SHUI ON BUILDING CONTRACTORS LIMITED SHUI ON CONSTRUCTION COMPANY LIMITED

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1 Title : Health and Safety Management System Manual Issue No. : 2 Revision No. : 1 This Manual and the information therein is the property of Shui On Building Contractors Limited and Shui On Construction Company Limited. All rights are reserved. No part of this Manual may be reproduced in any form, transmitted by any means or otherwise disclosed without the prior permission of the above companies.

2 Table of Contents 1.0 Summary of Amendments 2.0 General (Title Only) 2.1 Introduction 2.2 Manual Control 2.3 List of Abbreviations 3.0 Cross Reference with OHSAS and F&IU (Safety Management) Regulation 4.0 Health and Safety Management System (Title Only) 4.1 Scope of the Health and Safety Management System 4.2 Health and Safety Policy 4.3 Planning (Title Only) Hazard Identification, Risk Assessment and Determining Control Legal and Other Requirements Objectives and Programmes 4.4 Implementation and Operation (Title Only) Resources, Roles, Responsibility, Accountability and Authority Competence, Training and Awareness Communication, Participation and Consultation (Title Only) Communication Participation and Consultation Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 2 of 54

3 4.4.4 Documentation Control of Documents Operational Control Emergency Preparedness and Response 4.5 Checking (Title Only) Performance Measurement and Monitoring Evaluation of Compliance Incident Investigation, Nonconformity, Corrective Action and Preventive Action (Title Only) Incident Investigation Nonconformity, Corrective Action and Preventive Action Control of Records Internal Audit 4.6 Management Review 5.0 Company Health and Safety Procedures Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 3 of 54

4 1.0 Summary of Amendments Rev. No. Issue Date Amendments /6/ /12/31 NA Revise section para. 1 and 2 Insert section para. 7 and re-number paragraphs that follow Revise section para. 1 Revise section para. 1 and 2 Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 4 of 54

5 2.0 General 2.1 Introduction 1. Shui On Building Contractors Limited or Shui On Construction Company Limited is one of the leading building contractors in Hong Kong and holds a Government approved building works licence that allows the Company to tender for projects of all sizes. The Company is a subsidiary of the Shui On Construction and Materials Limited in the Shui On group of companies. 2. The Company has established and implement an Health and Safety Management System (H&SMS) in accordance with the requirements and interpretation of OHSAS This Manual is a document describing the Company s approach to fulfilling the system elements of OHSAS According to OHSAS requirements, the H&SMS consists of 20 elements which are maintained in a 5-step management cycle to achieve continual improvement. 4. This manual is written in a concise manner with the pragmatic objective that it can be easily understood by the users. Users of the manual should therefore refer to the complete set of H&SMS documents including but not limited to Company Health and Safety Procedures, Site Safety Plans as well as detailed work instructions. 5. The purpose of the H&SMS is to ensure that significant risk(s) identified in the Company s activities and services are being controlled. These significant risk(s) will be managed through operational controls and will be improved by objectives and targets from time to time. This Manual also addresses the documentation requirements of OHSAS and provides a road map to the system for employees and third parties. 6. To facilitate implementation of the H&SMS, system procedures are developed and referred as Company Health and Safety Procedures (CHSPs) listed in Section 5.0 of this Manual. Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 5 of 54

6 2.2 Manual Control 1. HSE Senior Manager is responsible for the preparation, maintenance, issue and control of this Manual. 2. HSE Steering Committee is responsible for reviewing this Manual and approving any changes. 3. The Executive Director is responsible for endorsement and authorization of this Manual by signing the front page of this Manual. 4. The issue status of this Manual is indicated on the front sheet and on every sheet of this Manual. Authorization by the Executive Director is provided on the front page of the master copy of this Manual. 5. This Manual Revision Number allows this Manual to be updated for the amendment of any section or sub-section. 6. This Manual is re-issued with a new Manual Issue Number when more than half of the sections or sub-sections need to be changed. 7. This Manual will be issued in electronic form by uploading to the Company s intranet where all staff can gain access. HSE Senior Manager is responsible for keeping the master copy of the signed Manual and arranging to keep the intranet version up-to-date. 8. Usually all printed copies are uncontrolled copies and are for reference only. Always refer to intranet for updated version of this Manual. 9. Uncontrolled copies may be distributed outside the Company with the approval of HSE Senior Manager. They will be printed on normal paper without orange company logo and will not be kept up-to-date. HSE Senior Manager will record to whom copies have been sent. 10. Controlled copies are only distributed outside the Company when approved by the Executive Director. In these circumstances, formal transmittal letters will be used. 11. Controlled copies, if necessary, will be printed on paper with an orange company logo Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 6 of 54

7 and distribution is controlled by HSE Senior Manager. 12. Anyone desiring a change to this Manual must address a request to HSE Senior Manager in writing. 13. HSE Senior Manager evaluates the request and prepares a draft of the proposed change for review by HSE Steering Committee. 14. When the change is agreed, HSE Senior Manager advances this Manual Revision Number and/or this Manual Issue Number accordingly and produces a master for authorization by the Executive Director. 15. For ease of reference, recent changes made will be given in italics. Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 7 of 54

8 2.3 List of Abbreviations CHSP(s) Company ED F&IU H&S H&SMP H&SMS HSE HSEMC HSEP HSESC OC(s) Company Health and Safety Procedure(s) Shui On Building Contractors Limited or Shui On Construction Company Limited as appropriate Executive Director Factories and Industrial Undertakings health and safety Health and Safety Management Programme Health and Safety Management System Health Safety and Environment Health Safety and Environment Management Committee Health Safety and Environment Policy Health Safety and Environment Steering Committee Operational Control Procedure(s) OHSAS18001 OHSAS 18001:2007 Occupational health and safety management systems Requirements OHSAS18002 OHSAS 18002:2000 Occupational health and safety management systems Guidelines for implementation of OHSAS SH&SP Site Health and Safety Policy Site HSEC Site HSE Committee SR SSP WI(s) Safety Resolution Site Safety Plan Work Instruction(s) Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 8 of 54

9 3.0 Cross Reference with OHSAS and F&IU (Safety Management) Regulation The cross reference between sections and subsections in this Manual and the elements of OHSAS standard and F&IU (Safety Management) Regulation are given below. Section Description OHSAS Ref. F&IU (Safety Management) Regulation 4.1 Scope of the Health and Safety 4.1 Safety Management System Management System 4.2 Health and Safety Policy 4.2 Safety Policy 4.3 Planning (Title Only) Hazard Identification, Risk Assessment Job Hazard Analysis and Determining Control Legal and Other Requirements In-house Safety Rules and Regulations Objectives and Programmes Safety Promotion 4.4 Implementation and Operation (Title 4.4 Only) Resources, Roles, Responsibility, Safety Organization Accountability and Authority Competence, Training and Awareness Safety Training Communication, Participation and Consultation (Title Only) Communication Safety Promotion Participation and Consultation Safety Committee Documentation Control of Documents Operational Control Process Control Personal Protection Programme Health Assurance Programme Evaluation, Selection and Control of Subcontractors Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 9 of 54

10 4.4.7 Emergency Preparedness and Response Emergency Response 4.5 Checking (Title Only) Performance Measurement and Safety Inspection Programme Monitoring Evaluation of Compliance Incident Investigation, Nonconformity, Corrective Action and Preventive Action (Title Only) Incident Investigation Accident/Incident Investigation Nonconformity, Corrective Action and Preventive Action Control of Records Internal Audit Safety Audit/Review 4.6 Management Review 4.6 Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 10 of 54

11 4.0 Health and Safety Management System 4.1 Scope of the Health and Safety Management System 1. This Manual is applicable to the Company with respect to site operations of building construction. 2. During the building construction phase, H&S management becomes the prime responsibility of the main contractor since the H&S hazards in construction phase have direct impacts on the employees and the surrounding neighbourhood. Aiming at minimizing or better still eliminating the H&S risks arising from building construction, the Company put in place a structured H&SMS that complies with the requirements of OHSAS Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 11 of 54

12 4.2 Health and Safety Policy 1. The Health and Safety Policy is incorporated into the Health Safety and Environment Policy (HSEP) statement of the Company. The HSEP states that the concern for the health, safety and environment is the responsibility of every employee and subcontractor. All operations shall comply with the relevant statutory requirements. All employees and subcontractors shall at all time adhere to the related responsibilities, work procedures which are clearly laid out in this Manual. 2. The HSEP states that continuous improvement is the strategic goals of the H&SMS. The current HSEP and associated measures shall be reviewed regularly to allow continuous upgrading of H&S standards. 3. The HSEP is stated in English and Chinese versions, and is communicated to all relevant levels through a variety of means described in CHSP 4 (Health and Safety Training and Promotion) and CHSP 5 (Communication). 4. Management of the HSEP is addressed in CHSP 1 (Health and Safety Policy). Supporting Procedure(s) CHSP 1 Health and Safety Policy CHSP 4 Health and Safety Training and Promotion CHSP 5 Communication Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 12 of 54

13 4.3 Planning Hazard Identification, Risk Assessment and Determining Controls 1. The hazard identification, risk assessment and risk control measures are developed to enable the Company to identify, evaluate and control H&S risks on the ongoing daily operations. 2. Hazard arising from construction operations and services are identified, evaluated and reviewed in accordance with CHSP 2 (Hazard Identification, Risk Assessment and Risk Control). 3. To each identified individual construction activity, its hazards are identified and their corresponding levels of risk are also evaluated with a pre-defined criteria. Such evaluation is important for defining risk control, prioritising programmes and actions for accident prevention. 4. The risk assessments address the hazard arising from all stages of the identified construction activity or process, so as to allow the identified hazard to be monitored and controlled respectively to CHSP 9 (Checking, Inspection and Maintenance) and CHSP2 (Hazard Identification, Risk Assessment and Risk Control). 5. When determining controls, or considering changes to existing controls, consideration shall be given to reducing risks according to the following hierarchy: - Elimination; - Substitution; - Engineering controls; - Signage/warnings and/or administrative controls; - Personal protective equipment. 6. In the event that new processes, equipment and materials are introduced to the sites or existing activities modified, the related H&S hazards shall be identified. Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 13 of 54

14 7. Review shall also take place if changes within the Company call into question the validity of the existing assessments. Such changes can include but not limited to the following elements: - expansion, contraction, restructuring; - reapportioning of responsibilities; - changes to methods of working or patterns of behaviour Supporting Procedure(s) CHSP 2 Hazard Identification, Risk Assessment and Risk Control CHSP 9 Checking, Inspection and Maintenance Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 14 of 54

15 4.3.2 Legal and Other Requirements 1. HSE Senior Manager is responsible for identifying, assessing, maintaining, reviewing and updating all relevant legal and other requirements (including consideration on applicable international standards) according to CHSP 3 (Legal and Other Requirements). These requirements also include the Safety Resolutions (SR) developed internally. 2. HSE Senior Manager shall take into account of these legal and other requirements in establishing, implementing and maintaining the Company s H&SMS. The Company shall ensure the key responsible staff understand and strictly follow these requirements by establishing appropriate work instructions, implementing monitoring programmes and conducting periodic internal inspection and auditing respectively according to CHSP 9 (Checking, Inspection and Maintenance) and CHSP 12 (Audit). 3. In case of any non-conformance, CHSP 10 (Nonconformity and Corrective and Preventive Action) shall be followed accordingly. Supporting Procedure(s) CHSP 3 Legal and Other Requirements CHSP 9 Checking, Inspection and Maintenance CHSP 10 Nonconformity and Corrective and Preventive Action CHSP 12 Audit Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 15 of 54

16 4.3.3 Objectives and Programmes 1. HSE Steering Committee (HSESC) shall set objectives and targets in line with the Health Safety and Environment Policy and communicate to all relevant functions and appropriate levels for implementation and review. The agreed targets shall be specific, measurable and achievable within specifiable time frame. 2. HSE Senior Manager is responsible for gathering information for establishing objectives and targets in HSESC. Objectives and targets shall be identified through the following steps: (i) (ii) Identify new and review the existing significant H&S risks, legal and other requirements. Review existing operational controls/practices to determine whether the significant H&S risks are effectively controlled. (iii) If no controls are in place, identify and implement necessary controls. Under certain circumstances objectives and targets may be set to address the control of significant risks. (iv) If controls are in place but not satisfactory, the following will be implemented: amend the relevant control mechanism, develop a new operational control/practice. (v) Alternatively the HSE Senior Manager shall improve control beyond the satisfactory level already being achieved, and in these circumstances the HSE Department shall establish new control(s) with reference to available technology, financial, operational and business requirements and views of interested parties. 3. Complaints from external interested parties and internal suggestions shall be discussed, reviewed and taken into the account for the establishment of objectives and targets. 4. Based on the agreed objectives and targets, measurable indicators and a Health and Safety Management Programme (H&SMP) shall be developed and used as the basis for H&S performance evaluation which can provide information about the effectiveness of the H&SMS at both the management and the operational levels. Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 16 of 54

17 5. The prime aim of the H&SMP is to achieve the objectives and targets and to achieve compliance with a recognised standard. 6. The H&SMP shall address clearly the objectives and targets, detailing the method of achievement and necessary action, responsibility for implementation and time scale over which the targets are to be achieved. 7. HSE Management Committee shall monitor, review and update the H&SMP as necessary in accordance with CHSP 13 (Management Review). The progress of achieving objectives and targets can be traced through the minutes of committee meetings. 8. Staff assigned to assist in the implementation of H&SMP, along with the objectives and targets they seek to achieve, shall be mutually agreed between themselves and management. 9. In this H&SMS, objectives and targets are addressed alongside with the management review process in accordance with CHSP 13 (Management Review). Monitoring and review of target achievement shall therefore be included as part of the management review cycle. 10. If appropriate, H&SMP shall be modified with reference to any changes to objectives and targets to ensure the actions and targets are fully in line with each other. Supporting Procedure(s) CHSP 13 Management Review Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 17 of 54

18 4.4 Implementation and Operation Resources, Roles, Responsibility, Accountability and Authority 1. To effectively maintain the H&SMS, the Company develops and maintains a cross-functional structure as shown below. Appendix 4.4.1A also shows the organisation structure of the Company. 2. Within this structure, roles, responsibilities and authorities are defined, documented and communicated in order to facilitate effective H&S management. 3. Management shall ensure resources essential to support the implementation and control of the H&SMS are provided whenever required. Resources cover competent/trained personnel with specialized skills, appropriate technology and financial resources. HSE STEERING COMMITTEE 安全健康及環保主導委員會 HSE MANAGEMENT COMMITTEE 安全健康及環保管理委員會 SITE HSE COM. 地盤安全健康及環保委員會 SITE HSE COM. 地盤安全健康及環保委員會 SITE HSE COM. 地盤安全健康及環保委員會 SITE HSE COM. 地盤安全健康及環保委員會 SITE HSE COM. 地盤安全健康及環保委員會 SITE HSE COM. 地盤安全健康及環保委員會 Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 18 of 54

19 4. Health Safety and Environment Steering Committee (HSESC) Executive Director (Chair-person) General Manager Assistant General Manager Senior HSE Manager Its main responsibilities are to: Formulate and review HSEP for approval by ED. Ensure the H&SMS meets the OHSAS requirements and Safety Management Regulation. Assess and anticipate the impact of existing and forthcoming legislation. Set objectives and targets as part of HSE planning which are compatible with the Company goals and objectives for continuous improvement. Review and ensure the effectiveness of the H&SMS. 5. Health Safety and Environment Management Committee (HSEMC) General Manager (Chair-person) Assistant Project Procurement Plant HSE Senior General Managers Senior Manager Manager Manager and Manager Managers Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 19 of 54

20 Its main responsibilities are to: Review on implementation and effectiveness of H&SMP. Formulate Safety Resolutions. Discuss on budgeting HSE program and training need in the planning stage. Set up an accountability system to motivate all levels to achieve good HSE performance. Implement policy and procedures made by the HSESC, and give feed back, if any, to the said committee for continuous improvement. Coordinate and designate work of management and establish responsibilities and authorities. Conduct in-house H&SMS audit to check over the effectiveness of implementation and review operational control measures for H&S issues with site staff. Work and maintain on pre-determined standard. 6. Site HSE Committees (Site HSEC) HSE Officer Project Manager (Chair-person) Mechanics Foremen Engineer Site Agent Project Supervisor Site Administrator Subcontractors' Worker Rep. Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 20 of 54

21 The main responsibilities of each Site HSEC are to: Ensure proper implementation of H&SMS. Develop, introduce and monitor working H&S rules. Enforce standards for H&S at all times. Give all trades foremen and gangers precise instruction on their responsibilities. Inspect the site to ensure all H&S measures are observed. Maintain on the adequacy of communication and publicity in the workplace. Provide interaction between management and employees on H&S problems where both have vital interests. Monitor all subcontractors activities regularly to ensure their continuous commitment to the prescribed H&SMS requirements. Consider and implement on recommendations provided by Government bodies and appointed HSE officer. 7. The HSE Senior Manager is appointed with specific responsibility for H&S of the Company while the Project Manager of a project site is responsible for H&S of that particular site. Their roles and authority include: ensuring that the H&S management system is established, implemented and maintained in accordance with OHSAS 18001; ensuring that reports on the performance of the H&S management system are presented to top management for review and used as a basis for improvement of the H&S management system. 8. The responsibilities and authorities of the employees who perform and verify work affecting the H&S conditions are described in their job descriptions or the related procedures. For easy reference, the responsibilities and authorities of the key members or departments are outlined in this section. 8.1 Executive Director Appoint senior management to HSESC. Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 21 of 54

22 Endorse Health and Safety Policy. Chair HSESC meetings. Set objectives and formulates Health and Safety Management Programme (H&SMP) to improve the H&S performance of operations. Approve and endorse relevant controlled documents such as H&SMS manual and procedures. 8.2 General Manager Chair HSEMC meetings. Take the lead to support the implementation of H&SMP. Decide on the provision of training, equipment and facilities to assist the implementation of H&SMS. Keep abreast in complying with all relevant statutory and contractual H&S requirements. Oversee and facilitate the sites for the implementation of H&SMS. Communicate and collect feedback on the overall implementation. 8.3 HSE Senior Manager / Managers Assist the HSEMC to implement H&SMS for improving the H&S performance of the Company and communicating of all relevant information to HSESC for Management Review. Ensure the Company is complying at all times with relevant statutory and contractual H&S requirements and OHSAS requirements. Draft H&SMS Procedures / documentation. Approve OCs and WIs. Maintain H&SMS records. Identify training needs for all relevant staff and promote H&S training program for all supervisory levels. Forecast the legislation impact on the Company. Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 22 of 54

23 Liaise with government authorities such as Labour Department, Fire Service Department and other professional bodies, etc. Conduct and revise H&S audit to check over working methods and H&S precautions. Oversee HSE Officers for effective implementation of H&SMS. Participate in management meetings for HSE issues. 8.4 Procurement Senior Manager / Managers Communicate and collect feedback from subcontractors and / or suppliers. Consider all subcontractors invited for tendering are H&S oriented. 8.5 Plant Manager Oversee the mechanics and provide technical advice on control facilities. Communicate and collect feedback from mechanics. 8.6 Senior Project Manager / Project Manager Chair Site HSEC meetings. Ensure overall implementation of H&SMS at site level through participating in regular inspections. Be familiar with the requirements of the H&SMP. Ensure that all site management levels are conversant with and fully comply with H&SMP, Company, statutory as well as contractual H&S requirements. Be responsible for ensuring that the H&SMP is reviewed half yearly, kept up to date and implemented. Ensure that all senior site staff are assigned appropriate duties and responsibilities of the H&SMP. Ensure the achieving of Company objectives and targets such as accident rate. Ensure that subcontractors are aware of and implement the H&SMP. Take appropriate actions against subcontractors with poor H&S performance. Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 23 of 54

24 Act as the Employee Representative for the site to maintain the communication between HSEMC and site HSEC. Maintain a direct line of communication with the HSE Officer. Support and uphold rectifications and recommendations from HSE Officer on H&S deficiencies. Supervise the implementation of corrective action plans. 8.7 Site Agent Be familiar with the requirements of the H&SMP. Be accountable to the Project Manager and responsible for implementing the H&SMP. Ensure that all subcontractors are conversant with and comply with H&SMP. Assess the H&S performance of subcontractors. Enforce H&S disciplinary system. Monitor the site operations to ensure they are conducted in accordance with the H&SMP and take urgent and appropriate action to prevent improper working practices or other infringements of statutory or H&SMP requirements. Coordinate incident investigations. Lead monthly site safety inspections. Attend and participate in site HSE committee meeting. 8.8 Engineer Ensure works are carried out according to the required standard with minimum risk to workers, public, equipment and materials. Understand and enforce the statutory and contractual H&S requirements. Co-ordinate activities between main contractor and sub-contractors and any other individual contractors who may be working at the same time. Check H&S condition of hired plant and that, where appropriate, copies of Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 24 of 54

25 valid test certificates are readily available for inspection. Ensure that all work carried out at workplace, all plant, machinery and equipment therein, conform to the prevailing statutory requirement. Organize and arrange site operations to ensure they are conducted so as to minimize risk to workers and other people. Prepare method statements and participate in risk assessment of high risk operations. Take urgent and appropriate action to suspend risky operations that affect structural safety. Obtain material safety data sheet of hazardous materials used on site. 8.9 Project Superintendent / Project Supervisor Know and understand the requirements of H&SMP and other relevant legislation and ensure that they are being observed. Advise foremen and engineers on the correct working practices to avoid dangerous occurrences. Liaise with subcontractors and other contractors to ensure that their sections of work are executed and conformed to H&S standards. Assess the H&S performance of foremen and subcontractors. Conduct regular H&S inspections. Enforce H&S disciplinary system. Participate in risk assessments and risk process control measures. Implement operational control. Take actions to rectify unsafe conditions and practices and to implement the H&S measures as recommended by the HSE officer. Coordinate and enact housekeeping measures to keep the site clean and tidy. Attend and participate in site HSEC meeting. Participate in incident investigations. Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 25 of 54

26 8.10 HSE Officer Assist site management to: Supervise and monitor the implementation of H&SMP. Address implementation and updating of the H&SMP and all relevant issues of H&S. Verify the H&SMP are implemented through regular inspection. Implement the recommendations in the H&S audit report. Keep aware of changes in legislation and H&S requirement and keep legal requirements affecting the site safety up-to-date. Organize H&S training and keep relevant training records. Carry out training for all levels of employees on preventing the occurrence of accidents. Keep up-to-date with recommended H&S requirements; circulate information applicable to each level of employee. Conduct risk assessment before high risk operations. Recommend risk control measures and compile safe working procedures for high risk operations. Carry out site inspections in association with appropriate site staff to see that safe methods of working are in operation; that all regulations are being observed. Implement H&S disciplinary system. Suspend unsafe operations with imminent danger. Report on accidents and dangerous occurrences for statistical analysis. Investigate incidents and compile investigation reports. Assess H&S performance of foremen. Organize and facilitate site HSEC meetings. Prepare and organize internal and external H&S audits Foremen / Assistant Foremen Be familiar with statutory regulations and the client s specific safety rules applicable to the work on which their gangs are engaged; insist that the Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 26 of 54

27 regulations are observed. Ensure that new employees learn to be safety aware. Ensure that plant / equipment are operated by competent person only and any defects are reported immediately to site agent / project supervisor. Ensure the right tools are used for the specific purpose of work. Ensure that appropriate clothing are worn and appropriate devices/equipment are used at work where required. Carry out inspection on the execution of operational control based on an approved checklist. Enforce H&S disciplinary system. Maintain good housekeeping of supervising area. Attend site HSEC meetings Operators / Mechanics Know the statutory and contractual H&S requirement in respect of the plant. Ensure possession of necessary certificate before operating any plant or equipment. Familiar with the characteristic of the plant to be operated. Ensure the plant is in good working condition prior to use and operate the plant in acceptable safe working method. Ensure regular maintenance has been carried out. Report defects in plant or equipment. Inspect electrical tools of subcontractors to ensure the tools comply with Company safety requirement. Supervise and guide their subordinates to carry out work in accordance with statutory and Company safety requirement. Ensure no illegal and unsafe use of electricity on site. Maintain good housekeeping of work area after work. Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 27 of 54

28 Attend safety meetings Site Administration Officer Support site in monitoring, documentation, record-keeping and inspection. Handle logistic arrangement of equipment calibration, document storage and coordination of site workers. Ensure sufficient stock of personal protective equipment and keep issue records. Arrange with HSE Officer to provide induction training to new workers. Maintain good housekeeping of site office and storage areas General Staff Be familiar with the HSEP, statutory regulations and safety rules applicable to the work on which their gangs are engaged; insist that the regulations are observed and all nonconformity events are reported immediately. Hold accountable for the performance of H&S, which is generally reflected by inspection reports. Take reasonable care for the working and surrounding environment and others who may be affected by their actions. Attend and/or release the workers for H&S training upon requested. Inform and report to site office immediately on the occurrence of any non-conforming event. Be familiar with the nature of work and the equipment or tools to be operated. Check relevant equipment regularly to ensure they are in good condition. Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 28 of 54

29 Appendix 4.4.1A Organisation Structure of Company Board of Directors Executive Director HSE - Steering Committee General Manager Quantity Estimating/ E & M Project Plant Human HSE Administration Finance/ Quality Surveying Procurement Engineering Engineering Department & Resources & Accounting Assurance Machinery Training Department Department Department Department Project Department Department Department Department Department Department Head Head Head Head Managers Head Head Head Head Head Head Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 29 of 54

30 4.4.2 Competence, Training and Awareness 1. All employees shall have attend Green Card Training and hold a valid certificate at all time when working on site. 2. All employees shall receive Induction Training which includes but not limited to issues relating to conformance with the HSEP general H&S awareness including the understanding of the H&SMS. 3. HSE Senior Manager shall identify training needs of staff whose work may have significant impact on the H&S performance of the Company. HSE Officer shall identify training needs of subcontractors workers on site. 4. Training will be provided in order to Maintain levels of competence Comply with existing new legislation and regulations, and Safety Resolutions Introduce new technology and Encourage two-way communication 5. H&S Training are provided internally or by external bodies, or by a combination of both. 6. Project Managers and HSE Senior Manager shall establish and maintain procedures to make its employees or members at each relevant function and level aware of The importance of compliance with the organisation s HSEP and objectives, and with the requirements of the relevant H&SMS standard specifications The importance of conformance with the HSEP and procedures and with the requirements of the H&SMS The significant risk, actual or potential, of their work activities, their behaviour, and the benefits of improved personal performance Their roles and responsibilities in achieving conformance with the HSEP and procedures and with the requirements of the H&SMS, including emergency preparedness and response requirements 7. Personnel performing the tasks with significant risks should be competent on the basic of Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 30 of 54

31 appropriate education, training and/or experience. 8. Management shall determine the level of experience, competence and training necessary to ensure the capability of personnel, especially those carrying out specialized H&S management functions. 9. Procedure CHSP 4 (Health and Safety Training and Promotion) has been established to ensure that where appropriate all employees are trained with respect to the above H&S issues, and that this training is reviewed and updated as necessary. Supporting Procedure(s) CHSP 4 Health and Safety Training and Promotion Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 31 of 54

32 4.4.3 Communication, Participation and Consultation Communication 1. Communication is an important part of our H&S management system. We need to communicate internally with employees and contractors and externally, with outside parties. 2. Our communication is a two-way process. Management communicate to make employees aware of aims and progress on H&S management. Management also listen and take heed of the opinions and inputs from staff and from outside organisation and individuals. 3. Procedure CHSP 5 (Communication) has been established and in place for receiving, documenting and responding to internal and external communications. 4. Internal communication aims to: Raise awareness of H&S issues Achieve commitment to the H&S management programme. Communicate changes and progresses that are made in H&S management Gather information from staff ideas, attitudes and suggestions 5. Receiving, documenting and responding to relevant communication from external interested parties is important in implementing the H&SMS. Changes on the H&S management and the activities description will be reported and provided to the interested parties, related departments and employees. 6. Employees are involved in the consultation over the development and review of policies, the development and review of H&S objectives, and decisions on the implementation of processes and procedures to manage risks, including the carrying out of hazard identification, and in reviewing risk assessments and risk controls relevant to their own activities. 7. Employees are also asked for comments on changes affecting workplace H&S such as the introduction of new, or modified, equipment, materials, chemicals, technologies, Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 32 of 54

33 processes, procedures or work patterns. Supporting Procedure(s) CHSP 5 Communication Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 33 of 54

34 Participation and Consultation 1. Procedures are established to get the participation of worker representatives in H&SMS implementation. 2. Relevant subcontractors site representatives will get involved when reviewing site policies and objectives that affect them. 3. Participation of worker representatives include: Hazard identification, risk assessment and determination of controls; Incident investigation. 4. Relevant external interested parties will be consulted about pertinent H&S issues. Supporting Procedure(s) CHSP 14 Participation and Consultation Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 34 of 54

35 4.4.4 Documentation 1. Documentation is necessary to provide direction to the System and to facilitate audits. The H&SMS is established in accordance with the Occupational Health and Safety Management System requirements of OHSAS The system comprises the following key documents which is controlled and maintained according to CHSP 6 (Document Control) and CHSP 11 (Records): Health Safety and Environment Policy (HSEP) A signed policy statement by top management stating its strategy for H&S management which provides the basis for the H&SMS and objectives. Health and Safety Management Programme (H&SMP) Programme that is compiled by HSE Department to detail the actions and time frame necessary to achieve the established objectives and targets. Health and Safety Management System Manual Comprehensive guide to all elements of the H&SMS; also refers to other related documents. Company Health & Safety Procedure (CHSP) System procedure for effective implementation of the H&SMS. Index of Construction Activities Summary of risk assessment of the Company s activities, products or services in which it can control or expect to have an influence. Site Specific Index of Construction Activities Similar to the Index of Construction Activities except it only accounts for the activities specific to individual project site. Health and Safety Legislation and Regulations Legislation and regulations can be assessed through internet to relevant websites. Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 35 of 54

36 Register of Legal and Other Requirements Summarizes all H&S legislation and other requirements to which the Company may subscribe. Safety Resolution (SR) Written resolution passed by HSEMC specifying the measure(s) that will be implemented for every site. Alternatives shall be undertaken if site environment does not allow the specified measure(s). Objectives and Targets Actions planned by HSESC to implement satisfactory H&S measures and controls if they are not already in place and to improve control beyond the satisfactory level already achieved. Operational Control Procedure (OC) General guidance including implementation of legal and other requirements developed to control the H&S risk arising from work activities. Work Instruction (WI) Activity-specific instruction developed with reference to the OC for supervisory to maintain their work in an acceptable safe manner. Health and Safety Records Records which demonstrate achievement of the required H&S standards and the effective operation of the H&SMS. Supporting Procedure(s) CHSP 6 Document Control CHSP 11 Records Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 36 of 54

37 4.4.5 Control of Documents 1. This part ensures that documents are reviewed and approved prior to issue and that the pertinent issues of appropriate documents are made available for the due performance of the H&S management and control. 2. Master list or equivalent document control procedures are used to identify the revision status of documents. Amendment sheets are used to identify changes in documents, which are reviewed and approved by the functions that performed the original review and approval. Obsolete documents are removed or clearly identified as such to prevent inadvertent use. 3. HSE Senior Manager is responsible for control and maintenance of the Manual as well as its associated procedures. Executive Director is responsible for approving the Health and Safety Management System Manual and CHSPs. 4. Obsolete documents retained for legal and/or knowledge preservation purpose are suitably identified by the respective holders. 5. HSE Senior Manager holds the master copy of the Health and Safety Management System Manual and CHSPs and ensure the updating of the copy placed on intranet. 6. Amendments to the Manual are drafted by HSE Senior Manager and authorized by Executive Director; while changes to CHSPs are drafted by the employee who proposes the changes, approved by HSE Senior Manager and authorized by Executive Director. Details of the changes are recorded in the amendment section of these documents. 7. Upon revision of these documents. HSE Senior Manager will arrange uploading of the updated version of documents to the intranet for every staff s reference. 8. All staff shall always refer to the intranet for the updated version when necessary. 9. Department Heads or Project Managers or their nominees shall file, distribute and control the incoming and outgoing project documents in accordance with CHSP 6 (Document Control). Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 37 of 54

38 10. Details of control of H&SMS records shall be referred to CHSP 11 (Records). Supporting Procedure(s) CHSP 6 Document Control CHSP 11 Records Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 38 of 54

39 4.4.6 Operational Control 1. HSE Senior Manager identifies those operations and activities that are associated with the identified hazards where the implementation of controls is necessary to manage the H&S risks. This shall include the management of change. For those operations and activities, the Company shall implement and maintain: Operational controls, as applicable to the Company and its activities; Controls related to purchased goods, equipment and services; Controls related to contractors and other visitors to the workplace; Documented procedures, to cover situations where their absence could lead to deviations from the HSEP and the objectives. 2. Operational control is addressed through the implementation of documented Safety Resolutions (SRs) and Work Instructions (WIs) for the relevant activities and operations. In addition, subcontractor s activities will be controlled through provisions in the contracts. 3. OCs aim at providing a general guidance for controlling significant H&S related activities in project operations so as to meet the requirements of OHSAS OC is divided into the following major categories: Health Assurance Programme Personal Protective Equipment Programme Process Control 4. WIs are developed with reference to OCs for supervisory to check the detailed instructions for controlling the H&S risks arising from individual operations. 5. In the event of a change to the Register of H&S related activities (see CHSP 2), OC(s) will be updated and reviewed; and modification and/or addition of WI(s) will be followed. Supporting Procedure(s) Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 39 of 54

40 CHSP 2 Hazard Identification, Risk Assessment and Risk Control OCs Operational Control Procedures Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 40 of 54

41 4.4.7 Emergency Preparedness and Response 1. Procedures are maintained to solve the problems in case of emergency, providing that the particular actions will minimize the H&S risks and consequences. 2. Training on dealing with accident and emergency situation are provided, and HSE Officer is responsible for organizing the training programs. Procedures mentioned in the emergency preparedness and responses will be reviewed and tested periodically (at least once a year) to ensure the procedures are applicable, and details related to the testing shall be recorded. 3. In case of emergency happened, Emergency Team is responsible for preparing the accident record, and reviewing the efficiency and effectiveness of the procedures. Also, by considering the consequences generated from the accident and emergency situations, HSE Senior Manager is responsible for judging the need of reporting the case to the HSE Steering Committee. 4. Procedures are established to identify the potential for, and the response to, accidents and emergency situations (to minimise H&S risks). These include Near miss and/or Accidents Fire and Explosion Spillage / Leakage Underground Contamination Landslide / Flooding Harsh Weather 5. Procedure CHSP 7 (Emergency Preparedness and Response) addresses the implementation of an effective and appropriate emergency response on dealing with potential incidents and accidents. CHSP 7 ensures that the effectiveness of this response is tested and staff has received the appropriate training. Supporting Procedure(s) Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 41 of 54

42 CHSP 7 Emergency Preparedness and Response Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 42 of 54

43 4.5 Checking Performance Measurement and Monitoring 1. Procedures are established and maintained to inspect, monitor and measure, on a regular basis, the key characteristics of its operations and activities that can have a significant impact on the H&S issue. This shall include the recording of information to track performance, relevant operational controls and conformance with the organization s H&S objectives and targets. Incident statistics shall be compiled as a means of monitoring H&S performance. 2. Constructional equipment shall be tested and examined and certificates shall be retained in accordance with relevant legislation. 3. A documented procedure is also established and maintained for periodically evaluating compliance with relevant H&S legislation and regulations, and the controls include Reviewing the frequency of inspection involved. Initiation of corrective actions on the validity of certificates when an equipment is found to have relevant certificates expired. Retaining suitable records on inspection and examination. 4. CHSP 9 (Checking, Inspection and Maintenance) outlines the requirements and responsibilities for carrying out this safety checking and inspection of sites activities in accordance with the requirements of OHSAS Supporting Procedure(s) CHSP 9 Checking, Inspection and Maintenance CHSP 15 Incident Investigation Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 43 of 54

44 4.5.2 Evaluation of Compliance 1. Legal and other requirements that are applicable to H&S shall be identified and periodically evaluated for its compliance according to CHSP 9 (Checking, Inspection and Maintenance). The records of the results of the evaluations shall be kept according to the CHSP 11 (Records). 2. HSE Senior Manager is responsible for identifying, maintaining, reviewing and updating all relevant legal and other requirements according to CHSP 3 (Legal and Other Requirements). 3. Project Managers shall inform HSE Senior Manager on H&S compliance of their projects. HSE Senior Manager is responsible for collecting the information and submits to senior management for review if necessary. 4. HSESC will conduct the legal compliance evaluation, such as prosecution and complaint records, in management review of the H&SMS to improve / revise the HSEP and / or Management Programmes and check that the H&SMS is effective in achieving its purpose. 5. Other methods which can be used to assess compliance, including: internal audits; inspections; document and / or records review; meeting; routine monitoring and measurement results. 6. The compliance evaluation can be integrated with other assessment activities such as environmental inspections and assessments. For any nonconformity events related to legal compliance, it should refer to CHSP 10 (Nonconformity and Corrective and Preventive Action). Supporting Procedure(s) Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 44 of 54

45 CHSP 3 Legal and Other Requirements CHSP 9 Checking, Inspection and Maintenance CHSP 10 Nonconformity and Corrective and Preventive Action CHSP 11 Records CHSP 13 Management Review Issue No. 2 Revision No. 1 Issue / Revision Date: 2008/12/31 Page No. 45 of 54