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ISSUE DATE:

IMCO Engineering & Construction Company WLL Rev : 2


04-08-2016
Procedure No: Procedure Title: Page: 2 of 21
AN IMS CERTIFIED Health, Safety and Environmental Management System
COMPANY QA/IMCO/HSE/MS/QT-001

TABLE OF CONTENTS

1. INTRODUCTION ................................................................................................................................. 3

2. HSE POLICY ......................................................................................................................................... 4

3. OUR MISSION .................................................................................................................................... 5

4. OUR VISION ........................................................................................................................................ 6

5. HSE MANAGEMENT SYSTEM .......................................................................................................... 7

5.1. COMMITMENT AND LEADERSHIP ............................................................................................. 9

5.2. POLICIES AND OBJECTIVES ....................................................................................................... 10

5.3. ORGANIZATION, RESOURCES AND DOCUMENTATION ..................................................... 11

5.3.1. ORGANIZATIONAL STRUCTURES ........................................................................................ 12

5.3.2. RESPONSIBILITIES AND ACCOUNTABILITIES .................................................................... 13

5.3.2.1. COUNTRY MANAGER ............................................................................................................ 13

5.3.2.2. HSE MANAGER ....................................................................................................................... 14

5.3.2.3. PROJECT MANAGER .............................................................................................................. 14

5.3.2.4. PROJECT HSE ENGINEER/OFFICER ...................................................................................... 15

5.3.2.5. PROJECT ENGINEER/SUPERVISOR ...................................................................................... 16

5.3.2.6. EMPLOYEE ................................................................................................................................ 17

5.3.2.7. SUBCONTRACTOR .................................................................................................................. 18

5.4. RISK EVALUATION AND MANAGEMENT ............................................................................... 18

5.5. PLANNING .................................................................................................................................... 19

5.6. IMPLEMENTATION, RECORDING AND MONITORING......................................................... 19

5.7. AUDIT AND REVIEW ( ASSESSMENT AND CONTINUOUS IMPROVEMENT) ................... 20

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04-08-2016
Procedure No: Procedure Title: Page: 3 of 21
AN IMS CERTIFIED Health, Safety and Environmental Management System
COMPANY QA/IMCO/HSE/MS/QT-001

1. INTRODUCTION

Health, Safety and Environmental (HSE) Management is an integral and essential part
of the way we do our business and is considered an equal part of the wider system for
the management of our business.

Through effective management, IMCO aims to be the preferred contractor and the
favored employer. The requirements set out in this document constitute the expectation
for compliance with IMCO policy.

The purpose of this document is to describe;

The structure for the management of Health, Safety and Environmental (HSE)
within the IMCO projects

The expectations for each element of the HSE Management System

It is the responsibility of each project to determine how these expectations and


requirements are to be achieved.

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COMPANY QA/IMCO/HSE/MS/QT-001

2. HSE POLICY

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3. OUR MISSION

We provide good services to strive for global excellence in Oil and Gas Industry and
Construction worldwide.

To distinguish ourselves through listening, learning and understanding industry


challenges and to capitalize on strategic and opportunistic possibilities.
To provide services those are attractive and fair to our Client and earn their loyalty while
also providing value to our shareholders.
To create a work place that protects worker health and safety with due respect for the
environment, and promote an atmosphere to grow employee learning and opportunity in
a way that is fulfilling, recognized and fairly rewarded.

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4. OUR VISION & VALUES

IMCO expects its personnel to achieve year-over-year improvement in safety


performance while Go to Zero injuries.
IMCO is aiming for a destination called zero zero safety incidents, zero injuries and
zero days off work due to injury; in other words, a perfect HSE record. Go to Zero
means accepting that every incident is preventable.
Our Go to Zero vision is a decision to change change behavior and the way things
are done to ensure safety is always at the forefront for every employee. As a global oil
and gas contracting company, we expect our workers to make safety on-the-job and off-
the-job an everyday priority by emphasizing five safety principles:

Participation
Accountability
Consistency
Communication
Training
At IMCO, we expect people to come to the job site and for just one shift, not have any
injures. Then we achieve it on the next shift, and the next. Day after day. We know it
can be done because many of our work sites achieve it every day, year after year.
The Go to Zero vision does not mean that another injury will never occur. Rather, it
means a commitment to working as many hours as possible without an injury. And it
requires an attitude an attitude that says any injury or incident, even a small one,
shouldnt be taken lightly. Any incident is unacceptable. Thats the attitude that is key to
Go to Zero.

Its an attitude that we expect from each employee at IMCO.

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AN IMS CERTIFIED Health, Safety and Environmental Management System
COMPANY QA/IMCO/HSE/MS/QT-001

5. HSE MANAGEMENT SYSTEM

IMCO Engineering & Construction Company HSE Management System defines the
elements by which we will conduct our operations worldwide in order to protect our
people, the public, our property and the environment in which they work and live.

The HSE Management System model is comprised of seven interrelated elements with
underlying expectations:

1. Commitment and Leadership

2. Policies and Objectives

3. Organization, Resources and Documentation

4. Risk Evaluation and Management

5. Planning

6. Implementation, Recording and Monitoring

7. Audit and Review

Each division must communicate these expectations to all employees, customers and
third parties associated with our business. Each division must provide positive evidence
of conformance to this Management System and continuous improvement.

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AN IMS CERTIFIED Health, Safety and Environmental Management System
COMPANY QA/IMCO/HSE/MS/QT-001

ELEMENT IN THE BUSINESS

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AN IMS CERTIFIED Health, Safety and Environmental Management System
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5.1. Commitment and Leadership

Management shall provide strong visible commitment, leadership and personal


involvement in health, safety and the environment. Management shall make
available the resources necessary to achieve our HSE objectives.

Expectations

Set a personal example day to day by following HSE rules.

Make decisions that consider HSE matters equal to cost, quality, morale and
production.

Delegate the necessary authority to the appropriate personnel and allocate


resources to carry out HSE functions.

Visit operations on a regular basis to demonstrate commitment and recognize


performance in HSE matters.

Hold those in positions of authority accountable at all levels of the company for
compliance with company policies and global standards.

Develop HSE objectives at your level of responsibility.

Communicate with employees, clients, subcontractors and industry personnel so


that they know and understand the intent of HSE policies.

Celebrate and promote your HSE success.

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5.2. Policies and Objectives

Say what you are going to do. Develop and communicate policies demonstrating a
commitment to HSE that is consistent with, and at least equal to, other business
aims. Supporting objectives shall be defined, deployed and maintained at all
organizational levels.

Expectations

Develop local HSE policies that support and are consistent with corporate
standards.

Set objectives for continuous improvement.

Involve all levels of management and personnel in the development of objectives


for the division.

Develop specific objectives for the reduction of risk.

Communicate the policies and objectives to all employees in a clear, readily


understood, medium.

Develop performance measures to guide and gauge progress towards achieving


objectives.

Meet and strive to exceed regulatory requirements in all jurisdictions.

Review policies and objectives at all levels on a regular basis, to determine


continued validity.

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5.3. Organization, Resources and Documentation

Define, document and communicate the roles, responsibilities and accountabilities to


enable every individual to fulfill their role in improving HSE performance.

Expectations

Define the interrelationships between individuals, operating groups, support


functions, employees, clients and partners in joint activities, trade associations
and regulatory bodies.

Appoint and support a management team representative to act as the focal point
for HSE matters.

Ensure that each group and individual receives sufficient information and
training to fulfill their role with respect to HSE.

Allocate sufficient resources to support policies and work towards achieving


objectives set for HSE issues.

Ensure a system that provides and maintains effective procedures, resource


material and records on HSE subjects.

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AN IMS CERTIFIED Health, Safety and Environmental Management System
COMPANY QA/IMCO/HSE/MS/QT-001

5.3.1. Organizational Structures

Qatar Country
Manager

QA/QC HSE
Manager Manager

QA/QC HSE
Inspector Coordinator

HSE Officer

Administration Senior Head of Manager Manager


Manager Accountant Estimation Project Controls Projects

Govt. Assistant Estimation


Relation Accountant Engineer
Cost Planning Procurement Engineering Project
Control Dept. Dept. Dept. Manager
Admin
Asst.
Sr. Cost Planning Sr. Engineering Const.
Control Engineer Procurement Lead Manager
Personne
l Officer
Asst. Jr. Purchase Design Lead Discipline
Cost Planning Engineer Elect./Inst. Site Engr.
Logistic
Coordinator
Local Engineer Supervisor
Purchase
Drivers.

Draftsman Foreman

Skilled
Workers

Helpers

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5.3.2. Responsibilities and Accountabilities

IMCO assigns the utmost importance to safety and accident prevention to


ensure that all employees are provided a safe and healthy work environment.
The success of the policy requires all levels of personnel management and
employees, to become totally supportive and to develop a thorough
understanding of safety as it pertains to their respective jobs. The following
responsibilities are assigned to accomplish this objective.

5.3.2.1. Country Manager

Country Managers shall be responsible and accountable for the


development, implementation and maintenance of all IMCO HSE
and rehabilitation policies and procedures.
The position carries the prime responsibility to demonstrate through
proactive measures the commitment of IMCO to all environmental
and safety issues. Pro-Active measures shall include management-
initiated actions to improve the safety and environmental systems
together with prompt response to meaningful suggestions and or
recommendations from all site personnel.
The Country Manager shall ensure that:

All on-site personnel are accountable for HSE performances


within their area of responsibility;
Appropriate safety standards are set through participation and
consultation with all site personnel including supervisors,
employees and client representatives.
All quality, safety and environmental reports and inspections
are reviewed and will initiate appropriate rectification responses
where necessary;
There will be an active participation in all accident/incident
investigations;
There will be active participation in safety/environment
meetings and programs;
Monitoring for compliance with environmental and safe work
methods shall occur.
Conduct Pre-start safety alignment meetings with Client As
required. Review first aid and accident/incident reports
Monthly Investigate serious incidents as required
Participate in workplace HSE hazard inspections
Monthly Review site safety performance Monthly
Participate in group safety meetings Monthly

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Attend safety toolbox meetings Weekly

5.3.2.2. HSE Manager

The HSE Manager shall be responsible for the operation,


implementation and control of the HSE System. He shall ensure
that this procedure is well coordinated and explain to all HSE
personnel. He shall be the direct contact in the event that HSE
requirements deviation observed. He is accountable for the
incident/accident investigation and shall report to the Country
Manager Projects Group in a regular basis.

The HSE Manager has the full authority for the compliance of the
ISO 14001:2004 and OHSAS 18001:2007 requirements and the
requirements of legal, regulatory and statury requirements. He shall
be responsible for conducting HSE Management Review Meeting
and arranging internal audits to all corporate operations.

5.3.2.3. Project Manager

The Project Manager has the delegated responsibility for all


operations of the project team and as such assumes responsibility
for the teams conformance with all relevant IMCO, client and
statutory based HSE requirements.
Consistent with assigned responsibilities and authorities, the
management team shall provide and be accountable for
maintaining a safe place of work. Duties include:

Reporting to the general manager or delegate regularly and/or


immediately in the event of a significant incident;
Assisting in developing and controlling company procedures
and safety instructions in all workplaces;
In consultation, provide active support to GE personnel in all
HSE matters;
Liaising with the general manager or delegate to ensure
statutory compliance and conformance to HSE acts, regulations
standards and specifications;
Providing a safety example, encouraging safety, quality,
environment and productivity through visible presence at all
workplaces.

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COMPANY QA/IMCO/HSE/MS/QT-001

PROJECT MANAGER - ACTIVITIES FREQUENCY


Review HSE Plan Prior to job start
Conduct Pre-start safety alignment meetings with Client As required
Review first aid and accident/incident reports Monthly
Investigate serious incident As required
Participate in workplace HSE hazard inspection Monthly
Review site safety performance Monthly
Participate in group safety meetings Monthly
Attend safety toolbox meetings Weekly

5.3.2.4. Project HSE Engineer/Officer

The project HSE Engineer/Officer is responsible for all


administration of HSE program. He will report directly to the Project
Manager and serve in advisory capacity.

In carrying out his responsibility, the project HSE/Officer Engineer:


Serves as technical advisor to the Project Manager / Site
Engineers in HSE planning.
Implements established policy, procedures and work practices
to promote the company project safety and health program
and administer assigned functions to aid in these overall
responsibilities.
Monitors compliance with mandatory HSE laws, standards or
codes.
Conducts inspection of job sites, documents and reports any
unsafe acts & unsafe conditions to the responsible Engineer /
Supervisor for immediate corrective action.
Tests the work environment and documents the results in
order to eliminate or control hazard which could contribute to
or result in an occupational illness.
Arranges and conducts regular HSE meeting for field
Supervisors. Ensures that a foreman or representative from
each unit is present at these meetings.
Attends all weekly progress and/or schedules meeting to
provide input regarding safety for current and future project
activities.
Ensures that unit supervisor conducts weekly tool box
meetings with all personnel in attendance provides appropriate
topic or discussion and initiates follow-up response to HSE
concerns addressed during these meetings.

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Investigates all incidents and accidents that could involve


potential liability, maintains adequate records of relevant data
and complies the required reports on experience.
If assigned, monitors compliance with established pollution
control and environmental protection standards and
regulations.
Arranges for securing safety permits based on site conditions.
Performs air monitoring for harmful or explosive substance in
the work environment.

Ensure that all required notices, posters and other related


literature is properly displayed for employees information.
Organizes necessary HSE propaganda program for promoting
safety and health program for HSE awareness.
Recommends, selects and ensures that Safety, First aid, fire
protection equipment are of relevant standards and also
ensures that such material is always at hand.
Assists Project Supervisor in the inspection of tools,
equipment and facilities.
Provides training to site personnel with regards to specific safe
work practices / procedures, use and care of personnel
protective equipment, and handling hazardous material /
equipments.
Identifies the safe areas near by the work place, locations of
emergency facilities such as fire service, water, first aid clinic,
etc.
Ensures that all work forces are aware of such in 6.5.16.
The Safety Engineer / Officer has the full authority to stop any
work activity for any safety reasons.

5.3.2.5. Project Engineer/Supervisor

It is recognized by senior management that project supervisors play


an important role in the effective implementation of the safety
program. Every effort shall be made by senior management to
encourage feedback from the shop floor as a vital part of the
Safety Management System.
Project Supervisors shall play an active roll on the safety
committee. Duties include:

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Reporting to the senior Project Manager;


A working knowledge of IMCO HSE policies;
Ensuring planned safe working methods are implemented;
Identifying and eliminating safety and environmental hazards in
the workplace;
Incorporating safety and environment instructions when
allocating tasks;
Convening tool box meetings;
Conducting incident investigations and reporting findings to the
HSE coordinator via the Project Manager;
Ensuring safety, quality inductions of all personnel including
subcontractors;
Undertake safety and environment inspections of workshops
and/or sites;
Liaise with the Project Manager at all times;
Provide a visible safety example, encouraging and promoting
safety and environmental policies and procedures in all
workplaces.
Attending safety and environment meetings;

ENGINEER/SUPERVISOR - ACTIVITIES FREQUENCY


Review and identify hazards in work scopes Tender
Attend safety toolbox meetings Weekly
Attend pre-start meetings Daily
Participate in informal hazard inspection Daily
Participate in formal hazard inspection Weekly
Review and authorize JSAs prior to task commencement As required
Participate in accident and incident investigations As required

5.3.2.6. Employee

IMCO believes that safety is everyones responsibility.


Employees shall:

Take reasonable care for their own safety and health;


Use all personal protective equipment that is issued to meet
safety requirements;
Report all identified hazards, defects in plant or equipment no
matter how minor;
Make all endeavors to warn other employees of known
hazards;
Comply with statutory, safety and environmental requirements
for the workplace;
Assist in achieving goals set by management
Actively support the project safety and environmental policies

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Maintain a sound knowledge of safe work practices;


Comply with guidelines formulated and distributed through
inductions, toolbox meetings and site instructions.

5.3.2.7. Subcontractor

Sub-contractors are accountable for:

Safety performance in their respective areas of control;


Compliance with the Project HSE Management Plan where
they have not already had a system in place or current
systems are below the standards set out by the Alliance
partners.
Provision and maintenance of safe systems of work.
The development and provision of Job Safety Analysis and
safe work procedures for their unique systems of work.

SUBCONTRACTOR - ACTIVITIES FREQUENCY


Develop JSAs for their scopes of work As required
Provide where requested representation to project safety meetings As required
Conduct workplace hazard inspection (formal and informal) Daily/weekly
Conduct toolbox meetings Weekly
Conduct pre-start meetings Daily
Report and investigate all accidents/incidents within their area of As required
control

5.4. Risk Evaluation and Management

Continually evaluate the HSE risks to the workforce, customers and the
environment. Continually evaluate processes and activities for specific hazards
assess potentials, record and control the subsequent risk to a tolerable level.

Expectations

Establish a methodology that identifies both acute and chronic hazards and their
associated impacts. Address routine and non-routine tasks, emergencies and
outside influences.

Conduct hazard assessments during the design, development, operating and


decommissioning stages of equipment, processes and facilities.

Control hazards and reduce risk to a tolerable level through mitigating and
recovery measures.

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Apply risk management tools to all proposed activities including acquisitions, bids
and new business development.

5.5. Planning

HSE considerations shall be integral to all aspects of business planning or changes


in the design, development, purchasing and delivery of our products and services.

Expectations

Identify and evaluate the consequences to health, safety and the environment
when making changes to organizational structure, personnel, equipment,
processes or procedures.

Assign responsibility for the achievement of HSE objectives in plans at all levels
of the organization.

Determine the resources required to achieve the plan.

Identify the means by which the plan is to be achieved. Set a time scale and
develop milestones for implementation.

Develop contingency plans for emergencies and in cases when plans or


objectives cannot be completely achieved.

Regularly review and follow up on progress towards achieving the HSE plans and
objectives.

5.6. Implementation, Recording and Monitoring

Do what you said you would do. Determine and record whether those actions are
effective. Activities shall be conducted in accordance with defined standards, and
continuous improvement shall be promoted and monitored through active employee
participation.

Expectations

Assign necessary resources and authority to groups or individuals to implement


plans, processes, procedures and work instructions.

Hold personnel accountable for completing tasks according to plans and HSE
performance standards.

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Develop and use systematic monitoring systems for both proactive and reactive
performance measures to measure and support HSE objectives.

Determine non-compliance and the opportunity for practicable improvement


against performance measures.

Determine what records are needed to meet HSE policies, objectives, company
standards, local laws or regulations and customer requirements.

Create records that are clear, easily understood and unambiguous in the
language applicable to Ensign. Store records for a time interval consistent with
good practice and local regulations.

Collect and record information on incidents which actually, or have the potential
to, affect health, safety and the environment.

Evaluate incident information to determine the need for corrective action to


prevent recurrence. Distribute lessons learned.

5.7. Audit and review ( Assessment and Continuous Improvement)

Prove you did what you said you would do. Is the Management System achieving
results and fulfilling policy intent? Audits and reviews shall be conducted to verify the
implementation and effectiveness of the HSE Management System and its
conformation to this specification.

Expectations

Set frequency and level for audits for each division or operation.

Document and distribute the audit report for corrective action and future
reference. Review with all affected employees.

Monitor progress towards achieving and completing corrective actions at


scheduled time intervals.

Schedule periodic management system reviews to include, but not be limited to:

Audit finding summaries

Analysis of incidents, regulatory citations and non-compliance to divisional


standards

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Current and future requirements of customers and regulators - Feedback from


customers and regulators

Feedback from employees

Analysis of risk management processes

Appropriateness of current systems to meet business needs

Create review team with the authority to change the system and update the
system requirements.

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