OH&S Handbook-Mar 03

March, 2003, TA

This document contains information that is confidential and proprietary to Holcim and is solely for the use of Holcim. No part of it may be circulated, quoted, or reproduced for distribution outside Holcim without prior written approval from Holcim Corporate Occupational Health and Safety Project Co-ordination Office. © 2002

Always check Holcim documentation against local regulatory/legal requirements

The current version of the Holcim OH&S Handbook is on HolSpace (SafetyNet) Please check for updates and/or changes.

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Table of Contents OH&S POLICY 7

OH&S PERFORMANCE TARGETS 7

1. INTRODUCTION 8

2. PYRAMID ELEMENTS 9 2.1 A structural model for the Holcim OH&S Pyramid. 10

2.2 Why apply the Pyramid? 11

3. ROLES, RESPONSIBILITIES AND ACCOUNTABILITIES 12 3.1 Summary of Intent 12

3.2 General Comment 12

3.3 Details 13

3.4 Auditor Evidence 14

4. HAZARDOUS WORK ACTIVITIES 15 4.1 Summary of Intent 15

4.2 General Comments 15

4.3 Detailed Discussion 16

4.4 Additional Issues 22


5. HAZARD IDENTIFICATION AND RISK ASSESSMENT 24 5.1 Summary of Intent 24


5.3 Details 25

5.4 General Risk Controls 27


6. PLANNED INSPECTIONS 28 6.1 Summary of Intent 28


6.3 Discussion of topics 29


7. LEGAL OBLIGATIONS 33 7.1 Summary of Intent 33


7.3 Details 33



The current version of the Holcim OH&S Handbook is on HolSpace Please check for updates and/or changes.

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8. MANAGEMENT COMMITMENT AND PLANNING 35 8.1 Summary of Intent 35


8.3 Issues to be addressed 37

8.4 Emergency Planning 38

8.5 Management Review 40


9. INDUCTION AND TRAINING 42 9.1 Summary of Intent 42

9.2 Induction 42

9.3 Training 43

9.4 Training Review 44


10. INCIDENT INVESTIGATION AND CORRECTIVE ACTION 45 10.1 Summary of Intent 45


10.3 Incident Investigation Process 46

10.4 Corrective Action System 49


11. INDUSTRIAL HYGIENE AND MONITORING 51 11.1 Summary of Intent 51


11.3 Workplace Monitoring 51

11.4 Health Monitoring 52


12. EMPLOYEE COMMUNICATION AND INVOLVEMENT 53 12.1 Summary of Intent 53


12.3 Details 54


13. INFORMATION AND REPORTING 56 13.1 Summary of Intent 56

13.2 Details 56

13.3 OH&S Manual 57

13.4 Records 58

13.5 Design Information 58



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13.6 Reporting 59


14. SAFE WORKING PROCEDURES 60 14.1 Summary of Intent 60

14.2 Task Analysis 60


15. INSPECTION AND TESTING 62 15.1 Summary of Intent 62


15.3 Inspection Topics 62

15.4 Critical Parts and Equipment 64


16. DESIGN SAFETY 66 16.1 Summary of Intent 66


16.3 Details 67


17. AUDIT AND SYSTEM IMPROVEMENT 69 17.1 Summary of Intent 69

17.2 General Comments – Internal Audit 69

17.3 General Comments – External Audit 69


18. OCCUPATIONAL REHABILITATION 71 18.1 Summary of Intent 71

18.2 Rehabilitation 71


19. PROCUREMENT 72 19.1 Summary of Intent 72


19.3 Details 72


20. MANAGEMENT OF CHANGES 75 20.1 Summary of Intent 75


20.3 Details 76



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21. HEALTH AND WELLNESS ISSUES 77 21.1 Summary of Intent 77

21.2 Employee Assistance Program 77

21.3 Other Issues 77


APPENDICES A1 Risk Management Methodology 74

A2 Management of Changes Form 89

A3 Example Emergency Plan 92

A4 OH&S Definitions 102



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OH&S Policy: We provide healthy and safe workplaces by striving for zero risk to our employees, contractors and visitors. We apply OH&S standards and guidelines, provide the necessary resources and training, and measure performance.

OH&S Performance Targets:

Zero deaths or injuries causing permanent disablement annually

A Lost Time Injury Frequency Rate of <five achieved annually

A Lost Time Injury Severity Rate of <60 achieved annually

We strive for continual improvement in the actual results we achieve, with a long-term goal of zero harm to people

… and a green OH&S pyramid in all Group companies by end 2005.


The current version of the Holcim OH&S Handbook is on HolSpace (SafetyNet) Page 8 Please check for updates and/or changes.

1. UINTRODUCTION

The Holcim Executive Committee (Exco) has clearly stated as a goal that the Group companies achieve “accepted good practice” with respect to Occupational Health and Safety (OH&S) performance.

To achieve this goal a Holcim OH&S Pyramid has been established. The purpose of this Pyramid, its elements (blocks) and associated documentation, is to indicate the key requirements within each of these elements for establishing “accepted good practice” in OH&S Management System performance.

Because of historical circumstances, companies in different countries have developed approaches to OH&S management in different manners. It is important that any Group wide OH&S Management System establishes clear guidelines regarding what must be achieved, so that as a minimum requirement can be reached. However, at the same time, it is important that the approach is not prescriptive, requiring companies to unnecessarily revise existing practices and existing work and effort, i.e. the approach should be to indicate what must be achieved by each Group company, but still leave the details of how they achieve it to them individually.

The purpose of this Handbook P

çP is to clearly establish the minimum level for the outcomes that

must be achieved for a site to achieve “accepted good practice” in OH&S management. This document is structured in a manner so that for each of the elements within the Pyramid

The goals that must be achieved are identified, Some guidance is given regarding key implementation issues, The evidence that an auditor would expect to find is identified.

Nevertheless, it is still left to the individual companies to determine what methodologies, systems, etc. they will choose to adopt in order to achieve these goals. The effect of this approach is to minimise any rework effort for sites, but also to provide the basis for a direct comparison between the level of performance and achievement at different sites.

AKNOWLEDGEMENT: Dr. W.G. Danaher of Risk Management Intercontinental (Brisbane, Australia) prepared the first version of this Handbook. A multi-functional Working Group representing a cross-section of Holcim business units worldwide, led by Ted Anderson, did subsequent versions.



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THE HOLCIM OH&S PYRAMID

OccupationalRehabilitation Procurement Management

of Changes

Information & Reporting

Incident Investigation &

Corrective Action

DesignSafety

Induction & Training

Safe Working Procedures

Audit and System

Improvement

IndustrialHygiene &Monitoring

Employee Communication

Roles Responsibilities

and Accountabilities

Hazardous Work Activities

Legal Obligations

HazardIdentification

and RiskAssessment

ManagementCommitment& Planning

Planned Inspections

Inspection& Testing

Implementationis planned

Implementationhas started

Fullyimplemented

Legend Health & Wellness

Issues

OccupationalRehabilitation

Managementof Changes

Information & Reporting


Corrective Action

DesignSafety



Audit and System

Improvement

IndustrialHygiene &Monitoring & Involvement



Hazardous Work Activities

Legal Obligations


and RiskAssessment

ManagementCommitment& Planning

Planned Inspections

Inspection& Testing

Implementationis planned

Implementationhas started

Fullyimplemented

Legend

ImplementationPlanned

ImplementationBegun

Fullyimplemented

Legend Health & Wellness

Issues

2. PYRAMID ELEMENTS

The elements within the Pyramid are:

People Related:

Roles, Responsibilities and Accountabilities, Hazardous Work Activities

Hazard Identification and Risk Assessment, Induction and Training

Incident Investigation and Corrective Action, Safe Working Procedures,

Occupational Rehabilitation

Process Related:

Industrial Hygiene and Monitoring, Planned Inspections

Audit and System Improvement, Inspection and Testing

Management of Changes, Design Safety, Procurement

Management Related:

Management Commitment and Planning, Legal Obligations

Employee Communication and Involvement, Information and Reporting

A Link to CSR:

Health and Wellness Issues



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2.1 A structural Model for the Holcim OH&S Pyramid

PE

OP

LE



Occupational Rehabilitation


Corrective Action




and Risk Assessment

PR

OC

ES

S

Planned Inspections

IndustrialHygiene & Monitoring

Audit and System

Improvement

Procurement

Managementof Changes

Design Safety

Inspection& Testing

MANAGEMENT

ManagementCommitment & Planning

Legal Obligations

Employee Communication& Involvement

Information& Reporting

Hazardous Work

Activities

Health & Wellness

Issues

The initial assessment of any Group company OH&S management system against the pyramid will identify where the areas with the most improvement possibility exist. Addressing these can then be prioritized on the basis of a risk assessment to decide which have the biggest potential threat to control/opportunity to realize. In general terms, lower blocks in the three subdivisions should be addressed at the same time and are likely to need to be dealt with before those higher up.



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2.2 Why apply the Pyramid?

The overall objective of implementing all of the blocks within the Holcim OH&S Pyramid is to provide an OH&S Management System that is capable of delivering healthy and safe workplaces. This is measured against the Targets for OH&S performance and, when all the blocks of the Pyramid are fully implemented, this will be evidence of the application of OH&S standards and guidelines, provision of the necessary resources and training, and measurement of performance. Individual Group companies will grade their accomplishment in relation to each Pyramid block according to the scale. This grading will be verified:

Initially in a verification process; and In ongoing reviews from time to time; that are Done by persons from outside that company. TP

1PT

Any company that cares about it's people and the management of health and safety in all its forms will likely not only become an employer of choice, but also enhance it's reputation with it's stakeholders. Hence, Group companies must be able to demonstrate that their activities are being conducted in such a way as to provide healthy and safe workplaces while striving for zero risk to employees, contractors and visitors.

TP

1PT eg. The Holcim Group OH&S Co-ordinator - Other Group company OH&S Co-ordinator - Other 3rd party - Or a

team made up from these people.

Always check Holcim documentation against Roles, Responsibilities local regulatory/legal requirements and Accountabilities


3. UROLES, RESPONSIBILITIES AND ACCOUNTABILITIES

3.1 Summary of Intent

Each Group company must ensure that appropriate organizational structures are put in place to manage OH&S, and there is an appropriate allocation of responsibility and accountability to all personnel within the organization to ensure successful functioning of the OH&S Management System.

Group companies must maintain, as a basic principle, that their activities will be conducted in such a way as to provide healthy and safe workplaces, and to strive for all operations to expose employees, contractors and visitors only to levels of risk that are as low as reasonably achievable.

Management commitment is an integral part of establishing an OH&S Management System. One way in which management commitment can be demonstrated is through appropriate organizational structures, and allocation of responsibility and accountability to key personnel within the organization.

This element of the Pyramid addresses such matters, and addresses also the importance of including annual review of OH&S management performance as part of each employees performance review; eg. including it in employee Dialogue or the equivalent local Personal Performance Management Program.

3.2 General Comment

Effective OH&S management occurs if persons at all levels within an organization are seen to be responsible for relevant aspects of OH&S management. Therefore, it is expected that:

There will be an OH&S responsibility and accountability system for personnel at all levels in the organization, eg. job/position descriptions or task statements

The system will specify OH&S responsibilities and accountabilities for all personnel commensurate with their level within the organization

Selection procedures will successfully match personnel to jobs Personnel will have been clearly informed of their OH&S responsibilities A mechanism will exist within the organization for reviewing an individual’s

performances with respect to OH&S management.

Management must ensure that responsibility and accountability for OH&S matters is seen to be an intrinsic part of each person’s job, irrespective of their level in the organization. Therefore, it is expected that performance requirements, or targets, for OH&S performance will be specified for all personnel.

It is considered critical that these targets are established as both “positive” and “negative” targets, eg. targets for injury reduction (negative), and positive targets whereby persons are



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required to actively undertake OH&S initiatives, (development of safe operating procedures, doing site audits, involvement in hazard identification and risk assessment, etc).

It is further expected that performance with respect to OH&S will be included as part of an annual performance review system. This system should involve annual setting of targets pertaining to OH&S for individuals, and the subsequent review of achievement with respect to those targets.

3.3 Details

Responsibility and Accountability System

Modern OH&S legislation is written such that obligations or duties of care are placed upon all persons at a workplace. The system establishing OH&S responsibility and accountability; eg. position descriptions, for all these persons should reflect the fact that everybody has some responsibility for OH&S.

It is important that all personnel at all levels have defined responsibilities and accountabilities for OH&S. Items that should be addressed include:

Legislative requirements; Reporting requirements; and Levels of authority.

Note: OH&S is not the responsibility of the OH&S Department or the OH&S coordinator. The role of the OH&S Department or the OH&S coordinator/Officer is to provide guidance and advice about OH&S matters. The discharge of OH&S responsibilities and the undertaking of actions necessary to ensure OH&S at a workplace is the responsibility of all persons delegated through the management structure at that workplace.

Performance Appraisal

Management should also evaluate the effectiveness of the performance of persons with specific allocated responsibilities for OH&S. This evaluation of performance should be no different to the evaluation that occurs with respect to performance in all other aspects of any person’s responsibilities.



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Performance can be evaluated in the following manners:

Formal performance appraisal. At management meetings. By means of written reports. Informal checks. Personal communications. Formal audits. Incident frequency and cost analysis. Random sampling. Analysis of property damage.

It is only through making individuals responsible and accountable for OH&S management in their areas of responsibility that long-term improvement of performance will occur. Note that it is also important that management, in assigning responsibility and accountability, provides the necessary resources and training to enable these responsibilities to be discharged.

3.4 Auditor Evidence

The following information will be sought as part of an audit.

Documented organizational structure. Documented evidence of a safety responsibility and accountability system in

place; eg. position descriptions Evidence that OH&S responsibilities and accountabilities are defined for all. Evidence of a performance monitoring or review system operating. Evidence of setting of “positive” and “negative” OH&S goals Evidence within the performance monitoring/review system that OH&S

performance is clearly addressed and measured.

Always check Holcim documentation against Hazardous Work local regulatory/legal requirements Activities


4. UHAZARDOUS WORK ACTIVITIES


This element has been included as one of the building blocks of the Pyramid because the activities addressed by this element are those where there is potentially the greatest risk for fatality or permanent disablement. The content of this element indicates the types of issues that should be addressed, and the structures and systems that should be in place to ensure that work permit systems are implemented and functioning effectively.

As a matter of priority, any organization serious about managing OH&S must address the control of those areas or work practices in which there is potential risk for a fatality or permanent disablement to occur. Work permit systems are the way to achieve this control.

Hence the aim of this element is to ensure that the organisation has in place the systems necessary

To identify areas requiring work permits, To identify particular activities to which those permits must apply, To identify the authorized personnel responsible for issuing of the permits, and To ensure that those personnel have the appropriate competencies

4.2 General Comments

The basic purpose of a work permit system is to ensure that a higher level of checking and control is applied to particular work activities and work practices. A work permit system aims to provide an independent check and assessment of particular work activities to ensure that suitable risk controls are in place.

The requirement for issuing work permits may require an assessment of risk, and therefore this element links to “Hazard Identification and Risk Assessment”.

For Holcim sites, it is expected that a system of work permits will be in place for the following activities:

Confined space entry Management of ignition sources; eg. welding, cutting, brazing, etc Excavation and digging High voltage work

Other high-risk work activities include, but are not be limited to:

Lockout and isolation Working at heights Working with hazardous materials, including radiation sources



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Use of explosives Kiln light up Traffic and road OH&S

These activities will not require a work permit system, but will have Standard Work Procedures (and Practices) that ensure that a higher level of checking and control is applied to them.

These lists above should not be considered exhaustive, and individual sites may have further specific requirements that they include as well.

4.3 Detailed Discussion

Confined Space Entry

A confined space may be defined as an enclosed or partially enclosed space which

a) Is at atmospheric pressure during occupancy, and

b) Is not intended or designed primarily as a place of work, and

c) Is liable at any time to

Have an atmosphere which contains potentially harmful levels of toxic substances/contaminants

Have an oxygen deficiency or an excess; or Cause a person to be engulfed/buried by a material; and

d) Could have restricted means of entry and exit.

If one or more such space is found at the site, a confined space entry/work procedure must be in place. As a minimum, the following would be expected.

A “Safe working in confined spaces procedure” be developed and implemented at the site. It is expected that this procedure would be based upon the requirements of internationally or nationally recognized standards.

The confined space procedure will require risk assessment to be undertaken prior to confined space entry

The confined space procedure will require a list of persons inside the confined space to be maintained outside the confined space

The site will undertake a survey of its activities and operations, and identify the confined spaces present at the site. These confined spaces should be summarized in a register and the confined spaces should be marked with suitable signage.

The site should also undertake a survey to identify restricted spaces, i.e. those spaces which are not automatically classified as confined spaces, but which could become confined spaces if activities are undertaken within the space which affects the quality of the atmosphere therein, eg. welding. A register of restricted spaces should also be prepared.

Specific personnel should be authorized by site management to be responsible for issuing confined space work permits. These personnel should be trained



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regarding the confined space entry system and their responsibility for issuing confined space permits. Training and refresher training should be provided.

Personnel who are required to work within confined spaces should be trained regarding the requirements of the permit system, and their responsibilities as workers within a confined space. The training should include how particular hazards identified with the tasks to be performed within the confined space have been controlled. Training and refresher training should be provided.

A rescue capability should be in place to ensure that personnel who may be trapped in a confined space can be rescued. Training should be provided to all personnel who are or may be required to effect rescues within confined spaces. This training should include use of breathing apparatus where this control is determined necessary by the Risk Assessment process. Suitable rescue equipment should be available. Training and refresher training should be provided.

Control of Ignition Sources

The site should develop and implement a permit system to control ignition sources based upon relevant international standards and practices. (Such a permit is often called a “Hot Work” permit). This system must also take account of the requirements of the Alternative Fuels & Raw Materials (AFR) Health & Safety Manual.TP

2PT As a minimum, the following should be in

place:

A written Control of Ignition Sources permit system and associated forms. This system should identify those circumstances where gas testing is required as part of permit issue.

The site should identify and document those circumstances/locations where Control of Ignition Sources permits will be required; eg. Flammables, combustibles, coal, coal dust, oil, gas and all other fuels.

Specific personnel should be authorized by site management to be responsible for issuing Control of Ignition Sources permits. These personnel should be trained regarding the Control of Ignition Sources permit system, and their responsibility to issue Control of Ignition Sources permits. Training and refresher training should be provided.

Personnel who are required to work under Control of Ignition Sources permits should be trained regarding the requirements of the permit system, and their responsibilities as workers. Training and refresher training should be provided

All personnel who are required to do 'Hot Work'; eg. welding, cutting, brazing, etc must be competent and possess an appropriate qualification.

Suitable fire fighting equipment must be available onsite; eg. fire barriers, fire screens (non-combustible), fire extinguishers, hose reels, foam, water, etc

A systematic program must be in place for testing fire fighting equipment Personnel must be trained and retrained in the use of fire fighting equipment

TP

2PT For more details on this, check on ENVIRONET on HolSpace or HGRS/CIE/ETPS [email protected]



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Excavation and Digging

Undertaking Excavation

Each site should develop and establish a permit system to control excavation and digging. Unauthorized excavation and digging may damage underground services and place personnel at risk through contact with buried electrical cables, gas lines, fuel lines, etc. As a minimum, the following should be in place:

The site should develop and implement an excavation and digging permit system.

Specific personnel should be authorized by site management to be responsible for issuing excavation permits. These personnel should be trained regarding the excavation permit system and their responsibility for issuing permits. Training and refresher training should be provided.

Reference to site plans prior to undertaking excavation will be required as part of the permit issue system

There must always be alternative access provided for persons who have to cross the excavated area.

Entering Excavations

In addition to the excavation permit system discussed above, the site must also implement a system for protecting persons entering excavations where there is potential for collapse of walls.

Ideally this will involve a separate entry permit or equivalent system. It is essential that a competent person inspects an excavation prior to persons entering that excavation. If necessary, risk controls must be put in place to prevent the walls of the excavation collapsing. In keeping with good risk management practice, attempts must be made to design the walls of excavations in such a manner so that the potential for collapse is minimized (eg. angled walls rather than vertical walls). Persons required to enter excavations must be trained with regard to the content of this aspect of the Management System.

High Voltage Work

The definition of high voltage is as given by the local electrical authority but will always include sub-station and/or plant distribution voltages. A permit system must be in place to manage associated risks. As a minimum the following is required:

A formal written high voltage work permit system be established and implemented.

Specific personnel should be authorized by site management to be responsible for issuing high voltage work permits. These personnel should be trained regarding the permit system and their responsibility for issuing high voltage work permits. Training and refresher training should be provided.



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Personnel who are required to work under high voltage permits should be trained and retrained regarding the requirements of the permit system and their responsibilities as workers

Personnel operating on high voltage electrical equipment must be suitably licensed with respect to local or international regulations. Such licenses must be kept current and an inspection system to ensure that they are must be in place.

Suitable OH&S equipment must be provided and maintained, and personnel trained and retrained in its use

Lockout and Isolation

Personnel may suffer severe injuries if equipment is energized at the time that work is being undertaken on, or in the vicinity of, the equipment. Therefore, formalized isolation and lockout procedures are required. As a minimum, the site must ensure:

That a documented lockout and isolation procedure is developed for the site. (This procedure may also include requirements for tagging of equipment.)

Unless totally impracticable, lockout and isolation points for key items of equipment must be identified and documented. If necessary, retro-fitting must occur

Specific personnel are to be authorized by site management to be responsible for issuing lockout / isolation permits. These personnel should be trained regarding the operation of the permit system and their responsibility for issuing work permits. Training and refresher training should be provided.

It should be noted that the accepted international good practice requirement is that there has to be the ability to physically lock out and isolate equipment, not simply to rely on protection of any worker by means of an advisory tagging procedure.

Working at Heights

Work at heights greater than 1.8 meters

While not a formal requirement under a work permit system, it is now internationally considered good practice that any persons working at a height where they could fall 1.8 meters or more wear fall arrest equipment. Note that this specifically refers only to those situations where persons are not protected by handrails, scaffolding, etc.

Therefore the site must ensure that there is a system in place to provide protection for those persons who may fall a distance of >1.8 meters. This will require those personnel to be provided with protection or suitable fall arrest equipment. Where fall arrest equipment is provided, the persons using the fall arrest equipment must be trained and retrained in its use. In addition, the fall arrest equipment must be subject to inspection by a competent person on a regular basis, and whenever a fall arrest system is used, there must be a system in place to retrieve a person who has fallen in less than 5 mins.



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Where it is decided to provide other forms of protection, eg. scaffolding, then the person erecting or providing that form of protection must be competent. Records of the necessary competency should be available.

Hazardous Material Handling (incl. radioactive Sources)

Hazardous materials may be used in a variety of applications at the site. As such, there is the potential for exposure of personnel to the material, should appropriate controls not be in place or fail. This system must also take account of the requirements of the AFR Health & Safety Manual.TP

3PT Therefore, the following is needed:

Each site to identify applicable local legislation and standards, and ensure that there is a mechanism in place for remaining up-to-date with respect to changes to that legislation.

Specific personnel should be authorized by site management to supervise hazardous material handling. This includes a qualified person who is named as taking overall responsibility for this (It is noted that this is not seen to be a separate job, but simply a formal responsibility that may be applied to a suitably skilled person at the site). These personnel should be trained regarding the permit system, and their responsibility for issuing work permits. Training and refresher training should be provided.

Personnel who are required to work with hazardous materials should be trained and retrained regarding their responsibilities as workers in the safe handling of hazardous materials.

Suitable emergency response systems must be in place to deal with an emergency incident involving a hazardous material.

Mineral Fiber Materials

A particular group of hazardous substances are mineral fiber materials (MFM's). This includes materials containing asbestos as well as those consisting of synthetic mineral fibers.

Synthetic mineral fibers (SMF's) are manufactured materials and include glass fiber and wool, mineral wool (eg. rockwool, slagwool, kaowool) and ceramic fibers. SMF's can irritate the skin, eyes, nose and throat, and cause itching, sneezing and coughing. The International Agency for Research on Cancer (IARC) classifies ceramic fibers, glasswool and rockwool as possible human carcinogens. Asbestos is a natural mineral fiber, which was used extensively in building work and insulation during the 1950s, ’60s and early ’70s. It is now only used rarely TP

4PT in some

few applications such as friction materials like brake linings and gaskets. Asbestos is hazardous because its dust contains tiny fibers that can be breathed in and lodge in lung tissue. These have been found to cause diseases including asbestosis and mesothelioma, a cancer that is usually fatal. Such diseases can take from 10 to more than 30 years to develop after exposure to the fibers has ceased.

TP

3PT For more details on this, check on ENVIRONET on HolSpace or HGRS/CIE/ETPS [email protected]

TP

4PT IMPORTANT NOTE: The use of asbestos has been banned in Holcim Group.



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Those who may be at risk from exposure to MFM's include asbestos removalists, demolition and construction workers, operators of plant and equipment, trades people, laborers, office workers and householders when they live in, work in or work on buildings, plant or equipment containing any MFM's.

The general requirements for managing hazardous materials given above apply and, in addition, to manage any special risks from MFM's, each Group company OH&S coordinator must:

Have a mineral fiber materials survey conducted in all workplaces; Report the results to the local Chief Executive Officer; Check for any potential exposures based on the results; Do a risk assessment on any exposures identified; and Act accordingly; ie: use the Hierarchy of Controls.P

5P

NOTE: Compliance with this guideline must be checked using the Assessment Audit Protocol

For more information/advice, please contact HGRS: CHRM/CSR-OH&S

More information on MFM's as well as information on good practices in managing them can be found on SafetyNet HTUhttps://web.holcim.com/safetynet/UTH

Special Notes on Asbestos Cement Roof and Wall Sheeting

In most circumstances, asbestos-cement (AC) materials are best left undisturbed. Removal of AC materials does not need to be undertaken unless it is suspected that they may be releasing asbestos fibers into the air because of poor condition. Unnecessary removal may pose a greater health risk than simply leaving these products in situ - so long as the products are undisturbed and are likely to remain undisturbed.

Where for aesthetic or other reasons, asbestos-cement products are to be removed, the risks to health caused by their removal should be minimized. Appendix 1 of the Good Practice Guideline "Management of Mineral Fiber Materials" outlines the steps that should be taken to minimize risks during removal and can be found on SafetyNet HTUhttps://web.holcim.com/safetynet/UTH

Piping, guttering/other associated roofing components and wall sheeting/other associated wall components that are manufactured from asbestos-cement should be dealt with in the same way as AC sheeting.

IMPORTANT: Where AC sheeting is damaged/not in good condition eg. badly weathered or hail storm damage, the AC sheet can be easily crumbled and release asbestos fibers. Fibers can also be released if breakage occurs during

TP

5PT See Appendix A1



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dismantling and removal. So, the removal of aged or damaged AC sheets can present particular risks to health and shall be left to a licensed asbestos removalist.

Explosives

Explosives are used extensively in mining and quarrying operations. Therefore, as a minimum, the following are required:

Each site to identify applicable local legislation and standards, and ensure that there is a mechanism in place for remaining up-to-date with respect to changes to that legislation.

Site management must ensure that position descriptions reflect responsibilities for the storage, handling and management of explosives.

Documented site procedures must be in place for • Receival of explosives,

• Storage of explosives,

• Design and operation of magazines,

• Management of magazine inventory,

• Loading of explosives into drill holes,

• Shot firing, including use of licensed personnel

• Dealing with misfires noted at time of explosion,

• Dealing with misfires identified during mining activities, and

• Dealing with emergencies involving explosives.

Personnel must be trained regarding procedures involved in storage and handling of explosives. Refresher training must also be provided.

Suitable emergency response systems must be in place to deal with an emergency incident involving explosives.

4.4 Additional Issues

In addition to the formal work permit systems documented above, it is necessary for the site to develop formal OH&S Management Systems/ procedures for dealing with the following activities.

Kiln Light Up / Coal Mill & Coal Dryer Start-Up

Documented Safe Working Procedures (SWPs) must be in place for dealing with risks associated with kiln light up as well as coal mill and coal dryer start-up. These SWPs will be developed based upon hazard identification and risk assessment of all kiln start activities. All personnel involved in kiln start-up must be trained and retrained regarding the content of the procedures and a record of this training maintained.



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Traffic and Road Safety

Traffic and road OH&S will be maintained by means of a documented set of traffic rules for a particular site. These traffic rules will be developed on the basis of hazard identification, risk assessment and the local traffic regulations.

The content of the traffic rules will be communicated to all site personnel and must be specifically addressed in the induction training/processes for all new site personnel, subcontractors and/or 3rd party/contractor personnel.


Specific requirements in relation to work permit systems have been noted in section 4.3 above. These effectively establish audit requirements, and an auditor would expect to sight evidence that all of these issues have been implemented.

Always check Holcim documentation against Hazard Identification local regulatory/legal requirements and Risk Assessment


5. UHAZARD IDENTIFICATION AND RISK ASSESSMENT


Hazard identification and risk assessment are key building blocks of modern OH&S Management Systems. From a legal point of view, OH&S legislation often specifies that organizations must undertake risk assessments on the tasks and conditions existing in their workplaces.

From a practical point of view, hazard identification and risk assessment provides the opportunity to be proactive and to identify situations in the workplace that could cause injury or illness, and deal with those situations before their consequences occur.

This guideline provides a lengthy discussion of hazard identification and risk assessment, and also a simple methodology that can be used to perform this activity.


Modern OH&S management legislation frequently spells out the need for a risk-based approach to managing OH&S in the workplace. This approach requires that hazards are identified, risks are analyzed and evaluated, and strategies put in place for effectively managing and monitoring those risks.

A comprehensive approach to OH&S Risk Management must be implemented within the organization to ensure that OH&S management goals are achieved, including:

Hazard reports and process hazard analysis Definition of risk Risk analysis and assessment Risk calculation matrix Specific risk controls in OH&S Monitoring and evaluation the effectiveness of controls

It is expected that there will be a formal system in place for hazard identification and the subsequent managing of the risks associated with those hazards.

A detailed discussion of Risk Assessment is included in the Appendix One at the end of this document.



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Examples of hazards or circumstances for which risk assessment is expected to be required include, but are not limited to:

• Noise • Vibration • Dust / silica • Hazardous substances • Manual handling • Ergonomics • Human factors • Electrical • Communicable diseases • Crane operations • Coal dust • Hazardous substances • Confined spaces

• Radiation • Biological hazards • Mobile plant and equipment • Fixed plant and equipment • High pressure • High temperature • Working at heights • Falling objects • Excavations • Hand tools • Plant rescue requirements • Introduction of new equipment • Changes to procedures

(NOTE: See the blocks Design Safety, Purchasing, and Management of Changes

5.3 Details

Hazard Studies

A number of different approaches are available for the management of OH&S at any site. One area, which must be addressed, is identification and management of hazards intrinsically associated with the process. Therefore, a formal Process Hazard Analysis (PHA) should be undertaken and documented and recommendations made for control of risk.

Types of techniques that may be applicable to such an analysis include:

Risk assessment HAZOP/HAZAN “What if?” analysis Failure mode and effect analysis Fault tree analysis Event tree analysis It is expected that: A multi- functional/disciplinary team will undertake any PHA done and that a

formal report will be issued; The PHA should be subject to regular review; and Hazard studies / risk assessments are undertaken on all operational and

maintenance activities.



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Key issues to be considered by those who own and operate plants include: • Risk management • Design and construction • Positioning of plant in the workplace • Operation • Damaged plant • Dismantled/stored plant • Plant with moving parts • Powered mobile plant • Electrical plant and plant exposed to

electrical hazards • Industrial lift trucks • Industrial robots • Air conditioning units • Auditing • Inspection • Servicing • Maintenance

• Repair • Modification • Cleaning • Disengaged and stored plant • Transporting plant • Lighting • Ventilation – mists, fumes and dusts • Wear corrosion and damage • Information provision • Instructing workers • Training workers • Supervising workers • Safe work practices • Competency • Consultation • Records

Operating Procedures

Written operating procedures, which specify key information for operations personnel, should be provided at the site. These assist personnel to manage OH&S by setting clear standards for operational practices. Operating procedures should provide plain instructions for safe operation of the facility and be consistent with the hazard identification and process OH&S information available.

Operating procedures should address the following:

Initial start up Normal operation Normal shutdown Start up following a shutdown or turnaround Emergency operations, including emergency shutdown Any temporary operations

Operating procedures should also provide information on operating limits and where a deviation from normal operations could have OH&S consequences, the following should be provided:

Consequences of the deviation Steps required to correct or avoid the deviation A reference to OH&S systems and their function.

Operating procedures should also address the following:

Properties of, and hazards presented by, materials used in the process Special precautions required to prevent exposure to materials Control measures to be undertaken if physical contact or airborne exposure

occurs Any special or unique hazards.

Operations procedures provide a description of operation of the plant and facility at a particular time. Over time, plant modifications will occur and operator understanding of key plant issues will also change. Therefore, operating procedures may need to be modified and updated to



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reflect these changes. Thus a system must be in place for ongoing review of the effectiveness of operations procedures and modifying and updating operations procedures, as required.

5.4 General Risk Controls

In addition to any outcomes from specific risk assessments, the following general controls should be in place

Drug and alcohol policy Fitness for duty protocol - both physical and literacy/language. Provision of first aid facilities Provision of general worker amenities (sufficient toilets, showers/washing

facilities, eating areas, heating/cooling, hot/cold potable water, lighting, etc) as well as maintenance of them


The Audit will seek evidence of:

Hazard identification Risk assessment Implementation of risk controls Review of effectiveness of risk controls Any audit will also normally assess mechanisms in place for reviewing,

updating and improving operating procedures.

Always check Holcim documentation against Planned Inspections local regulatory/legal requirements


6. PLANNED INSPECTIONS


Simple planned inspections can be undertaken even in the abseManagement Systems. These inspections are useful to quickly ihazards in the workplace.

The inspections discussed in this section are those that can easworker, eg. housekeeping, presence/absence of machinery guaHandbook, those inspections requiring a high level of expertise vessels/relief valves.

Undertaking regular inspections of key areas or aspects of a woeffective OH&S management. Planned inspections allow a reguthe workplace, and ensure that appropriate risk controls are in pbe carried out even if the more comprehensive aspects of an OHnot in place.

When deficiencies and hazards have been identified, a properlysystem ensures that they are eliminated or controlled. This bloctypes of planned inspections that should be undertaken.


Planned inspections may be applied to a range of different areaworkplace. These include the various topics listed in the table bdetermine those topics for which planned inspections are requirInspections in addition to those listed below.

Guards Ladders Access Hygiene andStorage practices Refuse storaRefuse disposal Hand tools Gas cylinder storage Mobile plant Personal protective equipment OH&S equipColor coding Labeling of cSignage Chemical sto

corrosives) Material OH&S Data Sheets Stairs Handrails Eyewash StaWorkplace Amenities Certification Housekeeping Training is cu

Training MasBreathing apparatus Lifting equipm

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nce of fully implemented OH&S dentify deficiencies and

ily be undertaken by any rding, etc. In section 15 of this are considered, eg. pressure

rkplace is an important part of lar checking of key features of lace. Planned inspections may &S Management System are

operating corrective action k provides guidance on the

s and activities within the elow. Each site should ed. This may require Planned

sanitation ge

and equipment ment ritical equipment rage (Including flammables and

tions and Safety Showers & Licenses rrent/up to date (according to ter Plan) ent

Always check Holcim documentation against Planned Inspections


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6.3 Discussion of Topics

In the sections below, each of the inspection topics is briefly discussed in order to indicate their role and purpose. The list is not expected to be comprehensive and each site should add local requirements.

Guards

Providing guards, where required, is an important way of protecting employees from injury. The requirement for guarding is likely to be determined by local legislation and applicable Standards or Codes. A register of items of equipment requiring guarding should be developed, including specific details relating to guards and, if appropriate, numbering of guards. The person undertaking the inspection is then able to identify whether the guard is in place and in good condition and, if necessary, make recommendations for further action.

Ladders

Ladders, stairs, and walkways are generally addressed either directly by legislation or by appropriate Standards and Codes. Details of all portable ladders should be recorded including their location. It is recommended also that each ladder be numbered for easy reference.

Access Inspection

This inspection is aimed at checking and making recommendations regarding access in various areas within the workplace. Access is essentially a housekeeping item. However, many incidents occur in workplaces because there is inadequate access. Where key problem areas are known these should be included on the inspection form to ensure that when an inspection for quality of access is undertaken those particular areas will be inspected.

Hygiene and Sanitation Inspection

This inspection aims to address hygiene and sanitation issues within the workplace. Therefore, the types of issues to be addressed by the inspection include cleanliness of wash-up and shower areas, toilets, restrooms, and lunchrooms. Each relevant area should be listed and when the inspection is undertaken problems and recommended actions should be identified. If the workplace has a specified first aid area or first aid room, this should also be inspected.

Storage Practices Inspection

The purpose of this inspection is to ensure those areas where materials are stored are inspected and checked for good storage practices. Issues, which may be addressed by this inspection, include storage of materials in work areas and also warehouses. The inspection should also address the suitability and adequacy of stacking practices.

Refuse Storage and Disposal Inspection

This inspection relates to good housekeeping practices by focusing on storage and subsequent disposal of refuse. The inspection can be used to check that materials are placed appropriately



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into bins and that bins are emptied at regular intervals. Therefore, the location of the key waste storage and waste bin areas should be identified. It is noted that in some circumstances different types of bins will be required for different types of materials eg. paper, glass, chemicals etc. Where different types of bins are used, each should be separately identified.

Hand Tool Inspection

Many accidents occur in workplaces because persons use faulty tools and equipment. The purpose of this survey is to inspect all key hand tools and ensure that they are fit for use. Generally, the responsibility for completing the inspection will fall to the person who has responsibility for the day-to-day use of the hand tool, or sometimes their supervisor to check the adequacy of the inspections being undertaken.

Gas Cylinder Inspection

The purpose of this inspection is to identify the different types of gas cylinders present at a worksite and their storage locations. The inspection enables identification of cylinders that have been present in a particular location for an extended period of time and those that are in need of maintenance attention and action.

Mobile Plant and Equipment Inspection

Because of the energies involved there is potential for serious incidents associated with mobile plant and equipment to occur. Therefore, this inspection requires that all items of mobile plant and equipment are identified and their usual location specified. The inspection then requires that each item of equipment is inspected for suitability for continued operation and any problems and associated recommendations are noted. These inspections may include daily pre-start checks and regular maintenance inspections.

Personal Protective Equipment Inspection

As noted in a later section, personal protective equipment is one key strategy for protecting employees from OH&S risks. However, PPE will be effective only if it is appropriately maintained. This inspection enables an inventory of PPE to be developed, the various locations to be identified and particular problems and recommended actions to be specified. Generally each employee should have responsibility for his or her own protective equipment.

Safety Equipment Inspection

As well as personal protective equipment and fire fighting equipment there may be other specified items of OH&S equipment present at a workplace. The purpose of this inspection is to create an inventory of such equipment and its location and also to specify testing requirements and confirm that tests have been undertaken. Depending upon the nature of the equipment there may be applicable Standards or Codes specifying test intervals.



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Color Coding and Labeling Inspection

One effective way of highlighting hazards in the workplace is to use color coding or labeling. For example, pipes containing different types of materials are painted with different colors in order to alert employees regarding their different contents. This particular inspection enables each item of plant or equipment to be specified in a register / form, including its location and the appropriate color requirement to be identified. Use of the inspection register then confirms the suitability of color-coding and can be used to identify the need for repainting etc. The requirements for color-coding, the use of specific colors and the interpretation of that use are usually contained in particular Standards, Codes or legislation.

Labeling of Critical Equipment Inspection

In any workplace, it is likely that there will be key items of equipment that are critical to the continuity of work practices or critical to the performance of certain OH&S actions or functions. An example is an emergency alarm or emergency shutdown button. This inspection requires the location of critical items of equipment to be specified, any appropriate labeling requirements also to be specified and problems associated with the labeling of the equipment to be identified as the result of an inspection.

General Signage Inspection

In any workplace, there will be a range of requirements for signage. These may be formal requirements relating, for example, to hazardous substances placarding and/or signs or there may be decisions made at a particular site regarding the erection of particular warning signs, eg. requirement to wear safety helmets, glasses, boots etc. Once decisions regarding signage have been made, it is essential that the signage is erected and maintained. The purpose of this inspection is to specify signage requirements at different areas in the workplace. Adherence to these requirements can then be assessed by use of an inspection.

Stairs

Stairs should be inspected to ensure that there are no deficiencies. This should include a consideration of treads and handrails.

Handrails

Handrails should be inspected for structural integrity and repairs effected where required. The requirements for handrails should be addressed in accordance with the relevant standards.

Chemicals and MSDS Inspection

Management of chemicals in the workplace requires an inventory of all chemicals and their location to be developed. In addition, there is a requirement that Material Safety Data Sheets are obtained for all chemicals classified as 'hazardous'. The purpose of this inspection is to generate an inventory of chemicals that are present at a workplace, their storage locations and determine whether a Material Safety Data Sheet is currently available. The Register should also provide scope for assessment of the adequacy of storage and the need for formal risk



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analysis. Management of hazardous substances in a workplace is a major issue and generally, there will be specific legislation and supporting Codes and Standards that must be addressed.

Eyewash Stations and Safety Showers

A register of eyewash stations and safety showers should be developed and these should be tested on a weekly basis. Where deficiencies in water flow are identified, corrective action should be carried out immediately.

Workplace Amenities

Workplace amenities refer to those amenities provided to workers in a workplace. They consist of items such as toilet facilities, changing/showering/locker room blocks, kitchen areas, eating areas, drinking water and heating or cooling devices. An inspection program to monitor the quality in all areas of amenities should be in place.


An audit will check

That a systematic inspection program is in place That outcomes of inspection are actioned by means of corrective action

requests That linkages exist to both MAC & SAP

Always check Holcim documentation against Legal Obligations local regulatory/legal requirements


7. ULEGAL OBLIGATIONS


It is essential that each site satisfies legal obligations and complies with relevant legislation. It is expected that if all the other elements in the Pyramid are fully addressed, then legal compliance should in most cases be in place, since there is a commonality within OH&S Management Systems and OH&S legislation.

Nonetheless, this element provides the opportunity for confirmation that all compliance objectives have been met, and also requires that each Group company has in place a mechanism for identifying changes to legislation, and ensuring that the impact of those changes is assessed and implemented at each site.


This element requires that each site establishes and maintains a procedure to identify and have access to current legal and other requirements that are applicable to the site.

Compliance with relevant legislation and/or regulations must be fully achieved. This block requires that Group companies have in place a mechanism for:

Identifying all legal obligations Confirming that these legal obligations have been addressed Ensuring that the companies are aware of any changes that may be made by

governments or regulators with regard to their responsibilities.

This block recognizes that there are sometimes external agencies such as SUVA in Switzerland or OSHA in the USA that can impose regulation on Group companies.

7.3 Details

Some of the issues that need to be considered include:

How the site accesses and identifies relevant legal and associated requirements, e.g, legislation, Standards, Codes.

How the site addresses/complies with these legal and other requirements. How the site monitors changes to legal and other requirements. How the site communicates relevant information on legal and other

requirements to people working there.

Always check Holcim documentation against Legal Obligations local regulatory/legal requirements


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It is noted that the regulatory requirements applicable to a site’s activities, products or services may exist in several forms. Examples include:

Those specific to a particular activity eg. site operating permits. Those applicable to the site’s products or services. Particular authorizations, licenses and permits.

In implementing a OH&S Management System, it is important to maintain a listing of current applicable Legislation. Note that different regulatory authorities, eg. Federal, State and Local, may administer different aspects of Legislation.

A master copy of the Legislation and all applicable Standards and Codes should be retained.


An audit will seek evidence of:

Identification of legal obligations System for maintaining knowledge of legal requirements System for communicating changes to site personnel Compliance audits

Always check Holcim documentation against Management Commitment & local regulatory/legal requirements Planning


8. UMANAGEMENT COMMITMENT AND PLANNING


To be effective, an OH&S Management System requires the participation and support of all sections of an organization. Gaining this commitment requires senior management to demonstrate a corporate commitment through leadership and allocation of resources.

Management commitment and planning must manifest itself within policies and targets adopted by Group companies.

Integration of OH&S issues into planning and budgeting processes Establishing and resourcing functional plans Reviewing the results achieved by their OH&S Management System In particular, OH&S related insurances (especially Accident Insurance /

Workers Compensation) must be sufficient and well managed The planning for action to be taken in the event of an emergency OH&S

situation.

Hence the existence and application of OH&S policies, budgets, standards, targets, annual plans, special programs, emergency and contingency plans, is addressed in this block.


This element is considered to be a key element within the Holcim OH&S Management System. Effective attention will not be given to the management of OH&S and implementation of OH&S management initiatives unless there is demonstrated by management a demand for, and commitment to, achieving good OH&S management.

The types of issues to be addressed as part of management commitment include:

Development of an OH&S Policy. Distribution of the OH&S Policy and other site critical information in the

necessary language(s). Specification of an organizational structure suitable for managing OH&S



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One recommended Structure for OH&S:

This model is recommended for effective and efficient OH&S structure and staffing, however local legal requirements may mean there is a variation in a Group company.

Other issues to be considered as part of management commitment include:

Each operating site with 80 or more FTE employees should have a person responsible for the function of providing OH&S support. A risk assessment is required to decide how sites with less than 80 employees are to be provided with OH&S functional support, and how much time should be allocated to perform the function at a site.

Specification of responsibilities of all persons within the organization, with respect to management of OH&S.

Structures for communication of OH&S information within the organization. Structures for consultation within the workplace. Commitment of sufficient financial resources towards the achievement of

OH&S management goals. Review of OH&S management performance.

The need to be able to respond to emergency situations is also a fundamental part of any OH&S Management System. Emergency planning is closely allied to hazard identification and risk assessment, because it is through the hazard identification that it is possible to identify where emergency plans are needed (See 8.4).

GC OH&S Co-coordinator

GC Exco Member

GC and/or Business Unit

OH&S Committee

Person responsible for

OH&S in a Business Unit

Informs

CEO & GC Executive Committee Overall management control of OH&S

in the Group company (GC)

Particular responsibility for OH&S in the GC

Co-ordinates the OH&S approach in the GC

Promotes OH&S in the GC

Provides OH&S expertise



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8.3 Issues to be addressed

OH&S Policy

Company management, in consultation with workers, must develop an OH&S policy. This Policy should embody the requirements of local legislation as well as the key aspects of the Holcim OH&S Policy. The policy should be signed by the Chief Executive or Company Manager, as appropriate, and be reviewed on an annual basis. This policy:

Should be a formal document Be dated and signed by the current Chief Executive or Company Manager Must clearly state OH&S objectives Must declare management’s commitment and determination for achievement of

OH&S objectives Must broadly define responsibilities for all parties at the workplace Must be clearly understandable and Be available to/provided for employees at all levels of the organization

Holcim OH&S Targets

Each site will develop an OH&S Plan with the objective of achieving Holcim’s corporate OH&S performance targets:

Zero accidents causing death or permanent disablement annually Achieving a LTIFR of <5 annually Achieving a LTISR of <60 annually

Communication of OH&S Policy and Targets

It is important that an OH&S Policy once formulated, and the performance Targets, are communicated effectively within the workplace. This can be done in a several ways:

Issuing written copies to employees. Issuing written copies to visitors. Including it in induction training. Including it in procedure manuals. Including it in OH&S promotions. Including it in contract documents. Displaying it on notice boards. Discussing it at group meetings. Discussing it at OH&S meetings. Discussing it at other formal and informal meetings



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Evaluation of OH&S Policy and its Communication

Management must also evaluate the effectiveness of the OH&S Policy and its communication. Ways of doing this include:

Checking that it is fully understood by all employees. Ensuring, where appropriate, that it is translated into other languages. Ensuring that it accommodates the needs of persons with specific disabilities. Checking notice boards. Participation in OH&S meetings. Participation in training sessions. Formal and informal discussions.

Resources

It is the responsibility of management to ensure that suitable resources are provided for the OH&S program. This could include some or all of:

Appointment of a person to the Group company OH&S coordinator function Appointment of site OH&S officer Training of OH&S officer Training of OH&S Committee personnel Other OH&S specific training Identification of key competencies required Provision of budget for OH&S initiatives Development of a plan to achieve OH&S objectives Linkage of the OH&S plan to the budgeting process

OH&S Plan

Managing OH&S should be a matter of ongoing and continuous improvement in OH&S performance. Therefore, an OH&S Plan should be developed and reviewed on an annual basis.

The OH&S Plan should address the following:

Input from site personnel (via the OH&S Committee or local equivalent) Focus on key hazards and risks Linkage to requirements of legislation Linkage to incidents that have previously occurred.

8.4 Emergency Planning

An effective risk management program aims at preventing the occurrence of incidents likely to pose a significant threat to individuals or operations. Nevertheless, it is possible that such incidents, including natural disasters, may occur and therefore an effective Emergency Plan needs to be in place - See Appendix 3 for an example.



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General Comments

As a minimum, the following is required:

A documented threat analysis to identify the scenarios for which emergency planning is required. (Note: This should flow in part from application of hazard identification and risk assessment practices.) The threat analysis should consider both on and off site impacts, as appropriate

Appointment of a coordinator for the emergency plan to ensure that the plan remains current.

Development of more detailed emergency response plans for each of the main scenarios identified in the threat analysis.

Nomination of responsibilities and duties for personnel to implement those plans.

Liaison with external authorities. Provision of suitable emergency response equipment. Training and retraining of personnel in emergency response procedures. A maintenance program for emergency response equipment. Undertaking of drills to test aspects of the emergency plan. Evaluation of those drills as a means of improving the quality of the emergency

response plan. Annual review of the plan

Risk Management Basis

A consideration of emergency planning and the development of suitable emergency plans should flow from the risk management process. When hazard identification and risk analysis is undertaken it is possible at the same time to identify those sets of circumstances that may lead to emergency situations. The strategy to be adopted in developing an emergency plan is:

Identify the different types of emergency scenarios that could occur, eg. fire, explosion, natural events, bomb threat, terrorism, etc.

Identify the types of consequences that are likely to emerge from such incidents and also identify the emergency response measures that will be needed to minimize the impact of those consequences.

Emergency planning follows naturally from risk management. Risk management aims to identify risks and control them so that undesired situations do not occur. Emergency planning and emergency response plans attempt to minimize the consequences of those undesired situations when they do occur.

Content

A well-constructed emergency plan should contain the following:

A list of scenarios that could occur and their likely consequences.



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Actions, involving specified personnel, which are required to deal with different emergencies (an emergency plan may have several pages containing identified scenarios and specific responses).

A list of contact phone numbers for emergency services, doctors, staff, contractors etc. to be called in out of hours, suppliers of emergency equipment, Government officials etc.

A list of emergency response equipment on-site and its storage location. Identification of an emergency control room or point if that is appropriate. A collection of relevant information that may be needed in an emergency, eg.

drawings, registers of chemical storage, etc.

Testing Emergency Plans

To be effective an emergency plan must be tested on a regular basis. Testing of emergency plans should be documented and after each test, the results should be reviewed in order to identify the types of improvements that can be made to the emergency response strategy.

Workplace circumstances may change and render the contents of an emergency plan ineffective. Therefore, regular reviews are needed to ensure that changes are incorporated into the plan and that the plan is reviewed at regular intervals.

Document Control

It is critical that at the time of any emergency, the Emergency Plan in place is current and is therefore able to be effective in dealing with the emergency. Therefore, an Emergency Plan should be a controlled document and those personnel participating in the plan or in need of an understanding of the plan, should be part of a formal distribution list for the Plan.

8.5 Management Review

There must be a senior management review within each Group company of the OH&S program on an annual basis. Although it is expected that OH&S performance and the OH&S program will be reviewed at several levels, including the OH&S Committee, senior management must do so, in recognition of their overall responsibility for OH&S management. They should:

Formally review the success of the program on an annual basis In particular, a check must be made that OH&S-related insurances are

sufficient and well managed Document that review, and Formulate an OH&S plan for the forthcoming year.


The following will be considered:

Existence of OH&S Policy. Date and signature on OH&S Policy. Evidence of OH&S Policy throughout the work site.



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Inclusion of OH&S Policy in site induction material. Evidence of review and updating of the OH&S Plan. Evidence of a review of sufficiency as well as the efficiency and effectiveness

of all OH&S-related insurances A process should be in place to ensure that ongoing audits and reviews of the

OH&S Management System are undertaken. Policy targets and communication of them OH&S planning Resourcing and budgets The existence of an emergency plan based upon a realistic scenario / threat

analysis. (The content of the plan will be reviewed). Emergency planning Testing emergency and contingency plans Evidence that the emergency plan is a controlled document and is reviewed

and updated regularly to reflect changes in circumstances Occurrence of drills to demonstrate the effectiveness of the Emergency Plan Action plan based upon outcome of drills Overall management review and system improvement

Always check Holcim documentation against Induction and Training local regulatory/legal requirements


9. UINDUCTION AND TRAINING


The basis for any program aimed at the prevention of risk exposures or accidents is to cultivate a culture of OH&S awareness, and to provide each person with the skills and knowledge necessary to ensure that they work in a safe and healthy way.

This block establishes the need for all workers at Group company workplaces to receive a systematic set of courses containing a series of guidance, instruction, schooling and assessment that is given:

When any employee or subcontractor or self employed person first starts to work in one of our workplaces or changes to a new job, or any other visitor comes to any of our workplaces (induction)

To meet and identify the need to improve the skill or knowledge of an employee (training).

Plant managers are responsible to ensure that site personnel receive the necessary OH&S training.

9.2 Induction

OH&S induction training for new employees is an important aspect of a site OH&S Management System. Every new employee or a current employee working at a site or in an area for the first time should undergo induction training.

The content of the induction training will depend on the circumstances, the type of work the person is undertaking and the hazards to which they are likely to be exposed.

The elements that are common to most OH&S induction programs are:

OH&S Policy and objectives for the site Main site hazards. Specific site OH&S rules. Location of first aid and medical facilities. Location of fire fighting facilities. Details regarding emergency plan. Information regarding OH&S Representatives. Information regarding OH&S Committee. Other general OH&S information.

Where possible it is desirable to provide to new staff a booklet or brochure summarizing the key OH&S issues relating to the site. Induction will also include a test to ensure the person's understanding.



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They should also receive a more detailed OH&S induction from their supervisor, manager, or team leader on the job that relates specifically to the hazards that they are likely to encounter in their area of work. Receipt of induction training should be recorded and it is important that persons who have received induction training are able to undertake refresher training later.

It is also important for a site to review the content of its OH&S induction training from time to time because as development occurs and processes change, the types of hazard that may exist in a particular area of the workplace may also change.

9.3 Training

Training is complementary to the notion of including OH&S responsibilities in position descriptions. Often many of the incidents that occur result from inadequate training.

The types of issues that need to be considered in identifying training needs are:

Occupation types. OH&S issues. Tasks within occupations. Critical tasks within occupations. Literacy and language

The following issues should be addressed:

Training requirements of particular occupations. Specific tasks within occupations requiring training. Critical tasks within occupations requiring training. Selection of the trainer. Attendance records. Documentation of training.

The types of training which may need to be undertaken may include:

Training of new employees. Training of promoted employees. Training of transferred employees. Induction training. Training in emergency procedures (including practical sessions). First aid training. Training on new or remodeled equipment. Training in hazard identification, risk assessment and risk control. Training in specific tasks. General supervisor/manager training. Specific training for OH&S coordinators, Representatives and Committees. Specific training relating to new or revised Standards or Legislation. Training relating to revised or different work methods Refresher training as required



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9.4 Training Review

It is important also that management tests and evaluates the effectiveness of the induction and training program. This can be done in a number of ways:

Reviewing of course content. Informal discussions with attendees. Formal testing for proficiency. Reviewing accident/incident records to determine whether involved persons

were appropriately trained. Reviewing the competency of trainers. Conducting task observations. Conducting random inspections particularly after training has been given on a

particular topic.

It is important that training is seen to be an on-going process. All skills need to be revised by means of refresher training. Refresher training is particularly important and should be constructed in a way that challenges the person who is undergoing the training to either demonstrate their current level of knowledge or to acknowledge the need for the refresher training and to update their knowledge.


The following information will be sought as part of an audit:

Initial training for new employees or person new in a job Consideration of differing levels of ability and literacy of attendees. Provision of training by appropriate competent personnel. Use of suitable training facilities. Maintaining training records. Evaluation of training sessions to ensure comprehension and retention. Regular review of training program.

An audit will also review the induction program for:

New employees Contractors Visitors

Always check Holcim documentation against Incident Investigation local regulatory/legal requirements and Corrective Action


10. UINCIDENT INVESTIGATION AND CORRECTIVE ACTION


In any organization incidents will continue to occur, and it is important to learn from them. A proper incident investigation system will permit identification of the root cause, contributory factors and system deficiencies in each particular case. It will also permit control of these causes to help prevent any similar incidents recurring.

An additional requirement for reporting and sharing of critical information between Group companies is established in this block.

It is fundamental to any improvement methodology that a corrective action system is in place in order to distil lessons learned from any mistakes or hazards found, and then correct identified deficiencies, and realize any identified opportunities for improvement.

In order for a site to

“Learn from its mistakes”, Correct identified deficiencies, and Identify opportunities for improvement,

It is fundamental that a corrective action system is in place. Note that companies with existing ISO9000 or ISO14000 systems should have this block substantially in place.


Incidents are unwanted occurrences for any organization. An incident may not necessarily result in damage or injury, but may be a “near hit”.

However, the occurrence of an incident provides the opportunity for identifying root cause, contributory factors and system deficiencies and making changes to Management Systems and work practices to prevent such an incident occurring again. Other elements of the OH&S Management System, eg. hazard identification and risk assessment, attempt to take a proactive approach to OH&S management and identify those circumstances that could lead to incident or injury. Incident investigation, however, takes a predominantly reactive approach and attempts to learn lessons from incidents that have occurred.

This particular element is included as one of the basic elements of the Holcim OH&S Management System, because it is considered that any site, irrespective of the overall OH&S Management Systems that are in place, should be capable of investigating incidents and putting remedial measures in place.

Always check Holcim documentation against Incident Investigation local regulatory/legal requirements Corrective Action


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It is also important that a robust incident investigation system is in place, so that relevant statistical data can be accumulated to provide a better indication to a site of their OH&S management performance. Formal incident investigation procedures should be in place for investigating process-related incidents such as high temperature excursions, overfilling of bins, silos etc.

Further, formal procedures should be in place to investigate incidents such as injuries, near hits/misses, damage, substandard conditions, substandard practices, defects in plant and equipment, hazards, illness, disease and any other matters of interest.

Investigation procedures should seek to determine the immediate and root cause, contributory factors and system deficiencies, and develops remedial actions for preventing the same or similar events occurring in the future. Managers and supervisors should be trained and retrained in incident investigation procedures.

10.3 Incident Investigation Process

Overview

There are four broad goals associated with incident investigation:

To prevent the same incident occurring again To learn from “near hit” incidents and so prevent incidents occurring To review management and work practices and prevent similar incidents

occurring in the future elsewhere in the Holcim group of companies To develop statistical data.

The first three sub-elements are particularly important. Many organizations are successful in investigating incidents and putting controls in place to prevent the same incident occurring again. However, they may fail to take a broader view and to develop controls that can prevent similar occurrences elsewhere within the organization in the future.

It is important, therefore, that any OH&S Management System is developed in such a way that incident investigation is seen to be a contributor to the overall improvement of the OH&S Management System and not simply a matter of reacting to a specific set of circumstances.

The purpose of incident investigation is to determine why a particular incident occurred and to set in place measures that will prevent that same incident or incident occurring again. Therefore a typical outcome from an incident investigation is a set of short-term (quick fix) measures that will prevent the same incident occurring immediately again. Additionally, there should be a series of longer-term measures, which will make fundamental changes to the OH&S Management System and therefore prevent the same or similar incident occurring again.

It must be strongly stressed that the primary purpose of incident investigation is to identify causes and not to attribute blame to individuals who may have been involved in a particular incident.



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Incident Reporting

Documented procedures should be in place for reporting

Injuries Note: An important part of this is SafetyAlert, the Critical Incident Reporting

System that has been established. All Fatal and Permanently Disabling Injuries must be reported on this as soon as they occur.

Illnesses Property damage “Near hits/misses”, eg. person nearly struck by a falling object Hazards Defects

Undertaking Incident Investigation

Each site should develop and implement specific procedures or strategies for undertaking incident investigation. However, any good incident investigation procedure should address the following issues:

1) Identification of what happened

It is important that incident investigation identifies in a factual manner “what happened”. This phase of incident investigation is not involved in determining causes or remedial action but is merely concerned with obtaining information.

A good incident investigation report should list briefly:

The nature of the incident. When it happened (date, time, shift). Who was involved. Who was a witness. The type of equipment that was involved. The nature of the injury. The nature of the damage to the equipment. A brief statement of the circumstances of the incident

After this is completed it is important to review it to ensure that it is purely factual information and does not include cause analysis or recommendations.

2) Sequence of Events leading to Accident/Incident

After factual data has been obtained it is then necessary to identify the sequence of events leading up to the incident. This might involve identifying the sequence of three or four events that occurred immediately before the occurrence of the incident.



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3) Determining Root Cause, contributory Factors and System Deficiencies

The key to effective accident investigation is to keep asking the question "Why?" For each of the events preceding the incident it is possible to ask and continue to ask why that particular event or the event that led to it happened. Continually asking “Why?” will lead to a series of basic causes for the incident. At the end of this stage of incident investigation, it should be possible to identify a series of causes and factors regarding why a particular incident happened.

4) Developing remedial Measures

Incident investigation will normally generate two types of remedial actions:

1) Short term fixes; and 2) Longer term solutions.

A “short-term fix” is something that can be put in place almost immediately and will prevent that same incident from occurring again in the immediate future. The purpose of a longer-term solution is to put in place measures that will effectively prevent the same incident occurring but will also prevent similar incidents occurring in other areas of the workplace.

5) Communication with Persons involved

After an incident investigation has been undertaken and documented, it is important that the results of the investigation are reviewed by the person or persons originally involved in the incident. Incident investigation reports typically have an attached circulation list such that the involved persons, the OH&S officer and also management, can review them. This must be specified in the procedure.

6) Follow-up and Review

Many organizations fail to learn from mistakes by not adequately implementing recommendations from incident investigation. Results of incident investigations should be audited to confirm suitability and success in implementation of recommendations. Procedures should be in place to review the outcome of incident investigation and confirm that recommendations have been implemented. Group companies should also be aware that sharing the results of investigations with other Holcim companies could help prevent a similar incident occurring in another company. This sharing is done via SAFETY and/or the OH&S coordinators' Community of Practice.



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7) Training

Personnel involved in incident investigation should be provided with training, including training in analysis of root cause, contributory factors and system deficiencies.

8) Statistical Analysis of Data

Review and analysis of data may reveal useful trends. Trends may be identified for:

Injuries Property damage “Near hits/misses” eg. person nearly struck by a falling object Hazards Illness Compensation claims

10.4 Corrective Action System

General

While incident investigation provides the opportunity for an organization to learn about deficiencies within its OH&S Management System and implement initiatives to prevent the same and similar incidents occurring in the future. Whereas incident investigation is a specific response to a particular occurrence leading to an injury or illness, establishing corrective action requests can be proactive and part of a broader approach to identify deficiencies and potential for improvement, even if undesired consequences have not yet occurred.

Note: It is expected that sites with existing ISO9000 or ISO14000 systems operating will have this element substantially in place.

Details

As a minimum, the following requirements must be in place:-

A mechanism for identifying the need for corrective actions. A mechanism for recording the requirement for a corrective action. (Typically

this will be a corrective action request form.) A mechanism for tracking corrective action requests, including a specific

number for each corrective action. A mechanism for assigning responsibility for implementation of corrective

actions. A system for assigning responsibility for reviewing the effectiveness of

corrective actions. A “sign off” and record system to ensure that corrective actions are completed,

and details appropriately recorded.



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An audit will seek evidence of

Hazard reporting Incident reporting (including Critical Incident reporting) Incident investigation procedure Incident investigation activities, including training Development and communication of corrective actions Implementation of corrective actions Review of corrective actions Statistical analysis of data

Always check Holcim documentation against Industrial Hygiene local regulatory/legal requirements and Monitoring


11. UINDUSTRIAL HYGIENE AND MONITORING


Industrial hygiene is the anticipation, recognition, evaluation and control of those environmental factors (sometimes called stressors) arising in or from the workplace that may cause sickness or impaired health amongst employees, visitors, contractors or the general public. (These various environmental factors or stressors are usually classified as chemical, physical, biological or ergonomic.)

All workplaces should have a program to identify and measure the extent of environmental factors in the workplace as well as the exposure of employees, visitors, contractors or the general public.

If it is indicated by the results of a risk assessment, employees should be involved in a medical monitoring program to identify if there has been any negative impact on them. This monitoring may need to be ongoing or continuous to ensure that exposures are controlled to levels that is as low as reasonable achievable.


An industrial hygiene and monitoring program will:

Identify and measure employee environmental exposures Undertake risk assessments Undertake monitoring Develop action plans Maintain records

Special consideration should be given to the introduction and/or use of a new waste (AFR) before it is to be utilized at the plant. This must also take account of the requirements of the AFR Quality Manual and the AFR Health & OH&S Manual.TP

6PT

11.3 Workplace Monitoring

Issues that may be addressed as part of such monitoring include: • Toxic/hazardous material exposures • Atmospheric contamination • Noise • Air quality • Ventilation • Vibration

• Temperature • Flammable gases • Fire • Radiation • Ergonomics • Lighting/Illumination

TP

6PT For more details on this, check on ENVIRONET on HolSpace, or in HGRS/CIE/ETPS [email protected]

Always check Holcim documentation against Industrial Hygiene local regulatory/legal requirements and Monitoring


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Each site should undertake hazard identification and determine the whether or not monitoring is needed. If it is, the type of monitoring that is required must then be decided. It is important to note that consideration should also be given to any environmental exposures being caused to neighbors or other emission points in the area around the site.

11.4 Health Monitoring

There is a requirement for undertaking employee health monitoring when employees are exposed to particular types of risks. This may be specified by local legislation or found through risk assessments.

Depending upon the nature of work circumstances, employees may be exposed to hazards requiring ongoing health monitoring. Hazards requiring health-monitoring programs may include exposures to:

Noise Dust containing crystalline silica Asbestos Lead, other heavy metals or other specified chemicals Excessive stress resulting from the activities in the workplace

A health surveillance program may be undertaken when a risk assessment determines the level of risk of exposure requires surveillance or there is a legislative requirement to have a program.

Any such program should established with suitable medical input. Results should be communicated to workers and records of the length and type of exposure to each material maintained on a secure long-term basis. Local legislation should be checked but as a guide, keeping records of monitoring for at least 30 years should be considered. Health surveillance results should also form the basis for improving strategies for minimizing worker exposure to risks.


An audit will seek evidence of the existence and implementation of the items listed above. An audit will also review evidence of record keeping.

Based upon a site inspection, a comment may also be made on the adequacy of monitoring undertaken.

Always check Holcim documentation against Employee Communication local regulatory/legal requirements and Involvement


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12. EMPLOYEE COMMUNICATION AND INVOLVEMENT


Modern OH&S Management Systems call for consultation through mechanisms such as OH&S Committees. Consultation is important because it directly involves those persons performing tasks in the workplace and it is these people who often have the best understanding of the nature of the hazards involved in the work. Consultation should also involve discussing the incidents (and near hit/miss incidents) that have occurred, and the solutions that can be put in place for controlling such incidents.

Therefore, an open consultation process will ensure that such issues are raised, and will also provide the opportunity for comment and feedback on the effectiveness of OH&S management strategies.

OH&S is an integral part of the process of stakeholder involvement in the whole Corporate Social Responsibility (CSR) program at a Group company, and this block includes recognition of that requirement.


Consultation in the workplace can occur in a number of ways. The most common method is through an OH&S Committee. The requirements for the formation of an OH&S Committee and the composition of the OH&S Committee are often specified by local legislation.

In some workplaces, it may be more practicable to have several OH&S Committees/OH&S groups. For example, each shift or work area such as operations and maintenance may have its own local OH&S group whose aim is to deal with their OH&S issues at the local level.

As a recommended minimum, an OH&S Committee should contain both workforce and management representatives (majority workforce representatives) and meet at least four times per annum. Minutes of meetings must be kept and communicated to both management and the workforce.

Consultation must also address the problems associated with different languages at a given site.



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12.3 Details

OH&S Committee

The key factor to be considered when forming an OH&S Committee is to ensure that an appropriate balance is maintained between representation of all interest groups and areas in the workplace, and the overall size of the OH&S Committee.

To be effective OH&S Committee members must have received basic training in understanding the applicable legislation and its impacts, and basic training in OH&S Management practices.

As a minimum, training in the following areas is recommended:

Overview of applicable legislation. Hazard identification and risk assessment. Accident investigation. Undertaking reviews, inspections and audits

There are a number of other issues that need to be considered in order to have a well functioning OH&S Committee. These include:

Making workers aware of the name/s of their OH&S representatives. Planning for OH&S Committee meetings. Preparation of meeting agenda. Ensuring OH&S Committee meetings are kept to a reasonable length, eg.

about one and half-hours. Ensuring that all members of the OH&S Committee are allocated tasks and

given time to follow up those tasks outside normal committee time.

OH&S Communication

The presence of communication systems will ensure that persons at all levels within the organization receive appropriate OH&S information.

Publications

One important aspect of establishing communication systems is to identify critical OH&S publications and determine the distribution list for them. The implementation stage requires that key OH&S publications are identified and that a register of those publications is produced. Similarly the distribution for each publication must be identified and a corresponding register produced. Having both of these document registers is evidence that key OH&S publications are distributed to the appropriate personnel in a timely manner.



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Training

Good communication is not simply a matter of distributing documents to appropriate personnel. To be effective Managers and Supervisors must also initiate communication on a personal basis. Therefore, it is important that Managers and Supervisors have appropriate communication skills. An assessment should be made of communication skills currently possessed by Managers and Supervisors and, where appropriate, additional training is provided.

OH&S Promotion

One of the most important functions of the OH&S Committee will be to engage in OH&S promotion. There are a large number of ways that this outcome can be achieved and these should be the focus of OH&S Committee considerations.

The OH&S Committee should consider the type of material that is currently available in the organization and identify also sources of external promotional material, eg. ability to hire videos, purchase other forms of OH&S awareness material, organize and run poster campaigns, etc.

It is not the purpose in this document to prescribe any particular approach to OH&S promotion. The topic of OH&S promotion is important because it raises the awareness of all persons at a workplace regarding the importance of OH&S. The Committee needs to be aware of the type of internal resources that are currently available, and those that are available for use from outside the organization.

Language

It is recognized that at a number of Holcim sites different languages may be spoken. Therefore, it is important that appropriate OH&S information is conveyed to all personnel. This may require preparation of key information, such as policy and procedures, in multiple languages. The site should demonstrate that it has reviewed this issue and produced information in the appropriate manner and language.

Review of Consultative Arrangements

As with any process it is important that consultative arrangements are reviewed on an annual basis. The OH&S Committee in consultation with the site management should, on an annual basis, review its effectiveness, consider new initiatives, and consider also the need to change the membership of the OH&S Committee.


Evidence expected to be available in an audit is noted in section 12.3 above.

Always check Holcim documentation against Information and Reporting local regulatory/legal requirements


13. UINFORMATION AND REPORTING


If the other blocks of the pyramid are to operate effectively, it is essential that the OH&S handbook and/or any other source or reference documents are readily available, properly controlled and updated to reflect any changes and improvements made. Hence a document Management System is essential.

Those companies with existing ISO9000 and/or ISO14000 systems should have this substantially in place.

Reporting of OH&S performance results is fundamental, and this block describes the reports needed internally within the Group company, internally to Holcim group level, and externally as appropriate.

13.2 Details

General

Many sites may already have document Management Systems based upon the ISO9000 or ISO14000 series of Standards. If this is the case, then the systems will be able to be used. A document Management System is required:

To ensure that documents are able to be located. To ensure that key information relevant to the ongoing management of OH&S

within the organization can be controlled. To ensure that appropriate OH&S information is identified, collected, filed,

maintained and controlled. To ensure that appropriate records can be retrieved. To ensure that critical records are retained for an appropriate period of time. To ensure that documents undergo periodic review and, as appropriate, are

revised and approved by authorized persons. To ensure that current versions of relevant documents are readily available at

those locations where processes, which are essential to the effective functioning of the OH&S Management System, are undertaken.

To ensure that obsolete documents are removed and suitably archived for further reference.

As a minimum, document control procedures should apply to all procedures and documents that will be subject to review, and other critical documents that may be identified by the management team or OH&S coordinator.

It is essential that each new document be subject to document control.



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Document Management

The intent of this section of the OH&S Management System is to ensure that persons have access to correct and up-to-date documents and that changes to documentation are only made with the approval of authorized persons.

In order to effectively manage OH&S it is important that key documents are identified and controlled at all stages. Therefore, it is expected that there will be procedures to:

Identifying OH&S critical documentation Ensuring documents critical to OH&S carry an identification of their status,

authorization, date of issue and date of modification The intended distribution of a document is specified on the document OH&S documentation is effectively and systematically stored Obsolete documents are promptly removed from use A system exists for making and approving changes to documentation A system exists for communicating changes in documentation to those people

on whom the document impacts.

13.3 OH&S Manual

It is often considered to be effective to summarize the key documents from the OH&S Management System into an OH&S Manual. This should show how key aspects of the OH&S Management System would be addressed.

A Group company OH&S Manual is likely to include information on:

Policy and Targets Document control Recording, reporting and planning Organizational structures, roles and responsibilities Task identification, analysis and performance management Consultation and communication strategies Design and planning Risk management (Hazard identification, risk assessment, risk control

measures) Emergency plans Training Permit systems and permits Inspection, monitoring and testing Incident investigation and reporting Audit, inspection and review Purchasing Employee health & wellness

It may also be desirable to have a section in the OH&S Manual describing how the company addresses the requirements of each block in the Pyramid.



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13.4 Records

Procedures should be in place for identifying, collecting, filing, maintaining and controlling OH&S records.

Records are required to demonstrate the standard of OH&S management achieved and the effectiveness of the OH&S Management System.

Records may include:

Minutes of OH&S Committee meetings Incident investigation reports Maintenance records Air sampling records

13.5 Design Information

Adequate OH&S information is an essential prerequisite to effective hazard identification and risk management. Systems must be in place to ensure that information is current and available.

Suitable process design information should be available to permit operational personnel to safely manage the plant and associated equipment.

Appropriate process design information should be available to operations and maintenance personnel. This information may include:

A process flow diagram Piping and instrument diagrams Details of the process chemistry Details of inventories Details of upper and lower operational limits OH&S related consequences of deviations from normal operation Properties of materials used in the process Detailed equipment drawings and diagrams.

Mechanical and electrical design information should be available to assist operations and maintenance personnel, and may include the following:

Materials of construction Piping and instrument diagrams Electrical area classification drawings Electrical diagrams Design and basis of OH&S systems Design of ventilation systems Description of shutdown and interlock systems Lighting/illumination system



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The mechanical design should be consistent with the requirement of local Codes and Standards and reference should be made to these Codes and Standards. If design is not consistent with Standards, then the differences should be documented.

13.6 Reporting

In addition to document control and the provision and recording of information, it is essential that reporting of OH&S information occurs. The expectation is that all incidents will be recorded in an incident register at each site. Based upon this information, the following reports must be made.

SafetyAlert It is mandatory that a report be done on any accident causing death or permanent disability. This can be done via HolSpace: HTUhttps://web.holcim.com/sustdev/polstrat/csr_intro.htmUTH NOTE: This report can also be applied for any serious accident, near hit or other incident the Group company feels should be reported.

Every Group company must report their performance with respect to achieving the Targets annually. This is to be done by the OH&S coordinator completing the Annual Safety Statistics Report and submitting it to the responsible HGRS person.

Regular reporting within the Group company will be done via a report that is currently being developed as part of the Holcim Information Platform (HIP) project.


The audit will confirm that a document control process is in place and that

Critical documents have been identified Critical documents are controlled The document control process is functioning The Audit will review the adequacy of mechanical / electrical design information

as listed above. Mechanisms for the review and updating of mechanical design information will also be addressed.

The Audit will review the adequacy of process design information as listed above. Mechanisms for the review and updating of process design information will also be addressed.

The Audit will review whether reports are made on time as well as looking at their adequacy and accuracy.

Always check Holcim documentation against Safe Working Procedures local regulatory/legal requirements


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14. SAFE WORKING PROCEDURES



Although hazard identification and risk assessment encourages personnel to identify hazards in all aspects of work activities, including work tasks, this element within the OH&S Management System stresses the importance of detailed task analysis.

Hazards are introduced into the workplace because of the work tasks or activities that must be undertaken to produce products and services. Therefore, it is important that key tasks are analyzed in detail, that hazards are clearly identified and understood, that risk assessment occurs, and that safe working practices are developed to ensure that personnel are protected in undertaking these activities.

Worker Behavior Modification

This aspect builds upon task analysis and hazard identification and risk assessment, and further stresses the importance of managing workers in undertaking tasks, and provides an obligation for supervisors to undertake task observation and provide comment and feedback regarding performance. One example of Worker Behavior Modification is job observation. This is not aimed at introducing a form of policing in the workplace, but emphasizes that it is the responsibility of supervisors to observe and manage their workers, and to provide suitable feedback to those workers regarding their performance.

14.2 Task Analysis

Introduction

The OH&S risks experienced by an organization are related to the particular activities that occur within an organization. For example, the types of risks present in a mining environment are different to those present in an office environment. Therefore, it is important to be able to analyze tasks undertaken in order to identify hazards and effectively manage risks.

General Comments

The topic of task analysis is closely related to hazard identification and risk assessment, and is also related to Worker Behavior Modification - Refer to Appendix One where risk assessment and task analysis are discussed in greater detail.

Hazard identification and risk assessment provides a general methodology for identifying and managing OH&S issues. Task analysis is specifically focused on work tasks or work activities,

Always check Holcim documentation against Safe Working Procedures local regulatory/legal requirements


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whereas hazard identification is generally concerned with the physical layout and design of the workplace as well as specific tasks.

The objective of task analysis is

To analyze in detail particular tasks, To identify the hazards and risk involved at each stage of those tasks, and then To ensure that suitable controls are put in place or proper task redesign occurs.

Details

Work procedures or work instructions should be available for work activities that are not addressed by standard operating procedures. Standard operating procedures will deal with particular OH&S risks associated with plant operation. However, there are many other activities, which will not be addressed by operating procedures, and appropriate work practices should be documented for these.

It is essential that documented procedures are established where the absence of such procedures could adversely affect OH&S

Procedures should:

Conform with appropriate legislation and/or standards Be prepared using risk management techniques Be readily available Be understandable by employees, i.e. targeted at the correct level of

complexity and language Be monitored, reviewed and updated as necessary


An audit will seek evidence of standard work practices generated by task analysis / risk assessment. Other issues will include:

Records of task analysis Training of personnel in task analysis and risk assessment Communication of results of task analysis Mechanism for review of task analysis outputs Evidence of a structured behavior modification program

Always check Holcim documentation against Inspection and Testing local regulatory/legal requirements


15. UINSPECTION AND TESTING


Where audits look at OH&S system performance, development and improvement, this pyramid block deals with sophisticated inspection and testing techniques that are required to ensure the ongoing reliability and OH&S of plant and equipment.

The inspections discussed in this section are different to those discussed in Section 6. Employees with only low levels of training typically undertake the inspections discussed in Section 6. The inspections discussed herein generally require employees with better qualification and/or training to use sophisticated testing techniques.

Note that companies with existing maintenance cement systems (MAC) should have this block substantially in place.


This element requires that regular inspections and tests of critical plant and equipment be undertaken. A good program should be based upon:

Identification of OH&S-critical plant and equipment Identification of key OH&S functions, eg. trips, alarms Development and documentation of maintenance work procedures and

practices Training of maintenance employees in the application of the procedures Quality control procedures to ensure that maintenance materials and spare

equipment meet design requirements Procedures to ensure that maintenance employees and contractors are

qualified to undertake repairs Procedures to ensure that changes in technology and facilities are

appropriately reviewed.

Recommended intervals between the inspection and testing of equipment for OH&S issues should be specified.

15.3 Inspection Topics

Inspections may be applied to a range of different areas and activities within the workplace. These include the various topics listed in the table below.



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Each site should determine those topics for which inspections are required. This may require inspections in addition to those listed below.

Buildings and Roofs Lighting/Illumination

Electrical Portable Electrical Equipment

Earth Leakage Circuit Breakers Lifting Gear

Pressure vessels Fire fighting equipment

Emergency Stop Systems Security & Fencing

Indoor Air Quality Lightening Protection

Overhead Cranes/Gantries Fixed Lifting Points

Brief descriptions of topics that may receive routine inspections are listed below.

Buildings and Roofs

Regular inspection of buildings and roofs should be undertaken. The types of issues that may need to be considered are:

Structural integrity of building Quality of access and egress (exits) Quality of roof to prevent water entry Structural integrity of roof and OH&S associated with persons moving across

roofs Tie-down of roof and potential to lose roofing material in bad weather

conditions.

Lighting

Lighting should be inspected on a regular basis to identify deficiencies or changes in lighting levels. A baseline survey should be undertaken to record light intensities at strategic locations, and these should be compared with the requirements of relevant standards. Ongoing monitoring should review changes in light intensity.

Electrical Electrical equipment should be inspected and tested by a qualified electrical tradesperson. A register of electrical equipment should be developed and the testing program undertaken in accordance with the relevant local standards.

Portable Electrical Equipment Inspection There is a requirement that items of portable electrical equipment are inspected on a regular basis. The frequency of inspection depends on the nature of the equipment and its usage. An inventory of items of portable electrical equipment (and their location) should be developed. The register should also provide an indication of test interval and confirmation that testing has been undertaken.

Earth Leakage Circuit Breaker / Residual Current Device Inspection



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This inspection serves a similar purpose as that regarding portable electrical equipment. Each earth leakage circuit breaker (or residual current device) should be identified, including location and test intervals specified. The inspection can then be used to confirm that the appropriate testing has been undertaken. Generally, legislation or applicable Standards and Codes will specify testing requirements.

Lifting Gear Items of lifting gear should be identified and recorded in a Register, including their usual location. In addition, where appropriate, a Safe Working Load (SWL) should be marked. The SWLs applicable should be marked on shelving where lifting gear is stored. Regular testing of lifting gear is required. Qualified personnel should inspect lifting gear and make recommendations for repair or replacement as appropriate.

Pressure Vessels

The requirement for testing of pressure vessels and associated pipe work and valves is generally covered directly by legislation or through appropriate pressure vessel Codes. A register of pressure vessels should be developed, including specification of the type of equipment, location, design pressure limits and required testing interval.

Fire Fighting Equipment Inspection

The purpose of this inspection is to ensure that all items of fire fighting equipment present at a workplace are identified and documented. Items will include fire extinguishers, fire blankets, fire hoses, fire pumps and other supporting items of fire fighting equipment. The location of each item should be specified and the required test interval also included on the inspection form. The required test interval for different items of fire fighting equipment is generally specified by the appropriate Standard or Code. The inspection form enables the due date for the testing to be identified and confirmation that the test has actually been done can also be included on the form.

Emergency Stop Systems Emergency stop systems associated with plant and equipment should be identified and documented. A structured program for proof testing the effectiveness of these should be implemented, with results recorded.

Other Inspections Other areas of consideration for inspection may include:

Corrosion monitoring Structural integrity checks (especially tall structures) Condition monitoring of bearings and drives Monitoring of natural hazards Areas agreed with local authorities and/or insurance companies

15.4 Critical Parts and Equipment

Procedures should be in place to ensure that critical parts and equipment are tracked during the fabrication stage, and that appropriate checks and inspection procedures are established and implemented to ensure that the installation of equipment is consistent with both the design and the manufacturer’s specifications.



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An audit will seek evidence supporting the requirements noted above.

Always check Holcim documentation against Design Safety local regulatory/legal requirements


16. UDESIGN SAFETY


There are many ways of controlling risk in the workplace. However, the most effective way of is to ensure that, where practicable, hazards are eliminated at the design stage, or where this is not practicable, the mechanism for control of those hazards, is incorporated intrinsically into the design. This element of the OH&S Management Pyramid requires the establishment of processes to ensure that all new designs are reviewed and hazards identified prior to construction of the plant or implementation of the particular change. This element also requires that designs be based upon internationally recognized standards, and that a design should also take into account human factors as well as the practicalities of engineering design.

This also cover the requirements of "due diligence" in identifying the necessary safety equipment, documented procedures and training to be included in new projects, mergers and acquisitions, etc.


OH&S Management must start at the initial design and planning phase and be an integral part of all phases of a project or activity; ie. planning, design, procurement, construction, operation, maintenance, modification, decommissioning and rehabilitation.

This particular element requires that consideration of OH&S issues be included in the design phase for plant, equipment and operations. Furthermore, a design should reflect consideration of the hierarchy of risk controls (see Appendix One), and formal design review should be conducted at appropriate stages in the development a design.

It is important also that there is a clear linkage between the design and the documentation generated by the design process.

The following techniques may be applicable:

Broad-brush review Design review Design standards HAZOP/HAZAN study “As built” study Commissioning risk assessment Updating of drawings



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16.3 Details

Design Process

Consideration of OH&S issues must be included in the design phase for plant, equipment and operations. The most effective way of managing OH&S is to ensure that risk control features are incorporated into the design of system, plant or equipment. Therefore, it is important that:

Design responsibility is clearly defined Designers are suitably qualified and competent Designers are trained in risk management principles and practices Adequate resources are provided in relation to design Design is based upon relevant Standards Design seeks to address relevant issues within legislation. Risk management activities are included in the design process (at an early

stage in the process)

Design Issues

Plant is a general term used to define a range of equipment and machinery used in the workplace. Typically there are many phases of plant life and hazards may exist in any phase. Phases include:

Design Manufacture Storage Transportation Installation Commissioning Use Cleaning Setting and adjustment Inspection Maintenance, servicing and repair Modification and refurbishment Decommissioning Dismantling and demolition.

Key issues to consider in designing plant include:-

Legislation, standards, codes and guidelines that may be applicable Intended use and reasonably foreseeable misuse The nature of persons who will use the plant Designing to facilitate safe use Environmental conditions Erection and installation Maintenance



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Provision of information Provision of guarding Identification of energy sources Static electricity Fire and explosion Noise Vibration Radiation Lighting and illumination Release of substances Testing of plant and operational stability Control devices and operating controls

Hierarchy of Risk Controls

Design should reflect a consideration of the hierarchy of risk controls. OH&S risks can be managed in a number of ways. Effective design should consider each of the elements of the hierarchy and, where practicable, and incorporate the most important. The hierarchy is:

Elimination Substitution Separation/isolation/engineering Administration Personal protective equipment.


The audit will seek evidence of:

Hazard identification Occurrence of design reviews Documentation of design risk studies Evidence of attempts to eliminate the need for PPE Consideration of OH&S in design reviews Completion of recommendations It is important that there is a clear linkage between the design and the

documentation generated by the design process.

Always check Holcim documentation against Audit and System local regulatory/legal requirements Improvement


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17. AUDIT AND SYSTEM IMPROVEMENT


A system of internal audits is essential to monitor and review the performance of those elements that have been implemented, and ensure the ongoing functioning and improvement of an OH&S Management System. Internal audits do not have to be extensive site wide audits, but may be internal reviews conducted within a particular department or work group aimed at reviewing the implementation and performance of the OH&S Management System in a specific area. For example, in relation to high-risk work activities, it is recommended that internal audit reviews of the performance of the work permit system be undertaken on a regular basis.

Similarly, internal audits should be undertaken in relation to the effectiveness of incident investigation, risk assessment etc. Outputs from internal audits can then be linked to the corrective action system to ensure that improvements are locked into place.

Although internal audits provide feedback regarding the effectiveness of OH&S management performance, it is important that an external audit by an independent party be undertaken to provide a full and objective review of the performance of the OH&S Management System.

External audit also provides feedback to senior management to assist them in their ongoing system improvement and development.

17.2 General Comments – Internal Audit

An internal audit program should be developed with aim of reviewing key aspects of the OH&S Management System. An audit program should be prepared with a risk-based audit frequency. Auditors should be trained by means of a recognized internal auditor’s course. Audit recommendations should be followed-up through the corrective action request system.

17.3 General Comments – External Audit

Internal audit provides ongoing feedback regarding the effectiveness of OH&S management performance. External audit by an independent party should be undertaken to provide a full review of the performance of the OH&S Management System. The external audit will provide feedback to senior management assisting them in the process of planning the ongoing development and improvement of the OH&S management program.

Always check Holcim documentation against Audit and System local regulatory/legal requirements Improvement


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A suitably qualified auditor should undertake an external audit, and the audit results reported to site management. This person or persons (in a team) could be drawn from HGRS or other Holcim companies and do not have to necessarily be from a 3 P

rdP party (external) organization.

Any recommendations from the external audit should be part of the site’s OH&S Plan.



Internal audit program Trained internal auditors Linkage to Corrective Action System Review of all audit recommendations Reports, reviews and system improvement

Always check Holcim documentation against Occupational local regulatory/legal requirements Rehabilitation


18. UOCCUPATIONAL REHABILITATION


Corporate social responsibility (CSR) addresses how a Group company manages its societal obligations and expectations. One key issue from an OH&S viewpoint is occupational rehabilitation. Implementation of this block requires close cooperation between all relevant stakeholders.

18.2 Rehabilitation

Although the primary aim of any OH&S Management System is to prevent the occurrence of incidents and injury, it is important in those situations where an injury or illness has occurred, that assistance is provided to an employee to return them to meaningful work as soon as possible. Therefore an effective employee rehabilitation scheme should be in place to return employees to productive work as soon as possible after a lost time injury or after contracting work related disease.

The rehabilitation scheme should be in place consistent with the requirements of any local Workers’ Compensation/Insurance Legislation.

Key issues to consider in a structured rehabilitation program are:

Appointment of a person responsible for coordinating rehabilitation Preliminary liaison with company doctors and local doctors about the feasibility

of light duties programs Structured procedure to identify injured persons and ensure that an early

indication and understanding of the nature of their illness or injury is identified to the rehabilitation coordinator

Identification of potential light duties available in consultation with the injured person and the doctor

Implementation of a formal light duties program for an injured person Ongoing monitoring of the progress of an injured person Criteria and processes for deciding when a person is able to fully resume

duties.



An occupational rehabilitation program A properly trained coordinator Records showing the program is working

Always check Holcim documentation against Procurement local regulatory/legal requirements


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19. UPROCUREMENT


Just as design safety is an important way of ensuring that hazards are not brought unnecessarily into the workplace, so management of procurement activities is also a way of preventing new hazards from entering the workplace. Taken together, these two elements are a combined approach to ensure that emerging OH&S issues are identified and controlled.

This OH&S pyramid block sets guidelines for ensuring that the procurement process for any new plant and equipment, goods or contractor services, is subject to a review process in which hazards are identified, risks are assessed, and appropriate control measures planned and taken prior to introduction.


It is important that procedures are in place to ensure that the OH&S requirements of procured materials and equipment are specified and met. To ensure OH&S issues are included in the process that defines how suitable equipment and services are obtained, the appropriate OH&S coordinator shall be consulted during the specification process. Further, the OH&S coordinator shall be asked to assist by providing OH&S input during the making of procurement decisions, if necessary.

19.3 Details

Procurement and Suppliers

The most effective way of dealing with any OH&S problem is to eliminate or minimize the problem. One pro-active way of doing this is to ensure that controls are placed upon the procurement of items of plant, equipment, and substances. The types of issues that can be addressed by an effective procurement policy are:

Ensuring that only OH&S equipment that meets criteria set by the Group company is procured, eg. hard hats, safety glasses, boots, respiratory protection, gloves, fire-resistant clothing, etc to ANSI or OSHA standards.

Ensuring that when items of plant and equipment are procured, OH&S and particularly ergonomic considerations are taken into account prior to placing an order, and when the goods are received on site that appropriate documentation relating to any OH&S aspects is obtained; etc

An effective procurement system will also ensure that:

All the additional information needed to undertake maintenance work in a safe way is obtained



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Material Safety Data Sheets are obtained before the procurement or receipt of a chemical (risk assessments can be undertaken before the chemical is used)

Persons involved in procurement are always made aware of the OH&S issues that need to be taken into account in the procurement process

People in procurement and stores should be included on OH&S training schedules relating to hazard awareness. Prior to purchasing, an evaluation should be carried out to ensure that materials and equipment to be procured meet:

Legislative requirements Relevant Standards and Codes Hazardous chemicals requirements Any other OH&S performance criteria or specifications.

Procurement documents must clearly describe the goods and specify OH&S needs. A system should also be in place for verifying that the goods supplied meet them.

Contractors

Contractors are best controlled in terms of OH&S performance through the selection process. The process of selecting a suitable contractor should involve consideration of that contractor’s past OH&S performance and whether they can show evidence of having an effective OH&S Management System operating.

Control of contractors is important for various reasons.

The company may have a duty of care to contractors who are working for it. Where it exists, part of this duty of care involves informing the contractor of the

types of hazards to which they are likely to be exposed and having systems of supervision and control that ensure that the OH&S of the contractor’s personnel are protected.

It is also important to control contractors by preventing them undertaking tasks or working in areas where it is considered that it is unacceptable for them to work. There may be, for example, high-risk areas in a plant where very specific training is required in order to work there. Part of the control placed on a contractor would be non-entry to certain areas without having received specific induction training.

So despite the contractual arrangements that may exist, OH&S for contractors should be addressed in the same way as that for an employee.


An audit is expected to address the details noted in section 18.3, including:

Procedures to ensure that OH&S requirements of procured materials and equipment are met.

Evidence of consideration of OH&S requirements in the procurement of materials and equipment.



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A selection process for contractors based in part upon their ability to meet clearly defined OH&S requirements.

Evidence of consideration of OH&S requirements in the procurement of services.

Always check Holcim documentation against Management of Changes local regulatory/legal requirements


20. UMANAGEMENT OF CHANGES


Management of changes builds upon the elements of Design OH&S and Hazard Identification and Risk Assessment. The inclusion of this element is recognition of the fact that circumstances in the workplace will change over time, and that changes may introduce new hazards or alter the effectiveness of existing OH&S Management Systems and controls.

Therefore, a risk-based Management of Changes procedure is required to identify hazards associated with proposed changes and ensure that those hazards are effectively controlled prior to the implementation of the change.

This block establishes a risk-based procedure to check for actual or proposed changes, examine the hazards associated with them, and ensure:-

Changes are documented and recorded as required in the Information & Reporting Pyramid block

Hazards are effectively controlled prior to the implementation of any changes as required in the Design Safety element


An organization and its facilities may be subject to continual change to increase efficiency, improve operability and safety and accommodate innovation and improvement. These changes may introduce new hazards or alter existing risks. Therefore, appropriate systems should be in place to manage changes.

The purpose of this element is to ensure that when a change is made to an organization's activities, products or services, the associated changes to OH&S aspects and impacts are identified at, or preferably before, the time at which the change is made. All of these factors are considered within the context of determining whether the change requires a change in OH&S objectives and targets and an overall change in the OH&S Management Program.

The Management of Changes procedure addresses both physical change and also changes in policies, standards, and work instructions. It is a critical procedure because it is through the Management of Changes procedure that a site will develop amended policies and standards and determine their impact on operations. This is a key aspect in the implementation of the OH&S Management System and provides the bridge between the global policies and standards and the specific instructions that provide guidance to workers at lower levels.

Always check Holcim documentation against Management of Changes local regulatory/legal requirements


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20.3 Details

Many OH&S problems emerge because changes (to technology, plant, equipment or systems) are made which destroy or diminish the integrity of plant and equipment or existing OH&S systems. Therefore, it is necessary that:

Changes are identified Changes are analyzed and assessed for OH&S implications Suitable risk controls are implemented Changes are communicated to affected personnel Changes are made to associated documentation Changes are authorized A sample Management of Changes form is included in Appendix Two.


An Audit will seek evidence of:

A management of changes procedure Implementation of that procedure Completion of all aspects of the procedure Identification of changes Documenting changes Use of a management of changes form

Always check Holcim documentation against Health and local regulatory/legal requirements Wellness Issues


21. UHEALTH AND WELLNESS ISSUES


Effective management of OH&S is not confined solely to the workplace and workplace activities. Many issues may impact on the ability of a worker to perform tasks and functions in a safe and efficient manner. This element of the pyramid addresses broader health and wellness issues, some of which are directly related to workplace activities and others may be related to business activities outside one’s normal work.

This block is a key element within the corporate social responsibility program, and recognizes Holcim’s commitment to addressing issues beyond the bounds of a particular work site.

21.2 Employee Assistance Program

Each Group company should have in place an Employee Assistance Program, consistent with the requirements of local customs and legislation. Such a program could be developed in consultation with the OH&S Committee and external experts (doctors etc) and be aimed at addressing issues such as substance abuse, stress, post-trauma counseling, etc

21.3 Other Issues

As a minimum, each site should demonstrate that risks associated with the following have been assessed for their workforce:

Precautions for overseas travelers (eg. vaccinations) Management of endemic diseases (eg. malaria, cholera, etc) Stress management and counseling Drug and alcohol awareness (substance abuse) Communicable diseases (eg. HIV/AIDS) Quality of life (eg. balancing time at work to time for recreation/with family) Other general health and lifestyle issues (eg. stop smoking, diet, fitness, etc)

Where the risk assessment finds a level of risk where action is necessary, appropriate systems for managing the risk(s) should be introduced into the workplace.


An Audit will seek evidence that other issues decided as relevant to the employees in the Group company are being dealt with appropriately.



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APPENDIX ONE: RISK MANAGEMENT METHODOLOGY



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Introduction

The first phase of the risk management process is hazard identification.

The purpose of hazard identification is to construct a comprehensive list of hazards associated with any particular asset, item of plant, work practice, work area etc. The fact that many hazards may exist is not necessarily an indication that there are significant levels of risk because the hazards may be well controlled.

Therefore, it is always important to maintain a clear distinction between the process of identifying hazards, and subsequently analyzing the risk associated with them.

Definition of Hazard

A hazard is typically defined as "anything that has the potential for harm or a potentially damaging energy source".

The key word in the definition of hazard is the word potential. By defining a hazard as a potential for harm, one is not stating that the harm will actually occur. Therefore, the notion of hazard is a notion of possible harm and possible future consequences. In hazard identification, one is attempting, through a range of techniques, to identify what could happen and the types of energies present in a workplace that could cause injury, illness, or property damage.

Sources of Hazards

As noted above, hazards can be identified as different types of damaging energies. Examples of damaging energies include:

Thermal Electrical Chemical Radiation Biological Vibration Noise Gravity Kinetic Mechanical Potential

In general terms, hazards can be associated with three categories.

People The workplace layout and general work environment. Work practices



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1. People

There are potentially damaging energies associated with people. These are damaging energies associated with physical/muscular exertion, activities such as:

Lifting Striking an object Being struck by another object Pushing/pulling/restraining Repetitive strain Postural strain

Some risks may arise because of mismatches between people, the tasks that they must perform, and the equipment that they must use. Care must be taken when assessing people as new employees may be at greater risk performing a task than older employees with years of experience behind them. On the other hand younger employees may be more agile and physically fitter than older employees.

2. Workplace Layout and General Environment

Many different hazards exist in the design and layout of the workplace, and the general work environment. Examples of damaging energies include:

Thermal Machinery: mobile, fixed Chemical Electrical Noise

The hazards associated with this category are those that arise from the type of plant and equipment that are in use, the general design and layout of the workplace and the broader work environment in which the workplace is located. Usually these types of hazards are the easiest to identify, and often (unfortunately) hazard identification does not proceed beyond this stage.

3. Work Practices

Many hazards arise through work practices, and many workers are exposed to hazards as that. For example, a chemical hazard may be present in the form of chemicals stored in drums. However the way that workers are exposed to the chemical will depend upon the work practices that are adopted. Particular work practices may also affect the nature of the hazard; eg., a chemical normally in liquid form may be sprayed in an airborne state where it can be easily inhaled.



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Identification of hazards in work processes is probably the most difficult part of hazard identification, and therefore such hazards are often overlooked. Because work practices may change on a daily basis, the nature of hazards and worker exposures to those hazards may also change. Safe work practices are one way of addressing such hazards. For new or unusual tasks, hazard identification and risk assessment should be undertaken before the commencement of the task. The process management approach will assist to clarify work practices and associated OH&S issues.

Techniques for Hazard Identification

Summary

A range of techniques exists to assist in hazard identification. They include:

Job Safety Analysis Review of incident data Consultation with workers Brainstorming Use of checklists Observation Flowcharting Experts Each of these techniques is discussed in more detail below

Job Safety Analysis Job Safety Analysis reports promote safe work practices and safe systems of work. They help sites ensure employees’ safety and health by documenting work procedures for each task that each employee has to carry out and listing the associated hazards, risks and control measures. They provide employees with information and instruction required under safety & health laws and act as a sort of standardized work procedure. Review of Historical Data Reviewing historical data is an effective way of identifying those hazards that have caused injuries or property damage in the past and the Pareto Chart is very effective in presenting historical data in a way that emphasizes the key problem areas. Because the hazards displayed in a Pareto Chart have been involved in past incidents, it can reasonably be expected that controls for those risks would have been developed and implemented in relation to those hazards as related to those incidents. However, reviewing historical data will not enable a focus to be made on the type of hazards that may be present in other circumstances where controls may not exist. Consultation with Workers Consultation with workers permits those persons who are exposed to the hazards on a daily basis, and who have to deal with those hazards, to provide relevant information. It is always workers who know ‘what really happens’, rather than what is dictated by a



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particular policy or procedure. Workers also may be aware of incidents that have occurred in the past that have not been formally documented or reported. Brainstorming Brainstorming is a technique that is used to tap the creative thinking of a group of people. Consultation with workers may occur via brainstorming, but it may also involve other people; eg. OH&S experts, managers, etc Use of Checklists Checklists can be used in hazard identification to focus attention on particular hazards and collect relevant data. It is often convenient to construct checklists based upon the results of previous hazard identification activities or upon a review of historical data. The main advantage of checklists is that they are easy to use and are good at focusing attention on particular issues. Their major disadvantage is that by focusing on some particular hazards, other significant hazards may be ignored. Observation Direct observation is also an effective technique for identifying hazards. Observation may be undertaken in conjunction with the use of a checklist or other suitable recording device, eg. video camera. Observation may be used for studying work practices and identifying hazards associated with workplace layout/design and environment, ergonomics and patterns of flow, etc. Flowcharting It has already been noted that it is essential that hazard identification addresses hazards associated with work practices. Although this can be partly achieved through observation, flowcharting is a systematic technique that can be used to break a work practice into its component parts and allow identification of hazards at each step of a work practice. Using a flowchart in this manner can provide the basis for HAZOP/HAZAN studies as well as the subsequent development of safe work practices for each of the steps. Selection of Hazard Identification Techniques As noted above a range of techniques are available for undertaking hazard analysis. For example, if the focus is on work practices then techniques such as observation and flowcharting should be used. If, however, the aim is to identify hazards associated with workplace layout, then observation, checklists, and consultation may be more effective. Relevant historical data should be reviewed on all occasions. It is essential in the longer term that all types of hazard (different damaging energies) and all sources are addressed (people, practices, layout, and environment). In addition, the human factor (people are fallible) should also be addressed by having a system to make sure that the person with the right abilities, skills and training required for the position is actually filling it (this is a normal function of Human Resources).

Definition of Risk

Risk is the chance of something happening that will have an impact on objectives or targets. It is measured in terms of likelihood and consequence and may arise from an event, an action or from a lack of action.



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Likelihood is used as a qualitative description of statistical probability and frequency - it is often given in % terms. Significance is the outcome of an event or situation, expressed qualitatively or quantitatively. This could be negative (ie. a loss or worsening in situation); or positive (ie. a gain or improvement) The key issue to address in managing OH&S is the management of risk. There will inevitably be many hazards with the potential to cause an impact on objectives existing in a workplace. The key issue to consider is what is the level of risk is actually posed by these hazards. A good OH&S Management System normally attempts to eliminate some hazards and minimize the risk associated with others.

Risk Analysis and Assessment

Simple Risk Assessment In some situations, risk assessment is simple. For example, the problem and solution may be obvious and the solution may be easily found and implemented, eg. identifying and removing a trip hazard.

Complex Risk Assessment In other situations, undertaking risk assessment may be extremely complex, and may require various scientific measurements to be made. Generally, where the nature of the risk is such that the impact develops over a period of time, eg. exposure to chemicals, radiation, noise, then a more complex assessment is required. Such assessments are generally topic-specific and are not addressed in detail in this Handbook.

Risk Calculation Matrix

One simple but extremely useful methodology for risk analysis is based upon a five by five matrix.



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Consequence can be rated from a ranking of 1 (considered minor) to 5 (catastrophic), as shown in the table below.

Consequence

RANKING DESCRIPTION OF CLASSIFICATION 1 Illness, injury requiring first-aid or no treatment 2 Medical (doctor) treatment 3 Single serious (hospitalization) injury 4 Single death or major permanent disablement 5 Multiple deaths

Likelihood ranks from A (considered certain) to E (improbable) with a range of values in between as shown below. IMPORTANT: Typically the likelihood scale is logarithmic with each succeeding level being a factor of ten times more or less likely than the adjacent level.

Likelihood

RANKING DESCRIPTION OF CLASSIFICATION A Expected many times per year B Expected about once per year C Expected between once every year and once every 10 years D Expected between once every 10 years and once every 100 years

(possibly once or twice in the life of a site/plant) E Expected between once every 100 years and once every 1000

years (not expected to occur in the life of a site/plant)

Once a risk has been assessed according to the classification descriptions above, a 5 X 5 risk analysis matrix is then possible in which consequence and likelihood are combined to give a measure or ranking of risk. Risks are ranked from low (possibly acceptable) to extreme. The purpose of this risk analysis matrix is to provide a prioritization of risks and therefore the basis for developing risk management plans and allocating valuable risk management resources.

Consequence 1 2 3 4 5 Likelihood A H H E E E B M H H E E C L M H E E D L L M H E E L L M H H

E = Extreme risk - immediate top management action required. H = High risk - senior management attention required quickly M = Moderate risk - management responsibility must be specified L = Low risk - manage by routine procedures; eg. Work Instructions/SWPs So, to simply assess a level of risk, the process is: 1. Identify a hazard or incident scenario



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2. Identify existing risk controls 3. Identify the consequences and likelihood for a given scenario (this may be done by

assuming the existing controls to be in place, or by calculating the risk in the absence of controls).

4. Assign Likelihood and Consequence rankings from the tables above. 5. Combine them in the matrix to give a measure of risk. 6. Implementing the appropriate actions based upon the risk ranking

Risk Control in OH&S Introduction Hazard identification is the process to identify potential sources of harm or sources of potentially damaging energy. The fact that a hazard may exist in the workplace does not necessarily mean that it will cause harm to a person or to property. It may be that the risk associated with that hazard is adequately controlled by some existing risk control mechanism. Therefore in undertaking risk assessment it was noted that it is important to determine and identify existing risk controls before trying to determine the consequences and likelihood relating to a particular hazard. When this is done, and consequences and likelihood are combined, a measure of risk is obtained and this may be compared against criteria to determine whether the risk is or is not acceptable. If it is considered that the risk is acceptable, then, no additional action will be required other than on-going monitoring and review to ensure that the level of risk remains acceptable. If however risk analysis and risk assessment indicates that the level of risk is unacceptably high, then action needs to be taken. With regard to OH&S risks, this is referred to as risk control. The purpose of risk control is to modify either consequences or likelihood (or preferably both), such that the level of risk is reduced to an acceptable or tolerable level. In this section, general strategies that can be used to control risk are discussed.



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Risk Control Strategies

It is considered that there is a hierarchy of risk control options. By calling them a hierarchy, it indicates that there are a number of risk control options but that some are better or more preferable than others. The hierarchy of controls is:

Note that any control measure adopted must achieve the following criteria:

Adequately control exposure to the risk; Not create another hazard; and allow workers to do their work without undue discomfort or distress.

Each of the "hierarchy of risk controls" is now discussed in more detail below. Elimination The best way to control a hazard in the workplace is to eliminate it, i.e. if the hazard is eliminated then all the risk associated with that hazard is also eliminated and there are no further problems relating to the control of that particular hazard. Elimination of a hazard involves some form of redesign of a workplace or a process. In many situations this may be quite simple and may not necessarily involve a lot of time or expense. Hazard elimination is the most preferable risk control option because it comprehensively changes the nature of the workplace and protects workers by ensuring that the hazard is no longer present. It does not require or rely upon the use of mechanical equipment, the use of procedures, the use of PPE or the cooperation/knowledge of particular persons.

ELIMINATION

SUBSTITUTION

ENGINEERING

ADMINISTRATIVE

PERSONAL PROTECTIVE EQUIPMENT



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Substitution Although hazard elimination is desirable often it is not possible to eliminate a hazard. In fact, although some hazards may be able to be eliminated, the vast majority will continue to be present at the workplace. The fact that work is being undertaken, that equipment is being used, that chemicals are being used, that persons are involved in various types of manual activity, means that there will be a whole range of hazards present. Ultimately the only way to eliminate such hazards would be to discontinue the particular work activity. Once a workplace is established a large number of hazards will also be introduced and the vast majority of those hazards will persist for the lifetime of the workplace. The strategy of substitution requires substituting something that is less hazardous for something that is more hazardous. For example, replacing a noisy piece of equipment with a new item of equipment that is less noisy is an example of substitution. There is a noise hazard present in both circumstances. However, with less noisy equipment the hazard is significantly reduced because substitution has occurred. Another example of substitution is to use a chemical in a pellet form rather than in a powder form. Solids that are present as powders may become airborne and so may be inhaled by persons. On the other hand, a chemical that is present in a pellet form will less easily become airborne, and therefore the level of risk in that situation will be lower. Substitution therefore is a highly desirable risk control strategy. Elimination and to a lesser extent substitution are the preferred risk control strategies. The main reason why they are preferred is that they make a fundamental change to the nature of the workplace. As noted above, elimination comprehensively removes a hazard from the workplace. Substitution on the other hand reduces the degree or severity of a hazard. Both of these strategies are independent of other aspects of the workplace, i.e. they do not require the continuous functioning of particular items of plant, they do not require people to understand and use procedures and they do not require the use of particular items of PPE. When considering risk control it is important that the possibility of elimination or substitution is seriously considered as the first step. In many situations, these may not be possible or realistic risk control strategies. However it is necessary that they are considered and, if possible, actions taken in this regard. Elimination and substitution are often not the quickest-to-implement control options that can be chosen. It is recognized that sometimes it may take a considerable period to apply either of these risk control strategies. To eliminate a hazard, for example, may require the redesign of a workplace and changing of work processes. In many situations, this may require significant capital expenditure that will need to go through various approval stages. In addition, associated design work will also need to be undertaken. However, Elimination and substitution should always be considered and if possible implemented.



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Engineering Controls The next control in the hierarchy of control options is engineering controls. Types of Engineering controls are varied and examples are: Ventilation systems Separation of workers and hazards Isolation

Fundamentally, an engineering control is one that changes or affects the way a hazard and the worker may come into contact. Therefore, an engineering control places a barrier between a worker and the hazard. The worker is unable to come in contact with the energy source that constitutes the hazard. It should be noted that an engineering control does not make any fundamental change to the nature of the hazard. For example, use of a ventilation system in an area where hazardous fumes are present is an example of an engineering control. The hazard in this situation is a chemical hazard associated with the chemical composition of the particular dust or fume. Installation of a ventilation system will protect workers by removing the fumes from the work area and venting them into some other safe location. However, the ventilation system does not prevent the fumes from being generated and therefore the nature of the hazard is unaltered. What is altered is how the hazard and the worker can come into contact. If an engineering control fails or ceases to be present then a worker will be exposed to the original hazard or energy source. Another example of an engineering control is a guard that prevents a worker coming into contact with moving mechanical equipment. A guard is very effective while it is in place. However on many occasions guards are removed during maintenance work and are not reinstalled. If this does occur, then the hazard associated with the mechanical equipment is uncontrolled and the worker is exposed to a higher level of risk. Therefore, although engineering controls are very effective in the areas in which they are applied, engineering controls also require on-going monitoring, observation and in some situations maintenance to ensure that control remains in place and continues to perform its desired function. Administrative Controls The fourth type of control in the hierarchy of risk controls is administrative controls. Administrative controls refer to those ways in which risks are controlled by procedures or particular rules and regulations. Regulatory authorities, eg. Acts of Parliament and associated Regulations, may define administrative controls. Administrative controls may also be present in particular Standards and Codes that may be applied in a given industry. For example, a Standard for Safe Working in a Confined Space is an administrative control because it defines a series of requirements that must be in place before a person can work in a confined space. Many administrative controls are generated at a particular worksite in response to the risks associated with a certain type of hazard. Therefore, the requirement to follow certain safe working practices when doing a job is a particular form of an administrative control. A well-developed administrative control will be effective in the control of risk. However for an administrative control to be effective it is necessary that the persons to whom the particular administrative control applies are aware of the control, understand the need for the control and have the skill, knowledge and experience to make control work.



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There are numerous instances where administrative controls have existed but for various reasons persons do not follow the requirements of a particular administrative control and as a result suffer an injury. Administrative controls therefore require the cooperation and involvement of workers at a worksite and this introduces a range of additional issues. Aspects relating to human factors in risk assessment are discussed in a following section. Role of Task Analysis The risk assessment process involves identifying hazards, assessing risk and if the risk is unacceptably high putting in place risk control strategies. Often the major focus of hazard identification is the physical layout and design of the workplace, i.e. hazards are identified in terms of storage of chemicals or other forms of equipment, access, and other states of affairs that exist in the workplace. One of the major sources of hazards in a workplace, however, is within work practices; i.e. workers are exposed to hazards because of the types of jobs that they do and the way they do those jobs. Therefore task analysis is an essential aspect of any OH&S Management System and incorporates the previously discussed aspects of risk assessment. The outputs of task analysis are safe working practices. Strategy: The key strategy involved in task analysis is to document particular work tasks. Until a work task is formally documented, it is difficult to identify the types of hazards to which a worker is exposed and the nature of the risk associated with those hazards. Documentation must be developed in consultation with the involved workers. It is important in documenting work practices and work tasks that workers are comfortable to discuss the actual practices that they use and adopt rather than those that might be specified in any existing procedure or be assumed by management to be undertaken. The quality of task analysis and the development of subsequent safe working procedures will depend upon the accuracy with which a particular task is documented.

Risk Assessment: After a task has been documented, it is possible to undertake a risk assessment of the risks associated with the task. This is done by reviewing the task and asking at each stage of the task what are the hazards associated with that task or what are the sort of incidents that could occur leading either to personal injury or property damage.



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Based on these identified hazards or incident scenarios it is then possible to estimate consequences and likelihood and determine risk. Once risk is determined it is then possible to decide whether the risk is unacceptably high and, if that is the case, risk controls must be applied. Task analysis as with any other risk assessment strategy provides the opportunity of using a range of different risk control solutions. Initially in task analysis one should attempt to determine whether or not fundamental changes can be made to the design of the workplace that significantly lowers the level of risk. If this is not the case then risk needs to be controlled through the task itself and therefore it is necessary to amend the task such that the risk is reduced to a low level. This may involve changing how a particular task is performed in terms of the steps that are involved in it or the type of equipment that might be required. After the risk controls have been added to the task and the new task has been documented the risk assessment process should be repeated again to confirm that the risk has been reduced to an acceptably low level. On this basis, it is then possible to confirm that the modified task meets all the requirements of risk minimization and the new task is generally referred to as a safe working procedure. Personal Protective Equipment The last risk control strategy is the use of personal protective equipment (PPE). This is a way of controlling risk by selecting a particular type of equipment that will provide a barrier between the hazard and the worker. For example, the purpose of a hard hat is to provide a barrier between a falling object and a worker's head at the exterior of the hat. Therefore, PPE does not in any way alter the nature of the hazards that exist at a workplace. PPE can be a very effective means of risk control providing hazard identification, risk analysis, and risk assessments have been undertaken in a comprehensive manner. PPE will only be effective if the nature of the risk is clearly understood and the correct type of PPE is identified. This may not always be a simple matter; eg. in handling solvents there are many different types of solvents and typically, one would use gloves to provide protection to the hands. However different solvents interact with different glove materials in a range of ways, and a pair of gloves that may provide excellent protection against one type of solvent may provide very poor protection against another. For PPE to continue to be effective in controlling a hazard, it is essential that the equipment is properly maintained, or in a situation where maintenance is not appropriate, that it is replaced when it no longer is able to do the job. In many circumstances, this may require an extensive program of monitoring the quality and the performance of PPE. To be effective, PPE also requires the cooperation of the person who is required to wear it. Therefore if PPE is chosen as a risk control option it is essential that the persons who are required to wear the equipment are given appropriate training.



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This training should include: 1. An understanding of the nature of the hazard and the degree of risk

2. The reason why PPE is required

3. How to use the equipment properly

4. Maintaining the equipment Understanding and recognizing when the equipment needs to be replaced. Use of PPE is the least desirable of all risk control options. As noted above, PPE merely provides a barrier to the hazard at the worker and therefore is a last line of defense. Selection of Risk Control Options The discussion above has indicated that there is a hierarchy of risk control options that can be used for the control of risk. The type of control that will be used in any set of circumstances will depend upon the nature of the hazard, the nature of the workplace and the availability and suitability of different types of controls; eg. in one situation redesign of the workplace to eliminate a hazard may be possible and in another situation, it may only be possible to have PPE provided. In undertaking risk assessments it must always be recognized that the whole hierarchy of risk controls are available and all must be considered. In many situations, PPE is chosen as a risk control option because it is the simplest and most convenient risk control to use. For example, it may merely be a matter of going to the warehouse and obtaining a respirator, a pair of gloves, a pair of goggles etc. PPE is often a very good temporary risk control, i.e. it can be instituted quickly and will be effective in the short term. However even if PPE is chosen in the short term, a comprehensive risk assessment will consider other possible risk controls and decide whether it may be preferable to introduce a different risk control in the future. For example, in a work area where fume was present, provision of respirators might be a suitable short-term risk control. It may be decided that a more effective risk control would be to install a ventilation system to ensure that the fume is removed from the work area and so eliminating the need for use of a respirator. PPE may also appear to be a cheap risk control option. This may not necessarily be the case! Use of PPE to control the risk will require on-going purchases of the protective equipment and it may be that some larger expenditure on an item that makes a more fundamental change to the nature of the workplace will be a more effective means of risk control. Verification of Effectiveness of Risk Control Measure(s) The risk assessment process discussed above has involved identification of hazards, analysis of consequences and likelihood, generation or measurement of a level of risk, evaluation of the level of risk and then decisions regarding the need for risk control. It is essential however if risk assessment is to be effective that risk controls are evaluated.



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Once a risk control has been identified, the risk analysis and risk assessment process needs to be undertaken again to confirm that that control is adequate. For example, a risk control may affect consequences, it may affect likelihood, or it may affect both. Therefore, it is necessary to undertake an analysis and assessment again considering the situation where risk control is in place and determine the level of risk. The level of risk remaining after a risk control has been put in place is called residual risk. The purpose in choosing a risk control is to ensure that the level of residual risk is as low as is practicable and/or acceptable. It may be that when a particular risk control is postulated and the assessment is undertaken again the analysis may show that the risk is still unacceptably high. In such a situation, it would be necessary to develop either a new risk control strategy or add another level of risk control to that already suggested. Once this is done, the analysis and assessment process should be repeated again to demonstrate and ensure that the level of risk is acceptably low. It is often this aspect of verification of the suitability of risk control that is omitted from the process of risk management. It cannot be stressed highly enough that it is necessary that each time a risk is identified as requiring risk control, that it is ensured that the control is evaluated to determine whether it will adequately control the risk. Role of Monitoring It is necessary to confirm that a particular risk control is achieving the desired level of risk reduction after being put in place, ie: Ongoing monitoring of risks and associated risk controls needs to be undertaken. For example, a risk might be identified, analyzed, assessed, and found to be unacceptably high. A risk control is then chosen, verified, and put into place. It would be expected that some months after the control has been put into place, a review of the adequacy and effectiveness of that control should be made. This is to ensure that it is achieving its role in the workplace as expected by those who undertook the risk assessment.



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APPENDIX TWO: MANAGEMENT OF CHANGES FORM



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MANAGEMENT OF CHANGES ASSESSMENT FORM7

Plant: Title: Reg. No: Underline those factors that have been changed by the proposal

Process Conditions temperature pressure flow level composition toxicity flash point reaction conditions Operating Methods start-up routine operation shutdown preparation for maintenance abnormal operation emergency operation layout and position of controls and instruments Engineering Methods trip and alarm testing maintenance procedures inspection portable equipment control logic OH&S Equipment fire-fighting and detection systems means of escape OH&S equipment for personnel Environmental Conditions liquid effluent solid effluent gaseous effluent noise

Engineering hardware and design line diagram wiring diagram plant layout design pressure design temperature materials of construction loads on, or strength of foundations, structures, vessels bellows/supports/bellows temporary or permanent bellows/supports/bellows valves, slip-plates restriction plates, filters instrumentation and control systems trip and alarms static electricity lightning protection radioactivity rate of conversation rate of erosion isolation for maintenance mechanical-electrical fire protection of cables handrail ladders platforms walkways tripping hazards access for operation, maintenance vehicles, plant, fire fighting underground/overhead: services equipment

7 Contact the Group OH&S coordinator at Holcim (US) for more detail on this form.



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Within the categories listed below does the proposal:

Yes or no

What problems are created effecting plant or personnel OH&S? Recommend action?

Signed and dated

Relief and Blow Down (1) Introduce or alter any potential causes of over/under pressuring the system or part of it? (2) Introduce or alter any potential causes of higher or lower temperature in the system or part of it ? (3) Introduce a risk of creating a vacuum in the system or part of it? (4) In any way affect equipment already installed for the pressure of preventing or minimizing over or under pressure Area Classification (5) Introduce or alter the location of potential leak of flammable materials? (6) Alter the chemical composition or the physical properties of the process material?

(7)Introduce new or alter existing electrical equipment?

OH&S Equipment (8) Require the provision of additional OH&S equipment? (9) Affect existing OH&S equipment? Operation and Design (10) Introduce new or alter existing hardware? (11) Require consideration of the relevant Codes of Practice and Specification ? (12) Affect the process or equipment upstream or downstream of the change ? (13)Affect safe access for personnel and equipment, safe places of work and safe layout? (14) Require revision of equipment inspection frequencies? (15) Affect any existing trip or alarm system or require additional trip or alarm protection? (16)Affect the reaction stability or controllability of the process? (17) Affect existing operation or maintenance procedures or require new procedures? (18) Alter the composition of, or means of disposal or effluent? (19) Alter noise levels?

OH&S assessor ....................... Date ........

Checked by ................................. Plant Manager Checked by ................................. Engineer



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APPENDIX THREE: EXAMPLE EMERGENCY PLAN



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Example: Emergency Management and Local Disaster Recovery Plan For … All Group Company Business Units and/or Sites This document must be kept next to the reception telephone or the central communication control point.



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Emergency Procedures and Disaster Recovery Plan A siren sounding continuously means to make your way quickly and calmly to the evacuation area.

Site Information - Plant/Site Name: _______________________________________

Location/Address: _____________________________________

Notification:

Person Phone

Emergency Co-coordinator _________________________________________

Plant/Site Manager _________________________________________

Business Unit Manager _________________________________________

Fire Warden _________________________________________

First Aid _________________________________________

Plant Communication Position Call Number/Sign

Telephone/s _________________________________________

_________________________________________

_________________________________________

CB _________________________________________

Two-way radio/s _________________________________________

Other _________________________________________

Evacuation Assembly Areas

1. _______________________________________________________________________

2. _______________________________________________________________________

3. _______________________________________________________________________



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Notification Procedures

Should one of the persons listed not be on site - notification is to be to the next level.

1. Plant should notify whichever of the following they are first able to contact -

a) Emergency Co-coordinator.

b) Plant/Site Manager.

c) Area Supervisor.

2. It is the responsibility of Managers, Supervisors, Emergency Co-coordinator to:

a) Ensure the safety of all on site.

b) Co-ordinate response.

c) Notify emergency services (If this has not already been done).

3. It is the responsibility of all personnel on site to comply with all emergency plan requirements.

4. Managers and Site Supervisors must notify external organizations as required.

5. The Business Unit Manager should contact The Divisional General Manager.

NOTE: Only the Business Unit Manager or equivalent can talk to/liaise with media.



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Emergency Communication Requirements Fill in names & phone numbers/relevant details - The flow of information is as shown: Etc

Site Manager/Supervisor Emergency Services

Phone ???

Internal Requirements

Activate

Site OH&S Officer

Gov’t Health & Safety Dept.

Gov’t Environment Dept.

Gov’t Mines Dept.

Division/Departmental General Mgr. Managing Director

Business Unit Mgr.

Police Siren

Fire Brigade First Aid

Ambulance Extinguishers

Other Emergency Services Water Truck

Corporate Crisis Management Team

Emergency Coordinator



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An Emergency Response Procedure

.

UGeneral Emergency ProceduresU

If you detect an emergency situation, NEVER place yourself in danger - Don’t panic!

Notify site management immediately.

Note as many details as you possibly can.

They will be necessary when calling emergency services, and also in the investigation that

must follow any accident or incident whether it is injury producing or not.

Call for emergency services.

Even when a situation looks minor it can escalate into a major emergency very quickly.

Make yourself aware of the emergency procedures and evacuation area at any site where you

work or visit; eg. Know that a siren sounding continuously means to make your way quickly and

calmly to the evacuation point.

Never leave the accident scene or evacuation area without letting someone know. Lives have

been lost trying to save someone who was safe but had not been accounted for. Act calmly and don’t panic.

1. Assess The emergency and its extent:

eg. What, Where, How many, How badly, Is the danger passed?

2. Alert Get help from appropriate Emergency Services:

The local and site numbers are beside the office phone.

External: Dial Number ????

3. Assist / Evacuate UYour personal safety must be assured U.

If all danger has passed, secure the accident scene and render assistance as necessary. If any

danger exists, make your way immediately to the evacuation area.



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Evacuation Procedures 1. The need for evacuation will be indicated by:

a) A siren sounding continuously. b) Verbal Orders. c) Both.

2. (Excepting for Flood, Storm or Cyclone/Hurricane threat) Leave immediately by the nearest exit - Do not stop to collect personal belongings.

3. Go straight to your head count area and report to the Emergency Coordinator. 4. Do not leave your evacuation area until told by the Emergency Coordinator.

If safe, a designated person should: a) For fire

i) Shut down machinery and all ENERGY sources. ii) Close all windows. iii) Close all doors behind them.

b) For bomb threat i) Shut down machinery and all ENERGY sources. ii) Open all windows. iii) Open all doors.

c) For storm or cyclone threat i) Shut down machinery and all except emergency ENERGY sources. ii) Slightly open windows on the side of building opposite to the direction of the

coming storm. iii) Close all doors. iv) Do not use the telephone during the storm. v) Stay indoors and away from windows.

d) For flood i) Shut down machinery and all except emergency ENERGY sources. ii) Close all windows and doors. iii) Sandbag entrances as appropriate iv) If possible, move computers and other electrical equipment to the highest area

inside the buildings. v) Stay indoors.

e) For earthquake, tsunami, volcanic eruption or other natural disaster i) Shut down machinery and all except emergency ENERGY sources. ii) Close and seal all windows. iii) Close and seal all doors.

EVACUATION AREAS are site specific and you must know where these are for any site that you are on.



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ACCIDENTS AND INJURIES 1. Quickly assess the scene, noting the type of accident, possible hazards, and the number of

injured people and the nature of the injuries. 2. Check for any danger at the scene and try to anticipate further possible danger. 3. If there are any dangers - control them eg. turn off all electricity, control petrol spillage, and

secure unstable elements. traffic control. DO NOT PLACE YOURSELF OR OTHERS IN DANGER.

4. Administer First Aid if qualified - Remain with the victim and arrange for immediate transport to medical assistance ie. Ambulance.

5. Where the accident involves live electrical contact, do not touch any victim. Turn off the power at its source if possible.

If not, use an unpainted wooden pole to break electrical contact or remove live wires. Do not move the victim unless there is immediate danger to them! If there are any hazards that you cannot control and you must move a victim, then as gently as possible drag them by holding the clothing, the ankles or under the armpits - If possible stabilize the neck/spine during all movement. SOME BASIC PROCEDURES THAT CAN BE USED IN EMERGENCIES: Death or Serious Injury on Site 1. (See Accidents and Injuries above) Assess the situation. 2. Stabilize/control any dangers as required but under no circumstances place any other person in

danger. 3. Alert site management immediately and advise emergency services providing all the available

details. 4. Provide whatever assistance possible for the victim. 5. Notify main plant entry gate and have a person standing by there to take Emergency Services

to the scene. Fire on Company Property 1. Alert all persons in the area and initiate evacuation. 2. Identify area effected. 3. Notify emergency services giving all details. 4. Turn off your equipment and any other energy sources. 5. Use fire extinguishers or hose reels ONLY IF IT IS SAFE TO DO SO. 6. Contain fire ONLY IF SAFE TO DO SO. eg. close doors and windows. 7. Secure the emergency scene and prevent entry. 8. Walk by the most direct route to your Evacuation area and report to your emergency

controller/warden 9. DO NOT LEAVE THE EVACUATION AREA UNTIL YOU ARE ADVISED TO DO SO.



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Fire on Neighboring or nearby Public Land - If you are told a fire is approaching your site 1. Secure equipment and buildings 2. Ensure all flammables are sealed, and where possible moved to a safer area. 3. Report to your Emergency Controller/warden at your assembly area 4. Await further instruction. 5. DO NOT LEAVE THE SECURE AREA Explosion 1. Determine nature of emergency. 2. Identify area effected and determine if danger still exists e.g. gas leak. 3. Notify emergency service - Do not attempt repairs unless qualified to do so. 4. Remove to safety/assist any injured persons ONLY IF SAFE TO DO SO (Refer Accidents and

Injuries). 5. Secure the area ONLY IF SAFE TO DO SO. 6. Move to evacuation area and report to your emergency controller. 7. DO NOT LEAVE THE EVACUATION AREA. Severe Rain/Wind/Hail/Electrical Storm 1. Notify all personnel on site. 2. Secure all loose materials/objects that could become missiles in wind gusts. 3. Shelter all personnel and mobile plant under cover and do not use telephones during lightning

activity. 4. Shutdown or electrically isolate operations, plant, machinery or energy sources as appropriate. 5. Stay indoors and Notify the Business Unit/Site Manager. Information System Failure 1. Notify Group company and local Information Technology Manager. 2. All sales details are to be entered by hand onto the sales dockets retaining, the numbering

sequence of dockets in order from the last computer generated docket. 3. When system is ‘up’, details must be entered into the system ensuring that the computer

generated number matches the hand written docket. Customers are to be notified should the computer-generated number may vary from that written on their delivery docket.

Environmental Contamination or Spill 1. Notify the Site and/or Group Environmental Manager or Supervisor. 2. Ensure all personnel are notified and instructed to remain clear of the area. 3. DO NOT attempt to recover or contain dangerous or hazardous goods unless qualified to do so. 4. Notify emergency services and the Environment Department in the case of dangerous or

hazardous goods. 5. Refer to and follow spill containment and clean up procedures for all other spills.



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Misfire During Blasting 1. Notify the Quarry/Mine Manager. 2. Ensure all personnel are notified and instructed to remain clear of the area 3. DO NOT enter the area until the Quarry/Mine Manager advises that it is safe to do so. Mobile Plant/Machine Rollover or Accident 1. Power down and discontinue use of the machine. 2. Notify the manager immediately. 3. Clear the area until the machine is stabilized. (See Accidents and Injuries above). Damage to Overhead Wires 1. Discontinue work in that area. 2. Notify the manager and the power provider. 3. If necessary, evacuate to the assembly area. (See Accidents and Injuries above - Don’t be the next victim). Communication System Failure 1. A mobile phone should be available at each site where no other communication exists to

ensure continued ability to communicate. 2. Notify the service provider. 3. Advise Business Unit/Site Manager. Civil Disorder 1. Alert Site and Business Unit/Head Office Management 2. Notify police and request urgent assistance. 3. Assist in action to restrict contact between demonstrators & occupants.

(Close and lock gates, doors, shutters, security barriers/screens and windows). 4. Assist in action to:

a) Restrict access. b) Confine disturbance. c) Secure respective work areas. d) Withdraw employees to a safe area. e) Shut down processes where necessary.

5. Protect all valuables, sensitive documents, computer discs or other materials by locking them away in a safe or in secure cabinets - Shutdown computers and network access.

6. If safe and possible to do without the knowledge of the persons concerned, take photographs of people attempting to obtain access to the site and protect the camera and/or video and films.

7. Don’t panic and under no circumstances offer any forcible resistance Recovery Plans 1. The Business Unit Manager , Site Manager / Supervisor and others as required shall determine

the action to be taken based on individual requirements. 2. All requests for information by external bodies, including the media, shall be referred to the

Business Unit/Site Manager. Note however that many Government Personnel (e.g. Police and Environmental or Occupational Health & Safety Inspectors) have very wide powers to require the provision of information and/or actions to be taken during any emergency situations. Hence all individual employees should always co-operate fully with such authorized personnel

3. The Corporate Crisis Management Team will be involved only at the request of the Chief Executive Officer/Managing Director or the Divisional General Manager.



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APPENDIX FOUR: OH&S DEFINITIONS



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Definitions related to the OH&S Policy HOLCIM OH&S POLICY We provide healthy and safe workplaces by striving for zero risk to our employees, contractors and visitors. We apply OH&S standards and guidelines, provide the necessary resources and training and measure performance. OH&S means Occupational Health and Safety

We place the highest value on being a responsible and caring employer. There are many reasons why we want to prevent accidents death or harm at work. They include: a safe and healthy workforce will be most likely to achieve other Group performance targets our moral responsibility to ensure our colleagues return home without being hurt at work, discharging any legal duties on individuals and the organization; as well as minimizing our costs for death, accidents and/or disease, illness and injury; and avoiding the potential for penalties relating to non-compliance with our legal obligations.

Hence, people are healthy and safe when their death or harm at work is prevented. Occupational

Occupational means involving a workplace, workplace activities or operational plant/equipment known to potentially represent higher risk. Examples(of operational plant/equipment known to potentially represent higher risk): Cranes and lifting equipment, pressure vessels, cooling towers for air conditioning open to the environment, etc

Health

Health means the absence of disease, illness, death or permanent disablement and can be physical or mental in nature. Example of a physical illness caused by a workplace: Asthma caused by inhaling spray paint mist in a workplace Example of a physical illness caused by a workplace activity: Carbon monoxide poisoning caused by a liquefied petroleum gas powered forklift being used inside an enclosed area that is poorly or non-ventilated Example of a physical illness caused by known high-risk plant: Legionnaire's disease (a pneumonia) due to inhaling Legionella bacteria from a contaminated cooling tower Example of an illness that is mental in nature: Stress … which can be due to a variety of factors and can contribute to physical illness such as heart disease

Safety

Safety means the absence of risks that may cause injury, illness, death or permanent disablement and can be physical or mental in nature. Example of a physical injury caused by a risk in a workplace: Cuts and abrasions caused by obstacles that cause tripping and falling at work



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Example of a physical injury caused by a workplace activity: A lime burn due to exposure to fresh mortar or concrete. Example of a physical injury caused by known high-risk plant: A crush injury caused by a crane load slipping Example of an injury that is mental in nature: Mental stress caused by a long period of working hours that exceed recommendations.

Workplace

A workplace is any place where work is, is to be, or is likely to be done by any Holcim employee or any other person acting under the direction of Holcim management. Examples: A cement manufacturing plant, an aggregates quarry or a plant making pre-mixed concrete; A room that has been rented for presenting the annual financial results of the organization; A vehicle supplied by an employer for use by an employee for the performance of work. A project office located in a client's site, but under Holcim's control.

Providing healthy and safe Workplaces

Providing healthy and safe workplaces involves the anticipation, recognition, analysis, evaluation and control of those hazards or factors that may cause disease, illness, injury or impaired health and well-being amongst persons at the workplace or those who are directly impacted by the workplace.

Striving for zero Risk to our Employees, Contractors and Visitors. By carrying out the process of Hazard Identification & Risk Assessment and Risk Control on an ongoing basis, we are striving for zero risk to our employees, contractors and visitors.

Risk Risk is the chance of something happening that will have an impact on objectives or targets. It is measured in terms of likelihood and consequence and may arise from an event, an action or from a lack of action.

Likelihood

Likelihood is used as a qualitative description of statistical probability and frequency - It is often given in % terms.

Consequence Consequence is the outcome of an event or situation, expressed qualitatively or quantitatively. This could be negative (ie. a loss or worsening in situation); or positive (ie. a gain or improvement).

Monitor Performance

To monitor performance is to check, supervise, observe critically, or record the progress of an activity, action or system on a regular basis in order to identify change. Each Group company will monitor its performance against the requirements of the Holcim OH&S Targets.



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Definitions related to the Holcim OH&S Targets

HOLCIM OH&S TARGETS Zero accidents causing Death and Zero accidents causing Permanent Disability annually A Lost Time Injury Frequency Rate of < 5 Achieved Annually A Lost Time Injury Severity Rate of < 60 Achieved Annually

Death

Loss of human life as a result of a work related accident. Permanent Disability

Permanent Disability occurs when person is no longer able to have gainful employment with Holcim or any other employer as a result of a work-related accident.

Lost Time Injury Frequency Rate Number of Lost Time Injuries (LTI’s) x 1,000,000

Total Number of Hours Worked Lost Time Injury Severity Rate Number of Work Days Lost from LTI's x 1,000,000

Total Number of Hours Worked

A Lost Time Injury (LTI) is a work-related injury after which the injured person cannot work for at least one full shift or full working day anytime after the shift or day on which the accident causing the injury occurred.

Injuries causing Death or Permanent Disability are not counted as LTI's and so are not in the Frequency or Severity Rates.

APPLICATION OF TARGETS All Targets will be applied for all our own employees in all segments and business units The Death/Permanent Disablement Rate Target will be applied for all sub-contractors, third parties

(contractors) and others where Holcim caused the accident The Lost Time Injury Frequency Rate Target will be applied for all sub-contractors

While there are no specific Targets defined, records will be kept of the: Total number of Accidents; and The number of Lost Time Accidents Involving all sub-contractors, third parties (contractors) and others where it is shown that Holcim

caused the accident Hours Worked

Hours Worked includes the actual hours worked by the non-exempt hourly personnel, as well as those for salaried exempt personnel.

Hours worked shall not be counted for vacations, holidays, sick leave, and any other off-duty time. For salaried personnel, the hours shall be calculated by using a given value of 8 hours per day

times the number of days worked (as per HARP). Number of Work Days Lost

Number of Work Days Lost is the number of work days (consecutive or not) after, but not including the day injury occurred, during which the person would have worked but could not do so; ie. could not perform the major duties of the work during all or any part of the workday or shift. The counting of workdays lost ceases when the person returns to productive work.



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Sub Contractors

Sub contractors are persons who are engaged in work for Holcim and meet all three of the following criteria: Holcim directly controls the number of hours worked; Holcim directly supervises the daily work activity; and The subcontract personnel fulfill the functions normally performed by Holcim employees

with Holcim expertise or know-how. (NOTE: This is the HARP definition)

Occupational Disease

An occupational disease is defined as a condition produced in the work environment over a period longer than one workday or shift; ie. usually such a disease is due to repetitive factors over a period of time. It may result from systemic infection, repeated stress or strain, chronic exposure to toxins, poisons or other ongoing aspects of the work environment.

TOccupational Injury: This i Ts any injury such as a cut, fracture, sprain, amputation, or other harm

resulting from a work-related event or a single instantaneous exposure in the work environment. TOccupational Illness

Occupational illness is any abnormal condition or disorder, other than one resulting from an occupational injury, caused by exposure to factors associated with employment. It includes acute illnesses or syndromes and immediate reactions which may be caused by a harmful exposure due to inhalation, absorption, ingestion or direct contact.

In order to report on their performance against the Targets, it will be necessary for all Group companies to collect the following data: Total number of Injuries causing Death Total number of Injuries causing Permanent Disability Total number of Lost Time Injuries For all own employees and subcontractors, as well as 3rd parties (contractors) and any

others where it is shown that Holcim caused the accident Total amount of time worked Total FTE personnel For all own employees and subcontractors separately Total working hours lost in Lost Time Accidents For all own employees only

NOTES: Cement plants already collect and report this data in the Annual Technical Report (ATR) each year. This requirement is now being extended to all parts of the Group, and will be done via HIP. External reporting (outside Holcim) of both the Lost Time Injury Frequency Rate and the Lost Time Injury Severity Rate will be done on a 24 month rolling average basis.

Holcim Group Support Ltd Phone +41 58 858 54 51

Im Schachen Fax +41 58 858 54 52

CH-5113 Holderbank/Switzerland [email protected]

www.holcim.com

11/2002

Documents

OH&S Handbook-Mar 03