).
Each worker who has participated in the JSA must sign the JSA
form.
The supervisor/foreman must then submit the JSA form to Aevitas
Pharmagro HSE Manager/Engineer with the work permit.
A.1 HOUSEKEEPING
Aevitas Pharmagro recognizes the importance of good housekeeping
practices in its areas of work.
Subcontractors are responsible to ensure that its work and
lay-down areas are maintained in an orderly fashion and free of
debris at all times. Aevitas Pharmagro reserves the right to
maintain good housekeeping by cleaning up the subcontractors work
area and back charging for the service.
Gutkha, pan masala, tobacco and other such material is not
allowed at site. Spitting at site is strictly prohibited. Waste
bins shall be kept on different location at site, and regular
removal of waste from waste bin shall be carried out to avoid over
filling and spreading of waste at the site.
Floors, platforms, stairs and walkways will be kept free of
loose materials at all times.
All equipment, tools and materials used on the site will be
removed from the work area and returned to the proper storage area
upon completion of each job.
Garbage, material, or tools will not be permitted to be thrown
from elevations. Lower in containers or special chutes.
Nails shall not be left protruding from formwork of other
material. They will be bent over or removed completely.
Materials will be well secured, especially at elevations, to
avoid movement during windy conditions.
Areas in the proximity of emergency equipment such as fire
extinguishers, hoses, and emergency personal protective equipment
shall be kept clear at all times.
Hoses, cables and cords will be kept in an orderly manner to
prevent tripping hazards. Electrical and welding cables will not be
allowed to lie in pools of water. Where possible, cables will be
suspended above the ground, or will be protected from mechanical
damage if they cannot be suspended. Unused hoses and cables will be
rolled up and stored. Unless cables and hoses remain in an orderly
manner, they will be rolled up on a frequent basis as determined by
Aevitas Pharmagro.
Oily rags will be disposed of in closed metal containers - not
with other garbage.
Hydrocarbons or chemicals will not be intentionally spilled onto
the ground or into the sewer system. Spills will be reported and
cleaned up immediately.
Rubbish, debris, and other materials will not be permitted to
blow around freely. Daily clean-ups will be performed to collect
all wind-blown materials.
A.1.1 Materials Stockpiling
Workers should avoid circulating at the bottom of the slopes of
stockpiled materials.
Materials should be stockpiled at least 1 meter or greater
distance from trenches and openings.
Materials must be stockpiled on a solid, leveled and stable base
and effectively blocked, if necessary.
Materials such as pipes must have a restraining system to
prevent the pile from spreading or collapsing or pipes from
rolling.
Remove pipes from ends of pile.
Do not stack pipe higher than 1.5 meters (5 ft.).
Stockpiled materials must be checked to ensure that pieces are
not sticking out into driveways or walkways.
While working or walking on a pile of materials, soils, rock,
etc. workers must ensure that the slopes are stable and that they
can safely go up or down the pile.
Check all bundles for broken or weak tie wires or bands before
attempting to unload. Place slings on structural steel before
releasing binder chains.
Do not allow piles to exceed ten bags in height unless the face
of the piles is supported by the walls of a storage bin or
enclosure.
Cross-pile bagged materials on skids and pile only to a
convenient height. The height depends on the nature and ability of
the mechanical aids used and the weight of the bagged
materials.
Do not stockpile material on a scaffold beyond the safe loading
capacity.
A.2 COMPRESSED GAS CYLINDERS
All cylinders and related equipment will be handled and stored
in full compliance with all applicable legislation.
A.2.1 General
Compressed gas cylinders shall:
1. Be clearly identified in accordance with applicable
legislation with regard to contents.
2. Be kept on a specially designed cylinder trolley with
retaining chains when in use.
3. If transported by crane, hoist, or derrick, be handled in
suitable cradle, nets, or skip boxes never by rope, chain slings,
or slings choked around the body. Ensure securely stored before
moving.
4. Have hoses and gauges removed, and valve guards installed
whenever cylinders are transported, stored, or not in use.
5. Have cylinder valves and gauges kept clean and free from oil,
grease and other hydrocarbons.
6. Be protected from physical damage, and kept away from areas
where they can absorb undue heat or be a hazard in a fire
situation.
7. Not be placed in confined spaces or non-ventilated areas.
8. Not be placed near electrical panels, or in proximity to
welding grounds.
9. Not lift cylinders by the protective cap/guard.
10. Cylinders shall only be refilled by authorized dealers.
11. Empty cylinders shall be identified and separated from full
cylinders and a protected cap shall be attached, and damaged
cylinders shall not be used nor shall they be repaired but shall be
returned to the supplier. Damaged or leaking cylinders must be
tagged.
12. Before commencing work, check all joints with soap solution
for any leak.
A.2.2 Storage
1. Compressed gas cylinders shall be stored, used and
transported in a secure, upright position, even when empty.
2. Oxygen cylinders will be separated from highly combustible
materials, especially oil and grease and other fuel gas cylinders
by a minimum of 8 meters, or by a 1.5 meter high non-combustible
barrier.
3. Storage areas will be clearly identified regarding contents
of cylinders, and empty cylinders are to be marked as such.
4. Storage racks will be specifically designed to keep cylinders
upright.
5. "No Smoking" and other appropriate warning signs shall be
posted in the area.
6. Fire extinguishers shall be placed in the immediate
vicinity.
A.2.3 Regulators and Hoses
1. Flashback devices shall be installed at both the regulator
and torch end of oxygen/fuel gas systems used for cutting or torch
welding.
2. Before connecting gauges to compressed gas cylinders, the
valve shall first be opened (away from personnel or ignition
sources) slowly to clear any debris.
3. Grease or oil shall not be applied to any cylinder threads or
gauges. Instant combustion will take place if hydrocarbons are
exposed to pure oxygen.
4. Before removing hose assemblies the cylinder valves will be
closed, and then the hoses will be bled of gas by opening the
regulating valves at the torch.
5. Hoses will be inspected for leaks frequently, particularly at
the connections.
6. Hoses will not be placed where they will become a tripping
hazard, run over by vehicle traffic, or crushed in doorways.
Unventilated areas such as gang boxes or cabinets cannot be used to
store hoses containing flammable gases.
7. Follow all manufacturer/distributor recommended pre-light and
lighting procedures and guidelines.
A.3 PERSONAL PROTECTIVE EQUIPMENT (PPE)
A.3.1 General
Employees will wear appropriate personal protective equipment
(PPE), for their performance of their normal work. MSDS and
manufacturers specifications will be carefully checked to ensure
that the type of equipment and material is suitable for the
hazard.
Close fitting shirts and/or jackets, and long pants (all in
serviceable condition, without rips, tears, etc.) will be worn at
all times throughout the jobsite work area.
Shorts and sleeveless shirts are prohibited. Work clothes should
be fire resistant and free of chemical contamination. Offices,
lunchrooms, and other designated areas may be excluded from certain
aspects of this policy with prior written authorization of Aevitas
Pharmagro.
Special protective clothing (i.e., coveralls, protective rubber
suits, and leg protectors for power saw operators) will be worn, as
specified. Clothes that burn easily or meIt (i.e., polyesters and
nylon) shall not be worn.
Sub-Contractors will ensure the availability, proper use, care
and will require their workers to wear PPE, necessary for the
workers' protection. Prior to use, all workers will be trained in
the proper use and care of PPE. Workers will properly wear all such
items where a hazard is known to exist or in situations where the
workers personal safety is enhanced through its use.
All personnel, including visitors entering an active
construction site will be properly equipped with approved safety
footwear, head and eye protection. All articles of PPE will conform
to IS standards or will meet the requirements of other recognized
standards.
The Sub-Contractor is responsible to ensure that the following
approved PPE, at a minimum, is available and used by employees.
A.3.2 Body and Limb Protection
Long trousers and long sleeved shirts (no muscle shirts, shorts,
etc.) will be worn at all times.
Gloves shall be worn by workers at all times. Gloves shall be of
the correct type, style, material, etc. to adequately mitigate
hazards.
Leather jackets/apron and chaps (leather limb protection) (or
equivalent fire-resistant material) will be worn for protection
during welding and other hot processes.
A reflective, orange colored security traffic vest shall be worn
at all time on the construction site.
Safety footwear conforming IS: 5852-1996 / IS: 11226 1993
standard shall always wear while on project site, incorporating
box-type toe protection, sole/shank puncture protection.
Heavy equipment operators within enclosed cabins are exempt from
wearing hard hats while operating, but enforced when the operator
leaves the cabin. IS: 2925-1984 confirming hard hats and liners
shall be worn in compliance with all manufacturers
recommendations.
Except as indicated, protective headgear must be worn at all
times by all workers and visitors on the site except for confines
of offices, lunchrooms and washrooms.
A.3.3 Eye Protection
Eye protection is intended to protect against hazards like
flying particles, chemical splashes, radiation (e.g. welding)
sparks, etc. Clean eye and face protection regularly, and replace
when lenses become pitted or scratched.
All eye and face protection must meet IS: 5983-1980, IS:
7524(Part-I)-1979 and IS: 9973-1981 impact and compliance
requirements:
Approved eye glasses complete with permanently attached side
shields (IS: 9973-1981 Eye and face protection compliant) to be
worn at all times except when using other eye safety wear (e.g.
welding hood, cutting glasses, etc.).
Tinted or shaded glasses shall not be worn at night, indoors or
in poor light conditions. Specially designed safety eye protection
(OTG) will be worn over any non-approved eyewear.
1. Contact lenses are prohibited in all working/operating
areas.
2. Goggles, face shields and cutting and burning goggles must IS
compliant.
3. Flash glasses (shade 3 or 4) are