ACCIDENT PREVENTION POLICY, SAFETY AND PROTECTION OF HEALTH AND ENVIRONMENT DOCUMENT OF ESSECO SRL (In compliance with Art. 2 of Ministry Decree of August 09, 2000) Page 1 of 6
1. INTRODUCTION The ESSECO S.r.l. plant in San Martino di Trecate is within the scope of the European Directive 96/82/EC (also known as Seveso II), adopted in the Italian legal system by the Legislative Decree no. 334 of August 17, 1999 as subsequently amended, pertaining to the presence and presence in excess of threshold limit values of the following substances: Sulphur dioxide (toxic) Aqueous Ammonia (dangerous for the environment) Oleum (reacts violently with water, causing release of toxic sulphur trioxide) and presence, below threshold limit values of: Cryogenic oxygen (oxidising agent) Anhydrous ammonia (toxic) present on-site only for the duration of off-loading of road deliveries. This Corporate Policy and the Safety Management System (SMS) developed by the Plant Manager apply to the processes and activities carried out by ESSECO S.r.l. at the Trecate Plant and to the development, production and sale of chemicals for use in industrial, agricultural and food industries. 2. FUNDAMENTAL PRINCIPLES Pursuant to the requirements of Legislative Decree no. 334 of 1999, ESSECO S.r.l. adopts the fundamental principles of directive 96/82/EC, which states that the safe operation of a production plant shall be ensured by a combination of management policies adopted when integrated with the worker's health protection aims, set forth in Legislative Decree no. 81/2008 as subsequently amended, and by the environmental provisions set forth in Legislative Decree no. 152/2006 as subsequently amended. The Safety Management System (SMS) has been developed pursuant to regulation UNI 10617: 2009, and is formalised via this document; the SMS Manual; and the Operational Procedures/Instructions. The SMS is integrated with the Quality Management System (QMS) developed pursuant to the UNI EN ISO 9001:2008 and the Environmental Management System (EMS) developed pursuant to UNI EN ISO 14001:2004. The overall systems structure is described in Section 5 of this document. The processes and procedures described in the SMS Manual and related documents have been assessed and are deemed appropriate to the risk scenarios defined. Approval and issue of documents related to prevention and control of relevant accident scenarios, together with the protection of workers, the general public and environment are the responsibility of the Plant Manager. Any modification to the System caused by changes in regulations, classifications, risks or hazards associated with the substances listed in the introduction may require a review of the relevant documentation. ESSECO S.r.l. promotes cooperation with the Supervisory Bodies and the relevant Competent Authorities to encourage mutual understanding, exchange of information, development of common emergency procedures and optimisation of checks to be carried out, adoption of the requirements and observations of the Supervisory Bodies and Competent Authorities. The Company also considers the attitude of its Employees with respect to Safety regarding the prevention of major accident hazards; protection of Environment; and Worker Health and Safety as an essential element in evaluating their professionalism. In 2009 ESSECO S.r.l. adopted an Organisation and Management Model in order to prevent those offences referred to in Legislative Decree no.231 of 2001 (corporate crimes, crimes against public administration, crimes against people, handling stolen goods, laundering of money or assets of illicit origin). The Company believes that adopting this Model, while at the same time issuing a Code of Ethics, represents a valuable addition tool in raising awareness Page 2 of 6
of all employees and stakeholders for the purpose of ensuring that the behaviours adopted are correct, proper and in line with the ethical and social values of the Company and will prevent the risk of committing the crimes described in the Decree. 3. GENERAL OBJECTIVES ESSECO S.r.l. is committed to developing its corporate mission whilst preventing accidents, occupational illnesses and pollution, by maintaining constant focus on its safety performance in; preventing risks of major accident hazards maintenance of health and safety at work maintenance of environmental performance To this effect, this Policy has been defined, documented, authorised and implemented in accordance with the following references: Legislative Decree no.334/99 and subsequent amendments Ministerial Decree of August 9, 2000 Legislative Decree no. 81/08 and subsequent amendments Legislative Decree no. 152/2006 and subsequent amendments. UNI EN ISO 14001:2004 UNI 10617:2009 The Company acknowledges that research and obtaining the highest levels of industrial safety and protection of health and the environment are of utmost importance, with its performance in these areas key to the overall success of the company s management. The Company also recognises that responsibility for the prevention and management of major accident hazards and protection of safety health and environment lies with every employee in the organisation, according to their individual roles and responsibilities. The Company's strategic and highest priority objectives are as follows: the prevention of risks to safety, health and the environment, with particular attention to the prevention of major accident hazards pursuant to Legislative Decree. no. 334/99, associated with hazardous substances in the production processes the minimisation of all impacts resulting from incidents via accurate, timely and proper application of the required protection measures safeguarding the health of the workers, customers and the general public environmental protection, focused on preventing pollution and saving energy ensuring the quality and safety of its products The Company's Policy relating to the prevention and control of relevant risks, workplace health and safety and the environment requires that all these objectives have been developed, implemented and maintained through systemic management of safety, health and the environment, in compliance with the fundamental principles of EU, national and local legislation and Company requirements. The Plant Manager shall ensure that this Policy Document is kept up to date and is always appropriate to the nature and scale of major accident hazards and the activities products and Page 3 of 6
services provided by the Company. It should be reviewed and revised at least once every two years to ensure that it provides an on-going framework for setting and reviewing objectives for safety, health and environmental protection. It should take into account changes in circumstances, legislation and knowledge, thus ensuring it remains meaningful and appropriate to the Company. 4. PLANT MANAGER'S COMMITMENT In order to achieve the objectives of the policy for safety, health and environment policy the Plant Manager will: develop, implement and maintain a suitable and effective Safety Management System, fully integrated with an appropriate Environmental Management System for continuous improvement of Health, Safety and Environmental issues as an integral part of the Company s management system and which are implemented through formalisation issued procedures, the planning of the relevant objectives and the implementation of audit programmes to verify the system regard prevention of major accident hazards, health and safety at work and environmental protection as an integral part of company management and to provide the financial, human and material resources required to achieve corporate objectives and continuous performance improvement ensure full compliance with EU, National, Local and Company provisions on workplace health and safety, as well to all commitments related to voluntary programmes in these areas identify the hazards and evaluate the risks related to the activities of the Site, with reference to the provisions of Legislative decree no.334/99 and Legislative decree no. 81/2008 and subsequent amendments.; perform risk assessments designed to identify, implement and maintain safety measures appropriate to prevent incidents and to minimise the consequences and limit the effects of the incidents, keeping them within reasonable limits compatible with safety for the employees and the general public and the protection of property plan, implement, monitor and maintain systems, production processes and ways of working, to ensure compliance with accident prevention measures. Furthermore the Plant Manager shall employ suitable technical, organisational and management resources and all reasonable measures to achieve the Company s safety, health and environmental objectives define the requirements for provision of information, education and training to all employees of the Company and third parties present on the Plant so that they are aware of potential risks related with the activities being performed on the Site and can therefore act responsibly develop and implement measures designed to guarantee that third parties working on Site adopt behaviours, practices and standards consistent with the principles of this Policy involve the Company s employees and the employees of third party Companies working in the Company premises in specific training events designed to share the objectives set out in this Policy Document. Ensure that employees are aware of the Health and Safety Policy of the Company ensure the availability of appropriate personal protection equipment (PPE) and that it is used correctly ensure that Emergency Action Plans, Safety Equipment and Alarm Systems are available and that employees and other personnel are trained in their use in the event of a major incident within the Plant or the Industrial Complex of Page 4 of 6
S. Martino di Trecate ensure that employees are consulted and involved as appropriate through the their safety representatives educate and inform employees on environmental protection regulations and policies in order to promote "environmentally responsible" behaviour periodically review the Company's performance in the management of incidents, workplace health and safety and environmental risks perform internal audits to continuously verify the efficiency and effectiveness of the Management Systems adopted In addition to the general commitments described above, details are given below of the specific activities that ESSECO S.r.l. shall perform in order to achieve the Company s objectives associated with safety of equipment and products sold, protection of workers' health and safety and environmental protection. Ø SAFETY OF EQUIPMENT AND PRODUCTS SOLD define and purchase of equipment and devices featuring suitable safety systems that are fit for purpose and that meet the standards for workplace safety implementation of suitable programmes of inspection and maintenance of plant and equipment to ensure safe and proper on-going use conduct studies to identify and maintain safe conditions for the manufacture, handling, transportation, use and disposal of the products provide customer support in the application of safety measures required for manufacturing, handling, transportation, use and disposal of the products Ø PROTECTION OF WORKERS' HEALTH AND SAFETY promotion of research, development and implementation of measures required to protect health implementation of regular health monitoring, to ensure the on-going wellbeing of the workforce is maintained and that the use of PPE continues to be effective zero tolerance on the use of alcohol and drugs by all employees during work, and outside of work when this could in any way effect their routine duties Ø ENVIRONMENTAL PROTECTION manage the plants to protect the environment and ensure the safety of the surrounding community and general public by implementing operational measures to guarantee the safe operation of the site and provide the ability to respond effectively to incidents increase the knowledge of production processes and of products with respect to their impact on the environment reduce the environmental impact of production activities e.g. emissions to atmosphere, generation of waste waters and solid waste, by adoption of appropriate measures for example using less raw materials, energy recovery and increasing process efficiency use of the Best Available Technologies (BAT) as required by Legislative Decree no. 152/06 as subsequently amended monitoring and maintain awareness of suppliers to ensure that purchases are Page 5 of 6
made preferentially from those suppliers whose corporate policies support those of the Company s in order to aid achievement of the Company s objectives establish and maintain an open and honest dialogue with all the stakeholders, paying specific attention to communication to staff of the Company s environmental objectives and performance commitment to disseminate this Policy to all employees and third parties working for the Company and to make it available to the general public and other stakeholders improvement in the use of energy resources and raw materials through saving and recovery, measured by monitoring consumption implement specific on-site and off-site Emergency plans and procedures to enable a systematic control of all possible emergency situations reduction and control of the most significant impacts 5. STRUCTURE OF THE SAFETY MANAGEMENT SYSTEM In order to achieve the general objectives described in this document and ensure compliance with the fundamental principles adopted, ESSECO S.r.l. has structured its Safety Management System through the following documents: This document, also containing the SMS Improvement Programme (2012-2013) SMS Manual, whose structure follows the template of Annex III of Legislative Decree no. 334/99 and subsequent amendments Initial Environmental Assessment as required by UNI EN ISO 14001:2004 SMS Procedures. Other procedures and Operating Instructions: Quality assurance management procedures, Plants and systems manuals, area procedures, operational safety instructions. San Martino di Trecate, June 2012 ESSECO S.r.l. Page 6 of 6