WASTE MANAGEMENT FACILITY AT 60 FITZROY ST DUBBO



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J R RICHARDS & SONS Development Proposal and Statement of Environmental Effects for Extensions to the WASTE MANAGEMENT FACILITY AT 60 FITZROY ST DUBBO SEPTEMBER 2013 APPENDIX I Integrated Management System (IMS) for JR Richards & Sons I:\Data\D&H\JOBS\JR Richards\JR333 Dubbo Liquid Waste\DA\Submission\JR333 SEE 260813.doc

JR RICHARDS & SONS INTEGRATED MANAGEMENT SYSTEM HEALTH, SAFETY, ENVIRONMENTAL AND QUALITY PLAN Issue 9.0 Prepared by: JR Richards & Sons Occupational Health Safety, Quality & Environmental Department Web site: www.jrrichards.com.au

TABLE OF CONTENTS TABLE OF CONTENTS... 2 MANUAL DOCUMENT CONTROL... 4 1.0 MANAGEMENT... 5 1.1 Purpose & Scope... 5 1.1.1 Purpose:... 5 1.1.2 Scope:... 5 1.1.3 Integrated Management System and Health, Safety, Environmental and QA Plan (HSE&QA Plan):... 5 1.1.4 AS/NZS ISO 9001 and AS/NZS ISO 14001 Compliance... 6 1.1.5 Integrated Management System Flow Chart... 7 1.2 Management Structure... 9 1.3 Policies... 10 1.4 Roles and Responsibilities... 10 1.5 Documentation and Document & Data Control... 11 1.6 Records... 11 1.7 Site Based Health, Safety, Environmental & Quality Plan (Annual Planner)... 12 1.8 Business Plan... 12 2.0 LEGAL AND OTHER REQUIREMENTS... 13 2.1 Legal Requirements... 13 2.2 Workplace Registrations & Operational Documents... 13 3.0 OBJECTIVES & TARGETS KPI S... 14 3.1 Management Performance Indicators... 14 4.0 PURCHASING... 14 4.1 Purchasing... 14 4.2 Approved Suppliers... 14 4.3 Approved Subcontractors... 15 5.0 CONSULTATION & COMMUNICATION... 16 5.1 Consultative Committee... 16 5.2 Toolbox talks... 16 5.3 Management Meetings and System Review Meetings... 17 5.4 External Communication... 17 6.0 HAZARD IDENTIFICATION & ENVIRONMENTAL ASPECTS... 18 6.1 Hazard Reporting... 18 6.2 Work Method Statement (Job Safety Analysis)... 18 6.3 Environmental Aspects & Impacts... 18 6.4 Workplace Inspections... 19 6.5 Risk Assessment... 20 7.0 OPERATIONAL CONTROL, TENDERING & SUPPLY OF SERVICES AND SPONSORSHIP... 20 7.1 Procedures... 20 7.2 Job Safety Observation... 21 7.3 Local Government Tendering & Contract Implementation... 22 7.4 Supply of Commercial Services (Quotes & Tenders)... 22 7.5 Credit Applications... 23 7.6 Discontinuance of Service... 23 7.7 Sponsorship... 23 Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 2 of 44

8.0 MONITORING & MEASUREMENT... 23 8.1 System... 23 9.0 RECRUITMENT/EMPLOYMENT & TRAINING (EMPLOYEES & SUB-CONTRACTORS)... 24 9.1 Recruitment... 24 9.2 Induction... 24 9.2 Code Of Conduct... 25 9.3 Sub-contractors... 25 9.4 Training... 25 9.5 Statutory Qualifications / WorkCover Certification... 26 10.0 WORKPLACE RULES AND PERMITS... 27 10.1 Rules... 27 10.2 Permits... 27 11.0 PLANT AND EQUIPMENT MANAGEMENT... 28 11.1 Health, Safety and Environmental Utensils... 28 11.2 General Plant Maintenance / Repair... 28 12.0 WORKPLACE HSE ISSUES... 29 12.1 Chemicals (Hazardous Substances)... 29 12.2 Noise and Vibration... 30 12.3 Working at Heights... 32 12.4 Waste Management... 32 12.5 Odour / Emissions... 32 12.6 Spill Management... 34 12.7 Personal Protective Equipment... 35 12.8 Occupational Health... 36 12.9 Infectious Diseases... 36 13.0 NON-CONFORMING PRODUCT, COMPLAINTS, CORRECTIVE AND PREVENTATIVE ACTIONS AND IMPROVEMENTS... 37 13.1 Non-Conforming Product & Complaints... 37 13.1.1 Council Services... 37 13.1.2 Commercial Services and Material Recovery Facilities... 38 13.1.3 Depot & Employee Non-Conformance... 38 13.2 Site Action Plans... 39 13.3 Corrective & Preventative Actions (Corrective Action Request CAR)... 39 13.4 System and Operational Improvement... 40 14.0 REPORTING SYSTEMS... 40 14.1 Incident & Accident Reporting (Injury, Vehicle and Environmental)... 40 14.2 Rehabilitation... 41 15.0 EMERGENCY PLANNING... 41 15.1 Emergency Planning... 41 15.2 Communication... 42 15.3 Practice Drills & Emergency Response... 42 15.4 Emergency Response Equipment... 43 16.0 AUDIT AND REVIEW... 43 16.1 System/Process Audits... 43 16.1 Regulatory Compliance Audits... 44 Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 3 of 44

MANUAL DOCUMENT CONTROL JR Richards & Sons Contact: JR Richards & Sons 1 Coral Avenue Tuncurry, NSW 2428 Phone: 02 6555 7007 Contact: Craig Shelton Issue Number Date Comments Issue 1 February 1996 First Release Issue 2 September 1997 Issue 3 August 1998 Issue 4 November 2005 Significant changes resulting from industry benchmarking. OHS, QA and Environmental systems collated into IMS. Incorporate minor changes and include reference to procedures and forms. Issue 5 January 2006 Incorporate minor changes. Issue 6 July 2006 Issue 7 August 2006 Issue 8.1 November 2007 Significant changes resulting from AS/NZS ISO 14001 pre-audit Incorporated minor changes resulting from AS/NZS ISO 14001 audit. Incorporated minor changes to sections 1.7, 5.2, 5.3, 8.1, 9.1, 9.2, 13.0 and removed section 17.0 Issue 8.2 August 2009 Compliance with new ISO AS/NZS 9001 Standard Issue 9 July 2010 Document name change, inclusion of site base plans and up dated management structure, Code of Conduct included Disclaimer This document has been prepared in good faith and no warranty is expressed or implied as a result of the content expressed and contained. The intent of this document is to heighten employees and contractors awareness in regards to their duty of care and statutory obligations in relation to Occupation Health & Safety, Quality Control and Environmental impacts while working for JR Richards & Sons. Confidentiality This document contains confidential material for employees, contractors and customers of JR Richards & Sons. All necessary measures must be taken by persons whilst handling this document to minimise unauthorised third party access. Copyright All rights reserved. The information contained in this document is copyright and cannot be coped or reproduced in any medium without the consent of JR Richards & Sons. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 4 of 44

1.0 MANAGEMENT AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element 4.1 Element 4.1 Element 4.1 1.1 Purpose & Scope 1.1.1 Purpose: The purpose of JR Richards & Sons Integrated Management System (IMS) is to ensure product and service quality continue to meet the highest standards demanded by the organization and expected by its customers, and to ensure JR Richards & Sons activities, products and services are carried out in an environmentally responsible and protective manner without harm to our employees or persons associated with our activities. 1.1.2 Scope: The scope of JR Richards & Sons activities includes tendering and servicing of waste management and recycling for Local Councils and commercial business. 1.1.3 Integrated Management System and Health, Safety, Environmental and QA Plan (HSE&QA Plan): The Integrated Management System comprises Health, Safety, Environmental and Quality elements which are essential to ensure that the company meets its legislative requirements and to comply with best practice. It includes JR Richards & Sons policies and describes how these policies are implemented and sustained throughout the organization. The core processes of the organization are described here, with references to the supporting procedures. The IMS is a living document and will be continually reviewed and updated as changes to legislation, company focus and structure are made. The System comprises: HSE&QA Plan: This plan sets out the minimum health, safety, environmental and quality requirements for the company as a whole. It is the divided into elements which are further divided into sections that give instruction and/or state how to implement and manage the requirements of the section. Position Descriptions: Documents the roles and responsibilities for each position within the company. These are located in the IMS Position Description Folder on the intranet or available in hardcopy from the ICT Department. Work Procedures and Safe Work Procedures: Work Procedures give instruction as to the standard method of performing a task or an overview of the task that may entail a number of specific tasks. These specific tasks are called Safe Work Procedures. Safe Work Procedures give detailed instructions on individual tasks that need to be performed to complete a larger, more detailed, task. Work Procedures (WP) and Safe Work Procedures (SWP) are located in the Procedures folder of the IMS. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 5 of 44

Forms: Are the approved templates required to complete a task, notify persons of information, give instruction, or record information relating to a task. Forms are located in the IMS Forms Folder on the intranet or from the ICT Department. Registers and Matrix: Are documents that relate to specific elements of the IMS. They can give guidance when reviewing site needs or help identify specific site requirements. Regulatory Compliance: Various elements of the organization are required to comply with regulatory requirements be it OHS, Environmental or other. To ensure that all these requirements are met the Regulatory Compliance Register has been developed for the company. Managers must refer to this register at least annually to ensure that their obligations are met. Intranet The IMS system is available to all depots with server access; otherwise it is distributed on disc. Site Based HSE&QA Plans (Annual Planner): These plans are developed from elements within the company HSE&QA Plan which are relevant to the site. The site plan makes references to elements within the company plan and sets timeframes for implementation and completion. Reference is also made to procedures, forms and persons responsible to ensure completion of tasks. 1.1.4 AS/NZS ISO 9001 and AS/NZS ISO 14001 Compliance The Integrated Management System is audited against the Current International Standards ISO 9001 for Quality Management Systems and ISO 14001 Environmental Management Systems. This requires documented procedures, accountabilities and objectives to ensure that the quality of service and environmental presentation provided by J. R. Richards and Sons is continuously improved and maintained. J. R. Richards & Sons are a waste management service provider to local government and industry. In performance of this service J. R. Richards & Sons are not held accountable for product being transported under existing environmental legislation. The scope of ISO 9001 and ISO 14001compliance is the development of tenders and the implementation and management of contracts from Head Office and project sites. This comprises the communication, monitoring and review of IMS use at all locations to ensure contractual compliance. J. R. Richards & Sons are excluded from the following clauses of ISO 9001 ; 7.3, 7.5.4 and 7.6. These exclusions are clarified below. J. R. Richards & Sons are not in the business of design/development or the modification of product or services. The monitoring, measuring or testing of product is not performed in the delivery of service. The incorporation of customer s goods, product or data does not take place in the performance of business and it is not an industry or legislative requirement to identify or trace product. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 6 of 44

1.1.5 Integrated Management System Flow Chart Quality, the environment and occupational health and safety are all unified by the concept of risk. Using three separate management systems within the one organisation is time consuming, expensive and ineffective. Therefore, to minimise duplication, align our objectives and to enable greater control of our management processes JR Richards & Sons have developed a company-specific Integrated Management System (IMS). This system combines the three previous separate systems, Quality (ISO 9001), Environmental (ISO 14001) and Occupational Health and Safety (AS/NZS 4801 ) into one manageable structure which is both simple to convey and able to be implemented across the company as a whole as one management tool. The IMS Manual is divided into 16 elements which comprise the management criteria for each standard. INTEGRATED MANAGEMENT SYSTEM Quality Management Plan Occupational Health & Safety Management Plan Environmental Management Plan JR Richards & Sons Health, Safety, Environment & Quality Plan (JRR Plan) Policies Management Commitment Position Descriptions Roles & Responsibilities Procedures Operational Controls Forms Monitoring & Review Code of Conduct Employee compliance Site Based Health, Safety, Environmental & Quality Plan (Site Plan) Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 7 of 44

1.1.6 Definitions & Terms Definitions The development and implementation of safety, quality and environmental management systems across various industries has created a considerable amount of terminology for identical components of these systems. These variances in terminology can cause confusion to persons when reviewing systems and hinder the education of staff and the greater community. To assist the reading of this document a list of definitions cross-referenced with industry terminology has been developed below. It is advisable to review this list prior to reviewing and implementing this document. JR Richards & Sons Comparable Definition Approved Suppliers Approved Subcontractors Consultative Committee Commercial Corrective Action Request (CAR) Domestic Environmental Aspects Environmental Impact Significant Environmental Aspect Management Review Meeting Organization Statutory Qualifications Safe Work Procedures Supplier Toolbox Talks Work Procedures Workplace Registrations Preferred Suppliers Preferred Subcontractor OH&S Committee Non-compliance Notice Improvement Request Managers Meeting Staff Meeting Employee tickets or certification Standard Operating Producers (SOP) Standard Work Procedures Toolbox Talks End of Shift Meeting Workplace Licenses Workplace Permit Suppliers that meet company OHSE&QA Requirements, Pricing and Service. Subcontractors that meet company OHSE&QA Requirements, Pricing and Service. Group of employee and management representatives elected to consult on issues pertaining to managing health, safety and environmental matters. refers to commercial service CAR s are issued for a non-conformance or when a system improvement is required. refer to Local Council contract Elements of the organization s activities, products or services, which can interact with the environment. Any change in the environment, positive or negative, wholly or partially resulting from the organizations activities, products, or services. The severity of an identified environmental impact is used to establish the objectives and performance targets for the environmental program. An environmental aspect that has, or can have, a major and/or long lasting environmental impact A forum used for managers to communicate and review operational and business subjects. refers to JR Richards & Sons Qualifications employees are required to hold when performing a particular task. e.g. Forklift ticket Additional guidance and/or instructional documentation relating to work procedures. Supplier of a product or service; can be a subcontractor, and/or vendor A two-way forum used to communicate operational issues between the workforce and management. A document outlining the standard system of work when performing a task. Regulatory Approvals Vehicle/Plant Registrations Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 8 of 44

1.2 Management Structure AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element 6.3 Element Element 4.4.1 J. R. Richards & Sons is a family owned and operated business within NSW. The management structure of the company comprises Managing Director, Directors, Department Managers, Depot Managers and Supervisors and Foreman. The Management Structure of two groups is shown below, being Management and Operations. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 9 of 44

1.3 Policies AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element 5.1, 5.3, 8.5 Element 4.2 Element 4.2 Policies have been developed and implemented to cover all areas of the operation that have an impact on OH&S, Environment and Quality. These policies are reviewed every 3 years or as necessary to ensure compliance with legislation and industry best practise. Other company policies may be reviewed at longer intervals. Employees are made aware of company policies on induction and during ongoing training. Sub contractors are supplied with company policies on request, which are also available on the company Internet site. Managers are to ensure copies of the OH&S, Environmental, Quality and Customer Service policies are displayed in the workplace and regularly communicated during Tool Box Talks. Documents: Policies are located within the Policy section of the IMS. 1.4 Roles and Responsibilities AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element 5.5.1 Element 4.4.1 Element 4.4.1 JR Richards & Sons Directors acknowledge their responsibility for providing policies and the framework for implementing management systems to control safety, quality and environmental aspects within the organisation, and for those occasions where company operations may cause impact outside of the usual work environment. The Integrated Management System has been established to embrace all safety, quality and environmental elements of these policies. The IMS enables a simple and effective way to communicate company policies and procedures to all staff and identifies roles and responsibilities of our staff in the implementation and ongoing control of these aspects. The Compliance Manager has the overall responsibility for the management of the Integrated Management System. Roles and responsibilities have been identified for all levels of management, employees, sub contractors and visitors. These have been documented in position descriptions, employee contracts and procedures. All staff are made fully aware of their roles and responsibilities during induction, and when undergoing training and review. Documents: Procedures: Position Descriptions WP-QA-003 Roles & Responsibilities WP-AD-179 Recruitment Procedures WP-AD-180 Procedure for Induction / Training Assessment Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 10 of 44

1.5 Documentation and Document & Data Control AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element 4.4.5 Element 4.4.5 Element 4.4.5 This Section deals with the control of the Integrated Management System and documents pertaining to tenders and contracts. The process of Document Control is necessary to ensure consistency across the business and that out-of-date details do not remain in our systems. Details that may need updating can include document content and/or personnel changes (management). If a new document needs to be implemented or an existing document requires modification the details are to be forwarded to the Compliance or ICT Manager for consideration. A Director must approve all major modifications and/or additions prior to inclusion. Should any document or form be currently in use but not recorded in the Integrated Management System, it must be immediately forwarded to the Compliance or ICT Manager for consideration and inclusion. Controlled documents include all policies, procedures, forms, registers and related documentation pertaining to the administration and general day-to-day running of the business. All in-service documents must be registered and authorised. All documents associated with to the IMS are reviewed periodically in accordance with the Workplace Registrations & Operational Documents RQA 1064. Documents are reviewed on a risk basis with frequency determined at the time of production or as determined by the Compliance Department. Documents: Procedure: WP-AD-202 Document Control WP-QA-070 Electronic Records Management - Naming Conventions Registers: RQA 1064 Workplace Registrations & Operational Documents 1.6 Records AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element 4.2.4 Element 4.5.3 Element 4.5.3 This section deals with the keeping of records required by legislation and/or JR Richards & Sons. The minimum records required have been identified and listed in the document retention register RQA 1023. Managers/Supervisors must consult this register and confirm all records that need to be managed. Records may be completed forms, personal details and/or signed procedures. Depots may be required to forward records to Head Office or file completed documents in the relevant section of the depots filing system. IMS documents are to be filed in the corresponding file of the depot IMS filing system. Site administration documents are to be filed in alphabetical order and stored within the administration filing cabinets. Tender documents and associated council correspondence are to be filed in the respective lever arch folders at Head Office. Folders are to be labelled according to the tender. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 11 of 44

Non-active Head Office Administration records are to be filed in their relevant sections in the archives. At the start of each calendar year site personnel responsible for the IMS system are to archive all relevant completed records in safe storage at the depot. Documents: Procedure: Register: WP-AD-520 Control of Records RQA 1023 Document Retention Register 1.7 Site Based Health, Safety, Environmental & Quality Plan (Annual Planner) This section deals with the development and implantation of site based health, safety, environmental and quality plans. The JR Richards HSE&QA Plan covers all the fundamentals required for the whole company. Given not all sites across JR Richards are the same individual plans must be develop to ensure all risks are captured for the location. Site plans are prepared by reviewing what the site risks are, reviewing tasks being performed, infrastructure, environmental aspects and the management structure of the depot. These plans are constructed from elements within the JRR plan and implemented at the site. Associated documents relating to each element, instructions for implementation and the names of persons responsible for actioning are recorded within the site plan. The site manager must refer to the JRR plan for detailed instructions and reference to procedures. The site plan also includes dates tasks are to be undertaken and reporting requirements. Site Plans are reviewed annually. Documents: Register: RQA 1065 Site HSE&QA Plan (Annual Planner) 1.8 Business Plan AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element 5.4.1 Element 4.3.3 Element 4.3.3 A Business Plan which includes company strategies and goals is developed annually by senior management. Departmental goals are set on an annual basis to monitor continual growth within the business. These goals are reviewed and are intended to meet business, tender and legislative requirements. Directors and Departmental Managers shall set these goals at the beginning of each financial year and review each department s progress during Management Review Meetings. Documents: Registers: Business Plan RQA 1088 Objectives & Targets KPI Register Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 12 of 44

2.0 LEGAL AND OTHER REQUIREMENTS AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element Element 4.3.2 Element 4.3.2 2.1 Legal Requirements As part of its responsibilities, the Compliance Department maintains a liaison with all applicable outside agencies and government departments regarding regulatory or legal requirements. The department employs various resources to ensure that the company is aware of and implements changes resulting from legislative or other changes. These resources are listed in the procedure WP-QA-001 Legal & Other Requirements. Legislation covering each depot is listed in the Regulatory Compliance Register. This register is also referred to during the tendering process. New and modified legislation is addressed using the Management Review Meeting and added to the register. The register is reviewed annually and on a needs be basis. Documents: Procedures: WP-QA-001 Legal & Other Requirements Registers: RQA 1085 Legal & Other Requirements register RQA 1090 IMS Document Review RQA 1064 Workplace Registrations & Operational Documents 2.2 Workplace Registrations & Operational Documents It is necessary to ensure that the systematic management of the workplace, vehicles, plant and support services required either by legislation or IMS policy are managed and maintained on a continual basis. Workplace Registrations are documents that may pertain to legal, organisational or operational compliance (vehicle registrations, plant licensing, etc). Operational Documents are those that pertain to the daily operation of the business. Managers/Supervisors are to review the Workplace Registrations & Operational Documents Register RQA 1064 and highlight those that are applicable to their site. They must consult with Departmental Managers and/or administrative staff when reviewing this register to ensure the inclusion of all workplace and support services. If any items that are applicable to a site are not listed on the register the Compliance Department or ICT Department must be contacted to update the register. OHS, Quality & Environment Compliance Manager Registrations, licences Associate Director Site Licences and/or Certification Associate Director/Area Manager Documentation, IT and Communication ICT Manager Documents: Procedures: Registers: WP-QA-001 Legal & Other Requirements RQA 1064 Workplace Registrations & Operational Documents RQA 1078 Regulatory Compliance Register Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 13 of 44

3.0 OBJECTIVES & TARGETS KPI s 3.1 Management Performance Indicators This section deals with the establishment of company objectives and targets and the implementation of Safety, Quality & Environmental Key Performance Indicators (KPI s). Indicators used by JR Richards & Sons are based on Council and Public complaints, Environmental Non-conformances, industry and organisational processes and business trends. Objectives and targets are established annually in conjunction with the annual business plan. Responsible persons are involved in the development of these objectives and targets and kpi s are established to monitor performance. Objectives and Targets are listed in Objectives & Targets KPI Register. Departmental and Depot Managers must review this register periodically to ensure that they are aware of the objectives and targets set for their area of responsibility in order to meet their goals. The register is reviewed in conjunction with the business plan. Documents: Procedures: WP-QA-002 Objectives & Targets WP-QA-004 Environmental Aspects & Impacts Business Plan Registers: RQA 1088 Objectives & Targets KPI Register 4.0 PURCHASING 4.1 Purchasing This section of the IMS addresses the purchasing of Non-Capital and Capital items and the use of Petty Cash. Non-Capital items are those purchased to replenished consumables or replace damaged worn or redundant items. Refer to procedure for purchasing limits. Capital items are those which will become an asset to the company. These items may be land and buildings, mobile plant and equipment or improvements to company assets. Managers must complete a Capital Expenditure Request and have it approved at Head Office prior to ordering Capital items. Documents: Procedures: WP-AD-002 Purchasing WP-AD-102 Capital Expenditure Forms: ADM 0009 Capital Expenditure Request 4.2 Approved Suppliers This section addresses the way in which suppliers of major goods and services are assessed to be an Approved Supplier. This assessment will help to ensure that quality products and services are delivered to each depot. A Major Supplier is one that supplies products or services on an ongoing basis. If the service is one that may involve high risk to safety/environment or business continuity, the service provider must be approved as well. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 14 of 44

The majority of major suppliers are controlled through Head Office and have already been listed on the Register. Examples of these are communications, tyres, fuels & oils, vehicle consumables & parts, safety items and waste management products. To ensure relief and/or new Managers/Supervisors are aware of current depot suppliers the Manager/Supervisor of each site must complete the approved supplier register by inserting the contact details for each of their major suppliers as well as adding other frequently used suppliers relevant to the site. To engage the services of a major supplier that is not on the register, complete the Supplier Approval Form and forward to Manager/Supervisor for approval. Be sure to include the date the product/service is required to ensure the supplier is approved in time. Documents: Register: Form: RQA 1066 Approved Suppliers Register QAF 1056 Supplier Approval Form 4.3 Approved Subcontractors This section addresses the management of Sub-contractors who conduct services for or on behalf of JR Richards & Sons. A number of checks are required to ensure that the Subcontractor is aware of each party s responsibilities and can comply with relevant legislation. A sub-contractor is a sole trader or company that works in conjunction with JR Richards & Sons in carrying out a larger contract (i.e. bin delivery company, handy bins) or works on behalf of JR Richards & Sons in carrying out services (i.e. owner/driver). A sub-contractor will work under the direction of JR Richards & Sons, as opposed to a contractor who provides a service to our business with JR Richards & Sons having no direct control over the performance of the service. Sub-contractors must be approved before services can be contracted. To be approved the sub-contractor must supply details such as: Insurances (Public Liability) WorkCover Workers Compensation Environmental Licensing Vehicle Registration Industrial Relations Policy & Employee Award Details WorkCover or EPA Improvement Notices or Infringements in past 12 months Environmental & OHS Policies Safety & Environmental Plans Risk Assessments Refer to the Approved Sub contractors Register which is maintained by the Accounts Department. If the sub-contractor is not on the Register, complete the Sub-contractor Approval Form and forward to Manager/Supervisor for approval. Be sure to include required start date to ensure processing is done in time. The sub-contractor must be issued with an order detailing works to be carried out and a copy of JR Richards & Sons OHS & Environmental Policies (or be directed to JR Richards & Sons internet site). Wherever possible they should be handed a list of all environmental aspects and impacts and hazards pertaining to the job. Sub-contractors must submit a Health, Safety, Environmental and QA plan for all works carried out. If the subcontractor is unable to develop their own plan they are required to complete Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 15 of 44

and submit the JR Richards & Sons Subcontractor Health, Safety and Environmental Plan including Safe Work Method Statements prior to commencement of duties. All subcontractors must comply with the requirements set out in the JR Richards HSE&QA Plan, relevant legislation and local government requirements. Once a sub-contractor has been approved they shall be included on the Sub-contractors Approval Register. The Sub-contractor is to be issued a Sub-contractor Health, Safety & Environmental Plan which they must complete and return for approval. All sub-contractors MUST undergo a sub-contractor induction in compliance with section 9.0 Recruitment / Employment & Training. Managers are to contact the Creditors Department in Tuncurry for the current register Documents: Manual: Subcontractor Health, Safety & Environmental Plan Procedures: WP-TQ-003 Sub Contractor Engagement Register: RQA 1094 Approved Subcontractor Register Forms: QAF 1037 Subcontractor Approval 5.0 CONSULTATION & COMMUNICATION AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element 5.5.3 Element 4.4.3 Element 4.4.3 5.1 Consultative Committee It is a legislative requirement for all companies to consult with employees, therefore JR Richards & Sons have formulated a consultative committee (OH&S Committee) made up of employees that have been elected by their peers from each work group. These employees have undergone training by accredited training providers in compliance with the OH&S Regulation. The committee meets regularly and addresses changes to the workplace pertaining to Health, Safety, Environmental and the IMS. Committee representatives raise issues of concern they have identified or that are brought to them by fellow workmates. These issues are reviewed and corrective actions agreed to if appropriate. Minutes of these meetings are communicated to all employees through Toolbox Talks. 5.2 Toolbox talks Toolbox Talks are planned meetings held between the workplace management and employees in an open forum. These meetings address health, safety, quality and environmental issues including operational and staffing matters. Toolbox Talks are required to be held on a monthly and needs be basis and are documented on the Toolbox Talk Meeting Record ADM 0038. Employees are encouraged to voice their opinion of any areas of concern and/or improvements at these meetings and to assist in the development of corrective actions. Issues raised at these meetings are to be transferred to the Site Action Plan to be assigned to a responsible person for actioning. If the issue is one that cannot be rectified through site management a Corrective Action Request is to be raised. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 16 of 44

Head Office circulates a quarterly Toolbox Talk Agenda which includes incidents and accidents that may have occurred during the previous period, safety, quality and environmental issues, new or modified policies, procedures and forms including general company business. Documents: Procedures: WP-AD-208 Management & Staff meetings & Communication Systems Forms: ADM 00038 Toolbox Talk Meeting record 5.3 Management Meetings and System Review Meetings AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element 5.6 Element 4.6 Element 4.6 Management meetings are held on a needs be basis between Departmental Managers and Directors. They follow a set agenda which covers the broad business. System review meetings are held quarterly and cover the implementation and ongoing improvement of the IMS, business development and operational controls. Minutes of these meetings are prepared and persons nominated to implement corrective actions for issues raised. Documents: Procedures: WP-AD-208 Management & Staff meetings & Communication Systems Forms: ADM 0147 Management Review Meeting Agenda 5.4 External Communication JR Richards & Sons utilises various forms of media outlets when communicating with the general public, Councils and organisations. The public is able to access a variety of company information though our website www.jrrichards.com.au. Information available on this site includes the Environmental and Safety Policies, domestic waste collection schedules, educational information and product and service types. An information brochure containing domestic waste collection schedules, collecting details, recyclable items and handy hinds on waste management is mailed out in each Council area on an annual basis. Ads are also run in local newspapers and on radio media advising of similar information. Where required under contract, brochures are produced and mailed out to local residents advising of bulky waste cleanups and collection information. These cleanups are also advertised in local media and radio. Monthly meetings are held with various Councils to review contractual requirements and include forward planning for bulky waste cleanups, landfill management, environmental and safety aspects and hazard controls. Councils are supplied with a copy of the IMS manual that outlines Significant Environmental Aspects and Health & Safety Hazards. Requests for information from other customers including the general public pertaining to Health, Safety, Environmental and Quality issues/systems and general business must be Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 17 of 44

received in writing addressed to the Associate Director. Requests will be dealt with at the discretion of the Company Directors. (The JR Richards & Sons annual business report is not produced for publication.) 6.0 HAZARD IDENTIFICATION & ENVIRONMENTAL ASPECTS AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element Element 4.3.1 Element 4.3.1 6.1 Hazard Reporting To ensure all hazards are reported and controlled to prevent injury or illness to persons and/or environmental damage, employees must be trained in the identification of hazards, the steps required to render hazardous situations safe, and the reporting of these hazards to management. This training is to take place during induction using the relevant procedures and is ongoing by the site Manager/Supervisor and Training Manager. Depots maintain a hazard log which gives employees a formal means of reporting hazards. Managers/Supervisors must address all hazards recorded in the log documenting actions taken on the report form. If preventive actions cannot be rectified at the site level the Manager/Supervisor must implement corrective actions and raise a CAR. Documents: Procedure: Forms SWP-OP-001 Hazard Identification WP-OHS-005 Hazard Reporting to Head Office SWPF 0001 Health, Safety & Environmental Hazard Report ADM 0011 Monthly Hazard Report Form 6.2 Work Method Statement (Job Safety Analysis) To ensure all hazards associated with non routine and low risk tasks are identified a Work Method Statement (WMS) is to be carried out prior to the commencement work. This is done by breaking the task into separate steps and looking at what hazards may be associated with the step with the controls needed to remove or reduce the level of risk. A WMA may list personal protective equipment required or specific licenses or qualification required. The WMS should also be reviewed following a incident or change to the task (new plant, equipment, change to a step, etc). Documents: Procedure: Forms SWP-AD-004 Work Method Statement (Job Safety Analysis) SWPF 0103 Work Method Statement (Job Safety Analysis) 6.3 Environmental Aspects & Impacts Environmental Aspects - Elements of the organization s activities, products or services that can interact with the environment. Environmental Impact - Any change in the environment, positive or negative, wholly or partially resulting from the organizations activities, products, or services. The severity of an identified environmental impact is used to establish the objectives and performance targets for the environmental program. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 18 of 44

Significant Environmental Aspect - An environmental aspect that has or can have a major and/or long term impact on the environment. JR Richards & Sons maintain procedures to identify the environmental aspects of its activities, products and services within the defined scope of its contractual requirements that it can control, and those that it can influence, taking into account planned or new developments, or new or modified activities, products and services; and to determine those aspects that have or can have significant impact(s) on the environment. In order to determine what can have a significant impact on the environment, JR Richards & Sons has identified all known environmental aspects and related impacts of its activities, products and services. These aspects and impacts are documented in the Environmental Aspects and Impacts Register RQA 1080 and reviewed as part of the IMS internal audit process. Additional reviews shall occur during the tender process and as a result of significant change to corporate structure, facility location or business plan. Significant Environmental Aspects are those inherent aspects deemed to have a major consequence and require substantial controls to manage as they may pose an irreversible impact on the environment. Significant Environmental Aspects are listed on the Significant Environmental Aspect Register RQA 1084. These aspects have been ranked by management using the best of their professional judgement to determine the order of priority for the implementation of future controls. These aspects are communicated to all involved employees and are included in job specific training. Environmental aspects will also be taken into account when setting Objectives and Targets. The Environmental aspects and impacts register is available to Councils on tender and other parties on approval by Directors Documents: Procedures: WP-QA-004 Environmental Aspects & Impacts Forms: QAF 0076 Environmental Aspects & Impacts - Initial Review QAF 0077 Environmental Aspects & Impacts - Assessment QAF 0078 Environmental Aspects & Impacts - Audit Review Registers: RQA 1080 Environmental Aspects and Impacts Register RQA 1084 Significant Environmental Aspect Register RQA 1085 Legal & Other Requirements Register 6.4 Workplace Inspections Workplace inspections are to be performed at each work area on a monthly basis by the responsible Manager/Supervisor and/or employee. Inspections of offsite workplaces may be required to be conducted on a more regular basis (mines, etc). The inspection is to ensure that all aspects of the workplace are maintained in a safe and environmentally sound manner that does not present an unsafe condition to persons or harm to the environment. Areas that fall below the required levels are to be documented on the inspection form for action. Managers are to rectify areas of concern where possible and sign off on the inspection from. Areas of concern that cannot be rectified at the site level are to be highlighted on the inspection report and transferred to the Site Action Plan. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 19 of 44

Completed inspections are to be filed in the depot IMS filing system with a copy faxed to the Compliance Department. Departmental Managers are to conduct site inspections of each depot and report all findings to the Directors. Documents: Forms: SWPF 0110 Workplace Inspection Form 6.5 Risk Assessment The fundamental basis of managing business risk is to ensure that all persons employed and those areas directly and indirectly affected by the business, including the environment and business assets, are not exposed to risks arising from activities performed by the business. To ensure that risks are identified and systems put into place to eliminate or control these risks it is the responsibility of employees to conduct risk assessments and implement controls. Employees will be trained in the risk assessment process on induction and during their employment. Managers are responsible for conducting risk assessments of all new tasks prior to implementation including new plant and equipment on receipt. Employees are to be made aware of the risks associated with the tasks or items and the controls implemented to reduce or remove the exposure. It is advisable wherever possible to include employees in the risk assessment process. Documents: Procedures: SWP-AD-002 Risk Assessment Forms: SWPF 0003 Risk Assessment Form 7.0 OPERATIONAL CONTROL, TENDERING & SUPPLY OF SERVICES and SPONSORSHIP 7.1 Procedures This section deals with the development and implementation of procedures and work method statement and associated documents that ensure standardization and consistency is maintained within the day-to-day management of the business. Procedures are developed for routine tasks and those with a high level of risk. Work Method Statements may be developed for non routine tasks and those with a low level of risk. They are used to train employees in the JR Richards & Sons method of completing tasks, controlling monies, plant and equipment and performing routine and critical tasks. Existing Procedures JR Richards & Sons have an extensive range of procedures covering a majority of tasks carried out within the work environment that address the requirements of this manual. Personnel are to make themselves familiar with these procedures and to have a full understanding of those that give direction to the tasks they perform. Identification of new tasks Managers/Supervisors are to conduct an assessment of tasks carried out within the work environment on a regular basis and list all tasks not already included in an existing register. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 20 of 44

Development of new Procedures and associate documentation Once a new or modified regular task has been identified, contact the Compliance Manager to ensure that a procedure has not already been developed for the task at another depot. If a new procedure is required consult with the workforce when developing procedures for each of these tasks. A risk assessment is to be conducted of the task to identify potential risks to employees, plant and equipment and the environment and the controls required to remove or reduce the level of risk. If other documentation is required to accompany the procedure (forms, registers) develop those in the same process. Approval of New Procedures and Documents Forward all new procedures and/or forms to the Compliance Manager for review. The Compliance Manager shall arrange for approval of the document. The new document is to be allocated an ID number and forwarded to the ICT Manager for inclusion into the IMS System. Once placed on the IMS site, notification shall comply with section 1.5 of the IMS. Training Managers and Supervisors are to ensure relevant personnel have completed all appropriate training in compliance with the Training Procedure. The Training Manager shall conduct and administer additional training on a needs be basis. Review Procedures are reviewed periodically and on change of process. Procedures may be reviewed during the tendering process. Coordinating Documents All procedures are to be controlled in compliance with section 1.5 of the IMS. Documents: Registers: RQA 1055 Forms RQA 1056 Procedures RQA 1057 Job Descriptions 7.2 Job Safety Observation A Job Safety Observation is a tool used to monitor employees and contractors to ensure tasks are performed in a safe manner and procedures followed. This involves supervisors and/or employees observing workers undertaking tasks and referencing the steps taken against the procedure. Observations include safety equipment used, methods employed to operate equipment and tools, team work, environmental management and safety controls. If the task is undertaken in-line with the procedure no action is required. If however the procedure is not followed the supervisor is required to review the procedure with the employee/s to ensure it is up to date and appropriate. If the task was not followed due to employee inconsistency the supervisor is to review the procedure with the employees involved and explain the reasons why it is necessary to comply. A Job Safety Observation Form is used during this process. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 21 of 44

7.3 Local Government Tendering & Contract Implementation To ensure compliance with company policy it is the responsibility of the organization to strive for best environmental and safety practices when tendering. Where a tender requires environmental and safety systems to be incorporated in the tender, Directors must ensure that they are offering systems and equipment that meets or betters current best practice. Where a tender does not call for best practice it is the responsibility of the directors to include such systems and equipment as an alternative to that requested. Assessments of environmental impacts and OHS risks are to be undertaken during the tendering process to ensure that all potential risks are identified and highlighted in the tender document. All environmental aspects/impacts and OHS risks associated with the tender are to be communicated to sub contractors during the development stage of the tender. Contracts are to be review periodically to ensure compliance. Documents Procedures: WP-TQ-001 Tendering WP-QA-004 Environmental Aspects & Impacts SWP-AD-002 Risk Assessment WP-TQ-002 Contract Implementation WP-TQ-003 Sub Contractor Engagement Forms: QAF 0079 Tendering QAF 1064 Contract Implementation ADM 0034 Contract Review Checklist Registers: RQA 1094 Approved Sub contractor Register 7.4 Supply of Commercial Services (Quotes & Tenders) Permanent Services The supply of commercial waste services is a substantial part of our business. To this degree it is the responsibility of depot managers/supervisors and/or salespersons to make formal contact with the customer to discuss the type and method of service/s required. A site risk assessment is to be undertaken and the collection options are to be agreed. Documents: Procedures: WP-AD-099 Completion & Processing of Service Agreements WP-AD-401 Printing of Service Agreements WP-AD-185 Procedure for Price Increases Forms: ADM 0017 Waste Service Agreement Quotes & Temporary Services At times customers will request a written quote for services. In this instance form ADM 0018 is to be used unless a formal written quotation (tender) is requested. When quoting, approval must be obtained from either the area manager or senior manager head office depending on the level of service required. This is to ensure pricing is correct and the service type requested in available. Approval levels are listed below: Area Manager quotes pertaining to one off or weekly services covered by the depot pricing schedule. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 22 of 44

Head Office Tenders for larger long term projects, multiple services, quotes/tenders that require capital expenditure and pricing for sub-contract work from other waste companies, etc. Documents: Procedures: WP-AD-185 Procedure for Price Increases Forms: ADM 0018 Quote and Temporary Service Agreement 7.5 Credit Applications It is company policy that a credit applicant is completed by costumers prior to the supply of services. Credits limits have been established and are available from head office. Documents: Forms: ADM 0021 Credit Application Form 7.6 Discontinuance of Service To ensure consistency within the business and enable management to evaluate product and service trends a number of procedures have been developed which must be followed when disengaging services. This includes stop services, removal of services and completion of contracts. Documents: Procedures: WP-AD-171 Cancellation of Contracted Commercial Customer WP-AD-098 Stop Service Orders Forms: ADM 0017 Waste Service Agreement 7.7 Sponsorship JR Richards & Sons are committed to community based sponsorship throughout regional and rural NSW. To ensure this sponsorship is beneficial to the local community approval must be granted from head office. Documents: Procedures: WP-AD-521 Approval for Advertising, Donations & Sponsorship Forms: ADM 0149 Costing Estimate for Non-monetary Donations & Sponsorship ADM 0150 Donation of Services or Sponsorship 8.0 MONITORING & MEASUREMENT 8.1 System This section addresses the monitoring and measurement of the elements within the Integrated Management System and associated business systems. Various forms of monitoring & measurement are utilised within JR Richards & Sons to ensure ongoing compliance with legislative and system requirements. These include the following elements of the IMS Manual: Legal Requirements section 2.1 Workplace Registrations & Operational Documents section 2.2 Management Performance Indicators section 3.1 Consultation & Communication section 5.0 Hazard Identification & Environmental Aspects section 6.0 Plant & Equipment Management section 11.0 Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 23 of 44

Monthly performance reports are produced for various Councils measuring Health, Safety and Environmental performance, and Management Meetings evaluate the operational performances of the business. Depot managers are to complete a monthly report ADM 0082 detailing specific health, safety and environmental controls which have been implemented and/or undertaken throughout the month. These reports are to be forward to Head Office for collection and review. CAR s are raised for corrective actions arising from audits (internal and external) and are then listed on the company action plan. Documents: Procedures: WP-AD-510 Monitoring & Measurement WP-AD-207 Regulatory Compliance Forms: ADM 0082 Depot Monthly HSE Report ADM 0146 Regulatory Compliance Audit ADM 0086 OHS&E Systems Assessment Registers: RQA 1078 Regulatory Compliance Register RQA 1085 Legal & Other Requirements Register RQA 1096 Depot Audit Schedule 9.0 RECRUITMENT/EMPLOYMENT & TRAINING (EMPLOYEES & SUB- CONTRACTORS) 9.1 Recruitment This section addresses the recruitment of new employees and the process of employment. If recruiting for a newly created position is required, authorisation must be obtained from Head Office prior to recruitment. All prospective employees must complete an employment form in full and supply a current RTA driver s history report for all driving appointments. Once a short list has been made the applicant/s must undergo a medical. Approval must be obtained from Head Office prior to final selection and employment. Note: All relevant documentation must be completed prior to starting any new employee otherwise wages cannot be paid. Documents: Procedures: WP-AD-179 Procedure for Employment WP-AD-180 Procedure for Induction, Training & Assessment Form: ADM 0078 New Position Approval ADM 0022 Employment Application Form ADM 0042 Pre Employment Medical SWPF 0004 Probationary Statement ADM 0145 Employment check sheet 9.2 Induction This section covers the issue of generic and site specific inductions, to ensure new and existing staff are aware of the hazards in the workplace, environmental aspects and impacts, risk control measures, company expectations, their entitlements, acceptable standards of behaviour and the like. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 24 of 44

Employees: All new employees must undergo a general and job specific induction using the Staff Manual with the Manager/Supervisor responsible for the area in which the employee is employed prior to the commencement of duties. All drivers must undergo a thorough assessment of driving ability by the Manager/Supervisor in accordance with SWPF 0007 Driver Induction Check Sheet. Employees are issued a Staff Manual containing all relevant induction documentation for the position/s they are to be employed. If an employee s position is changed they must undergo additional induction for the task and be supplied with the relevant documentation for their Staff Manual. Managers are to notify the Compliance Department of employee inductions to ensure a Staff Manual is issued. Documents: Procedures: WP-AD-180 Induction, Training & Assessment Procedure Form: ADM 0022 Employment Application Form SWPF 0007 Driver induction Check sheet ADM 0043 Employment Check sheet and Questionnaire Manuals: Staff Manual 9.2 Code Of Conduct JR Richards & Sons have developed a new Code of Conduct to reflect our core values. It clarifies the standards of behaviour that are expected of staff in the performance of their duties and gives guidance in areas where staff need to make personal and ethical decisions. All employees are to be issued and with a copy of the code of conduct and its content is to be explained so everyone understands their roles and responsibilities. 9.3 Sub-contractors All sub-contractors and their employees must undergo a site induction prior to commencement of any works. The person responsible for works must complete a thorough induction in compliance with ADM 0040 Sub-contractors Declaration / Induction checklist. All documentation is to be filed onsite with copies forwarded to Head Office, Payroll Department, for filing in the sub-contractor induction files. 9.4 Training Documents: Procedures: WP-TQ-003 Sub contractor Engagement Form: ADM 0040 Subcontractors Declaration / Induction checklist AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element 6.2 Element 4.4.2 Element 4.4.2 This section covers the requirements for training that are essential to ensure that all staff have the skills required and can display a level of competency to perform their duties safely and efficiently. The continual review of skills and competencies required by our people will ensure appropriate changes as the business develops and grows. Employees are to be trained in their roles on induction and through the buddy training system. Specialist training needs are addressed by way of certified trainers within JR Richards & Sons or by approved suppliers. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 25 of 44

OH&S Committee members and Representatives are required to undergo specific training by accredited training providers in compliance with the OH&S Regulation. Employee Competency Managers are to refer to RQA 1089 Training Needs Matrix when commencing new staff or transferring existing staff to ensure that they have the desired competencies for the role. Employees that require training to meet the skill levels for a task will be instructed initially during induction and then placed with an experienced employee for on the job (buddy) training and instruction. Vehicle Operators New operators must undergo a competency assessment within 3 months of employment by the Training Manager. The Manager/Supervisor or appointed employee shall instruct the new driver on a one-to-one basis until they are confident that the employee is able to operate the vehicle in a safe and productive manner. The training areas shall be documented on the Vehicle Training Form: SWPF 0040 Internal Training All internal training must be recorded on a training record QAF 0118 stating the nature of the training provided, person conducting the training, and names and signatures attendees. Certified Training The Training Manager will conduct certified training of employees in accordance with legislative and award requirements as well as for personal development. Records All training must be documented and certificates of attendance must be supplied for external training. Training records are to be filed in the personnel files at Head Office. The Manager/Supervisor must record all employee training on the Depot Training Register. Documents: Procedure: Registers: Forms: WP-AD-180 Induction, Training & Assessment WPN-AD-060 Driver Training & Assessment RQA 1089 Training Needs Analysis Matrix Training Register ADM 0023 Performance Appraisal Form ADM 0007 Review of Training Requirements ADM 0040 Sub contractor Declaration / Induction Checklist SWPF 0007 Driver Induction Check sheet SWPF 0006 Driver Training / Assessment Sheet SWPF 0040 Vehicle Training Form QAF 0118 Training Record 9.5 Statutory Qualifications / WorkCover Certification This section deals with the licences and certificates that persons must have in a particular function to operate particular pieces of equipment. Managers/Supervisors are required to ensure that all employees under their control have the required licences or certificates for the tasks they are performing. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 26 of 44

Using the Statutory Qualification Register RQA 1067 Managers/Supervisors must review all relevant licences and certificates for all employees and then date and sign off on the register. Copies of all licences and certificates must be maintained onsite and forwarded to the Payroll Department at Head Office. If an employee is required to operate a particular item of plant that requires WorkCover certification and they are not certified to do so, the manager/supervisor must firstly issue the employee with an appropriate training manual and review the manual and operation of the plant with the employee. The employee is to be issued with a WorkCover Training Log book and be placed under the instruction of a certified operator. Both the trainee and operator must sign off on the training log each time the trainee operates the plant. The Training Manager shall review all trainees and arrange for formal assessment when they are deemed capable of safe operation. Documents: Register RQA 1067 Statutory Qualifications Register 10.0 WORKPLACE RULES AND PERMITS 10.1 Rules This section covers the topic of workplace rules and permits. Rules have been developed and implemented to control risks within the work environment. There are two types of rules within the company being generic rules and site-specific rules. Generic Rules are those developed to control inherent risks throughout the business. Site-Specific Rules are those developed to control risks that are relevant to a particular task or work environment. Documents: Rules: Generic and Site-Specific Rules are available in the IMS Rule Folders 10.2 Permits Special Work Permits are required for recognised high risk activities that need to be closely managed by the Manager/Supervisor. Work Permits are based upon legislative requirements and/or recognised industry practice. The issuing of Work Permits is a very structured process, starting with training for both the person issuing the permit and those using the permit. The Manager/Supervisor must complete an assessment of the work environment to assess the need for permits using form SWPF 0013. If the need for a permit is identified contact is to be made with the Compliance Manager to evaluate the task. The Compliance Department will develop the permit required or determine if one is currently in use. The manager/supervisor must then instruct all employees in the correct use of the permit and ensure that all equipment/documentation required to safely complete the task is available. All completed permits are to be filed in the IMS folder or office file system. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 27 of 44

Documents: Forms: SWPF 0013 Work Permit Assessment Form SWPF 0017 Hot Work Permit SWPF 0018 Confined Space Permit 11.0 PLANT AND EQUIPMENT MANAGEMENT 11.1 Health, Safety and Environmental Utensils Particular pieces of equipment have been designed for the safety of workers and/or the protection of the environment and need to be maintained in accordance with relevant regulations and/or recognised industry practice. To ensure that equipment is correctly maintained, Managers/Supervisors are required to identify these items using the Specific OHS&E Assessment form. The content of the form is to be reviewed against those items onsite and those items not on the list are to be added. Consult with the Compliance Manager for legislative requirements or industry practice. The Special OHS&E Systems Management Matrix is used to identify, plan and record all the required information in each of the columns across the page. Extra items and inspection intervals must be added to the yearly planner. Documents: Forms: Register: ADM 0086 Special OHS&E Systems Assessment RQA 1068 Special OHS&E Systems Management Matrix 11.2 General Plant Maintenance / Repair Vehicles The administration of maintenance for the vehicular fleet is controlled by way of the company s computer based fleet management system. The maintenance and administration departments are responsible for data entry into this system and the generation of reports and preventive maintenance schedules. Operators are responsible for pre-trip inspections of all vehicles referring to the pre-trip inspection form. Operators are to complete a full pre-start inspection at the commencement of each shift and sign off on their time sheet stating that the inspection has taken place. All vehicle defects are to be reported in the vehicle defect book and the depot Manager/Supervisor is to review the content of these books daily as part of the daily inspection to ensure that defects have been addressed. Operators are to advise their Manager/Supervisor if an item has been written in their defect book. If the Manager/Supervisor is not available the operator must inform a mechanic or responsible person. The operator is to write the defect in the top section of the book and sign off. Once the defect has been rectified actions taken must be written in the bottom section and signed off by the person that performed the repair/action. Servicing of vehicles must comply with the vehicle service form for the type of service being undertaken. These forms must be completed and signed by the mechanic undertaking the service. Completed service forms are to be forwarded to the Tuncurry Workshop for filing. Managers must complete a vehicle pre-delivery & acceptance check sheet when despatching or receiving vehicles and an RTA inspection check sheet must be completed prior to sending vehicles for an RTA inspection. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 28 of 44

Managers/Supervisors must inspect all vehicles on a weekly basis to ensure the unit is in safe operating condition. Documented quarterly inspections of all vehicles must be completed by the Manager/Supervisor and forwarded to the Compliance Department. Documents: Procedures: SWP-MN-221 Vehicle Service SWP-OP-004 Vehicle Breakdown & Defects WP-MN-301 Tag Out Procedure Forms: ENG 0010 Vehicle Pre Start Check sheet ENG 0008 Vehicle Pre-Delivery & Acceptance Check sheet ENG 0009 RTA Inspection ENG 0003 Service A Sheet ENG 0004 Service B Sheet ENG 0006 Service C Sheet ENG 0007 Service D Sheet QAF 0113 RORO Tankers & Others QAF 0114 Service Sheet Recyclers & Garbage QAF 0115 Service Sheet O.H.L Plant The maintenance of plant is controlled through the maintenance department and the maintenance database. Employees are required to complete a pre-start inspection prior to the commencement of duties and report all defects in the plant defect book and to the depot manager. Monthly inspections of plant are conducted by Managers/Supervisors to ensure compliance with operating requirements and operators are to conduct visual inspections of plant which is documented prior to starting duties. Documents: Procedures Form: SWP-OP-053 Plant Breakdown & Defects SWP-OP-052 Forklift Pre Start Checks SWP-OP-062 Drott Pre-start Check SWPF 0032 Daily Safety Checklist Loader SWPF 0033 Daily Safety Checklist Dumper SWPF 0031 Daily Safety Checklist Excavator SWPF 0030 Daily Safety Checklist Spreader SWPF 0020 Daily Safety Checklist Forklift 12.0 WORKPLACE HSE ISSUES 12.1 Chemicals (Hazardous Substances) As an employer, JR Richards & Sons is obligated under Occupational Health and Safety legislation to provide access to all employees the information on hazardous substances used, transported, stored and disposed of by the organisation. A Hazardous Substance is defined as: - Any substance in which a potential hazard exists or arises when such a substance is stored, handled, used or disposed of. The potential hazard includes any detrimental effects, both short and long term, on the health of humans or any detrimental effects on equipment, structures or the environment. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 29 of 44

This information is supplied as Material Safety Data Sheets in the format approved by Worksafe Australia. The M.S.D.S. shall be available at the point of use if practical, and also in a master manual at each site. Managers/Supervisors are to ensure that all hazardous substances (e.g. caustic, corrosive, asphyxiant, toxic, narcotic, flammable and explosive) used, kept or produced on site are identified and that measures are taken to remove or reduce, as far as is practicable, the risk presented by hazardous substances. Common substances are chemicals and can be poisonous (toxic). These include: fuels lubricants paints solvents detergents disinfectants adhesives Although JR Richards & Sons only use a small number of chemicals Managers/Supervisors are to survey the workplace and list all chemicals present using the workplace survey form, establish which chemicals are required, and then remove those not required. Actions will be implemented to ensure that chemicals are managed correctly on site and MSDS obtained for each chemical. MSDS are to be updated every 5 years. Superseded MSDS are to be forwarded to Head Office for archiving. Chemicals must be stored in a safe place free from any potential hazards (fire, electrical) and incapable of harming the environment. Collection and Disposal of Dangerous or Hazardous Waste All employees involved in the collection and disposal of dangerous or hazardous waste must be trained in the correct procedures and have access to appropriate PPE. If the collection of waste involves that of a regulated waste controlled under the Protection of the Environment Operations Act a Waste Data Tracking Form must be completed. Contact the Compliance Manager for details. Documents: Procedures: SWP-OP-029 Safe Handling of Regulated Waste SWP-OP-030 Safe Handling of Pathological Waste SWP-OP-300 Safe Handling and Disposal of Asbestos SWP-OP-301 Identification of Dangerous / Hazardous Material at Disposal Sites SWP-OP-303 Safe Handling and Storage of Waste Chemicals SWP-OP-400 Liquid Waste Biological Hazards Forms: SWPF 0050 Hazardous Substances Risk Assessment QAF 0011 EPA Waste Data Tracking Form 12.2 Noise and Vibration Safety Loud continuous noise damages the sensitive hair cells of the cochlea inside the ear. A person with damaged or destroyed hair cells can suffer hearing loss, tinnitus, and dizziness, headaches or permanent deafness. In addition to hearing loss, noise can have other adverse effects such as fatigue and irritability and can consequently adversely affect health and safety in a less obvious manner. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 30 of 44

Loud noise can also cause lack of concentration, poor performance, poor communication, inability to hear warning signals and hence major accidents. Noise level is measured in units of the decibel A scale (the dba). Vibration is often closely associated with noise because the origin and control of both are similar. Vibration can have various effects on the human body. Noise (and also vibration) can often be reduced at the source by design/modification or by interrupting the transmission path between the source and the employee. Managers/Supervisors are to ensure that suspect workplace noise levels are recorded by the OHS Department and that where possible, noise levels are reduced by engineering methods. Training in noise exposure measurement and reduction will be provided to those employees in need. Area, Branch & Depot Managers 1. Ensure that surveys are carried out to identify areas of unacceptably high levels of noise or vibration and make appropriate recommendations. 2. Ensure that any identified high noise and/or vibration zones related to equipment and machines (fixed or mobile) are suitably and correctly signposted. 3. Ensure that an up to date plan of work locations and/or mobile equipment items is maintained indicating areas/zones of high noise level or vibration hazards. 4. Ensure that every reasonable effort is made to: (i) silence and/or muffle noisy plant and equipment (fixed or mobile). (ii) (iii) Environmental Isolate vibration hazards wherever practical. Separate personnel from the source of the noise or vibration where this is the better solution. Noise is also a major component with the general collection of waste. Managers/Supervisors are to ensure that all employees are trained in the correct use of equipment to minimise noise during collection. Runs are to be planned, where possible, for times that will cause least inconvenience to the public. Employees All employees are to wear appropriate PPE in high noise level areas and to operate plant and equipment in compliance with correct operating procedures to reduce the exposure to noise. All employees are to undergo audiometric screening prior to employment. Complaints All complaints received relating to noise will be reported on the complaints form. Documents: Procedures: SWPF 0023 Noise Survey Form Form: Monthly Workplace Inspections Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 31 of 44

12.3 Working at Heights This section deals with working at heights both within the workplace and off site. The OH&S Act 2000 division 6 states that employers must ensure that risks associated with falls from heights are controlled. As a minimum fall protection must be in place for persons working at heights of 2 metres or more. Fall protection may be in the form of: Handrails Fencing Scaffolding Screening Lanyards and guide ropes If employees are required to work in locations on a permanent basis where falls are likely to occur then fixed controls must be set in place. If the work area is temporary then lanyards and guides ropes may suffice. A risk assessment must be completed to identify the safest and most appropriate controls required for the task. 12.4 Waste Management This section addresses the management of waste generated from depot activities. Environmental legislation states that waste generators are responsible for their waste from cradle to grave. Therefore, it is our responsibility to ensure that waste generated from our depot activities has minimal impact on the environment by implementing the Waste Hierarchy that encourages waste avoidance, reuse or recycling processes ahead of treatment or disposal to landfill. In addition, J. R. Richards is responsible for ensuring that its waste is transported, treated or disposed of in a legal and responsible manner. Managers/Supervisors are to review form QAF 0125 and determine the types of waste generated from their depot, investigate how the waste is produced and if it is possible to reduce the amount of waste generated. They must ensure that where practical the waste is reused or recycled as opposed to disposing to landfill. If waste is not to be reused or recycled as it is impossible to do so, site plans will be used to manage waste in such a manner as not to impact on the environment. Waste is to be controlled in a suitable manner as not to cause injury or illness to a person or damage to the environment. Waste is to be stored in appropriate storage containers. All employees are responsible for working in a manner that produces a minimal amount of waste and where possible to reuse or recycle. Managers must ensure that when new processes are implemented the subject of waste generation and disposal is addressed, highlighting any means to reduce or reuse waste. Documents: Forms: QAF 1063 Waste Management Suppliers Monthly Workplace Inspections 12.5 Odour / Emissions This section addresses the management of odour and emissions to air from depot/site activities. Environmental legislation states that all reasonable and practicable measures must be taken to prevent and/or minimise air pollution from the site. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 32 of 44

Managers/Supervisors are to review all activities carried out on site and identify sources of odour and emissions (i.e. vehicles, welders, odorous bins, wash bay grills, grease traps) and document these activities on the Emission Register. Once odour and emission (including potential) sources have been identified, develop control measures to minimise odours and emissions. In most cases, good housekeeping and regular maintenance will address potential odour and emission issues. Controls shall be recorded on the register. Implement control measures into the site-specific induction, training and work procedures. If possible install signage for improved controls. Monitoring Some plant and equipment may require emissions monitoring on a regular basis to comply with regulatory requirements. Using forms supplied note what elements of the environment require monitoring and the organization responsible. If monitoring is the responsibly of J. R. Richards & Sons add to the YEARLY PLANNER. Complaint Recording Should a complaint be received regarding odour or emissions, it is to be recorded in the complaints register. Refer to 12.0 External Complaints. The complaint must be investigated immediately and if found to be true an accident/incident form will need to be completed. Guidelines for Minimising Odour Issues ISSUE MRF Skips/Bins Domestic Garbage Vehicles Grease traps/ interceptors Dead Animals Waste ACTIONS Only store minimal amounts of bailed product in yards. Retain all bailing residue in contained area around bails and clean daily. Maintain yards. Where possible do not leavel product in hoppers overnight. Bins returned for repair or changeover cleaned in the wash bay before storing on site. Use of odour mitigating detergents or over-sprays. Load areas are cleaned before servicing/repair or parking overnight. Use of odour mitigating detergents or over-sprays. Regularly serviced (particularly in hotter months). Serviced at times where odour is less likely to impact on neighbours and employee. Not left at depot overnight. Containers cleaned regularly. Regular servicing of waste, in particular putrescible waste, generated on site. Where possible, locate bins away from work areas and site boundaries. Guidelines for Minimising Emissions from Vehicles ISSUE Loads ACTIONS Efficient organisation of loads from customers to disposal sites. Even distribution of loads on trucks/trailers and correct tarping down of loads. Even distribution of loads in tankers to reduce friction on wheel bearings and tyres. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 33 of 44

Fleet Maintenance Fuels Drivers Vehicles Regular servicing, repair and maintenance of vehicles. Correct tyre pressure in all tyres at all times. Regular rotation and balancing of wheels and tyres on prime movers and trailers. Regular alignment of steer wheels. Pressure levelling devices on dual trailer tyres. Reduce brake dragging. Use of alternative fuels (where possible). Driver education and training to improve driver skills and performance of fleet (this can reduce fuel consumption by 10-15% and minimise vehicle down-time). Aerodynamic vehicle design features. Low rolling resistance tyres to improve energy consumption. Use of wind deflectors and or skirts on tankers to reduce wind resistance. Removal of bull-bars on trucks and prime movers to reduce wind resistance. Use of pressure balanced tyres to reduce energy consumption. Use of nitrogen filled tyres to reduce energy consumption. Documents: Register: Form: RQA 1073 Odour / Emission Register Monthly Workplace Inspections 12.6 Spill Management This section addresses the management of spills in the workplace, including those from vehicles. Environmental legislation requires that all reasonable and practicable measures be taken in the prevention of spills. Managers/Supervisors are to survey the workplace for areas where there is potential for spills (i.e. waste/chemical storage areas, workshop floors). Using the Spill Register, note the type and volume of substances and determine the potential size of the spill in these areas and where the spill is likely to run. Review vehicle operations and identify the type and volume of substances being transported by each vehicle and the likelihood of spillage. After assessing the type and volume of substances refer to the Spill Management Matrix (Register & Matrix folder) for guidelines on determining the requirements of a spill kit. It is essential that the contents of the spill kits be checked periodically and restocked to ensure maximum spill control at all times. Employees shall be trained in how to use spill kits quickly and to effectively contain spills. In most cases, distributors of spill response products can be requested to conduct practical demonstrations. Training is to take place on induction or when being trained to operate vehicles or equipment that has a potential for spillage. Waste Disposal Small and unsaturated amounts of organic absorbent used to clean up grease, oil or fuel spills can be disposed of as general waste. However best practice would be to have this waste treated. Absorbents used to clean up hazardous chemicals should be contained separately and removed by licensed transporters for treatment at a licensed facility. This service would be on an as needs basis. In most cases for vehicle spills, the clean-up materials can be disposed of in the same manner as (and ideally with) the original load being transported. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 34 of 44

Emergency Management Emergency procedures must be present at all times in the workplace or cabin of a vehicle. Employees are to be trained in these procedures on induction. Accident/Incident Reporting Should a spill occur in a non-bunded area, in a public place, or to land or a watercourse, the operator must contain the spill and immediately notify their Manager. The Manager must contact Head Office upon notification and advise details of the spill and action taken. Register RQA 1069 is to be followed in an incident. Head Office Management will notify appropriate authorities of the event where required. Please see Section 13.1 Accident/Incident Reporting. Documents: Registers: RQA 1070 Spill Management Matrix RQA 1069 Workplace Spillage Register 12.7 Personal Protective Equipment This Section provides advice on the issue of Personal Protective Equipment (PPE). PPE is a common form of risk control; however it is a potentially unreliable risk control measure due to the human factors and the limitations of the equipment. Each site has unique tasks that may incorporate the use of PPE. These tasks and PPE requirements shall be identified when undertaking risk assessment and implementing controls. The company has implemented some standard PPE requirements across the organization that is listed in the induction manual. All Managers/Supervisors are to conduct periodic reviews of tasks performed at their depots and to ensure the correct type of PPE is in use. If a new or modified task is identified, a risk assessment is to be completed. If PPE is a control to be implemented, ensure that the correct type is supplied and personnel trained. A PPE Matrix has been provided (Register & Matrix folder) for the general PPE requirements for each occupation within the organization. All non-disposable PPE issued to employees must be issued against that employee s name. (Non-disposable PPE involves items that can be used more than once). Document the issue of all non-disposable PPE on the PPE Issue form SWPF 0014 when issuing non-disposable PPE to employees. This will assist with the control and ongoing supply of products. Managers are to conduct a signage survey & post signage as required for areas/equipment requiring PPE. Also they must regularly review relevant workplace inspection checklists & include identified PPE and signs, review relevant Standard Operating Procedures and if PPE requirements need to be added to a procedure, contact the Compliance Manager for modification. PPE requirements are included in the site-specific induction and addressed at Tool Box Talks. Where possible the supply of PPE is to be managed through the Tuncurry Workshop, as a large stock of PPE is stored at the Workshop. Managers are to e-mail or phone the workshop with stock orders. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 35 of 44

Documents: Registers: Forms: RQA 1071 PPE Issue Matrix SWPF 0014 PPE Issue Form 12.8 Occupational Health This Section addresses the minimum requirements for the control of occupational health within the workplace. Occupational health is the management of specific items or tasks within the work environment that may impact on the health of employees and visitors. Managers/Supervisors are to regularly conduct Hazard Identifications/Risk Assessments/Task Analysis/Hygiene Surveys to identify hazards within the workplace that may pose a health risk to employees or public. On completion of the survey review the controls in place to manage the risk and determine if extra controls are required. If PPE is the management control in place, ensure that the type in use is correct and that employees are trained to use the equipment correctly. (See item 12.6 above) Document: Register: RQA 1074 Occupational Health Survey Register 12.9 Infectious Diseases This Section addresses the management of infectious diseases in the workplace. Infectious diseases include but are not limited to Hepatitis A & B and Q Fever. The following procedures must be adhered to: Managers/Supervisors are to survey the workplace to identify employees who perform tasks that may expose them to infectious diseases. Where possible, eliminate the risk. If the risk cannot be eliminated, employees exposed to the risk of infectious diseases are to be immunised against those diseases. Existing Employees. All existing employees identified as being exposed to the risk of infectious diseases that are not currently immunised must be identified and vaccinated as soon as possible. Employees who are currently immunised against some or all infectious diseases must have the details of their immunisations recorded on immunisation forms ADM 0043 & ADM 0044, in their personnel file at Head Office, and in the health register on the main server at Tuncurry. Any employee who refuses to be vaccinated should, where the opportunity exists, be placed in an alternative position within the company where there is no risk from infectious diseases. This may include changes to and re-allocation of runs wherever possible. If there is no available alternative, they must sign off on the refusal to be vaccinated form ADM 0045 confirming their awareness of their exposure to the risk of contracting an infectious disease and that they understand and appreciate the hazards associated with contracting such a disease and that they still refuse to be immunised against these identified infectious diseases. Further, that they will wear and use Personal Protective Equipment (PPE) as a means of minimising the risk of exposure to infectious diseases. They must also acknowledge on the refusal to vaccinate form that failure to wear this PPE when carrying out their work duties may be grounds for immediate dismissal. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 36 of 44

New Employees For all New Employees it is a prior condition of employment that should their position be assessed as involving duties that may expose them to the risk of infectious diseases then they must be immunised against these diseases. Documents: Procedures: SWP-OHS-102 Personal Protective Clothing and Equipment SWP-OHS-100 Needlestick Injuries SWP-OP-400 Liquid Waste Biological Waste Forms: ADM 0075 Q Fever Immunisation Form ADM 0076 Hepatitis Immunisation Form ADM 0077 Immunisation Refusal Form Register: RQA 1082 Hep B & Q Fever Immunisation Register 13.0 NON-CONFORMING PRODUCT, COMPLAINTS, CORRECTIVE AND PREVENTATIVE ACTIONS AND IMPROVEMENTS AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element 8.3 / 8.5 Element 4.5 Element 13.1 Non-Conforming Product & Complaints The section addresses non-conforming products, which within J. R. Richards & Sons comprises waste services relating to domestic mobile garbage/recycle bin (MGB/MRB) collection and commercial waste management. Significant non-conformances have been identified as non-conforming MGB/MRB (contamination), missed services, incorrect supply of commercial service, and contamination of recycling from material recovery facility, depot non-conformance and non-conforming performance. Non-conformances are grouped into three areas being Council Services, Commercial Non-Conformances and Depot & Employee Non-Conformance. 13.1.1 Council Services Non-conforming MGB/MRB A number of Councils require the monitoring of contaminated waste within MGB/MRB s (nonconforming MGB/MRB) and have determined actions for operators of waste collection vehicles to take. Procedures for notifying property owners of the placement of prohibited items in recycling MRB s varies between Local Government Areas and are addressed in the relevant Council Contract. These procedures are also set out in the IMS Procedure Folder. Generally property owners are to be given a number of notices for non-conformances prior to a service being removed. Documents: Procedures: WP-QA-500 Great Lakes Council Waste Collection MGB Contamination WP-QA-501 Moree Plains Council Waste Collection MGB Contamination Forms: Council Waste Collection Problem Form (refer to IMS Forms) Council Complaints Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 37 of 44

Complaints received pertaining to a Council Contract is to be logged into the depots Bin Track Program. Once the complaint has been logged into the system the Operations Manager is to be advised for actioning and completion of corrective and preventive actions If a complaint is received outside of the Council scope, it is to be handled in accordance with the procedure for commercial complaints Documents: Procedure: Data Base: WP-QA-505 Complaints & Improvement Bin Track 13.1.2 Commercial Services and Material Recovery Facilities Complaints & Non-Conforming Product Commercial services represent a substantial component of our business and therefore it is of importance that complaints and non-conformances relating to commercial services are managed in a professional and timely manner. When a commercial complaint or nonconformance is received the procedure for a Corrective Action Request (CAR) is to be followed. Material Recovery Facilities It is company policy to reduce contamination of recycled materials and waste to landfill generated through our MRF s by way of employee education and procedural compliance. Employees are trained in correct sorting processes and recycled material is constantly inspected throughout the shift to ensure contamination is maintained below minimum standards. Documents: Procedure: Forms: WP-QA-070 Corrective Action Request WP-QA-021 Final Inspection ADM 0080 Corrective Action Request Form 13.1.3 Depot & Employee Non-Conformance Non-conforming Depot It is the responsibility of each Depot Manager/Supervisor to ensure that operations run within the company scope and comply with the business plan, operational procedures and contractual requirements. If a non-conformance relating to operational control is detected then a CAR is to be raised and issued to the responsible person. It is the responsibility of the person the CAR has been issued to for ensuring corrective and preventive actions are implemented to prevent any recurrence. Non-Conforming Performance It is the policy of the Company to provide customers with a consistent and appropriate level of service. To support that policy job descriptions and work procedures have been developed for employees so that they know the extent of their jobs and how to consistently perform the various tasks required of them. It is the responsibility of every employee in the Company to fully understand job descriptions, work procedures and all documentation relevant to their jobs. Non-conforming performance occurs when activities are not performed in accordance with approved procedures or benchmark time frames. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 38 of 44

Managers are responsible for monitoring employees and where non-conforming performances are identified (employee behaviour, run times, sorting, maintenance, etc) they are to consult with the employee. If the non-conformance cannot be rectified immediately by the employee a non-conforming performance report shall be completed by the Manager. A review date of no greater than 3 weeks shall be set and a copy of this report is to be handed to the employee with original forwarded to the Payroll Department at Head Office. The Manager is to monitor the employee s performance over the review period and consult with the employee on the review date. Documents: Procedure: Forms: WP-QA-070 Corrective Action Request WP-QA-005 Review of Non Conforming Performance ADM 0080 Corrective Action Request Form ADM 0069 Non Conforming Performance Employee Review Form 13.2 Site Action Plans This section is necessary to ensure that all issues arising from depot incident investigations, toolbox talks, site inspections, hazard reports and CAR s are captured and actioned. By placing all actions on the one form Management can easily identify outstanding issues and prioritise corrective and preventative actions. Transfer Items Following an investigation, toolbox talk, site inspection, CAR or other OHSE&QA related matter complete the relevant documentation and transfer outstanding actions to the site action plan. Complete Actions As the action plan develops, prioritise items and action highest priorities first. As items on the action plan are addressed sign off on their completion. Do not delete items from the action plan as it will serve as an audit tool. File all completed action plans in the IMS folder. Document: Forms: ADM 0051 Action Plan. 13.3 Corrective & Preventative Actions (Corrective Action Request CAR) A Corrective Action Request (CAR) is used to record and track corrective and/or preventive actions taken to eliminate the root cause of quality related problems. Such events include: non conformance (both process and system), audits findings (internal & external), customer complaints, suggestions or any other situation involving quality or system improvement. The CAR system is also intended to be used as a tool by Management in the reporting and tracking of corrective actions relating to operational and site issues. The CAR system is not intended to be used by employees in place of the site hazard & incident reporting systems. Once a CAR s has been raised it is logged into the CAR database at Head Office, reports are generated monthly for Senior Management to track. Documents: Procedure: Forms: WP-QA-070 Corrective Action Request ADM 0080 Corrective Action Request Form Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 39 of 44

13.4 System and Operational Improvement To enable employees to formally lodge suggestions relating to system and operational improvement the CAR form includes an area for improvements. When an employee raises a suggestion relating to system or operational improvement the Manager/Supervisor can complete a CAR form detailing the suggestion including the name of the employee that raised the suggestion. The CAR is to be logged and both Area and Senior Management are to review the suggestion and assess it for implementation. The employee is to be made aware of any outcomes. Documents: Procedure: Forms: WP-QA-070 Corrective Action Request ADM 0080 Corrective Action Request Form 14.0 REPORTING SYSTEMS 14.1 Incident & Accident Reporting (Injury, Vehicle and Environmental) AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element Element 4.5.2 Element 4.5.2 This Section relates to incident reporting and investigation. The reporting of incidents is paramount to enable investigation and to implement workplace changes to remove or reduce the likelihood of recurrence. Investigation is required to determine the root cause of incidents in the workplace so that controls can be put in place to prevent recurrence. Incident reporting is not only a legislative requirement it also provides valuable data for the creation of an internal database for improved risk management and prioritising actions. Managers/Supervisors are to ensure all employees are fully aware of reporting requirements on induction. Employees are to be educated in the reporting procedure and associated forms. If an incident is serious, the Manager/Supervisor must immediately contact the Compliance Manager or a Director at Head office to report the situation. The Director at Head Office will notify any Regulatory Authorities (WorkCover, EPA) if required. Site contact with these authorities is not to take place without Head Office being notified first. Investigation If an incident involves a medical treatment injury, renders a vehicle unserviceable or causes damage to property resulting in the cancelation of business or activity the event must be investigated by the Depot Manager / Supervisor Documents: Procedures: WP-OP-012 Incident/Accident & Near Miss Report Procedure Forms: QAF 0100 ADM 0012 ADM 0200 ADM 0032 QAF 0101 Incident / Accident & Near Miss report Form Accident Repair Estimate Form Incident / Accident Investigation Form General Motor Vehicle Accident Investigation Form Motor Vehicle Accident Checklist Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 40 of 44

14.2 Rehabilitation This Section relates to the management of Workers Compensation Claims and Rehabilitation. Legislation requires all injured employees to undergo rehabilitation to promote recovery and the return to pre-injury duties. Employees must report all injuries to their supervisor as soon as practicable and complete relevant document. If the employee requires medical treatment the supervisor is to arrange transport to a company doctor or hospital. A WorkCover medical certificate must be obtained on treatment. The supervisor or employee is to inform the treating practitioner of the availability of suitable duties and forward a company letter explaining those duties to the doctor. The Manager/Supervisor is to advise the Compliance Manager of the injury prior to shift end and what actions have been taken. The Compliance Manager will implement the rehabilitation program in compliance with relevant procedures and legislation. Documents: Procedures Forms: WP-OHS-001 Rehabilitation Flow Sheet WP-OHS-002 Rehabilitation Role Statement WP-OHS-003 Rehabilitation Program WP-OHS-004 Rehabilitation Alternate Duties ADM 0004 Return to Work Plan ADM 0005 Rehabilitation Checklist ADM 0065 Travel Claim Form ADM 0049 Case Notes ADM 0050 Claims Cost 15.0 EMERGENCY PLANNING AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element 8.3 Element 4.4.7 Element 4.4.7 15.1 Emergency Planning This Section addresses the Emergency Planning that identifies potential emergencies, the preparations for dealing with an emergency and the immediate management of those emergencies that may arise in the workplace or work areas. Contingency Planning deals specifically with returning the business to a level of operational status that ensures the business can deliver its contractual and statutory obligations. Emergency Procedures and Planning Emergency procedures have been developed for likely events that may impact directly or indirectly on the workplace. These procedures are to be communicated to all employees at the workplace. The Manager/Supervisor is to regularly review these procedures to ensure that all likely emergency situations have been addressed. Risk Assessment Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 41 of 44

To ensure that all potential emergencies have been covered, the Manager/Supervisor is to conduct a risk assessment of the workplace using form SWPF 0024 and document those areas not covered in the emergency procedure manual. He must then draft a management plan for the areas not covered and forward all to the Compliance Manager for review. Emergency Manual A generic emergency response manual has been developed covering all areas of operation. Managers are to print this manual, insert details of evacuation points, contact details, first aiders, first aid kits and other relevant information in the areas required. A manual must be located in a prominent location in each work area (workshop, office, MRF, etc). An emergency manual must be located in each vehicle. Emergency Contact List SWPF 0099 must be completed by Managers/Supervisors and displayed in all workplaces. A copy of the contact list must be located in every vehicle. Evacuation Points Managers/Supervisors must designate two evacuation points for each depot/mrf. These points must be easily accessible to all persons away from hazards (chemical storage, electrical installation, etc) and be clearly signposted. 15.2 Communication Emergency procedures will be displayed in a prominent location for all employees to access. All employees shall be made fully aware of emergency procedures, evacuation points and emergency equipment. 15.3 Practice Drills & Emergency Response Emergency management drills will be conducted and outcomes recorded to ensure reactions to emergencies use appropriate procedures. Post Response Debriefs Following each emergency or drill a debrief of staff and the Emergency Response Team will be conducted and any improvement to the system identified during the debrief implemented. Any changes shall be reviewed, implemented & communicated internally and externally as required. All emergencies shall be thoroughly investigated. Contingency Planning The Manager/Supervisor shall be consulted about strategies they may have for returning the workplace to a normal operating status (i.e. if a particular shed has become unusable). Contingency planning can extend past reacting to and managing the aftermath of an emergency. It could extend to managing a wide range of business crises such as: A local landfill or MRF being closed: - list of suitable alternates Theft of a computer with valuable data: - back-up taken off-site daily Dangerous Goods drivers not being available: - list of casual employees with qualifications Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 42 of 44

15.4 Emergency Response Equipment To ensure all equipment supplied is maintained in an operational state at all times these items have been included in the monthly workplace inspection. Fire fighting equipment must be checked every 6 months by an approved supplier and listed on the depot fire fighting equipment register. Documents: Procedure: Forms: Registers: Emergency Procedures Manual SWP-OP-002 Emergency Procedures (off side) SWPF 0070 Emergency Management Risk Assessment SWPF 0099 Emergency Wall Chart RQA 1093 Emergency Drill Register RQA 1075 Fire Fighting Equipment Register 16.0 AUDIT AND REVIEW AS/NZS ISO 9001 AS/NZS ISO 14001 AS/NZS 4801 Element 8.2.2 Element 4.5.4 Element 4.5.4 16.1 System/Process Audits This Section addresses the ongoing management of workplace standards through planned, formal Audits. System Audits are generally conducted on IMS content (Head Office) while Process Audits shall be conducted at each site. Many of the other sections of this IMS assist in setting the standards required by law and internal policy. This section assists in ensuring that those standards are not allowed to slip and therefore, elevate the level of risk to workers, environment and business. It ensures that all employees are made accountable for their roles and responsibilities. Internal system audits are to be conducted by a trained auditor who is not responsible for the program which is being audited. It is the responsibility of the Compliance Department for the planning and reporting of internal audits. Setting Audit Schedules An appraisal of each element of the standards (ISO 9001 & ISO 14001) is undertaken using Audit Planning ADM 0101 to determine if a formal audit is required or the element is monitored through process review (product reports and monitoring). Elements required to be audited are transferred from the Audit Planner to the audit schedule ADM 0028 and dates for audits are set. The audit schedules are planned over a 3 year period. Conducting Audits Ensure all resources required are available. Thoroughly read the element of the IMS and all relevant procedures and forms to obtain a full understanding of the element. Using form ADM 0030 and the Audit Schedule carry out the audit, document all nonconformances and recommendations. If required complete a Corrective Action Request (CAR) form. Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 43 of 44

Reports All parties involved in the audit must sign off on the report. The Compliance Manager shall present audit reports at Management Review Meetings. The audit is to be recorded in the Audit Register RQA 1102. Filing of Audit Reports Reports are to be filed in the System Audit Folder located with the Compliance Manager. Audits reports are to be made available to external auditors as required. 16.1 Regulatory Compliance Audits Regulatory Compliance Audits are conducted to ensure continued compliance of all elements involving legal and contractual requirements within the Head Office and/or onsite. These audits are planned and listed on the depot audit schedule. Setting Audit Schedules Using the Legal & Other Requirements Register dates are set for depot audits on the Depot Audit Schedule RQA 1096. The audit schedules are planned on a risk basis over a 5 year period. Conducting Audits Ensure all resources required are available. Thoroughly read the Legal & Other Requirements Register and any relevant licenses, approvals, legislation and contracts. Using form ADM 00146 and the Audit Schedule carry out the audit, document all nonconformances and recommendations. If required complete a Corrective Action Request (CAR) form. Reports All parties involved in the audit must sign off on the report. The Compliance Manager shall present audit reports at Management Review Meetings. The audit is to be recorded in the Audit Register RQA 1102. Filing of Audit Reports Reports are to be filed in the System Audit Folder located with the Compliance Manager. Audits reports are to be made available to external auditors as required. Documents: Procedure: Registers: Forms WP-QA-070 Corrective Action Request RQA 1102 Audit Register RQA 1096 Depot Audit Schedule ADM 0101 Audit Planner ADM 0028 Internal Audit Schedule ADM 0030 Internal Audit Report ADM 0146 Regulatory Compliance Audit Report QAF 0005 Safety Audit Checklist ADM 0080 Corrective Action Request Form Doc. Name: HSE&QA Plan Doc. No.: HSE&QA 0001 Date of Last Review: 16.07.10 Page: 44 of 44