HSE MANAGEMENT PLAN

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 Table of Contents

1. Purpose

2. Scope

3. Definition of Terms

4. HSE Policy Statement

5. Commitments and Motivation

6. HSE Rules

7. HSE Organizations and Coordination.

8. Procedures for Implementation of the Basic Rules

9. Regulation Monitoring

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1) Purpose
This document is to define the general technical guidelines established by the
CONTRACTOR to provide all personnel with safe operating practices and awareness for the
work they perform in the course of their duties.

The purpose of this plan is therefore:

To explain the rules and organization setup by the CONTRACTOR to monitor and
improve the performance regarding health and safety of employees at work and
environmental protection.
To describe the allocation of responsibilities at all levels of the project.
To describe some of the tools to analyze, advise and review on health, safety and
environmental issues.

2) Scope
This document must be applied to the entire construction site, employees, and
subcontractors, and must be considered as a minimum requirement. The application of this
plan is the direct responsibility of the management and all employees, subcontractors and
Vendors involved in its day-to-day application.

3) Definition of Terms
Where the term —

"Contractor" is used this includes the contractor and all its subcontractors.

"Incident": An event or a chain of events that has caused or could have caused human
injury/illness and/or damage (loss) to assets, the environment or third parties.

"Accident": Any event that results in injury, and/or damage and/or loss.

"Near miss": Any event which had the potential to cause injury and/or damage and/or loss,
but which was avoided by circumstances.

"Anomaly": Any situation having the potential to contribute to an Incident. An Anomly is an

incident factor, which requires to be combined with several others to generate an Incident.

"Audit": Systematic and independent examination to determine whether or not activities and
related results comply with planned arrangements and whether or not these arrangements are
implemented effectively and are suitable to achieve objectives.

"Critical": Qualifies an item of equipment, a product, a service or an operation having the

potential to give rise, directly or indirectly, to risks off ill-health or injury, damage to
property, plant or the environment.

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"HSE": Health, Safety and Environmental HSE improvement plan: A document, which
defines the corrective or preventive actions needed to improve 1 1 SF performance.
"HSE Committee": The committee at the site in charge of monitoring all HSE matters,
especially the HSE improvement plan.

"Site": Defined area where the activity takes place.

"Management": Management of PROJECT activities at a specific location.

"Risk": A combination of the probability (or frequency) of occurrence of a defined hazard and
its estimated cavity.

"Simultaneous Operations": Two or more major activities( construction, modifications,

production) carried out in the same vicinity at the same time potential interference creating
notable risks.

"Specification": All internal rules and regulation adopted by PROJECT.

"System": Organization structure, responsibilities, procedures, processes and resources

needed to implement HSE management.

"Approved": An internationally recognized approval authority and/or the company have

approved the item or procedures shall: Indicates a mandatory course of action and should
Indicates a preferred or recommended course of action.
"TPA": Third Party Authority.

"PPE": Personal Protective Equipment.

"MSDS": Material safety Data Sheet.

"PTW": Permit to Work.

4) HSE Policy Statement

Health, Safety and Environment Policy Statement PEPC is committed to the
achievement of a Safe, Healthy, Injury free and environmentally sound business. The Project
Management Team of PEPC recognizes that, to ensure well being of general public,
employees, contractors and environmental sustainability must do all that is reasonably
practicable to identify potential Health, Safety and Environmental risks, eliminate them
where possible and/or implement effective risk control measures. The objectives which PEPC
considers of greatest importance are:

Consideration of health and safety at work and respect for the environment as
important as the economic performance of PROJECT. Prevention of exposure to risk
in all areas of its endeavors
Adoption of an attitude of openness and constructive dialogue with public Authorities
and local communities to protect the environment and to safeguard the health, safety

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 and quality of life of those living or working in the vicinity of our operating facilities.
Minimization of any adverse effects of its operations on the environment. To meet
these objectives of a safe, healthy, injury free and environmentally sound business:
PEPC commits to the:
Establishment of HSE management systems and programs and endorsement of them
at all levels.
Education and understanding of HSE systems, plans and practices for all Project
personnel and other people involved in activities where there is a chance of personal
injury illness or environmental harm.
Enforcement of all HSE policies, procedures, plans and preventive measures.
Education of HSE management systems, plans and programs to ensure ongoing
continuous improvement in providing and maintaining a safe, healthy and
environmentally responsible workplace. PEPC will achieve these commitments by:
Continued development and implementation of management plans to eliminate or
control hazards associated with the operations.
Involving all employees in HSE programs through consultation, participation and
using an effective proper communication system.
Ensuring that HSE policies, procedures and practices are in accordance with the
legislative requirements, industry and standards and best practice concepts.
Ensuring that all relevant HSE legislation, regulations, codes and licenses are
complied with.
The development and implementation of training programs to ensure that employees,
supervisors and managers are familiar with, and understand principles, policies,
procedures and practices.
Ongoing implementation of environmental management plans through pollution
prevention, eco-efficiency and waste avoidance, reduction re-use, recycling and
natural resource management.
Ensuring the all potential HSE impacts are considered prior to changes to the business
or operations.
Providing levels of supervision appropriate to the nature and risk of the task being
ensure that the suppliers and contractors are aware of and comply with PEPC. HSE
policies, procedures, practices and legislative requirements where applicable.
Conducting regular HSE management audits and inspection in due time, and
developing and monitoring defined HSE objectives. All employees, contractors,
vendors and visitors shall comply with this present HSE policy whilst involved in
PEPC Project operations. It is the responsibility of all managers and supervisors to
ensure understanding, implementation and enforcement of this policy. That HSE
policies, procedures and practices are in accordance with the Legislative
requirements, industry and standards and best practice concepts.
Ensuring that all relevant HSE legislation, regulations, codes and licenses are
complied with.

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 The development and implementation of training programs to ensure that Employees,
supervisors and managers are familiar with, and understand HSE principles, policies,
procedures and practices.
Organizing of effective emergency and injury management plan.
Ensuring that all potential HSE impacts are considered prior to changes to the
business or operations.
Providing levels of supervision appropriate to the nature and risk of the task being
performed.
Ensuring that the suppliers and contractors are aware of and comply with PEPC.
HSE policies, procedures, practices and legislative requirements where applicable.
Conducting regular HSE management audits and inspection in due time, and
developing and monitoring defined HSE objectives. All employees, contractors,
vendors and visitors shall comply with this present HSE policy whilst involved in
PEPC Project operations. It is the responsibility of all managers and supervisors to
ensure implementation and enforcement of this policy. Objectives and goals. The
following are the goals and objectives of the HSE Management System.

a) To ensure and display compliance with International Codes and Standards.

b) No (Zero) Lost Time injuries, permanent disabilities and fatal accidents.
c) No (Zero) Significant Property Loss
d) Exclusion of unsafe conditions/situations on the site.
e) Exclusion of situations that could have a negative impact on employee's health, safety
or welfare.
f) Exclusion of activities that might have a negative impact on the environment.
g) To preserve COMPANY and Project image.

5) Commitments and Motivation

PEPC is fully committed to this Health, Safety and Environmental Policy and
Standards and will provide motivation through.

Planning all work in a safe manner prior to executing the tasks and conducting risk
assessments for non-routine and hazardous activities.
Providing a safe facility, equipment, personal protective equipment and safe working
procedures.
Providing suitable training, supervision, information and instruction to all personnel
engaged in Project activities.

Accepting and being accountable for the responsibility of accidents and incidents in
the workplace.

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 Introducing systems to encourage active involvement of the management workforce
and the local community in providing suggestions and proposals for improvements in
the HSE performance.
Providing active support to the workforce by way of specialist advice in safety and
quality areas.
Assessing the risks in the workplace with subsequent communication to the
workforce. Assessing the risks in the workplace with subsequent communication to
the workforce.
Maintaining an active record of all incidents for continual evaluation/analysis of the
Project safety refinance so that ways and means for improvement can be developed
and implemented. A continuous effort, driven by Project Management involvement,
will be made throughout all phases of Project activities to motivate the workforce to
take an active part in use issues and activities.

6) HSE Rules
In order to formulate the necessary standards to be used in the HSE policy, Ten Basic
HSE Rules are considered to be the foundation for such standards that have been established
to achieve Project Objectives. The Ten Basic Rules are:

l) PEPC will comply, as a minimum, with national and international laws and
applicable local regulations and rules throughout its operations and activities.
2) These Health, Safety and Environmental Policy and Standards are to be clearly
defined and made known at all levels of the Project. Responsibilities and
accountabilities for the associated application are to be identified and assigned in
writing.
3) Throughout Project's activities and operations, the risks to health, personnel,
assets and environment are to be identified and the means by which they are to be
minimized / avoided are to be defined.
4) All subcontractors must be evaluated for their ability to conform to the Project's
health, safety and environmental requirements that must be clearly stated in the
contract. All contract award recommendations must address this issue.
5) All operators with a potentially critical effect on health, safety and environment
are to be covered by procedures that are reviewed and updated on a regular basis.
6) Training and competency programs are to be formalized and implemented to
ensure that personnel are prepared for the tasks required of them with particular
attention being given to safety and environmentally critical posts.
7) Emergency procedures covering communications and actions in case of medical,
accident and environmental emergencies are to be maintained and tested.

8) All incidents and accidents, including near misses, are to be reported, analyzed
and remedial actions taken to avoid re-occurrence.
9) All project's operations and activities are to be assessed by inspection and audits.

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 10) Each area of operation will establish objectives and improvement plans based on
incident analyses, audit results and risk analyses in order to raise the level of HSE
performance.

7) HSE Organizations and Coordination

The emphasis on protection of project safety, health and environmental standards
starts with Contractor corporate management and extends throughout the project organization
from the management team to each and every work front on site. As noted, this requires the
commitment of all members of the team to meet their own individual responsibilities toward
the health, safety and welfare of the project as a whole.
The HSE Management Team and team members are charged with responsibility for
the implementation of HSE management system and programs for the project as a whole and,
as such, play a key role in the success of the project. They not only have a direct hand in the
daily direction of HSE matters on the project, they have responsibility for supporting all
members of the project team through the review of safety features, the review of construction
plans and methods, the provision of proper training and safety guides, the supply of safety
tools and equipment throughout the site, the auditing of working practices, advising on
preventative measures and implementing safety improvements as required. In addition to this
primary role in preventative action, the HSE team will act as leaders of the first line response
teams in the event of accidents or incidents. Contractor will submit its site specific HSE
Manual for COMPANY approval as soon as well prior to commencement of work at site.
However, the principles of organization will be as follows:

(l) Management
The Project Manager acts as the sponsor for project compliance with Project
HSE Policy for the whole project. He is also a member of Contractor's corporate HSE
Management Committee and answerable to them for conduct of HSE Policy on the
project.

The HSE Manager for the project will be assigned at an early stage and
immediately well prior to the commencement of work at site. He will report directly to
the Project Manager at this initial stage and, with the support of project management,
select the members of his team who will participate in initial safety reviews in Project.

(2) Personnel

The site HSE supervisors will be assigned in sufficient numbers to ensure that fill
time coverage and support is provided at every major work face. Contractor's policy is to
ensure that all field supervisory staff, from Construction Manager to the field foreman
level, plays a proactive role in protecting the health, safety and welfare of the work force
on the site. This policy ensures the maximum numbers of field personnel are given direct
responsibility and accountability, in the direct achievement of site health and safety goals.

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 The HSE Manager and his supervisors will be responsible for the necessary
training, auditing and support necessary to ensure that Contractor's construction
supervisory team and that of sub-contractors, can exercise this responsibility at all times.
Site management shall carry out regular reviews of the HSE organization in order to
confirm its suitability to fulfill the stated HSE objectives.

8) Procedures for Implementation of the Basic Rules

In order for HSE policy to be effective, the necessary HSE manual for implementation
of the Ten Basic Rules must be addressed and followed. For the implementation, the
following guidelines shall be adopted:

9) Regulation Monitoring

9.1. Contractor
Contractor ensures to establish and maintain procedures to dentil' , collect,
update and communicate to all concerned parties and to enforce the legislative and
regulatory texts applicable to its activities.

Contractor ensures that no activity is undertaken if the required official

authorization for its execution has not been obtained.

9.2. Personal Protective Equipment (PPE)

The Contractor will provide the full range of personal protective equipment
and clothing to ensure the safe working of the work force. As noted, no personnel
will be admitted to the working areas prior to receiving suitable PPE. This applies to
visitors to the site who shall also be issued with the PPE required for their specific
activity. All gears will be "Purpose Approved" for the service and selected with the
advice of the HSE Supervisors for the specific task BODY PROTECTION The
Contractor provides protective clothing and equipment to all its employees engaged
in work where such devices are required to protect them from injuries and health
hazards HEAD PROTECTION Approved safety helmets shall be worn at all times
when working or visiting any of the work site.

EYE AND FACE PROTECTION

Protective goggled, safety glass spectacles, visors or screens of approved type

shall be worn to give protective to the face and eyes against the effectsof welding
arcs, sparks, chipping, hydrocarbons, chemicals and injurious light rays.

HEARING PROTECTION

Earmuffs or earplugs shall be worn in areas designated as "Noise Areas" as

normally more than 85 dB or whilst operating equipment with a high noise level.
Such as generators, air compressors, high pressure service lines, etc.

FOOT PROTECTION

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 Only approved safety footwear shall be considered satisfactory for use, when
working in or visiting operating areas and / or work sites. Footwear having external
steel toes or heel plates or fitted with metal studs will be strictly forbidden in all
areas.

HAND PROTECTION

General purpose had gloves provide protection against usual job hazards such
as slipping, abrasion, dirt, oil, grease and moderate heat. These shall be worn at all
times during the normal course of work. Suitable heat protection gloves will be
provided for welders / fitters exposed to welding, cutting flames, heating torches,
etc., and shall be worn at all times when tasks requiring this type of protection are
performed. Gloves should not be worn while working with running rotating
equipment to prevent the risk of entanglement.

SAFETY HARNESS AND LIFELINES

Safety harness with lifeline shall be worn when any work is calmed out from
an exposed position and 2 meters or more above ground. Static lines will be installed
for use at elevation along pipe racks and structures. All persons required working in
confined spaces where there is a deficiency of oxygen or which contains toxic or
noxious gases or fumes will wear a safety belt and life line in addition to the
appropriate breathing apparatus.

9.3 Communication

A system is to be set up to ensure that personal, including subcontractors employees,

are kept regularly informed regarding HSE matters, can discuss or acquire
information relevant to current issues relating to HSE, and that questions raised will
receive appropriate action.
Language problems shall be identified and measures taken to avoid any risk of
misunderstanding. Clarity of communication is to be addressed regularly.
In case of a major accident. Project in co-operation with site management shall be
prepared for communication with local communities, public authorities, the press,
families of concerned parties and partners. In this respect, an Emergency
Management Team consisting of representatives designated by Project shall be
organized.
This authority and responsibilities of these representatives shall he specified in
writing.

9.4 Risk Evaluation

9.4. I General Statement

Contractor accepts that some of its operations may, unless properly controlled, create
risks to members of its staff, and others, and will take all reasonably practicable measures to
reduce these risks to an acceptable level. Contractor will take all reasonable steps to ensure
that risks assessments are carried out which will detail the range of hazards associated with

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working operations together with any necessary remedial actions. Any employee who
discovers a hazard during working operations should report the hazard to management so that
the necessary remedial action can be taken.

9.4.2 Procedures for dealing with HSE Issues

The current system for discussing Health and Safety issues with employees is via
HSE team. The employee safety coordinators provide an avenue which any concerns raised
by employees, emanating from the risk assessments, can be brought to the attention of senior
management for more formal discussion. Contractor will delegate the HSE manager as the
manager with special responsibility for the implementation and operation of the risk
assessment process. HSE manager provides the management with the necessary knowledge,
information and resources to ensure the proper operation of this process.

9.4.3 Control and Monitoring

The purpose of the risk assessment is to formulate a system of control for hazards
associated with daily working environment and working practices. To achieve this a proper
system for the formulation of remedial actions to cater for the hazards identified has been
developed. All items of concern arising from the completed risk assessment procedure are
discussed by the HSE team. The assessment team leader will detail members of the team to
be responsible for monitoring implementation of the recommended controls, assessing the
efficiency of the controls and making any additional recommendations.

9.5 Work Permit System

Working in a petrochemical palm involving hydrocarbon and toxic material presents

special risks and, in order to provide safe working conditions, a Work Permit system shall be
followed. This is a comprehensive permit to work system and will be reviewed and agreed
with COMPANY prior to work in any area or on any systems deemed to be potentially
hazards and subjects to the Work Permit System for the operation plant.

9.5.1 Function of the Work Permit

The basic purpose of the Construction Work Permit system is to prevent injuries or
harm to personnel. Protect property from damage and ensure that all work is carried out in the
safest p90ssible manner. The Work Permit also fixes responsibility and authority of each
party for the safe execution of the works.

It should be clearly understood that adherence3 to the system does not in itself
guarantee freedom from risk. Therefore, all personnel involved in the task shall ensure that
safe practices prevail throughout the work period. The Construction Works Permit system is
devised to allow work to be carried out within the designated period and construction areas.
The work permit serves the following functions.

Prescribe the nature of the work and the way of execution

Specify the places and equipment on which persons are, for a specified time, allowed
to work

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 Details any remaining hazards and precautions to be taken
Bring to all parties' attention the steps that have been taken and that shall be
maintained to make the area/plan safe for work to be carried out.
Gives written permission for work to be done.
Provides for auditing and reconfirmation of safe working conditions during the course
of work.

9.5.2 Work Permits

The following types of work permits, although not normally applicable to most work,
may apply uncertain specific cases to construction work carried out in the designated
unrestricted" work areas;

1. Excavation Permit - An Excavation Permit is required for any excavation in an area

where the absence of existing underground facilities cannot be confirmed there is
existence of risk of falling and or risk of collapsing.
2. Cold Work Permit - A Cold Work Permitting system is required for all general
construction work on the plant and equipment that does not involve activities related
to Hot Work as described below. This will provide for general observance and
surveillance of safe work practices; and provided an audit tool for work safety.
3. Hot Wok Permit is required for work carried out in the construction area if the use of
a local source of ignition is capable of igniting flammable gases, liquids or any other
materials that may be present. Examples in the construction area are welding, burning
grinding, open fires, etc around confined stores of chemicals, gases, etc.
4. Confined Space Entry Permit Required for personnel entry into confined spaces that
could be subject to the presence of hazardous materials or present a deficiency in
fresh area. Deep manholes subject to ground water leakage or tall vessels with no
controls on manhole closure are just two examples.
5. Electrical Permits Prior to work on electrical circuits/equipment, an electrical permit
shall be used. The authorized competent Person shall isolate the power from
substation. If a multi-lock system is required, each concerned person shall register as
required.
6. Radiography activity permits
7. Read closure permits
8. Post Weld Heat Treatment (PWHT)permit
9.6 Hazardous Substances
Products, materials or substances considered as hazardous by local regulations or the
international standards of reference, must be identified with an indication of where they are
stored and in what quantities. For each hazardous product, a safety data sheet shall be
available on-site.

Dangerous waste are to be segregated, stored safely and taken off-site using approved
methods and properly qualified service companies. Procedures shall be in place to cover:

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 Information and documentation of Hazards the course the label, as- Safety Inducted"
will be stamped on the gate pass card and in addition one HSE induction card will be issued.

9.7 Alcohols and Drug Prohibition, Smoking Restriction

No alcoholic beverages or illegal drugs are permitted on worksite. The Contractor
shall ensure that Personnel is made aware of and fully comply with this prohibition.

No smoking takes place in the non-smoking areas.

Safety at work is not jeopardized by any kind of narcotics and drugs, which may
include some medical drugs, affecting the sense of vies, balance or awareness.

9.8 Emergency Preparedness

Emergency procedures covering communications and actions in case of medical,

accident and environmental emergencies are to be maintained and tested.

Contractor establishes and updates emergency procedures, including medical

evacuations, which define immediate actions to be taken in the case of an accident or
hazardous situation.
For certain critical scenarios (major accidents) the emergency procedures shall
include contingency plans that define the organization of assistance, emergency action
methods and the means available for controlling the situation. For those scenarios
wherein the local communities may be affected, the system shall be developed to
ensure community awareness and assistance, if applicable, is included.
The procedures and contingency plans are to be evaluated and updated regularly
through exercises and drills. The procedure applies to all operations on and associated
with the construction activities on the Project. It applies to the activities of
subcontractors under the supervision or control of Contractor. It applies to the
following situations:
Fire/Explosion
Chemical spill or release
Sabotage
Natural disaster Traffic accident
Evacuation
Emergency equipment and personal protective equipment and clothing shall be
inspected regularly and reviewed at appropriate internals in order to verify suitability
and good working order.

9.9 Identification and inspection of equipment

Equipment critical to HSE performance is to be identified

For identified critical equipment, an inspection schedule defining the method and
frequency of inspections and tests and the measures to be taken to ensure that and item of
equipment I not used unless its compliance with specified requirements has been verified

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shall be established. Collective actions are to be taken regarding all non-conformities
detected during inspection.

In order to reduce the risk of failure of critical equipment, a preventive maintenance

program shall be developed, implemented and periodically reviewed to ensure adequacy.

9.10 Environmental Management

The Contractor will develop detailed procedures covering the handling, treatment and
disposal o liquid and solid wastes generated in the course of the Project.

To implement the Environmental Management System into the Project site, the
following items shall be inspected continuously.

1. Hazards Chemical and Waste Material collection/storage/disposal areas.

2. Oil and Chemical Spillage.
3. Solid Waste Materials (rubbish, garbage, etc...) generated from the Camps and Site
areas,
4. Dust control on the unpaved roads.
5. Housekeeping around all Site areas.
6. Waste water Treatment.
Good housekeeping is an important part of the site Safety and Loss Prevention Plan.
Good housekeeping practices, when practiced as part of normal work methods, will lead to
increased productivity , reduced materials and tools losses and a much safer, more hygienic
and easier area ing which to work. The Contractor will ensure that the tool, equipment and
resources necessary for the maintenance of site cleanliness and orders are provide.

9.Il Incidents and corrective actions

All incidents and accidents are to be reported, analyzed and remedial action taken to
avoid re-occurrence.

Contractor establishes a procedure for incident (accident or near miss) and

anomaly processing. This procedure is to cove reporting, analysis of the
causes, evaluation of potential damage and implementation of remedial
actions.
All incidents are to be reported formally to site management. For serious
accidents, transmittal of this information shall be issued immediately. A
comprehensive report shall be issued.
Incidents with obvious lessons for other departments of Project are to be
reported in such a way as to allow feedback across the Project organization.

9.12 Audits and inspections

9.1 2.1 Audits

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 Audits of the HSE system are to be organized on a regular basis in order to check that
procedures are applied, comply with the requirements of the present document and are
suitable for achieving objectives.

A schedule of audits stipulating the activity to be audited, those responsible for the
audit and the reference documents to be used is established.

A report indicating any observed nonconformity shall be issued for each audit. This
report is to be delivered to the head of the audited activity that proposes and implements the
corresponding corrective actions.

9.12.2 Planned Checks

Planned general checks are to be organized regularly in all sectors of the activity.
Corrective actions are to be applied to any nonconformity detected.

9.13 Health and Hygiene

The Contractor will provide and maintain the facilities and services necessary to
provide First Aid medical treatment for all site personnel. This service will provide for both
the minor first aid needs, which can readily and properly be taken care of on site, and for the
immediate emergency aid required for those injured or seriously ill requiring more extensive
care and /or treatment at outside facilities. The Contractor will maintain adequate hygiene
levels due to consideration to the local climate, and in particular for:

Potable water to be provided in sufficient quantities and meeting Health

Organization specified quality. Food storage and processing
Sanitary services
Adequate camp and accommodation facilities conditions

9.14 HSE Improvement Plan

Each area of operation will establish objectives and improvement plans based on
incident analyses, audit result and risk analyses in order to raise the level of HSE
performance. Site management shall establish an HSE improvement plan that will allow
monitoring of; objectives, corrective actions following incidents, Corrective actions regarding
non-conformities observed during internal and external audits, self-and imposed inspections,
impact monitoring on the environment, training, exercises/drills and integrating experience
gained from incidents outside Project, Risk assessment and preventive actions, Action
required by this document,

The HSE Committee shall have the responsibility to collect information relative to the
incidents; set priorities according to the risks incurred and monitor corrective actions that are
integrated into the HSE improvement plan.

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