Cristal Mining East. Mine Safety Management Plan

Transcription

1 Doc No: AP_ME_ Revision: 3 Series: Management Plan Location: Mining East Cristal Mining East Mine Safety Management Plan Next Review: Nov-2015 Owner: J. Sulicich Revision Date: Nov-2014 Approver: C. Reynolds

2 1. INTRODUCTION DEFINITIONS PLANNING GOALS AND TARGETS Documents Policies Standards Management Plans Procedures Standard Operating/Maintenance/Isolation Procedures Forms and Manuals Operational HSE Targets and Objectives LEADERSHIP AND ACCOUNTABILITY HSE Management System Management Responsibility Supervisor Responsibility Personal Protection Equipment Contractor Pre-Selection and Assessment LEGAL REQUIREMENTS AND DOCUMENT CONTROL State Specific Australian Statutory Requirements Document Control RISK AND CHANGE MANAGEMENT Process for Hazard and Risk Management Hierarchy of Controls Hazard Reporting Job Hazard Analysis (JHA) Take Safety Interaction Program Management of Change (MOC) INDUCTION, COMPETENCE AND BEHAVIOUR Induction Training and Competency Assessment COMMUNICATION AND CONSULTATION Daily Pre-Start Meetings Toolbox Meetings Safety Alerts, Bulletins and Incident Notifications Disciplinary Process EMERGENCY PREPAREDNESS AND RESPONSE of 38

3 9.1 Emergency Services First Aid and Injury Management Incident Reporting Injury Definitions INSPECTIONS, AUDITING, MONITORING AND REVIEW Inspection and Testing HSE Management System and Compliance Auditing HSE Audits HSE Review FITNESS FOR WORK Drugs and Alcohol Fatigue and Working Hours Employee Assistance Program (EAP) Hygiene Noise and Vibration Dust, Fumes, Mists, Gases and Vapours Chemicals and Hazardous Materials Radiation Smoking Sun Protection and Awareness SAFETY STANDARDS Subcontracting and Purchasing Handling, Storage, Packaging and Delivery Manual Handling Confined Space Entry Isolations and Tagging Housekeeping Excavations Barricading Grid Mesh, Flooring and Handrail Removal Working at Heights Scaffolds and Scaffolding Man cages / Workbox Ladders, Fixed and Portable Fire Protection SAFETY STANDARDS VEHICLES AND MOBILE PLANT Vehicle Maintenance and Mechanical Inspections Speed Limits of 38

4 13.3 Cranes Significant Crane Lifts Mobile Elevated Work Platforms (EWP) Forklifts SAFETY STANDARDS FIXED PLANT AND EQUIPMENT Equipment Safeguarding Lifting Equipment and Winches Welding and Gas Cutting High Pressure Water Equipment Compressed Air Equipment Hoses Air, Water, Hydraulic and Gas Portable Tools SAFETY STANDARDS ELECTRICAL Electrical Equipment Inspection, Testing and Tagging Procedure Flexible Cords/Extension Leads Generators and Welding Machines ENVIRONMENT General Environment Conditions Discharge of Liquids COMMUNITY Concerns of the Local Community Caring for the Environment APPENDIX A ORGANISATIONAL STRUCTURE APPENDIX B REFERENCED AND APPLICABLE LEGISLATION, AUSTRALIAN STANDARDS AND CODES OF PRACTICE of 38

5 1. INTRODUCTION Cristal Mining Australia Limited (Cristal) is fully committed to the journey to zero harm and believes that all incidents are preventable. Cristal has a clearly defined ongoing responsibility and commitment to Workplace Health, Safety and the Environment (HSE). This Management Plan lists the minimum requirements to comply with HSE targets and objectives to achieve a workplace that is free of risks to health or safety as far as reasonably practicable. The HSE performance of Cristal will be reviewed and audited on a regular basis against the requirements of this plan. Results of these audits shall be used to assess workplace health, safety and environmental performance / compliance in accordance with all statutory and company requirements. This Management Plan has been developed so that it may be used by all workers. The Plan contains a series of systems designed to assist with maintaining the highest levels of HSE performance. 2. DEFINITIONS Term ALARP At-risk behaviour At-risk situation Competent Person Consequence Contractor Emergency Event Fall Prevention Fatigue Definition As low as reasonably practicable used in defining the desired level of risk and hazard control measures Conduct (whether witnessed or not) that unnecessarily increases the likelihood of injury. A physical situation in the workplace that may lead to an incident or injury if not corrected A person assessed as competent for the tasks they shall perform and who has acquired, through training, qualification, experience or a combination of those things, the knowledge and skills required to perform the required task competently and safely Outcome or impact of an event An individual, company or other legal entity that carries out work or performs services pursuant to a contract for service, this includes sub-contractors/third parties An abnormal occurrence that can pose a serious threat to the safety or health of workers, customers, local communities or which can cause significant damage to assets or the environment. An occurrence of a particular set of circumstances Fall prevention is creating a safe working area that eliminates the possibility of a fall or objects falling by using fixed working platforms, temporary working platforms, scaffolding, and physical barriers, elevating work platforms, lanyards or mobile work platforms. It is a state of impaired physical performance and lowered alertness arising as a result or combination of hard physical and mental work, health and psychosocial factors or inadequate restorative sleep. It can be either work or non-work related or a combination of both. 5 of 38

6 Term Harm Hazard Hierarchy of Controls Incident JHA Near Miss PCBU Procedure PPE Risk Risk Assessment Shall Definition Significant and / or long-lasting adverse impact on people, the environment or the community. A source of potential harm, injury or detriment. A series of controls, which should be applied in the following order; Elimination Substitution Isolation Engineering/Redesign Administrative Personal Protective Equipment A number of these options may be considered and applied individually or in combination. Any occurrence that has resulted in, or has the potential to result in (i.e. a near miss), adverse consequences to people, the environment, property, reputation or a combination of these. Significant deviations from standard operating procedures are also classed as an incident. Ongoing conditions that have the potential to result in adverse consequences are considered to be incidents. A Job Hazard Analysis. A process to document the systematic identification, assessment and elimination or control of hazards (to as low as reasonably practicable ) prior to the commencement of a task by a work group which is outside the scope of a Procedure or where a procedure is not in place. A near miss is any occurrence or a situation which potentially could have caused adverse consequences to people, the environment, property, reputation or a combination of these but which did not. Person conducting business or undertaking as referred to in the NSW WHS Act May be Cristal Mining or Contractors where contractor is a company, partnership or sole trader A specified, documented way to carry out an activity or a process. Personal Protective Equipment. Worn by personnel to protect them from hazards which cannot be eliminated by other reasonable and practicable controls The Danger that injury, damage or loss will occur, it has two dimensions: the likelihood of something happening and the consequences if it were to happen A formal systematic examination of a process, design, plant or other situation/condition to identify and assess the potential hazards of operation and the proposed methods of their control. Referenced requirement must be complied with and is not negotiable 6 of 38

7 Term SIP Smart Solve SMP SOP Working at Heights HSE Worker Definition Standard Isolation Procedure A document management system that stores relevant documents pertaining to the Safety Management System Standard Maintenance Procedure Standard Operating Procedure Ascending, descending or working in any position where a person can fall from one level to another. Health, Safety and Environment Any person, including staff, labour hire, contractors, work experience or others, who undertake work for Cristal 7 of 38

8 3. PLANNING GOALS AND TARGETS Cristal has a Journey to Zero vision. That being that Cristal believes that all injuries and incidents are preventable and will continually work towards achieving this. Health, Safety and Environmental (HSE) management is integral to the ongoing success and sustainability of Cristal Mining Operations. This HSE Management Plan is designed and developed to ensure that goals and targets are established to drive continuous improvement of performance in line with company and legislative requirements, mining industry best practice and the Journey to Zero philosophy. The relationship between Corporate, site Company and Legislative requirements is shown below. Figure 1.0 HSE Management System Structure - Hierarchy of Documents What needs to be done? How it is done 8 of 38

9 3.1 Documents This section covers the documents related to the management system. 3.2 Policies Policies are high level documents that define the intent, broad approach and beliefs in relation to health, safety and the environment. 3.3 Standards The Standards are a set of relatively brief statements which set out the requirements in relation to a range of issues which have the potential to affect the safety and health of people, or the environment. The Standards are effectively an expansion of the Policies and are high level statements that define what has to be achieved in relation to HSE, without including any prescriptive requirements as to exactly how these requirements are to be met. The Standards are as follows: Accountability and Commitment Planning and Resources Legal Compliance Hazard and Risk Management Training and Competency Incident Investigation and Reporting Performance Measurement Documentation and Records Reviews, Audits and Inspections Communication and Consultation Capital Projects and Design Construction, Demolition and Decommissioning Management of Change Contractors, Suppliers and Visitors Emergency Preparedness and Response Product Stewardship Operational Procedures Control of the Working Environment Plant and Equipment Integrity Hazardous Materials Management Fitness for Work Environmental Effects Waste Management Resource Management 9 of 38

10 3.4 Management Plans Management Plans document commitment, intentions and principles in relation to overall management of a particular aspect of the operation (i.e. emergency response plan) and to provide the framework for action and the setting of its objectives. 3.5 Procedures Procedures are a series of documents that define what will be done, when, and by whom and what records will be kept. They are an expansion of the Standards and apply to all Mining East sites. The requirements of the Procedures are mandatory. 3.6 Standard Operating/Maintenance/Isolation Procedures Standard Operating Procedures (SOP s) Standard Maintenance Procedures (SMP s) Standard Isolating Procedures (SIP s) These are site specific procedures that are required by operations to meet the requirements of the Mining East Procedures. They are step by step instructions that define what will be done, when and by whom. 3.7 Forms and Manuals The associated documentation required to support the various elements of the management system. 3.8 Operational HSE Targets and Objectives As part of the Journey to Zero, the HSE Management Plan commits to the objective of achieving a target of Zero Harm to people, the environment and the community. Cristal has established Key Performance Indicator (KPI) targets specifically for the purpose of monitoring SHE performance. Performance is reviewed against targets monthly with the KPI metric also reviewed annually. Cristal will regularly communicate, consult, and provide feedback and direction on HSE performance and issues in support of the Journey to Zero. These KPI s are cascaded down to individual employee safety performance goals that are formally reviewed biannually through performance appraisals. HSE KPI s that are recorded and reviewed monthly include (but are not limited to) the following: Lead Indicators Safety Interactions Performed Workplace inspections and audits conducted; Hazards Reported Take 5 s completed Near Misses Reported Action Completion % 10 of 38

11 Lag Indicators Recordable Injury Frequency Rate All Injuries Frequency Rate All Incidents Frequency Rate Environmental Incidents Frequency Rate Reportable Incidents 4. LEADERSHIP AND ACCOUNTABILITY All Cristal personnel must be committed to and support the Journey to Zero. Senior Leaders will provide visible proactive leadership to assist in achieving the highest attainable standards of HSE performance. The following SHE Operations Statement was issued by the Director of Cristal Mining. 4.1 HSE Management System Cristal has a HSE Management System with documented standards and procedures detailing the company s commitment, responsibilities and methods to achieve leading HSE performance. The structure of the HSE Management System is shown in Figure 1.0. In the implementation of this HSE Management plan, Cristal will: Specifically address and develop Standards and Procedures that meet Cristal Corporate and Legislative Requirements. Make available all relevant Statutory Acts and Regulations, Australian Standards, Codes of Practice and the HSE Management Plan Ensure a communication and consultative mechanism is developed and promoted in the implementation the HSE Management Plan. 11 of 38

12 4.2 Management Responsibility Cristal will: Have in place a visible SHE Policy and objectives which have been distributed and communicated to all workers; Provide information regarding SHE requirements to all workers including subcontractors and visitors Monitor, review and communicate the HSE Management System; Provide adequate, suitably qualified and experienced supervision to act in Supervisor positions Audit and monitor the SHE performance Identify safety critical roles and ensure these roles are suitably fulfilled. Consult, communicate and coordinate HSE requirements with all key stakeholders Maintain an up to date Organisational Structure 4.3 Supervisor Responsibility Supervisor roles and responsibilities include (but are not limited to) the following: Complying with the HSE Management Plan and HSE Management System requirements; Ensuring risk control measures are implemented in areas and activities for which they are responsible Communicating safety information to relevant persons, including between supervisors at the change of shifts. Are responsible for ensuring that workplace inspections are carried out in accordance with MB Procedure Workplace Inspections Ensuring personnel under their supervision have the appropriate skills, training, competency and knowledge (including access to relevant procedures) to perform their required tasks Ensuring all employees associated with their department can attend a toolbox talk each month and the minutes of the meeting distributed appropriately and outcomes communicated to the appropriate people. Being aware of the MB s Emergency Response and Crisis Management Procedure and act accordingly. Giving appropriate feedback to those employees seeking clarification on Health, Safety and Environmental issues. Investigating and reviewing all accident/incidents within their work area and ensures all information from accidents/incidents is communicated to all personnel within the department and other relevant parties. 4.4 Personal Protection Equipment Cristal will ensure that personal protective equipment (PPE) is provided to all personnel and that personnel are trained in the correct use and maintenance of all PPE they are required to use whilst undertaking their assigned duties. Risk Management principles will be used to determine appropriate PPE for all site activities, whenever PPE requirements are not covered by existing Procedures. Minimum site requirements; 12 of 38

13 High Visibility Long sleeved shirts and/or High Visibility Vests (with reflective stripes at night or in dark periods) Long trousers Safety footwear Safety helmets Safety glasses and Gloves Additional information regarding PPE is detailed in the Personal Protective Equipment Procedure available from SmartSolve. 4.5 Contractor Pre-Selection and Assessment Cristal has established and implemented a process for the selection and engagement of subcontractors. This process ensures that information is gathered and an assessment of the contractors SHE Management activities, quality programs and insurances prior to engagement. Subcontractors shall be audited for HSE compliance during the work as part of planned audits. Any Contractor who is unable to satisfactorily meet the minimum Cristal HSE requirements shall be required to follow the Cristal HSE Management whilst working on site. Any Contractor who is unable to provide sufficient evidence of a commitment to HSE policies, principles, procedures and/or statutory compliance shall be excluded from the tendering, selection or work process. Additional Information regarding Contractor Management can be found in the Contractor Management Plan available from SmartSolve. 5. LEGAL REQUIREMENTS AND DOCUMENT CONTROL Cristal has an obligation and duty of care to comply with legislation. Cristal will document through the HSE Management System how it will aim to meet legislative requirements. 5.1 State Specific Australian Statutory Requirements The main legislative requirements governing the Cristal Mining East Operations are: Work Health and Safety Act 2011 Work Health and Safety Regulation 2011 Mine Health and Safety Act 2004 Mine Health and Safety Regulation 2007 Refer to Appendix E Legal Requirements for further information 5.2 Document Control Cristal has an established Document Control procedure and electronic Document Management System (SmartSolve) for the purposes of controlling documents that form the HSE Management System. Specific information on the document control process can be found in the Document Control procedure available via SmartSolve on the company s intranet. 13 of 38

14 6. RISK AND CHANGE MANAGEMENT Cristal will integrate risk management into its everyday activities. Cristal shall establish a risk registers to identify all foreseeable HSE risks associated with its operation, as far as is reasonably practicable. Cristal shall: a) Ensure the HSE risk register is reviewed regularly b) Ensure HSE risk assessment controls are implemented prior to an activity commencing; c) Maintain and supply documented training records; and d) Develop, implement and communicate HSE standards, procedures and work methods as required for work activities including, but not limited to: Hazard identification and risk assessment; Document control and records management; Workplace inspections; Working at heights; Confined space entry; Personnel training and induction; Excavations and open edges; Emergency preparedness and response; Scaffolding; Hot works; Isolation and tagging; Electrical equipment safety; Hand and power tools; Dangerous goods and hazardous substance management; Traffic control and safe movement of vehicles; Fitness for work and fatigue; Alcohol and other drugs; Noise control; Water, air and soil contamination; Waste management; Use of ladders; Cranes and rigging; Personal protective equipment; 6.1 Process for Hazard and Risk Management The following hazard and risk management processes will be followed: defining the job/task; identifying the hazards; assessing the risks; 14 of 38

15 implementing control measures (controlling the risk); and Monitoring and reviewing the process and the effectiveness of controls in place. For further information on Risk Management refer to the procedure available via SmartSolve 6.2 Hierarchy of Controls Cristal will develop and implement controls with consideration and priority given to the Hierarchy of Controls. Control measures to eliminate or minimise the risk, as low as reasonably practicable, will be considered and implemented in the following order of priority: Elimination: The complete elimination of the hazard Substitution: Replacing the material or process with a less hazardous one Isolation: Isolating the hazard by guarding or enclosing it Engineering/Redesign: Application of suitable guarding or protection Administrative: Providing control such as training, procedures, signage etc. Personal Protective Equipment: Use appropriate and properly fitted PPE where other Controls are not practical or in combination with other controls as a final barrier. 6.3 Hazard Reporting Identified hazards are to be reported and rectified as a matter of priority in accordance with the level of risk. Identified hazards will be discussed at daily pre-start meetings and a summary of hazards provided monthly. Hazard reports and resulting corrective actions are be tracked through Accstat, the incident/event tracking database. For further information on Hazard Reporting refer to the procedure available via SmartSolve. 6.4 Job Hazard Analysis (JHA) A Job Hazard Analysis is required to be developed by work teams prior to commencing any task that is not already covered by a procedure or where a task varies from the standard operating / standard maintenance procedure or as determined by a Take 5. The JHA shall be used to list the specific job steps, identify potential hazards or risks associated with job step (including the immediate work environment) and appropriate control measures that mitigate the identified risks (using the Hierarchy of Controls methodology) ensuring they are as low as reasonably practicable (ALARP). JHAs are developed by the personnel conducting the task, required to be signed by persons completing the task and reviewed prior to commencing and periodically during the task. The completed JHA must be reviewed and approved by a Responsible Supervisor prior to commencing the task. If a JHA is continually being completed for a task, A Standard Operating or Standard Maintenance Procedure shall be developed. For further information on Job Hazard Analysis refer to the procedure available via SmartSolve. 6.5 Take 5 Cristal has established a Take 5 risk assessment tool that is used by personnel to assist them in identifying and documenting risks associated with their job/task and work environment. The Take 5 is to be used as the first action of assessing risk in a task prior to commencement. If the hazards identified in the Take 5 cannot be reduced to a LOW residual risk rating, then a JHA must be completed. 15 of 38

16 A take 5 must be used in conjunction with an SOP at least once prior to commencing the work to identify is anything has changed since the SOP was written. If there are changes, these shall be added to the SOP and signed by all people undertaking the task 6.6 Safety Interaction Program Cristal has established a robust program for performing safety interactions. Specialised training has been performed aimed at Supervisory and Management level on how to perform safety interactions, what to look for and how to deal with or manage any at risk behaviours or situation. Safety Interactions are one of the lead safety KPI s for the company. 6.7 Management of Change (MOC) Cristal has an established method for the management of changes in the workplace This will minimise the risk of proposed changes creating an unacceptable risk to health, safety, assets and/or the environment, The change management process aims to ensure the following: changes are identified and recognised; consultation and communication with all the relevant parties; careful consideration is given to managing the risks associated with any change; due diligence can be shown to have taken place; involvement of the right people in the change process; and All statutory requirements are met. Requests for changes are to be reviewed and approved by relevant personnel to ensure that all modifications are analysed systematically and implemented in a manner that does not present an unacceptable or uncontrolled risk. Further information on change management can be found in the Change Management Procedure found on SmartSolve. 7. INDUCTION, COMPETENCE AND BEHAVIOUR 7.1 Induction Personnel required to work on, or visit the site must complete the appropriate level of training and induction requirements: Site personnel including Management, Supervision and workers (employees and contractors) must undergo the company induction which includes information on but is not limited to: Cristal Mining Operations HSE Management System Risk Management and Job Hazard Analysis Work Permits Training and Competency Fitness for Work Isolation of Equipment Camp and Accommodation requirements Emergency Procedures 16 of 38

17 An ID / Security pass shall be issued when a person has completed the appropriate inductions and met pre-employment screening criteria. Visitors are required to undertake a visitor s induction that will explain relevant site requirements. The visitor must be escorted / accompanied at all times by a full inducted person whilst on site. Visitors are no permitted to perform work / tasks). Induction refresher training is required every 3 years as a minimum or where a person has been absent from site for a period of greater than 6 months. 7.2 Training and Competency Assessment Cristal has established procedures and allocated sufficient resources to identify and provide the training needs and assessment of competence of personnel on site. Cristal will: Identify training requirements of employees; Ensure training complies with the National Training and Competency Assessment guidelines; Ensure that where required by legislation or Australian Standards such training is conducted by a Registered Training Organisation (RTO) ( e.g. High Risk Licenses such as forklifts, rigging etc.); Implement a plan to ensure all workers attend relevant task training; Maintain documented records of training and assessment; Have approved training in the relevance to the work being performed; i.e. Working at Heights, Isolations and Confined Space, Ensure HSE information is regularly circulated on site via pre-start and toolbox meetings, notice boards, etc. Provide documentary evidence that all personnel have been assessed as competent to safely carry out their assigned tasks. Provide training to relevant personnel in relation to any site SOP or SMPs developed. 8. COMMUNICATION AND CONSULTATION Cristal will ensure clear communication and consultation with workers to facilitate positive input and participation in HSE matters. 8.1 Daily Pre-Start Meetings Cristal Operational departments will conduct pre-start meetings at the beginning of each shift to discuss relevant HSE matters and planned work activities for the day. This will include cross shift communication of identified risks and control measures implemented. The pre-start meeting will be the centre of the workplace HSE communication, consultation and coordination. Pre-start meeting minutes, relevant attendance records and records of notices etc. shall be maintained. Any specific topic that may have an effect on other site activities shall be communicated immediately following the meeting. 8.2 Toolbox Meetings Cristal will conduct formal toolbox meetings on a monthly basis. Meeting minutes and relevant records shall be maintained by the Safety Department. Toolbox meetings will give a regular and formal forum for discussion on HSE matters, incidents, hazards, HSE KPI s, safety topics, personnel issues etc. 17 of 38

18 8.3 Safety Alerts, Bulletins and Incident Notifications The Cristal Senior Safety Advisor will circulate via , relevant Safety Alerts, Bulletins and Incident Notifications from both internal (for example Cristal Global Sites) and external (for example Department of Trade and Investment) sources. These communications shall be discussed at pre-start meetings and displayed at prominent positions throughout site. 8.4 Disciplinary Process Where an individual breaches a legislative requirement, a Life Critical or other site procedure, appropriate counselling / disciplinary action will be taken in accordance with the disciplinary procedure. Where the breach is blatant, counselling / disciplinary action can result in dismissal / prohibition from site. 9. EMERGENCY PREPAREDNESS AND RESPONSE Cristal shall establish appropriate Emergency Preparedness and Response procedures and facilities including procurement of suitable equipment to manage an array of foreseeable emergencies. These procedures and further information of emergency response can be found in the Emergency Preparedness and Response Plan available via SmartSolve. 9.1 Emergency Services Cristal shall establish good relations with local emergency services. These relations should involve (where practicable) site familiarisation visits, communication regarding any hazardous materials or practices, company emergency response plans and capability. Cristal safety and health professionals shall maintain at minimum an annual meeting with the local emergency services to ensure communication of any changes that may/will occur to the emergency response services with regard to the mine. 9.2 First Aid and Injury Management Cristal aims to have all of its employees trained in Senior First Aid as a minimum and shall ensure processes are in place to provide prompt care of injured people should an injury occur. Additionally, at the Mine sites appropriate levels of Occupational First Aid coverage shall also be established to provide a higher level of care in the more remote area. Cristal shall provide a sufficient quantity of suitable first aid kits for an industrial environment in addition to plant and vehicle first aid kits Transport for Medical Assistance If off site medical assistance is required, appropriate means of travel shall be arranged depending on the urgency of the situation and may include (but not be limited to): Transport via the RFDS Transport via Ambulance Transport via company vehicle; Others means as necessary First Aid Rooms Cristal has established suitable First Aid Rooms /facilities located on site for treatment of an array of foreseeable injuries. All injuries treated at site, no matter how minor and no matter if work or non-work related, shall be documented. 18 of 38

19 9.2.3 Injury/Case Management Cristal has established Injury and Case Management Policy s and processes in place and the principles apply to all site personnel (employees, contractors and visitors). The aim of injury management is to ensure appropriate and adequate treatment is provided to injured workers to enable a quick and efficient return to the workplace. Cristal is committed to open lines of communication and cooperation with regard to injury management on site as to ensure that any injured party receives the appropriate treatment and that their return to work can be suitably managed. Cristal has an appointed Return to Work Coordinator (RTWC) to assist with facilitating the injury management process. Effective injury/case management must commence immediately after the accident has occurred and is to include; The RTWC liaising with the patient; Referral to the Company Doctor (where required); Follow up, including personal off site visits (where required); Liaising with the company s Workers Compensation insurer Conducting formal assessments of employee capabilities prior to returning to work; Provision of alternate meaningful duties, where appropriate. Discussions between the RTWC, treating physician and injured party Discussions between the RTWC, injured party and their Supervisor regarding returning to work. 9.3 Incident Reporting All incidents (including near misses) regardless of how minor shall be reported and investigated appropriately. Cristal has a documented Incident Reporting and Investigation Procedures and many site personnel trained in incident investigation. Incidents should be reported to Cristal Supervision immediately but no later than the shift in which it occurred. Cristal has an Incident Report form available via SmartSolve. Cristal has a duty to report certain incidents to the Department of Trade and Investment. A list of these incidents is included in Appendix A of the Incident Reporting and Investigation Procedure 9.4 Injury Definitions The following are definitions regarding the severity of injuries. Loss Time Injury (LTI) A work related injury or illness resulting in the employee being unable to attend their next rostered day after the day of the injury. Restricted Work Injury (RWI) A work related injury or illness which results in the employee being unable to perform one or more of their routine functions, or from working the full day on or after the next calendar day after the illness or injury. Medically Treated Injury (MTI) A work related illness or injury resulting in the management or care of a patient to combat disease or disorder, including any loss of consciousness. MTI does not include: visits to the physician or other licensed health care professionals solely for observation or counselling; 19 of 38

20 First Aid Injury the conduct of diagnostic Procedures, such as X-rays and blood tests, including the administration of prescribed medications used solely for diagnostic purposes (e.g. eye drops to dilate pupils etc.); and First aid cases. A work related injury or illness that requires first aid treatment but not medical treatment. Note: Any LTI, RWI or MTI is a reportable injury and must be reported appropriately to both the Department of Trade and Investment and Cristal Global. 10. INSPECTIONS, AUDITING, MONITORING AND REVIEW Cristal shall conduct regular workplace inspections in accordance with the Workplace Inspections procedure and maintain a schedule of the workplace inspections to be conducted and who is responsible for carrying them out. The Workplace Inspections Procedure and Area (housekeeping) inspections form are available via SmartSolve. The corrective actions proposed shall be entered into the company s action tracking system (Accstat) for follow up Inspection and Testing Cristal shall ensure that procedures for planning and conducting inspections of plant, equipment and processes including incoming materials and products and use only suitably qualified and competent workers to carry out inspection and testing. Site records are to be maintained of inspections and testing. Cristal shall conduct regular inspections in accordance with company and legislative requirements on (but not limited to) the following: Plant and equipment; Electrical installations and electrical equipment; Rigging and lifting equipment; Ladders and access equipment; Scaffolding; and Cranes, light vehicles, elevating work platforms and mobile plant HSE Management System and Compliance Auditing Cristal shall conduct regular audits and workplace monitoring to verify compliance with company statutory requirements either directly or by independent 3rd party process HSE Audits Cristal shall ensure HSE compliance audits are undertaken to provide verification of the implementation and effectiveness of the HSE Management System HSE Review Cristal shall conduct regular internal HSE reviews, which shall include results of audits and workplace inspections. Cristal shall: 20 of 38

21 Conduct internal HSE reviews at on a regular basis with representation from senior management at each review session; Maintain records of HSE management system reviews; and Ensure corrective actions are allocated to a responsible person, documented, implemented, monitored and closed out. 11. Fitness for Work Cristal shall establish procedures and processes for ensuring and monitoring personnel s fitness for work. The fitness for work program shall consider the possible health effects of: general level of personal fitness and/or pre-existing medical conditions; consumption of alcohol; use of other drugs (prescription, pharmaceutical or illegal); Fatigue and stress Drugs and Alcohol Cristal has a zero tolerance approach to drugs and alcohol in the workplace. Cristal has a rigorous drug and alcohol testing regime which included pre-employment testing, blanket and random on site testing, post incident and for cause testing. This testing regime is designed to minimise the risks to health and safety in the workplace due to the effects from drugs and alcohol. The use of prescribed drugs also shall be reported to the worker s supervisor so that a fitness for work assessment can be undertaken and the medication be recorded on a confidential medical report for use in the event of an emergency. Persons found in the possession of, or under the influence of alcohol or non-prescription drugs at the work site (excluding the Mine site Camp / accommodation area), will be subjected to the company s counselling and disciplinary procedures. Further information on Drugs and Alcohol can be found in the company s Drug and Alcohol procedure Fatigue and Working Hours Cristal has established a Fatigue Management Plan and Procedure on Working Hours to assist in managing the risks associated with fatigue. The Fatigue Management Plan was developed from industry advisory guidelines and documents information on fatigue, how to manage fatigue, roster design and rest periods. The Fatigue Management Plan and Working Hours Procedure can be found on SmartSolve Employee Assistance Program (EAP) Cristal has established an Employee Assistance Program that is available to all workers via telephone The anonymous service has been established to assist personnel with a variety of issues that they may face including (but not limited to) the following: Relationship and family problems Grief and loss Conflict with fellow workers Workplace issues Gambling Alcohol and Drug use 21 of 38

22 Stress and Emotional Distress Hygiene Cristal shall ensure that its personnel and subcontractors personnel maintain high standards of hygiene in the workplace. Cristal shall maintain all crib rooms and work areas in a clean and tidy state and shall promptly and appropriately dispose of waste material. Suitable washing facilities are provided at various places throughout the workplace Noise and Vibration Cristal shall manage the risk of exposure to noise and vibration hazards in accordance with current safety legislation and shall include scheduled periodic surveys of noise exposure Dust, Fumes, Mists, Gases and Vapours Cristal shall ensure exposure to dust, fumes, mists, gases and vapours is as low as reasonably achievable and in compliance with regulatory requirements. Respiratory protection shall comply with Australian Standards AS1715 Selection Use and Maintenance of Respiratory Protective Devices and persons shall be trained and assessed in the safe use, care and maintenance of respiratory protection. Respiratory protection shall be worn in designated areas Chemicals and Hazardous Materials Any chemicals or hazardous materials shall be risk assessed prior to procurement or entry onto site. Consideration should always be given to substituting the chemical or hazardous material for a less hazardous substance. No chemicals or hazardous materials are to be brought onto site without a Material Safety Data Sheet. Cristal shall ensure that personnel are trained in the use and understanding Material Safety Data Sheets Radiation Cristal shall ensure work involving the use of radiation sources and radioactive materials are controlled in accordance with ARPANSA - Regulation: Regulatory Guides and the Radiation Management Plan available via SmartSolve Under no circumstances shall untrained or unauthorised persons attempt to remove, or in any way interfere with, radioactive sources or carry out any maintenance, adjustment or modifications to controlled radiation apparatus or remove any pipe work which has a radiation gauge mounted or attached. Cristal shall ensure that a Radiation Safety Officer is appointed and that all workers receive a briefing on working with Naturally Occurring Radioactive Materials (NORMs) / Mineral Sands and general radiation safety Smoking Personnel shall not smoke in any vehicle, enclosed building nor in hazardous work areas that shall pose a health or safety risk. All smoking areas are to be left in a clean and tidy state and all butts placed in appropriate disposal containers. 22 of 38

23 11.9 Sun Protection and Awareness Cristal shall have an active program for prevention of sun exposure and heat related illness. This shall include but not be limited to: provision of factor 30+ sunscreen; acclimatisation (both heat and cold); requirement for all personnel to wear suitable clothing and a hat in strong sunlight; provision of ample drinking water at all times; and provision for shade in open areas 12. SAFETY STANDARDS Cristal shall maintain the following work area health and safety standards as a minimum requirement. Each of the subjects below has more information and specific detail documented in procedures that can be found on SmartSolve Subcontracting and Purchasing Cristal shall ensure that all plant, materials, equipment services purchased or hired and all subcontracts conform to the required legislative and HSE requirements. All procurement and subcontracting is managed by the Commercial Management Plan that can be found on the Cristal intranet. As a minimum, Cristal shall ensure: All materials, equipment, plant and services to be purchased or hired are assessed against the relevant legislative and HSE requirements; Procedures are implemented addressing the delivery, handling, storage and disposal of hazardous substances; Subcontractors are assessed for suitability and display and maintain at least a compatible Safety Management System as required of the contractor or work directly under Cristal s HSE Management System; Monitor and document HSE performance of subcontractors whilst on site for compliance Handling, Storage, Packaging and Delivery Cristal shall establish procedures to ensure compliance with legislative requirements for handling, storage, packaging and delivery of products and materials. Cristal shall: Implement a procedure for the storage, labelling and use of hazardous substances which shall include a register, MSDS file; Screen new products and plant prior to entry onto site for HSE hazards; and Ensure all vehicle, plant and equipment operators are correctly instructed, trained and certified/licensed 12.3 Manual Handling Cristal shall ensure that manual handling hazards are identified and managed in accordance with company requirements and relevant Codes of Practice for Manual Handling. All workers are encouraged to report manual handling hazards. Cristal shall implement a manual handling awareness and training for personnel and ensure as far as practicable that mechanical means are substituted for applicable manual handling tasks. 23 of 38

24 12.4 Confined Space Entry Cristal shall ensure that all confined spaces on site are appropriately signed and documented on a Confined Space Register. All training; control and associated activities comply with the requirements of AS/NZS 2865-Safe Working in a Confined Space, relevant legislation and company requirements documented on the Confined Space procedure. A Confined Space Entry Permit shall be completed prior to entry into any confined space Isolations and Tagging Isolations and tagging on site shall be in accordance with the Isolation and Tagging Procedure. Specifically, prior to any person conduction work on equipment that if started, energised or made operational, poses a risk to themselves or others, must isolate and tag the equipment prior to commencing work 12.6 Housekeeping Cristal shall incorporate the housekeeping function into all processes, operations and tasks to ensure housekeeping is an integral part of its processes. Material stored in open areas shall be stored in a tidy manner and in appropriate containers. Aisles, walkways, corridors, doorways, entrances, exits, etc., shall be unobstructed, free from slippery hazards and the accumulation of combustible materials. Waste material and rubbish shall be removed from job site areas, on a continuous basis so as to prevent a build-up of rubbish and construction waste Excavations Cristal shall ensure that excavations (other than specific mining excavations) on site are carried out in accordance with conditions as specifically details in the Excavation Procedure and an Excavation Permit must be raised prior to the commencement of the excavation Barricading Barricading shall be erected and maintained around work areas where segregation, delineation or protection of works is required. Other points of note; excavations and areas where the risk of a fall exists are to be hard barricaded to prevent persons from falling; bunting shall only be used as a last resort for minor short term temporary works such as identifying the slew radius of a crane or identifying hot work above areas; appropriate signage and information tags shall always be used with all barricades and bunting; and workers are responsible for the daily maintenance and removal of all barriers 12.9 Grid Mesh, Flooring and Handrail Removal All grid mesh and flooring removal shall be performed in accordance with the Grid Mesh and Flooring removal procedure. Specifically, physical barricades must be erected prior to removal of flooring as to prevent any inadvertent access / falling through the open floor or penetration. Persons removing the flooring or handrails must be wearing the appropriate fall restraint equipment Working at Heights Where personnel are at risk of falling from height or being at risk from falling objects, effective measures must be taken to prevent the potential of injury or damage. All work at heights shall comply with relevant legislation and company requirements. 24 of 38

25 Persons who are exposed to the risk of falling shall: Participate in the risk assessment of the work. Know and understand the control measures for fall and falling objects prevention. Be competent and authorised in the correct use and application of control measures. Be medically fit to work at heights. Inform their supervisor if they have any medical condition (permanent or temporary) that may adversely affect their competency to work safely at height. Effective control measures include: Eliminating the need for working at height by conducting the task on the ground if possible. The provision of edge protection (guardrails) systems. Fall prevention injury prevention systems. The use of scaffolding and/or elevated work platforms to access work areas. A working at height s permit system. Training personnel who work at heights in the requirements of safe working at height practices. Providing personnel with appropriate equipment and PPE for the task to be conducted. The Hierarchy of Controls shall be used when considering any work methods and controls for working at height. In all cases where the use of PPE is considered appropriate, fall restraint shall be considered as the preferred option rather than fall arrest Scaffolds and Scaffolding Cristal shall ensure that all Scaffolding erection and dismantling complies with the requirements of AS1576 Scaffolding and AS4576 Guidelines for Scaffolding and company procedures. Scaffolding shall be controlled using the scaff-tag system and shall be inspected by a competent person and recorded in a scaffold register. Scaffold erection and dismantling shall only be carried out by certified competent scaffolders Man cages / Workbox All workboxes ( dogboxes ) comply with AS Design and Construction of Workboxes. A Man Cage Permit must also be completed prior to use Ladders, Fixed and Portable Ladders are to be used primarily as a means of access and egress to an area. All ladders must comply with the relevant Australian Standard: fixed ladders shall comply with the requirements of Australian Standard AS1657 Fixed Platforms, Walkways, Stairways and Ladders ; portable ladders (timber) shall comply with Australian Standard AS and AS Portable Timber Ladders (including step ladders and trestle ladders) ; and portable ladders (metal) shall comply with Australian Standard AS Portable Ladders Metal Cristal shall ensure portable ladders are regularly inspected by a competent person and documented on a register. Ladders are required to be inspected for damage and integrity prior to use on any task. Working from ladders shall comply with the following as a minimum acceptable standard: 25 of 38

26 personnel are not to be exposed to the risk of a fall from working off ladders; use of ladders as a working platform is restricted to minor maintenance or light work personnel working from ladders must maintain three (3) points of contact at all times and/or be physically restrained from the risk of a fall (i.e. fall restraint PPE); portable ladders when in use shall be secured, with rope or ladder clamps to prevent slipping or overbalancing; ladders shall always be placed on a firm, stable footing to prevent the ladder feet from moving unexpectedly; portable ladders shall be placed on a substantial base at a 1:4 pitch, have a clear access top and bottom and extend a minimum of one (1) metre above the egress landing; and portable metal ladders and wire-reinforced ladders shall not be used for any electrical work or where contact with electrical conductors is foreseeable Fire Protection Cristal shall supply, install, and maintain adequate portable fire extinguishers in workshops, site offices, plant, equipment, vehicles, and flammable storage areas. Cristal shall ensure that all workers are instructed in the basic inspection, safe use and operation of all relevant fire extinguishers types. Cristal shall maintain records of inspection and maintenance of fire extinguishers for audit purposes. Cristal shall ensure sufficient supply and regular maintenance of fire extinguishers is carried out in accordance with the Australian Standards listed in Table SAFETY STANDARDS VEHICLES AND MOBILE PLANT Cristal shall ensure that the vehicles it uses on site are licensed, maintained in a roadworthy condition and mechanically inspected by a trained and certified competent person. All vehicles and mobile plant on site must conform to Cristal s Vehicle and Mobile Equipment Standard. Specifically: Light vehicles must be 4WD (exemption at MSP) Prestart checks must be conducted on work site vehicles daily Light vehicles must be fitted with: Flashing light High visibility flag on pole Seat belts Horn Reverse alarms Fire extinguishers First aid kits Breakdown equipment for off lease use Cargo Barriers &/or load restraints The operation of vehicles must comply with site traffic plans 26 of 38