Safety Manual

EFFECTIVE SAFETY MANAGEMENT SYSTEM HSE POLICY DESIGNED FOR A SAUDI CLIENT

Abstract One of the fundamental tenets of the safety management system is that Safety Program is structure so that it fits the organisation and values of the organisation. Sample Health, Safety and Environment Policy of our member company on the lines of which we are planning to adopt is attached. After due discussions, deliberations and approval, established system protocols like International Safety Rating System (ISRS), A Safety Management System proprietary to protocol of M/s DNV will be adopted. Sample safety manual on the lines of which we are planning to adopt is attached. ISRS is a leading safety Management System protocol extensively used by over 7000 sites world wide including more than 230 refineries and 25% of the fortune 500 companies. The system is an excellent tool for auditing and bench marking Safety Management System (SMS). It is the most widely endorsed and best tool available in the world to assess continually improve safety performance. ISRS provides a Systematic and Comprehensive basis for assessing performance based on Safety program standards. It is a system of objectively measuring works being done to manage and control all types of loss in an organisation and can also be used as a system to guide the development of effective safety programs. ISRS does, however, encompass much more than the vital concern of personal safety alone. It provides users with an assessment tool that quantifies the safety and loss control performance and this in tun facilitates continuous Safety improvement. ISRS is also used as a tool for benchmarking and setting goals for safety. The quantitative basis provided by ISRS also allows organisations to compare their safety performance with that of International leaders best known for their safety management.

HEALTH, SAFETY AND ENVIRONMENTAL POLICY The Policy: A) Provide Safe and Healthy Operations. B) Progressive Improvement of Environmental Performance. C) Respect the interest of our Neighbours and the community at large. D) Observe the concern in practice. Policy Implementation Through: A) Organisational Set up B) Employees' involvement C) Observing the individual's responsibility. Our Health, Safety and Environmental Policy reflects the continuing commitment of the board to protect lives and health of our employees, safeguard plant and building and avoid adverse Environmental effects. A Good Health, Safety and Environmental Performance is an integral part of the Organization's Business. Our Policy in these areas is declared clearly mentioning the salient features, the role of management as well as of employees. In order to achieve the corporation's objectives for betterment of the society, it also defines responsibilities for achieving the objectives at the company level.

PART – 1: SYSTEM MANUAL SECTION No.

DESCRIPTION

1.

THE SAFETY MANAGEMENT SYSTEM

2.

POLICY & OBJECTIVE

3.

STANDARD AND PROCEDURE

4.

PERFORMANCE MONITORING

5.

AUDIT

6.

MANAGEMENT REVIEW AND IMPROVEMENT PROCESS

PART – 2: FIRE & SAFETY REGULATION Fire & Safety Regulation

PART - 1 : SECTION 1 1.0 THE SAFETY MANAGEMENT SYSTEM 1.1 INTRODUCTION 1.1.1 SMS Objective. The objective of the SMS is to ensure that the hazards inherent in all types of operations in the Refinery have been systematically identified; that arrangements are in place to control those hazards and to deal with the consequences should the need arise; and that the necessary information, training, auditing and improvement processes are in place. 1.1.2 SMS Definition. The SMS is defined as the policies, objectives, organizational structure, responsibility, standards, procedures, process controls and resources which are in place to manage safety in all phases of Refinery operations at all levels. 1.1.3 SMS Manual Purpose. The purpose of the SMS Manual is to be the single management system document within the Refinery which will enable anyone to find out how the activities of individuals are to be managed in order to comply with the Refinery's HSE policy of ensuring safe operation. 1.1.4 SMS Manual Description. The SMS Manual covers all phases of Refinery activities, which defines the management system in place to manage the Refinery's HSE policy of assuring safe operation. The Safety Management System Manual describes the Safety Management System by reference to the various departmental procedure manuals and activities of the Refinery work Processes. The SMS Manual is intended to be used primarily in conjunction with the departmental procedure manuals by all levels of the employees in the Company. The SMS Manual comprises of three parts and: φ Shows that in the Refinery, safety is being managed in a responsible and professional manner. φ Acts as a quality improvement tool for improving the management of safety by integrating Hazard Management into the core business of all departments.

1.1.5 SMS Manual Structure. The SMS manual has three parts. A brief summary of the contents of each part is given below: Part 1 of this manual describes the main elements of the Refinery's Safety Management System including discussions on: • The Safety Management System Manual. • Application of SMS. • Policy and Objectives • Standards and Procedures • Performance Monitoring • Audit • Management Review and Improvement Process Part 2 of the manual provides the essential Fire & Safety regulations to be followed in the refinery. This also includes various Safety critical activities and procedures to be followed thereof. Part 3 of this manual is a description of performance standards to be complied with by staff at all levels to realize the objectives of the SMS. 1.2 ACCOUNTABILITY FOR SMS. The Owner of the SMS is the Executive Director (Refinery). As owner he issues clear directives to the Custodian on how the SMS must be maintained and implemented. The Custodian is the Safety Coordinator. As custodian he would coordinate with all HODs for setting and monitoring performance targets, carry out audits and take corrective actions as often as considered necessary to assure the effectiveness of the SMS. 1.3 REVIEW AND UPDATE. The SMS manual is to be updated when any major change occurs to applicable legislation or to the Refinery's policy, its objectives and the system of achieving them, including changes to the organisation. As a minimum requirement it is to be reviewed once a year to ensure currency.

1.4 SMS APPLICATION. The SMS is a live management system and is to be applied continuously throughout the Refinery. SMS is effective as long as it is rigorously applied. It is a basis for management reviews and improvement, job descriptions, training and competence requirements and reviewing of procedures. It uses a Model Management System Structure based upon quality principles similar to that outlined in ISO 9000 standards. The application of the Refinery's Safety Management System φ Provides continuous assurance that the processes and equipment in the Refinery are being safely designed and operated to meet specified management goals. φ Describes the methods employed to achieve these goals and shows that they are systematically identified and appropriate knowledge, understanding, controls and verification processes are being applied to their execution. φ Describes the methods of continuous assessment and improvement by a systematic programme of performance monitoring, audit and review. φ Provides documentary evidence of above points and a clear feedback of information and continuous improvement. 1.5 SMS CONTROLS The Hazard Management Process (identification, assessment, control of and recovery from hazards) applied to the Refinery's business processes identifies the scope of the SMS. i.e. the relevant safety critical business processes, their safety critical activities, the hazard management objectives and the methods to be deployed to meet these objectives. Control and support at all levels in the Refinery organization is also required. The SMS is founded upon the essential management level guidance, control and support. Three levels of management control are identified: φ SMS Management levels Controls (By the Senior Management viz. Functional and Deptt. Heads). φ Overall SMS Process monitoring and Control (By the Process Owners viz. Section Heads). φ Control of individual activities inside the SMS (By first line supervisor). 1.5.1 SMS Management Controls. The Management Controls applicable to the SMS are contained in this Part I of the SMS Manual. They cover policy and objectives (Section2), organization aspects (Section 3), standards and procedures (Section 4), performance monitoring (Section 5), audit (Section 6) and management review and improvement (Section 11). 1.5.2 Overall SMS Process Monitoring and Control.

These controls ensure the on-going effectiveness of the SMS applied to a particular business process. They involve establishing a custodian for the process (the process owner) who assures that:φ The safety management objectives of the process are fully understood by those involved in it. φ The safety -critical activities and selected controls are sufficient to meet the objectives. φ The process remains effective via the use of both business and HSE related performance indicators. The process owner is responsible for setting up both business and HSE related performance indicators for his process for carrying audits and taking corrective action as often as considered necessary to assure the effectiveness of the SMS. 1.5.3 Control of Individual Activities inside the SMS. Line supervisors ensure that the safety critical activities, which are under their responsibility, are performed to standards by ensuring that the executors of the safety critical activities are: φ Committed to meeting the Safety objectives by carrying out safety critical activities as per the existing HSE rules and regulations. φ Reviewing the safety critical activities in co-operation with the process Owners to identify potential improvements. 1.6 SMS IMPROVEMENT PROCESS Various parties involved in applying the SMS, i.e. executors, line supervisors, process owners and senior management, must be actively involved as part of the live SMS. Identified improvements at the activity level can be readily implemented by updating the SMS catalogue of safety critical activities in consultation with the line and the process or activities. When fundamental changes are required to improve efficiency e.g. organizational changes or changes to departmental missions and roles, management will be consulted by the process owners.

1.7 SMS MANUAL APPLICATION The SMS manual may be used as a reference for: JOB ENHANCEMENT

TECHNICAL SAFETY INVESTIGATIONS/AUDITS

SAFETY ENHANCEMENT & ASSURANCE Program Activity Planning

Integration of HSE Safety objectives into the Development business. Safety Program Setting Competence Hazard Management Development. Requirements. Incident Investigation Job Description Preparation. Technical Safety Auditing Design and Operability Increasing Awareness reviews. (Existing staff)Training SMS Review and Familiarization (new Improvement staff) All levels of management and line supervisory staff may refer this manual and identify their responsibilities and accountabilities and what is required of them to manage their particular part of the business in respect of HSE policy requirements.

PART - 1 : SECTION – 2 2.0 POLICY & OBJECTIVES 2.1 STATEMENT ON POLICY AND OBJECTIVES The Health Safety & Environment (HSE) Policy provides the directional framework on the Refinery's objectives to safety management. It applies equally to its employees, Contractors, Consultants, Agents and other Third Parties engaged in work for, or on behalf of the Refinery, or associated with its activities. Refinery’s Health Safety and Environment Policy reflects the continuing commitment of the board to protect life and health of our employees, safeguard plant and building and avoid adverse environmental effects. A good health, Safety and Environment performance is an integral part of the organization's business. The Policy in these areas is declared clearly mentioning the salient features, the role of management as well as employees. In order to achieve the corporation's objectives for betterment of the society, it also defines responsibilities for achieving the objectives at the company level. Our Health, Safety and Environment Policy is to: φ Provide Safe and Healthy operations. φ Progressive improvement of the environmental performance φ Respect the interest of our Neighbors and Community at large φ Observe the concerns in practice. The Policy implementation will be through organizational set up, employee involvement and observing individual responsibilities in such a manner as to: φ Comply with or surpass the requirement of all applicable legislation. φ Provide a safe working environment. φ Ensure the safety and health of it's own and Contractors' employees. φ Protect the public from injury and health hazards. φ Prevent loss or damage of property resulting from its activities. φ Safeguard the conservation of the natural environment.

2.2 POLICY & OBJECTIVES DOCUMENTS The Safety Coordinator is the custodian of the HSE Policy and objectives. Refinery HSE Policy & Objectives are communicated to all individual employees in the Refinery. The key HSE policy statements and targets are also published as a special document that is publicly put on notice boards throughout the companies work facilities. 2.3 SAFETY TARGETS Refinery has adopted the following safety targets. φ No fatalities. φ Prevention of all lost time accidents. φ Continuous reduction in minor injuries. 2.4 IMPLEMENTATION The implementation of the policy covers the following: φ Compliance with the requirements of legislation on health, safety and environmental matters. φ Application of Refinery's standards, specifications and codes of practice. φ Pursue progressive reduction of emissions, effluents and discharges of waste that are known to have a negative impact to the environment with the ultimate aim of eliminating them. φ Establish contingency procedures to minimise harm from accidents.( Refer On-site DMP ) φ Ensure that clear work instructions and procedures are available with specific regard for safety and environmental requirements. (Refer Fire & Safety Manuals, Operations Manuals, Maintenance Manuals, ISO 9002 & 14001Systems and Procedure Manuals.) φ Design, construct and operate the Refinery in such a way that work is carried out safely and in an environmentally sound manner. φ Provide materials, tools and equipment to meet acceptable safety standards, which are also environmentally acceptable. φ Enhance safety awareness by training each employee in relevant emergency response, safety and environmental conservation skills and practices. φ Ensure that contractors adopt and maintain the same or higher standards with regard to health, safety and environment. (Refer Fire & Safety Regulation for Contractor's safety requirement). φ Hold regular safety meetings at all levels. Address environmental topics explicitly in these meetings or hold separate environmental safety meetings as required. φ Support developmental activities towards safety and health improvement and conservation of the environment. φ Seek continuous improvement in efficiency of use of natural resources and energy. 2.5 LEGAL REGULATIONS

Legal regulations regarding health and safety at work, and environmental protection, have been issued by the Govt. authorities and are complied with. 2.6 REFERENCE HSE DOCUMENTS IN THE REFINERY Listed below are some of the reference documents covering health, safety and the environment. These and other relevant documents are listed in Part three of the SMS manual. φ φ φ φ φ φ φ φ φ φ

Departmental Administrative Procedure Manuals (APMs) Operating and Maintenance Manuals. Fire and Safety Regulations. Emergency Handling Manual. Fireman ship manual. Civil Defense Plan. Disaster Management Plan Contractors' Safety guides. ISO 14001 Environmental Management System Manuals. ISO 9002 Systems and Procedure Manuals.

PART - 1: SECTION - 3 3.0 SAFETY STANDARDS / PROCEDURES / SAFETY MANAGEMENT SYSTEM ELEMENTS 3.1 INTRODUCTION This Section discusses φ Codes and Standards φ Change Control φ Contingency Plans φ Permit to Work System φ Contractor HSE Management φ HSE Plans φ Safety Management System elements. 3.2 CODES AND STANDARDS All codes used in the Refinery are external documents normally relating to Legislation or Industry Regulations and are outside the control of Refinery. However, these codes are referenced in all Refinery Standards as applicable. While a recommendation to initiate a standard may come from anyone in the Refinery, the Inspection and Advisory Engineering Section will carry out the development work. All Standards reviews are carried out by the line and approved by the relevant department manager prior to issue. 3.2.1 Use of Standards In the context of SMS, Standards can be divided into four groups: i.e. Management Standards, Equipment and Material Standards and working methods Standards. 3.2.1.1 Management Standards These standards set the framework in which Refinery operates and deals with overall policy, objectives, accountabilities and controls (refer Management Procedure Manual BPM/REY/P/000/01). 3.2.1.2 Equipment and Materials standards These set the standards to which equipment and materials are procured in the Refinery, whether directly through the materials department or indirectly through the consultants involved in project work. 3.2.1.3 Standards relating to work practices.

These standards set out the way in which day-to-day work is to be carried out, monitored and inspected. Documents on "Working Methods" (Standards, Procedures, Work Practices) in a function or department are held by the relevant line. 3.2.2 Responsibility for Control of Standards Specification, maintenance and review of all standards, relevant to the health and safety of personnel and protection of the environment, is vested in the line function (see part 1 section 4.2 above). These standards are reviewed during specific audits in line with the safety and environmental audit plan (refer part 1, section 6 of the SMS manual). For the purpose of this manual, the term, "standards" covers all policies, philosophies, codes of practice and procedures which are part of the Safety Management System. Standards are generated and maintained with the specific aim of providing a means to: φ Assure technical and operational integrity. φ Assure quality and performance. φ Standardize materials, equipment and documentation. φ Transfer knowledge and improve communications. All refinery activities including design, construction, operations and maintenance are carried out as per national and international codes and standards. Standards provide a means for performance to be measured and evaluated and enable corrective actions to be identified and executed. Each department is responsible for the specification, maintenance and monitoring of the appropriate standards relevant to the SMS as identified in Part 3 and for specifying their scope and application. Each department is also responsible for monitoring both the continuing appropriateness of, and compliance with, the SMS standards stated by this SMS Manual. Line management is responsible for the implementation of standards, for monitoring of compliance and for advising document custodians of any inaccuracies or impracticalities and obtaining custodians approval for, and documenting any deviations.

3.3 CHANGE CONTROL Change Control procedures are employed to ensure that any proposed alterations to the facility or safety critical document (amongst others; standards, procedures etc.) are rigorously evaluated and approved at an appropriate level and any consequent changes are properly engineered, executed and documented. Control of deviations from design or any approved standard is also required to ensure that all non-compliance is correctly endorsed and recorded. All alterations in the Refinery are controlled by the MOC procedure which describes the methods of performance of various SMS elements. 3.4 CONTINGENCY PLANS The Emergency Response Procedure Manual (known as the Disaster Management Plan - DMP) is a controlled document issued and maintained by the Safety Coordinator. It contains response organization, duties of persons in an emergency and emergency response procedures. This document is issued to a controlled list of personnel. This document is also available in the Refinery wide LAN system for easy reference by all through a PC from the work place. Each manual contains only those sections relevant to the individual. 3.4.1 Emergency Planning and Organization All the operating units in the Refinery have well-documented operating manuals. Likely emergencies in the unit and the corrective emergency actions to be taken are listed in all such operating manuals. The shift officer of the operating unit remains the person in charge of handling such plant emergencies till such time he is relieved by the plant manager. In the event the emergency leads to a fire or likely to escalate, the shift officer will call for emergency response from the Shift Superintendent and the fire station. On receipt of such call, the Shift Superintendent will reach site and the fire station will immediately send an emergency turnout. Depending on the nature and size of the emergency, minor or major emergency siren will be sounded by the fire station. Accordingly the minor or major emergency response organization will be activated. The details of the planning and organization including the duties and responsibilities of the persons to be involved in emergency handling are included in the DMP. In the event of a major emergency, the ED-R or in his absence GM-OPS-R or GM (E&P) takes over as the chief coordinator for handling the emergency. He operates from the crisis control room (also known as the Central Disaster Management Post - CDMP) and has specific duties and responsibilities defined in the DMP. In managing the emergency, he will be assisted by functional coordinators in charge of public, press, security,

medical, transportation, canteen, materials, finance etc. All these functional coordinators are assisted by the area coordinators. The functional coordinators operate from the crisis control room. The crisis control room has all the facilities of emergency communication. At the emergency site, plant coordinator takes control of emergency handling. The plant coordinator may be the DGM (Process) or DGM (Prod. Desp) depending on the location of the emergency. The plant coordinator operates from the Site Disaster Management Post (SDMP) established in the affected unit control room or if not possible near the site in a mobile van. Functional coordinators in charge of engineering, process, fire & safety, environment etc. assist the plant coordinator in handling the emergency. A number of area coordinators in turn assist these functional coordinators. Telephone and VHF operating in a dedicated emergency frequency ensure the communication between the SDMP and the CDMP. For details about planning and organization of handling emergencies, refer the DMP. The Safety Coordinator is responsible for establishing, maintaining and updating of the DMP. 3.5 PERMIT TO WORK SYSTEM The safety of all facilities and everyone on them is critically dependent on the proper organization and control of work. This requires a disciplined approach to all operations with effective planning, control and co-ordination of maintenance/ construction activities and modifications. In order to control and perform, the large number and variety of work safely that takes place in the Refinery a General Permit to Work Procedure and document has been developed (refer Fire & Safety Regulation). All works in the Refinery are carried out within the framework of the work permit system. Two types of permits are used in the Refinery - hot work permit and cold work permit. The Refinery has been divided into various zones for the purpose of issue of permits. Each zone has a designated Fire Zone Signatory (FZS) and a Gas Safety Inspector (GSI). All FZSs and GSIs are authorised by the General Manager (OPS) - Refinery. FZSs and the GSIs issue work permits for any work in their respective zones on behalf of the GM (OPS) -R who is the ultimate responsible person for the proper functioning of the work permit system. Hot work permits are issued by the GSIs and reviewed and countersigned by the FZS of the same zone. All work involving the use of energy source or of highly hazardous nature like work in confined space, excavation work, work involving use of radiography etc. are covered by hot work permits. All cold works without the use of any energy source are covered by cold work permits. Cold work permits are issued by the GSIs. Issue of a work permit does not authorize commencement of work. Recipient of the permit is to first register the same at the Fire Station and then obtain an

appropriate clearance (hot work clearance against hot work permit and cold work clearance against cold work permit) from the shift in charge of the area where the work is to be carried out. Full details of the work permit system can be found in the Fire and Safety Regulation. The custodian of this system is the Safety Coordinator. The permit to work is a key tool to enhance safe work management. The requirement for a Permit to Work is based on Job Safety Analysis which is carried out by the personnel involved in the work authorization, supervision and execution. This policy is being followed in all permit to Work training programmes and specified in the work permit system. 3.6 CONTRACTOR SAFETY Safety Coordinator has prepared a Contractors Safety Guideline. All contractors are required to follow the guideline for safe work. With the introduction of SMS all Contractors will be required to follow the requirement of SMS. 3.6.1 Management Refinery requires that contractors and sub-contractors working on its behalf shall: φ Prove that they are capable of conducting themselves in a safe and competent manner. φ Apply the safety measures fully consistent with those of the Refinery and achieve comparable levels of safety performance. φ Consistently demonstrate an acceptable standard of safety awareness. The Refinery HSE management process to achieve the above includes contractor safety assessments at the pre-contract stage, performance monitoring while the contract is in operation and final performance appraisal evaluation at the completion of the contract. At each of the stages, detailed feedback may be provided to contractors to facilitate discussion on concerns and to provide opportunity to remedy deficiencies. The Safety and Technical assessment process involves review of the contractor's safety management and performance namely: φ φ φ φ φ φ

Safety plans and programs Management and Supervision of Work Activities. Competence of Staff Safety training and Organization Equipment control and Maintenance Personal Protective Equipment Arrangements

φ Records of Incidents / Accidents and injuries φ Safety improvement Initiatives φ The Contractors' written response, together documentation is evaluated for assessment

with

submitted

3.6.2 Safety Performance Monitoring Contractor Safety Performance Monitoring is a continuous process, during which results are recorded as a separate written report and submitted to all HODs including those who controls contract work. The report provides a formal basis for the departments on site supervision to discuss safety performance and improvements with the Contractor's Representative. 3.6.3 Responsibilities Contract executing departments in the Refinery are accountable for initiating, specifying, controlling and monitoring the work or services performed and are accountable for the performance of the Contractor throughout the life of the contract. This accountability covers all aspects of Contract performance, including adherence to Refinery's established health, safety and environmental protection standards. The Contractor accepts responsibility for the safety of its personnel and of third parties and protection of the environment in which the work is carried out. In addition, the Contractor is also responsible for:φ Demonstrating commitment to achieving a standard of safety performance comparable with that of the Refinery's. φ Effective means of communication with Contractor personnel. φ Managing the compliance by Contractor's personnel with all relevant safety and environmental legislation. φ Providing employees with requisite training to enable them to execute the work competently and safely. This does not however, absolve Refinery's overall responsibilities for health, safety and environmental management of all its Contractors work. 3.7 HSE PLAN Specific requirements for long term and short term safety programmes are derived firstly from a comparison of current position with the stated goals in the policy objectives, and secondly from known deficiencies to be put right. Long term plans provide the vision and broad strategies, while short-term (annual) safety programmes lay down the more specific and realistic targets. Supporting activities such as training, performance monitoring, auditing and reviews are also included in the plan. Refinery's HSE Plan runs from 1 April to 31 March of the following year and is prepared annually and reviewed quarterly by the Management Safety

Committee. The plan identifies accountable parties, puts forth schedules for corrective action required to rectify safety defects and deficiencies, establishes safety performance targets and schedules safety training and emergency drills. The HSE plan is developed from audit findings, management review action items, feedback from proactive performance indicators, accident and incident findings and safety suggestions from the work force. 3.8 SAFETY MANAGEMENT SYSTEM ELEMENTS 3.8.0

INTRODUCTION The Safety Management System in the refinery has been developed in line with the International Safety Rating System. The various systems and practices for the development of SMS have been grouped under 25 system elements as follows: 1. Leadership and administration 2. Leadership training 3. Planned Inspection and Maintenance 4. Critical Task Analysis and Procedures 5. Accident / Incident Investigation 6. Task observation 7. Emergency Preparedness 8. Rules and Work Permits 9. Accidents / Incidents Analysis 10. Knowledge and Skill Training 11. Personal Protective Equipment 12. Health and Hazard Control 13. System Evaluation 14. Change Management 15. Personal Communication 16. Group communication 17. General Promotion 18. Hiring and Placement 19. Materials and Services Management 20. Off the job safety 21. Quality Management Safety 22. Environment Management System 23. Contractors Safety 24. Transportation Safety 25. House keeping

3.8.1

LEADERSHIP AND ADMINISTRATION Safety Management System depends on management commitment, guidance and resources. The systems and practices have been developed towards demonstrating visible management commitment in all HSE activities in the refinery. General policy:

It is the first step towards exhibiting management commitment. The head of the refinery issues a policy statement stating the intended purpose and goals to achieve. The policy statement addresses management commitment for prevention of injury / damage to personnel, plant, equipment, material and environment. The policy sets out programs to comply with legislative requirements, prevent occupational health hazard, promote good house keeping and responsible care towards community. To put the policy in practice, management will provide adequate resources in terms of personnel as well as the other infrastructure. A full time safety coordinator oversees the implementation of the intents of the policy. The safety coordinator will act as an MR to achieve the objectives and goals set out in the policy. Senior and Middle level management participation: Safety is strengthened if it is discussed right up to the grass root levels and involvement of all levels of employees is ensured. This is possible when members of the Senior Management Staff are able to demonstrate that they are committed to the promotion of safety. One of the ways to show this concern is regular communication on safety to the employees by senior management staff. All members of the senior management staff upto the department head level will spend some quality time at regular interval at the shop floor level discussing exclusively HSE matters. This initiative is termed as safety sampling by senior management staff. To aid senior management staff in safety sampling, a standard checklist namely “safety sampling report format” has been developed. At the end of safety sampling tour, senior management staff will fill in this checklist and forward the same to the safety coordinator. Participation in Safety activities: Improvement in safety is achieved by contribution from all persons in the system. It is therefore, expected that all management staff participates in some safety activities. The staff can get involved and carry out internal safety audit, involve in safety training, participate in safety promotional activities during safety campaign, participate in safety meetings, carrying out safety sampling etc. Management will provide all opportunities to staff for participating in various safety activities including providing them adequate training to assume leadership role in safety management. Internal Audits: Audit is an effective tool to monitor performance in safety. As a management control, internal safety audit is carried out every year. For

convenience, entire refinery has been divided into 14 zones. For each zone a multidisciplinary team of management staff would be formed to carry out internal audit of the Safety Management System as well as the compliance with cores and practice GM (OPS) would form the teams and set out the process once every year. Each team, which includes an employee, would carry out the internal audit as per checklist developed for this purpose and submit reports to the GM (OPS). Internal audit is a technique, which calls for special skills. In order to equip the persons involved in Internal Safety Audit, appropriate training will be provided to them. Individual Safety Responsibility: Responsibility and Accountability are the pillars for successful implementation of safety management system. Each member of the management staff will have an assigned target on HSE issues and be accountable for meeting them. The targets would be included in the job description of the staff concerned, which will be reviewed periodically by his section / department head. The Annual performance management map of individual management staff be will clearly indicate the task related to HSE that he has to accomplish. Employees too will have specific safety responsibilities, which are mostly contained in standing orders and fire and safety regulations. The annual performance appraisal of the employee will also reflect his performance in safety. Annual Safety Objectives: No goals can be met unless there is proper planning. Refinery will plan every year its objectives and targets for accomplishment of HSE goals through the implementation of systems set out in SMS. The plan and objectives would be congruent with the organization’s business objectives and would be drilled down from the refinery level to individual department / sections including the safety department. Monitoring is essential for success of the plan. Accordingly the performance in HSE activities is reviewed against the plan in the management safety committee by the senior level of the management on a regular basis every quarter. 3.8.2

LEADERSHIP TRAINING: Training needs analysis Systematic training provides confidence to individuals to assume leadership role in translating HSE goals into practice. Training also needs to be in line

with the organization’s safety systems and objectives, prevalent regulations, codes and standards and the skill set required for individual staff including the safety coordinator. Every line Manager will assess the training needs of individual staff based on above requirement. The training requirement would be reviewed once in a year to ascertain efficacy. Safety orientation / Induction: Every employee joining new to the organization or on transfer from one job to a different job will be given proper orientation / induction about specific HSE requirements of his assignments. This is an essential requirement in order to allow the employee perform his work safely.

Training of senior Management staff and the safety coordinator: Sr. Management staff and the safety coordinator are required to guide, direct and monitor the implementation process for the SMS. This calls for adequate information and appreciation of the various aspects of the SMS. All the members of the senior management team and the safety coordinator will be provided initial as well as refresher training on various aspects of SMS not only at the introductory level but also at advance level. 3.8.3

PLANNED INSPECTION AND MAINTENANCE 1.

Planned General Inspections

Section heads of respective areas will carry out by multidisciplinary teams surveys of areas, structures, equipment etc. in their work areas to identify and assess safety hazards that may be expected and based on that to ascertain the required frequency of inspections of those areas / structures / equipment. Safety coordinator will organize training to the members of the multidisciplinary team in inspection techniques prior to assigning them to carry out the survey. He will also develop inspection checklist for each area in consultation with the section heads of that area. Based on the potential safety hazards identified in each area safety coordinator will assign frequency of inspection and will issue every month a program for planned general HSE inspection as per this frequency. Section head of each area would then ensure that the planned HSE inspection is carried out as per program circulated and also as per the checklist pertaining to his area. The teams conducting planned HSE inspections would report in writing in the checklist all substandard conditions and practices observed during inspections. Concerned function head will suitably recognize any employee identified doing above standard work or an area demonstrating above standard conditions during the planned general inspections. The teams conducting planned HSE inspections will categorize all substandard conditions / practices as per hazard potentials. Based on experience gained during past planned general HSE inspections and also whenever there is any change in the plant, safety coordinator will update the HSE inspection checklist of that plant.

2. Follow Up System Concerned section heads will take appropriate actions to remedy any unsafe act or conditions observed during inspections and reported. They will forward a copy of the inspection checklist along with action taken to the safety coordinator for record and further analysis. The team carrying out planned general HSE inspection would classify hazards based on potential pertaining to all substandard conditions and practices so as to decide priority of intervention and management attention. Section head of concerned area along with section head of maintenance of that area will be responsible to rectify the substandard conditions / practices within the time frame as suggested in the planned HSE checklist based on the hazard potentials. Section head of each area of will report every month to the safety coordinator the details of remedial actions taking together with reasons for delay if any for each of the observed substandard conditions and practices. Based on that, safety coordinator will prepare a consolidated report of the planned HSE inspections of all areas together with status of all substandard conditions/practices and submit the same to the management safety committee once a quarter. The section head and the department head of each area will discuss the status of the substandard conditions/practices highlighted in the planned HSE inspection of his area in the sectional safety committee meeting as well as departmental safety committee meetings which are attended by employees also. All planned HSE reports from all areas would be available for ready reference. 3. Inspection Report Analysis Safety coordinator will carry out an analysis of all planned HSE inspection reports to identify common and repetitive problems and their underlying causes and forward the results of analysis along with appropriate recommendations to all departments for taking corrective actions. Section head of each area will take appropriate actions to remedy the basic/underlying causes of substandard conditions/practices identified in his area. The results of the analysis of planned general HSE inspections would be discussed in sectional safety committee meetings by section heads, departmental safety committee meetings by department heads and management safety committee meetings by the safety coordinator and presented during experience sharing sessions to all employees. 4. Critical Parts/Items

Section heads will prepare an inventory of safety critical item/equipment/activity for each operation, activity, structure, equipment and material pertaining to their jurisdictions. This list will be forwarded to safety coordinator. This list will remain under constant review and updated annually by the section heads. Identified critical items, equipment, activity, structure and material will form part of the planned HSE inspection checklist. Section head of each area will also make a thorough assessment of the risk / hazard of each equipment, material or structure in his area that can interfere with safety of other and make necessary preventive actions. He will thereafter systematically review and update the list of critical parts / items. 5. Preventive Maintenance Section head (maintenance planning) will develop an effective plant preventive maintenance program. Section heads (field maintenance and shops) will critically observe at the time of any repair work to identify and record all accidental damage to any equipment or part thereof inform section head (maintenance planning). Investigation of all equipment damage cases more than Rs 50,000 would be carried out so as to ascertain the basic causes of the damage. Section head (maintenance planning) will inform safety coordinator of all such damages more than Rs 50,000 along with investigation report. He will carry out once in three month analysis of all equipment breakdowns and accidents so as to evaluate the effectiveness of the preventive maintenance system. He will also review and modify as necessary based on available information, the inspection and maintenance schedules of all plants and equipment. 6. Special Systems Inspection Section heads of all areas will review all equipment/machinery/tools in their areas to identify and list those items the function of which is primarily safety health and environment protection. They will ensure that for each safety critical equipment in their areas, a frequency of inspection has been established and be responsible for inspection of these equipment / items as per established frequencies. Each area in-charge will regularly follow up to ensure completion of any recommendations arising out of inspection of safety critical equipment in his area. 7. Pre-Use Equipment Inspection Section head (transport maintenance) will carry out a survey with the help of element champions and employees of his area of all mobile and material handling equipment to identify the requirement of pre-use inspection for safe operation of that equipment. He will prepare pre-use checklist for all mobile

and material handling equipment. Apart from that he would also specify the persons responsible for pre-use equipment inspection for each equipment, determine the schedule and extent of pre-use inspection, the stage of equipment operation when the pre-use inspection is to be carried out, actions to be taken in case substandard conditions are observed during pre-use inspection and also the system to be followed for correction of such substandard items. As a system check, he will review the pre-use inspection system at least once a year and also whenever a new equipment is received or existing equipment has been changed/modified or a hazard assessment/risk analysis pertaining to an equipment has been carried out or immediately after a major/high potential accident takes place. 8. Alternative Substandard Conditions Reporting System. Section head of each area will encourage employees to report in writing whenever they observe a substandard or hazardous condition. On receipt of such reports, he will forward these to the safety coordinator. Simultaneously, he will also take immediate action to remove the substandard/hazardous conditions and make the work area safe so that the employee can resume normal work. Till that time employees shall have right to remain away from the potential hazard. 9. Compliance Requirement. Safety coordinator will make a list of inspections required to be carried out under various regulations. He will review and update the list of inspections required under legislation at least once a year. He will also carry out a detailed study by knowledgeable persons to determine compliance with all applicable regulations/codes/industry standards in respect of all inspections of physical conditions.

3.8.4 ACCIDENT/ INCIDENT INVESTIGATION The process of accident/incident investigations including near miss and hi-po incidents are specified in the document “Accident/incident investigations procedures.” 3.8.5 EMERGENCY PREPAREDNESS The details of procedures related to emergency planning and preparedness are contained in the “Disaster Management Plan”. 3.8.6 RULES AND WORK PERMIT 1. Procedures in respect of General Fire & Safety Rules: In order to ensure personal safety as well as Safety of others in the work place, it is essential that all works are carried out following required Safety precautions. Whereas, there will be many safety requirements unique n nature for specific jobs, certain general requirement should always be kept in mind by all the personnel working within the refinery premises. In order to achieve these objectives, general fire & safety rules have been compiled up by the Fire and Safety Department in consultation with Staff and employees of various departments. These rules will be made available for information of all personnel working within the refinery premises in easily understandable languages through a. Distribution to all employees, in Marathi, Hindi and English along with the Annual Safety Diary. b. Display in all plant control rooms and workshop areas. c. Jumbo Display board at various locations in the refinery. The general Fire & Safety rules displayed in the Control rooms and workshop will be checked for readability and condition along with the planned HSE inspection to be carried out as per schedule. The Jumbo Display boards will be inspected once in six months by Safety Officers and carryout refurbishing as required. These general Fire and Safety rules will be reviewed by the Fire & Safety Department whenever there is a major change in Process, equipment, system etc and at least annually along with the Safety Diary.

2. System for framing Specialised work rules: The refinery operation is requiring many tasks being simultaneously performed by various groups employees of having differing degrees of skills, educational background and knowledge. Whereas, some tasks are of routine nature and may not pose any special hazard to the persons executing the task or the environment, there would however be some tasks, which are inherently hazardous to the people and the environment. These tasks, need to be performed with special attention and care. For safe work, it is therefore, essential to identify these tasks and also to relate these tasks with the occupation performing the same. In order to achieve this objective, a team comprising of both management and non-management staff having all round experience in refinery working will carryout survey in the refinery to identify the various occupations and the tasks performed by respective occupations. While preparing the list of occupation and the corresponding tasks, the team will review the various existing task procedures, regulatory requirements, process descriptions and also the records of past incidents / accidents. The list of tasks so prepared would be ranked in order of criticality and an inventory of highly critical tasks will be made. Special work rules for such critical tasks will be prepared and documented by the team in consultation with individuals executing such tasks. All such critical tasks will be performed as per the rules and procedures developed. The inventory of critical tasks will be reviewed whenever there is a major change in the process or equipment (refer Management of Change documentation). In general, the critical tasks will be reviewed once in a year by a team specially constituted for this purpose by the General Manager (Ops)Refinery. 3. Requirements of Work Permit system Refinery is a high hazard area. It is therefore essential that, all work in the refinery area to be regulated by a work permit system. The team carrying out the occupation survey and preparing the inventory of various tasks performed in the refinery will to classify the identified tasks as per their hazard potential. In addition to the occupation survey, the team will a. Review risk assessment and past incident / accident reports. b. Carryout site observation. c. Obtain employee suggestion while classifying tasks as per hazard potential.

Based on this classification, non-hazardous and routine activities would be segregated from the high hazard activities. All non-hazardous activities will be carried out under a cold work permit whereas all high hazard activities will be covered by hot work permits. Whether the work is covered by cold or hot work permits, actual work will start only on issue of a clearance certificate by the area shift in-charge where the work is to be carried out. The regulation of work in the refinery through permits will be governed by the work permit system described in Chapter 10 in Fire & Safety Regulations. The cold work permits will be issued by Gas Safety Inspectors of respective areas whereas hot work permits for high hazard jobs will be issued by Gas Safety Inspectors as well as the Fire Zone Signatories. The shift in-charge of the area where the work would be carried out shall issue clearance certificates based on the permits issued for the job. The job condition listed in the permits / clearance should be as listed in the procedures developed for the critical tasks. In addition, conditions as required by the prevailing conditions at the workplace at the time of executing the tasks shall also be laid down in the clearance. The GSI's and FZS's of respective areas in the refinery would be nominated by the General Manager (Operations)-R which will be reviewed and revised as required quarterly. All GSI's, FZS's and the users of the work permit system will be made aware about the need for the work permit system as well as the risks involved in various jobs through training workshops conducted periodically for this purpose. The details of all such workshop shall be documented and maintained in In-plant training center as well as the Refinery Training Center. All permits will be made in triplicate - the original with the execution agency, second copy with Fire Station and third copy with the issuer of the permit. All permits are required to be registered centrally at the fire station before approaching for clearance certificate to start the work. Both Cold & Hot work clearances will be issued in duplicate - the original with the executing agency and the copy with the issuer. However, before starting work, the hot work clearances are to be registered centrally in the fire station. The work permit system will be reviewed periodically atleast once in two years along with the review of specialised work rules by a team comprising of Management as well as on Non-Management staff and constituted by the General Manager (Ops)- R. During such review, all major and high potential accidents during the previous period shall be examined and changes if any, in the work permit system felt necessary shall be incorporated. 4. SYSTEMS TO ENSURE OPERATIONS ARE BEING CARRIED OUT WITH VALID LICENCE / PERMITS

To operate the process units and the refinery as a whole including all the equipments we require licenses, certificates or permits from various regulatory agencies or as prescribed in standards or as suggested by the suppliers of the process / equipment. In order to ensure that processes and equipments are operated in compliance with the requirements laid down by the regulatory bodies, standards and codes and also by the manufacturers, a systematic study would be carried out to identify such requirements. The approach for such systematic study would be as under a. Constitution of team / teams to study applicable regulations governing the operations in the refinery. b. Study the applicable standards for operating processes as well as equipment used in the refinery. c. Study the requirements spelt out by the manufacturers of equipments for operations of the same. d. After such study, list down the various licenses / authorizations required to operate including the agencies from whom licenses / authorizations are to be obtained. e. Mention against each license / permit, a responsible person by designation (to be known as custodian) who will ensure issuance of such license / permit and also the renewal of the same on expiry. f. The list also would mention against each required license / permit the name of a person by designation who would be responsible for carrying out the necessary work required for obtaining / renewing the license / permit. g. The custodians will ensure that the applicable licenses/ authorization for which they are responsible are current and up-to-date. h. Whereas, all original licenses / permits would be maintained by the respective custodians, copies of the same shall be forwarded by them to the Senior Manager -Design and Drawing for centralised documentation. i. The safety coordinator will organise once in a year, a review of the status of all license / permits along with the custodian, the Sr. Manager - Design and drawing as well the persons responsible for complying with the requirements of the license / permits I. To ensure that all required license / permits are updated. II. To ensure compliance of all license / permit requirement. j. Custodians will ensure communications with the regulatory bodies pertaining to revision / renewal / reapplication etc as laid down in the regulations k. All parties involved in the system shall be given necessary training inputs in respect of the requirements of complying with various licensing / permit conditions once in a year. l. The list of licenses / permits along with the condition for issue required will be circulated to all concerned personnel who are required to operate under such licenses and hence comply with the conditions thereof. 5. CREATING AWARENESS IN RULES AMONGST EMPLOYEES

However, meticulously rules and procedures might have been framed, these would be of no value unless the people supposed to adhere to understand and followed. The awareness for rules and procedures leading to effective application is possible only through proper dissemination of the same amongst the employees. Following guidelines may be used to ensure such dissemination a. A pocket book of relevant Fire & Safety rules will be distributed to all existing employees under proper acknowledgement. b. All new employees will be issued with this pocket book at the time of joining the refinery by Staff Section (for Management Staff)/ IR Section (for Non-Management employees) / Training Center (for trainees & apprentices) with proper acknowledgement. c. All acknowledgements would be forward to and centrally kept with the Manager - Safety. d. For existing employees, the first line supervisors will discuss these rules progressively with his employees atleast once in a week so that all the employees working with him are aware about the rules. For all new employees, the section head (T&D) would ensure briefing of the rules at the time of first induction in the training center. e. The section heads through their first line supervisor / Section Head (T&D) (for all new employees) will document such rule education programmes appropriately (Communication book / logbook etc.) mentioning therein the various rules that have been discussed and the name of the persons present in such discussions. f. The Section Heads would examine atleast once in a year the extent of understanding of the rules by the employees by administering a written objective type questionnaire. g. They may also consider recognising employees with high degree of awareness. The employees needing further education would also be known through such testing and appropriate actions can be taken for further education. h. The section heads will obtain suggestions from employees for review of rules and pass on the same to the safety section for necessary revisions as may be required. i. In case of new/transferred employees, the concerned section heads will ensure that specific rules pertaining to his new areas of operations are explained to the employee. He would also ensure that the new employee has understood all the rules. This may be accomplished by administering an objective type written test. The section head will certify the new employee is fit for the job. 6. GUIDELINES TO ENSURE RULE COMPLIANCE Compliance of rules and procedures by the employees are to be ensured by a systematic approach. Recognising on employee for rule compliance goes a long way in motivating other employees to comply with rules. However, occasionally it may be required to deal with employees who are

consistently non-complying with specified rules and procedures. In order to ensure rule compliance the following guidelines may be adhered to : a. During all communications with employees, the first line supervisors and the section heads will encourage compliance of required rules and procedures by the employees. b. Find out the employees who are observed to be consistently following all required rules and procedures and also taking more than standard precautions in doing a job thereby preventing accidents. c. Commend such employees giving them adequate recognition to continue with such positive behaviour. This may be accomplished as below. I. Appreciate his behaviour in presence of other employees. II. Mention about his good behaviour in group meetings like Sectional / Departmental Safety Meetings and record them. III. Issue him an appreciation letter with a copy to his dossier. IV. Recognise consistently outstanding performers by awards during departmental / sectional safety functions. All such recognition shall be appropriately documented and forwarded to Manager - Safety for centralised documentation. Whereas recognition is important for motivation it may be required some times to appropriately deal with habitual violators of rules. Following guidelines may be adhered to in this regard: a. Whenever a violation of rule / procedure is noticed, the first line supervisor / section heads will have a personal communication with the erring employees and explain the safety implications in violating these rules. Such communications are to be recorded in the plant communication book. b. Subsequent violations of rules by the same persons would be discussed in group meetings like sectional / departmental safety meetings and recorded. c. In the event violation recurs, the concerned employees would be issued with office notes advising them to comply with the required rules and procedures. d. If violations still continue, a second office note will be issued with a copy to their dossiers. e. If no improvement is observed, necessary disciplinary actions as per conduct discipline rules may be initiated against the employees. All such actions initiated against erring employees are to be properly documented and forwarded to Manager-Safety for centralised documentation. The system for rule compliance and recognition as above would be circulated to all employees for their awareness by the plant managers through the first line supervisors / safety observers / safety surveyors. 3.8.7 ACCIDENT/INCIDENT ANALYSIS

1. Statistical Analysis & Consequence Measurements The Safety Coordinator will compile accident and incident statistics and will communicate these studies, arranged department wise to Director (R), Executive Director (R), General Managers and other Department Heads monthly. He will also compute every month for the entire refinery as well as dept./section wise frequency and severity rates of work injuries/illnesses and also rates of property damages, fires and adverse environmental events. The computed results will be communicated to all senior managers every month. 2. Accident /Incident Analysis The Safety Coordinator shall prepare analysis of the incidents for the refinery as a whole as well as department, section and occupation wise. The analysis will cover unsafe act, unsafe condition, personal factors, body part affected etc. The detailed analysis will be communicated to Director (R), Executive Director (R), General Managers and other department heads monthly. He will analyze every month each accident / incident to ascertain the underlying causes (immediate / basic / lack of control). The causes as ascertained shall be analyzed for the whole refinery as well as dept./section wise. Safety department will provide dept. wise accident statistics/ records to all supervisors by putting the information on the Intranet and will maintain all accident/incident statistics and analyses in a central location at least for a period of two years. 3. Property Damage / Process Loss Identification And Analysis Safety coordinator will review quarterly the reported cases of property damage and process loss to ascertain the repetitive or significant ones. He will also evaluate every six months each of these repetitive/significant property damage and process loss cases and prepare a list of critical few department- wise. 4. Incident (Near Miss) Analysis Frequency rates of near miss incidents would be computed every quarter and reported to senior management. Safety department will identify and analyze all high loss potential near miss incidents once in a quarter and report to senior management. 5. Problem Solving Project Teams General Manager (ops) will form from time to time multidisciplinary problem-solving teams to study critical problems identified during analyses of occupational injuries/illnesses, property damage cases, process loss

incidents, environmental violations, fires etc. to suggest remedial measures. Report of problem-solving teams will be discussed once in three months in the management safety committee meetings. All members of problem-solving teams will be given appropriate training in problem-solving techniques. 3.8.8

KNOWLEDGE AND SKILL TRAINING 1. Administration: Management of overall employee knowledge and skill training programs in the refinery will be the responsibility of the Section Head (T&D). He will develop all training programs from a training need analysis. 2. Training Needs Analysis: Section Heads will review various occupations as well as critical tasks performed by each occupation for identifying training needs. Section Heads will gather inputs from Safety coordinator to identify employee-training needs in the areas of Safety. For identification of training needs Section Heads in coordination with Chief HR Manager and Safety coordinator, where required, would also review φ φ φ φ φ φ φ φ φ

Operating Procedures, Inspection Reports, Change Management Analysis, Training programme evaluation reports, Performance appraisal reports, Hazards and risk in the process plants, Accident / incident analysis, Applicable statutory regulations / Codes / Standards. Training program evaluation reports.

Section Heads in coordination with Section Head HR and Incharge of Inplant Training Centre will organise to carry out sample surveys of employees and staff to obtain inputs for training needs once a year . Section Heads in coordination with Section Head (T&D) shall carry out training needs analysis as above once in a year. Section Head (T&D) will prepare and update annually training plans for each individual employee and administer training programme accordingly. 3. Instructor Qualifications:

Section Head (T&D) shall prepare a list of training instructors based on their knowledge and skill for administering identified training programmes based on Training needs analysis. He will conduct training programmes for the knowledge and skill-training instructors in various instruction techniques. He will evaluate atleast once in two years the list of training instructors to ensure that their qualifications and skills are up-to-date. 4. Training Systems: Section Head (T&D) will develop and use appropriate lesson plans to guide and standardise employee training so that training meets the employee needs. He will evaluate the employee training performance to determine the knowledge and proficiency gained by the employee through the training. The result of such evaluation will be forwarded to the trainees' line manager. He will maintain records of training imparted to each employee against the needs identified annually. The training department and In-plant Training Center will issue certificates of competence for the successful completion of employee training courses. Section Head (T&D) will conduct formal refresher training programme to review the critical portions of the original employee-training program once in three years. He will advice the plant managers for the refresher training requirements of their employees and arrange the programs accordingly. Section heads will ensure proper skill training to employees on transfer from other jobs or prior to assigning to an employee a new work before actually allowing him to take up the work. Section heads will identify in their area equipment, the operation of which would require license. Section heads will provide required competency training to operators to obtain license and upon obtaining such license shall authorize the operators to operate such equipment. Section heads will Institute a system developed by safety coordinator to recognize employees in their areas who exhibit high level of knowledge/competency level. 5. Training System Evaluation: Section Head (T&D) will evaluate the training programmes once in a year and produce a written report of his evaluation to the DIR (R), ED-R, GM's and the department heads. The evaluation will cover the following areas:

φ Comparison of number of people needing training and the numbers received the training. φ Quality of the lesson plans for employee training courses as highlighted by the trainees. φ Teaching techniques and aids adapted. φ Comments of the course reviewer. φ Results of written / oral tests, if any. φ Observation reports / proficiency on the job after the training. φ Review of changes based on accident / incident analysis. φ Review of risk analysis. φ Review of teaching aids used in training.

3.8.9 PERSONAL PROTECTIVE EQUIPMENT (PPE) 1. Personal Protective Equipment Standards: Section heads will carry out, involving group of employees, formal assessments of the requirement of personal protective equipment for each task under each occupation identified in their areas. The assessment will be based on a survey of job analyses, risk analysis reports, physical hazard assessment, past accident/incident/near miss analyses, review of codes/regulations etc. Safety coordinator will provide required support to the Section heads. He will review at least once a year the tasks/activities requiring use of personal protective equipment and consider options available to put in place so as to reduce/eliminate the requirement of personal protective equipment for that work/task. Personal Protective Equipment (PPE) Standards, procedures for cleaning and maintenance needs will be defined in writing by Safety Coordinator, following an analysis of all job/occupations and discussions with line managers / employees on site. All employees, who are required to use PPE, will be able to participate in the selection of equipment, through discussion in Safety Committees and Group Communication meetings. Employees will be properly instructed by their line supervisor and where required, Safety personnel in the use, cleaning and maintenance of personal protective equipment that is assigned to individuals. Personal Protective Equipment (PPE) will be regularly checked by the owner to ensure that it is in good condition. Safety coordinator will provide personal protective equipment to all employees with proper fitting. All employees will immediately discard damaged PPE and receive a reissue. Safety Personnel will carry out PPE compliance surveys at various areas once at least every quarter. The results will be communicated in writing to Plant Manager, Safety Coordinator. 2. Personal Protective Equipment Record Keeping : Safety coordinator will put in place a system of recording all issues of personal protective equipment to individual employees as and when the same are issued. He will carry out analysis of the usage of personal protective equipment at least annually. He will also carry out proper cleaning/maintenance of all types of respiratory equipment and keep proper records of such actions.

3. Enforcement Of Standards And Procedures: Section Heads / Site Supervisors will enforce the standards and procedures for the use of PPE and will use appropriate forums to discuss the requirement with their employees. PPE should be specifically discussed at Safety Committee Meetings. They will identify non-users of required PPEs and consider the same while evaluating safety performance of individual employees. Employees who escape injury due to use of personal protective equipment should be recognized and such incident should be widely publicized. 4. Regular Program Monitoring: The Safety Coordinator will evaluate the degree of compliance of PPEs and procedures throughout the operations as part of the annual audit programme. The result of this evaluation will be reported in writing to all Managers and Site Supervisors. 3.8.10

HEALTH AND HYGIENE CONTROL 1. Administration & Management: Management will provide adequate staff and infrastructure to facilitate proper assessment and control of occupational health and industrial hygiene hazards. The occupational health and industrial hygiene control systems will be facilitated and supported by the Section Head (Medical Services). He will provide appropriate training to all individuals responsible for health and hygiene activities. 2. Health and Hygiene Hazard Identification: Section Head (Medical Services) will maintain a list of all occupation and related tasks for all operational areas. He will analyze the occupations and the tasks in consultation with Plant Managers and Safety representative to identify and evaluate any occupational health and hygiene hazards to which employees may be exposed. He will also review the Hazard / risk analysis reports, accident / incident analysis of the past three years, inspection reports, change management results, applicable regulations etc, for the identification and evaluation of health and hygiene hazards. A survey of employees and managers also would be carried out to identify and evaluate health hazards. 3. Health Hazard Control: Section head (material services) along with concerned Section heads will carry out survey of each plant area for identification/evaluation of

chemical, noise, radiation, illumination, vibration, extreme temperatures, biological, ergonomic, physical and stress related hazards. Department head (Technology) will maintain an updated list of all chemicals used in the refinery along with their MSDS. He will also maintain chemical composition of all hazardous substances used, manufactured, stored, treated, transported, disposed off, and released to environment along with their quantities. 4. Occupational Health and Industrial Hygiene Monitoring: Section head (medical services) will put in place a system of measuring and evaluating all chemical, noise, radiation, illumination, vibration, extreme temperatures, biological, ergonomic, physical and stress related hazards are within safety limit. He will establish the periodicity of health check up of persons exposed to various health hazards and carry out actual medical examinations/tests as par that periodicity. He will also review once in two years health hazard monitoring requirements, analyze health hazard monitoring reports, various controls in place, adequacy of follow-up measures to ensure control in place, system and results of calibration of monitoring equipment and revise the health hazard monitoring as maybe required. All data generated through monitoring of health hazards as required by regulations will be systematically maintained. 5. Information and Training: Manager Medical Services in association with Section Head (T&D) will organise awareness programmes on potential occupational health and Industrial Hygiene Hazards related to various works carried out in the refinery. It is to be ensured that all management staff and employees are suitably exposed to such awareness programmes. Section Heads will communicate to employees about any potential health hazards of their jobs at the time of assigning the same. He will keep MSDS giving details of safety and health hazards of all materials in the work place, which should be readily available for reference by all employees. He will also ensure that all employees exposed to work having potential for health hazards are provided with refresher training atleast once a year. 6. Health Care System: Manager Medical Services will develop and implement health care programmes with specific focus on general wellness of employees’ health. He will periodically organise employee wellness programmes like alcoholism, absenteeism, gambling, stress management, nervous breakdown, family problems, drug abuse, problem of any other physical fitness including counseling to cope up with such health problems.

7. Professional Assistance: Management will provide full time professional medical officers and fullfledged medical centre facilities for employees for attending to employees health problems arising out of work or otherwise. It will be the duty of the Manager Medical Services to circulate as well as display in prominent locations the procedure for obtaining medical attention during emergency as well as normally. This procedure will be reviewed once at least every year. Manager Medical Services will properly maintain reports of all first aid cases and will review all first aid cases and investigate those cases, which are high potential. 8. Communication: Manager Medical Services will encourage employees during general medical examination to talk confidentially about their health problems, which may be arising out from their work. He will inform employees any health problem diagnosed during medical examination/health hazard monitoring. All restricted duty cases arising out of any health problems will be reported to the Sr. Manager. Similarly employees will report immediately all injury / sickness cases as per Fire & Safety regulations. Manager Medical Services and Safety Coordinator will apprise management safety committee once in three years about the effectiveness of the occupational health and industrial hygiene programmes.

9. Record Keeping: All records of medical examinations of employees will be maintained in a proper and retrievable manner confidentially. Manager Medical Services will maintain a system of authorised access to all such medical records. 3.8.11. SYSTEM EVALUATION 1. Assessment Of Loss Control Requirements Safety coordinator will prepare a long-term plan for the refinery setting targets for attaining higher ISRS levels in respect of safety management system and also other HSE related goals together with a road map to achieve these goals. While preparing the plan he will involve all departments as well as cross-section of employees at all levels in formulating such long-term HSE plans. Once the plan has been finalized he will obtain approval from the Senior Manager for refinery long-term HSE plans. Respective Department Heads would communicate the approved long-term HSE plan to all department employees. Safety coordinator will evaluate the status of implementation of the longterm plan against objectives and long-term goals and also the effectiveness of the plan once every six months and report his findings to the management safety committee. Based on the evaluations of development of safety management system against long-range plan, corrective actions for continuous improvement as well as modification of the plan, if required, would be undertaken by the safety coordinator. Actions identified for continuous improvement would be communicated by the safety coordinator to all levels of management as well as employees prior to implementation to allow for discussion and feedback. 2. Regular System Monitoring Safety coordinator will 0rganize system audit every quarter of all plant areas to evaluate compliance with the various requirements under the 20 ISRS elements of the refinery safety management system. He will communicate the results of such compliance audit to all departments as well as to management safety committee. Section heads would undertake necessary remedial measures to implement any deviations observed during such system audits. The effectiveness of the system audits would be periodically reviewed, at least once a year.

3. Evaluation Of Compliance With Safety Management System Performance Standards. Safety coordinator will carry out once a year an audit by a multidisciplinary team to ascertain extent of compliance with the safety management system performance standards by each section/dept. Management will provide appropriate training to persons involved in audit of SMS performance standards. Safety coordinator will prepare an action plan to bridge any gap that might have been identified in any of the twenty elements under the SMS performance standards audit. He will thereafter follow up with Section heads implementation of the actions to bridge the gaps once every two months. 4. Perception Surveys Safety coordinator will organize once a year survey across the refinery to ascertain employer perceptions about refinery’s safety arrangement system as well as their awareness levels. P&A will ensure that perception of employees about refinery’s safety practices are discussed and recorded at the time of exit interview of any employee. P&A will also hand over to safety reports of such perception for suitable improvement action. Safety coordinator will review results of perception surveys/exit interview and address improvement opportunities. He will then communicate to all employees the results of perception surveys through “Weekly Notice”. 4.0 ACCIDENT / INCIDENT INVESTIGATION AND REPORTING 4.1 The Accident / Incident Investigation and Reporting System All accidents / Incidents are to be Investigated and Reported as per procedure laid down for the proposal.

4.1.1 Purpose The purpose of accident / incident investigation and reporting is to identify the root causes in order to: φ Prescribe and implement suitable action(s) to eliminate or avoid similar occurrences in future. φ Disseminate the information to other areas of operations likely to have the same hazard, and so enhance the safety awareness of all personnel. φ Ensure that statutory and group requirements on injury and accident reporting are met. φ The procedure guide explains how to report accidents and incidents, which occur within the Refinery. 4.1.2 Injuries have been classified into 4 classes φ φ φ φ

Fatality Lost Workday Case (LWC) - LTAs Medical Treatment Case (MTC) - Minor Injuries First Aid Case (FAC)

Investigations are conducted into all incidents in the Refinery. A standard incident report form is prepared for all incidents. The same form is used for reporting accidents involving contractors.

PART - 1 : SECTION – 5 5 AUDIT 5.1 INTRODUCTION This section describes: • Safety Audit Process • Corrective Action Procedures. 5.2 HEALTH, SAFETY AND ENVIRONMENTAL AUDITS All audits within the Refinery would be as per procedure laid down. 5.2.1 Objectives of Safety and Environmental Audits φ To keep Refinery Management informed of the health and integrity of all the Refinery activities by reviewing, on a cyclical basis and in a systematic manner, the safety and environmental quality of these activities. φ To assist management to update hazard management strategies. φ To assist management to identify safety and environmental shortcomings. φ To assist management to identify remedies. The Safety Coordinator is responsible for compiling the safety audit plan in consultation with the functional departments, for review/assessment by the Management Safety Committee. He is responsible for preparing and Coordinating the implementation of the audit plan for all activities. Audits would be conducted according to the guidelines provided in the SMS Manual and the Safety Performance standards included in the SMS Manual. The audit would be carried out by a team comprising of Section Heads, Representative of the employees (preferably the sectional safety observer) and an element champion. Section Heads will serve as the team leader of the audit teams. The team leaders will in principle be independent of the Section/Department being audited, but normally one line person be included in the team to provide specific knowledge of the subject being audited. General aspects of the Safety Management System are audited during the safety audit. The HSE Audit Plan specifies annually which parts of the SMS are audited. Audit reports are addressed to the auditee and to the Refinery Management. The auditee based in the auditors recommended action points draws up a time schedule with action plans. The follow up action is the responsibility of the line and is monitored by the safety section.

5.3 CORRECTIVE ACTION PROCEDURES This section describes the corrective action process for implementing φ All audit recommendations and follow up. φ Incident report recommendations. Reasons for rejection of any safety improvement action from the above are approved by the concerned HODs. Deviations from the recommendations of the above are also approved by the concerned HODs. Where the auditee and auditor cannot agree on corrective actions resolution should be sought with the Management Safety committee. Progress on all corrective actions is reported at regular intervals to the top management and the Safety Coordinator through the departmental monthly report until the audit recommendations are finally closed out. Safety coordinator puts up a consolidated information to the Management Safety Committee.

PART - 1: SECTION – 6 6.0 MANAGEMENT REVIEW AND IMPROVEMENT PROCESS 6.1 INTRODUCTION This Section describes φ The development and maintenance of the Refinery Health, Safety and Environmental Plan (HSE Plan) and departmental programmes. φ The review and effectiveness of the Refinery Health Safety and Environmental Plan and Safety Management system. φ The improvement strategy and revision for the Safety and Environmental Plan and the Safety /management System. 6.2 DEVELOPMENT AND MAINTENANCE OF THE HSE PLAN An annual HSE Plan is produced and runs from 1 April to 31 March. The Safety Coordinator in co-operation with the line departments prepares it. The purpose of the plan is: φ To set annual targets for achieving the long term improvement objectives. φ To detail activities to be performed for achieving these targets. φ By means of annual programmes, to focus on key elements of the safety management with the objective of systematically eliminating the root causes of accidents. φ To maintain the SMS. φ To create an understanding of the Refinery HSE policy and give it a common direction. The HSE Plan has the following content: φ Review of previous year's performance. φ Department Programmes for objective period. The HSE Plan sets targets for all levels of the organisation. Application of this plan and the cascading down of its targets to individual tasks and targets ensures that all staff have clearly defined HSE objectives. These tasks and targets, are in line with the over all Refinery objectives and will be annually reviewed during the staff reporting exercise. The outcome of this annual review will go back into the next years targets.

6.3 REVIEW OF PERFORMANCE AND EFFECTIVENESS OF THE HSE PLAN AND SMS 6.3.1 HSE Plan Department heads are responsible for implementation and monitoring of their programmes in accordance with a timetable. Management at regular intervals would review the effectiveness of the HSE plan. Review procedures are to be written specifying the frequency and format of such management review of the HSE plan. 6.3.2 Safety Management System Adherence to specific elements of the SMS is audited in Technical Safety Audits. A plan for review and improvement of the SMS is prepared annually in conjunction with the HSE plan. The review will consider SMS audit findings and attempt to identify any weakness in safety management objectives or corresponding controls. The revision and improvement programme is based on: φ Examination of Safety performance indicators and targets to see where SMS improvements are necessary to improve performance. φ Review of audit and incident investigation reports for patterns of performance needing improvement by enhancing the SMS. φ Review of SMS documentation in accordance with a structured plan φ Review of SMS elements in a structured fashion by the SMS custodian. 6.4 IMPROVEMENT STRATEGY AND PLAN REVISION 6.4.1 Health Safety and Environment Programme The Refinery HSE improvement strategy is set against the long term targets of zero accidents and progressive reduction of emissions, effluents and discharges of waste that are known to have a negative impact to the environment with the ultimate aim of eliminating them. The improvement strategy is based on the identification of key HSE and SMS issues each year and addressing these in the departmental programmes by a series of actions. Once identified, they will continue to be addressed in annual plans until conditions have been improved as far as reasonably practicable. Improvement in performance may require new tools, policies or procedures, enhancements to existing policies, improvements to existing procedures and / or practices. The improvement strategy may identify these needs or may take advantage of new ideas from outside.