SHANICA

HEALTH, SAFETY,
SECURITY AND ENVIRONMENTAL
MANAGEMENT SYSTEM

© SHANICA - REV 6 Page 1 of 35

DOCUMENT CONTROL
This is a controlled document. The electronic format is the controlled version of this document.
An authorized and signed hard copy of the document is filed with the site Project Manager who
is the custodian of the document.

The revisions take into account changes that were identified at mobilization and the time
afterwards.

The table below summarizes the status:

Task Name Designation Signature

Author/Custodian Paul Bishop Programme Manager
Reviewed/ Abdulwahid Malaki General Manager
Approved by

REVISION HISTORY

Revision Date Pages Reason

0 27th October 2013 All Initial Publication
1 27th October 2013 All Following Review
2 19th March 2014 All Update for
Genel Ber Bahr Project
3 11th March 2014 All Update following
Genel comments
4 29th April 2014 All Update for
GNME Halabja Project
5 26th October 2015 All Update for
BGP Qara Hanjeer Project
6 20th October 2016 All Following Review

AUTHORISATION

20th October
Paul Bishop Programme Manager Signed: Date:
2016

© SHANICA REV 6 Page 2 of 35

1. INTRODUCTION .............................................................................................................. 5
2. PURPOSE OF THE HSE MANAGEMENT SYSTEM ................................................. 5
3. LEADERSHIP AND COMMITTMENT ......................................................................... 6
4. POLICIES AND STRATEGIC OBJECTIVES .............................................................. 7
4.1. SHANICA MINE ACTION - HEALTH, SAFETY AND ENVIRONMENTAL POLICY...................... 7
4.2. SHANICA MINE ACTION - ENVIRONMENTAL POLICY ......................................................... 8
5. ORGANISATION, RESOURCES AND DOCUMENTATION .................................... 8
5.1. HSE ORGANISATION .......................................................................................................... 8
5.2. RESPONSIBILITIES AND JOB DESCRIPTIONS ........................................................................ 8
5.2.1. RESPONSIBILITIES & JOB DESCRIPTION: GENERAL MANAGER ....................................... 9
5.2.2. RESPONSIBILITIES & JOB DESCRIPTION: PROGRAMME MANAGER (SAFETY MANAGER) 9
5.2.3. RESPONSIBILITIES & JOB DESCRIPTION: PROJECT MANAGER (PROJECT SAFETY
MANAGER) ................................................................................................................................ 10
5.2.4. RESPONSIBILITIES & JOB DESCRIPTION: TEAM LEADER ............................................... 11
5.2.5. RESPONSIBILITIES & JOB DESCRIPTION: EMPLOYEES ................................................... 11
5.3. SUB-CONTRACTORS ......................................................................................................... 12
5.4. HSE COMMUNICATIONS .................................................................................................. 12
5.4.1. LANGUAGE ................................................................................................................... 12
5.5. HSE MEETINGS ............................................................................................................... 13
5.6. HSE PROMOTION AND AWARENESS................................................................................. 13
5.7. HSE COMPETENCE REQUIREMENTS ......................................................................................... 13
5.8. INDUCTION AND ORIENTATION ........................................................................................ 13
5.8.1. ALL STAFF .................................................................................................................... 13
5.8.2. DRIVERS ....................................................................................................................... 13
5.9. HSE TRAINING ................................................................................................................ 14
5.10. HSE LEGISLATION, STANDARDS AND DOCUMENTS ...................................................... 14
5.10.1. INDUSTRY GUIDELINES ............................................................................................. 14
5.10.2. DOCUMENTATION AND DOCUMENT CONTROL .......................................................... 14
5.10.3. MANAGEMENT OF CHANGE ....................................................................................... 15
6. HAZARDS AND EFFECTS MANAGEMENT ............................................................ 15
6.1. METHODS AND PROCEDURES ........................................................................................... 15
6.2. ASSESSMENT AND EXPOSURE .......................................................................................... 16
6.2.1. CONTROL OF RISKS....................................................................................................... 17
6.2.2. ANALYSIS OF RESIDUAL RISK....................................................................................... 17
6.2.3. RECOVERY FROM SYSTEM FAILURES ............................................................................ 17
6.3. ASSESSMENTS OF PPE REQUIREMENTS ............................................................................ 17
6.3.1. PERSONAL PROTECTIVE EQUIPMENT (PPE) .................................................................. 18
6.4. EXPLOSIVE REMNANTS OF WAR (ERW) AND MINEFIELDS .............................................. 18
6.4.1. SAFE WORK PROCEDURES ............................................................................................ 19
6.4.2. PERMIT TO WORK ...................................................................................................... 19
6.4.2.1. ERW COORDINATION ............................................................................................. 19
6.4.2.2. TASKING ORDERS .................................................................................................... 19
6.4.2.3. CLEARANCE CERTIFICATES AND PERMIT TO WORK ............................................. 19
6.5. TERRAIN ASSESSMENT ..................................................................................................... 20
6.6. JOURNEY MANAGEMENT ................................................................................................. 20
6.7. LOCAL TRAFFIC ............................................................................................................... 20
6.8. METHODS AND PROCEDURES FOR WASTE MANAGEMENT ............................................... 21
6.9. FIRE ................................................................................................................................. 21

© SHANICA REV 6 Page 3 of 35

 6.10. DISEASE........................................................................................................................ 21
6.11. HEAT AND COLD/WET MANAGEMENT ......................................................................... 22
6.11.1. FOR HOT CONDITIONS:.............................................................................................. 22
6.11.2. FOR COLD/WET CONDITIONS: ................................................................................... 23
6.12. DRUGS AND ALCOHOL .................................................................................................. 23
6.13. SECURITY ..................................................................................................................... 23
6.14. MANAGEMENT OF CHANGE .......................................................................................... 23
7. PLANNING AND PROCEDURES ................................................................................ 24
7.1. HSE PROCEDURES ........................................................................................................... 24
7.1.1. JOB SAFETY ANALYSIS (JSA) AND WORK PROCEDURES .............................................. 24
7.2. BASIC HSE RULES ........................................................................................................... 24
7.3. EMERGENCY RESPONSE PLAN (ERP) ............................................................................... 24
7.4. HSE EQUIPMENT AND INSPECTION .................................................................................. 25
7.4.1. VEHICLES ..................................................................................................................... 25
7.5. OCCUPATIONAL HEALTH ................................................................................................. 26
7.6. MEDICAL SUPPORT STAFF (MSS) .................................................................................... 26
7.6.1. MEDICAL FACILITIES .................................................................................................... 26
7.7. JOURNEY MANAGEMENT ................................................................................................. 26
7.8. DRIVERS AND VEHICLES .................................................................................................. 27
8. IMPLEMENTATION AND MONITORING ............................................................... 27
8.1. HSE PERFORMANCE ........................................................................................................ 27
8.1.1. RECORDS ...................................................................................................................... 28
8.1.2. NON-COMPLIANCE AND CORRECTIVE ACTION ............................................................. 28
8.2. INCIDENT INVESTIGATION AND FOLLOW UP .................................................................... 29
8.2.1. INCIDENT REPORTS ....................................................................................................... 29
9. AUDITING AND REVIEW ............................................................................................ 30
9.1. AVAILABILITY ................................................................................................................. 30
9.2. REMEDIAL WORK PLAN (RWP) ....................................................................................... 30
9.3. REVIEWS .......................................................................................................................... 30
9.4. SCOPE .............................................................................................................................. 30
9.5. COVERAGE ....................................................................................................................... 31
9.6. EFFECTIVENESS ................................................................................................................ 31
9.7. FOLLOW UP ..................................................................................................................... 31
9.7.1. HSE AUDITS OF SUB-CONTRACTORS ........................................................................... 31
9.7.2. FINAL PROJECT EVALUATION ....................................................................................... 31
9.7.3. HSE-MS REVIEW ......................................................................................................... 31
10. ENVIRONMENTAL MANAGEMENT ........................................................................ 32
ABBREVIATIONS .................................................................................................................... 33
APPENDIX A: HSE ORGANISATION CHART .................................................................................. 35

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1. INTRODUCTION

Shanica’s Health, Safety, Security, and Environmental Management System (HSE-MS) is

designed to ensure that all company work is conducted in the absence of significant risk, by
continuously identifying and controlling hazards which may arise through any aspect of
the company's work activities.

The system also provides guidance and procedures for managers managing projects, so that
the work undertaken under their control is as safe, and environmentally benign, as
possible.

Shanica's HSE-MS is designed to link with Client and other company HSE management
systems, and the company recognizes the importance of interfacing with such systems in a
manner which provides a seamless structure for managing individual projects. Where
necessary a bridging document between Shanica and clients systems will be developed.

The management of Health, Safety, Security and the Environment is based on the following
principles:

 Setting objectives;
 Providing and documenting a system to realize the objectives;
 Assessing risk;
 Defining performance standards;
 Monitoring performance;
 Continuous improvement.

To address all of these principles the Shanica HSE-MS conforms to the seven element model
recommended by the International Association of Oil and Gas Producers (OGP), and
described in the document. A copy of the model is shown below:

2. PURPOSE OF THE HSE MANAGEMENT SYSTEM

This HSE-MS document provides a full description of how HSE is managed in the company.

It covers:

 Shanica key activities;

 All employees, Contractors and others when with Shanica;
 Demonstrate that Shanica would have the necessary procedures and controls in place
from the HSE perspectives to achieve a smooth and successful project.

Together with accompanying components it may be used as a reference document for:

 Planning safe projects;

 Risk management;
 Activity planning and Job Safety Analysis (JSA);
 Familiarisation with Shanica's HSE systems;
 HSE audits;

© SHANICA REV 6 Page 5 of 35

  Incident investigations;
 Increasing safety awareness for existing staff;
 Competence setting;
 Training;
 Preparation for future programs;
 Review and improvement of HSE systems.

In delivering the project, Shanica will comply with:

 Shanica internal HSE policies and standards;

 Client contract HSE requirements;
 The relevant local laws and regulations governing transportation, labour,
environmental protection, health and safety of workers.

3. LEADERSHIP AND COMMITTMENT

Shanica firmly believes that good HSE performance is integral to the quality of its services, and
that HSE performance is as important a measure of quality as any technical, financial or other
aspect of those services.

Shanica further believes that safe, healthy and environmentally friendly projects can be
achieved through the pro-active management of risk.

Shanica draws particular attention to the importance of all managers providing a visible
expression of commitment to the HSE-MS. This will be demonstrated by:

 Allocating the necessary resources to HSE matters;

 Setting a personal example in day-to-day work;
 Putting HSE matters high on the agenda of meetings;
 Being actively involved in HSE activities, audits and reviews;
 Communicating the importance of HSE considerations in business decisions;
 Recognizing good performance when objectives are achieved;
 Encouraging employees’ suggestions for measures to improve HSE performance;
 Participating in Shanica and Client initiatives.

Shanica recognizes that management leadership is also required to create and promote a
company culture conducive to good HSE performance, in which the Shanica HSE Management
System can function effectively. This culture is based on:

 Belief by company management, Project Managers, and key employees in the

company's, and Clients, desire to achieve the highest possible HSE performance;
 Motivation to continuously improve HSE performance;
 Acceptance by all personnel of responsibility and accountability for HSE performance;
 Participation and involvement at all levels in developing the HSE-MS;
 Commitment to an effective HSE-MS.

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4. POLICIES AND STRATEGIC OBJECTIVES

Shanica has the following HSE policies in place:

 Health, Safety, and Environment Policy;

 Quality;
 Journey Management Policy;
 Drug and Alcohol Policy;
 Smoking Policy;
 Firearms Policy.

It is the responsibility of the Shanica's Programme Manager to approve revisions to these

policies in line with the review process of the Shanica HSE Management System.

All the above policies will be available at the Programme Managers office and at project sites
(held by the Project Manager). Signed copies of the policies are available in the HSE Project
Template folder. Policies are currently available in English.

 Additional HSE policies may be produced at the project level but will require
Programme Manager approval prior to use;
 Strategic HSE objectives will be set or revised annually following the review of the
Shanica HSE Management System;
 The annual review system will adhere to Shanica's financial year, which runs from 1
January to 31 December.

4.1. Shanica Mine Action - Health, Safety and Environmental Policy

It is the policy of Shanica to provide adequate prevention and control of all health and
safety risks arising from business activities in order to prevent injury and ill health. In
support of this policy the company will:

 Ensure all employees and field staff are competent to do their tasks;
 Establish and maintain safe working practices and documented procedures for
clear process management and legal and regulatory compliance;
 Ensure safe handling and use of substances;
 Provide and maintain safe plant and equipment and create and maintain a safe
and healthy working environment;
 Promote health and safety as a company objective of the highest priority;
 Promote health and safety as a direct responsibility of line management;
 Create and develop interest, enthusiasm and personal responsibility for health
and safety by provision of adequate training and regular consultation with
employees;
 Ensure regular audits and reviews of the systems are conducted to enable
continuous improvement;
 Review and revise this policy and objectives as necessary at regular intervals.

© SHANICA REV 6 Page 7 of 35

 4.2. Shanica Mine Action - Environmental Policy

It is Shanica International’s policy to conduct its worldwide business in a manner that

assumes optimum protection of the environment. In addition to careful compliance with
the relevant laws and regulations, waste reduction and efficient use of natural resources
are keys to achieving this objective.

In order to fulfil this policy, Shanica will:

 Ensure all employees and contractors are competent to do their tasks and
provide training where appropriate;
 Establish and maintain ‘best practices’ and documented procedures to ensure
that all activities that impact on the environment are managed in a pro-active
and environmentally responsible manner;
 Obtain the necessary licenses, permits and approvals from the appropriate
government/regulatory bodies and ensure compliance;
 Prepare and rehabilitate working sites in accordance with the relevant
environmental regulations;
 Communicate client environmental policies/procedures to all contractors and
site personnel and ensure compliance;
 Implement management plans in order to minimize the impact of projects
on native flora and fauna, minimize disturbance to cultural/historically
significant sites and minimize site environmental damage where evident by
using appropriate risk assessment techniques to reduce environmental risk
to ALARP (As Low As Reasonably Practicable);
 Ensure emergency plans are in place to contain any accidental spillage or
escape on-site;
 Ensure regular reviews of the environmental systems are conducted to enable
continuous improvement;
 Review and revise this policy and objectives as necessary at regular intervals.

5. ORGANISATION, RESOURCES AND DOCUMENTATION

5.1. HSE Organisation

Organisation charts demonstrate that HSE is a line management function in Shanica's

organisation. HSE performance is achieved through the line management system in the
same way as any other business requirement.

Shanica's organisation chart is included at Annex A to this document. A project specific HSE
organisation chart is also included in the Project Method Statement.

5.2. Responsibilities and Job Descriptions

All personnel involved in Shanica activities are responsible to some degree for HSE
matters. Individual HSE responsibilities are defined for key personnel in terms of:

© SHANICA REV 6 Page 8 of 35

  For whom they are responsible;
 For what they are responsible;
 To whom they are accountable.

5.2.1. Responsibilities & Job Description: General Manager

The General Manager is responsible for the overall arrangements and for ensuring that
the company’s work is conducted at all times in such a manner as to ensure, so far as is
reasonably practicable, the health, safety and welfare of all employees and others who
may be affected by its work.

In particular the General Manager will:

 Ensure there is an effective company policy for health and safety and that all
employees, contractors and temporary workers are made aware of their
individual responsibility;
 To understand and ensure, through the appointment of competent persons,
that the company’s responsibilities are met;
 To appoint a Manager responsible for safety – this is the Programme Manager;
 To ensure that all Managers understand and fulfil their responsibilities with
regard to health and safety;
 Arrange for funds and facilities to meet the requirements of company policy and
legislation;
 Make provision for adequate and appropriate training to be given to all
employees;
 To ensure that notification and reporting procedures to the relevant statutory
authorities are carried out;
 Set a personal example on all matters of health and safety.

5.2.2. Responsibilities & Job Description: Programme Manager (Safety Manager)

The Programme Manager is Responsible for Health and Safety and is accountable to the
General Manager for all matters relating to health, safety and welfare of employees and
those affected by the company’s work.

In particular the Manager Responsible for Health and Safety will:

o To bring company related health and safety matters to the attention of the
General Manager at regular intervals;
o To ensure that good communications exist between employer and employees
and are maintained;
o Liaise with the person appointed in the role of Project Safety Manager over the
full range of their duties and responsibilities, with respect to inspections, audits,
report recommendations, changes in legislation and advice obtained from other
sources;
o Ensure adequate means of distributing and communicating health, safety and
welfare information;
o Ensure that an adequate programme of training for health and safety is
established and that the safety culture is encouraged amongst employees;
© SHANICA REV 6 Page 9 of 35
 o Set a personal example at all times by using the correct personal protective
clothing/equipment and following all safety requirements and procedures.

5.2.3. Responsibilities & Job Description: Project Manager (Project Safety Manager)

The primary role of the Project Manager (Safety Manager) is to advise the General
Manager and Programme Manager on all safety, health and welfare matters to ensure
the Company complies with its statutory obligations.

The Safety Manager is designated responsibility by the Manager responsible for health
and safety to control and update this Project HSE Plan and to ensure that all
Departments operate to the procedures and instructions contained there:-

In particular the Safety Manager will:

o Understand the application of the Health and Safety procedures and legislation
relevant to the Companies business;
o Keep up to date with changes in procedure and legislation and to bring to the
attention of the Manager responsible for Health and Safety any relevant new
information;
o Provide visible and active leadership for good health and safety practice with
the project;
o Co-ordinates activities concerned with Health & Safety within the project
o Identifies key priorities and areas for improvement;
o Provide adequate supervision and training (development and refresher training
where appropriate;
o To recommend control measures and advise on the standard of P.P.E. issued to
employees;
o Immediately contact the Manager responsible for health and safety if situations
are found, that in the opinion of the Safety Manager, require immediate
rectification or the stopping of any work;
o To notify the Manager responsible for health and safety if the corrective action
agreed after any workplace inspection is not implemented by the arranged date.
o To carry out investigations into all accidents and near-miss incidents and to
record the findings on the relevant forms;
o To bring new techniques for improving health, safety and welfare to the
attention of the Manager responsible for health and safety;
o Conduct Risk Assessments on activities within their department ensuring that
the methods and systems of work are safe. Also that the necessary procedures,
rules and regulations designed to achieve this are formulated, published and
applied;
o Provide written instructions of work methods outlining potential hazards and
precautions, and ensure they are complied with;
o To set a personal example by wearing appropriate personal protective
clothing/equipment and observing all safety requirements/procedures.

© SHANICA REV 6 Page 10 of 35

 5.2.4. Responsibilities & Job Description: Team Leader

Each Team Leader is responsible for his personal safety and that of all personnel under
his or her authority, including others who may be affected by the company’s activities.

In particular they will:

o Understand and implement the company safety policy and operating

procedures;
o Appreciate the responsibilities of personnel under their authority and ensure
that each employee knows his/her responsibility and are equipped to play their
part;
o Ensure that teams fulfil their responsibilities for Health and safety;
o Ensuring that teams are adequately trained to manage Health and Safety;
o Take all reasonable care for their own safety and that of other persons under
their supervision;
o Report to the Project Manager any situation which they have reason to believe
could present a hazard and which they cannot themselves correct;
o Ensure accident and near-miss reporting procedures are understood and
complied with, and assist with accident investigations where appropriate;
o Ensure all employees and sub-contractors are suitably trained/competent to
carry out the prescribed task and that the necessary licenses/certificates of
competence are in force and appropriate;
o Ensure that all new employees in the company are provided with a copy of the
policy statement, receive such induction training as may be laid down in
procedures, are issued with personal protective equipment as required and
their personal responsibilities as set out in this document;
o Reprimand any employee for failing to discharge their health and safety
responsibilities;
o Set a personal example with regard to health and safety matters.

5.2.5. Responsibilities & Job Description: Employees

The employer and employer have an equal responsibility for Health and safety of
themselves and others. In this connection, the Company reminds employees of their
duties to take care for their own health and safety and that of others who may be
affected by their acts or omissions. Additionally, employees must also co-operate with
the company to enable it to discharge its own responsibilities successfully.

Furthermore, all employees are expected to:-

o Carry out assigned tasks and duties in a safe manner, in accordance with
instructions, and to comply with safety rules/procedures, regulations and codes
of practice;
o If aware of any unsafe practice or condition, or if in any doubt about the safety
of any situation, consult their supervisor;
o Obtain and use the correct tools/equipment for the work and not to use any
that are unsafe or damaged. All tools, equipment and personal protective
equipment must be stored in the approved place after use;

© SHANICA REV 6 Page 11 of 35

 o Ensure that all safety equipment and personal protective clothing/equipment
provided are used;
o Not to operate any plant or equipment unless authorised;
o To report any accident, near-miss, dangerous occurrence or dangerous
condition to their line management;
o To switch off and secure unattended plant or equipment;
o To avoid improvised arrangements and suggest safe ways of eliminating
hazards;
o Not to participate in horseplay or place fellow employees in danger by their
actions.

5.3. Sub-Contractors

A Sub-Contractor is defined as any company providing capital equipment, goods, services or

personnel which will be operated or administered by that company in the field as part of a
Shanica project, and under overall Shanica control.

Shanica requires all its Sub-Contractors to demonstrate standards consistent with

Shanica's HSE-MS. Shanica will not allow Sub-Contractor status to be used as an excuse for
below standard HSE performance.

Sub-Contractors shall be audited in advance of commencing work and shall have to

conform to the requirements of Shanica policies, rules and procedures and the
requirements stated in this HSE Plan.

Sub-contractor equipment and services will be inspected by Shanica to ensure compliance

with standards set in the contract.
Sub-Contractors of Shanica will be expected to take part in an interfacing exercise as part of
project planning.

If a sub-contractor has its own HSE management system, then a bridging document shall be
required.

Sub-Contractor management will be in accordance with OGP document “HSE Management

– Guidelines for working together in a contract environment.

5.4. HSE Communications

HSE information is communicated via a series of documented meetings, reports and

activities.

HSE information shall be publicised within field teams via a HSE notice board as well as
email and verbal communications.

5.4.1. Language

English is the operating language of Shanica.

© SHANICA REV 6 Page 12 of 35

 5.5. HSE Meetings

A programme of HSE meetings takes place at the team level; these include, but are not
limited to:

 Daily toolbox meetings prior to starting work;

 Daily planning meetings;
 Weekly and Monthly HSE meetings;
 Incident/accident review meetings.

Documentation will be made available to the client for checking.

5.6. HSE Promotion and Awareness

Management regularly communicates on HSE to increase awareness and successes and

failures are openly communicated to all staff (employees or Contractors). Suggestions are
recognised and encourage success. All staff are expected to participate in and promote
industry sharing of lessons learnt, e.g. safety alerts, and the company has a system to
continually improve behaviour through observation, recording and coaching.

5.7. HSE Competence Requirements

Shanica will determine the level of competence necessary to ensure the capability of its
personnel to carry out their jobs in full accordance with all associated HSE considerations.
This level of competence acted on in a timely manner and systems are in place to
recognise, reward
will be based on:

 Personal abilities;
 Skills;
 Experience;
 Formal qualifications;
 Training.

5.8. Induction and Orientation

5.8.1. All Staff

It is expected that all Shania project staff will receive a HSE induction from the HSE
department of the client prior to starting work on the project.

This should include but not be limited to, organisation chart, camp layout, emergency
procedures, local customs, driving, drugs and alcohol policies, environmental concerns.

5.8.2. Drivers

If required Shanica drivers will receive, and pass, Defensive Driver Training (DDT) from
the client DDT Trainer prior to starting work on the project.

© SHANICA REV 6 Page 13 of 35

 All HSE inductions and driver training will be recorded and filed in the client HSE
documentation.

5.9. HSE Training

Shanica recognises HSE training as a crucial element of the HSE Management System and
allocates the necessary financial resources to achieve this training.

Shanica adheres to all national regulations and international guidelines regarding the
provision of training to field staff. A database is maintained on each member of field staff,
which includes training details.

5.10. HSE Legislation, Standards and Documents

All applicable HSE laws, rules and regulations of any government or regulatory body having
jurisdiction over Shanica work will be identified and adhered to in each country of that the
company works in.

5.10.1. Industry Guidelines

Shanica follows the guidelines issued by the International Association of Oil and Gas
Producers (www.ogp.org.uk) and IMAS (International Mine Action Standards).

The main industry documents of the above Organisations which are utilised by Shanica
to form a basis for its HSE Management System are:

o OGP “Guidelines for the Development and Application of Health, Safety

and Environmental Management Systems;
o IMAS Industry Guidelines;
o Relevant local laws and regulations governing transportation, labour,
environmental protection, health and safety of workers.

Other industry documents followed by Shanica are referred to in the relevant sections
of this document.

5.10.2. Documentation and Document Control

The documentation associated with the HSE-MS is designed to provide a

description of the system and to serve as a permanent record of the implementation
and maintenance of that system. The documentation enhances the system by:

o Demonstrating the existence of systems and practices;

o Avoiding information being invested solely in individuals;
o Aiding awareness of responsibilities and correct task performance;
o Reducing learning time on new tasks and preventing repetition of errors;
o Providing verification of systems and performance by way of audit.

© SHANICA REV 6 Page 14 of 35

 Full details of HSE records are held electronically within the project working folder.

HSE critical documents shall be controlled documents, including:

o Shanica HSE Management System;

o Project Standard Operating Procedures;
o Key job descriptions;
o Project HSE Plans;
o Journey Management;
o Drug and Alcohol;
o Emergency Response Plans;
o Security Plans;
o HSE critical procedures.

Document control is achieved by making documents “read-only” and by limiting

distribution of documents where applicable.

5.10.3. Management of Change

Shanica recognises that any changes to work routines may give rise to increased risk,
and warrant careful control. Changes in projects, operations, procedures, equipment,
facilities, permits, laws or personnel must be planned to ensure that HSE risks arising
from these changes remain at an acceptable level. It is essential that processes and
procedures for managing change are applied to ensure HSE standards and requirements
are not compromised.

6. HAZARDS AND EFFECTS MANAGEMENT

Effective risk management is a key component of Shanica’s HSE-MS. The company Risk
Management System is based on five processes:

 Identification of hazards;
 Analysis of initial risk;
 Control of risk;
 Analysis of residual risk;
 Recovery from system failures.

These processes are described below.

Environmental Impact Assessments, whether conducted by Shanica or the Client, represent a

specific method of evaluating and managing environmental risk.

6.1. Methods and Procedures

The Programme Manager has conducted a pre-start risk assessment for the project.
Significant common hazards inherent in the work of Shanica have been identified and listed
in the Shanica Risk Assessment document. This covers controls and mitigation measures.

© SHANICA REV 6 Page 15 of 35

 This is a living document and any new hazards identified will be assessed and the risk
assessment updated and discussed with staff at the morning toolbox talk.

All hazards, risks and controls will be communicated to staff during HSE inductions and
safety meetings.

The document lists:

 The category of hazard;

 The incident resulting from the hazard;
 The possible consequences of the hazard and incident;
 Aggravating factors;
 The area of Loss i.e. People, Security, Environment, Financial, Assets, and
Reputation;
 The initial levels of likelihood and severity;
 The initial risk level;
 The preventative measures;
 The recovery measures;
 The residual levels of likelihood and severity;
 The residual risk level;
 The job title of the person responsible for controlling the risk.

The input and output risk analyses on the generic Shanica Risk Assessment show
typical values that may be expected.
The hazard identification process is continuous. Shanica's Risk Assessment is reviewed prior
to the start of each project.

As part of the on-going assessment, controls and recovery measures will be formulated and
documented and implemented.

After this initial review any additional project specific hazards arising from the local
environment or the equipment and techniques in use is carried out, and any such new
hazard and information will be added to the Project Hazard Register/Risk Assessment.

The process is then on-going, identifying new hazards as mobilization, start- up and work
proceeds.

6.2. Assessment and Exposure

Every reported hazard is analysed for risk level. Where possible this should be a
quantitative process, but the nature of Shanica’s work often involves risks that can only be
subjected to qualitative analysis. This qualitative process is based on the knowledge and
experience of the person/s conducting the analysis.

Bias is reduced by ensuring that risk assessments are conducted by a team of personnel,
and by use of the Shanica Risk Matrix. Initial risks can be categorised as being high,
medium, or low.

© SHANICA REV 6 Page 16 of 35

 6.2.1. Control of Risks

Risks are reduced and controlled by the application of the following hierarchy of
reduction and mitigation measures:

o Eliminate;
o Substitute;
o Reduce;
o Isolate;
o Procedure;
o Protect.

6.2.2. Analysis of Residual Risk

After controls have been applied, residual risk is examined to judge if the risk level is
acceptable for activities to take place, i.e. below high risk. Residual risk should be as low
as reasonably practicable (ALARP).

ALARP means that risk is reduced to levels such that further risk reduction measures
would be so disproportionate to the probability of occurrence, or the severity of the
outcome, that it would be objectively unreasonable to implement them. All risks should
be reduced to this level (though this does not imply that all risks can be reduced to low
levels).

High risk to projects is intolerable. Where residual risk is assessed as high, the planned
work or task must be changed to reduce risk to at least a medium level.
Projects and tasks may therefore be conducted with medium or low risk levels.

6.2.3. Recovery from System Failures

Measures to recover from the unintended release of any hazard are put in place to
mitigate the effects of the release. These measures may be simple, e.g. first aid kits, or
complex, e.g. emergency plans. They are included with the controls in place to prevent
the hazard being released.

6.3. Assessments of PPE Requirements

Risks to health and safety shall be controlled by elimination, by engineering controls, or by

procedural or administrative processes first. PPE only protects the wearer.

Shanica realizes that even with the application of safe systems of work, residual risk exists
at worksites that require a base level of PPE to be worn at all times. Only personnel
wearing the appropriate equipment shall be allowed to carry out their work on the
worksite.

Specific PPE requirements over and above any base level PPE will be determined by
risk assessment and is generally provided at the worksite.

The physiology of the individual (i.e. their size, dimensions, etc.) shall also be taken into

© SHANICA REV 6 Page 17 of 35

 account as this will have an impact on the type of PPE that can be worn or the effectiveness
of an item of equipment. Where more than one size or type of PPE may be required this
shall be provided.

Personnel shall be supplied with information and training on the correct selection,
use, care and maintenance of PPE. This information shall include but is not limited to:

 An explanation of the hazards that the PPE is designed to provide protection

from;
 Method of use including correct fitting and method of wearing, performance
and limitations of the equipment;
 Circumstances where PPE shall be used;
 Action to be taken by personnel to maintain and store PPE in effective
condition.

The information above will vary greatly depending on the nature of the PPE itself. Training
will be carried out in-house.

6.3.1. Personal Protective Equipment (PPE)

PPE will be made available to all staff. This will be appropriate to their role and the tasks
being undertaken and in accordance with the risk assessment for each project.

6.4. Explosive Remnants of War (ERW) and Minefields

There has been periodic conflict within the area dating back to the 1970’s. This escalated
particularly during the Iran/Iraq war (1980-1988) and decreased during the First Gulf War
(1990-1991) and Second Gulf War (2003).

During these periods the area was contaminated by anti-personnel mines, typically around
defensive positions on the high ground, as well as being subjected to air, artillery and
infantry munitions strikes with further evidence of Explosive Remnants of War (ERW)
including anti-tank mines; and artillery, mortar and grenades.

There therefore remains a serious risk of serious personal injury and possible fatality in
these areas. Vehicles are also at risk of being damaged if driven over anti-personnel mines.
An added hazard is the barbed (razor) wire that is often positioned near contaminated
areas to prevent people from entering the areas. This could cause deep flesh wound if
contact is made.

There will be very strict security control measures to prevent any personnel from entering a
contaminated area.

Shanica have been contracted by to develop and implement an ERW mitigation plan to
ensure the safety of project staff.

© SHANICA REV 6 Page 18 of 35

 Control measures will include:

 The client will conduct mine/UXO Awareness and Safety training for all staff
before being they are allowed to work on the line;
 Shanica clearance teams will clear all work areas;
 The boundaries of cleared areas so that there is no ambiguity between areas
that are ‘safe’ ad ‘unsafe’;
 Implement a robust ‘permit to work’ system;
 The client will produce project hazard maps and line access maps that clearly
identify UXO/mine threat areas and the safe corridors for work. These shall be
discussed each day will all line crews at their respective daily section meetings.

6.4.1. Safe Work Procedures

Shanica has documented its safe work policies and procedures within the Project
Method Statement. These policies and procedures are designed to ensure that safe
work practices are followed and the safe use of equipment at the work site to
complete tasks with no significant risk to personnel, property pf the environment.

6.4.2. Permit To Work

6.4.2.1. ERW Coordination

Responsibility for the coordination of the clearance process is with the client UXO
Coordinator. The client UXO Coordinator is the primary point of contact for the
Shanica Project Manager and will inform him in a timely manner of client intentions
and clearance support requirements.

6.4.2.2. Tasking Orders

Each significant task is documented within an ERW Tasking Order, issued in writing
by the client UXO Coordinator to the Shanica Project Manager. This details the start
and end coordinates, reference details, proposed start date as the nature of the
task.

Where insufficient time is available to prepare a formal tasking order the task can
go ahead but must be followed by a written tasking order within 24 hours. In this
event the Project Manager must be notified at the time of tasking by the client UXO
Coordinator (by email).

In order to book a clearance team, client had to give a detailed request of their
requirement to the client UXO Coordinator at least 12 hours before a clearance
team was required to give adequate time for planning and coordination.

6.4.2.3. Clearance Certificates and Permit to Work

The Project manager will issue client a Clearance Certificate for each area that has
been cleared.

© SHANICA REV 6 Page 19 of 35

 Clearance Certificates certify that an area is free from ERW and that the client can
then conduct survey related works on that area. It is important that no work is
conducted on these areas until such time as this certificate was been completed.

6.5. Terrain Assessment

A thorough Terrain Assessment must be conducted prior to the start of work. The terrain
shall be classified in accordance with the guidelines in the Mountain Work Rule
&Procedures;

Initially a desktop terrain assessment shall be done by the Survey department.

Subsequently, a Secondary and documented Terrain Assessment shall be done by the
Survey Department and Mountaineers (if RED zones are identified).

Class 1 and 2 terrains – Open to all field personnel regardless of

fitness level.
Class 3 and 4 terrain – Accessible only to personnel who meet
minimum fitness requirements and who have been trained and
demonstrated competency in more rugged terrain and when
appropriate rescue and evacuation systems are available.
Class 5 and 6 terrain – Accessible only to mountaineers who have
been trained in the use of fall protection and rope access systems and
when appropriate rescue and evacuation systems are available.

6.6. Journey Management

Vehicle movements should be restricted to the absolute minimum required for the safe
completion of the project. Vehicle movement and driving are a significant risk on the
project. Shanica will implement a Journey Management Procedure (see additional
document - Journey Management Procedure).

In addition Shanica is required to comply with client journey management requirements

including real time personnel and vehicle tracking.

6.7. Local Traffic

There is a high potential for road traffic accidents and the potential for multiple injuries and
fatalities with vehicles transporting personnel (every day on project), unless safe driving
and journey management procedures are followed.

Traffic hazards include:

 Narrow roads, blind bends blind hills;

 Roads zigzag up and down step gradients because of the nature of the terrain;
 Poor driving behaviour among local drivers (high speeds and dangerous
overtaking slow moving vehicles);
 Gravel tracks and graded roads with dust;
 People and animal is densely populated areas.

© SHANICA REV 6 Page 20 of 35

 Control measures must be implemented to prevent accidents. There shall be:
 Vehicles inspection before being allowed to work on the project;
 Strict driver selection;
 Journey management;
 Mandatory speed limits and wearing of seatbelts;
 No night driving (unless authorised in exceptional circumstances);
 Drug and Alcohol testing (where required).

6.8. Methods and Procedures for Waste Management

The waste minimisation and management plan will include an on-going, concerted
waste minimisation effort, as well as proper waste storage, transportation and
disposal. It will also involve the documentation of waste management activities.

Each site shall have a waste minimisation and management plan that identifies each
waste stream generated, the process generating the waste, the hazardous nature of the
waste source, reduction and recycling options, the disposal options (methods and
locations), and the ultimate disposal location. The plan will include a program to
evaluate and document all waste recycling and disposal sites used.

Waste management efforts shall focus on waste minimisation (source reduction, reuse,
and recycling) as the preferred course of action, thus limiting the amount and toxicity of
waste that must be stored, transported, and disposed. Managing waste by disposal is
not considered waste minimisation and should be considered only after waste minimisation
efforts have been exhausted.

6.9. Fire

Measures must be taken to guard against fires, both in residential/camp areas and during
projects.

 Good housekeeping will be established;

 Smoking shall only be allowed in designated smoking areas (no smoking in
offices, work areas or accommodation);
 Regular inspection will be initiated to ensure that fire prevention rules are
followed and fire detection and fighting equipment is serviceable;
 An integral part of safety training will be the dangers of fire, particularly during
the summer months whilst working on projects.

6.10. Disease

There is always a risk of water borne disease in post conflict areas or those prone to conflict
and civil unrest. For example there have been 2 outbreaks of Cholera in Kurdistan in the last
6 years.

The disease can passed on through:

 Contaminated water & food supplies;

© SHANICA REV 6 Page 21 of 35

  Dirty hands;
 Contact with vomit or stools of sick people.
Preventative measures include:
 Good hygiene practice is necessary to safe guard crew employees;
 Chlorinating the crew water supply at source (or drinking bottles water);
 Washing hands after toilet & before preparing or eating food;
 Clear signage in Kurdish/English for hand-washing;
 Providing information to employees on how to avoid sickness;
 Eating freshly cooked food and avoiding cold uncooked food;
 Avoiding eating from street side food outlet.

6.11. Heat and Cold/Wet Management

Due to the extremes in weather conditions and temperature during the different seasons, it
is necessary that Heat & Cold Management Procedures are applied. This shall cover the
signs, symptoms, emergency response actions for heat and cold related illnesses.

The Heat & Cold/Wet Management Procedure covers:

 Heat and cold management;
 Frostbite and hypothermia;
 Camps, exhaustion and stroke.
The procedures shall include requirements that ensure:
 Heat & cold management training to all workers;
 Provision of appropriate PPE and clothing for weather conditions;
 ‘Right to Stop Work’ when temperatures are extreme;
 Medic on site monitors the shade temperature on an hourly basis and a log of
the recorded temperatures is maintained.

6.11.1. For Hot Conditions:

Temperatures during the hot season (May to September) range from 35° to 43°.
o Workers are educated on hot weather injuries;
o There is an adequate supply of water or all workers;
o As summer temperatures increase, plan to re-fill vehicle water tanks
and issue rucksacks capable of water carriage to staff;
o Rest breaks are scheduled into work;
o All staff are provided with cotton uniforms and head protection (can include
safety helmets, caps or hats);
o An dedicated vehicle for the medic carries adequate amounts of IV solution to
treat victims of heat exhaustion or heat stroke;
o Work shall cease in extremely hot weather conditions (in excess of 50°c).

© SHANICA REV 6 Page 22 of 35

 6.11.2. For Cold/Wet Conditions:

The temperatures during the winter months (December to March) drop significantly -
range from 1° to 15° and heavy rain is common. This rain can make tracks
impassable/slippery and create a major safety hazard. The decrease in temperature
coupled with rain increases the risk of cold weather injuries.

o Workers are educated on cold weather injuries;

o Workers are provided with suitable warm, foul weather clothing to prevent cold
related illnesses such as frostbite and hypothermia;
o Work shall cease in heavy rain/snow/blizzard conditions.

6.12. Drugs and Alcohol

In those countries where Shanica is allowed to test for A & D by law, Shanica shall include a
clause in the labour hiring contract that will include the right to remove person from the
team(s) if they are tested positive. Driving a vehicle under the influence of alcohol or drugs
shall be strictly prohibited.

Details are contained in the Shanica Policy document on Drug & Alcohol.

6.13. Security

Due to the instability within the Kurdistan region there will be a security presence within the
project area at all times. Shanica staff comes under the security ‘umbrella’ of the client and
their security team. For the purpose of this document, and project, security team includes
the client security staff, sub-contractors and OPF. The client will remain contact point for all
security issues and the dissemination of security information.

The security plan put in place by the client will be appropriate to the risk and levels of
exposure.

The client concept revolves around a layered security strategy built on a robust hearts and
minds community relations and liaison programme.

6.14. Management of Change

Changes in projects, procedures, equipment, facilities, permits, laws or personnel must be

evaluated and managed to ensure that the total effect of the change is controlled, worth
the effort and the final result is better for the people, the environment and the Client.

Routine changes deemed necessary can be made by the Project Manager with final
approval required from the Shanica Programme Manager.

In the event of any major changes, deviations from procedures, changes in methodology,
new equipment or process changes, these are to be documented by the Project Manager
and submitted to the Programme Manager for approval prior to implementation.

© SHANICA REV 6 Page 23 of 35

7. PLANNING AND PROCEDURES

7.1. HSE Procedures

This document will constitute the project HSE plan for each project. This plan will constitute
a combined team and project HSE plan.

Four major planning processes which will be included in the HSE plan are:

 Risk Assessment;
 Environmental Management Plan;
 Journey Management Plan;
 Security Plan;
 Emergency Response Plans.

7.1.1. Job Safety Analysis (JSA) and Work Procedures

Field HSE procedures are designed using the Job Safety Analysis process, followed by
the Work Procedure process.

7.2. Basic HSE Rules

The field HSE procedures are prepared for any activities where the absence of such
procedures and standards could result in infringement of HSE policy, legislative
requirements or other performance criteria. Particular priority will be given to
production of procedures required to control major risks, and those associated with asset
integrity.

Standard Operating Procedures are stored in the Shanica HSE Procedure Folder. This is a
company resource, which individual teams can use for guidance to develop procedures
specific to their work.

New team or project specific procedures will be added to those in the above mentioned
folder.

7.3. Emergency Response Plan (ERP)

The risk management process may identify situations which may be considered as having
the potential to become emergencies, where life may be endangered or the whole team is
placed in danger. Because of the nature of geophysical acquisition projects, Shanica
requires that the following emergency response scenarios are covered by an ERP:

 UXO;
 Medevac;
 Spills;
 Fire;
 Security.

© SHANICA REV 6 Page 24 of 35

 Individual contracts may require further emergency plans depending on local conditions.
These may be for natural hazards, civil unrest, war or other risks. Responsibility for the
design of emergency plans will be allocated by the Project Manager.

Emergency Response Plans for projects must be included in the HSE Plan.

Emergency drills will be carried out to test the effectiveness of the ERP.

7.4. HSE Equipment and Inspection

All HSE equipment will be inspected on a regular basis during the project period; this will
include but not be limited to:

 UXO detection tools inspected on a daily basis;

 Vehicles on a daily basis;
 PPE on a daily basis;
 Camp fire alarm on a weekly basis and also when a fire exercise is carried out;
 Fire extinguishers and smoke alarms on a monthly basis.

All faulty equipment will be report following the chain of command, repairs and or
replacements will be completed in a timely manner.

7.4.1. Vehicles

Shanica shall adhere to the following vehicle guidelines:

o All vehicles are to be made available for inspection (and passed as

suitable/serviceable) by a suitably qualified member of the clients group to
starting work on the project;
o Vehicle seat belts must be worn at all times when driving. It is each vehicle
driver’s responsibility to ensure compliance of all passengers;
o All vehicles and equipment will be turned off while fuelling;
o Vehicles being refuelled must not be left unattended;
o Vehicles travelling between sites will be subject to a Journey Management Plan
which will be strictly enforced;
o All drivers shall be properly licensed for the type of vehicle they are allowed to
operate;
o Freight carried inside a vehicle’s passenger compartment is to be firmly secured;
o Backup (reversing) audible alarm devices are mandatory on all field vehicles;
o Speed limits are controlled by local laws and drivers are to adhere to those laws;
o The driver of the vehicle is to inspect the vehicle for faults and serviceability
prior to starting work each day;
o Drivers are not to use mobile phones while driving a vehicle;
o All Vehicle journeys will be subject to a Journey Management Plan which will be
strictly enforced.

© SHANICA REV 6 Page 25 of 35

 7.5. Occupational Health

Shanica recognizes the need to reduce risk and to provide safe working environments
which are fundamental principles of mine action management. In doing so the company
complies with the regulatory body IMAS.

The International Labour Organisation (ILO) has established minimum norms and basic
standards which regulate conditions of work and safety in the work place.

These standards apply to all branches of economic activity and categories of employment,
including mine action, unless specifically excluded by national legislation. Notwithstanding
the legal requirements, mine action imposes a moral imperative and duty of care by
managers at all levels.

7.6. Medical Support Staff (MSS)

There will be a MSS with a dedicated safety vehicle on site during projects. The exception to
this will be in those instances when a Small Demining Team (SDT) is utilised whereby the
team will be supported by a course qualified MSS, but no dedicated safety vehicle will be
used. This will apply equally to all projects. All projects are to stop if these requirements
are not met. The safety vehicle will comply with the requirements detailed in para 5.4.1.

NOTE:
The MSS used by Shanica is not to be confused with a Trauma Medic. The MSS is course
qualified to provide immediate assistance to Shanica staff in the event of an incident

The Safety Vehicle is not an ambulance. The International Mine Action Standards (demining
industry guidelines) state that the vehicle must be capable of carrying a casualty on a
stretcher, with attendant, with the back doors closed.

7.6.1. Medical Facilities

Good medical facilities exist in Kurdistan. The nearest to Qara Hanjeer being in
Sulaymaniyah and then in Erbil. Further details are contained in the project Emergency
response Plan (ERP).

7.7. Journey Management

As transportation and driving has been identified as a major risk within Kurdistan, Shanica
will implement a project specific Journey Management Plan.

This Journey Management Plan shall describe the criteria to be used for all journeys.
Additionally, it shall outline the methods to be used for monitoring journeys and personnel
in the field, and the responsible person for that monitoring.

Shanica will refer to OGP document “Land Transportation Safety Recommended Practice,
with respect to guidance on Journey Management issues.

© SHANICA REV 6 Page 26 of 35

 7.8. Drivers and Vehicles

One of the most dangerous activities undertaken on projects is driving. The purpose of the
Shanica driving rules and procedures is to establish minimum requirements for safe use of
Shanica and contractor vehicles.

The procedures cover:

 General driving rules;

 Graded road and off-road driving;
 Vehicle reversing;
 Vehicle parking;
 Vehicle breakdown and recovery;
 Wheel changing;
 Vehicle hijacking.

The rules shall include:

 Drivers must hold a valid license for the type of vehicle driven;
 Undergo the driver selection process;
 Have his driving record checked;
 Be medically fit for driving;
 Have an accident free history;
 Documented vehicle inspections;
 Pre-works A&D testing (where required);
 A&D testing after each accident;
 A&D testing with reasonable suspicion;
 Reversing alarms;
 Driving safety rules.

8. IMPLEMENTATION AND MONITORING

8.1. HSE Performance

Activities and tasks should be conducted according to the procedures and plans outlined in
Section 5, following the risk management routines described in Section 4, and through the
line management processes stated in Section 3.

Shanica undertakes both pro-active and re-active monitoring of HSE factors.

Pro-active monitoring includes the tracking and logging of such events as:

 HSE meetings;
 HSE audits and inspections;
 HSE inductions and training.

© SHANICA REV 6 Page 27 of 35

 Re-active monitoring includes the tracking and logging of:

FAT Fatality
LWDC Lost Workday Case
LTI Lost Time Injury
RWC Restricted Work Case
MTC Medical Treatment Case
TRI Total Recordable Injuries
FAC First Aid Case
NM Near Miss Incident
HPI High Potential Incident
ENV Environmental Damage
MAT Material Incident/Accident
INC Incident - Nonspecific
CD Cultural Damage

Exposure hours are also monitored as they provide a basis for normalizing performance
between teams of varying manpower levels.

The exposure hours and the re-active HSE factors allow incident frequencies to be
calculated and monitored i.e. Lost Time Incident Frequency (LTIF) and Total Recordable
Injury Rate (TRIR).

The injury classifications correspond to those of the OGP.

The key HSE statistical monitoring document is – Project Manager Daily Reports.

Monitoring may also take place of medical activities and environmental factors.

A further important monitoring document is the Action Point Register (APR), where action
points are logged

8.1.1. Records

Shanica maintains a system of records in order to demonstrate the extent of

compliance with the HSE-MS.

Retention times of records have been established and recorded, and records are
classified with respect to availability and confidentiality.

8.1.2. Non-Compliance and Corrective Action

Non-compliance with specific requirements of the HSE-MS will be identified through

means of:

o The monitoring program;

o Incident investigations;
o HSE and toolbox talks (tailgate meetings);

© SHANICA REV 6 Page 28 of 35

 o The observation card program;
o Interaction with Client;
o Feedback from stakeholders.

Incident/accident action items will be logged in the Action Point Register (APR). The
APR will be the control document for closure of the corrective action.

8.2. Incident Investigation and Follow Up

An incident report is required for any event or chain of events (no matter how minor),
which has caused or could have caused injury, illness, damage to assets, impact to the
environment, or affected the quality of work produced.

Reporting and investigating incidents is conducted in order to avoid reoccurrence.

A healthy HSE culture promotes reporting of near misses, unsafe acts or situations, quality
weaknesses, environmental impacts and human right abuses.

The procedure includes:

 The required composition of the investigation and reporting team;

 The actions to be taken immediately after an incident;
 The actions to be taken by the investigation team once assembled on site;
 The steps to ensure lateral learning from an incident;
 The process of incident follow-up.

8.2.1. Incident Reports

The categories of work related losses which are recorded on Incident Investigation
Reports are listed the incident reporting and classification document.

Definitions of relevant OGP classifications are provided in the same document.

A copy of the Shanica's standard Incident Investigation Report Form is available in the
HSE Program folder.

Other Near Misses, as well as Unsafe Acts and Conditions, are reported through
the observation card program.

Initial reports are submitted within strict time limits according to outcome.

Action items listed in Incident Reports are added to the Action Point Register, as are
those from incidents logged through the Near Miss Card program.

© SHANICA REV 6 Page 29 of 35

9. AUDITING AND REVIEW

Audits will be conducted to ensure that the HSE-MS and HSE Plans are working by making a
comparison between the contents of documentation and what is happening on site. They will
assist managers and teams with the implementation of the HSE-MS and their individual
HSE Plans and ultimately enhance HSE performance.

HSE audits are seen by Shanica as a positive process designed to:

 Determine whether or not the HSE Management System elements and activities;
 Conform to planned arrangements, and are implemented effectively;
 Confirm compliance with relevant legislative and contractual requirements;
 Identify areas for improvement leading to progressively better HSE management.

Shanica recognises OGP document “Guidelines for HSE Auditing in the Geophysical Industry as
a basis for conducting internal HSE audits, and co-operating with external HSE audits. A copy
of this document is stored electronically in the Shanica office.

9.1. Availability

Shanica will co-operate with any audits of the HSE Management System carried out by
clients or third party independent auditors.

Internal team audits will be conducted by Shanica corporate management or team staff.

Team audits may be external, and conducted by client personnel or third party
independent HSE auditors. Shanica will co-operate with any such audits.

9.2. Remedial Work Plan (RWP)

The RWP shall be the central data base of ALL action points arising from any sources
(audits, inspections, drills, exercises, incidents, hazard reports, near miss reports, safety
suggestions, good ideas, observation reports, etc.) so they can be tracked and reviewed
systematically by the Project Manager through to closure.

9.3. Reviews

Reviews shall be carried out at least once per month of all closed action points to ensure
that their implementation has been effective. This is the responsibility of the Project
Manager who shall chair the HSE Committee meeting in order to carry out this review.

9.4. Scope

Each team develops inspection checklists to ensure that controls are in place, routine
checks have been done, and to verify HSE action points have been closed or are on
schedule for closure. Any new checklist created is stored electronically in the HSE Program
folder

© SHANICA REV 6 Page 30 of 35

 9.5. Coverage

All Elements of Shanica field teams will be audited and/or inspected on a regular basis.

9.6. Effectiveness

Audit function plays an important part in Shanica's risk management. In order to be

effective, the audit/inspection will work on the basis of an audit methodology that explicitly
focuses on risk management.

9.7. Follow Up

Audit recommendations require prompt resolution and implementation of corrective

actions so that audit benefits can be realised. This will be carried out in the following
manner:

 Enter action items in to the Remedial Work Plan;

 Assign responsible party;
 Assign a target date for closure;
 Ensure the action items are being closed out;
 Verify at next audit.

9.7.1. HSE Audits of Sub-Contractors

Auditing of Sub-Contractors by Shanica will always be carried out.

9.7.2. Final Project Evaluation

Whenever possible, Shanica holds meetings with clients following the completion of a
project to review:

o The HSE evaluation and performance;

o Learning points and recommendations for future projects.

9.7.3. HSE-MS Review

Shanica management carries out an annual review of the HSE-MS and its performance.
The timing of the annual HSE review corresponds to the fiscal year cycle. The review
includes, but is not limited to, the following:

o Updating the HSE policies and objectives in the light of changing circumstances
and the commitment to strive for continual improvement;
o Resource allocation for HSE-MS implementation and maintenance;
o New HSE hazard and emergency planning situations;
o Recommendations from Team and any HSE-MS audits.

All changes will be approved and authorized by the Programme Manager before
distribution.

© SHANICA REV 6 Page 31 of 35

10.ENVIRONMENTAL MANAGEMENT

Shanica will adopt and implement a range of environmental management techniques which
will be documented in the Environmental Management Plan.

The plan is intended to:

 Address the mechanism through which the environmental mitigation and control
measures will be implemented;
 Propose actions to be taken in response to emergencies; and to lay down the required
documentation, communication and reporting procedures;
 Ensure that commitments and avoidance mitigation and controls are implemented;
 Ensure that all environment-related legal obligations are met;
 Ensure that any necessary post-works restoration is completed properly;
 The plan describes the feature and practices to mitigate the environmental impact
during the project.

These shall include:

 Projects will meet regulatory guidelines as required by the Kurdistan Region of Iraq;
 Encouraging environmental, regulatory and socioeconomic awareness at all levels;
 Establishing both personal and management environmental responsibilities;
 Emergency procedures to respond efficiently to environmental incidents.

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ABBREVIATIONS

ALARP As Low As Reasonably Practicable

APR Action Point Register
CD Cultural Damage
CEO Chief Executive Officer
DDT Defensive Driver Training
EIA Environmental Impact Assessment
EMP Environmental Management Plan
EMS Environmental Management System
ENV Environmental Damage
ERP Emergency Response Plan
FAC First Aid Case
FAT Fatality
HPI High Potential Incident
HSE Health, Safety and Environment
HSE Health, Safety, Security and Environment
HSE-MS Health, Safety, Security and Environmental Management System
IAGC International Association of Geophysical Contractors
INC Incident - Nonspecific
IPIECA International Petroleum Industry Environmental Conservation Association
JSA Job Safety Analysis
LTI Lost Time Incident/Lost Time Injury
LTIF Lost Time Incident Frequency
LWDC Lost Workday Case
MAT Material Incident/Accident
MoC Management of Change
MTC Medical Treatment Case
NM Near Miss Incident
OGP International Association of Oil and Gas Producers
OSHA Occupational Safety and Health Administration
PTW Permit to Work
RA Risk Assessment

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 RWC Restricted Work Case
TRI Total Recordable Injuries
TRIR Total Recordable Incident Rate
WMP Waste Management Plan

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APPENDIX A: HSE ORGANISATION CHART

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