PREVENTION AND SAFETY MANUAL

Transcription

1 Edton 10 Page 1 of 30 PREVENTION AND SAFETY MANUAL Verson 1 February 1996 Creaton Verson 2 Aprl 1998 General Revew Verson 3 Aprl 2002 General Revew Verson 4 June Addton of PP Serous Accdents Adaptaton where hazardous substances are nvolved. Verson 5 September Addton of PP Hazard Identfcaton and Rsks at Work Assessment PP Incluson of the concepts of Act 54/2003 reformng the legslaton framework of the Preventon of Occupatonal Rsks. - Incluson of concepts of R.D. 171 regardng the Coordnaton of Busness Actvtes n PP.13. Verson 6 December 2005 OHSAS Adaptaton Incluson of the responsblty for submttng the documentaton Verson 7 July 2007 requred n paragraph 5.3, n case of stoppage of actvtes Verson 8 December 2007 Revson of Serous Accdent System Verson 9 May Safety Commttees added n Company organzaton chart - Correcton of functons of Management representatve - Added presentaton of Acerálava Verson 10 July Defnng the new Preventon Management model. Organsatonal Change, dutes and responsbltes of Management and of the Preventon Department

2 Edton 10 Page 2 of 30 CONTENTS 0. INTRODUCTION TO THE COMPANY 1. SCOPE OF APPLICATION 2. TERMINOLOGY 3. PURPOSE AND NATURE OF THE MANUAL 4. PREVENTION ORGANISATION 4.1. Preventon Servce 4.2. Preventve Integraton n the Company 4.3. Partcpaton of the Workers. Preventon Delegates 5. DUTIES AND RESPONSIBILITIES 5.1. Tubacex Group Management 5.2. Aceralava and TTI Operatons Management 5.3. Management Representatve 5.4. Plant Drectors (or other Drectors or Managers wth people under ther supervson) 5.5. Chan of command 5.6. Preventon Department 5.7. Mantenance and Techncal Offce 5.8. Personnel Development. Tranng 5.9. Purchasng Correctve and Preventve Mantenance 5.11 All Employees Plant Operatons Commttee 5.13 Operatons Commttee Safety Executve Commttee Plant Health and Safety Commttees 5.16 Intercentre Health and Safety Commttee Montorng and Standards Commttee Operatons Chart 6. SAFETY ACTIVITIES 6.1. Polces 6.2. Hazard Identfcaton, Rsks Assessment and Rsk control Identfcaton and Complance of Legal Requrements 6.4. Targets and Programme Plannng the Preventve Actvty Structure Defnton and Responsbltes 6.6. Tranng, Rasng Awareness and Competences 6.7. Consultaton and Communcaton 6.8. Documentaton and controllng data and documents 6.9. Operatonal Checks Emergency Plans Checkng and Correctve Acton Management Revew

3 Edton 10 Page 3 of INTRODUCTION TO THE COMPANY T.T.I. - Tubacex Tubos Inoxdables, S. A., s a prvate and ndependent company, whch has been tradng n the sector snce 1963 and operatng under ts current name snce It s dedcated to the manufacture and sale of seamless ppes, hot or cold rolled, n alloy or stanless steel and n nckel alloys. It also produces seamless bmetal ppes. The Company employs around 500 people and has an annual producton capacty of 30,000 tons of ppng. The corporate headquarters, together wth the central offces, are located n Llodo, n the provnce of Alava, about 20 km from the cty of Blbao, n the North of Span. At the Llodo producton centre, the process, whch begns wth raw materal n the shape of bllet receved from Aceralava, S.A., comprses, after a cuttng operaton to pre-establshed measurements has been performed, perforatng at a hgh temperature, followed by reheatng and hot extruson (UGINE SEJOURNET process). After hot reducton, straghtenng, cuttng, bevellng and nspecton operatons have been carred out, the surfaces of the ppes are then treated and the ppng s nspected and packed to be sent to the customer as hot rolled ppes, or to Amurro, as slab ppe, to then be cold rolled. At the Amurro producton centre, the process, whch begns wth the slag ppe from Llodo, comprses ts cold rollng (PILGER process), when the thckness and dameter of the tubes s reduced, removng the grease, thermal treatment, straghtenng, cuttng, nspecton, and subsequent surface treatment. The ppes are then nspected agan and are packed to be sent to the customer as cold rolled ppng. The manufactured products are bascally used n the ol and gas ndustry, n the food, arcraft, chemcal and energy sector and n the mechancal manufacturng ndustry. They have to meet the qualty requrements mposed by nternatonal specfcatons and other contractual requrements. The Company operates on the domestc and nternatonal markets, wth the latter accountng for a hgh percentage of the sales. These operatons are run through a network of ts commercal offces, located n the most mportant market areas. T.T.I., S.A. s part of the TUBACEX group, whch ncludes the followng ndustral companes: Acería de Alava, S.A. (Acerálava), dedcated to manufacturng steel and located n Amurro (Alava) Tubacex Taylor Accesoros, S.A., dedcated to manufacturng tubng accessores. It s located n Arcenega (Alava). Salem Tube, Inc., dedcated to manufacturng cold rolled tubes. It s located n Greenvlle (Pennsylvana, USA). Schoeller Bleckmann Edestahlrohr, A.G., dedcated to the manufacture of hot and cold rolled ppng. It s located n Terntz (Austra). 9 Acería de Álava, S.A., company ntegrated n the Group, t s a prvate company consttuted n 1975 and whose captal s totally owned by Tbacex S.A.. The man offce s located n Llodo (Alava) and the producton facltes n Amurro (Alava) at 15 km from Llodo. The producton plant has a total area of 78,701 m 2, of whch 20,000 m 2 are occuped by producton facltes. Producton was started n January 1978 by manufacturng carbon and alloy steels n the form of rolled bars and bllets. Yearly producton capacty s 140,000 t of fnshed products. From 1988 the plant produces stanless steels, materal whch together wth nckel alloys currently means almost the total producton. Current producton conssts of rolled and/or forged bllets, rolled and/or forged round bars, square blooms and other types of ngots, such as polygonal ngots, and castngs. The plant employs a total of about 200 people. The producton process, usng ferroalloy scrap as raw materal, conssts of meltng raw materals n an electrc arc furnace and subsequently refnng t n an AOD furnace. Molten metal s poured n moulds and subjected to a heatng process as preparaton for hot rollng and/or forgng. After rolled and/or forged the materal s cut to sze and heat

4 Edton 10 Page 4 of 30 treated accordng to purchase order requrements, ground or machned and nspected and packaged for dspatch to the customer. Products are bascally used as raw materal n ppe and tubng ndustry, beng the Tubacex Group the man customer. 1.- SCOPE OF APPLICATION Ths Safety and Preventon Manual shall apply to: o Tubacex Tubos Inoxdables, S.A. at ts producton centres located at: Tres cruces, Llodo (Alava) Polígono ndustral de Saracho s/n Amurro (Alava) o Acería de Alava, S.A., at ts producton centre located at: Polígono ndustral de Saracho s/n Amurro (Alava) Its status beng the same as the applcable legslaton n all ts scope for all the plants. Lkewse, COMPANY s used to dentfy the actvtes establshed n the above paragraph throughout the document. 2.- TERMINOLOGY The termnology exstng by the three benchmarks used by the company s compared below: Preventon of Rsks at Work Act, OHSAS and that exstng n the company NAMES ACT OHSAS STANDARD TUBACEX SYSTEM OR Preventon Plan SSL Management System Rsk Preventon Programme Annual Management Plan: Plannng the Preventve Actvty. SST Management Programmes and Targets Plan of actons to mplement and mantan the system SST mprovement targets 3.- PURPOSE AND NATURE OF THE MANUAL The purpose of ths Manual s: Comply wth what s envsaged n the General Preventon Polcy Establsh general gudelnes that regulate the actvtes and behavour of the plants employees, of the contractors who work there and thrd partes who are n the plants. Acheve maxmum effcency n the feld of the Preventon of Rsks at Work to control and mnmse professonal rsks, as well as n the feld of Serous Accdents where hazardous substances are nvolved, n order to control and mnmse the njury to people and damage to assets and the envronment. Establsh the way to meet, complement and support the company's SOCIAL STRATEGY. Comply wth what s envsaged n the General Preventon Polcy n ts Artcle 16. It establshes the duty to set up a Preventon of Occupatonal Rsk Plan n the company, ncludng the organsatonal structure, the

5 Edton 10 Page 5 of 30 responsbltes, dutes, practces, procedures, processes and resources requred to ensure the preventon of rsks n the company. Ths Manual establshes the fundamental pllars to mplement the aforementoned plan, whch wll be known n the Company as the Safety and Preventon Occupatonal Rsks Programme. Comply wth current legslaton regardng Serous Accdents nvolvng hazardous substances. Comply wth the requrements establshed n the OHSAS techncal specfcaton: Occupatonal Health and Safety Management Systems" The Manual s n addton to everythng envsaged n current legslaton, whatever the range of the provson and, n partcular, n the Preventon of Rsks at Work Act, the Techncal Regulatons and ther complementary nstructons, nsofar as the Company s affected, and together wth Serous Accdents legslaton, developed by Royal Decree 1254/1999, of July 16th, whch approved the measures to control the rsks nherent to Serous Accdents nvolvng Hazardous Substances. Everythng envsaged n the nternal regulatons and n partcularly n the collectve wage agreements are also complementary to the above. The contents of the Manual may be amended, when so recommended by legslaton and experence, as well as when there are mportant changes n the organsaton of the company, ntroducton of new processes or technologes and new system audt actvtes. Ths Manual shall be revewed, at least, every four years. The Preventon Standards Commttee s responsble for submttng the amendment proposals to Management for ther subsequent approval. Ths Safety and Preventon Manual ncludes all the necessary references to the followng elements of the System: 1. Organsaton and workforce 2. Rsk dentfcaton and assessment 3. Controllng operatons 4. Adaptng modfcatons 5. Plannng regardng emergency stuatons 6. Montorng set targets 7. Audtng and revew Thus, all the Procedures or Standards requred to carry out the Safety and Preventon Programme are defned and referred to heren. Therefore, the Company s Safety and Preventon of Rsks at Work Programme or Preventon of Rsks at Work Programme", wthout dstncton, ncludes the management part relatng to Safety when Serous Accdents occur. 4.- PREVENTION ORGANISATION: 4.1. Preventon Servce Tubacex, S.A., T.T.I., S.A. and Acería de Alava, S.A. have a Jont Own Preventon Servce, n the areas of Occupatonal Safety, Hygene and Medcne, whch s backed and advsed by an External Preventon Servce for the other specaltes

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7 Edton 10 Page 7 of 30 CEO GROUP GENERAL ACERALAVA CORPORATE MANAGEMENT TEAMS PERSONNEL MANAGEMENT DIRECTOR HEALTH & SAFETY COMMITTE OF EACH PLANT COORDINADOR GRAL. DE PREVENCIÓN LLODIO AMURRIO ACERALAVA PLANT DIRECTOR PRODUCTIÓN PRODUCTIÓN PRODUCTION PROCESS MAINTENANCE QUALITY CONTROL PROCESS MAINTENANCE QUALITY CONTROL PROCESS MAINTENANCE QUALITY CONTROL ORGANIZATION ORGANIZATION ORGANIZATION PREVENTION PREVENTION PREVENTION COST CONTROL COST CONTROL

8 Edton 10 Page 8 of 30 The above graph depcts the general organsatonal chart of the company wth the dfferent departments and ther relevant servces. Lkewse and as regards the preventon of Rsks at Work, t shows the locaton of the preventon department wthn the organsaton and personnel management dvson on the one hand and the Preventon Executve Commttee on the other hand. The Preventon Department conssts of two dvsons: Preventon Dvson: It s run by the Preventon General Coordnator. At an operatonal level, ts team ncludes a Preventon Offcer for the Llodo plant and a Preventon Offcer for the Amurro plants. There s also a Preventon Analyst. All of them are qualfed as Occupatonal Health and Safety Senor Techncans. Ths dvson manages the areas related to safety, hygene and ergonomcs & psychosocology. The Preventon Offcers of each plant report to the Organsaton and Personnel Management Offcers of each plant and, at an operatonal level, to the TTI-Acerálava Preventon General Coordnator. Preventve Medcne Dvson: Consstng of a doctor specalsng n occupatonal medcne and helped by sx Santary Techncal Assstants (3 per plant) The dutes carred out by each of the members of the Preventon Department are descrbed n pont 5.4 heren Preventve Integraton n the Company Preventve Management n the company requres the nvolvement and partcpaton of the dfferent members and levels to be found n the organsaton. Pont fve descrbes ther dfferent dutes and responsbltes and those lsted below: Workforce n general Secton and shft operatonal meetngs Chan of command Departmental meetngs Management Representatve Plant Operatonal Commttee Management Operatonal Commttee Montorng and Standards Commttee Safety Executve Commttee Management Commttee A descrpton of the dfferent bodes nvolved n preventon n the company s set out n PP 08 Group Meetngs, Personal Contacts and Suggestons Partcpaton of the Workers. Preventon Delegates The company lkewse has the legally requred partcpaton bodes, whch are the followng: Plant Health and Safety Commttees Intercentres Health and Safety Commttee These commttees are regulated pursuant n the Operatng Regulatons of the Health and Safety Commttees PP DUTIES AND RESPONSIBILITIES The general dutes and responsbltes of the dfferent levels of the Organsaton are establshed below. These are specfcally defned n the procedures that regulate each of the actvtes that make up the Safety and Preventon of Rsks at Work Programme. Each of the dutes descrbed below wll have the followng general dutes n ts area of competence: Ensure that the dvson s procedures and nstructons are correctly appled Collaborate n the mplementaton of the establshed programmes to acheve the targets

9 Edton 10 Page 9 of 30 Provde the necessary measures n order to perform the envsaged preventve and correctve actons Ensure that hs employees are aware of the relevance and mportance of ts actvtes and how they help to acheve the exstng targets. All the company's employees are responsble for the Occupatonal Health and Safety Management System operatng correctly. Irrespectvely of ther specfc dutes, they shall collaborate n the mplementaton, practce and mprovement of the System by means of: Applyng the procedures, nstructons and other documents that affect them. Notfyng through the establshed channels the rsk stuatons or ncdents that affect the safety of the company's workers or nstallatons. Propose mprovements Tubacex Group Management Accountablty The management s fully accountable for all spheres of managng the company. In the sphere of Preventon, the Top Management, the Personnel Management Team and the Operatons Management team partcularly play a key role n that accountablty. Dutes n the feld of Preventon Defnng and revewng the general preventon polces Ensurng suffcent resources for the mplementaton and mantenance of the Preventon system Fosterng, supportng and streamlnng preventon Establshng targets and montorng ther complance The Operatons Management team s entrusted wth a more drect and detaled montorng of the complance of the polcy, procedures and targets by the Plants. The Personnel Management Team s entrusted wth a more drect and detaled montorng of complance of the dutes assgned to the Preventon Department TTI-Acerálava Operatons Management The Operatons Management team s entrusted wth a more drect and detaled montorng of the complance of the polcy, procedures and targets by the Plants. 3.Management Representatve The Organsaton and Personnel Management Drector s apponted by the General Manager as the Management Representatve as regards Occupatonal Health and Safety Management Hs drect access to the General Manager allows hm to nsst on the mplementaton of as many measures as necessary to ensure that the SGSST n accordance wth the OHSAS standard s establshed, mplemented and mantaned. The Personnel Management Team s entrusted wth a more drect and detaled montorng of complance of the dutes assgned to the TTI-Acerálava Organsaton and Personnel Management Managers and the Preventon General Coordnator..

10 Edton 10 Page 10of Plants drectors or other Drectors or Dvson Managers Accountablty Managng safety n ther respectve spheres: plannng, organsng, mplementng, overseeng and controllng safety pursuant to the polcy, procedures and targets establshed by Management. Dutes: - Controllng complance wth the targets establshed n the Annual Management Plan - Establshng, complyng wth and ensurng complance of the Preventon procedures and work nstructons. - Ensurng the approprate tranng of the workforce n the feld of preventon - Rsk dentfcaton - Introducng correctve measures - Accdent nvestgaton Of the chan of command Artcle 16 pont 1 of the Preventon of Rsks at Work Act establshes that ther preventon shall be part of the company s general management system, wth respect to the actvtes as a whole and at all ts organsatonal levels, by means of mplementng and applyng an preventon of occupatonal rsks plan. Therefore, t s a fundamental msson of the chan of command s to manage safety: plannng t, organsng t, mplementng t, overseeng and controllng, wthn ther area of responsblty, and advsed by the Preventon Department. Therefore: They shall know, comply wth and enforce the general preventon procedures n force, the nstructons, procedures and standards referrng to the work place and the current legslaton applcable to ts area of responsblty, always overseen by the Preventon Coordnator. They shall plan, where approprate, the possble tranng requrements of ther personnel. They shall comply wth the objectves and measures wthn ther competence and arsng from the mplementaton of the Rsk Preventon Programme. They shall ensure that the rsks or potental hazards are known, dentfed and that the approprate and necessary actons are taken to prevent and/or correct them. They shall ensure, where approprate, that the correctve actons arsng from the Safety and Preventon of Occupatonal Rsks Programme, are carred out. They shall nvestgate the Accdents/Incdents and Potental Rsks, where approprate, n order to determne the basc and mmedate causes of the event and establsh preventon measures, wth the am of avodng ther recurrng. They shall ensure that any anomaly or unsafe act that s detected wthn ther area of competence s corrected and shall notfy the relevant authorty for any areas not wthn ther competence. Any member of the chan of command shall be empowered to order stoppage of work n stuatons of mmnent rsk and then mmedately notfy hs superor, n order to fnd the most approprate soluton for ts preventon Preventon Department

11 Edton 10 Page 11of 30 Accordng to what s envsaged n Artcle 31.2 of the Preventon of Rsks at Work Act, the Preventon Department shall advse and help the employer, the workers and ther representatves to carry out preventve actvtes, n order to guarantee the approprate protecton of the health and safety of the workers In partcular, they shall manage and coordnate the Preventon Management actvtes and answer to Management regardng the effcency of the system. TTI-Acerálava Preventon General Coordnator Runnng the Preventon Department Ensurng that the SGSST general requrements are establshed, mplemented and kept up to date. Streamlnng the actve partcpaton of all the employees n the System. Assessng shortcomng and the system and proposng mprovements. Supportng the whole system (audts, accdent nvestgaton, procedures, etc.) Desgnng, mplementng and revewng the Safety Management System part of the chan of command. Plannng and montorng annual targets for the chan of command Perodcally reportng to Management on the degree of complance of preventon targets Advsng the chan of command, management and the workforce n general as regards the actvtes of the system. Proposng mprovement programmes to management Plant Preventon Offcers The poston of GPO Offcer has been created n each plant, answerng to the Techncal Drectors. The Preventon Offcers of each plant report to the GPO Offcers of each plant and, at an operatonal level, to the TTI-Acerálava Preventon General Coordnator. Both plant postons, GPO and Preventon, assume ther respectve management and preventon responsbltes to ther sphere of acton. Updatng and montorng the safety requrements of all posts and processes Indcatng correctve actons to any part of the organsaton, actng mmedately on the process and mmnent rsks. Identfyng and loggng problems, provdng solutons and checkng the mplementaton of the solutons Advsng the chan of command and the workforce n general as regards the actvtes of the system. Daly nspecton of the nstallatons and checkng the actons of the workforce n accordance wth the establshed Procedures Inspectng Emergency Installatons Checkng contracts Checkng purchased materals and product data sheets

12 Edton 10 Page 12of 30 Checkng and overseeng hygene assessments Executng the programme actvtes scheduled n the annual targets Preventon Analyst (Contracted Servce) Updatng and montorng correctve measures resultng from the system's actvtes beng mplemented. Assessment of the chan of command s target complance. Preparng, checkng and dssemnatng the programme's documentaton. Conductng nspectons, observatons and ntal ergonomc assessments of the work statons Head of the Medcal Department Plannng and montorng preventve medcne actvtes Performng medcal examnatons Health care dutes as company doctor Nursng staff Health care dutes as nursng staff Performng medcal examnatons Conductng nspectons, observatons and ntal ergonomc assessments of the work statons 5.7 Mantenance and Techncal Offce Dependng on the Producton Dvson Deputy General Drector, apart form the applcable responsbltes descrbed n pont 5.4 for ther area of competence, they ensure that: The best economcally vable technology mprovements avalable are taken nto account when desgnng new nstallatons. All the statutory requrements as regards new nstallatons are met. The subcontracts comply wth the applcable SGSST requrements. 5.8 Personnel Development (Tranng). Dependng on the Organsaton and Personnel Management Drector, apart form the applcable responsbltes descrbed n pont 5.5 for ther area of competence, they have the followng specfc responsbltes: Channellng and structurng the tranng needs of all the personnel that carry out actvtes that affect occupatonal safety, and organsng and montorng the planned tranng actvtes, whle keepng the approprate personnel tranng records. Establshng and promotng the channels that ensure the nput and output nformaton flow 5.9. Purchasng regardng the Preventon of Rsks at Work. Dependng on the Organsaton and Personnel Management Drector, apart form the applcable responsbltes descrbed n pont 5.5 for ther area of competence, they have the followng specfc responsbltes: Ensurng the supply of materals n accordance wth the establshed purchase specfcatons. Informng the subcontractors of the applcable SGSST requrements Correctve and Preventve Mantenance

13 Edton 10 Page 13of 30 There s a Mantenance Department that: In accordance wth a preventve mantenance plan, carres out scheduled nterventons on the parts of the nfrastructure. The scope and frequency of these nterventons are accordng to the crtcal nature of the dfferent parts of the nfrastructure. When so requested by the users, t ntervenes to repar the broken parts of the nfrastructure s such a way that they become functonal agan as soon as possble Of all Employees Pursuant of Artcle 29 of the Preventon of Rsks at Work Act, the oblgatons of the workers are as follows: 1. It shall be the responsblty of each worker to take care as far as possble of hs own safety and health and of other persons whom may affected by hs actons at work n accordance wth the tranng and nstructon gven by the employer. 2. The workers, n accordance wth ther tranng and the nstructons gven by the employer, must n partcular: 1) Use correctly, n accordance wth ts nature and foreseeable rsks, the machnes, apparatus, tools, hazardous substances, transport equpment and, n general, any other means of producton. 2) Make correct use of the personal protecton equpment suppled by the employer, n accordance wth the nstructons receved from hm. 3) Refran from dsconnectng and make correct use of the exstng safety devces or whch may be ftted n the means related to ther actvty or n the places of work where the actvty takes place. 4) Inform mmedately ther drect superor, and the workers desgnated to carry out actvtes of protecton and preventon or, where approprate the Protecton Servce, about any stuaton, whch, n ther opnon, supposes, due to reasonable causes, a rsk to the safety and health of the workers. 5) Co-operate n the fulflment of the oblgatons mposed by the competent authorty wth the object of protectng the safety and health of the workers n the workplace. 6) Cooperate wth the employer to enable hm to ensure that the workng condtons are safe and pose no rsk to the health and safety of the workers. The workforce shall lkewse: Know and comply wth the company's General Preventon Standards, together wth any specfc ones applcable to ther area of responsblty. Receve Preventon tranng and undertake to mplement t Plant Operatonal Commttee (daly Operatonal Meetngs) The Operatonal Commttee s chared by the Plant s Techncal Drector and s made up by the Heads of Department and other managers apponted for that purpose.

14 Edton 10 Page 14of 30 Ths Commttee meets everyday. These meetngs wll nclude aspects of safety and runnng the programme wth tradtonal ssues, such as Producton, Organsaton and Qualty. At least once a month, the Techncal Drector and the Heads of Department wll meet to consder ndvdual aspects of the Annual Preventon Plan and montor target complance, actons arsng from the Programme s actvtes, status of such actons, complance requrements, accdent rates results, general standards comments, etc. In general, ts functon as regards Preventon s overseeng the programme and decson takng regardng any aspects of the latter that other levels of the organsaton have been unable to assume. In partcular, ts dutes and responsbltes wll be: Knowng, dssemnatng, complyng and enforcng safety nstructons and standards. Revewng and studyng the Accdent/Incdent reports and notfy the most sgnfcant potental rsks and where approprate, propose new measures to avod ther beng repeated. Montorng and overseeng complance of the Annual Plan targets, based on the assessment made by the Preventon Department. Montorng and controllng the degree of mplementaton of approved correctve actons, arsng from the Preventon Programme actvtes, accordng to the nformaton from the Preventon Department, and takng decsons n those cases when they have not been able to be taken at other levels of the chan. Montorng repettve anomales detected n the programmed nspectons, accdent/ncdent nvestgatons or other actvtes of the Safety and Preventon of Occupatonal Rsks Programme to detect the basc causes, due to falure n the control of the organsaton and propose general correctve actons to mtgate them, based on the montorng by the Preventon Department. Permanently montorng the status of the CRITICAL POINTS that have been dentfed through the Programme actvtes Operatons Commttee It nvolves a monthly meetng coordnated by the General Manager wth the drectors, durng whch occupatonal health and safety ssues are analysed among other questons Safety Executve Commttee The Safety Executve Commttee s made up as follows: General Manager Operatons Drector Personnel Management Drector Techncal Managers General Preventon Coordnator: GPO Offcers Preventon Offcers

15 Edton 10 Page 15of 30 The Head of Envronmental and Qualty Guarantee wll present when dscussng aspects of Serous Accdents. In general, ther msson wll consst of takng strategc decsons n vew of the mplementaton and results of the Programme. In partcular, ther dutes wll be: Studyng and approvng the Annual Preventon Plans. Submttng the budget tem to carry t out to the Management Commttee. Montor and oversee complance of the targets, based on the assessment made by the Coordnator. Carry out a quanttatve montorng of the degree of mplementaton of the approved actons, together wth the evoluton of the accdent rate, outcome of effectveness or neffectveness of the actons taken. Decson takng n the cases when they have not been able to be taken at other levels of the chan due to the magntude of the acton. Studyng the accdent cause statstcal analyss, whch the Coordnator prepares, together wth the repettve aspects to take general correctve actons and establsh the relevant organsatons and checks to mtgate them. Permanently montor the status of the CRITICAL POINTS that have been dentfed through the Programme actvtes. Take the relevant actons to ensure complance wth current legslaton and nternal operatng standards. Ths meetng shall be held at least once a year. Nonetheless, the management of the company shall be nformed every month of the most mportant aspects of the Preventon Plan durng the monthly meetngs of the Management Operatonal Commttee Plant Health and Safety Commttees The Health and Safety Commttees are the partcpaton jont and collectve bodes amed at the perodc and regular consultaton as regards the Company's rsk preventon actons. Its composton per plant s as follows: Plant Techncal Drector. General Preventon Coordnator: Head of the Medcal Departments. Three Preventon Delegates The GPO Offcer, Preventon Offcer and any ndvdual wth a specal qualfcaton or nformaton shall partcpate, wth the rght to speak but not to vote, regardng specfc ssues that are debated n ths body, provded that ths s requested by any of the members of the commttee.

16 Edton 10 Page 16of 30 Pursuant to Artcle 39 of the LPRL, the competences and powers of the Health and Safety Commttee are to plan and control the preventve actvty of the company. The SAFETY AND PREVENTION OF OCCUPATIONAL RISKS s amed at achevng the greatest effectveness and the full development of the functons and responsbltes of the Health and Safety Commttees. Therefore, the performance of the actvtes fallng under the programme shall be assessed through the nformaton and data that the Preventon Department supples n order to acheve, by means of checks, full complance wth what the Law and Standards establsh wth respect to plannng and controllng the preventve actvty. The decson takng, whether or not urgent, regardng any ssue related to the actvtes of the Programme or any other event that may occur, n relaton to the Preventon of Occupatonal Rsks, shall be carred out by the chan of command and n the last resort by the Safety Executve Commttee. In all cases, the relevant Health and Safety commttee shall be nformed and any resultng suggestons and opnons shall be taken nto account, as far as possble. The functons, responsbltes and operatng standards of the dfferent Health and Safety Commttees are developed n the operatng regulatons of the Health and Safety Commttees (PP.1.1) Intercentre Health and Safety Commttee Every year, pursuant to Artcle 38.3, jont meetngs wth all the members of the Health and Safety Commttees and the Executve Commttee may be 38.3.held at the year end and concdng wth the System Revew by management. It wll be known as the Intercentre Health and Safety Commttee Its msson shall be to ensure the approprateness and ongong effectveness of the Preventon Programme, as well as how to mantan the contnuous mprovement. The Preventon Department's Annual Report and the current annual Preventon Plan shall be used as the medum to carry ths out Of the Montorng and Standards Commttee The composton of the Montorng and Standards Commttee of the Safety and Preventon of Occupatonal Rsks Programme s as follows: T.T.I, S.A. Techncal Drector, Llodo Plant T.T.I, S.A. Techncal Drector, Amurro Plant Acera de Alava, S.A. Techncal Drector General Preventon Coordnator: The msson of the members of the Standards Commttee shall be the desgn, dssemnaton, mplementaton and revew of each of the programme actvtes that result n a programme standard. It may be attended by people from dfferent department affected by the Standards n order to put forward ther comments n order to adapt the standards to ther needs and foster the ntegraton of the chan of command. The msson of the members of the Programme Montorng Commttee shall be to prepare the Annual Preventon Plans and the necessary measure so that they are mplemented. The management s to be perodcally notfed of the acheved complances.. The Commttee shall meet as requred

17 Edton 10 Page 17of Operatng Chart All the nformaton and correctve actons that emerge as the result of the mplementaton of the programme's actvtes shall be transmtted or executed, n general, through the chan of command, n collaboraton wth the operatves, up to the levels establshed n each of the Standards that are developed, as ndcated n the attached operatng chart. Wth the respect to the most mportant ssues, where no acton has been able to be taken n prevous levels, the Plant Operatonal Commttee, or where applcable, the Safety Executve Commttee, receves the nformaton, analyses t and as a result of ths, t may entrust actons to the dfferent departments or sectons. The Health and Safety Commttee, n vew of the evoluton of the mplementaton of the Programme, and pursuant to the Annual Plans may request the takng of preventon actons. These actons are set out n the followng chart.

18 PROCEDURE Nº:PP.01 Date: December Edton 8 Page 18 of OPERATING AND COMMUNICATION CHART (Contnued) PLANT HEALTH AND SAFETY COMMITTEE PROPOSING AND CHECKING MEASURES SAFETY EXECUTIVE DECISION AND C PLANT TECHNICAL MANAGEMENT MONITOR DESIGN PERFORMING POST-ACCIDENT ACTIVITIES REUNIÓN OPERACIONAL DE PLANTA ASESORAMIENTO Y CONTROL PERFOR Start Frst ad Accdent/ncdent nvestgaton Emergency Plan Start: Leadershp Inspectons Tranng Meetngs INVOLVEMENT OF WORKERS AND MANAGERS ANOMALIES REPORT PROPOSED ACTIONS INV DEPARTMENTAL, SHIFT AND SECTION GROUP MEETINGS DEPARTMENTAL, SHIFT AND SECTION GROUP MEETINGS DEPARTMENTAL HEADS. DECISION D PREVENTION COORDINATOR AND DEPARTMENT ADVICE AND CONTROL

19 Date: December Edton 8 Page 19 of SAFETY ACTIVITIES The Safety and Preventon of Occupatonal Rsks at T.T.I, S.A. Acerálava, S.A. comprses the development, mplementatons and montorng of a seres of actvtes that overall consttutes a contnuous operatng and systematsed tool to Prevent and Improve the Management of Health and Safety n the Work Place. Ths programme comples wth the requrements establshed n the OHSAS 1800 Occupatonal Health and Safety Management Systems specfcaton. The developed actvtes am to comply wth the followng ponts of the standards: Polcy Plannng o Hazard Identfcaton, Rsks Assessment and Rsk control. o Identfcaton and Complance of Legal Requrements o Health and Safety equpment supplers o Health and Safety equpment supplers Implementaton and operatng o Structure Defnton and Responsbltes o Tranng, Rasng Awareness and Competences o Consultaton and Communcaton o Documentaton o Controllng data and documents o Operatonal Checks o Preparaton and reacton to emergences Checkng and Correctve Acton o Montorng and measurement o Accdents and ncdents, preventve and correctve acton o Records and Records Management o Audts Management Revew These actvtes are descrbed below: 6.1. Polcy The company has two polces relatng to the preventon of occupatonal rsks. The frst one set out n document PP s the GENERAL PREVENTION POLICY, whch ncludes the undertakngs of the management n relaton to managng health and safety n the work place. The second polcy set out n the preventon of serous accdents polcy document PP establshes the undertakng of the company n the preventon and control of any stuaton that may results n a serous accdent caused by hazard substances regulated n the serous accdent regulatons Hazard Identfcaton, Rsks Assessment and Rsk control Occupatonal Rsks Evaluaton Pursuant to Artcle of the LPRL, the Company has to perform an ntal evaluaton of the rsks for the health and safety of the workers. Lkewse, and on an ongong bass, the hazards are dentfed and the occupatonal rsks are analysed and evaluated n our actvtes, products and servce, whch wll provde the necessary nformaton per work staton so that the Company s n a poston to adopt an

20 Date: December Edton 8 Page 20 of 30 approprate decson regardng the need to carry out correctve measures to elmnate or reduce the dentfed rsks and n such a case regardng the type of measures that must be adopted. The result of the evaluatons and ts contnuous updatng, accordng to the changes and measures that are gong to be taken, allows the ongong control actvtes to control the mplemented occupatonal rsks to be defned, mantaned or mproved: Inspectons, Observatons, Audts, Measurements, Safe Work Procedures, etc. Ths actvty s lad out n the OCCUPATIONAL RISKS EVALUATION AND HAZARD IDENTIFICATION PROCEDURE (PP.16) Rsk dentfcaton and assessment Llodo and Alava plants are affected (n ts hghest level) by the specfc laws on serous accdents SEVESO, Royal Decree 1254/1999, dated July 16 th, accordng to whch measures are approved for control of rsks nherent to serous accdents, and n whch the use of hazardous substances s nvolved, (later modfed by Royal Decrees 110/2005 and 948/2005). In complance wth these regulatons, the company has developed and mplemented the requred documentaton: 1. Polcy for Preventon of Serous Accdents 2. Safety Reports (for each plant) consstng of: Basc Informaton for the Government and Rsk Analyss 3. Self-protecton plans (for each plant) 4. Safety Management System (ntegrated n ths Program for Preventon of Labor Rsks and Safety) PP15 procedure ( IDENTIFICATION AND ASSESSMENT OF SERIOUS ACCIDENTS ) contans gudelne and responsbltes for: Ensurng proper control of any modfcaton whch could affect the control of Rsk of Serous Accdents (prevously to ts mplementaton), lnked to the early dentfcaton of resultng legal requrements. These legal requrements could nclude, as the case may be, the need of updatng and assessng the rsks for serous accdents (Rsk Analyss). Ensurng, moreover, full complance wth all perodcal revsons and nspectons set forth n the applcable regulatons. If modfcatons are related to machnes or facltes (news, subjected to sgnfcant modfcatons or to be restarted after a long shutdown perod) affectng the control of rsk of serous accdents, PP.12 Procedure, Control of procurement of facltes and engneerng 6.3. Identfcaton and Complance of Legal Requrements Access to applcable legslaton s guaranteed by means of recevng and analysng dfferent nformaton sources, whch provdes the company wth a record of applcable preventon legal requrements.

21 Date: December Edton 8 Page 21 of 30 The approprate channels are lkewse establshed for transferrng the applcable legslaton to the people responsble for ensurng ts complance n the Company and for verfyng the complance of those legal requrements. These actvtes are descrbed n further n the LEGAL STANDARDS PROCEDURE (PP Goals and Programme Plannng the Preventve Actvty Plannng the Preventve Actvty. The procedures of the Safety and Preventon of Occupatonal Rsks Programme actvtes defne a serous of actons at the dfferent levels of the chan. The Preventon Department plans these actons n one-year perods and are set out n the so-called Annual Preventon and Safety Plan. Ths plannng ncludes specfc targets, wth approxmate mlestones, assgned managers and perodc evaluaton of the complance wth the set targets. Pursuant to the Preventon of Rsks at Work Act, the draft plans shall be submtted for the comments of the Health and Safety Commttee n order to be subsequently approved by the Management Commttee. The General Preventon Coordnator s responsble for performng perodc evaluatons of the complance wth the targets set n the Plan. Ths nformaton shall be dssemnated to the Operatonal, Health and Safety and Safety Executve Commttees. Some of the ponts that wll be ncluded n the Annual Preventon Plan, but not lmted to, shall be: Strategc corporate target as regards Preventon: % complance wth the Annual Plan, % of ndex reducton, % use of garments, etc. Chan of command complance targets as regards the montorng and control actvtes. Programme standards to be mplemented or revewed. Annual Inspecton Plan (area, nspector groups and frequency) Accdent results standards. Annual analyss of basc causes of accdents. Tranng Plan. Checkng the degree of use of garments and revewng garment charts. Checkng emergency equpment Campagns to be carred out. Emergency drlls and exercses. Preparng toxcologcal data sheets. Montorng and Control Plan of contamnants n the work place. Workers Health Check Plan. Medcal checkups. Group Meetngs Plan and personal contacts. Lst of work to be observed. Allocaton of responsbltes. Safe Work Procedures and Rules to be prepared and revewed. Annual results self-assessment plan. Annual Internal Audt Plan. Etc Establshng mprovement goals

22 Date: December Edton 8 Page 22 of 30 Each year, the preventon coordnator prepares the relevant nformaton for the management to revew the system. Ths nformaton ncludes proposed mprovement targets as regards occupatonal health an safety. As a result of the system revew process, the management approve the specfc mprovement targets as regards occupatonal health and safety, whch as ncluded as an annex to the Annual occupatonal rsks preventon management plan. Lkewse, f the proposed target requre a sgnfcant nvestment, they are also ncluded n the socalled nvestment plan.

23 Date: December Edton 8 Page 23 of Structure Defnton and Responsbltes Pont 4 heren sets out the structure of the occupatonal health and safety management system and pont 5 the man responsbltes. Lkewse, each procedure establshes the people n charge of executng the dfferent actvtes to develop Tranng, Rasng Awareness and Competences Tranng all the workforce n a way that ntegrates safety, qualty and producton s fundamental to acheve greater awareness and tranng n all the tasks that are carred out. In order to acheve ths, the relevant qualfcaton requrements have been establshed n order to undertake specfc actons establshed by the Health and Safety at Work Management System. Programmed tranng sessons are lkewse organsed n the subjects deemed necessary for the dfferent levels of the plant. A tranng plan s establshed each year and ncluded n the Annual Preventon Plan that covers both aspects. In addton to the above, safety tranng s ncluded n the day-to-day job tranng. Workers jonng the company wll receve an ntal ntroducng course, enttled the "Welcome Plan", wth respect to the relevant areas, ncludng Safety. Specal emphass s placed on evaluatng the rsks of the job and complance of the Job Standards and Work Procedures n ther area of competence. Transferred workers or whose work changes wll also be traned n the rsks nherent to the task to be carred out. There wll also be a readjustment perod for workers who return to the post after a long absence. The mplementaton of ths actvty s set out n TRAINING PROCEDURES (PP.05). Actvtes to dssemnate and promote safe atttudes are also organsed as regards shortfalls n occupatonal health and safety that can be mproved by actons and awareness rasng, for example: use of nformaton panels, safety posters, nformaton meetngs, campagns, medcal checkups, etc. These actvtes are ncluded n PROMOTION AND AWARENESS PROCEDURE PP Consultaton and Communcaton Communcaton between the dfferent levels of the Plant plays an mportant role n ensurng that every job s done correctly and that a certan level of occupatonal qualty at the work place s acheved. Therefore, varous cascade communcaton channels have been establshed between the dfferent levels of the chan dealng wth ssues that affect occupatonal health and safety, ncludng such area as, preventon of rsks as regards new tasks to be carred out, mprovng producton process and ther awareness, awareness of accdents and ncdents and ther causes, protecton garments, emergences, safety outsde the workplace, hygene, correctve measures arsng from accdents or safety nspectons, workers suggestons, etc, as well as other area that are consdered to be mportant to ensure that the work s carred out n safe condtons. The members of the chan of command are also n contact wth the workers to provde nformaton, tran or as awareness rasng. These actvtes are descrbed n further detal MEETING Procedure (PP.08). n the PERSONAL CONTACTS AND GROUP

24 Date: December Edton 8 Page 24 of 30 Improvements regardng occupatonal health and safety proposed by the workforce are regulated by means of communcatng potental rsks establshed n the INVESTIGATION AND ANALYSIS OF ACCIDENTS / INCIDENTS / POTENTIAL RISKS PP 03 procedure. The workers consultaton and partcpaton actvtes are managed by settng up the dfferent Health and Safety Commttees dscussed n pont 3 of ths Manual. These commttees are governed by the HEALTH AND SAFETY COMMITTEES OPERATING REGULATIONS PP Documentaton and controllng data and documents The PREPARING AND CONTROLLING THE PREVENTION OF OCCUPATIONAL RISKS DOCUMENTATION (PP.09) lays down the methodology to prepare, approve, dstrbute, amend, control and fle the system s documentaton. Ths documentaton may be broken down nto the followng types of documents: Ths Manual: Document that ams to set out the ntal framework of acton that results n the mplementaton of each of the actvtes of the Preventon Programme. The preventon programme procedures: They are operatonal documents that descrbe tasks, measures and responsbltes requred to carry out the actvtes envsaged n the Preventon Manuel and the General Management's undertaken n the General Preventon Polcy. These procedures comprse the plannng and organsaton of the company's preventve actvty. Safe work procedures: gudes that establsh the work method to be followed, step by step, to perform a specfc task, from the begnnng to the end, ncludng the rsks that exst n each of the steps, ther evaluaton, and the measures to be adopted to elmnate or reduce them. Work staton safety standards: Set of nstructon or rules that must be enforced and whch lay down the occupatonal behavour gudelnes when carryng out tasks, wthout descrbng the actons to be carred out step by step and whch affect the whole workforce (General) or the workforce from one dvson, zone or specfc post (Specfcs), but t does state what must be done and what must not be done, thus foreseeng the majorty of the rsks. When a record s generated as the result of applyng or mplementng a preventon programme procedure that clearly shows the executon of an establshed measure n that procedure, t shall establsh the person n charge of generatng, controllng and flng t Operatonal Checks The company, gven the operatons and actvtes assocated to dentfed rsks, a seres of procedures have been prepared that allow the rsk stuatons generated when mplementng these actvtes to be controlled and whose absence may result n dfferences from the polcy, and the occupatonal health and safety target. Pursuant to ths crtera, there s the followng documentaton: Coordnaton of contracts corporate actvtes The COORDINATION OF CONTRACTS CORPORATE ACTIVITIES PP.13 procedure ams to defne the actons to be taken to ensure the best coordnaton and the best control possble regardng the executon of works, assembles, repars, etc., carred out by workers of other companes, contracted for that purpose, to ensure that the establshed work procedures and standards are respected at any gven moment n order to guarantee the safety of the workers and the nstallatons and the safety of contracted workers. Ths coordnaton and control s contemplated and executed, by dfferent levels of responsblty, from the moment of desgn the project, subsequently pror to carryng out the work, durng ts executon and development and ts completon.

25 Date: December Edton 8 Page 25 of 30 Lkewse, the carryng out of extraordnary tasks that requre other non-standard actvtes s regulated. Such actvtes may nclude: perodc meetngs between the companes, presence of preventve resources and appontment of the preventve coordnator Purchased materals audt The PURCHASED MATERIALS AUDIT PROCEDURE 12.1 establshes the methodology to be followed n order to control the health rsks for the whole workforce that may result from acqurng and handlng materals. Supplers of chemcal products wth rsks of toxcty, flammablty, etc. are requred to provde the safety data sheet wth the necessary nformaton to control the health rsks. Ths safety data sheet s dstrbuted to the people handlng t. Lkewse, the responsbltes are establshed to guarantee the correct dentfcaton, handlng and storng of the dfferent purchased products Loadng, unloadng and transportng hazardous goods The exstence of hazardous merchandse subject to road transport regulatons (ADR) oblges the company to establsh systems to control the loadng, unloadng and handlng of those goods. The LOADING, UNLOADING AND TRANSPORTING OF HAZARDOUS GOODS PROCEDURE PP has been prepared n order to comply wth ths oblgaton. Ths procedure also ensures complance arsng from the oblgaton to have a Safety Advsor who s responsble for advsng the company on the operatons relatng to the transportng of hazardous merchandse and for checkng the fulflment of the applcable rules Engneerng and Purchasng Audts Wth respect to any major purchase, any project nvolvng new equpment and/or nstallatons, as well as any modfcatons to the exstng ones (materals, nstruments, processes, etc,), the departments n queston, whch nclude Preventon, shall establsh a seres of requrements to be met that are consdered throughout the project and ther mplementaton verfed as a requrement pror to ther beng commssoned. The mplementaton of ths actvty s set out n ENGINEERING AND PURCHASING AUDITS PROCEDURE (PP.12) Mantenance Checkng and mantanng crtcal nstallatons from the safety pont of vew are controlled pursuant to the Mantenance Plan ncluded n "CORRECTIVE AND PREVENTIVE MAINTENANCE PTX Indvdual Protecton Equpment Once the concluson has been reached that the only way to reduce the rsk exposure s to use an ndvdual protecton tem, that tem s to be provded to the workers at the post. Safety s to be combned wth the best comfort, wherever possble, whle always complyng wth current legslaton. Personal protecton garment charts are to establsh the mandatory and recommended ndvdual protecton equpment to mnmse the consequences of the exstng resdual rsks at the work staton.