BTME HSE Plan
BTME HSE Plan
BTME HSE Plan
A 01.09.2014 Updated to New House Style & Various sections. MSA AVD
All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means without
permission of the publisher.
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Table of contents Page
0 Preamble 5
1 Objectives 7
1.1 Understanding the organization & its context 7
1.2 Understanding the needs and expectations of interested parties 7
2 Responsibilities & Communication 8
2.1 Responsibilities 8
2.2 Compliance 10
2.3 Bilfinger Life Saving Rules 11
2.4 Procurement 11
2.5 Communication, Participation and Consultation 11
2.6 Documentation 12
3 Hazards, Risks & Control 13
3.1 General 13
3.2 Bilfinger Tebodin Middle East Offices 15
3.3 Secondments and Site Visits 16
3.4 Driving 16
3.5 Field Trips 17
3.6 Construction Management 17
4 HSE in Design & Outsourcing 20
4.1 HSE in Design 20
4.2 HSE in Outsourcing 21
5 Legal Requirements 22
6 Personal Protective Equipment 22
6.1 Standard PPE 22
6.2 Specific PPE 22
6.3 PPE Procedure 22
7 Incidents 24
7.1 Responsibility Scope 24
7.2 Root cause analysis (RCA) 26
7.3 Lessons Learned 27
8 Competence & Training 29
8.1 Competence 29
8.2 Training 29
9 Performance Measurement, Monitoring and Reporting 31
9.1 General 31
9.2 Audits & Non-Conformities 31
9.3 Management Review 32
10 Improvement 33
10.1 General 33
10.2 Incident Non Conformity and Corrective Action 33
10.3 Continual Improvement 33
Appendix
2. Training Program
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4. Risk Assessment Flow Chart
Amendment Record
Paragraph Page number Description of amendment Revision date
- All pages Formats and layout changed as per new house style 01.09.2014
2.2 - 2.4 10-11 Compliance, Lifesaving rules and Procurement added 01.06.2016
- All pages Minor updates inline with ISO 45001 standards 03.01.2021
Reference Documents
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The occupational health and safety of everyone who works for and with us, the impact of our operations in
the communities and environments we work in and top-quality service lie at the core of mission,
vision and values. We aim to reduce any impact on people and the environment to zero.
In the Bilfinger Tebodin Middle East Occupational Health Safety & Environment (HSE) Manual, we have
translated the Bilfinger Integrated HSEQ Policy Statement, and Corporate Global HSE standards. and the
Bilfinger Business Principles (see figure 1 for the hierarchy of documents) into a set of objectives,
procedures and forms as indicated in figure 2. This manual is guidance for Management and Workers of
BTME in their way to increase HSE awareness. This manual shall also meet the criteria for ISO 45001 and
ISO 14001 certification (see appendix 3 for cross reference table). The scope of the business activities
covered by BTME is referenced in the following statement, which also is the basis of the scope of our ISO
45001 and ISO 14001 certification.
, Engineering, Consultancy, Procurement, Project and Construction Management services for, but
not limited to Chemicals, Oil & Gas, Industrial, Civil & Structural, Water & Infrastructure sectors (office and
/ or site based)
Bilfinger Tebodin Middle East HSE manual is available for all BTME via Sharepoint and intended to be a
real time on-line system. Because of this only documents viewed on-
Definitions and abbreviations are given in appendix 1.
MiViVa
Policy HSEQ
Business
Principles
Code of Conduct
Manual TQM
BTME HSE Manual
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Figure 2: BTME HSE Framework
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Bilfinger is determined to deliver sustainable solutions that enrich communities in which we work
and live. A safe working environment in which our workers can maximally develop their talents and
skills is a prerequisite for our success. Zero Harm is the guiding principle of our HSE culture. An
outstanding safety culture and first rate performance is essential to a successful business and
helps us reach our goal of being both a top class employer and service provider.
The above Bilfinger mission shall guide BTME in our behaviour toward Occupational Health, Safety and
Environment excellence through:
Putting the safety of our employees and those working under our responsibility as our highest priority;
Always targeting Zero Harm injury to our people and contractors (IF-formula see chapter 7) and Zero
impact on the environment;
Relating our activities to the local risks that we (pro-actively) identify and assess;
Adopting a management system that continually aims to increase the HSE AWARENESS of our
workers, clients and (sub) contractors;
Regularly reporting our successes, failures and status of our HSE behaviour;
Actively monitoring, auditing and reviewing our management systems in order to identify areas of
continuous improvement;
On a BTME level these objectives shall each year be made specific, measurable, acceptable, realistic and
time-bound (SMART) in the Balance Score Card of the Director and by issuing an annual HSE Action Plan.
purpose, objectives and sustainability. The Top Management of BTME shall identify all internal and external
issues that are relevant to its strategic directions and business objectives. Further details to identify the
external and internal issues, please refer sec. 1.6 of Bilfinger Tebodin Integrated Management system.
All BTME employees are responsible to implement HSE management system for its effectiveness and to
meet customer and applicable statutory and regulatory requirements.
Management determines, needs / requirements and expectations of interested parties for compliance
obligation through various means. Further details to set the needs and expectations, please refer sec. 1.7
of Bilfinger Tebodin Integrated Management system.
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The organogram of Bilfinger Tebodin Middle East is given in figure 3.
It is the role of the Bilfinger Regional Management to take initiatives, set corporate targets and report on
trends in order to support the Offices in continually improving the HSE awareness. The Bilfinger Board of
Directors HSEQ policy and ensure that is within the
defined scope of its HSEQ Management System.
BTME Managing Director (MD) is responsible to ensure that the HSE management system is established,
implemented and maintained at BTME in accordance with Corporate and regional requirements. Monitor
the performance of various offices of BTME concerning HSE Management objectives and provide the
framework for setting and reviewing OH&S objectives. BTME Managing Director is responsible to ensure
sufficient man power and resources are provided in the offices to develop and implement HSE in the
region.
In Bilfinger Tebodin Middle East the main responsibility for HSE lies with the Directors for their Country
/Offices. The Director shall appoint and instruct various employees in the office to delegate HSE tasks
and take responsibility for all EHS communications with stakeholders. The Directors are committed to
comply with the applicable legal requirements and all other requirements to which the organization
subscribes and that relate to its OH&S hazards. The Directors shall assess the risks to health and
safety of workers and ensure the provision of a safe workplace for all personnel in the office and site
to avoid incidents/injuries and/or minimize pollution to the environment.
The HSEQ Coordinator supports the Director for the execution and coordination of HSE tasks.
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Table 1 shows a division of responsibilities for HSE tasks in an office
Additionally all our management, workers, freelancers, visitors and subcontractors are given the following
mandates:
a) Each individual related to BTME shall always take responsibility to stop their own work immediately in
case he/she is exposed to an unacceptable risk (and report to the Department Manager/Construction
Manager).
b) Each individual related to BTME shall always take responsibility to immediately stop any site activity in
case of unacceptable and immediate HSE hazards (and report to Construction Manager/ Department
Manager).
BTME
Managing Director(s)
BTME
HSEQ Manager
HSEQ Coordinator
HSEQ Coordinator
Employees Employees
Figure 3 Organogram
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Subject Chapter Main Responsibility = , Delegated Responsibility = X
MTD/ HSEQ
MD Director PM CM
DM Coordinator
Objectives 1 X
Communication 2.2 X X
Environment 3.2
Driving 3.4 X X
Construction 3.6 X
Management
Design & 4 X
Outsourcing
Legal Requirements 5
PPE 6
Incident Report 7 X
Competence 8.1
Training 8.2 X X
Performance 9.1
Measurement
Management 9.3 X X
Review
Compliance with all the relevant requirements, particularly regulatory requirements, is a top priority for
us. We regularly determine these requirements in a systematic manner, derive appropriate actions and
document the results.
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All Offices must implement documented processes to ensure compliance with relevant HSE customer
requirements, legal requirements and HSE standards. The process must comprise at least:
The Bilfinger Life Saving Rules are a compilation of eight elementary rules for occupational safety.
Their purpose is to protect the lives of all workers who are exposed to risk in the conduct of their work.
We expect that all colleagues and the people we work are comply with these rules and take a conscious
approach to workplace safety and raising awareness of the dangers.
By not complying with the Life Saving Rules an woker exposes themselves or others to a higher risk
of injury or fatality. Failure to comply with any Life Saving Rules will result in disciplinary action .
Offenses against occupational safety requirements endanger people, the environment and materials.
Violations are not tolerated and will be punished with the appropriate consequences regardless of
the person or their position in the organization. BTME views these consequences as an integral part
of its culture of responsibility and care for its workers. Our goal is to guide our employees in working
safely and thus to prevent accidents, injuries and damages.
The procurement process is regulated by Procurement Manual. Requisitions for purchasing must take
into account relevant legal HSE requirements. To support the safe, environmentally sound and legally
compliant procurement of machinery, equipment, labor and resources, each organization must
establish and implement appropriate processes.
When choosing suppliers, relevant HSE requirements as well as HSE risks associated with the
execution of the contract must be taken into account.
Subcontractor requirements, as well as products and services that have yet to be acquired must be
contractually agreed upon. This includes, among other things, HSE minimum requirements,
requirements for products, services, equipment, procedures, processes, qualifications and systems.
The performance of service providers or subcontractors should be evaluated regularly.
If crises or serious incidents arise, external communications are governed by the Crisis Management Plan.
In such cases, the top management and the corporate communications department of Bilfinger SE will
handle all communications with the media and the public.
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Only by open communication and collaboration shall our actions result in increased awareness and Zero
Harm.
The management plays a crucial role in creating a culture of open communication and showing leadership
(walk the talk).
Starting all our meetings with addressing HSE topics (with minutes);
Involving employees in setting the objectives and targets;
Encouraging the employees in reporting Occupational Health, Safety and Environment Incidents;
Explaining the importance of corporate HSE themes for example Zero Harm and Intervention Saves
Lives;
Worker participation on HSE issues shall be encouraged through brainstorming sessions, open
discussions, workshops and suggestion schemes where any accepted suggestions / initiatives
may be awarded;
Presenting and discussing incident reports and lessons learned;
Addressing HSE in the KPIs of the managers;
Taking special HSE initiatives;
Publishing Safety alerts through site notice boards and Sharepoints;
Pro-actively taking initiatives to discuss and raise HSE awareness among clients and contractors;
Awareness campaigns and newsletter;
Convening Annual HSE meeting with our employees;
Providing Office guidelines for visitors;
Internally all employees have access to Sharepoint where all formal reports (for example office Risk
Assessment) and supporting information can be found.
External HSE communication and documentation shall be demonstrated in the project file at site or in the
office by:
Minutes of meetings;
Instructions to contractors;
Approved HSE plan;
Approved method statements;
Work permit check log;
Site introduction register for visitors;
Initialled toolbox meeting forms and site inspection forms;
Pictures, safety alerts and special site initiatives;
Letter of concern to contractor or client;
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All documents produced by BTME shall meet the criteria of TQM with regard to numbering, revisions,
approvals and filing.
In case of any other circumstance or changing circumstances (e.g. change of security situation in a country,
change in management), the Director needs to take immediate action to prepare a Risk Assessment and
take control measures.
To provide a safe workplace and have zero impact on the environment we require all offices and projects to
assess the risks to our workforce, contractors and others who may be affected by our activities e.g. the
public and the environment. The aim is to prevent accident, illness, environmental harm, property damage
and any other general loss. It is carried out by identifying risk and using appropriate control measures to
mitigate or eliminate the risk.
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When BTME acts as the company responsible for managing health and safety on a project (in contract), we
have a duty to ensure that before work starts on projects, a review of key tasks, identification of risk and
applicable control measures is undertaken by the Project or Construction Manager (Risk Assessment). The
results of this exercise will enable BTME Site Management to inform the contractors of the identified risks
and control measures required to eliminate or to reduce the risk to as low as reasonably practicable
(ALARP).
We must also ensure that contractors under our supervision have produced a risk assessment for all critical
construction activities. The risk assessment must be reviewed by BTME and any significant risk control must
be outlined in a Method Statement and/or Permit to Work which must be approved by BTME before work
can start.
The approved methodology of risk control must be documented and communicated to all parties concerned.
The review and approval process will be governed by the level of risk. E.g. tasks such as low level painting
will need to be approved only by the BTME supervisor. However, if the painting task involves working, for
example on a 4 meter high column, this then becomes a Very High Risk situation and the approval process
must involve a formalized review by the BTME Construction Manager or Project Manager.
The following Risk Ranking system can be used to assess most office and project conditions and activities.
Situation #1: We noticed that the chains contractor will be using to lift a heavy load are damaged.
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Action required to eliminate or reduce risk = STOP WORK ensure that risk is assessed by a competent
person and introduce new control measures which eliminate the risk or reduces to ALARP. Maintain close
supervision. In this situation the chain set is replaced and tagged not to be used.
Situation #2: Electrical cables are temporarily placed across the floor of an office and left unattended.
Action required to eliminate or reduce risk = IMMEDIATE ACTION REQUIRED- ensure that risk is assessed
by a competent person and introduce new control measures which eliminate the risk or reduces to ALARP.
In this situation the cables are either removed (if safe) or they are re-routed and secured to prevent tripping.
The majority of the activities of BTME are executed within a BTME office environment. In general the
hazards related to office work are limited and the risk profile is low. However in order to establish a Safe,
Healthy & Sustainable working place in the individual Bilfinger Tebodin Middle East offices:
Hazards shall be identified and risks shall be assessed, through a Risk assessment and a Register of
Environmental Aspect and Impact (Register EA&I);
At regular intervals the effectiveness of measures shall be controlled and evaluated by:
We expect all BTME worker to know how their work related activities have an impact to the environment,
how the impacts can be avoided or minimized, and if any specific environmental legislation is applicable to
their activities. The impacts to the environment caused by our activities are mostly related to electrical power
consumption for appliances, use of water and use of fossil fuels for travelling, emissions to air caused by
combustion emissions for travelling, paper consumption and waste generation. BTME employees also need
to be aware of the environmental impacts caused by unexpected events or emergencies, and how these
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can be avoided or mitigated. The Register of environmental aspects and impacts gives the relevant aspects
and environmental impacts of our activities
1. Risk Assessment
2. Register of Environmental Aspects and Impacts (Register EA&I)
3. Facility Emergency Plan
4. Visitor Guide BTME Office
5. Office Inspection Form
6. HSE Audit Form
Employees seconded to other BTME Offices or Client site and/or offices shall work in a Safe and Healthy
environment and avoid incidents/injuries or minimize environmental impacts
Prior to the secondment the following aspects shall be checked and reported to the employee by the
Department Manager (DM).
Employees are encouraged to follow the BTME Middle East driving policy and Journey Management Plan.
The Journey Management Plan shall be followed by all Bilfinger Tebodin Middle East staff if the journey is
more than 250 km, in one direction or if it is an off-road (desert, pipeline corridor, hills etc.,) and/or any other
risk in the trip.
Proper planning of the trip and checking the availability of alternatives (public transport, video
conferencing etc.) respecting speed limits and not driving continuously for more than 2 hours followed
by a break of at least 15 minutes;
Proper car maintenance. BTME shall make available a vehicle with lower CO2 emissions for business
trips if feasible;
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Respecting traffic rules and regulations. Fines are always the responsibility of drivers;
Not using mobile phones, smart phones or laptops while driving;
Not eating and drinking while driving;
Car pooling;
Employees are often required to work in the field involving them to be away from their normal work location
and communication systems (e.g. for pipeline route surveys) and could therefore be exposed to unfamiliar
and unexpected hazards. Therefore, all field trips must be planned to ensure:
BTME employees at site and those working as a subcontractor of BTME are continually exposed to HSE
hazards. In order to minimise and control the risks to which our staffs are exposed,
commitment to Site Safety Form shall be completed by all employees at each site visit and signed off by
employee, Construction Manager and/or Department Manager.
iven to:
Pro-
Pay attention to specific job related hazards;
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The contractor is responsible for the HSE issues of his employees, subcontractors, equipment, work
activities and visitors. The most important document at site is the HSE Plan.
In most cases the BTME contract stipulates that we shall supervise contractors HSE activities and that we
shall comment, challenge and approve contractors HSE documents (when deemed acceptable and prior to
start of the work).
BTME shall:
Assess and comment the HSE plan and get it approved by the client;
Supervise work against the contract, HSE plan and approved method statements;
Address any HSE issue immediately to the contractor and discuss and report the status in the weekly
progress meeting;
Take repeated measures (and inform client accordingly) if any HSE issue is not solved to our full
satisfaction;
Take initiatives to improve the HSE awareness situation at site (like poster campaign, toolbox initiatives,
cleaning day, presentations of specific topics);
The Site Safety Blueprint shall be used as a guide to improve the HSE situation at construction sites. The
BTME Construction Manager is responsible for making sure the following topics as further detailed in the
Site Safety Blueprint are addressed by contractor and BTME employees at site.
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- manual handling
- working at height
- excavation
- hazardous materials / handling
- vibration
Environment
- air quality
- water quality
- noise
- hazardous material management
- waste management
Plant & Equipment
- competency
- inspection
- lifting equipment & accessories
- lifting plans
Control Measures
Incident Reporting
Monitoring & Review
Design Changes / Variations
It shall be noted that Managing Director, Director, Management Team Director, Department Manager /
Construction Manager, Supervisor and HSEQ Coordinator execute regular inspections at site and meet with
site staff in order to ensure a pro-active HSE culture on site. Construction Manager shall pay special
attention to changed circumstances at site like design changes or changed work plan (e.g. night shifts).
Prior to the start of the particular part of the work, the RA&E shall be revised and new method statements
BTME shall review said documents prior to start of
the activities.
Bilfinger Tebodin Middle East Management is taking their own responsibility for site safety to protect all our
stakeholders. We will never compromise ourselves due to a lack of commitment to safety by the client. In
case site staff and contractors are violating site safety standards due to negligence from client, the Director
shall immediately enter into talks with the client in order to improve the HSE awareness. This may also
involve BTME Managing Director or Bilfinger Middle East Management.
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BTME aims to implement HSE measures in the design stage of a project. The objective is to prevent and
mitigate risks, unfavourable working conditions and negative environmental impacts to a level as low as
reasonably practicable (ALARP) for the successive project phases.
The objective is achieved by identifying and understanding the project related hazards and sustainable
opportunities in an early stage of the project. The Project Manager is responsible that the hazards shall be
addressed in the design stage based on a project specific HSE plan. Implementation of this HSE plan is
subject to thorough review at the final stage of the project, which can result in corrective actions. If there are
design changes in the course of the project, the associated hazards have to be re-determined and re-
assessed. The sustainable opportunities can be identified and presented to the client at each phase in the
project but most beneficial in the early design stages.
This also means that during the design a documented review shall be conducted of the constructability of a
designed project: Can large components access the construction area? Are underground utilities expected?
How can the design be adapted to minimize these kinds of risks? Are there sensitive environmental
receptors in the vicinity of the project that could be negatively affected by the project due to increased noise
levels, emissions to air, odour etc.?
In addition to that, the design shall ensure an adequate operability and maintainability of the designed facility
or object. Safety and environmental mitigation measures shall be in place to prevent or minimize the effects
of incidents.
Legal environmental requirements shall always be fulfilled, but a client may also choose to enhance a design
or
BREEAM.
The responsibility for incorporating HSE aspects and sustainability in the design lies with all BTME
engineers. The HSE awareness among BTME employees is promoted to ensure full understanding of the
relevance of this topic. The BTME Project Manager is responsible for applying the HSE in design procedure
in the right manner (refer HSE in Design Procedure).
For all design engineering projects and other projects in cases where design can potentially result in
hazardous situations at site, the PM should address in the project plan whether:
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The term outsourcing covers two main areas:
1. Where BTME has to obtain the services of (Sub) consultants or (Sub) contractors.
2. Where BTME works as an EPCM Contractor, making commitments for and on behalf of and for the
account of a Client or where BTME acts as a PMC and bears the responsibility for compiling complete
tender packages for and on behalf of the Client, to procure the services of an EPC Contractor.
For all out-sourcing the BTME Project Manager (or in case of non-project related outsourcing the Director)
bears the responsibility to:
Make sure the specific hazards and risks for the outsourced work are identified and controlled and that
emergency preparedness is in place;
Inspect and if necessary correct the HSE related aspects during the execution of the outsourced work;
Make sure that whenever applicable the minimum requirements as given in this OHSAS manual are
reflected in the (sub)contract for the outsourced work;
All enquiries for sub-consultancy shall be made using BTME -consultancy agreement. All
HSE documents and requirements that form part of the Contract between BTME and its Client must be
included, when appropriate, in the enquiry for sub-consultancy services. Where no such documents exist,
BTME shall include its own HSE Requirement of Contract or parts hereof whatever is applicable for the
nature of the outsourced work. No commitment shall be made with a sub-consultant unless the sub-
consultant has clearly accepted, without reservation, the contents of the sub-consultancy agreement,
including the HSE content.
EPCM / PMC
In case of a EPCM/PMC the BTME PM must actively pursue the Client to obtain a full inventory of the HSE
systems and procedure that the Client normally employs to maintain acceptable HSE performance. These
systems and procedures must be included in tender documents that are issued to vendors and contractors.
BTME
add their own specific HSE requirements.
Where EPCM/PMC activities require new vendors or contractors to be qualified for bidding, appropriate HSE
qualification criteria must be agreed with the Client prior to the commencement of any prequalification being
performed. Enquiry packages for Purchase Orders and Contracts shall be issued to vendors and
Contractors who are qualified to bid, either by virtue of their inclusion in an existing list of approved bidders
or identification through prequalification exercises.
Enquiry packages shall always include dedicated section on HSE requirements and evaluation criteria for
bidders responses to the enquiry must be agreed with the Client prior to the bid closing date of any enquiry.
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BTME employees whose activities are governed by the requirements of any of the applicable laws,
standards, regulations, legislations related to OH&S requirements/hazards and environmental aspects, are
required to comply with those requirements. The office legal register provides an overview of applicable
legal requirements to each office activities. Director shall ensure that these applicable legal and standard
requirements are up to date and communicated to all employees. BTME employees must be aware of,
understand and determine how these legal requirements apply to occupational health and safety hazards
and environmental aspects in their area of operation and activities.
BTME Employees and their guests working outside an office environment are exposed to risks. Based on
the most common risks the Directors shall personal protection package. A typical
standard PPE package is given in figure 5.
While instructing an employee to make a site visit/field trip or to take a role in a construction management
team, the specific HSE risks / site requirements shall be assessed by the DM/PM. Based on the assessment
additional PPE shall be provided to the employee (including specific instruction / training). For example
safety harness, safety glasses protecting against dust, light rays and liquid chemicals, face masks,
evacuation masks, filter masks, boots, gas detection (H2S) equipment, oxygen meter, etc.
BTME employees and their guests shall be provided with the required PPE for their duration of work.
E shall receive
personalized PPE. The PPE remains BTME property and shall be returned when the employee leaves the
company or when the work is finished. PPE shall be provided also for short (site) visits to employees and
visitors. The user is expected to keep PPE in a clean state.
The Director is responsible for the availability of PPE to employees of his office and assigns an employee
who is in charge of stock control, issue and registration of the PPE as well as the ordering of additional PPE.
PPE shall be provided to an employee after filling in and approval by the DM
Some PPE has a limited lifetime, e.g. a hard hat. After the expiry date the PPE shall be replaced. The user
is responsible to check the expiry date and condition of PPEs before use.
The employee must wear the PPE in the right manner and according to the site instruction.
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Figure 5 BTME Standard PPE Package
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Reporting and investigating accidents, incidents and near misses is an essential part of the BTME HSE
Management System. Valuable lessons can be learnt and steps taken to avoid recurrences, thereby making
the workplace.
Flow chart 1 describing what needs to be reported, how to report, and how to investigate. It also outlines
mechanisms for reviewing the outcomes of all incidents.
Directors shall ensure they have appointed members of staff to carry out the roles described in the flow
chart-1. Duties would normally fall on both line managers. HSEQ Coordinators and supervisors as the
involvement of these people reinforces the need for health and safety shall and be viewed as an integral
part of normal management roles.
Any accident or incident that falls under the following circumstance must formally be reported to Bilfinger
Tebodin Middle East HSEQ and in Active.
To a BTME employee(s).
Other employee who has an employment relationship with BTME including (sub) contractor who has as
contractual relationship directly with BTME.
Direct contractual / legal liability for safety on a project.
BTME.
a) All incidents which fall under the Decision Matrix (Table -2), must be reported to the Director/Managing
Director and to HSEQ Managers at the office / country / corporate level irrespective of the legal /
contractual liability. (green ticks and red crosses)
b) All incidents shall be discussed / investigated / reported to the client irrespective of the legal / contractual
liability.
c) Only those incidents where BTME bears legal / contractual liability will be reported to higher
Management (green ticks in the Decision Matrix Table -2)
d) For the incidents under (c in this section), a formal investigation will take place.
e) Only those incidents under c) will count in the BTME
BTME had no legal / contractual liability for HSE will no longer be reported.
f) Only those inciden HSE reporting tool. Updating
HSE.
g) HSE accidents and incidents that come under severity levels I, II
and III as described in Appendix 5 which involves BTME personnel as outlined in (Table 2 Decision
Matrix).
h) Vital lessons learned from any incident, if deemed applicable will be shared amongst BTME employees.
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Employee Group Fatality Lost time Non lost First aid Near Environmental
injury time injury treament miss incident
BTME contracted employee
Some remarks
In case of an incident always ensure it is safe to give aid e.g. isolate electricity before touching the
victim;
Never enter into a confined space to help a victim without taking preventive measures;
In case of Lost Time Injury appoint someone to secure and safeguard the site;
Depending on the circumstances the final reporting on an accident shall not take more than 14 days.
The final reporting on a near miss and observed risk shall not take more than 7 days;
LTI/Serious incident if deliberately not reported by a BTME employee, this shall result in immediate
termination of the employment contract;
Incident Frequency shall be calculated and reported every month, based on formulas;
Final outcomes of all significant incidents shall be shared appropriately to prevent a repeat elsewhere;
Notification to Police and other Authorities is the responsibility of the s (in the offices) and the
main contractor (at site);
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Severity level I Registration has to take place immediately after the incident occurred but at the latest within 3
hours.
Severity level II Registration has to take place immediately after the incident occurred but at the latest within
12 hours.
Severity level III Registration should occur in a timely manner after the incident but at the latest within 24
hours.
Severity level Registration should occur in a timely manner after the incident but at the latest within 48
IV/V hours.
Note: Severity level 1 accidents shall be reported immediately to the Boad of Directors, Managing Director, Directors and
HSE-representatives by the best and quickest means.
A Root Cause Analysis (RCA) shall be carried out for all accidents resulting in harm to individuals according to the
following description. The objective of the RCA is the identification of appropriate and necessary corrective and preventive
measures. Thereafter, updates / adjustments of the risk assessment and implementation of measures must be carried out.
Depending on the severity level or the potential risk the responsibilities for conducting an incident analysis (RCA) is as
follows:
Tripod
TapRoot
5W
Active RCA methodology
The investigating team determines possible causes that led to the incident. The results of the RCA are then
document should be
attached as a document in ACTIVE.
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The following table defines the application frame of the methods depending on the severity level:
The RCA is carried out by a team. The investigation team leader and team composition are depending on
the severity level.
The leader of
interim and final reports. Depending on the severity level, the team commences as quickly as possible with
the RCA on site, latest though according to the deadline mentioned in the table. The HSEQ team leader is
responsible for selecting the method and the proper implementation of the RCA.
Regardless as to whether the incident is reported into ACTIVE or not, if there are valuable transferable
lessons for BTME, after which a Safety Lessons Learnt or Safety Alert shall be prepared and distributed.
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Occurrence Immediate response Notification Investigation/ reports Close out/Lessons learned
1. Start investigation
immediately
2. Perform investigation as per
1. Emergency services
Sec.7.1.3
Immediately
1. Suspend operations 3. Liaise with emergency
2. PM/CM/DM/CD/HSEQ-C/
Fatal industrial accident 2. Make area safe and
immediately (verbal +
services
secure 4. Compile draft incident
initial INF)
report
3. C-HS/Client immediately
5. Ensure corrective actions
are clearly identified
recorded 1. Final report / (update on
Injury / Active)
ill health 2. Decide on
recommendations
3. Implement corrective
1. PM/CM/DM/HSEQ-C/CD action
First Aid 1. Apply first aid
(verbal + Active) 4. Verify the implementation
5. Approve
6. Close the case
Near miss
1. Report to PM/Line 1. Record the incidents
Manager 1. Ensure corrective actions
2. Analyse the results &
Unsafe act 2. SAFE booklet or Active are clearly identified,
Create awareness
3. Hand over to HSEQ-C recorded and expedited
3. Verify the implementation
Unsafe condition
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Department Managers shall ensure that suitably informed and competent people are put on the job who are
able to identify potential hazards and risks and are able to eliminate or reduce risks to as low as reasonably
practicable.
HSE competence is vital for all employees and shall be assessed by the DM (in collaboration with PM/CM)
at the recruitment stage, while working and during the annual appraisal. Any observed short coming in HSE
competence shall be discussed and action immediately with the employee and addressed in the annual
performance management/appraisal procedure.
Director shall actively promote specific actions in increasing competence and awareness of his employees
like training programme, annual HSE meetings, newsletters, poster campaigns etc.
Clients and contractors that show lack of HSE competence shall be guided by our management and staff in
order to coach them on their journey towards increased awareness.
BTME and contractor employees who repeatedly show lack of competence with regard to HSE issues shall
be denied access to our sites.
Regular training is one of the most important instruments to improve continually the safety and
environmental awareness of the BTME employee.
HR Department in the office shall maintain all training records and plans of the employees in a systematic
way.
Directors shall determine the specific local requirements for training needs related to the assignment of
certain HSE tasks to employees (like first aider).
shall identify the client/site specific training need before sending an employee to construction sites
or client premises.
In table 3 the general BTME training program for HSE is given. Appendix 2 contains typical subjects for
these trainings.
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Training Participants Remarks
The Director shall determine the need for developing a specific training program based on hazard
identification, incident investigation of annual HSE evaluation. Common examples are
Training for individual employees related to specific competence development, shall be agreed during
annual PMA meeting
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At country level the Director with the HSEQ Coordinator shall ensure pro-actively that scope for continual
improvement is observed and that best practices are communicated to employees and colleagues at other
BTME offices e.g. by publishing lessons learned, through employee meetings and by taking particular
initiatives (like poster campaigns).
The regular tools in BTME for performance measuring, monitoring and reporting are:
a) Audits (see 9.2) shall be done at predetermined intervals, shall be reported to Director (including CA).
b) Management Review (see 9.3) shall be done annually per Country, shall be summarised at regional
level.
c) Incident Frequency (see 7) shall be done at country level per month and reported to regional level,
where it is summarised and reported to Directors.
e) Incident Reporting (see 7) for near misses and observed risks to HSEQ Coordinator in the same
week.
f) Site & Office Inspections by Director /Managing Director at least 2 times a year and reported to BoD
on a monthly basis.
g) Site & Office Inspections by employees as per agreed schedule and reported to HSEQ Coordinator
on a monthly basis. Trends in these inspections shall be reported to Director level.
h) Performance Management each employee shall get HSE targets through BSC (management) or
appraisal form (all employees) which shall be assessed at year end and evaluated with the employee
at least 1 time in between.
i) Energy Consumption Set and document targets and measures to improve energy efficiency and track
the status, Track and analyze the total energy consumption (at minimum: electricity, water, fuels, etc.)
a) Internal Audits - Each office shall address in the annual action plan an audit scheme, making sure
offices and projects are audited at regular intervals against the BTME HSE audit form.
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b) Client Audits - It is BTME policy to encourage clients and other business partners to audit our HSE
management system.
c) Independent Third Party Audit - Once in 3 years for re-certification and once or twice a year for a
compliance check against ISO 45001 and ISO 14001 requirements as well as against BTME objectives
and action plans.
d) Interoffice Audits - As a part of the annual BTME action plan an interoffice audit schedule shall be
developed where each office in the BTME network shall be audited by another office at least once a
year against HSE audit form.
e) Corporate and Bilfinger Audits - At any time each of the BTME offices can be audited by Bilfinger.
Each audit shall be recorded by auditor and evaluated by office management, who shall action any
observation, violation or non-conformity. Audit, correction & presentation procedure and form are applied as
per TQS.
Main purpose of our yearly management review is to learn how we can improve the way we work.
Board of Directors set topics for HSE shall be addressed in Management Review;
Countries execute management reviews ensuring that local recommendations are properly translated
into local actions with local ownership and overarching recommendations are forwarded to the BTME
Board;
Management reviews shall be adequately documented and recorded at an country level;
BTME Board shall prepare HSE management summary, covering all countries and translating
conclusions and trends into BTME HSE action plan for following year;
Action plan shall be aligned with topics as addressed by BoD;
Management review shall take place on annual basis in Q1;
HSE Management Review shall be combined with management review of the quality management
system;
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Next year objectives and action plan (SMART objectives);
The annual management review reports ;
BTME encourange all workers to report all incidents, deviations in the OHSE performance and potential non
conformities through Active and are reviewed in the Management Review.
Incident investigation and analysis are carried out as a process of identifying the underlying causes of incidents and
implement the steps to prevent similar events from occurring as per sec. 7. Incidents.
Upon Incident or happening of any non-conformity, case owner shall record this in ACTIVE, in ACTIVE action shall be
created and assigned to responsible person to correct the situation and avoid future occurrences. Upon completion of
corrective actions, the Line Manager and HSE shall review the effectiveness of the action and close it out in ACTIVE.
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Appendix-1: Definitions & Abbreviations
Absence as a result of an The total number of working days lost as a result of an industrial accident. The
industrial accident maximum absence allowed following an industrial accident is 260 working days.
Acceptable Risk Risk that has been reduced to a level that can be tolerated by BTME having regard
to its legal obligations and our HSEQ Policy.
ACTIVE Central HSEQ management software for registration and communication of
incidents.
ALARP As low as reasonably practicable.
Audit Systematic, independent, objectively and documented process for obtaining audit
fulfilled.
Continual Improvement Recurring process of enhancing HSE Management to improve performance
consistent with policy, achieved by audits, reviews, etc.
Contractor employee A person employed by a (sub) contractor at locations where BTME has
responsibility for HSE.
Corrective Action Action to eliminate the cause of a detected nonconformity or undesirable situation,
which addresses actual problems.
Environment Surroundings in which BTME operates, including air, water, land, natural resources,
flora, fauna, humans, and their interrelation.
Environmental aspect Elements of BTME
environment.
Environmental impact Any changes to the environment, whether adverse or beneficial, wholly or partially
resulting from BTME
Fatal industrial accident An industrial accident that results in the death of the person involved either
immediately or within 30 days of the accident.
Hazard Any situation, substance, activity, event, or environment that could potentially cause
injury or ill health.
Hazard identification A process that involves recognizing that an HSE hazard exists and then describing
its characteristics.
Ill Health Identifiable, adverse physical or mental condition arising from and/or made worse by
a work activity and/or work related situation.
Incident Work related event(s) in which an injury or ill health or fatality occurred, or could
have occurred. An accident is an actual occurrence. A near miss, near hit, close call
and dangerous occurrence are types of incidents that could have occurred.
Industrial accident An unintended occurrence during a period of paid work that results in physical injury
or illness.
Industrial accident without lost An industrial accident (see above) in which the person involved is at work on the
next normal working day.
Industrial accident with lost An industrial accident that results in the person involved being absent for the whole
time shift for at least the next normal working day.
Interested party A person or group interested in the HSE performance of BTME. Interested parties
come from both inside and outside of the workplace.
Lost Time Injury (LTI) An accident or incident which occurred in the workplace (or while traveling between
workplaces) which caused the person being absent from work for the full shift on the
next normal working day.
Material damage An event that causes an interruption in operations or damage to property which has
serious short and long-term implications.
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An unintended occurrence that does not result in an injury / damage but had the
Near Miss
potential to do so under different circumstances.
Nonconformity The non fulfillment of a requirement or a deviation from the BTME TQS handbook
and/or HSE manual.
HSE A term that refers to all of the factors and conditions that affect or could affect
occupational health, safety and environment in the workplace.
HSE Objective HSE goal in terms of performance that BTME has set itself to achieve. The objective
should be measurable and consistent with the policy.
OH&S performance Measuring the effectiveness of BTME
achievements against the policy, objectives, or any other suitable performance
requirements.
HSEQ Policy Overall intentions and direction of BTME related to our HSEQ performance as
formally expressed by the BTME Board of Directors.
Quarterly absence The total number of working days lost as a result of industrial accidents, including
continuing absence during the quarter concerned as a result of industrial accidents
that occurred in the previous three quarters.
Preventive Action Action to eliminate the cause of a potential nonconformity or other potential
undesirable situation.
Procedure Specified way to carry out an activity or a process. Procedures may or may not be
documented.
Record Document stating results achieved or providing evidence of activities performed.
Risk Combination of the likelihood of an occurrence of a hazardous event or exposure(s)
and the severity of injury or ill health that can be caused by the event or exposure.
Risk Assessment Process of evaluating the risk(s) arising from hazards, taking into account the
adequacy of any existing HSE controls and deciding whether or not the risk is
acceptable.
Root cause analysis (RCA) Standardized method/process of investigation to determine the underlying causes of
an incident. Special qualification is required of those who carry it out.
Serious industrial accident An industrial accident that leads to the person involved being admitted to hospital for
more than 24 hours or results in an amputation or fracture.
Severity level Each consequence of an incident will be divided into 5 severity levels. Severity level
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List of Abbreviations
BoD Bilfinger Board of Directors
BSC Balanced Score Card
CM Construction Manager
CO2 Carbon dioxide
DM Department Manager
EIA Environmental Impact Assessment
GPS Global Positioning System
IF Incident Frequency
INF Information
JSA Job Safety Analysis
LL Lessons Learned
LTI Lost Time Incident
LTIF Lost Time Injury Frequency
MD Managing Director
MIVIVA Mission, Vision & Values
MTD Management Team Director
CAPA Corrective and Preventive Action
CD Director (Director of the office)
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Appendix-2: Training Program
HSEQ Policy & Manual HSEQ Policy Brief about project scope
Emergency Preparedness (incl. Importance of HSE Contractual requirements
escape routes & fire fighting) Brief about HSE Manual Details of site
PPE Procedure / Use of PPE Facility Emergency Plan HSE Plan
HSE job responsibility HSE in the office Emergency procedure
Incidents and reporting HSE on site & field trips Site contact numbers
PPE use/procedure Hazards/Risk on site
Life Saving Rules General site rule
Incidents & Reporting Life Saving Rules
Environmental Awareness Incidents and reporting
Environment Management
Basic Safety Training Safety Awareness Training for Site Emergency Response Teams
Staff (Safety Passport)
HSE manual and procedures HSE Management System Office facility emergency plan
HSE in office, during site visits Safety culture & Supervision Emergency preparedness
HSE in Design Procedure Understanding occupational Basic First Aid
Workstation Ergonomics hazards Basic Fire Fighting
Emergency Preparedness Legislations & Company
Use of PPE on construction site procedures
Basic Fire Safety & First Aid Tools of managing risk /
Incidents reporting identifying unsafe acts and
Environmental Awareness situations
Safe work behavior
Safety Inspection
Incidents
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Appendix-3: Cross Reference Table ISO 14001 and ISO 45001
Page 38 of 45
Risk Assessment & Method Statements
Activities and condition within an operation or in a office that have the potential to cause significant risk of injury to an
employee, contractor, client, member of the public or an environmental impact are subject to a formal Risk Assessment
and production of a Method Statement.
Director /
Competent personnel are identified and trained in risk
Project Manager
assessment techniques
Office Project / The risk assessment is approved and where required, amended
Reviewed Risk
Construction Manager following an incident or when the scope of the activity changes
Assessment.
significantly and re-briefed where required.
Meeting Minutes
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HSEQ-Incident Category I
Actual Severity
Damages to Equipment or Major impact on the business results of the Incident which results in a damage which
Products subgroup - Cat.1 can have a major impact on the business
results of a subgroup.
Health Impairment Death (Influences which can result in death) Death (Influences which can result in death,
- Cat.1 e.g. occupational illness, a heart attack).
Release to Environment Major impact on the environment/public Incident, which results in the release of a
health (warnings issued) - Cat.1 product to the environment and has a major
impact on the environment/public health.
Force Majeure Major impact on the business within the Incident which results from sabotage,
country (sabotage, criminal act, natural criminal act, war act, natural disaster,
disaster, strike, plague, epidemic, national strike, which has a major impact on
pandemic) - Cat.1 business activities within the country.
Actions by the client Cessation of all business processes - Cat.1 Actions of clients, which result in the
cessation of all business processes with the
company
Actions by Public Cessation of all business processes - Cat.1 Actions of public authorities, which result in
Authorities the cessation of all business process of the
company.
Impact on Reputation Media Interest - Cat.1 Incident, which due to its special
constellation, evokes interest with the media.
Production/ Productivity Performance Loss/ Component Failure - Incident, which results in the loss of
important aspects of the performance and/or
Major Impact on Business - Cat.1
results in important financial impact on the
result of the executing unit and/or results in a
final non-acceptance by the client.
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HSEQ-Incident Category II
Actual Severity
Personal Harm Severe, possibly permanently handicapped Incident, where a person is severely injured
- Cat.2 and the person potentially remains
permanently physically handicapped.
Damages to Equipment or Impact on the business results of the Incident which results in damage, which can
Products subgroup - Cat.2 have an impact on the business results of
the subgroup.
Health Impairment Serious (chronic) Illness - Cat.2 Incident which results in a person being
seriously/chronically ill, e.g. as a result of
occupational influences.
Release to Environment Impact on environment/public health Incident which results in the release of a
(restricted zones) - Cat.2 product to the environment and which has an
impact on environment/public health.
Force Majeure Medium impact on the business within the Incident which results from sabotage,
country (sabotage, criminal act, natural criminal act, war act, natural disaster,
disaster, strike, plague) - Cat.2 national strike, which has a medium impact
on business activities within the country.
Actions by the Client Cessation of project - Cat.2 Client actions which result in the cessation of
the project.
Actions by Public Cessation of project - Cat.2 Public authority actions which result in the
Authorities cessation of the project.
Impact on Reputation Top client/ Dispute with authorities - Cat.2 Incident which results in a dispute between a
top client and public authorities.
Productivity
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HSEQ-Incident Category III
Actual Severity
Personal Harm Severe Injury - Cat.3 Incident which results in a person being
severely injured. This includes:
Damages to Equipment or Low impact on financial result of subgroup - Incident which results in a damage which
Products Cat.3 has a low impact on the business results of
the subgroup.
Health Impairment Acute, severe health problems - Cat.3 Incident which results in a person getting
acute severe health problems.
Release to Environment Release into an open space - Cat.3 Incident which results in the release of a
product to the environment and the released
product remains in an open space.
Force Majeure Low impact on the business within the Incident which results from sabotage,
country (sabotage, criminal act, natural criminal act, war act, natural disaster,
disaster, strike) - Cat.3 national strike, which has a low impact on
business activities within the country.
Actions by the client Cessation of activities - Cat.3 Client actions which result in the cessation of
activities.
Actions by Public Cessation of activities - Cat.3 Public authority actions which result in the
Authorities cessation of activities.
Impact on Reputation Client/Influence of public authorities - Cat.3 Incident which results in repercussions to the
business due to actions of clients or public
authorities (influence).
Production/ Productivity Currently not yet defined Currently not yet defined
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HSEQ-Incident Category IV
Actual Severity
Personal Harm Injury medical care - Cat.4 Incident which results in a person being
injured and requiring medical care.
Damages to Equipment or Impact on financial result of company - Incident which results in a damage which
Products Cat.4 can have an impact on the business result of
the company.
Health Impairment Temporary health impairment - Cat.4 Incident which results in a person
experiencing a temporary health impairment.
Release to Environment Release into a closed space - Cat.4 Incident which results in the release of a
product to the environment and the released
product remains in a closed space.
Force Majeure Local impact on the business (sabotage, Incident which results from sabotage,
criminal act, natural disaster, strike) - Cat.4 criminal act, war act, natural disaster,
national strike, which has a low impact on
business activities.
Actions by the Client Equipment respectively works not released - Client actions with the consequence that
Cat.4 neither equipment nor works are released.
Actions by Public Equipment respectively works not released - Public authority actions with the
Authorities Cat.4 consequence that neither equipment nor
works are released.
Impact on Reputation Interest Representatives (or client/public Incident which results in discussions with
authority) - Cat.4 interest representatives, clients of public
authorities.
Production/ Productivity Currently not yet defined. Currently not yet defined
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HSEQ-Incident Category V
Actual Severity
Personal Harm Injury, first aid Cat.5 Incident where a person is injured and first
aid is necessary.
Damages to Equipment or No impact on the financial result of the Incident which results in damage, but does
Products company- Cat.5 not impact the business results of the
company.
Health Impairment Health impairment (stress) - Cat.5 Incident which results in a person having
health impairment.
Release to Environment No impact on environment/public health - Incident which results in the release of a
Cat.5 product to the environment and has no
impact on the environment/public health.
Force Majeure No impact on the business of a subgroup Incident which results from sabotage,
(sabotage, criminal act, natural disaster, criminal act, war act, natural disaster,
strike) - Cat.5 national strike, which has no impact on the
business activities.
Actions by Client Withdrawal of a work permit of a person - Client actions which result in the withdrawal
Cat.5 of a work permit of an employee.
Actions by Public Withdrawal of a work permit of a person - Public authority actions which result in the
Authorities Cat.5 withdrawal of a work permit of an employee.
Impact on Reputation Minor local problem - Cat.5 Incident which represents a minor local
problem.
Production/ Productivity Currently not yet defined Currently not yet defined
Page 44 of 45
Notes
Page 45 of 45
Bilfinger Middle East
RULE: DEFINITION:
ALWAYS ensure that Energy isolation separates people from hazards such as
hazardous energy sources electricity, pressure and energized equipment.
Verify Isolations are isolated, locked, and
tagged before work begins.
RULE: DEFINITION:
ALWAYS position yourself Line of Fire is placing yourself in the path of moving
in a safe zone in relation objects, the release of high-energy, or substances that
Line of Fire to moving and energized could have adverse affect on human bodies, or by placing-
equipment. ing yourself in harm´s way.
RULE: DEFINITION:
ALWAYS protect yourself Working at height’s where a person could be
Working against falls from height. injured by falling, above or below ground level.
at Height
RULE: DEFINITION:
NEVER work under the The consumption of any intoxicating substance (Drugs and
No Drugs & influence of intoxicating Alcohol), which can severely affect a person’s physical and
RULE: DEFINITION:
ALWAYS stop work and Employees are empowered and have the responsibility
Stop Work intervene when unsafe and obligation to stop work if there is a perceived unsafe
Authority
conditions or uncontrolled condition or behavior that may result in an unwanted
situations are observed. event.
RULE: DEFINITION:
ALWAYS use appropriate A machine, device or implement used to carry out a
Tools & and regularly inspected particular function.
RULE: DEFINITION:
ALWAYS wear a seatbelt, A person having complete control over any vehicle at all
NEVER use your phone times.
Safe Driving and DO NOT exceed speed
limits while driving.