HES POLICY/MANUAL

Table of Content

                                                                                                                   Page

1.0            Introduction                                                                                         4

2.0            HES Management System                                                               5

3.0            Health, Environmental and Safety (HES) Policy                           6

4.0            HES Organization and Responsibilities                                         7      

5.0            Mobilization of Personnel Equipment and Material                     11

6.0            HES Meetings, Communications & Consequence

Management  13

7.0            Training                                                                                               15

8.0            Inspections and Audits                                                                     16

8.1       Incidents/Accidents Reporting and Investigation                    16

8.2       Environment Protection Management                         16

9.0            Health Facilities and Occupational Health Management                    17

10.0         Safety Management                                                                           17

11.0         Sub-Contractors HES Management                                                17

12.0         Leadership and Commitment                                                           18

13.0         HES and Community Affairs Plan                                                   18

13.1         Policy and Strategy                                                                 20

13.2         Community Affairs Policy/Strategy                                       21

13.3         Safety Policy/Strategy                                                             22

13.4         Health Policy/Strategy                                                 23

13.5         Environment Policy/Strategy                                                 24

13.6         Security Policy/Strategy                                                        25

13.7         Policy Objectives                                                                     27

14.0         Standards                                                                                 27

14.1         Documentation System                                                           27

14.2         Planning and Procedures                                                      28

15.0         Targets and Objectives                                                                   29

15.1         Project Specific Tasks and Targets                                      30

15.2         Health                                                                                      30

15.3         Environment                                                                            31

16.0         Hazard and Effect Management Process (HEMP)                    32

17.0         Road Transportation                                                                        32

Page

17.1     Vehicle Requirement                                                                            32

18.0         Interfaces with CNL/Sub-contractors                                         33

19.0         Performance Monitoring                                                                 34

20.0         Incidents and Accident Reporting Investigation                        35       

21.0         Occupational Health and Safety Organization Chart                36       

22.0         HES Incentive/Recognition Program                                            37

23.0         HES Goals and Targets Set and Tracked                                     37

24.0         HES Inspection and Audit                                                               37

25.0         Drug and Alcohol/Substance Abuse                                             38

26.0         Respiratory Protection                                                             38

27.0         Hearing Conservation Program                                                     39

28.0         Short Service Employee Program                                                40

29.0         Behavioural based Safety Program                                              41

30.0         Fall Protection/Working at Heights                                              42

31.0         Permit-To-Work System                                                                   43

32.0         Pre-Task Planning                                                                             44

33.0         Portable hand Tools –Electric & Pneumatic                                45

34.0         Signs and Barricading                                                                     46

35.0         Unsafe Condition Reporting                                                           47

36.0         Journey Management (All forms of Personnel & Equipment) 48

37.0         Task Specific Procedures                                                              49

38.0         Scaffolding Procedures                                                                  50

39.0         Equipment and Work Area Auditing                                              51

40.0         Fire Prevention/Protection                                                             52

41.0         Compressed Gas Cylinders                                                             53

42.0         Emergency Response/Evacuation                                                54

43.0         Housekeeping                                                                                    55

44.0         Job Safety Analysis                                                                         56

45.0         Personal Protective Equipment & Dress Requirements including

Face and eye protection                                                                     57

46.0     Welding and Cutting Torch                                                                 58

1.0       INTRODUCTION

The work being performed under any project with Client involves activities necessary to ensure the successful completion of the project.

This HES plan is a guideline to the attainment of the goal stated above.

2.0       HES MANAGEMENT SYSTEM

PURPOSE

The HES management system is to define the company’s organization, policy and objectives, responsibilities of all personnel, systems/methods and programs to achieve set targets which aim at eliminating injuries/accidents, occupational illness and damage to the environment.

The HES plan, which shall be derive from this document, will be established on yearly basis. The plan is to detail specific targets/ceiling and strategy to achieve them.

            3.0       Health, Safety and Environment  (HES) Policy

It is the policy of JOSWAC that its operation should be carried out at all times in such a way as to ensure that health, safety, environment and security of its employees and all persons likely to be affected by its operation, including sub-contractors, clients and the general public are safe guarded and that the same dedication will be shown to the protection and conservation of the environment. This policy is the direct responsibility of the company’s Managing Director who is responsible for the overall implementation of the policy.

Within JOSWAC Health, safety, Environment and Security (HES) is a line management responsibility for which individuals will be held accountable and it is recognized that implementation by line mangers of the policy will lead to a greater efficiency and higher standards throughout all departments within the company.

The duty of all employees is to reasonable care of their own safety and that of others who may be affected by their acts or omissions as clearly stated by government acts and to this end, JOSWAC will encourage and support each employee in every way to ensure that the aims of these laws are met.

JOSWAC is committed to work within the regulations and codes of practices lay down by government agencies, and will liaise closely with all government department as well as professional and academic bodies to ensure improvement of all HES regulations.

It is the company’s policy to sustain the appropriate training for all her employees and contractors personnel to ensure that her procedures and government regulations are known and observed.

Contractors working for or on behalf JOSWAC will be required to work under the same policies and standards.   

4.0       HES Organization And Responsibilities

The personnel responsible for managing HES on any (JOSWAC ) project and their responsibilities are as follows:

Managing Director

The Managing Director is ultimately responsible for the successful implementation of the HES management system. The HES Coordinator reports directly to the Managing Director.

Admin/Personnel Manger

·        Reports directly to the Managing Director and is responsible for office administration, recruitment, accommodation and catering facilities.

·        Ensure that the facilities and personnel in the offices and accommodation meet the HES standards for the project.

·        Ensure that daily execution of work by the administrative section is in line with the HES policy, Standards and procedures.

·        Ensures that enough resources are channeled towards emergency preparedness in the office and living accommodation.

·        Participate in the review of HES performance.

Project Manger

·        To ensure that the HES policy and procedures are prepared, issued and implemented.

·        To ensure that enough resources are provided for the full implementation of the HES plan.

·        To monitor set targets periodically vis-à-vis performance to achieve overall project objective.

·        To lead and participate in audits and inspections.

·        To set up incident investigation team, according to severity.

HES Coordinator

·        Reports directly to the Managing Director on all matters concerning Health, Safety and Environment.

·         Advise on the establishment and maintenance of HES plan and procedures for safe execution of projects.

·        Advise on the provision of resources for full implementation of HES plan.

·        Selection and training of HES personnel.

·        Advise on the organization of training of personnel at the task level on HES aspect of the project. Establishment and maintenance of HES training database.

·        Ensure that all necessary HES procedures and instructions are available and followed by personnel.

·        Instigating the conduct of periodic HES audits and coordination of all follow-up actions.

·        Periodical inspection of project facilities to ensure compliance with HES requirements.

·        A member (secretary) of incident investigation team.

·        Advising on the provision of resources for and instigation of emergency response drills.

·        Verify with site HES officer and supervisor the competence, adequacy and direction of all project employees.

·        Participate in all safety training session and ensure that a record is kept that all project employees have received the necessary training.

·        Prepare monthly reports highlighting safety activities, accidents, safety infractions, safety statistics and analysis as well as actions taken to correct safety problems.

·        Conduct investigation of all fatal loss time, accidents, significant first aid cases, near misses or damage to property or equipment.

Community Liaison Officer (CLO)

·        Implementation of the CA/CR plans and achievement of targets.

·        Avoid disruptions and disturbances to work due to community related issues.

·        Establish and maintain effective and reliable systems of controlling response to community complaints and dispute resolution.

·        Ensure JOSWAC personnel have a clear understanding of community affairs issues, their responsibilities and established procedures.

·        Ensure that the host communities’ benefit in procurement and the use of their services in maximized in their areas of competence in the award of local contracts.

·        Ensure proper employment of indigenous personnel in accordance with CA/CR plan.

·        Maintain a central log of all community affairs issues raised and keep our client informed of such issues and their resolution.

·        Interface through our client community affairs department with the project affected community, chiefs etc.

·        Community Liaison Officer will assist the HES Coordinator in performing his duties.

Supervisors

·        Report to the Project Manager as regards the execution of work in their different disciplines in line with the overall project HES objectives.

·        Ensure that all necessary HES procedures and instructions are available and followed by personnel.

·        Ensure that all staff have clearly defined HES task and targets review the individual performance against these.

·        Ensure the daily jobs are done in compliance with the HES management system.

·        Carry out job hazard analysis and ensure dissemination of results via toolbox meetings.

·        Ensure staff attends regular HES meeting.

·        Conduct training needs analysis for staff and ensure such staffs are scheduled for necessary training courses.

·        Ensure that enough resources are provided in their different disciplines for emergency response management.

·        Ensure staffs participate fully in emergency drills, monitor effectiveness of procedures and give useful suggestions.

·        Participate in audits, incidents/accidents investigation.

·        Participate in the review of HES performance.

·        Stop any unsafe activity observed.

Site HES Officer

·        Exhibit safe behavior in compliance with the HES plan as an example for other employees.

·        Assist to provide JOSWAC line managers and supervisors with toolbox meeting subjects that are applicable to the work planned for execution in the near term.

·        Perform continuous safety inspection at the job sites.

·        Prepare weekly and monthly reports to the HES Coordinator highlighting safety activities, accidents and safety infractions, safety statistics and analysis as well as actions taken to correct safety problems.

·        Provided access identification badges to all employees and sub-contractors.

·        Ensure implementation and compliance with all security issues.

·        Monitor and report all environmental concerns on their job sites.

·        Monitor safety and environmental activities for project compliance especially in consistent use of PPE and proper housekeeping.

·        Maintain and monitor with the supervisor employees log register on site.

·        Disseminate all security information to the relevant personnel.

·        Assign responsibility to all security personnel on different job locations.

·        Report all security matters to the HES Coordinator.

·        Assist in the investigation of incidents.

·        Stop any unsafe activity observed.

Technicians

·        Familiarization with the company safety and accident prevention program. Must be knowledgeable of and comply with major regulations and codes applicable to job title.

·        Enforce established safety regulations and work methods. Assures that proper tools and safety equipment are provided to perform the work. Take disciplinary action necessary to ensure compliance with rules.

·        Instill by action, example and training a sincere safety attitude with fellow employees.

Employees

·        Employees must follow safe procedures and take an active part in protecting themselves and their fellow workers. Working safely is a condition of employment.

·        Employees must make safety art of their job by following safety rules and regulations taught in the indoctrination and pep talk/toolbox meetings.

·        Employees are expected to report to the HES officer and their supervisors’ hazardous conditions, practices and behavior in their work areas and are invited to make suggestions for their prevention/correction.

·        Attend all scheduled HES meetings and programmed courses.

·        Achieve individual HES set targets.

            5.0       Mobilization of personnel, equipment and materials.

5.1       Personnel

All personnel shall be subjected to the following procedures before being allowed to commence work on site.

·        Pre-placement screening for competence and requisite experience to be conducted by the different discipline heads.

·        Medical fitness test to ensure that the personnel are medically fit to do work for which he/she is being employed without further jeopardizing the health of the worker or of other employees.

·        Initial HES induction course which is basically the first in the series of HES training to which every employee shall be subjected. In this induction, the following shall be taught:

a.     Company HES policy.

b.     Basic HES rules

c.      Policy on PPE, types required and their use.

d.     Site layout, jobsite rules of personal safety, security and conduct.

e.     Environmental pollution prevention.

f.       Emergency response procedure.

g.     Muster points.

h.     Incidents/accidents/unsafe acts reporting.

i.       Policy of toolbox meeting and pep talk.

j.       Smoking/drugs/alcohol policy.

k.      PTW system and procedure.

l.       HES incentives/disciplinary measures.

5.2       Equipment

To minimize accidents resulting from equipment, all equipment that will be used on any project being executed by JOSWAC shall be subjected to pre-mobilization inspection by the HES Coordinator and witnessed by client if required. This shall be done making use of some equipment inspection checklist is a comprehensive questionnaire. It covers all aspects of HES requirements, operational techniques, and maintenance/inspection log for the equipment.

5.3       Materials

The HES Coordination shall inspect all materials being mobilized to the site. The hazardous ones must not be mobilized without the material safety data sheet (MSDS).

6.0       HES Meetings, Communications And Consequence Management.

6.1       Meetings

HES meeting shall be a regular feature on site. Several types of meeting shall be convened as the need arises but the regular ones shall be:

a)     Management HES meetings.

b)     Toolbox meetings and Pep talk.

c)     General review meetings.

a)     Management Meetings.

This shall be convened on a monthly basis and presided over by the project manager. The agenda for the meeting shall include review of the implementation of the company policy, review of the minutes of general meeting (and status of actions arising there from), HES performance scorecards among other things.

b)     Toolbox Meeting and Pep talk.

Toolbox meeting and pep talk shall be held on daily basis before start of work and shall last between 5 to 10 minutes. The toolbox meetings shall be convened with each work group and presided over by the supervisor or foreman, while pep talk would be presided over by the HES officer. The agenda shall be discussion of the day’s work, inherent hazards and prevention of accidents.

c)     General Meetings.

This shall be convened on a monthly basis. Attendance shall be mandatory for all staff and agenda shall include the review of performance in the past month and other matters.

6.2       Communication

HES suggestion boxes shall be located at strategic positions on site. This shall enable staff to air their views or make useful suggestions.

Aside from meetings, HES information shall be communicated to workforce through memos/newsletters, performance scoreboard and slogans. Detailed statistical performance shall be communicated to client, corporate management and work force on a monthly basis.

6.3       Consequence Management

6.3.1    Motivation

     There shall be an award in terms of HES every six months. Prizes shall accompany this award.

6.3.2    Disciplinary action

Disciplinary measures as a means of controlling HES violation will take the form stated below:

·        Prompting / counseling.

·        Award of unsafe act ticket on persistent refusal to change.

·        Management warning letter.

·        Suspension without pay.

·        Termination of appointment.

7.0       Training

A project is always in a state of change. The job site and personnel change as the work progresses. JOSWAC will ensure that the basic types of information and training required by all employees, supervisors and visitors are provided prior to the start of work and throughout the project.

This requirement will be met through verification of previous experience, on the job orientation and training. All supervisors shall be trained in their responsibilities and their HES responsibilities.

In addition to the HES induction course, further specific HES training shall be given to selected personnel. The HES training will be integrated into the craft training program and HES certificate of attendance will be issued to all staff who has attended safety-training courses.

8.0       Inspections and Audits

HES coordinator and supervisory staff shall carry out site inspections and audits on a regular basis. These audits will determine the level of compliance with HES goals and procedures for the project and will note all non-conformances. Corrective actions for all non-conformances will be given in the audit report. Also once hazard is observed, it shall be promptly corrected. Hazard identification report and register shall be used to monitor actions to prevent the reoccurrence of such hazard till closure. Serious incidents will trigger a non-scheduled audit. It is the goal of JOSWAC in any project to close out and/or implement all negative audit findings within five days.

8.1       Incidents/Accidents Reporting and Investigation

Accidents/incidents/near miss reporting is an essential ingredient of the HES policy. It shall be explained to all staff in their basic induction program.

8.2       Emergency Response Management

Contingencies developed for the various types of emergencies shall be put in place on mobilization. Procedures for all types of emergencies shall be communicated to all staff. There shall be regular drills to test the efficacy of the procedures.

8.3       Environment Protection Management

Every effort shall be made to minimize adverse impact of our activities on the environment. From the pre-mobilization inspection of equipment, the adverse impact of such equipment on the environment shall be spotted and mitigating factors put in place. A regular check of this equipment shall be conducted to ascertain that their pre-mobilization status is being maintained.

All employees will receive environmental awareness training in the initial induction course, and a number of restrictions made known. There shall be full procedure on the management of wastes in line with Federal Ministry of Environmental guidelines.

9.0       Health Facilities and Occupational Health Management

There shall be retainer clinics and first-aid stations in the facility or site. All offices, workstations, residential and catering facilities shall have a minimum health standard for human usage.

All personnel shall undergo pre-employment medical examination with special emphasis on physical fitness and personal hygiene.

There shall be adequate supply of wholesome drinking water and this would be readily accessible to all workers.

There shall be regular education of workers on personal hygiene and prevention of diseases.

10.0     Safety Management

Every effort shall be made to ensure that any project executed by JOSWAC is performed in a manner that will limit the risk of injury to persons or property damage. All personnel operating machines and equipment shall be certified competent and experience enough for the work they are to do.

Pre-job hazard analysis shall be carried out regularly by supervisors and discussed with all workers before work commences. Aside from the induction training, the training needs analysis of all personnel shall be done and adequate training given for continuous improvement.

All personnel shall be fully equipped with basis Personal Protective Equipment (PPE). Other PPE’s shall be provided also according to need.

All non-routine jobs to be carried out in the facilities shall be carried out in line with Permit to Work system of client.

There shall be several procedures for safe performance of work and the client procedures strictly adhered to.

11.0     Sub-Contractors HES Management

All sub-contractor shall work in line the company’s policy and standards. Pre-mobilization inspection audit shall be carried out on all sub-contractor to ensure they meet the company standard before they are allowed to mobilize t site. This inspection shall include office place, workers and equipment. Only sub-contractors that meet the minimum requirement shall be mobilized. Periodic audits shall be carried out on all sub-contractors to ensure implementation of the company policy and standards.

            12.0     Leadership and Commitment

To show and demonstrate management commitment to HES, the Managing Director as well as other top mangers shall embark on site visit once in every two months. The findings of such visits shall be documented and discussed in management HES meetings. All areas that require urgent action during the inspection will be addressed and closed out.

13.0     HES AND COMMUNITY AFFAIRS PLAN

General

The purpose of this HES plan is to provide a framework to implement the activities required to achieve the goals of the policy statement. This framework if for:

·        The formal identification and assessment of hazards and CA issues during project execution together with the steps taken to eliminate them or otherwise control them, and in the event of failure, recovery procedures.

·        The implementation of HES policies and procedures.

The identification and assessment of hazards and techniques for this purpose, as well as management system criteria are defined in this HES plan and relevant client’s regulations. This would be applicable to any project would be executed by JOSWAC presently or in the near term.

JOSWAC will comply with all appropriate Nigerian Federal, State, and Local legislation, Standards and codes during project execution.

            13.1     Policy and Strategy

HES Policy

Community Affairs, safety, Health, Environment and Security (HES) Policy

JOSWAC is committed to executing her projects in such a way to ensure a safe and healthy work environment for all employees, and the safety of persons likely to be affected by its operations. This policy is the direct responsibility of the management who is accountable for the overall implementation of the policy. This will be achieved by maintaining proactive programs designed to prevent injuries and related incidents, and a project goal of ZERO INCIDENTS. Project objectives are to:

·        Maintain a prevention based HES program.

·        Safeguard the environment.

·        Cooperate fully and support the communities in which we operate by respecting property and, to the extent possible, providing business opportunities and job to local citizens.

All managers and supervisors are responsible for promoting the highest standards of safety and must be committed to developing, maintaining and enforcing appropriate systems, plans and procedures to achieve the objectives of this HES policy.

The following principles guide project actions in all areas of operation:

·        People are the company’s most important asset

·        All incidents and injuries are preventable

·        All risks can be controlled

·        Safety, positive community relations, environmental protection ad security are line management responsibilities.

·        Management has the responsibility to train employees to work safely and to develop a “work safe” culture.

·        Working safely is a condition of employment.

·        No task is so urgent that it cannot be performed safely.

·        Working safely makes financial sense.

This policy requires that:

·        Managers and supervisors shall ensure compliance with the safety, health, community affairs and environmental rules, laws and regulations as they apply to their respective operations.

13.2     Community Affairs Policy/Strategy

It is JOSWAC’s strategy to pursue mutually beneficial relationships with her host communities. To achieve this goal JOSWAC shall continue with the use of a Community Liaison Officer (CLO) who will interface with the CNL area Community Liaison Officer (CLO). JOSWAC Community Liaison Officer (CLO) shall cooperate with CNL Community Liaison Officer (CLO) to ensure to ensure that the local communities are aware of and approve of JOSWAC activities and to ensure that any conflicts are resolved in a timely manner. The Community Liaison Officer will report directly to the Managing Director.

            The strategy will be to:

1.     Establish projects-specific Community Assistance / Community Relations plan that takes into cognizance the peculiar circumstance of each host community.

2.     Focus on community assistance that has a long-term impact and benefit a broad spectrum of host population.

3.     Alleviate the negative impact of our operations on the inhabitants of the host communities.

4.     Establish and maintain effective communication with all segments of the host communities in order to understand them and try to address their needs.

5.     Respond to complaints and suggestions from the host communities in a timely manner.

6.     Encourage staff and sub-contractors to be sensitive to the needs of host communities.

13.3     Safety Policy/Strategy

JOSWAC aims at ensuring that risks to personnel and equipment involved in the execution of projects are identified, assessed and controlled to zero and that recovery measures are in place if otherwise. A system of incidents and accidents reporting will be implemented. See procedure as PROJECT-HES-DOC-010.

The strategy is as follows:

1.     Fire fighting, first aid and other such training that may be required by client will be given to staff, accepting assistant from client whenever possible.

2.     Pre-mobilization inspection shall be carried out on all JOSWAC equipment. (Offices and accommodation, if applicable)

3.     JOSWAC  journey management procedure (see PROJECT-HES-DOC-002), which will include testing and selection of drives, route mapping to facilitate planning and tracking of crew movement, training and re-training on Defensive Driving Course (DDC) and daily driving hazard analysis will be followed.

4.     Job hazard analysis shall be performed for all critical activities during project execution and this will compliment toolbox and pep talks. These will be documented as evidence of compliance of safety requirements. Daily inspections and random audits will be carried out on all work areas.

5.     A team of JOSWAC and client’s representatives will carry out scheduled audits.

6.     All personnel on project shall wear appropriate Personal Protective Equipment (PPE). As a minimum, project personnel will receive safety shoes, coveralls and hardhats. Specific task may require additional PPE as indicated in the project procedures.

7.     CNL Permit to Work system shall be strictly adhered to.

8.     Muster points will be located for each project site and base office area.

9.     All JOSWAC personnel and visitors will receive a safety orientation and special training to assure that they can perform their duties safely.

13.4     Health Policy / Strategy

JOSWAC is to operate a healthy workplace with no health incidents and to improve the health awareness of JOSWAC personnel.

The strategy will be as follows:

1.     Pre-employment medical examination consisting of blood screen, general physical examination and TB test.

2.     Reduction of exposure to hazardous substances, noise, vibration, chemical handling, and manual lifting.

3.     Prevention of malaria and other diseases.

4.     Materials, including chemicals, and equipment used on projects shall be appraised to control health risks. Those proven or known to be injurious to health shall be discarded or minimized with use of the MSDS control.

5.     Work site supervision will be very intensive especially in the area of controlling hazards and their effects.

6.     JOSWAC will utilize designated clinics. In addition some of the JOSWAC staffs will receive training in basic first aid.

7.     Health staff will ensure disease control in accommodation areas and that caterers, if used, serve good quality food and water.

8.     There will be no use or possession of intoxicants or illicit drugs by any person on any project work sites or base compound. Persons found to be in possession or under the influence of such substances shall be terminated from the job.

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13.5     Environment Policy / Strategy

JOSWAC aims to execute her projects in a manner that her activities will have minimal or insignificant impact on the environment.

            The strategy will be as follows:

1.     The environmental impact of each activity shall be routinely monitored, controlled and corrective action taken as necessary.

2.     All practical measures will be taken to minimize the generation of waste, manage and dispose of unavoidable waste in an environmentally acceptable method.

3.     Wastes will be manage as indicated in the Waste Management Plan (see PROJECT-HES-DOC-004) and waste streams shall be monitored, recorded and efforts taken to reduce emission or discharge of waste known to have negative impact on the environment.

4.     Noise, air, soil and water pollution will be monitored and mitigated.

5.     All chemicals shall be transported, stored, used and disposed of in an environmentally acceptable manner.

6.     Resources shall be provided and contingency plan developed to respond to spills or any other environmental incident in timely manner.

13.6     Security Policy / Strategy

JOSWAC plans to eliminate losses of materials, injuries to personnel and property due to third party activities. HES site officers, who report to the HES Coordinator, will be responsible for achieving this goal. JOSWAC would in addition employ security consultants whose advice will be incorporated, as appropriate into the security operation.

JOSWAC shall be responsible for properly securing their equipment, supplies, etc. kept on the work sites.

The strategy is as follows:

1.     If the lives of project personnel are at risk, JOSWAC will withdraw from the risk area, if possible, and report the problem to client as well as the appropriate Nigerian security authority and seek its assistant to restore law and order.

2.     JOSWAC will employ security guards that are experience in the protection of life and property.

3.     A security hazard register will be maintained for all work areas.

4.     Access to project work site will be controlled to prevent unauthorized entry as follows:

·        Access will be allowed to only those persons who have genuine business in the site and such persons shall be issued a badge.

·        The HES Coordinator or his designee will issue the access badges.

5.     Travel from the sites at night will not be allowed without the permission of client. If authorized, it must be done with strict adherence to client’s travel regulations. JOSWAC will cooperate with client on its corporate travel restrictions.

13.7     Policy Objectives

In accordance with the stated HES policy JOSWAC management has set the following project objectives:

·        Measure, monitor, and assess community affairs, health, safety, environmental and security performance.

·        Reduce exposure to health and safety risks.

·        Active management of safety to foster constant awareness among all staff of the health and safety aspects of their work and of the environment they work in.

·        Foster good relationship with host community.

·        Take steps to enhance the reputation of client and JOSWAC in dealing with host communities.

·        Collection, discussion and dissemination of up to date authoritative information on HES issues particularly those arising out of incidents.

·        Comply with applicable codes and regulations.

·        Minimize the project impact on the environment by minimizing the waste generation.

·        Consider the impact of the project during execution on the community.

PROJECT GOALS based on site activities shall be managed so that all possible precautions will be taken towards preventing incidents. As a minimum site HES activities shall focus on.

·        Identifying all hazards associated with the project and ensuring controls are in place to manage them safely.

·        Limiting the consequences if incidents should occur and thereby provide safety for personnel, the external environment and property.

·        Ensuring that all JOSWAC  personnel are appropriately trained for the work they will undertake

These goals shall be achieved based on the following principles:

·        HES is a management and a line management responsibility

·        HES activities shall be planned and scheduled.

·        HES requirements and criteria shall be known, understood and implementation.

·        HES activities shall be verified and documented.

·        HES performance excellence is the responsibility of every individual.

.1           DRUG / ALCOHOL POLICY

As regards drug/alcohol policy, JOSWAC INVESTMENT NIG LTD, will comply and apply strictly to all relevant government agencies rules and regulations and her client safety practice concerning the issue of drug/alcohol, in order to protect her employees and others regarding the hazards associated with misuse of drugs and ensuring that the working environment is safe for working.

The following are the drug/alcohol policy; we are to strictly adhere to:

-           The illegal possession of contraband drugs is highly prohibited in all JOSWAC work site.

-           Drug prescribed by medical personnel or expert brought into company premises must be in their original sachet or bottle or container in which they were ordered or prescribed with prescription from a medical practitioner (qualified).

-           Alcohol and any other intoxicant must not be consumed during working hours and in designated areas.  They are not also to taken when off duty at designated areas.

-           Illegal drugs that are found after inspection had been carried shall be ceased.

-           On no account should any staff get involved and also no employee should be involved in self medication.

-           No company transport facility should be manned or operated by anyone noticed to be under the influence of alcohol or illegal drug.

-           Any company employee who is on legal drug that could affect his job performance must inform the safety officer or supervisor upon reporting to work.

-           Any violations of this policy will face appropriate disciplinary action which may include termination of employment and also visitor shall remove immediately from the premises by security personnel.

-           JOSWAC Nigeria Limited has the right and authority to send any suspected personnel under the influence drugs or alcohol for test in her retainer clinic. 

1.0    PRE – HIRE DRUG SCREEN

It is mandatory for all newly employed workers to undergo “Pre-Hire Drug Screen” which is in line with responsibility of company’s management and safety body.

The pre-hire screen would be carried out in a standard screen center, in order to recognize any of the employees that are abusing any of the illegal drugs /enhance performance drug.

1.0    Random Drug Screen

This is a test that is carried by JOSWAC INVESTMENT NIGERIA LIMITED either quarterly or periodically by collecting blood sample of employee and subsequent screening of such samples to ascertain of any of the employee, after successfully passing the pre-hire drug screening test, and went further to abuse contraband drug or those drugs that is considered illegal.

1.0    Random Search Program

It is JOSWAC INVESTMENT NIGERIA LIMITED policy to subject equipment and personnel to screening before entering company premises if they deem it necessary.

-           Subcontractor:

It has been made compulsory that all the sub-contractors carrying out jobs for JOSWAC must have searching procedures for people working for them for safety reasons.

9.2       FOR CAUSE DRUGS AND ALCOHOL TESTING

JOSWAC INVESTMENT NIGERIA LIMITED shall conduct random drugs and alcohol test on all her personnel as situation demanded.

In the event of any incident while working for the company, the affected personnel that involved in the accident shall be taken to JOSWAC retainer clinic for drugs and alcohol test to determine whether it contributed to the cause of the accident. Any personnel find wanting in the use of illegal drugs and alcohol shall be discipline accordingly.

10.0     SMOKING POLICY

Smoking due to its health implication on human constitutes a great problem to all industries worldwide, since the smoker and non smoker do get the impact as a result of smoking.  Smoking could be very dangerous when not handled with care, which could lead to serious fires and injuries.

To this effect JOSWAC has deem it necessary to treat smoking issue with all seriousness it deserves. We are want an environment that is free of smoking due to inherent health hazards associated with it.

In order to achieve this, employee must adhere seriously to the following measures:

-           On no account must any employee carry lilted cigarette that could act as an ignition source to any restricted and non-restricted area of JOSWAC LTD.

-           Smoking is not allowed in company location that has compressed gas cylinder and hydrocarbon e. g. petrol.

-           No smoking is allowed in any office building, accommodation building, vehicle, even when employee are been transported by boat.

-           Smoking is highly prohibited in all JOSWAC LTD work location except in area that have been specifically designated and approved by management and there must be a safety permitted signature to that effect.

-           The use of butane lighter is not allowed in any company work site and also no employee must use lighter to ignite cutting torches.

-           Matches and lighter which are ignition sources are not to be use in any company work site.

11.0     STANDARDS

Project designs and activities shall be carried out in line with applicable client’s standards throughout projects execution as specified in contract documentation system in place.

11.1     Documentation System

All related HES issues would be documented and maintained at the respective site and base offices. All documentation and records are to be:

·        Legible.

·        Identification.

·        Traceable to activity/services/products involved.

·        Stored and maintained to avoid loss or damage.

·        Retention times to be established and recorded.

Documentation and records will include:

·        Reports of progress towards meeting objectives and targets.

·        Training records

·        Inspection and review reports

·        Non-conformance and corrective actions

·        Environmental, injury incidents and investigation reports

·        Maintenance records

·        Equipment inspection records

The project HES Coordinator is responsible for ensuring compliance with these systems and procedures.

A HES hazard register shall be used as a tool to follow up HES findings, recommendations and tasks during project execution. Unresolved issues of particular concern shall be reported to the HES Coordinator, who will initiate corrective actions to resolve the issues.

The project Manager and the HES Coordinator will maintain statistical data in the form of HES summary.

A copy of this statistics data will be forwarded to client on a monthly basis

12.0     PLANNING AND PROCEDURES

The various project sites will use this HES plan as their basis for site HES planning. The Project Manager is accountable for proper HES planning. The performance standards established for the project will be cascaded through to the various JOSWAC supervisors and sub-contractors.

The tasks required to address these issues are tabulated below:

S/N

TARGETS AND ACTIONS

TASKS

REVIEW PERIOD/DATE

1.

HES performance management

1.1

Management site inspection visit

Quarterly

1.2

Review project team HES performance

Biweekly

1.3

Prepare JOSWAC HES Plan

April 2004

1.4

Conduct pre-mobilization inspection of all project equipment.

Before mobilization

1.5

Invite CNL/client for final pre-mobilization inspection.

Before mobilization

1.6

Monitor and measure team HES performance

Monthly

1.7

Review HES performance on all identified safety critical activities.

Monthly

1.8

Inspect and audit work sites

Quarterly

2.0

Work site supervision

2.1

Induction for all new employees, which includes job related hazards, etc.

Before being sent to site and on first day at site

2.2

Pep talk and toolbox meetings held by site HES officer and responsible supervisors with crew members

Daily

2.3

Report/investigate/review all incidents (including near miss cases) with management and supervisors. Disseminate learning points.

As required

3.0

Operations environmental issues

3.1

Develop waste management procedure of JOSWAC operations team.

Before mobilization

4.0

Hazards and Effect Management

4.1

Periodically review emergency response and recovery plan

As required

4.2

Carry pout JHA sessions for all HES critical activities

As required

13.0 Targets and Objectives

The HES targets for projects are as follows:

·        Develop and maintain an incident free environment on each work site

·        Minimal disruption to project schedule due to community affairs issues

·        Minimal adverse project impact on host communities

·        Maximum possible benefits to people from host communities.

·        Zero fatalities for JOSWAC personnel and third parties.

·        Achieve an LTI (Lost Time Injury Frequency) rate under one per million man hours

·        No fatality and permanently disabling injuries or illness

·        Less than two preventable road traffic accidents for drivers with the project.

·        No environmental incident

·        No medical emergencies requiring MEDEVAC

·        No health incidents

·        No security incidents

·        Close out of all incidents, action items from inspections and audits and near miss timely.

·        Audit all HES resources once every three months

14.0Project Specific Tasks And Targets

 Community Affairs:

JOSWAC will incorporate the tasks and targets reached on CA/CR meetings with CNL CLOs.

·        Achieve zero loss days to community disturbance for the first one-year of operation.

Action: All staff

Safety:

·        Achieve zero fatality for staff, sub-contractors and visitors.

Action: All staff and visitors

·        Achieve zero LTI targets frequency rate under one per million man-hours for staff and sub-contractors.

Action: All staff

·        Achieve less than two PRTA (Preventable Road Traffic Accidents) throughout the first two years of the project.

Action: All staff

·        Conduct a minimum of one inspection per project work site quarterly.

Action: HES team

·        Make a minimum of three suggestions quarterly

Action: All staff

·        Attend all JOSWAC meetings. Minimum of 90% attendance.

Action: All staff

15.0 Health

·        Carry out a minimum of one occupational health audit at each project work site and base compounds in two months.

Action: HES staff

·        Make a minimum of two health improvement suggestions.

Action: All staff

15.1 Environment

·        Nominate and ensure attendance of staff relevant environmental courses organized by the HES department.

·        Conduct a minimum of one Waste Management control audit at project sites per month.

Action: HES staff

15.4  Security

·        Conduct a monthly security audit at base compound facility and each project work sites.

Action: HES staff

·        Make a minimum of two security improvement suggestions.

Action: HES staff

Nominate and ensure attendance of staff at security training and awareness lectures. Disseminate information from security circulars, etc. to all staff.

Action: HES Coordinator.

16.0 HAZARD AND EFFECT MANAGEMENT PROCESS (HEMP)

Project Specific Hazards and Effect Management Plan (HEMP)

The identification and evaluation of hazards at the various stages of project and the development of control measures is part of the HES management system. Identification and evaluation of HES hazards for specific activities would be done in conjunction with client/ JOSWAC team. The methodology adopted is in the form of a Hazard and Effect Management Plan.

The purpose of the HEMP is to establish a formal system for the performance and documentation of risk assessment of Health, Safety and Environmental issues both during project execution.

17.0 Road Transportation

JOSWAC will ensure that all employees or the employees of sub-contractors receive adequate instructions and that the instructions are implemented to maintain a safe standard of defensive driving.

Drivers will be examined from time to time to determine their knowledge of existing traffic laws and regulations that being enforced by the Nigerian Government.

17.1 Vehicle Requirement

Vehicles will be regularly inspected and well maintained in accordance with good driving practice and statutory requirement. The front and back seats of all vehicles shall be equipped with seat belts.

Vehicles used on project areas will be equipped with In Vehicle Monitoring Systems (IVMS). All project vehicles will be equipped with first aid kits and fire extinguishers and motorcycles shall not be used in any project being executed by JOSWAC Vehicle documentation will be put in place.

The company journey management procedure (see PROJECT-HES-DOC-002) will be implemented throughout the project. Sub-contractors are expected to adhere to this procedure. Project road route plans and associated hazards will be disseminated to drivers.

18.0     INTERFACES WITH CNL/SUB-CONTRACTORS

JOSWAC recognizes that HES responsibility lies with the line management.

There will be an interfacing meeting with JOSWAC/sub-contractors regularly. HES issues will be reviewed as follows:

·        From inception of project to date incidents and accidents

·        Previous week’s incidents.

·        HES projection for the upcoming period (week).

Walkabouts will be scheduled for each site on both a regular and random basis. Inspection and observations will include safety, environment, security and impacts of community affairs program. Client’s personnel fulfilling those functions will be actively solicited for inputs and advice.

HES meetings will be scheduled as follows:

·        Daily pep talk session held with all staff. A daily toolbox meeting will be held by line supervisors with their team prior to commencement of work in order to disseminate HES strategies related to the planned activities. All personnel have a right to express their concerns pertaining to HES issues, and those concerns will be taken as feedback, addressed and rectified.

·        Daily HES induction sessions for all new employees and visitors.

·        JOSWAC line management and supervisors meeting to review past activities and the planned activities for upcoming week(s).

Inspections will be as follows:

·        Random HES walkabouts of project work sites, base compounds and accommodations, etc.

·        Random inspections of health documentation.

·       

19.0     PERFORMANCE MONITORING

Meetings

Regularly scheduled meetings on occupational health, community affairs, safety and environment would be held as an essential element in HES management. A formal agenda will be prepared with formal minutes recorded. Any action items will be assigned and followed up on a continuous basis until resolution is achieved.

Periodic HES meetings will be held under the chairmanship of the Project Manager and will be attended by relevant personnel, such as HES Coordinator, Community Liaison Officer and Supervisors.

HES performance will be measured by the use of statistical methods, audits, drills, accident and incidents reports/investigation. These methods and techniques are given in the relevant procedures.

The following statistical records will be maintained and reported on a weekly basis and will be documented in the written minutes.

·        Man-hours

·        Recordable medical treatment cases/frequency rate

·        LTI frequency

·        Near misses

·        First aid cases

·        Material losses

·        Hazards

·        Other incidents, lost time or otherwise, (e.g. labor or community related disturbances)

·        Environment incidents and standards as compared with project/regulatory requirements.

·        Medical or health statistics i.e. occupational health records.

·        Security incidents.

20.0     Incidents and accidents reporting investigation.

Incidents will be immediately investigated and reviewed as required by CNL procedure. Causes will be determined and corrective actions will be decided on. The resulting corrective actions will be discussed with other work groups/areas during preview meeting, or sooner depending on the severity of the incident and the ability need of other groups to learn from it. It is set as a project goal to close out all investigations in 15 days or less.

The HES Coordinator and his team are responsible for the investigation of HES incidents and follow up of injuries as well as community affairs incidents.

21.0     Occupational Health and Safety

First aid kits shall be provided at various work sites to take care of non-serious injuries.  JOSWAC will use contract hospitals with the adequate equipments to deal with health hazards identified. JOSWAC will maintain communication with these hospitals by telephone.

The workers and cleaner will carryout regular housekeeping after each job and everyday within the work sites. The wastes collected will be disposed off in accordance with the waste management program.

Personnel will be continually updated on occupational health matters relating to their jobs. This will be in the pep talk meetings, health promotional lectures and through posted announcements.

22.0     HES INCENTIVE/RECOGNITION PROGRAMME

There is an incentive program in place where some very safe workers are selected monthly for an award and every quarterly a souvenir/gift are shared among all worker as an appreciation for a safe work without LTI.

23.0     HES GOALS AND TARGETS SET AND TRACKED

Our overall objective is to have an LTI free project, no accident and above all make safety a culture.  Operate without damage to animals and plant life within the environment, thus our health and environment protection programmes are designed to:

- Sustain management’s commitment to health, safety an environment protection

- Increase the level of awareness among all employees

- Provide health and safety working conditions for all employees.

24.0     HES INSPECTION AND AUDIT

There is routine inspection of operations on site by the company HES representatives.  Cases where there are abnormalities i.e. operatives working in an unsafe manner or unsafe condition, corrections are made.

A team of HES representatives would after some time embark of an audit, take records, suggest corrective measures on own before that by asset owners.

25.0     Drug and  Alcohol/Substance Abuse

The use or possession of illegal or unauthorized drugs or drug paraphernalia is prohibited in all our operations.

The use of alcohol is prohibited during working hours in all our operations.  The company retains the right to conduct  workplace searches and screening.

25.1     Pre-Hire Drug Screen

Before anybody is employed they shall be an drug test carried out on such a prospective employee and if found violating, chances of employment shall be give up.

25.2     Random Drug Screen

Once in a while, some workers shall be handpicked for drug test especially workers involved in hazardous jobs.  Any worker who prove positive may lose his/her job.

25.3     Random Search Program

The company reserve the right to embark on a screening exercise where a number of workers would be picked from every department and violators would be duly punished.  Violators of this drug and alcohol policy are subject to disciplinary action up to and including termination.

26.0     Respiratory Protection

Employees involved in jobs that typically require the use of respiratory protection such as painting confined space entry, sand blasting and handling chemicals and pesticides are made to received medical clearance and respiratory protection training and fit testing before performing such jobs.

27.0     Hearing Conservation Program

A training program shall be organized for all employees making them know the consequences of working in a continuous or intermittent high noise area and recommendation of hearing protection devices (earplugs/earmuffs) as “Ear Protection Required” signs are posted. Example of locations were hearing protection is required are, dockyard around where crane is working, generation, jackhammer etc.  Where the noise level is 85 decibels and above.

 JOSWAC INVESTMENT NIGERIA LIMITED has a policy that ensures that every high noise areas in the work place are identified and also provides appropriate hearing protection for the workers.  High noise areas can be manually known when one can only communicate by shouting for others around to hear.

Periodically, all work areas shall be tested with a sound level meter to determine high and low end noise levels.  The result shall be documented and retained on file.

Work areas identified as high noise areas must have safety signs posted at all entrances advising the workers to wear hearing protections.

Work areas identified as high noise areas must have hearing protections readily available for workers at all entrances to work area.  Some of such recommended hearing protections includes disposable ear plugs and sound barrier ear muffs.  All workers should comply with the use of hearing protection whenever they are in high noise areas, working.

28.0     Short Service Employee Program

There is a special program in place for employees that are to stay for a short term.  Apart from the normal wages there is safety incentive in form of cash or souvenirs and an end of contract bonus or pay off for the workers after the project.

JOSWAC INVESTMENT NIGERIA LIMITED has a policy that ensures the safety of employees no matter how short their duration may be in a project.  There is always a safety orientation program that covers the risk inherent in the task of workers, possible risk in the job of other in their immediate environment, possible danger from equipment uses in the location, location of high hazards e.g. restricted area in a facility, knowledge of necessary personnel protective equipment.

Employees who join other in the process of time in an ongoing project shall have an incident free mindset created in them like other workers and most be made to know that an unsafe act committed and not corrected could create an unsafe condition that could lead to a near-miss or even an incident.

A short service employee must understand that it take a second for an accident that could danger lives and equipment to occur and for that nothing should be taken for granted in trying to develop an high safety standard.

Accident does not just occur, rather they are caused by errors of people, failure of machines not properly checked and maintained and for that all accident can be prevented; every employee should bear in mind. 

29.0     BEHAVIOURAL BASED SAFETY PROGRAM

This program has been developed in order to reduce incident/accident or eradicating any form of hazardous condition/unsafe behavior practice, from employees, equipment in JOSWAC premises and site or location. To achieve this, all workers have authority to stop any unsafe work without being punished.

All these can be monitored by critically observing the unsafe practices that employees exhibit on the job that could lead to any form of injuries.  And these acts must be properly recorded for analysis during safety meeting or on the spot correction to enhance their safe practice (behavior), in line with her client “Stop program”, but JOSWAC has developed her own form of Stop program to work with and the principle are:

-        Providing observation feedback to address unsafe act/condition that has to do with the following:

-        Position of people

-        Personal protective equipment

-        Condition/use of hand tools and equipment

-        Recommendation action to prevent re-occurrence

-        Procedure and orderliness

-        People are the most important in the HES program

-        Subcontractors shall be advised to have a HES programme that is detailed as per the job they render.

-        All subcontractors must be involved in HES orientation, safety meeting and audit to be carried out

To achieve the aim and objective of this program, all personnel working for JOSWACshall be train on how to use BBSP checklist to collate and correct any negative behaviour notice during the exercise.

“STOP” BBSP

-        Safety off the job is important part of overall safety program

-        Training is an essential element in safe practices

-        Safety audit must be conducted.

30.0  FALL PROTECTION/WORKING AT HEIGHTS

Full body harness fall protection devices shall be worn by employees working off-shore over open water, 6ft and above over the ground where there are no rails as protection.

The harness should be properly worn and in good condition.

JOSWAC INVESTMENT NIGERIA LIMITED is of a policy that effect should be made to eliminate exposure to fall hazard and the work site.  They provide certified fall protection (full body harness) to workers doing their job at height.

They also ensure that the support of the project supervisor and HES representative the said provided fall protection are used and in the appropriate way.  Workers shall also be trained for this and even in case for the equipment.

All workers should be familiar to the use of stairways, always having a hand on it and always walking and not running on them.  Care should always be taken for materials, tools, equipment and even personnel  not to accidentally fall to the lower level when work is being done at elevated area and walkways located above the work areas.

All openings in floor areas will be covered, guarded or made inaccessible to personnel by the use of barricades.

There shall be an inspection of fall protection equipment as to manufacturers recommendation on a regular basis and certificate shall be given to that effect and duly documented at site and division office.

The use of wooden ladder shall not be allowed only aluminum ladders are permitted.  In cases of electrical works or where there is possibility of coming in contact with life current and shock hazards in the task and insulated or fiberglass ladder are recommended

31.0     PERMIT TO WORK SYSTEM

For non-routine activities, a permit-to-work must be prepared and approved before the commencement of work.  In this written document, restrictions and precaution of the job to be done are clearly defined.

There are various types of permit to work i.e. General work permit, request for hot work, daily hot work permit, request for confined space entry.  Daily safe entry permit, permit for simultaneous operations, excavation permit etc.

JOSWAC INVESTMENT NIGERIA LIMITED has a policy that ensure that they shall develop and post in the work area a chain of command flour chart that identifies work site specific supervision positions that will be required to sign off on work permits as authorizing authorities at the work site and as required by the client’s work permit forms.

It shall also be ensured that these personnel that will do the signing meet the required standard as set by the clients.

Only job specified on the work permit shall be done by our workers on site and the precautions and restrictions shall be adhered to strictly.

JOSWAC INVESTMENT NIGERIA LIMITED shall consult the client on issues of hot work as regard the fact whether there can be alternative to the hot work and if not all restriction and precaution in it shall be followed strictly.

JOSWAC INVESTMENT NIGERIA LIMITED shall prepare a written safe-entry procedure for any work involving confined spaces, limited access vessels or below grade pits and shall ensure that a total energy deactivation system (lock-out/tag-out) is implemented while performing work on any equipment or machinery where there is a possibility of accidental turn over.

32.0     PRE-TASK PLANNING

Pre-task planning involves the job safety analysis review at the job site involving all those to be involved in the job activity.  Another section of this is toolbox talk which is also a part of the pre task planning; this is analyzing all the possible risk in the job considering the location.

33.0     PORTABLE HAND TOOLS – ELECTRICAL & PNEUMATIC

Portable hand tools shall be rated for industrial use and grounded.  They should be equipped with a three-pronged plug and three-wire grounded conductor cord and should be used only in a three prong service outlet.

Before use, there should be an inspection of the components of the hand tool and by powered by appropriate voltage.

JOSWAC INVESTMENT NIGERIA LIMITED ensures in their policy that appropriate hand tools are provided to workers in any given task.

Good care and maintenance culture is required by workers.  Proper hand tools storage boxes are to be provided and ensure that workers always return tools to appropriate boxes after use for storage.

To prevent moisture from invading the electrical connectors, all electrical extension cords must have connectors that lock together.

Electrical hand tool that does not have the intrinsically safe on them should not be used in a restricted area unless a hot work permit.

Alternatively pneumatic (air) power tools can be used in restricted area (hydrocarbon processing or storage area).

Air hose lines shall be rated to meet or exceed the supply air pressure.

Only qualified mechanics shall service pneumatic and electrical hand tools.

High pressure air hoses shall have connectors that lock together and are retained in place with a safety pin (e.g. crow’s feet connector)

34.0     Signs and Barricading

Signs should be duly posted wee appropriate in our various work site there are different signs, cautioning people at different dangerous locations.  Some signs does not tell of danger, rather caution or safety information, there are all color coded.

Barricading is use to prevent people from entering into specific location, this could by the use of caution tape etc.

JOSWAC INVESTMENT NIGERIA LIMITED has a policy that ensures the use of caution/warning tape at a work area with ditches, holes, excavations and earthen pits enough to prevent an individual from tripping into them.

When there is a trench far from our work area and we have an activity that is getting close to where the safety of our worker now become an issue warning and caution light should be provided

Barricade should be made around work areas that are located directly under overhead work to prevent personnel from inadvertently passing under the overhead work.

Danger, caution and safety instruction signs shall be posted at our various work areas as it relates to the possible hazards in the area.

35.0     Unsafe Condition Reporting

The reporting of unsafe condition is a working tool in avoiding re-occurrence.  Correcting most unsafe acts could be done by improving on housekeeping and following procedure in every of our operations.

JOSWAC INVESTMENT NIGERIA LIMITED has policy that ensures the prompt reporting of unsafe condition.  This is the bringing to the notice of an abnormal situation of an area or work site that had being cause by an unsafe act of a worker so that an immediate remedy can be made.  In situations where the correction can be made simply by either cleaning of liquid from the walkway, removal of obstacle, arrangement of tools and other measures that can be put in order by an employee or with an assistance of another worker the correction should be made first by reporting to avoid an accident.

Reporting of unsafe acts has numerous advantages in our work site; it protects material and equipment, saves lives, saves time and money.  It gives an opportunity for people to have more clear reasons for such acts to be completely avoided and promotes high level of safety standard in our operations.

36.0     Journey Management (All forms of personnel and Equipment)

There is so much to be put in place when personnel and equipment are to be moved from one location to the other.  The security and safety of the personnel to embark on the journey must be considered.  In doing this, one should study security condition of either the road or the water way, so that if government security forces are required, they can be introduced.

In cases were personnel are to travel by air, due helicopter or aircraft safety briefing must be made before the journey is made.

JOSWAC INVESTMENT NIGERIA LIMITED has a policy that ensures safe journey for all.  In situations where personnel are to use boat to and fro work on daily basis.  It must be ensure that such personnel undergo due training on how to journey by boat, and it must be enforced on all passengers the use of life vest always and only trained and certified boat drivers shall be engaged and periodically, boat captains shall be tested of alcohol and drugs and if at any time they are faulted regards to this policy they could be dismissed.

In cases where means of transport is only by air and is solely arranged by our clients, a time table of our workers in and out trips shall be given to our client for prior planning exception may only arise in case of emergency.

37.0     Task Specific Procedures

The Standard Operating Procedure (SOP) on a give task must be known, understood and followed.  Statistics had shown that most incidence/accidents are as a result of neglect or non compliance with written procedures on the specific task.

For a job involving lockout and tag out (LOTO); there is a written standard operating procedure (SOP) on the job and it must be known and followed for a safe work to be achieved.

JOSWAC INVESTMENT NIGERIA LIMITED has a policy of developing a task specific procedure for all major tasks they have to perform as it is expected of them in their project.  During pre-job planning a copy of the procedure is made available for use so that workers can always consult as reference document.

When pre-task safety meetings are held, information from this document that identify specific hazards associated with the task are highlighted for worker to take not of during work time.

38.0     Scaffolding Procedures

In scaffold erection, due procedure most be adhered to strictly.  The scaffolders must always wear the full body harness when erecting scaffold, they must not hold tools or materials with one hand while climbing, rather there materials should be lifted or lowered with a line and a certification scaff-tag on scaffold before they are used by personnel.

JOSWAC INVESTMENT NIGERIA LIMITED has a policy that all scaffolding will be erected to meet the international standards.

We will request assistance and guidance from our client is necessary for any scaffolding standards they may require in the process of our services.

We shall embark of thorough inspection of all materials and tools to be used on scaffolding since it is to be used for a job at height and any abnormality could cause a severe fatality.

39.0     Equipment And Work Area Auditing

Periodically, equipment should be audited and a record of their safety condition to be taken and to give room to improve on it.  For work area, auditing gives room for improvement on good housekeeping, use of right tools for the job, correcting of unsafe acts, use of correct PPE and following of procedures in embarking on our task.

40.0     Fire Prevention/Protection

Provision of Chevron Nig Ltd trained and certified fire watch and fire extinguishers at hot work sites. JOSWAC INVESTMENT NIGERIA LIMITED operates a policy of ensuring the provision of fire extinguishers that are appropriately rated and of size to wade against fire hazard in our various work locations.

There shall be a clear access without obstruction to fire extinguishers and hoses and these equipment shall be inspected monthly with record tags on them.

Appropriate training shall be conducted for personnel on fire extinguisher and hoses inspections and our fire extinguishers shall be hydrostatically tested after some years.

Fire retardant coverall shall be provided for worker who spend 20% of their working time in a life hydrocarbon processing and storage (restricted) area.

Fire extinguishers that have been discharged should be removed out of service and be replaced by a fully charged unit.

JOSWAC INVESTMENT NIGERIA LIMITED shall ensure good housekeeping by disposing papers, rags, trash and other combustible materials in appropriate containers

The transportation and storage of flammable liquid i.e. gasoline, kerosene, fuel and oil shall be stored in approved metal containers that are designed to specification and far away from fire source.

None of our workers shall temper with fire protection equipment and shall duly report any discovered leakage of gas.

All engines shall be shut down before they are refueled except where the refueling point is far from the engine.

In case of fire, operatives should know that personnel should be protected first before equipment and then extinguishing the fire

41.0 Compressed Gas Cylinders

Oxygen and acetylene should always be kept in an iron, non combustible barrier and the bottles should not touch each others, at least 6.1m and the rack should also be of a height of at least 1.5m

These bottles should always be stored in an upright position; there should also be a network of chain around them, which is to serve as a securing measure.

At every time and condition whether full or empty the cylinders should always have a protective valve caps on them.

There should be a label always on the cylinders showing the content.  This is to ensure cylinders are assembled according to content and the possibility of trying to use a wrong cylinder content for another job never arise.

Gases are highly inflammable and could result into a hazardous situation if not properly managed. Cylinders therefore should be stored out of direct sunlight, ignition source and possible heat.

There should be confirmed lack of leakage by a hydrostatic test using a soapy water and should be conducted on site to confirm the condition of the cylinder. The cylinders should be tagged to confirm the test.

There should be a protective screen in place around welding and cutting torch operations. This is to ensure that flash burns, slags or sparks on workers are dully prevented.

There should be a hot work permit from the asset owners before a welding and cutting job is done except a designated safe welding area.  This document shows clearly the restrictions and precaution inherent in the operation.

The hoses of oxygen and acetylene bottle used in cutting jobs should be bled down to zero pressure when out of use for some time.

41.0         Emergency Response/Evacuation

There shall be a record of various emergency response procedures, especially those that are applicable during our operations in the field.

Some of these could be:

- Personal Medical Emergencies and Evacuation

- Fire Emergencies

- Environmental Emergencies

- Community Unrest

- Well Control Emergencies

- Others

The subcontractor and the contractor are to make a review of the clients emergency response procedures and if need be for a change or an amendment being made, it will be done to ensure an alignment.

There shall be a weekly emergency response drills on site and dully documented, as due training of operatives has been done.

Some of our duties shall be the posting of emergency medical evacuation information to include:

- Map/GPS co-ordinates for emergency helicopter evacuation services

- Useful information about hospital or clinic and doctors to be contacted.

- Useful details about personnel of our company to contact shall be made know to all.

Normally, there is the provision of firefighting equipment strategically located on site and a routine inspection is carried out periodically.

The company shall not release any information related to an emergency situation that has to do with their operations without the client’s approval.

42.0         Housekeeping

It is mandatory to maintain a clean work site at all times.  A good housekeeping standard in our work ways, floors, workshops and every location where work is being done to avoid slip, trip and fall hazards.

The company owns the responsibility to keep access road to locations such as mustering points, emergency exits, fire hose stations, fire extinguisher and any other emergency response equipment clear.

Tool, equipment and materials are not to be left on walk ways to avoid trip hazard.  Drains on floors should be kept clean and free of debris to prevent clogging. They should also be covered at all times or get it barricaded.

43.0 Job Safety Analysis

Job Safety Analysis is a technique used to identify job hazards and device corrective steps.

JOSWAC INVESTMENT NIGERIA LIMITED has a policy that before any general work is done especially those that are not frequently performed, all hot work and confined space entry jobs, a job safety analysis shall be developed.  And for jobs with high hazard potential they should be analyzed in detail with a Job Safety Analysis (J.S.A).

Job Safety Analysis shall be developed by a team composed of personnel who are familiar with the planned work.

The process for performing a Job Safety Analysis involves considering the;

Task which is breaking down of the job down into discrete series of steps or activities but avoid too much little detail.

Hazard: Potential hazards or incidents should be identified for the various steps of the job, what could go wrong and the possible effects.

Controls: Action to eliminate the identified hazards should be recommended by the crew.

Responsibilities: Who to take the action should be identified specifically among the work group.

44.  0 Personal Protective Equipment and Dress Requirement including

Face and Eye Protection

JOSWAC INVESTMENT NIGERIA LIMITED has a policy that mandates all operatives to use appropriate Personal Protective Equipment (PPE) required for every job being done, as required by the company we may work for or as the law decree according to legal jurisdiction.

Signs that specify the use of various Personal Protective Equipment shall be posted at different locations.

Personal Protective Equipment storage container shall be maintained at work location, this shall be clearly labeled and PPE shall be allocated to operatives when necessary as job progresses.  This container shall not be used as tool box for any reason whatever except for the original purpose.

JOSWAC INVESTMENT NIGERIA LIMITED shall ensure with the support of her site supervisors and HES representatives embark on periodic training to ensure that Personal Protective Equipment are always used appropriately and workers to cultivate a high maintenance culture of PPE as recommended by manufacturer.

Some Personal Protective Equipment includes:

i) Full body harness with lanyards and shock absorbers

ii) Chemical resistant aprons and gloves for use with chemical handling and mixing

iii) Hearing Protection

iv) Face shields and goggles

v) Respirators

Appropriate work clothes are dully provided and a follow-up to ensure they are properly used is maintained.  Work clothes shall be either coveralls and shirts or pants and shirts which can either be 100% cotton or fire retardant/resistant materials.  These clothes should cover the shoulder area and trunk completely but not too loose to avoid being cut off in equipment.  Work clothes should be change if stained with oily substance.

45.0Welding and Cutting Torch

There should be a trained and certified Fire watch allocated at any hot work operation.  He ensures that the area is clear of every combustibles, check the level of gas in the area, using a gas detector i.e. The “Orion Multi gas Detector” to ensure a gas free hot work environment.

There should be a certification on all welders in the facility by a body approved by the client and records and copies of which should be documented by all parties involved.

All electrical connections involved in welding operations should be in perfect condition to avoid electrocution.

Oxygen and gas cylinder should have a regulator that must be functional and air hoses should be connected using the appropriate connectors.