Project EHS Plan

ENVIROMENTAL, HEALTH & SAFETY PROJECT PLAN
ENVIRONMENT, HEALTH & SAFETY PROJECT PLAN
SUMADHURA INFRACON PVT LTD
Prepared by Reviewed by Approved by:
Project EHS Incharge EHS Manager Project MR
Document No: SIPL-EHS-MAUL-001| Revision No.: 00 | Effective Date: 01/02/2023 Page 1 of 32

CONDITIONS
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means, in whole or in part, without prior written permission of Sumadhura Infracon Pvt Ltd.
This document is provided with the understanding that it contains proprietary information of
Sumadhura Infracon Pvt Ltd. and will be confined to its employees and clients, and that no part of its
contents will be disclosed to third parties.
Sumadhura Infracon Pvt Ltd. recognizes copyright, trademarks, registrations and intellectual
property rights of certain third parties whose work is included or may be referred to in this document.
The rights of those parties to express ownership are accepted.
The content of this document does not constitute a contractual agreement and Sumadhura Infracon
Pvt Ltd. accepts no obligations associated with this document except as expressly agreed in writing.
The information contained in this document is subject to change. All rights reserved.

INDEX
[A] Revision History ............................................................................................................................... 5
1. INTRODUCTION ...................................................................................................................................... 6
1.1 Purpose ................................................................................................................................................. 6
1.2 Scope .................................................................................................................................................... 6
1.3 Abbreviations........................................................................................................................................ 6
1.4 Terms & Definitions ............................................................................................................................. 7
1.5 Our purpose, Vision & Mission ............................................................................................................. 8
1.5.1 Our purpose ....................................................................................................................................... 8
1.5.2 Vision ................................................................................................................................................ 8
1.5.3 Mission .............................................................................................................................................. 8
1.5.4 EHS Policy ........................................................................................................................................ 9
1.5.5 Project Detail ..................................................................................................................................... 9
2. PROJECT ORGANIZATION ..................................................................................................................... 9
2.1 Project EHS organization chart.............................................................................................................. 9
2.2 Roles and Responsibility ..................................................................................................................... 10
2.2.1 Roles And Responsibility Of Chairman & Managing Director And Vice Chairman: ......................... 10
2.2.2 Responsibility Of IMS Management Representative: ........................................................................ 10
2.2.3 Responsibility Of EHS Core Committee ........................................................................................... 10
2.2.4 Responsibility Of Director Operations: ............................................................................................. 11
2.2.5 Responsibility Of Management Representative Functions: ................................................................ 11
2.2.6 Responsibility Of President - Technical ............................................................................................ 12
2.2.7 Responsibility Of Head EHS ............................................................................................................ 12
2.2.8 Responsibility Of Cross-Functional Team At Corporate Level: ......................................................... 13
2.2.9 Responsibility Of Audit Team .......................................................................................................... 14
2.2.10 Responsibility Of Project In-Charge .................................................... Error! Bookmark not defined.
2.2.11 Responsibility Of Project EHS Committee: .................................................................................... 14
2.2.12 Responsibility Of EHS Officer’s..................................................................................................... 14
2.2.13 Responsibility Of Construction Work In-Charge............................................................................. 15
2.2.14 Responsibility Of HR & Admin ...................................................................................................... 15
2.2.15 Responsibility Of Store In-Charge .................................................................................................. 16
2.2.16 Responsibility Of Plant & Machinery In-Charge ............................................................................. 16
2.2.17 Responsibility Of Emergency Response Team ................................................................................ 16
2.2.18 Responsibility Of First Aid Team (Nurse) ...................................................................................... 17

2.2.19 Responsibility Of Engineers And Supervisors ................................................................................. 18

3. ORGANIZATION OF EHS PLAN ........................................................................................................... 18
3.1 General ............................................................................................................................................... 18
3.2 Documented Information..................................................................................................................... 19
4. GENERAL PROJECT SITE CONTROL .................................................................................................. 19
4.1 General Project Site Control ................................................................................................................ 19
4.2 General Site Safety Rules .................................................................................................................... 20
5. LEGAL AND REGULATORY COMPLIANCE ..................................................................................... 21
6. ENVIRONMENTAL MANAGEMENT .................................................................................................. 22
7. HEALTH MANAGEMENT .................................................................................................................... 22
8. SAFETY MANAGEMENT ..................................................................................................................... 23
8.1 Safety management is tackled under the following sub-heads. .......................................................... 23
8.2 Control Of Man And Vehicle Movement In The Project ...................................................................... 23
8.3 Control On Equipment Operations....................................................................................................... 24
8.4 Material Storage .................................................................................................................................. 24
8.5 Material Handling ............................................................................................................................... 25
8.6 Hazard Identification And Risk Assessment (HIRA) ........................................................................... 25
8.7 Unsafe Conditions And Unsafe Acts ................................................................................................... 26
8.8 Operational Control Procedures (OCPs) .............................................................................................. 27
8.9 Work Permit Systems For Critical Activities ....................................................................................... 27
8.10 Emergency Response Management ................................................................................................... 27
8.11 Housekeeping ................................................................................................................................... 29
9. INSPECTION AND AUDITING .............................................................................................................. 30
10. EHS AWARENESS AND PROMOTIONAL PROGRAMS .................................................................... 30
11. EHS REPORTING ................................................................................................................................. 32
12. ANNEXURE .......................................................................................................................................... 32

[A] Revision History
Revision Chapter Page Cu rrent Updating Detai ls of DCN

No. No. No. Revision Date Change No.
No.
Not Applicable as
00 00 this is the first
release

1. INTRODUCTION
Sumadhura Infracon Pvt. Ltd. is one of the prominent residential and commercial real
estate developers in Bangalore & Hyderabad. One of the most admired and trusted brands,
Sumadhura has been growing from strength to strength over the past three decades marking its
presence over the skylines of Bengaluru and Hyderabad. Sumadhura so far has delivered over 8
million sft of projects while approximately 20 million sft of projects are under construction and
planning stages. From being prominently a residential developer, Sumadhura has expanded its
horizons into Commercial, Coliving, Plotted Development and other real estate verticals.
We operate with a belief that everyone deserves a better life. Over the past three decades
Sumadhura has delivered more than 45 projects where thousands of happy customers reside.
Our projects are built to provide exceptional life experiences, security and value. Sumadhura
properties have seen the highest rate of capital appreciation and have given our customers an asset
to own for life.
With innovation, quality, and sustainability at the core of our work and a unique customer
centric approach has put us on the league of the best and most trusted developers in the business.
Our expertise in land acquisition, understanding the customer needs, execution capabilities
including the appointment of architects, designers, project managers along with exceptional sales
and after sales service has helped us to be counted among the forerunners in real estate
development.
1.1 Purpose
The project EHS Plan has been prepared and formulated as a summary of the EHS related
activities required, This plan spells out the management practices and describes the EHS
management for this project and This plan acts as a guideline to educate people involved in the
project about the EHS requirements, in devising engineering and administrative controls and to
enforce the same.
1.2 Scope
The contents of this document are applicable to procurement, construction, inspection,
commissioning and testing of this project in a safe manner, which are being carried out and the
finished works that are in conformance with project technical specifications and other relevant
code specification requirements of the project.
1.3 Abbreviations
S.No. Abbreviation Expansion
1 AIA Aspect Impact Assessment

2 ANSI American National Standards Institute

3 EHS Environment, Health and Safety
4 HIRA Hazard Identification & Risk Analysis
5 IMS The Integrated Management System
6 ISO International Organization for Standardization
7 ISI Indian Standards Institute
8 LTI Lost Time Injury
9 MSDS Material Safety Data Sheet
10 MR & DMR Management Representative & Deputy Management
Representative
11 OCP Operational Control Procedure
12 OH&S Occupational Health & Safety
13 PCB Pollution Control Board
14 PDCA Plan – Do - Check – Act
15 PPE Personal Protective Equipment
16 SOP Standard Operating Procedure
1.4 Terms & Definitions

In the context of this document, the following terms or phrases shall have the meanings
noted against.
S.No. Term / Phrase Definition

1 Audit Systematic, independent and documented process for
obtaining audit evidence and evaluating it
objectively to determine the extent to which the audit
criteria are fulfilled
2 Competence Ability to apply knowledge and skills to achieve intended
results
3 Corrective action Action to eliminate the cause of a nonconformity and to
prevent recurrence
4 Documented information Information required to be controlled and maintained by

an organization and the medium on
which it is contained
5 Environmental aspect Elements of an organization's activities or products or
services that interacts or can interact with
the environment

6 Environmental impact Change to the environment, whether adverse or

beneficial, wholly or partially resulting from an
organization’s environmental aspects
7 Hazard Source with the potential to cause injury and ill health
8 Incident Occurrences arising out of, or in the course of, work that
could or does result in injury and ill health
9 Management system set of interrelated or interacting elements of an

organization to establish policies and objectives
and processes to achieve those objectives
10 Non-conformity Non-fulfilment of a requirement
11 Objective Result to be achieved
12 Outsource Make an arrangement where an external organization
performs part of an organization’s function
or process
13 Procedure Specified way to carry out an activity or a process

14 Process Set of interrelated or interacting activities which transform
inputs into outputs
15 Risk Effect of uncertainty
16 Top management Person or group of people who directs and controls an
organization at the highest level
1.5 Our purpose, Vision & Mission
1.5.1 Our purpose

To Deliver Happiness
1.5.2 Vision
To be a trusted global real estate brand creating a melodic harmony of customer’s
happiness, environmental preservation, and society’s progress.
1.5.3 Mission
We are on a mission to serve families by enhancing their quality of life through our core
principle of Q.U.E.S.T which is to constantly be in the pursuit of excellence and maximizing
customer happiness. While doing this, we provide a rewarding and challenging environment to
our employees and value to our stakeholders.
Our Q.U.E.S.T defined:

Q – Quality – Be the brand that raises the benchmark of the Quality of Life for our customers
U – Unify – Create life spaces that unify the melody between our customer’s life and our nature’s
needs.
E – Engage – Be the extended family of our customers by always being there, hearing them out
fully and serving them with a smile.
S – Sustainability – Build Spaces that makes Mother Earth Smile.
T – Technology – Optimize Quality of Construction and Experience of Customers with use of
cutting -edge technologies.
1.5.4 EHS Policy
1.5.5 Project Detail

Please refer to the annexure -1 for the project details
2. PROJECT ORGANIZATION
2.1 Project EHS organization chart
Please refer to the annexure - 2 for the Project Organization Chart

2.2 Roles and Responsibility

2.2.1 Roles And Responsibility Of Chairman & Managing Director And Vice Chairman:
 To guide, advise and lead the management team in the right direction for growth and
profitability of the Company under the policies implemented
 Accountable for defining EHSMS, EHS policy and EHS Objectives
 Appoint ISO Management Representative
 Approve the EHS System manual and its amendments
 Provide necessary resources for promotion and implementation of good EHS practices
across the organization.
 Chair the EHS Core committee meetings
 Overall, accountable for continual improvement of the EHS Management system
2.2.2 Responsibility Of IMS Management Representative & IMS Deputy Management

Representative:
 Responsible for ensuring that the EHS management system is established, implemented
and maintained in accordance with the ISO 45001 and ISO 14001 Standards
 To report on the performance of the EHS Management System and the need for
improvement of the top management
 Responsible for organizing the internal audits and compliance audits
 Accountable for liaison with external parties (ex., consultancy organization,
certification bodies, factories inspector, etc) on matters relating to the EHS management
system
 Responsible for demonstrating that the organization and its staff are committed to the
continual improvement of EHS performance
 Responsible to ensure the compliance of legal and other requirements
 Review EHS performance of the organization and establish / update the objectives and
targets on a regular basis
 Communicate changes in the EHS Management system to all concerned departments
proactively
2.2.3 Responsibility Of EHS Core Committee
 The EHS Committee shall meet as often as necessary but at least quarterly.

 Prepare annual EHS strategy methodically

 Review EHS MS policy, Objective and target, SOP, OCP etc.,
 Review implementation at organization level to determine the lapses provide required
resources
 Promote a safety culture around the vision of zero harm across the organization
 Reviews the Status of incident investigations, corrective actions and preventive actions
(CAPA)
 To evolve new strategies from time to time to meet the legal and other standards
 Review of organization EHS management performance
 Dealing with all critical level matters, that reaches corporate level, concerning EHS, and
to arrive at practical solutions to problems encountered.
2.2.4 Responsibility Of Director Operations:
 To assist the Chairman & Managing director and vice Chairman in taking important
decisions pertaining to EHS related matters
 Ensure decisions and policies are getting implemented in true spirit to achieve
sustenance in EHS performance of organization
 Allocate resources towards EHS management (Budget, Manpower)
 Approve EHS SOP OCP as part
 Review EHS performance of projects with the management representative, project in-
charge, EHS management representative and head of EHS
 Direct/Advice action to management representative, project in-charge on EHS Review
presented /reported
 Approve identified training needs of line management and project team in the EHS
domain
 Initiate action against non-performing employees & labour contractors
2.2.5 Responsibility Of Management Representative Functions:
 Ensure EHS execution on site is being carried out as per the requirements and standards
are established
 Plan & allocate resources towards EHS management (Budget, Manpower etc.,)
 Review and approve EHS plan
 Review EHS performance of projects with PH and EHS team

 Ensure all operational controls pertaining to EHS activities are established and are
being followed to avoid any EHS non-conformance
 Ensure all monitoring and measurements (calibration, compliance, EHS performance
etc.) are being carried out as per the EHS plan and periodic reports are generated by all
concerned departments
 Direct/ Advice action to PH on EHS Review presented/reported by Head EHS, external
agency or MR- EHS
 Resolve conflicts/issues escalated to his level
 Initiate/Recommend action against non-performing employees & labour contractors
 Reward & Recognize individuals/ team for good EHS performance
 Ensure all EHS performance targets are met
2.2.6 Responsibility Of President - Technical
 Review Site EHS plans for individual sites

 Act as internal expert & guide to project heads
 Review the site's EHS performance on a periodic basis
 Ensure all statutory and regulatory compliance is being done as per the requirements
 Induce safety culture among employees, workers, customers, visitors and stakeholders
at project sites
 Monitor the accident/incident rates and review corrective actions status on site to avoid
recurrences of incidents
 Counsel and warn the line managers and workmen if involved in at risk behaviour and
repetitive at risk behaviour.
 Review continual improvements on sites for achieving EHS Performance targets
 Identify individuals/ team for good EHS performance
 Get complete understanding and monitor the understanding among employee team and
workers regarding EHS policy, work method statement, risk assessment aspect and
impact, objective targets and program, EHS performance targets, emergency
preparedness and response plan and safety alerts
2.2.7 Responsibility Of Head EHS
 Development & deployment of EHS strategy.

 Accountable to ensure that the EHS management system is established, implemented
and maintained in accordance with the ISO 45001 and ISO 14001 Standard

 Assist IMS MR to organize ISO certification, surveillance audit

 Accountable for planning and conducting internal audits of EHS MS
 Act as internal expert & guide to senior leadership team and a promoter of safety
culture.
 Acquire, induct and deploy competent EHS personnel.
 Keep employees engaged (sensitized, aware and updated) on EHS
 Responsible to demonstrate that the organization and its staff are committed to the
continual improvement of EHS performance.
 Align, educate, train and develop line management and supervisors to take
responsibility for EHS enforce EHS accountability to line managers
 Catalyse infusion of safety culture within an organization through training, promotion
of felt leadership, Behaviour Based Safety, motivation and exposure to international
standards for the Management
 Undertake periodical visit to project sites - record observations, recommend action &
follow up for closure.
 Monitor EHS performance, assist reviews, feedback & implementation
 Responsible to ensure that reports on the performance of the EHS management system
are presented to top management for review and used as a basis for improvement of the
EHS management system.
 Accountable for liaison with external parties (i.e... Consultancy Organization,
Certification bodies, Factories Inspector, etc) on matters relating to the EHS
management system
 Responsible for ensuring EHS performance of the organization and establishing /
updating the objectives and targets on a regular basis
2.2.8 Responsibility Of Cross-Functional Team At Corporate Level:
 Responsible for preparation of management program to comply with the objective and
target of their department
 Communicating EHS policy to all staff and ensure that the policy requirements are
adhered
 Responsible for conducting departmental reviews in EHS matters
 Responsible to coordinating in providing resources for their departmental EHS elements
 Accountable for providing direction to their department on the design, implementation
and maintenance of the EHS Management System

 Responsible to identifying training needs for their departmental personnel in co-

ordination with project managers
 Ensuring an adequate mechanism for monitoring Legal Parameters and ensuring all the
departmental legal requirements are complied
 Review of EHS training needs of their departments
 Responsible in resolving corrective action issues related to their departments
2.2.9 Responsibility Of Audit Team
 Responsible for conducting internal audits for EHS MS as per the audit schedule
 Generate audit reports
 Verify the closure of audit findings
 Responsible to ensure project in-charge closes all NC
2.2.10 Responsibility Of Project EHS Committee:
 Creating EHS awareness among all the workers

 Undertaking training and promotional activities
 Carrying out health and safety surveys and identifying the cause of incidents
 Looking into any complaints made about the likelihood of imminent danger to the
safety and health of the workers and suggesting corrective measures and reviewing the
implementation of the recommendations made by it
 Incident investigation results & review of the effectiveness of the action taken
 The EHS Officer is responsible and the project manager is accountable for conducting
the EHS committee meeting
2.2.11 Responsibility Of EHS Officer’s
 Act as internal expert & guide to project head and project team
 Responsible to verifying all applicable legal compliance at project
 Accountable for conducting induction formalities to all staff and workmen
 Responsible for implementing company EHS policy and procedures at project site
 Responsible for preparation and implementation of project safety plan, emergency
evacuation plan, monsoon plan and reviewing project logistics plan.
 Responsible for developing safety culture at project site through training to project team
and toolbox talks to workmen
 Responsible for 100% implementation of PPEs at site

 Responsible for verifying that all machinery, equipment, lifting ropes and shackles and
vehicles etc. inspected by a competent person licensed by Dept. of Industries of local
government.
 Responsible for ensuring safe working conditions with the help of construction
engineers and supervisors
 Accountable to report project EHS performance on a monthly and weekly basis to
project in-charge and corporate head - EHS
 Responsible for all EHS documentation
 Responsible for preparation of incident reports in coordination with the project manager
and reporting to top management
 Responsible to conduct site walk through along with project head - record observations,
recommend action & follow up for closure.
 Responsible for providing visual awareness posters on site
 Visit worker camp frequently along with nurse and admin - record observations,
recommend action & follow up for closure
2.2.12 Responsibility Of Construction Work In-Charge
 Accountable for the implementation of the organization’s EHSMS in his work area
 Accountable to ensure his / her working area is safe for workers.
 Accountable to ensure all workers working in his command area are EHSMS inducted.
 Accountable for providing job specific PPEs to workers as per Operational Control
Procedure .
 Responsible for checking whether safety instructions have been prepared and displayed
at relevant places through operation control instruction for use of personal protective
equipment.
 Authorized to take disciplinary action on EHSMS violations
 Accountable for issuing work permits in his work area
 Accountable for preparing EHSMS activity checklists
 Accountable for conducting TBT before the start of activity
2.2.13 Responsibility Of HR & Admin
 Accountable for worker screening and worker document verification

 Accountable for conducting pre-employment medical check formalities to all staff and
workers

 Responsible to identify and fulfil the applicable legal and other requirements.
 Accountable for evaluating all legal compliance once a month
 Accountable to communicate the legal non-compliance's to the top management
 Responsible to conduct review meetings on legal requirements.
 Responsible for updating & communicating in the organization, with the latest
legislation / amendments.
 Head-HR &Adm.is accountable for compliance with EHS legal & other requirements.
 Accountable to visiting worker camp frequently along with EHS officer and nurse -
taking action against observations and recommendations
2.2.14 Responsibility Of Store In-Charge
 Accountable for implementing the organization’s EHSMS in stores.

 Accountable for safe stacking and storage of all materials
 Accountable for maintaining MSDS related to chemicals stored at stores.
 Accountable for maintaining MTC records of PPEs
 Accountable for collecting used PPEs and disposing it properly
 Authorized to issue materials to workers and staff
 Accountable for maintaining PPEs stock & issue register
2.2.15 Responsibility Of Plant & Machinery In-Charge
 Accountable for maintaining legal compliance for all plant & machinery, equipment,
lifting tools and tackles
 Accountable for doing the TPI for all the lifting machines, tools and tackles as per the
legal requirements
 Accountable for preventive maintenance of plants, machinery & equipment
 Accountable for stack monitoring of DG set if deployed
 Authorized to raise indent for required maintenance
 Accountable for providing qualified operators for the machines used
 Accountable for preparing and maintaining preventive maintenance record and
inspection checklist
 Accountable for preparing and maintaining all documents related to plant & machinery
2.2.16 Responsibility Of Emergency Response Team
 Responsible for reviewing emergency response & preparedness manual

 Responsible for training the people for emergency response

 Conduct the defined role during the mock drills
 To ensure that the entry of unauthorized persons is restricted to areas of emergency.
 To check whether fire extinguishers are provided at appropriate places and are tested
periodically.
 To identify safe assembly area
 Impart safety awareness to all employees through in-house training as per the needs
identified.
 To verify the effectiveness of the emergency preparedness
 An emergency response team has been constituted with personnel from all departments
to review / initiate actions to identify potential emergency situations through the
significant study.
 To co-ordinate with the respective functions, head for identifying different types of
emergency situations and prepares an “onsite emergency plan” which briefly describes
the action to be taken by the employees during an identified emergency internally.
 To prepare an evacuation plan & to describe the plan for evacuation from the
emergency area and to identify the gathering point.
 To prepare mitigation actions after the emergency.
 To organize mock drills or mock exercises, to test the onsite emergency plan for the
different identified emergency situations.
 To make sure the Mock Drill records are maintained by the site EHS Officer. To decide
the possible changes needed in the emergency plans.
 The site EHS officer is responsible for compliance with emergency preparedness and
response plan
 Accountable for maintaining adequate first aid medicines, providing first aid to injured
personnel.
2.2.17 Responsibility Of First Aid Team (Nurse)
 The team should regularly monitor medicine availability in the First aid box.
 First aid personnel shall take care of the injured people
 The first aid persons should take care that the injured persons are shifted to the hospital
in time as decided by the project manager.
 Responsible for follow up and updating the project in-charge and EHS officer about the
condition of people admitted to the hospital

 The first aid persons should prepare the ambulance checklist, record the first aid
 Responsible to visiting the worker camp and site to identify the worker's health and
hygienic condition and report to the EHS officer
 Responsible for conducting regular medical camp at site and worker camp
 Responsible for conducting pre-employment medical check formalities to all staff and
workmen
2.2.18 Responsibility Of Engineers And Supervisors
 To abide by the EHS policy of organization

 To participate in the Hazard identification and Risk assessment (HIRAC) &
Environment Impact Assessment & control (EIAC) process
 To train the workers on operational control procedures and explain the hazards and the
risk associated with the job
 To proactively identify at risk behaviour of workers and counsel them about the
consequences of risky behaviour and reprimanding on repeated violations
 To report at risk behaviour, safety observations, near misses & other incidents to the
project EHS officer and participate in Incident investigation and implement CAPA.
 Get complete understanding and monitor the understanding among workers regarding
EHS policy, method statement, HIRAC, EIAC, emergency preparedness and response
plan, safety alerts.
 Implementation of EHS Manual, Procedures, standards, best practices and zero
tolerance policy.
3. ORGANIZATION OF EHS PLAN
3.1 General
This EHS plan is organized into the following sub sections:
i. General project site control

ii. Legal and regulatory compliance
iii. Environment management
iv. Health management
v. Safety management
vi. Inspection and auditing
vii. EHS awareness and promotional programs

viii. EHS reporting
3.2 Documented Information

In any organization, irrespective of its nature or size of business, different processes have
to be run to produce the required business outcome. To communicate the processes throughout the
organization and to run these processes effectively, some documented guidelines are essential. By
following the documented guidelines, the organizational processes are run and the results are
recorded to verify the effectiveness of the operations.
 The Head EHS will review and approve all the necessary project based on standardized
documentation as prepared by the respective project EHS in-charge and released to the
project sites as necessary.
 This standardized project documentation includes but is not limited to:
 List of activities to be covered for EHS monitoring in the project
 The Project EHS plan includes Hazard Identification & Risk Analysis (HIRA)
 Aspect and impact Analysis (AIA)
 Required Operation Control Procedures (OCP)
 Required project wise emergency preparedness and response plan (EPRP)
 Relevant checklists & formats
The documents mentioned above are named as per the document nomenclature system
adopted by the organization
A master list of project EHS records, (Annexure-3) approved by the project manager, is
maintained by the project EHS in-charge.
The EHS Head will train the project EHS team on the project documented information and
it has to be maintained in respective projects
4. GENERAL PROJECT SITE CONTROL
4.1 General Project Site Control

 The total project area will be barricaded covering the project boundaries.
 Man and material movement will be allowed from the security gates only after verifying
the documents
 Entry to the site is restricted to people, with an acceptable identity card or entry pass
issued by site admin and wearing a mandatory PPE only.
 All the workmen, staff and any visitors must be inducted into the project EHS system
before entering the construction zone

 Visitors will be provided visitor identity cards with traceability entered into the visitor’s
register.
 An emergency assembly area sufficient for peak labour strength will be earmarked and
clearly identified with signage.
 A logistic plan (annexure) will be developed by project EHS in-charge and site planning
from time to time, indicating the salient locations of the project like offices, stores, first
aid room, emergency assembly points and allowing routes for man and material
movements segregated clearly.
 Entry and exit of man and material will be monitored using bio-metrics / identity cards /
security registers / gate pass, as the case may be.
 Signage boards of information, of caution and of prohibition will be displayed at
appropriate locations of the project
 Smoking and use of any intoxicates are strictly prohibited at project site. Any violation
will invite disciplinary action as per the policy of the organization.
 Mandatory legal approval and BOCW requirements notice board display have to be
displayed on site entrance
4.2 General Site Safety Rules

 All employees should be in a fit condition suitable to perform their site duties, with no
sight or hearing problems, arm or leg adverse conditions, circulation complaints or
symptoms of nausea, extreme high or low heart rates.
 Each employee must obey safety rules at all times
 Every employee should consider it as a part of his duty to work safely.
 Any situation likely to affect the safety of an employee must be promptly reported to
the concerned HOD or safety department.
 Please do not use defective equipment or tools, it may be hazardous. Please do not sit
on railings/ edge.
 Do not throw anything from height
 Do not remove the barricades without permission
 Do not dislocate any fire extinguisher
 Keep all exits free of obstructions for emergency escape.
 Compressed air or instrument air must not be used for cleaning or blowing dust out of
clothing.
 Be aware of your duties in case of any emergency.

 Report any defect or abnormality in any equipment.

 Report any deviation in the normal process operation.
 Do not bypass in-built safety interlocks without proper authorization.
 Do not work without PPE‟s at site.
5. LEGAL AND REGULATORY COMPLIANCE

 All the legal and regulatory requirements related to the workmen, staff, environment
and other construction activities will be identified by the project EHS in-charge in
coordination with HR & Administration department
 The mandatory statutory requirements are mentioned below:
 BOCW Buildings & Other Construction Workers Act, 1996 & BOCW Karnataka
rules, 2006
 The Employees Provident Funds and Miscellaneous Provisions Act, 1952.
 Employees State Insurance Act, 1948
 The Workmen’s compensation Act 1923 & Rules 1924
 The Environment (Protection) Act,1986 & Rules, 1986 & Rules,
 Provisions of the Arbitration and Conciliation Act 1996 and 2015
 Sate Water Supply and Sewerage Act
 The Airports Authority of India Act, 1994
 Sate Fire force act
 The Indian Wireless Telegraphy Act, 1933
 Indian Electricity Act, 1910, rules 1956
 The Petroleum Act 1934 & The Petroleum Rules 2002
 The Water (Prevention & Control of Pollution) Act, 1974 & Rules 1975
 The Air (Prevention & Control of Pollution) Act, 1981 & Rules, 1982
 The Noise Pollution (Regulation & Control) Rules, 2000.
 Hazardous and Other Wastes (Management and Transboundary Movement) Rules,
2016.
 Bio-Medical Waste Management Rules, 2016.
 Solid Waste Management Rules, 2016
 E-waste (Management) Rules 2016
 Batteries (Management and Handling) Rules, 2001 & Amendment Rules, 2010
 The Indian Electricity Act 2003 & Rules 1956.
 Gas Cylinder Rules 2004 & 2016

 Psara act 2005

 Plastic waste management rules 2016
 Construction and Demolition (C&D) Waste Management Rules, 2016
 Motor vehicles Act 1988
 Public Liability Insurance Act, 1981
 All the requirements are monitored, and compliance evaluation will be done on a
quarterly basis by the project EHS in-charge and the results and status of the evaluation
will be communicated to Head EHS
6. ENVIRONMENTAL MANAGEMENT
As part of preventive measures, to minimize the impact of construction activities on the
environment, the following measures will be adopted.
 All the construction roads in the project will be sprinkled with water to suppress dust
 Fuel filters and exhaust pipes of energy generators will be checked on a periodical basis
 All the vehicles plying in the project will be verified for acceptable emissions limits
(checking of pollution under control certificates)
 The Diesel generators will be installed in enclosed spaces to reduce noise levels
 All the construction chemicals and fuels will be stored on a concreted bed and a tray
will be used to avoid inadvertent spillage directly on to the ground
 As a monitoring and control mechanism, noise levels and air quality will be monitored
on a monthly basis and, based on the results, corrective actions will be done (if any)
 All the waste generated during project execution will be segregated and disposed of as
per the applicable norms
7. HEALTH MANAGEMENT
 The worker will be screened for the pre-employment medical fitness
 Periodic medical health surveillance will be conducted to ensure workers’ occupational
health and safety
 The trained nurse will be deployed to monitor worker health and provide first aid
facility at the site
 The workmen camp will be provided with clean drinking water and sanitation facilities
and potable water for other purposes
 At the project site, drinking water tanks will be provided at different locations based on
the number of workmen at the site

 The required number of toilets and urinals will be provided at the site based on the
number of workmen at the site
 The toilet and urinal facilities will be kept clean and hygienic all the time.
 A qualified MBBS doctor will visit the workmen camp once a month to assess the
health of workmen.
 All the drinking water tanks will be cleaned once a week.
 The workmen who are required to work at heights will be screened for their blood
pressure levels and any history of vertigo, diabetes before being assigned to those
activities
 Fogging will be done at project offices and workmen camp at fixed intervals to curb the
mosquito menace.
8. SAFETY MANAGEMENT
8.1 Safety management is tackled under the following sub-heads.

 Control of men and vehicle movement
 Controls on equipment operations
 Material storage
 Material handling
 Hazard identification and risk assessment (HIRA)
 Unsafe conditions and unsafe acts
 Operational control procedures (OCPs)
 Work permit system for critical activities
 Emergency response management
 Housekeeping
8.2 Control Of Man And Vehicle Movement In The Project

 Man movement will be restricted to a specified path using hard barricading, segregating
the man movement from vehicle movement effectively
 General vehicle movement is restricted to limited locations like offices, stores etc.
 Movement of concrete transit mixers and other construction equipment will be highly
controlled and an assistant / helper should be available for each vehicle.
 For all vehicles, reverse horn is mandatory.
 The speed of the vehicle is restricted to 16km / hour in side project
 Based on the changing project logistics, man and vehicle movement paths are updated

8.3 Control On Equipment Operations

 All equipment that has linear or rotational movement will be controlled by EHS
personnel.
 Any equipment brought to the site will be inspected by EHS as well as the Plant &
machinery dept., to verify its fitness for use and a tag will be issued for that equipment
if it is fit to use
 Validity of the tag is 7 days or till equipment breakdown, whichever is earlier.
 For equipment that has vertical movement as well as horizontal movements such as
tower crane or other mobile cranes, a rigger will be assigned to control its movements
in coordination with the operator. Barricades will be provided to restrict the entry into
their operational space.
 All the plants / equipment having rotating parts will be provided with covers / guards to
protect people from accidental injury
8.4 Material Storage

 Cement shall be stored in a closed space and the height of stacking for cement bags
should not be more than 1.5m
 Cement stacking shall be done in such a way that access is clear and removing the
material from the stack is easy.
 All the reinforcement steel and structural steel shall be stored and not dumped in the
designated yard
 The stacks of steel shall be done with side restraints so that the material would not role
down on the legs of workmen.
 All pipes (PVC / metal / RCC) shall be stacked on supports and with side restraints to
avoid rolling.
 Any flammable material such as petrol, diesel, paint etc. shall be stored in separate store
provided with firefighting equipment
 All the construction chemicals / hazardous chemicals shall be stored separately along
with their material safety data sheets (MSDS)
 All the combustible material shall be stored clear of any flammable material.
 Other materials will be stored in store either in racks or in containers.
 Racks should be less than 2 mtr height and the material in the racks should be reachable
by hand without using any ladder.

 If the height of storage required is more, then that should be done on rigid scaffolding
base.
 No flammable material shall be stored in the main store
8.5 Material Handling

 Manual handling of material is restricted to 50 kg. for an adult male worker unless
aided by mechanical handling.
 All equipment used for vertical transportation of material will do so using material
baskets or lifting gears such as ropes, chains, slings, hooks etc.
 All the lifting appliances (crane, hoist, derrick, winch etc.) shall be thoroughly
examined by a competent person at least once in 12 months
 A table showing the safe working loads at the corresponding inclinations or radii of the
jib on the crane shall be provided with operator
 All lifting gear (ropes, chains, hooks, slings etc.) in use is thoroughly examined once at
least every twelve months by a competent person
 A chain / wire / rope in use shall be thoroughly examined once a month by a responsible
person for its use.
 A register of periodical tests, examination and certificates for lifting appliances and
lifting gears to be maintained in Form XXVI of BOCW act.
 Every operator of a crane or any lifting appliances, transport equipment or vehicle shall
be medically examined before employing and periodically as per Schedule VII of the
BOCW act
 Any material handled by moving telescopic crane / stationary tower crane, shall be
provided with guiding ropes to avoid unwanted excessive swing of the material
8.6 Hazard Identification And Risk Assessment (HIRA)

Hazard identification and risk assessment (HIRA) will be conducted for all materials and
activities those have a potential to cause considerable hazards.
For this project, the following are considered for HIRA.

 Aluminium forms work S Form work Handling (storage, transportation and usage)
 Mass excavation
 Footing marking & excavation
 Plain cement concrete (PCC)
 Marking (footing, Columns)

 Footing, column, slab reinforcement

 Footing, column, slab shuttering
 Footing, columns, slab concreting
 Stair case reinforcement, shuttering and concreting
 Spoil back filing and compaction
 Scaffolding
 External loading and unloading platform
 External working platform
 Safety related works (providing barricade, Safety net etc.,)
 MEP (Electrical, fire fighting, fire alarm and plumbing work)
 Sunken slab core cutting ( kitchen, toilet, balcony and utility)
 Internal plumbing wall chasing (toilet, kitchen, balcony and utility)
 Kitchen, utility and toilet plumbing lines & pressure testing
 External plumbing vertical pipe line
 Hanging pipe line in toilet
 Basement PCC
 Slab MEP and services work
 Electrical wall chasing, box fixing and conducting
 GI wire pulling for electrical services
 Electrical wiring
 Switch plates fixing with cover and testing
 Block work
 Slab and columns hacking
 Concrete operations
 Heavy material handling
 Structural steel erection
Activity specific HIRA will be prepared and submitted for client approval, 14 days before
the start of each activity listed above
8.7 Unsafe Conditions And Unsafe Acts

 The project area will be monitored by EHS Officer / Stewards on a daily basis for any
possible unsafe conditions and unsafe acts
 Any unsafe conditions identified will be cleared or isolated by placing access
restrictions to that area

 Any unsafe acts observed will be dealt with using educational and administrative
control measures
 Cautionary signage will be displayed about unavoidable unsafe conditions, like “high
voltage”, “deep excavation” etc
 Signages about do’s and don’ts of safety practices will be displayed to minimize unsafe
acts by workmen
 A stringent penalty system will be practiced for repeated unsafe acts by any workmen
or staff
8.8 Operational Control Procedures (OCPs)

For the critical activities, operational control procedures will be developed and submitted
for approval
A list of operational control procedures (OCP) is attached with the annexure.
8.9 Work Permit Systems For Critical Activities

In order to address the residual risk in any activity, after adopting all possible engineering
and operational control, administrative controls in the form of work permits are adopted. Work
permits shall address the following;
 The location and level of area where the work is performed

 The duration of work for which a permit is required
 List of men and machinery involved
 Responsible person for the activity
 Signing off by a responsible person mentioning that he / she has checked the working
area and involved machinery and it is safe to work
 Signature of authorizing person for permit
 Permit closure
8.10 Emergency Response Management

An emergency is an event at a project that may lead to potential damage to the
environment, property, serious injuries or endangerment to the life of the work force. This needs
to be tackled on a war footing basis to arrange rescue and relief measures at a short notice.
An emergency response plan for the project will be prepared with the below objectives:
 Protecting the environment and safeguarding life and property from the consequences
of the emergencies at the project site.

 Systematic coordination and control of emergency to avoid further escalation of

situation, evacuating of personnel to a safe place.
 Restoring normalcy in project operations with minimum loss of time
An emergency response team (ERT) shall be formed comprising the following key
personnel of the project:
 Project Manager (Emergency main controller)

 Nominated in-charge (One who acts in the absence of the PM)
 Project in-charge-EHS
 Plant & Machinery in-charge
 Area in-charges
 HR &Adm. In-charge
 Stores in-charge
 Representative of relevant external providers
A project specific emergency preparedness and response plan (EPRP) as a minimum,

should address the following:
 Type and nature of potential emergencies

 A sequence that shows the actions and decisions since the declaration of emergency till
declaration of normalcy
 Indicate the preparedness for facing the situation
 Indicate the response to address the situation
 Role and responsibility of each ERT member
 List of emergency contact details of ERT members, hospitals nearby, police station of
the jurisdiction, fire station and the driver of an emergency vehicle at project (to be
displayed at all prominent locations of project)
 An approved Emergency evacuation logistics plan (to be displayed at all prominent
locations of the project)
 Location of fire extinguishers deployed at project (to be displayed at all prominent
locations of the project)
 A List of items required to tackle a general emergency, such as emergency power, hand
lights, hand operated alarm/siren, PA system etc.

8.11 Housekeeping
Housekeeping is considered as an integral part of EHS management as poor housekeeping
contributes to poor environmental conditions, poor health of workers and poses safety hazards.
Housekeeping is the act of keeping the working environment cleared of all unnecessary
waste, thereby providing a first line of defence against incidents and injuries.
As part of good housekeeping practices, workers are trained
 To clean the waste generated due to their activities at the end of the day before leaving
their work area.
 To keep the tools and tackles at a place assigned for that purpose after their usage
 To stack all the scaffolding and shuttering material in designated places only.
 To keep all the access and emergency exit paths clear of any obstructions
 To deposit the garbage in the bins placed at prominent locations
 Housekeeping is the responsibility of all the personnel, and line management
commitment shall be demonstrated by the continuous effort of supervising staff towards
this activity.
 All stairways, passageways and gangways shall be maintained without any blockages or
obstructions
 Wooden pieces with protruding nails shall be either bent or removed & properly stacked.
 All surplus earth and debris are removed / disposed of from the working area to
designated dump sites. truck carrying sand, earth and any pulverized materials etc. In
order to avoid dust or odour impact, shall be covered while moving.
 Proper and safe stacking of materials is of paramount importance at yards, stores and
such locations where material would be unloaded for future use. The storage area shall
be well laid out with easy access and material stored / stacked in an orderly and safe
manner.
 Unused / surplus cables, steel items and steel scrap laying scattered at different places
within the working areas, shall be removed.
 All wooden scrap, empty wooden cable drums and other combustible packing materials
shall be removed from the workplace to an identified location(s).
 Empty cement bags and other packing materials shall be properly stacked and removed.
 Adequate lighting shall be provided in and around the site
 Periodical scrap removal shall be done from each section.
 Proper storage of Reinforcements and shuttering shall be done.

 Proper barricading and its cleanliness.

 Removal of waste concrete, empty cement bags, plastic bottles, plastic tea cups, oily
waste, cotton waste, empty chemical tins etc.
 Empty oxygen cylinders and LPG cylinders are removed from the site and sent back to
the store immediately
 Proper access shall be maintained with non-slippery floors.
 Dangling wires, protruding nails and storage at access should be prevented / eliminated.
 Proper storage of flammable materials should be done.
 Drain cleaning shall be done on a periodical basis
 A dedicated team for housekeeping will be formed to monitor and keep housekeeping in
the desired state.
9. INSPECTION AND AUDITING

As part of monitoring and controlling the EHS system, daily, weekly and monthly
inspections will be conducted by in-house team as well as third party agencies as per the statutory
requirements.
Standard checklists will be used to cover the inspection of construction activities as well as
machinery and equipment.
Inspection of material lifting equipment, related lifting gear will be inspected by a certified
third-party competent person as per the frequencies set by statutory requirements.
As part of internal audits of the management system, EHS will be audited every 3 months
and the findings will be discussed in the management review meeting for further course of action.
10. EHS AWARENESS AND PROMOTIONAL PROGRAMS

 The objective of EHS promotion is to develop and maintain awareness about the
environment, health and safety among all personnel of the project site.
 Project site management shall make every effort to communicate with the environment,
health and safety measures through different methods
 EHS information boards will be provided at the site to display information such as safe
man hours, incidents at site, important contact numbers etc.
 Site EHS officer will be responsible for keeping the updated record on EHS information
board.
 Posters and signage will be adopted at the site as visual aids for incidents prevention,
fire prevention and EHS promotion.

 Posters and signage will be related to safety, environmental protection, Occupational

health etc. and posters shall be in English, Hindi and local languages.
 All new personnel (Employees, Sub-contractors and labours) shall receive EHS
Induction on basic EHS requirements of the Project site and salient features of the
construction work. It is mandatory that all contractors and employees attend the EHS
induction prior to starting their work. No employee will be permitted to work on the
construction site without having attended the EHS induction.
 EHS talk to the work force or screening of videos on safety, environment will be
conducted at the site regularly.
 An EHS incentive programme will be developed at the site to recognize and
acknowledge good EHS performance by individuals.
 EHS awards will be given to different categories of contractors and employees.
 EHS related occasions, such as National safety day/safety week, world environment day
will be celebrated at the site to encourage safety and environmental protection.
 Policies will be defined on site for identifying people violating EHS rules and will be
fined for the same.
 All fines collected on EHS violations will be used for EHS promotion activities.
 Every month, three training on various aspects related to EHS functions must be
conducted at the site by an EHS officer
 All contractors and employees perform high-risk jobs such as working on height,
confined space entry, hot work, heavy structure erection and handling of hazardous
substances shall be given job specific training.
 All training records should be sent to the HO EHS & HR Department as well as, It
should be maintained properly on site.
 Besides indoor training, demonstrations on various aspects like fire extinguishers, mock
drills, use of PPE, etc, also should be organized on site.
 Training regarding use of first aid items must be given to the selected staff for carrying
out first aid treatment at site.
 A toolbox talk (TBT) should be arranged to create awareness about EHS on site.
 EHS training will be a continuous exercise and will be regularly imparted through
refresher courses, seminars, talk, etc.
 Supervisor shall identify competency to carryout activity based on hazards and
significant aspects as per EHS requirements.
 EHS officers shall devise training modules to fulfil the above competency requirements.

 EHS officers shall conduct training programmers to improve the competency of

identified persons by conducting EHS training on a regular basis.
 Records of such training programme shall be maintained by EHS officer.
11. EHS REPORTING

 EHS observations and inspection findings will be communicated throughout the project
within 24 hours
 Monthly reporting will be done on safety statistics such as safe man hours, number of
inductions done, details of training conducted, details of critical safety observations,
details of first aid cases and near miss incidents
12. ANNEXURE
1) Project Details
2) Project Ehs Organization Chart
3) Master List Of Project EHS Records & Forms
4) Project Logistics Plan
*********

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ENVIROMENTAL, HEALTH & SAFETY PROJECT PLAN

ENVIRONMENT, HEALTH & SAFETY PROJECT PLAN

SUMADHURA INFRACON PVT LTD

Prepared by Reviewed by Approved by:

Project EHS Incharge EHS Manager Project MR

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2.2.19 Responsibility Of Engineers And Supervisors ................................................................................. 18

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[A] Revision History

Revision Chapter Page Cu rrent Updating Detai ls of DCN

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2 ANSI American National Standards Institute

1.4 Terms & Definitions

S.No. Term / Phrase Definition

4 Documented information Information required to be controlled and maintained by

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6 Environmental impact Change to the environment, whether adverse or

9 Management system set of interrelated or interacting elements of an

13 Procedure Specified way to carry out an activity or a process

1.5 Our purpose, Vision & Mission

1.5.1 Our purpose

Our Q.U.E.S.T defined:

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1.5.4 EHS Policy

1.5.5 Project Detail

2.1 Project EHS organization chart

Please refer to the annexure - 2 for the Project Organization Chart

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2.2 Roles and Responsibility

2.2.2 Responsibility Of IMS Management Representative & IMS Deputy Management

2.2.3 Responsibility Of EHS Core Committee

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 Prepare annual EHS strategy methodically

2.2.4 Responsibility Of Director Operations:

2.2.5 Responsibility Of Management Representative Functions:

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2.2.6 Responsibility Of President - Technical

 Review Site EHS plans for individual sites

2.2.7 Responsibility Of Head EHS

 Development & deployment of EHS strategy.

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 Assist IMS MR to organize ISO certification, surveillance audit

2.2.8 Responsibility Of Cross-Functional Team At Corporate Level:

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 Responsible to identifying training needs for their departmental personnel in co-

2.2.9 Responsibility Of Audit Team

2.2.10 Responsibility Of Project EHS Committee:

 Creating EHS awareness among all the workers

2.2.11 Responsibility Of EHS Officer’s

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2.2.12 Responsibility Of Construction Work In-Charge

2.2.13 Responsibility Of HR & Admin

 Accountable for worker screening and worker document verification

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2.2.14 Responsibility Of Store In-Charge

 Accountable for implementing the organization’s EHSMS in stores.