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1. Introduction 1.1. PURPOSE & SCOPE This Health & Safety Management Manual (HSMM) and associated documents describe the Health & Safety Management System (HSMS) operated by Dŵr Cymru Welsh Water to ensure the health and safety of employees, visitors and any person who may be affected by the Company s activities, and to ensure compliance with legislation relating to Health and Safety matters. 1.2. AUTHORITY & RESPONSIBILITIES This H&S Management Manual, the Top Level document of the H&S Management System, is authorised by the Operations Director of Welsh Water, who has been nominated by the Board as the H&S Management Appointee, ie the Director with specific responsibility for Health & Safety. A Health & Safety Steering Group, see HSMS 257, has been established to set, implement and manage Company H&S Objectives and Targets and to carry out Management Reviews. The Health & Safety Policy Manager has been appointed as the H&S Management Representative with responsibility to establish, maintain, review and continually improve the H&S Management and its effectiveness in preventing injuries and ill-health. Details of H&S responsibilities are set out in individual role descriptions and job ladders as appropriate and are summarised below: 1.2.1 Senior managers are responsible within their areas of control for: - The upkeep, implementation and monitoring of any H&S procedures allocated to them; Ensuring that appropriate risk management strategies are identified, implemented and monitored; Agreeing and authorising the provision of procedures and supporting systems, including any necessary training requirements for supporting the health and safety policy; Monitoring the discharge of the delegated health and safety responsibilities of their line managers; Monitoring accident investigations for all injuries and significant incidents; Monitoring the implementation of recommendations following investigations into injuries and incidents; Monitoring and producing reports on the health and safety performance of their function. 1.2.2 Area, Catchment and other Line Managers are responsible, within their areas of control, for: Identifying areas of significant risk, ensuring that adequate assessments are made and that effective control measures are implemented using the appropriate risk management strategies; Monitoring the health and safety performance of their business area or unit; Monitoring the discharge of the delegated health and safety responsibilities of their employees; Liaising, where required, with other occupants of premises to ensure that interface responsibilities are adequately addressed; Identifying, agreeing and arranging training and re-training needs (through Talent Development business processes); HSMS 288 Issue 3 Issue Date 25.11.2011 Page 1 of 14

Undertaking accident investigations into injuries and incidents, providing suitable reports into the circumstances which identifies root causes and make any necessary recommendations to prevent similar occurrences; Implementing any recommendations following investigations into injuries and incidents. 1.2.3 All employees in all disciplines are responsible for: Assessing the risks associated with a particular task, work activity or location, applying appropriate safety measures and referring any problems which are outside their control to their line manager; Following relevant safe systems of work and any safety standards as laid down in Company procedures, including the use of correct tools; relevant protective clothing, proper equipment and in the case of low risk activities, following good working practices to accepted standards; Ensuring the safety of colleagues, contractors and members of the public who may be affected by their activities. 1.2.4 The Head of Health & Safety with the Health & Safety Team provide advice, guidance and support to all business areas in Health & Safety matters, including :- Developing and reviewing the H&S Policy in consultation with the Board and the Executive and ensuring that all managers are aware of the Policy and their responsibilities within it. Effective two-way communication with Directors, DCE and managers to ensure that all of these are familiar with and understand relevant H&S legislation. Monitoring the effectiveness of the implementation of the Company H&S Policy and Management System by reviewing the findings of workplace inspections and audits and progress of corrective and preventive actions. Participation in the H&S Steering Group & providing specialist support for the Company H&S Forum, ensuring that required information is available. Developing, establishing, implementing and monitoring the progress of Company Health & Safety Objectives on an annual basis. Assisting managers in undertaking investigations into work related injuries and incidents. Assisting managers to monitor the H&S management and H&S performance of contractors they use, and report findings to the director with particular responsibility for H&S. Advising on appropriate occupational health provision and reporting on adequacy of provision. Liaising with the Inspectors of the H&S Executive, Local Authorities, Fire Authorities, and any other professional body employed in the enforcement of H&S. HSMS 288 Issue 3 Issue Date 25.11.2011 Page 2 of 14

Head of H&S Administrator & PA to Head of H&S H&S Team Manager H&S Policy Manager H&S Improvement Manager Senior H&S Advisor Water (North east) Senior H&S Advisor Waste (South East) H&S Advisor (North West) H&S Advisor (South West) H&S Technical Assistant Senior H&S Advisor Support Services (Central) 2. Contents Figure 1 Health & Safety Team Structure Section Title Page No. 1 Introduction 1 1.1 PURPOSE & SCOPE 1 1.2 AUTHORITIES & RESPONSIBILITIES 1 2 Contents 3 3 Record of Changes 4 4 Company Profile 4 5 Definitions [Used throughout the HSMS] 5 6 Health & Safety Management System Structure 7 6.1 GENERAL REQUIREMENTS 7 6.2 HEALTH & SAFETY POLICY 9 6.3 PLANNING 9 6.4 IMPLEMENTATION & OPERATION 11 6.5 CHECKING 13 6.6 MANAGEMENT REVIEW 14 HSMS 288 Issue 3 Issue Date 25.11.2011 Page 3 of 14

3. Record of Changes Issue No. Date Relevant Section Brief description Added by 1 10.06.2011 All New Manual unifying H&S arrangements for all of Welsh Water business areas Henryk Freyer 2 08.07.2011 All Revised to take into account the findings of the Internal Audit of 10.06.2011 Henryk Freyer 3 25.11.2011 1.2 Details of H&S responsibilities at all levels added Henryk Freyer *This Manual is reviewed 3 years from date of last issue, unless required by changes in Company Policy or arrangements or H&S legislation 4. Company Profile Dŵr Cymru Welsh Water [Welsh Water] is owned by Glas Cymru, a single purpose company with no shareholders that is run for the benefit of customers. Under Glas Cymru s ownership, Welsh Water s assets and capital investments are financed by bonds and retained financial surpluses. Welsh Water is the sixth largest of the ten water and sewerage companies in England and Wales and employs a total of approximately 1850 staff. Welsh Water operates 81 reservoirs, 105 water treatment works and supplies an average 900 million litres of water every day through a network of 27,000km of water mains, including 532 pumping stations and 715 service reservoirs. Welsh Water also collects waste water (including surface water and highway drainage) through a network of 35,000 km of sewers, including 17,000 former private sewers and lateral drains transferred on the 1 st October 2011. Our network incorporates 1,700 sewage pumping stations, with another 1,500 stations expected to be adopted progressively between now and 2016 and 3,300 combined sewer overflows. This wastewater is treated at 832 wastewater treatment works located next to rivers and along the coast of Wales. Welsh Water has its Head Office in Nelson, Treharris, a number of smaller offices, depots, garages and Education centres and an Operational Control Call Centre at Linea, St. Mellons, Cardiff. The main sites are listed in the IMS Asset Register. Starting in April 2010, Welsh Water re-integrated operational control into the main body of its business activities and now has direct management of all its business activities. Staff (previously employed by operational partners KWSW and UUOS) have been transferred into a new enlarged and re-structured organisation, details of which are available on the Company Infozone. Dŵr Cymru Welsh Water is a registered company, registration number 2366777, with its registered office at: Pentwyn Road Nelson Treharris Mid Glamorgan CF46 6LY HSMS 288 Issue 3 Issue Date 25.11.2011 Page 4 of 14

5. Definitions [Used throughout the HSMS] Health & Safety Management System Manual 5.1 Acceptable risk Risk that has been reduced to a level that can be tolerated by the organisation having regard to its legal obligations and its own General Statement of Policy. 5.2 Audit Systematic, independent, and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which audit criteria are fulfilled. 5.3 Company Dŵr Cymru Welsh Water 5.4 Continual improvement Recurring process of enhancing the H&S Management System in order to achieve improvements in overall H&S performance consistent with the organisation s H&S policy. 5.5 Corrective action Action to eliminate the cause of a detected nonconformity or other undesirable situation. 5.6 Document Information and its supporting medium. 5.7 Hazard Source, situation, or act with a potential for harm in terms of human injury or ill health, or a combination of these. 5.8 Hazard identification Process of recognizing that a hazard exists and defining its characteristics. 5.9 Health and Safety [H&S] Conditions and factors that affect, or could affect the health and safety of employees or other workers (including temporary workers and contractor personnel), visitors, any other person in the workplace or affected by the Company s business activities. 5.10 H&S Management Representative This function is held by the H&S Policy Manager HSMS 288 Issue 3 Issue Date 25.11.2011 Page 5 of 14

5.11 H&S Management System (HSMS) Part of the Company s management systems used to develop and implement its H&S policy and manage its H&S risks. 5.12 H&S Objective H&S goal, in terms of H&S performance, that the Company sets itself to achieve and is consistent with its H&S Policy. 5.13 H&S Performance Measurable results of the Company s management of its H&S risks and its implementation of its H&S Policy, H&S Objectives and other H&S performance requirements. 5.14 H&S Policy The Company s overall intentions and direction related to its H&S performance as formally expressed by top management, published as a General Statement of Policy and signed by the Managing Director. 5.15 Ill health Identifiable, adverse physical or mental condition arising from and/or made worse by a work activity and/or work-related situation. 5.16 Incident Undesired work-related event(s) in which an injury or ill health (regardless of severity) or fatality could have occurred. This includes unsafe acts or situations, possible but no injury, or statutory visits by regulators. 5.17 Injury Physical injury incurred by any person as the result of the Company s business activities. 5.18 Interested party Person or group, inside or outside the workplace, concerned with or affected by the H&S performance of Dŵr Cymru Welsh Water. 5.19 Nonconformity Non-fulfilment of a requirement imposed by policies, standards, specifications, procedures, safe working methods, legislation etc. 5.20 Preventive action Action to eliminate the cause of a potential nonconformity or other undesirable potential situation. HSMS 288 Issue 3 Issue Date 25.11.2011 Page 6 of 14

5.21 Procedure Specified way to carry out an activity or a process to ensure H&S. 5.22 Record Document stating results achieved or providing evidence of activities performed. 5.23 Risk Combination of the likelihood of an occurrence of a hazardous event or exposure(s) and the severity of injury or ill health that can be caused by the event or exposure(s). 5.24 Risk assessment Process of evaluating the risk(s) arising from hazard(s), taking into account the adequacy of any existing controls, and deciding whether or not the risk(s) is acceptable. 5.25 Workplace Any physical location in which work related activities are performed under Welsh Water s control. This may be by Welsh Water s own employees or those of contractors or other persons acting on Welsh Water s behalf and under the control of the organisation. 6. Health & Safety Management System Structure 6.1. GENERAL REQUIREMENTS The Company has implemented a Health and Safety Management System (HSMS) based on the elements of the Occupational Health and Safety Assessment Series (OHSAS) 18001:2007. This standard defines the minimum requirements for managing Health and Safety in the Company s business activities. A HSMS based on OHSAS 18001 consolidates and enhances current arrangements in place and those being developed to take into account recent and very significant changes in the Company s organisation, structure and business areas under direct management control. Welsh Water is undergoing re-structuring and has adopted the main elements of the previous UUOS H&S Management System, registered to BS OHSAS 18001 for those business areas previously operated by UUOS and has added them to its own HSMS, also registered to BS OHSAS 18001, which it operated in that part of the business before in-sourcing and re-structuring. Welsh Water has also adopted the H&S arrangements for those operational activities previously managed by KWSW, based on earlier versions of the UUOS HSMS, but not registered to BS OHSAS 18001. As the re-structuring of the Company progresses, the previous H&S arrangements, that continue to be used in the different business areas, are being integrated into the overall HSMS that applies to the whole organisation. This is to ensure that H&S continues to be managed effectively while changes are being made. New arrangements are being developed in consultation with management and the workforce to ensure a common approach in the new organisation, which is still undergoing changes. As any part of the new overall HSMS is agreed, authorised and published, it replaces equivalent parts of the previous H&S arrangements still being used. HSMS 288 Issue 3 Issue Date 25.11.2011 Page 7 of 14

General Policy Statement HSMS Manual DCWW 18001 HSMS [Offices, Depots & Education Centres] Unified HSMS All Business Areas Operations HSMS Water & Waste Water Procedures [Process Flows] Working Instructions [H&S Procedures] Unified H&S Procedures [HSP...] H&S Procedures [HSP...] Forms & Documentation Unified Records & Forms [HSR... & HSF...] Records & Forms [HSF...] Being developed Figure 2 Development of Unified HSMS Management System Documentation. The Welsh Water HSMS is held on the Infozone, where the current versions of all documentation are available to all staff, with guidance to the different sections. The management model is based on continual improvement as shown below: HEALTH & SAFETY POLICY Best Practice Legal Requirements Corporate Requirements Health & Safety Management Manual MANAGEMENT REVIEW REVIEW of all relevant data & information PLANNING Identification of HAZARDS Assessments of RISKS Implementation of CONTROL MEASURES CHECKING & CORRECTIVE ACTION Monitoring & measurement of PERFORMANCE Reporting, investigation & correction of INJURIES, INCIDENTS & NONCONFORMANCES Keeping & disposition of RECORDS Carrying out & reporting of INTERNAL AUDITS IMPLEMENTATION & OPERATION Management STRUCTURE & RESPONSIBILITY Training for AWARENESS & COMPETENCE Employee CONSULTATION & COMMUNICATION Publishing DOCUMENTATION & DOCUMENT CONTROL Establishing SAFE OPERATING PROCEDURES Preparing INCIDENT & EMERGENCY REPONSE Figure 2. - Health & Safety Management Model HSMS 288 Issue 3 Issue Date 25.11.2011 Page 8 of 14

6.2. HEALTH & SAFETY POLICY This is published as a separate document entitled Employee Health and Safety at Work General Statement of Policy HSMS 005. 6.3. PLANNING 6.3.1 Hazard Identification, Risk Assessment & Determining Control All aspects of the Company s business activities, including work carried out off-site by Company personnel and that of other people under the control of the Company sites, are appraised for hazards, referring to :- the requirements of relevant H&S legislation existing knowledge of, and guidance on, H&S issues within the Company best practice guidelines available from the HSE and industry & trade associations specialist knowledge external to the Company Control measures are implemented to eliminate risks to H&S, or if not reasonably practicable, to reduce the risks to an acceptable level. Changes to activities and new activities are assessed and control measures put into place before being added to routine work. Risk assessments are carried out using trained and experienced personnel, and where task-specific assessments are carried out, there should be at least one person, who has particular knowledge of the activity in routine tasks and also in foreseeable non-routine activities. Risk Assessments are carried out in a hierarchy, starting with overall functional assessments of all operational and maintenance activities and general assessments for office-based activities. For each type of work activity, each risk is assessed and rated for significance using standard methodology and where risks are deemed not acceptable, control measures are taken to eliminate the hazards. Where hazards cannot be eliminated, control measures are taken to minimise the risks by physical controls, using safe working methods and personal protective equipment as a last resort to reduce risks to acceptable levels. The work activity at each site, location or as a separate task is then assessed using the relevant functional or general Risk Assessment and the input of competent persons. Any new hazards are added to the record, associated risks assessed and all relevant control measures reviewed. Where there are gaps, revised and additional control measures are agreed, recorded and implemented for that work activity. Finally, each time the work activity takes place, all factors that may affect the level of risks are assessed before the work is started. The arrangements for identifying hazards and assessing associated risks to safety and health are described in more detail in a H&S Procedure, see HSMR 001.The requirements in this document apply to all suppliers of services, who are required to carry out their contracted activities to the same standard and to supply suitable and sufficient risk assessments for the work they carry out for Welsh Water. HSMS 288 Issue 3 Issue Date 25.11.2011 Page 9 of 14

6.3.2 Legal and other Requirements The Company HSMS implements arrangements to: fully comply with applicable Acts of Parliament, regulations, by-laws, orders, standards, and codes of practice and strive towards higher standards through continuous improvement apply responsible standards where legislation does not address the matters in hand participate actively with industry in the development of appropriate legislation and regulations review and update its health & safety standards in the light of developments in technology, legislation, industry practices, and changing community expectations review and measure applicable operational controls, process, and procedures against existing and aspirational frameworks and guidance with a view to establishing the levels of compliance Welsh Water has established and maintains an Integrated Management System procedure SP(2) 08 Legal Compliance and Evaluation for identifying and recording all legislative, regulatory, and other requirements and codes of practice to which they subscribe, applicable to the health and safety aspects of activities, processes and products. This procedure and an associated Legal and other Standards Register are maintained by the IMS Manager as part of the Company s Integrated Management System. 6.3.3 Objectives and Programmes The Company has established a Health & Safety Steering Group to set Company H&S Objectives and Targets. These are set out in a strategy document, which sets out to ensure compliance with all legal requirements and to improve Welsh Water s Health and Safety performance. Progress in individual projects is discussed in meetings, minutes of which are available on the Infozone. The objectives are cascaded down to all business areas in a programme of Unit Assessments. Senior managers in each business area select the relevant parts of the Unit Assessments that they need to work on, and the levels of completion to be achieved, to implement the strategy each year. Planned and actual progress are monitored and reported monthly using the Enable software reporting system, with details of progress against targets available on the Infozone. HSMS 288 Issue 3 Issue Date 25.11.2011 Page 10 of 14

6.4. IMPLEMENTATION & OPERATION 6.4.1 Resources, Roles, Responsibility, Accountability and Authority Health and Safety is managed as shown below: Figure 3 Management Responsibilities Structure All employees have H&S roles and responsibilities referred to within their job descriptions, job ladders or personal work plans. The Health & Safety Steering Group, chaired by the Operations Director, with representatives from the Leadership Team, sets the overall approach to continuous improvement in H&S performance, sets H&S Objectives and Targets for the Company each year, monitors H&S performance throughout each year, culminating in an annual management review. 6.4.2 Competence, Training and Awareness Each employee receives the necessary training and assessment in order to be able to perform their roles and work activities safely and without risks to their health. For senior management, management and supervision at all levels, this includes understanding and awareness of effective Health & Safety management to ensure that they take it into account in all business decisions they make. HSMS 288 Issue 3 Issue Date 25.11.2011 Page 11 of 14

Training is managed by the HR Department to ensure that each member of staff receives the necessary training and experience to ensure that can carry out their duties and work activities without putting themselves at risk or anyone else who may be affected. An overall Health & Safety Training Matrix is held and maintained by HR s Talent Development Department, based on individual Personal Development Plans and, where appropriate, Job Ladders for the positions that staff hold. Each individual has a training record, that contains details of the training that person has received and copies of any relevant certificates and other evidence. These arrangements are described in the HR Department s Training procedures. 6.4.3 Communication, Participation and Consultation 6.4.3.1 Communication H&S management issues are communicated through a variety of methods to ensure that : - there is common understanding of overall Company, department and personal Health & Safety objectives, - information is passed effectively up and down the organisational structure and across all business areas and to contractors and all other interested parties, to include identified hazards and risks and the control measures used to eliminate or reduce risks to acceptable levels, - information on H&S issues are communicated effectively to external interested parties and any communications received from external sources are brought to the attention of relevant levels of management to be dealt with accordingly. These are described in HSP procedures, see HSMR 001, and IMS procedure SP(2) 09 External and Internal Communication. 6.4.3.2 Participation and Consultation All employees are encouraged to participate in identifying and reporting of hazards, unsafe conditions and unsafe acts. The procedures for risk assessment involve employees with experience and knowledge of work activities and there are multiple levels of consultation, where Union Appointed Safety Representatives meet management representatives, discuss H&S issues of concern to employees and are consulted on new and changes to H&S arrangements, policies and procedures. More details are given in HSP procedures, see HSMR 001. 6.4.4 Documentation This Health & Safety Management Manual describes the elements of the Health & Safety Management System [HSMS] operated by Welsh Water and designed around the requirements of BS OHSAS 18001:2007. This HSMS is currently based on the HSMS operated by Welsh Water before it in-sourced its main operating partners UUOS and KWSW and their HSMSs at the time of in-sourcing. This Manual and General Policy Statement now includes the whole new organisation as it continues to develop, with the relevant Welsh Water and UUOS/KWSW documented arrangements available on the Infozone, with guidance to direct staff to the appropriate versions. As new unified arrangements are agreed and published, superseded documents will be archived with full details. (see Figure 2 above in 6.1 GENERAL REQUIREMENTS). HSMS 288 Issue 3 Issue Date 25.11.2011 Page 12 of 14

6.4.5 Control of Documents HSMS documents are controlled by the IMS procedure SP(2) 04 Governance, Document and Record Control and Retention to ensure that they all: - Can be clearly identified - Are periodically reviewed, revised as necessary and approved for adequacy by authorised personnel before publication and use - Are only available as current versions on the Infozone (at all points of use) - When obsolete, are promptly removed from all points of use. Details of all HSMS documents are kept on the IMS Document Control and Issue Database. Any employee may suggest an improvement or update to any HSMS document by recording their comments and forwarding them to the H&S Management Representative. 6.4.6 Operational Control All work activities that involve significant risks, are the subject of specific legal requirements or have significant Health & Safety impacts on areas of business activity are managed under arrangements that are documented in separate procedures to ensure that Health & Safety risks are identified and eliminated or reduced to acceptable levels and that all legal requirements are met. Documented H&S procedures that were used in those business areas that were separate before the significant changes to the Company still remain valid for those areas in the new organisation, until updated and superseded by unified versions. Where new management arrangements are being developed to address Health & Safety issues for the new organisation as a whole, they are documented when finalised and published to replace previous separate documents (see Figure 2 in 6.1 GENERAL REQUIREMENTS). All H&S documentation is published on the Infozone, with links for general access to the different documents for separate business areas. Unified H&S procedures will eventually replace all separate procedures. 6.4.7 Emergency Preparedness and Response Emergency plans and procedures have been developed by the Emergency Planning Team for Welsh Water sites, including depots, offices, education centres and treatment works and networks. These are documented and tested to prevent, as far as is reasonably practicable, injury, illness, business interruption and environmental impact. More details are given in procedures listed in HSMR 001. 6.5. CHECKING 6.5.1 Performance measurement and monitoring Welsh Water has documented procedures to measure, monitor and manage performance against published objectives and targets, including the elimination of non-conformances with procedures and non-compliance with legal and other requirements and the implementation of preventive actions. Monthly reports on H&S performance are published and reported to senior management, that include statistics on accidents, incidents, Near Misses and progress against planned improvement programmes, including Unit Assessments being progressed by all parts of the business. Where equipment, including instrumentation, is used to confirm or achieve safe working environments, Welsh Water has documented procedures to ensure routine and regular, inspection, examination, testing and calibration of such equipment to ensure safety and health. HSMS 288 Issue 3 Issue Date 25.11.2011 Page 13 of 14

More details are given in procedures listed in HSMR 001. 6.5.2 Evaluation of Compliance Welsh Water has established procedures for the monitoring of compliance with legal requirements through the use of inspections, internal audits, accident and incident investigations and progress in implementing improvement programmes, where weaknesses in implementation of arrangements have been identified. More details are given in procedures listed in HSMR 001. 6.5.3 Incident investigation, nonconformity, corrective action and preventive action Welsh Water has established procedures for the reporting of all injuries, incidents, Near Misses and illness and has clear processes for investigating all such occurrences to identify root causes and to take corrective and preventive actions: - Accident (Injury) & Incident Reporting and Investigation HSP 802 The recommended corrective and preventive actions for serious incidents, such as those that are RIDDOR reportable, and those indentified in internal and external audits, are reported under the IMS procedure SP(2) 03 Corrective and Preventive Action. Details of agreed actions are recorded on the IMS Corrective Action Register [CAR], with names of responsible persons, timetables for completion and closure and indications of current status. 6.5.4 Control of Records All H&S records produced and kept by Welsh Water are controlled by the IMS procedure SP(2) 04 Governance, Document and Record Control and Retention and details are kept on the IMS Document Control and Issue Database. 6.5.5 Internal Audit The internal auditing of Welsh Water s HSMS is carried out by Business Assurance. Audit reports are agreed with the management of the areas audited, corrective and preventive actions are agreed with names and timetables, monitored and reported each month in performance reports. Details are given in the IMS procedures SP(2) Internal Auditing and SP(2) 03 Corrective and Preventive Action. 6.6. MANAGEMENT REVIEW Welsh Water reviews the effectiveness, suitability and adequacy of the Health and Safety Management System and arrangements at least annually under the IMS procedure SP(2) 02 Management Review. This is carried out by the H&S Steering Group, which also meets quarterly to review progress in meeting overall Company H&S Objectives and Targets, H&S performance and significant incidents. Minutes of the annual management review and quarterly Steering Group meetings are published and available on the Infozone. Signed... Date... Operations Director HSMS 288 Issue 3 Issue Date 25.11.2011 Page 14 of 14