ENVIRONMENT MANAGEMENT PLAN

HEALTH SAFETY AND ENVIRONMENT MANAGEMENT PLAN

HEALTH SAFETY AND ENVIRONMENT MANAGEMENT PLAN DOCUMENT No.: PL01 DATE 19/02/2012 DOCUMENT TYPE : Plan TOTAL PAGES : 48 APPROVED: Craig Dunlop AMENDMENT DATE DESCRIPTION OF AMENDMENT REVIEWED APPROVED Page Rev.

HEALTH SAFETY AND ENVIRONMENT MANAGEMENT PLAN INDEX SECTION 1 INTRODUCTION... 1 OBJECTIVES... 1 RELATED DOCUMENTS... 1 ACTS REGULATIONS AND STANDARDS... 2 SECTION 2 SAFETY AND HEALTH PHILOSOPHY... 3 2.1 VISION STATEMENT... 3 2.2 HEALTH AND SAFETY POLICY... 3 2.3 ENVIRONMENTAL POLICY... 4 2.4 ACCIDENT PREVENTION AND REHABILITATION POLICY... 5 SECTION 3 ADMINISTRATION... 6 3.1 MANAGEMENT STRUCTURE... 6 3.2 RESPONSIBILITIES.... 7 3.2.1 Managing Director... 7 3.2.2 Operations Manager... 7 3.2.3 Maintenance Manager... 8 3.2.4 Supervisors... 8 3.2.5 Drillers... 10 3.2.6 Other Employees... 10 3.2.7 Subcontractors... 11 3.3 DOCUMENT CONTROL... 11 3.3.1 Document Identification and Preparation... 11 3.3.2 Documents of External Origin... 12 3.3.3 Controlled Documents... 12 3.3.4 Site Specific Documents... 12 3.3.5 Document Revision... 12 3.3.6 Obsolete Documents... 13 3.4 HEALTH AND SAFETY COMMITTEE MEETINGS AND COMMUNICATION SESSIONS... 14 3.4.1 Safety Committee... 14 3.4.2 Safety Committee Meetings... 14 3.4.3 Site Safety and Tool Box Meetings... 15 3.4.4 Site Prestart Meetings... 15 3.5 REPORTING... 16 3.6 ACCIDENT AND INCIDENT INVESTIGATION... 17 3.6.1 Root Cause... 17 3.6.2 Suggested Remedies or Risk Controls... 17 3.7 HAZARD ASSESSMENT AND RISK EVALUATION... 18 3.7.1 Risk Register... 18 3.7.2 Risk Analysis and Evaluation... 19 3.8 CONTROLLING RISKS... 19 3.8.1 Traffic Management... 19 3.8.2 Safe Work Procedures... 20 3.8.3 Job Safety Analysis... 20 3.8.4 Work Permit System... 20 3.9 DRILL RIG, PLANT AND EQUIPMENT... 21 3.9.1 Element Drilling Standards and Procedures... 21 3.9.2 Equipment Procurement... 22 3.9.3 Equipment and Vehicle Prestart Checks and Inspections... 22 3.9.4 Certified or Registered Plant... 22 3.9.5 Equipment Maintenance... 23 3.9.6 Equipment Documents and Records... 23 3.10 INSPECTIONS AND AUDITS... 23 3.10.1 Procedure... 23 3.11 TAGGING AND ISOLATION... 24 3.11.1 Isolation... 24 3.11.2 Danger Tags... 24 3.11.3 Out of Service Tag... 25 3.11.3 De-Isolation... 25

HEALTH SAFETY AND ENVIRONMENT MANAGEMENT PLAN SECTION 4 MANAGEMENT OF CHANGE... 26 4.1 INTRODUCTION... 26 4.2 CHANGE OF PLANT OR EQUIPMENT... 26 4.2.1 New Equipment... 26 4.2.2 Alterations to Plant or Equipment... 27 4.2.3 New or Altered Procedures... 27 4.2.4 Changes to Personnel... 27 4.2.5 New Substances or Chemicals... 27 SECTION 5 PERSONNEL... 28 5.1 EMPLOYMENT... 28 5.1.1 Application for Employment... 28 5.1.2 Pre Employment Checks and Medicals... 28 5.1.3 Conditions of Employment... 28 5.1.4 Employee Assessments... 28 5.1.5 Health Surveillance... 29 5.2 TRAINING... 29 General... 29 5.2.1 Induction... 30 5.2.2 Workplace Training... 30 5.2.3 External Training... 30 5.2.4 Employee Training Needs Assessment... 31 5.3 INJURY MANAGEMENT AND REHABILITATION PROGRAM... 31 5.3.1 ACCIDENT PREVENTION AND REHABILITATION POLICY... 31 5.3.2 ACCIDENT PREVENTION AND REHABILITATION PROCEDURES... 31 5.4 FIT TO WORK... 32 5.4.1 Alcohol and Drug Testing... 32 SECTION 6 - ENVIRONMENT... 33 6.1 ENVIRONMENTAL POLICY... 33 6.2 HYDROCARBON PRODUCTS MANAGEMENT PLAN... 34 6.2.1 Diesel Fuel... 34 6.2.2 Lubricating Oils... 34 6.3 TRAVELLING... 34 6.4 DRILLING OPERATIONS... 35 6.5 WORKSHOPS... 36 6.6 RECYCLING... 36 6.7 CAMPSITES... 36 6.8 PREVENTING BUSH FIRES... 37 SECTION 7 EMERGENCY RESPONSE PLAN... 38 7.1 EMERGENCY COMMUNICATION... 38 7.2 SITE OR DISTRICT EMERGENCY RESPONSE PLANS... 38 7.3 FIRE PROTECTION AND RESPONSE... 38 7.3.1 Fire Prevention and Protection... 38 7.3.2 Fighting Bush Fires... 39 7.4 EMERGENCIES INVOLVING ACCIDENTS AND INJURIES... 39 7.5 MEDIA LIAISON... 39 7.6 TRAUMA MANAGEMENT... 39 SECTION 8 INDUSTRIAL HYGIENE... 40 8.1 PERSONAL PROTECTIVE EQUIPMENT... 40 8.2 CHEMICAL MANAGEMENT... 40 8.3 HEALTH SURVEYS... 40 8.4 SMOKING POLICY... 41 8.4 HEARING PROTECTION... 41 8.4.1 Identification of Noise Hazard... 41 8.4.2 Minimisation of Risk of Hearing Loss... 42 8.5 PERSONAL HYGIENE... 42 Refer to the Safety Manual and Induction PowerPoint training material.... 42

HEALTH SAFETY AND ENVIRONMENT MANAGEMENT PLAN APPENDIX A RISK MATRIX... 43

HEALTH SAFETY AND ENVIRONMENT (HSE) MANAGEMENT PLAN SECTION 1 INTRODUCTION This safety and health management plan outlines how Element Drilling will: 1. provide a safe workplace for their employees, subcontractors, visitors and other people who might be affected by their operations. 2. prevent damage to the environment. 3. respond to an emergency. In preparing our Safety Management Plan Element Drilling has endeavoured to provide an easy to follow system that covers all of their systems of work, policies, standards, safe working procedures and other measures designed to minimise risk of injury, damage or loss in the workplace. This plan must be supplemented by a site specific safety management and emergency response plan. This Safety Management Plan is continually under review and is subject to amendment on a continuous basis. OBJECTIVES The Safety and Health Objectives are: A Lost Time Injury Frequency Rate (LTIFR) of Zero. The continual total compliance with Legislation, Codes of Practice and Australian Standards. To continually improve work practices and safe work procedures. To provide a safe workplace. To reduce workers compensation insurance costs. RELATED DOCUMENTS Element Drilling s Policies Safety Induction Manual Safety Induction PowerPoint Presentation Safety Matrix Safe Work Procedures Risk Register Standards Manual Page 1

ACTS REGULATIONS AND STANDARDS A The following Australian Standards apply to this document: AS/NZS 4801: 2001 : Occupational health and safety management systems - Specification with guidance for use. AS/NZS 4804: 2001 : Occupational health and safety management systems - General guidelines on principles, systems and supporting techniques. AS/NZS ISO 31000:2009 Risk Management AS 1885.1: 1990: Measurement of occupational health and safety performance - Describing and reporting occupational injuries and disease (known as the National Standard for workplace injury and disease recording) B C The following Acts and Regulations apply to this document: Western Australian Mines Safety and Inspection Act and Regulations Occupational Health and Safety Act and Regulations. Workers Compensation and Rehabilitation Act and Regulations Environmental Protection Act and Regulations For other Acts, Regulations Standards and Guidelines relating to specific procedures refer to Element Drilling s Standards Manual. All the above are to be readily available for all employees and contractors of Element Drilling. Page 2

SECTION 2 SAFETY AND HEALTH PHILOSOPHY 2.1 VISION STATEMENT The vision of Element Drilling is to achieve the highest level practicable for safety and health and to be considered as the leader in the drilling industry. 2.2 HEALTH AND SAFETY POLICY Element Drilling is dedicated to the protection of the safety and health of all employees, contractors and visitors by providing a safe workplace with zero lost time injuries. To accomplish this goal management will: Provide competent supervision Promote an environment in which safety and health is considered to be part of the normal work environment Foster co-operation, participation and consultation with employees and clients in the formation of plans aimed at minimising the risk of injury or illness due to workplace hazards Provide adequate resources to develop, implement and maintain a safe working environment, safety awareness, education and training Abide by all statutory acts and regulations as our minimum standard Regularly review safety and health programs and procedures to enable continual improvement All employees have a responsibility to: Take reasonable care for their own well being and that of others To work in a safe and healthy manner To comply with safety and health instructions issued by the company or by clients To report immediately any incident, injury or workplace hazard To be actively involved in the continued development, implementation and management of the organisations Safety and Health management Safety and Health is seen as individual and shared responsibility and it is up to everyone within the company to participate and co-operate with this policy to ensure its success Cooperation and consultation with employees is a key factor to achieve these objectives.. Craig Dunlop Managing Director Issued: 24/10/2005 Last Reviewed: May 2012 Review Date: May 2013 Page 3

2.3 ENVIRONMENTAL POLICY ELEMENT DRILLING Element Drilling is committed to the minimisation of short-term effects and the elimination of long-term effects on the environment due to our drilling activities. To enable this, Element Drilling will ensure that: All statutory requirements that relate to the environment will be observed Basic and practical procedures and practices are to be adopted at all times Any incident that could have or has the potential to cause damage to the environment will be reported All client requirements will be complied with This policy applies to all employees and contractors to Element Drilling... Craig Dunlop Managing Director Issued: 17/10/2006 Last Reviewed: May 2012 Review Date: May 2013 Page 4

2.4 ACCIDENT PREVENTION AND REHABILITATION POLICY The management of Element Drilling recognises that the Safety and Health of its employees and contractors is of the utmost importance. To ensure this: Every practicable method to eliminate potential causes of accidents will be used Supervisory personnel are to ensure safe work practices and conditions are maintained Prompt reporting of occurrences such as near misses, environmental, personal injury and equipment damage Employees are encouraged to contribute by way of suggestion which could result in safer work practices All accidents will be investigated and a report compiled In the event of injury to personnel, Element Drilling will make every practicable effort to rehabilitate that person back to their pre-injury work as a minimum. It is the policy of Element Drilling to provide the resources to ensure: All employees who have been injured in the course of their work receive competent medical care and attention That there are alternative duties to enable gradual return to work programs Management support in the form of employee interaction... Craig Dunlop Managing Director Issued: 17/10/2006 Last Reviewed: May 2012 Review Date: May 2013 Page 5

HEALTH SAFETY AND ENVIRONMENT MANAGEMENT PLAN SECTION 3 ADMINISTRATION 3.1 MANAGEMENT STRUCTURE MANAGER (OPERATIONS AND MAINTENANCE MANAGER) (SUPERVISOR) SENIOR DRILLER DRILLERS TRAINEE DRILLERS DRILLER S ASSISTANTS UTILITY WORKERS Page 6

3.2 RESPONSIBILITIES. 3.2.1 Manager Provide adequate human and financial resources to meet the requirements of the Safety Management Plan. Monitor activities within the Health Safety and Environment Management Plan and demand adequate and timely reporting by employees. Assist in the preparation and review of the Health Safety and Environment Management Plan. Keep informed of current legislation and codes of practice applicable to the work carried out by Element Drilling. Ensure that all employees, contractors, and visitors are made aware of the company s commitment to provide a safe and healthy workplace. Chair meetings of the Health and Safety Committee. In the event of being unavailable to chair a schedule meeting, appoint a chair person from senior staff. Facilitate the election of a safety representative if requested by employees and provided for by legislation. 3.2.2 Operations Manager Be satisfied as to the competency of their staff. Ensure adequate investigation of all work processes prior to the commencement of work. Keep informed of current legislation and codes of practice applicable to the work carried out under their control. Participate in accident and incident investigations and prioritise action on implementing controls based on the category of the event and taking into consideration the hierarchy of control. Be involved in the effective activities of the Health and Safety Committee meetings. Consult and cooperate with the elected Safety and Health Representative in all matters related to Occupational Health and Safety. Resolve safety issues in a manner that maintains industrial harmony and that complies with legislation. Prepare reports as required by Regulatory Authorities. Page 7

Ensure the Managing Director is kept properly informed of such matters to enable him to discharge his responsibilities as listed above. Review performance with the Safety Officer. Carry out inspections of workplaces under their control. Review accident / incident statistics and any relevant safety reports. Ensure Subcontractors comply with the Health Safety Environment Management Plan. Review Subcontractor s safety performance. 3.2.3 Maintenance Manager Be satisfied as to the competency of their staff. Conduct weekly safety meeting with office staff Ensure adequate investigation of all work processes prior to the commencement of work. Ensure adequate investigation of all work processes carried out under their control prior to the commencement of work. Ensure they are fit for work and not affected by alcohol or drugs in such a manner as to endanger their own or others health and safety or the environment. Keep informed of current legislation and codes of practice applicable to the work carried out under their control. Resolve safety issues in a manner that maintains industrial harmony and that complies with legislation. Ensure Maintenance Subcontractors comply with the Health Safety Environment Management Plan. Carry out inspections of workplaces under their control. Ensure machinery is in a safe condition. Keep maintenance records. Participate in investigations of accidents or incidents involving machinery or plant and give advice on implementing controls based on the category of the event and taking into consideration the hierarchy of control. 3.2.4 Supervisors Ensure they are fit for work and not affected by alcohol or drugs in such a manner as to endanger their own or others health and safety or the environment. Page 8

Ensure all employees and contractors are inducted and receive training as appropriate to perform activities safely Assist in the training of drill crews so that they are competent to carry out their allocated tasks. Conduct safety and toolbox training sessions on a regular basis. Record positive and negative safety performance of personnel under their control. Ensure that properly maintained plant and equipment is made available to enable operations to be carried out safely. To ensure that all necessary items brought up at Safety Meetings that are delegated to the supervisor are dealt with in a reasonable time. To ensure all necessary registers are maintained. To comply with the reporting requirements of the Health Safety Environment Management Plan To ensure the competency of drill crew to carry out tasks required as a part of their duties. To be aware of existing legislation, codes of practice and company safety procedures, and to consult with the Safety Officer in respect of any safety issues. Implement the SHE policies, procedures and legislative requirements To ensure the compliance of all employees in relation to their duty of care. Monitor compliance of Subcontractors to the Health Safety Environment Management Plan. Ensure the Manager kept properly informed of such matters to enable the Manager to discharge their responsibilities listed above. Review performance with the Safety Consultant and inspect all company workplaces from time to time. Review sub contractors safety performance. Monitor SHE performance within their area of responsibility Demonstrate commitment to SHE through participation in formal and informal discussions, workplace visits, hazard inspections, etc. Participate, where required, in the resolution of safety issues Investigate all accidents/incidents within their area of responsibility Review any SHE reports and take appropriate action Page 9

Participate in SHE committees as and when required Ensure liaison with employee representatives for SHE, particularly for any workplace changes which may effect SHE Actively monitor the workplace to determine the presence of hazards and take appropriate action to rectify the hazards detected Initiate actions to improve SHE Facilitate rehabilitation of injured employees 3.2.5 Drillers Are to be familiar with and have an understanding of the Health Safety Environment Management Plan. To enforce and ensure compliance of all Element Drilling s safety rules and regulations and site-specific requirements. If working with Subcontractors, they are to ensure that they comply with Element Drilling s Safety Policy, Plans, Procedures and Regulations along with site specific requirements. To ensure Offsiders Drill Assistants and Trainee Drillers and those working under their control comply with all Safety Policies, Plans, Procedures and Regulations. To assist the Safety Representative, Safety Consultant and Supervisors with investigation of all accidents, incidents and near misses. Conduct or participate in Toolbox Meetings. Ensure they discharge their job in accordance with the Statute Acts, Regulations, Company Policies, Plans and Safe Working Procedures. Ensure all equipment in their care, custody or control is properly maintained in a safe condition before operating or using that equipment. Ensure they are fit for work and not affected by alcohol or drugs in such a manner as to endanger their own or others health and safety or the environment. Cooperate at all times with any contractual arrangements Element Drilling has agreed with the client. 3.2.6 Other Employees Ensure they are fit for work and not affected by alcohol or drugs in such a manner as to endanger their own or others health and safety or the environment. Page 10

Every employee has a legal responsibility to take responsible care for the safety and health of themselves and others that may be affected by their acts or omissions. Must cooperate with arrangements made for the provision of any training activities. No employee shall intentionally or recklessly interfere with or misuse any equipment provided for the safety or welfare of personnel. All employees are asked to provide input at safety meetings with regards to improving safety at work sites. All employees must report all accidents, incidents and hazards on the day of occurrence to enable investigation to proceed promptly to prevent a re-occurrence. All employees are to tag out any faulty equipment and report the problem to a Supervisor so that maintenance can be carried out. All employees are to correctly maintain their Personal Protective Equipment. Cooperate at all times with any contractual arrangements Element Drilling has agreed with the client. 3.2.7 Subcontractors Must adhere to Element Drilling s Safety and Health Policy for the prevention of accidents and incidents. Must be aware of and comply with the Health Safety Environment Management Plan Report all accidents, incidents and hazards to Element Drilling s supervisor or Participate in safety at Toolbox Meetings Safety Meetings conducted by Element Drilling. 3.3 DOCUMENT CONTROL Document control will ensure That the pertinent issues of appropriate documents and data are available at the locations where the information is required Invalid or obsolete documents are promptly removed from use or suitably identified to preclude unintended use Authorised personnel shall review changes to documents and/or data. 3.3.1 Document Identification and Preparation Page 11

All procedures, safe work procedures (SWP), standards, accident and incident and hazard reports shall be allocated with a unique identifier. All accident and incident forms will be numbered Personnel wishing to prepare new documents shall request the next available identifier from the document controller, providing a description of the document and its topic. All controlled documents will be registered, ensuring that their document number, title, dates, is recorded in the document register by the document controller. 3.3.2 Documents of External Origin Documents of external origin referred to in Element Drilling certified systems will be registered ensuring that their number, title and recipient are detailed. Any controlled documents of external origin, which are identified as obsolete, will be destroyed when replaced with the current issue. 3.3.3 Controlled Documents All controlled documents will be kept in a folder on the main computer. Any printed copies of controlled documents or copies of controlled documents from other sources are classified as uncontrolled.. 3.3.4 Site Specific Documents Any document modified to cover conditions specific to an individual site or created in compliance with SHE or Quality systems for use exclusively on that site, shall be controlled by the controller using a register set up for that site. A copy will be sent to the Manager for filing separate to controlled documents. This may include:- work instructions JSA s Risk Assessments Site Specific Plans Site Emergency plans 3.3.5 Document Revision Hand written amendments are permitted if the amendment had been signed by the relevant authority for that particular document Requests for amendments to documents shall be made in writing either by describing the changes or by marking up the changes on a copy of the document (preferred method) The amended document shall have its revision status increased and may be distributed to appropriate reviewers for review and comment in draft form. A Revisions Register shall identify the last only revision/s made to the document. This register is in the front of some documents and in the controlled document register. Page 12

3.3.6 Obsolete Documents An electronic copy of obsolete documents shall be stored in an obsolete document directory. The entry in the Document Database will checked as obsolete. The date the document was made obsolete to be added as an extension to the name of the old document. For example if the document FormY became obsolete on the 27/02/2009 it will be renamed FormY20090227. Page 13

3.4 HEALTH AND SAFETY COMMITTEE MEETINGS AND COMMUNICATION SESSIONS 3.4.1 Safety Committee The safety committee will consist of the Managing Director, and Safety Representatives or persons appointed by employees to represent them on the committee. A forum for a meeting will consist of a minimum of 2 members. Where practical, 50% of the members should be safety Representatives or representatives of employees. Voting on issues will be done so that Safety Representatives or persons appointed by employees will have 50% of the votes. Resolution of any disputes will be done according to the relevant legislation. Matters to be discussed and approved by the committee include: Review identified hazards in the work place, make recommendations and where necessary and take steps to limit employee s exposure to hazards. Review new risks that have been added to the risk register. Review and give recommendations on risk controls. Review accident / incident statistics and trends identified and make or endorse recommended action. Initiate, develop and implement measures to promote and maintain a safe working environment. Review and approve safe work procedures. Review and approve the Health Safety Environment Management Plan Review and approve site specific health safety and environment plans. Consider any proposed changes or intended changes to procedures, equipment or operations, which may affect Safety Health and Environmental issues. Make recommendations on any Safety and Health matters brought to its attention. 3.4.2 Safety Committee Meetings Safety committee meetings are held in the workplace quarterly, chaired by the Managing Director or a responsible person in his place if he is not available. An agenda is made prior to the meeting covering all aspects of the safety issues raised during the quarter. This agenda will have a general business section where any member can put forward any concerns they have regarding health safety and the environment. The agenda will be forwarded to all members prior to the meeting. It will detail the matters to be Page 14

discussed, who will attend, time, date and place of the meeting and have attached any documents to be reviewed prior to the meeting Minutes of meetings will be recorded and will include an action column indicating who will be responsible to action an item if further action is required. A copy of the minutes is to be posted on notice boards and each member of the committee will receive a copy. Minutes of the previous meeting will be tabled at each meeting and approved as a true record by members of the committee that were at that meeting. Any recommendation arising from the committee shall be made by consensus of members The meetings will be conducted in an orderly manner and the chairman can expel a member if they act in an abusive or disorderly manner. 3.4.3 Site Safety and Tool Box Meetings Communication sessions are held with all employees once a week. Sites include operating drilling sites, maintenance workshops and the administration office if applicable. All employees and subcontractors on a site are required to attend the weekly Safety and Toolbox Meetings. The following topics will be discussed at these meetings: Any accidents, incidents or hazards reported in the previous week. Outcomes and action taken to control hazards identified through events or observation by employees. Any serious event that has occurred in the industry. Any changes made to or new procedures, policies or standards. Any new equipment, substances or chemicals introduced to the site. Any changes to legislation, standards or codes of practice. 3.4.4 Site Prestart Meetings Prestart meetings are to be held on all drill sites and at the workshop. The following topics will be discussed at these meetings: Handover report from previous shift. Status of work carried out in the previous shift. Weather forecast for the coming shift. Work to be performed during the shift Any new equipment or substances to be used during the shift. Any tasks that could be hazardous and require a job safety analysis. Safe work procedures that could be used during the shift. Any other event that could occur during the shift that could affect the operations or safety of the crew. Page 15

3.5 REPORTING All accidents incidents and hazards must be reported. The initial report shall be verbal either direct or by telephone and then in writing using the appropriate Element Drilling s report forms. Refer to the Site Safety and Emergency Plans for specific reporting procedures for that site. In the case of a serious accident or incident, an accident causing an injury, an accident involving electricity or an uncontrolled release of flammable gases or a fire, the event must be reported immediately or as soon as possible. Work on the site must cease until the event has been investigated and the operations manager or client approves the restart of operations. Reports should supply the following information if known: Date & time the event occurred and date & time it was reported. Occurrence type Location of occurrence Environmental conditions at time of event. Tasks being performed when event occurred. Name, occupation, age, sex, date of birth and job experience, of person involved. Details of roster and shift duration of person involved. Nature of any injury or disease Mechanism of injury Body location of injury Breakdown agency Cause of accident What controls on the risk in the register broke down Preventative action proposed or taken Rehabilitation status of any injured persons What plant or equipment was involved Damage or loss caused by the event All accident and incident investigation reports are to be faxed or emailed to the main office as soon as practicable. Page 16

ELEMENT DRILLING 3.6 ACCIDENT AND INCIDENT INVESTIGATION All accidents and incidents will be investigated. In the case of a serious accident or incident, an accident causing an injury, an accident involving electricity or an uncontrolled release of flammable gases or a fire, the event must be investigated by a team consisting of manager, supervisor in charge and the safety representative or a representative of the employees. Minor accidents, incidents and hazards must be investigated by the supervisor in charge and the safety representative or a representative of the employees. Statements must be recorded and signed by any witnesses to the event. Results of all accident investigations must be tabled at the next Safety Committee meeting to determine any further action required. These investigations are designed to establish the root causes of the event to enable risk controls to be put in place to prevent further similar occurrences. 3.6.1 Root Cause Determine if it was caused by: equipment failure-overload-under design- wear worker fatigue inexperience bad training incorrect methods being used were standard Company practices used use of wrong tools bad machinery design bad house keeping not using proper safety and protective equipment lack of maintenance lack of regular safety checks operating environment 3.6.2 Suggested Remedies or Risk Controls Determine what has to be done to prevent a similar event: does the employees have to be retrained does the equipment need repairs does the equipment need redesigning do methods need altering Page 17

do the work safe practices need changing is additional equipment or tools required is additional protective safety equipment required can the operating environment be improved 3.7 HAZARD ASSESSMENT AND RISK EVALUATION The sources of risks to a company are: Commercial and legal relationships Economic circumstances Human behaviour Natural events Political circumstances Technology and technical issues Management activities and decisions Individual activities This section is mainly concerned with risks that involved the health, safety of people and the risks to the environment. 3.7.1 Risk Register The risk register has been prepared by assessing known risks and then updated from risked recognised through observation of members of staff, investigations of hazard, accident and incident reports and other events in similar industries. A risk register is to be maintained. Risks are to be evaluated from the consequence and likelihood of an event occurring using the risk matrix (Appendix A). The register will record the following information on risks Description of hazard involved Likelihood of the event occurring Consequence if the event occurred. The evaluated risk using the risk matrix (Appendix A) Risk controls put in place Procedures used to help control the risk Risk breakdown agency The residual likelihood of the event occurring after controls have been put in place. The residual consequence if the event occurred. Page 18

The residual risk. The date the risk was last reviewed. ELEMENT DRILLING 3.7.2 Risk Analysis and Evaluation The objectives of analysis are to separate the minor acceptable risks from the major risks, and to provide data to assist in the evaluation and treatment of risks. Risk analysis involves consideration of the sources of risk, their consequences and the likelihood that those consequences may occur. All known risks must be analysed and evaluated. The analysis should consider the range of potential consequences and how likely those consequences are to occur. To evaluate the risks, consequence and likelihood are combined to produce an estimated level of risk using the risk matrix in Appendix A. To analyse the residual risk, determine the existing controls and analyse risks in terms of consequence and likelihood in the context of those controls. The following is the priority of action to be taken after the risk has been evaluated: Extreme Risk - requires immediate action High Risk senior management attention needed Moderate Risk management responsibility must be specified Low Risk manage by routine procedures. 3.8 CONTROLLING RISKS After risks have been analysed and evaluated controls must be put in place to reduce the risk to an acceptable level. Control measures are to be implemented according to the hierarchy of control : Elimination Substitution. Engineering controls. Administrative (procedural) controls. Personal protective equipment. All risk controls must be included in the Risk Action Plan. 3.8.1 Traffic Management Personnel designated to control traffic must be trained in the process. Element Drilling will comply by the client s traffic management plan. Page 19

3.8.2 Safe Work Procedures Common tasks are analysed and safe work procedures are drawn up and included in Element Drilling Procedures Manual. These are controlled documents and must be reviewed at least once per year. 3.8.3 Job Safety Analysis Work tasks not covered in the Procedures Manual (safe work procedures) must be analysed for safety and evaluated for risks. Before commencing to do a job safety analysis, refer to Element Drilling Standards Manual to determine if any standard covers the task or aspects of the task. This must be considered when determining what hazard controls to put in place. From this analysis safe work procedures are agreed upon for the tasks involved. These tasks can only be carried out if the residual risk is low. Record the analysis on the form as shown in Appendix A unless requested by client to use their site form. A copy of these forms must be sent to the office administrator for filing. 3.8.4 Work Permit System There is a requirement to adopt permit systems in order to carry out selected tasks safely. These permits are designed to force a job safety analysis to be carried out before carrying out designated tasks that could be hazardous. These permits include: Excavations permit. Excavation permits are required at some sites where there is a risk of hitting buried cables, pipes, services or old workings. Hot work permit. Before any hot work is carried out in designated areas a hot work permit will have to be filled out and signed by the supervisor or his representative. Hot work includes welding, thermal or oxygen cutting, heating and other fire producing or spark producing operations that may increase the risk of fire or explosion. Areas requiring hot work permits include fuel and oil storage areas, within two metres of a fuel tank, other areas where it is not practicable to remove or clear combustible materials or in the vicinity of the Explosive Storage Facility. For at least 30 minutes after completion of the hot work task, the area is to be monitored to ensure there is no likelihood of a fire starting. On completion of the fire watch, the permit is to be signed and returned to the supervisor or officer in charge. It may be necessary to refer to the following safe work procedures SWP23 Oxy-Acetylene Cutting, SWP43 Drilling in Areas Containing Methane Gas, SWP78 Running Steel Casing Welded Joints Confined space permit Element Drilling Personnel are not required to carry out work in confined spaces and therefore will not be required to use these permits. Only people who have received confined space training can work in a confined space. Page 20

The following is for information so that employees are aware what a confined space is and for information only: This permit is designed to ensure the health and safety of any persons required to enter or work in a confined space. A person whose head, i.e. the breathing zone, or upper body is within a confined space is considered to have entered the confined space. Most confined spaces have one or more of the following characteristics: Limited or restricted access - making it difficult to enter with lifesaving equipment, or to rescue a worker, in the case of an emergency Are not designed for continuous worker occupancy; May contain known or potentially hazardous atmospheres too little or too much oxygen, or the presence of toxic or flammable substances; Where conditions of engulfment or entrapment, or any other recognised serious safety or health hazard, may exist or develop Confined spaces can include: Water or storage tanks Boilers or air receivers Degreasing pits Wells Excavation holes Refer to Australian Standard AS/NZS 2865:2009: Safe working in a confined space. When completing the confined space permit it might be necessary to refer to Element Drilling standard ST28 Respiratory Protection Respiratory Equipment, ST43 High Pressure Cleaning, ST13 Portable Electrical Equipment and Leads, ST20 Differential Level Fall Protection, ST21 Safety Harnesses Life Lines and Life Belts, ST25 Electric Welding, ST26 Barricades and Barricading, ST46 Isolation and Tag Out Power Corridor Permit. Before any drilling is carried out within 10 metres of a powerline (or a distance less than the height of the extremity of the mast), a powerline corridor permit must be filled out and signed by the supervisor, client or his representative or the operator of the powerline. Refer to standard ST54 Powerlines and Electrified Equipment and safe work procedure SWP77 Working Near Powerlines. 3.9 DRILL RIG, PLANT AND EQUIPMENT 3.9.1 Element Drilling Standards and Procedures Refer to Element Drilling standard Handrails ST1 Fork Lift Trucks ST4 Motor Vehicles and Rig Carriers ST8 Exposed Machinery Guarding ST10 Fixed Platforms, Walkways, Ladders and ST11 Lifting Equipment and Records ST31 Use of Vehicle Loading Cranes ST35 Machine Servicing in the Field Page 21

ST37 Basic Checks Before Starting Equipment ST38 Engine Shutdown Procedures ST46 Isolation and Tag Out SWP90 Operation of a Vehicle Loading Crane The tasks involved in operation plant and equipment are included in Element Drilling Safe Work Procedures. Employees must be trained in these procedures before operating plant or equipment. Specific training is also required for heavy vehicles, forklifts, and vehicle loading cranes. 3.9.2 Equipment Procurement Element Drilling is to ensure that machinery, plant and equipment is safe and without risks when used correctly according to the manufacturers operating instructions. This requires that the plant and equipment be checked by a competent person to ensure that the plant and equipment is manufactured to minimum Australian Standards and complies with any Legislation as well as being safe to use in its attended application. Refer to section 4.21 for management of change. 3.9.3 Equipment and Vehicle Prestart Checks and Inspections All equipment and vehicles must be checked before use. Prestart checklists must be completed at the beginning of each shift. A copy is to be emailed of faxed to the Maintenance Department and the Administrator. If they contain any safety issues, a copy must be sent to the safety consultant for advice or action. If, during the inspection any equipment faults or hazards are discovered the work will not commence until they have been made safe. Faulty equipment must not be used until it is repaired or replaced. Element Drilling has developed inspection forms for drill rigs, trucks, light vehicle and generator. These inspections report forms are to be used when formal weekly inspections are carried out. A copy of these inspection forms is to be returned to the main office for filing, and a copy must be kept on site for the mining company s auditing process until the client indicates they are no longer required (usually after the audit). 3.9.4 Certified or Registered Plant It is necessary to register some plant. The plant includes: 1. Pressure vessels categorized as hazard level A, B or C according to the criteria set out in AS 4343, and not serially produced as per Australian Standard AS2971:2007 - Serially produced pressure vessels. 2. Cranes over 10 metre tonnes Page 22

A plant book must be kept with registered plant. Details of the registration, any incidents involving the plant and any approved modifications to the plant must be entered into this book. The maintenance department must keep a copy of the details of registration on file. 3.9.5 Equipment Maintenance The Maintenance Manager must ensure that all vehicles, plant and equipment is maintained in a safe condition A maintenance schedule must be drawn up for all vehicles, plant and equipment. This schedule should be adhered to as close as possible. Inspection sheets must be checked each day to determine if any unscheduled maintenance or repairs are required. Maintenance schedules are to be reviewed annually or if a high or increased frequency of breakdowns occur with items of plant or vehicles. 3.9.6 Equipment Documents and Records The following documents and records must be kept in the workshop: Repair manuals for vehicles, plant and equipment. MSDS sheets for substances used in the workshop or while carrying out maintenance. Records of all maintenance carried out. Records of all repairs carried out. 3.10 INSPECTIONS AND AUDITS Refer to company standard ST29 Area Safety Inspections. Workplace inspections ensure that Element Drilling complies with its obligations to monitor the workplace on a regular basis to identify hidden and previously unforeseen hazards. 3.10.1 Procedure Training shall be provided for all personnel in the use of inspection procedures and refresher training shall be provided as required (i.e.: if changes are made or issues identified). As a guide formal internal workplace hazard inspections will occur as follows: 1. Drill Rigs and Site Workshops as directed by the client and/or company management but in any case minimum monthly 2. Production, Stores, Workshops and Site Offices as directed by company management and/or client but minimum is 3 monthly 3. Office Areas 6 monthly Completion of each inspection shall be recorded on these schedules and details distributed throughout all operations on a regular basis. Review A copy of the completed inspection checklist will be tabled at the safety committee meeting Page 23

The workplace inspection score and any outstanding risks assessed as Medium or greater will be recorded in an incident report. A yearly audit of the safety system shall be conducted by an outside safety contractor. All Element Drilling sub contractors are to assist the auditor if requested. Audit Systems are subject to regular Management Review. 3.11 TAGGING AND ISOLATION Refer to Element Drilling Standard ST46 Isolation and Tagout Refer also to Element Drilling Safety Manual Whenever employees could be in danger in the course of their work from the operation of machinery, electricity, gas or liquids, or the use of faulty equipment, employees must be protected by the use of isolation procedures including personal danger tags and locks. 3.11.1 Isolation To achieve positive isolation, all energy sources associated with the equipment or plant that is to be worked on will have been de-energised, tagged and locked at the required Isolation points. Those Isolation points will have each been isolated by an isolation device that prevents the energy source from being accidentally released, and the isolation will have been tested and proven. Positive Isolation shall remain in place as long as there are people potentially exposed to the hazard in the course of their work on the equipment or plant All isolation points on site will be uniquely and clearly identified. Isolation shall always be applied to the energy source and not rely on control circuitry. Push buttons, stop switches, interlocks, emergency stops, pilot circuitry, lanyards, etc shall not be used as a means of isolation. To achieve positive isolation the following steps shall be followed: Isolate (the energy source); Tag (to identify the isolation); Test (to prove the isolation is effective). All isolations shall be secured by means of a locking device at the isolation point. All locking devices will then have a padlock attached. 3.11.2 Danger Tags Danger tags are placed on the control or isolating point by the employee before work commences and removed by that employee when you finish work or leave the work area. If the employee leaves the work area before the repairs are complete, the danger tag must be replaced with an Out of Service Tag. Page 24

It is the employee s responsibility to place the danger tag and that person is the only person that can remove it. The employee must write their full name clearly on the tag. The only person permitted to remove a danger tag is the person who placed it. Under no circumstances can a control be operated if it has a Danger Tag or lock attached. When more than one person is working on the equipment, people must place their own tag and lock on the control or isolation point. Out of Service Tags must not be used as Danger Tags. If an employee accidentally remove or damage someone else s Danger Tag they must put one of their own tags on until they can inform that person and he/she replaces the tag. 3.11.3 Out of Service Tag Out of Service Tags are used to prevent the use of damaged equipment or equipment that could cause material damage or could cause harm to some one if used. The employee s name and reason for placing the tag must be clearly written on the tag. Equipment must not be operated when an Out of Service Tag is in place. An Out of Service Tag may only be removed by the person who placed the tag, or by a person qualified to repair the fault shown on the tag, or by the Supervisor after he has checked the reason for the tag. Before removing an Out of Service Tag, the authorised person will check that the equipment is in proper working order and that when operated it will not cause injury to persons or damage to plant. 3.11.3 De-Isolation De-isolation is the process of removing isolation from isolation points, and returning equipment to normal operation. The generic process of de-isolation involves: Verifying that work has been completed; Physically checking all Personal Danger Tags and Personal Locks have first been removed; Removing tags and Locks where applicable; Clearing the Permit of Isolation where applicable. In all cases, isolation point(s) may not be de-isolated until all Locks and Tags have been removed by persons authorised to do so. Page 25

HEALTH SAFETY AND ENVIRONMENT MANAGEMENT PLAN SECTION 4 MANAGEMENT OF CHANGE 4.1 INTRODUCTION Managing change is critical to preventing incidents and controlling loss. On occasion, temporary repairs, connections, bypasses, or other modifications may be made out of operating necessity. Any of these changes can introduce new hazards or compromise the safeguards built into the original design. Care must be taken to understand the operational, and personnel safety and environmental implications of any changes. Although some changes may be minor with little likelihood of compromising health, safety or environmental protection, many changes may have the potential for disruption, injury, or business loss. Some changes can cause occupational stress. Element Drilling will manage change effectively by assisting employees to understand the need for change through clear communication, justification for decisions, a shared vision for the future and transparency in the decision making process. All changes must be discussed at toolbox meetings before they are implemented. Any training required must be introduced before implementing the changes.. The Safety Committee must review these changes at a meeting preferably before they are introduced but if not, at the meeting immediately after the change. 4.2 CHANGE OF PLANT OR EQUIPMENT Plant or equipment changes, including the addition of new plant or equipment or modifications of existing plant or equipment. These can include changes in alarms, instrumentation, and control schemes. Before making changes or purchasing new equipment refer to Element Drilling Standards as listed in section 3.8.1 above and any relevant Australian Standard. These changes could be introduced to increase production or to increase the safety of the operators or drilling crew. They could be made as a result of new equipment being available or affordable or as a result of a hazard or risk analysis. 4.2.1 New Equipment Suppliers of equipment must supply operating instructions and indicate load or operational limitations. Safe work procedures must be prepared or reviewed taking into consideration these operating instructions and design parameters. A risk analysis must be conducted to assist in preparation or review of these procedures. Page 26

Employees must be trained in the use of this plant equipment before the commence operating the plant equipment. A maintenance schedule must be prepared for new plant or equipment if applicable. 4.2.2 Alterations to Plant or Equipment Substantial alterations to plant or equipment must be checked by a competent person to make sure the alterations do not reduce the safety of the plant or equipment. Special care must be taken when modifying the mast structure as it could downgrade the load carrying ability of the structure or allow accelerated corrosion to weaken structural members. A risk analysis must be conducted to assist in preparation or review of the procedures for the altered plant. Employees must be trained in any new or modified procedures before the commence operating the plant equipment. 4.2.3 New or Altered Procedures New or altered procedures must be sent to relevant sites and posted on notice boards. It is the responsibility of supervisors or managers to ensure all employees required to use these procedures are suitably trained and that they are discussed at toolbox meetings prior to their implementation. 4.2.4 Changes to Personnel New employees must be inducted to company rules, standards and procedures before they carry out any tasks. It is the responsibility of supervisors or managers to ensure all employees are suitably trained and suitable to become an effective team member. A meeting of the crew must be conducted before a new employee or new team member starts to work in that team. 4.2.5 New Substances or Chemicals Before any new substance or chemical is used or taken to site a risk analysis must be done with reference to the materiel safety data sheet. Procedures should be prepared or modified or alternate substances or chemicals used if the risk is above low (20 or less on the risk matrix as in Appendix A). Page 27