2016 global environmental management system - snc … environmental... · section 1 - corporate...

2016 Global Environmental Management System

TABLE OF CONTENTS

SECTION 1 - CORPORATE ENVIRONMENTAL OBJECTIVES 2016

SECTION 2 - GLOBAL ENVIRONMENTAL MANAGEMENT SYSTEM (GEMS) 2016

APPENDICES

Appendix A - SNC-Lavalin’s Best Environmental Management Practices Appendix B - Corporate Environmental Audit Tool

Cover photographs taken from current SNC-Lavalin projects, from left to right:

• John Hart generating station, Campbell River, British Columbia: a silt curtain protects the reservoir, which is also used as the city of Campbell River’s source of potable water.

• New Champlain Bridge project, Montreal, Quebec: retention pans are extensively used to protect from spillage by hazardous materials. All work sites are near or on the St-Lawrence River, a major source of potable water in Quebec.

• Jimmy Creek Run of river power project, Toba Inlet, British Columbia: working in pristine wilderness, great care is taken to identify environmentally sensitive areas.

Last printed on December 22, 2015 Page 1 of 1

SECTION 1

Corporate Environmental Objectives 2016

CORPORATE ENVIRONMENTAL OBJECTIVES 2016

CORPORATE LEADING INDICATORS

1. Audit Programs

Objective: Ensure all SNC-Lavalin’s Sectors establish and implement an audit program for their active Controlled Sites.

Target: All Sectors’ active Controlled Sites perform Management System Audits and Environmental Compliance Audits as required in GEMS Sections 5.2.3 and 5.2.4.

Measure: (1) Number of 2016 audit programs submitted to Global Environment and Sustainability. (2) Number of audit programs revised on a quarterly basis (3) Number of audits conducted per quarter. Percentage of achieved audits versus planned for the quarter. (4) All audits identified in the audit program are completed by year end, with audit reports filed on GEMS SharePoint site.

2. Nonconformities Objective: Ensure all corrective actions are implemented in a timely manner to close all

nonconformities identified during Corporate Environmental Audits. Target: To have all nonconformities identified during a Corporate Environmental Audit closed

within 90 days. Measure: Number of closed nonconformities versus the total number of nonconformities

identified during a Corporate Environmental Audit. 3. Environmental Incident Investigations

Objective: Ensure incidents are investigated to indicate closure and prevent recurrence. Target: All Level III and High Potential incidents as well as incidents requiring external

assistance are investigated. Measure: Number of investigations versus the number Level III, high potential incidents and

incidents requiring external assistance. 4. Lessons Learned

Objective: Encourage the sharing of environmental management issues or initiatives within SNC-Lavalin’s Sectors.

Target: Minimum of one documented lesson learned per Business Unit communicated to all Sectors by the end of 2016.

Measure: (1) Lesson learned approved by the Sector’s Environmental Lead (2) Lesson learned reviewed and approved by the Environmental Leads of the other Sectors. (3) Lesson learned published by Global Environment and sustainability.

5. Site Visits Objective: Demonstrate visible environmental leadership. Target: Senior Managers (e.g. Group Presidents, Executive Vice Presidents, Managing

Directors, Senior Vice Presidents, General Managers and Project Managers) conduct at least two visits which have evidence of an environmental focus at every Controlled Site by the end of 2016.

Measure: Number of documented Senior Managers site visits.

6933.3.1-EN-2016 Last printed on December 21, 2015 Page 1 of 2

CORPORATE LAGGING INDICATORS

1. Trends towards zero Level II incidents;2. Target of zero Level III incidents;3. Zero notices of violation or other governmental enforcement action.

6933.3.1-EN-2016 Last printed on December 21, 2015 Page 2 of 2

SECTION 2

Global Environmental Management System (GEMS)

2016 GLOBAL ENVIRONMENTAL

MANAGEMENT SYSTEM

6901-EN-REV04 Last printed on December 21, 2015 Page 1 of 32

TABLE OF CONTENTS 1 SCOPE ................................................................................................................................. 5

1.1 Introduction ...................................................................................................................................... 5 1.2 Application ........................................................................................................................................ 5 1.3 References ....................................................................................................................................... 5 1.4 How to use this Document ............................................................................................................... 7 1.5 Terms and Definitions ...................................................................................................................... 7

2 POLICY ................................................................................................................................ 9 2.1 Code of Ethics and Business Conduct ............................................................................................. 9 2.2 Environmental Policy ........................................................................................................................ 9 2.3 Approach to Environment................................................................................................................. 9 2.4 Leadership ..................................................................................................................................... 10

3 PLAN .................................................................................................................................. 11 3.1 Environmental Aspects Identification and Assessment to Determine Controls ............................. 11

3.1.1 Environmental Aspects Impacts Register ............................................................................ 11 3.1.2 Project Risk Register ............................................................................................................ 12

3.2 Compliance Obligations Identification ............................................................................................ 12 3.3 Objectives ...................................................................................................................................... 13

4 DO ...................................................................................................................................... 14 4.1 Roles and Responsibilities ............................................................................................................. 14

4.1.1 President & CEO .................................................................................................................. 14 4.1.2 Executive and Senior Management (Sector Presidents and Business Units Heads i.e.

Executive Vice Presidents, Managing Directors and Senior Vice-President & General Managers) ............................................................................................................................ 15

4.1.3 VP Global Environment & Sustainability .............................................................................. 15 4.1.4 Sector Environmental Leads ................................................................................................ 15 4.1.5 BUs HSSE Managers ........................................................................................................... 16 4.1.6 Risk Managers ..................................................................................................................... 16 4.1.7 Project Managers ................................................................................................................. 16 4.1.8 Construction/Operation Managers ....................................................................................... 17 4.1.9 Project Environmental or HSSE Managers/Coordinators .................................................... 17 4.1.10 All SNC-Lavalin Employees .................................................................................... 17

4.2 Training, Awareness and Competence .......................................................................................... 18 4.2.1 Induction Session ................................................................................................................. 18 4.2.2 Specific Environmental Training ........................................................................................... 19

4.3 Internal and External Communication ............................................................................................ 19 4.3.1 Internal Communication ....................................................................................................... 19 4.3.2 Meetings ............................................................................................................................... 19 4.3.3 External Communication ...................................................................................................... 20

4.4 Documented Information ................................................................................................................ 20 4.5 Operational Control ........................................................................................................................ 20

4.5.1 Environmental Control Procedures ...................................................................................... 20 4.5.2 Contractor Management....................................................................................................... 21


4.5.3 Job Environmental Analysis ................................................................................................. 21

4.6 Emergency Preparedness and Response ..................................................................................... 21 4.7 Positive Incentive Program ............................................................................................................ 22

5 CHECK ............................................................................................................................... 24 5.1 Performance Evaluation ................................................................................................................. 24

5.1.1 Environmental Indicators Definitions for Corporate Tracking............................................... 24 5.1.2 Environmental Incident Notification and Investigation ......................................................... 27 5.1.3 Monitoring Program .............................................................................................................. 28 5.1.4 Instruments Calibration ........................................................................................................ 29

5.2 Evaluation and Assessments ......................................................................................................... 29 5.2.1 Inspection Program .............................................................................................................. 29 5.2.2 Self-Evaluation ..................................................................................................................... 29 5.2.3 Management System Audit .................................................................................................. 30 5.2.4 Environmental Compliance Audit ......................................................................................... 30 5.2.5 Corporate Environmental Audit ............................................................................................ 30

5.3 Non-conformity and Corrective Action ........................................................................................... 31 5.4 Visible Environmental Leadership .................................................................................................. 31

6 ACT .................................................................................................................................... 32 6.1 Corporate Management System Review ....................................................................................... 32

6.1.1 Resource Allocation Review................................................................................................. 32 6.2 Sector Management System Review ............................................................................................. 32


1 SCOPE

1.1 INTRODUCTION This Global Environmental Management System (GEMS) is the foundation for effective development, implementation, and improvement of environmental practices within SNC-Lavalin to ensure our activities are conducted in a manner that minimizes both corporate and individual operational risks and financial liabilities. It is the governing corporate document that outlines expectations for all SNC-Lavalin Business Units (BUs) in order to support the “One Company” approach with respect to Environment.

SNC-Lavalin expects business partners, such as associate companies or joint ventures where we do not have full environmental responsibility, as well as principal contractors, suppliers with whom we have a substantial involvement, to conform to equivalent Environmental Management Systems. SNC-Lavalin will inform business partners of these standards, policies and procedures, and work with them where appropriate to support their adoption of practices consistent with our own.

SNC-Lavalin’s goal is to achieve and maintain environmental excellence by incorporating strategies, policies, standards, processes, and procedures that promote sound environmental practices and/or environmental stewardship throughout all business activities.

1.2 APPLICATION All SNC-Lavalin BUs and their Controlled Sites shall implement or demonstrate conformance to the GEMS as well as applicable local environmental laws, regulations and other requirements. GEMS shall be applied as a whole and not limited to individual sections.

For non controlled sites in which the client, a joint venture partner or other entity assumes site responsibility, or when SNC-Lavalin assumes minority equity participation, the relevant Business Unit shall ensure that the managing entity implements a robust Environmental Management System (EMS) which ensures compliance with applicable laws and best environmental practices.

For all new projects and activities, GEMS requirements shall be taken into consideration as early as the proposal stage and at all preliminary stages, to ensure sufficient resources are allocated and appropriate environmental performance objectives are met.

All contractors and subcontractors’ activities undertaken on SNC-Lavalin Controlled Sites shall also conform to GEMS requirements as well as applicable local environmental laws and regulations.

1.3 REFERENCES GEMS is designed to achieve continuous improvement throughout Plan-Do-Check-Act cycles. It is based on and is compatible with ISO 14001.


GEMS provides high-level guidelines; further details can be found in the referenced documents.


1.4 HOW TO USE THIS DOCUMENT Corporate Environmental documentation is available on the GEMS SharePoint site, available online at:

http://csc.snclavalin.com/sites/cop/CoP_GEMS/Documents/Forms/AllItems.aspx

Modifications to GEMS are made annually to ensure it is up to date.

GEMS is a controlled document. Whilst it may be printed, the electronic version posted on the GEMS SharePoint site is the only controlled copy.

1.5 TERMS AND DEFINITIONS 4Rs – Stands for Reduce, Reuse, Recycle and Resource recovery;

ALARP – As low as reasonably practicable;

BEMP – Best Environmental Management Practices refer to methods or techniques found to be the most effective and practical in achieving pollution prevention;

BU – Stands for Business Unit;

Complaints – A claim of dissatisfaction brought to SNC-Lavalin by any interested party (i.e.: clients, communities, general public, etc.);

Compliance Obligations – Refers to requirements that SNC-Lavalin has to or chooses to comply with, including but not limited to legislation, contractual requirements, codes of practices, voluntary standards, etc;

Contractor – Means any individual who is not a client or employee and who has a contractual relationship with SNC-Lavalin. This includes consultants, inspectors, Subcontractors and suppliers (altogether counted when on an SNC-Lavalin Controlled Site);

Controlled Site – Means a location (office, construction site, field operation, facility in operation or maintenance) where SNC-Lavalin has full and contractual environmental responsibility;

ECA – Stands for Environment Compliance Audit, an audit to evaluate environmental performance and environmental management practices against legal and other requirements;

EIA – Stands for Environmental Impact Assessment;

EIRP – Stands for Environmental Incident Response Plan;

Employee – Means regular, occasional, temporary, contractual, full or part-time employee working at all levels of SNC-Lavalin;

EMS – Environmental Management System refers to part of SNC-Lavalin’s overall management system that includes organizational structure, planning activities, responsibilities, resources for developing, implementing, achieving, reviewing and maintaining the Environmental Policy Statement;


http://csc.snclavalin.com/sites/cop/CoP_GEMS/Documents/Forms/AllItems.aspx

Environment – Refers to surroundings in which Controlled Sites operates, including air, water, land, natural resources, flora, fauna, humans and their interrelationships;

Environmental Aspect – Means any element of Controlled Site’s activities that can interact with the environment;

Environmental Impact – Means any change to the environment, whether adverse or beneficial, wholly or partially resulting from a project’s Environmental Aspect;

Environmental Incident – Means an unexpected occurrence, failure or loss, with the potential for harming the environment. It also encompasses an uncontrolled, unplanned or accidental release, or release or action taken in contravention of applicable laws, regulations or orders issued by government;

EVP – Stands for Executive Vice President;

GEMS – Stands for Global Environmental Management System;

GES – Stands for Global Environment and Sustainability;

GHS – Stands for Global Health and Safety;

H&S – Stands for Health and Safety;

HSSE – Stands for Health, Safety, Security and Environment;

ISO – Stands for International Organization for Standardization;

JEA – Stands for Job Environment Analysis;

JSA – Stands for Job Safety Analysis;

Prime Contractor – Party or designate with primary responsibility whether legislative or contractual for Environment;

Project – Refers to any design, construction or operation activity;

SEA – Significant Environmental Aspect refers to an environmental aspect that has or can have a significant Environmental Impact;

Sector – Refers to each of Infrastructure, Mining & Metallurgy, Oil & Gas and Power sectors;

Subcontractors – Means a Contactors’ contractor;


2 POLICY

2.1 CODE OF ETHICS AND BUSINESS CONDUCT The Code of Ethics and Business Conduct sets the tone for the entire organization for how we perform on a daily basis in everything we do as a company.

http://eww/cw_Corporate/internal-audit/docs/1003_en.pdf

2.2 ENVIRONMENTAL POLICY SNC-Lavalin’s Corporate Environmental Policy provides an overview of this management system and includes a statement signed by the President and CEO which shall be communicated to all our Employees and people working on our behalf, and made available to all interested parties.

Should a Controlled Site operate under a registered ISO 14001 EMS, that system’s policy may replace SNC-Lavalin’s Corporate Environmental Policy Statement.

http://eww.snclavalin.com/house-of-policies/corporate_policy_list_en.asp

2.3 APPROACH TO ENVIRONMENT At SNC-Lavalin we strive to implement GEMS and achieve the following:

• Ensure all projects are carried out according to SNC-Lavalin’s Environmental Policy Statement;

• Implement EMS to ensure our work is conducted in an environmentally sound manner;

• Ensure all Employees understand their environmental responsibilities and receive the training required to properly conduct their work;

• Comply with all applicable Compliance Obligations;

• Implement preventive strategies to protect the environment;

• Apply the principle of Reduce, Reuse, Recycle and Resource recovery (4Rs) in all our activities;

• Work with contractors and suppliers to demonstrate and share our commitment to preserving the environment;

• Pursue continuous improvement in our environmental performance.


http://eww/cw_Corporate/internal-audit/docs/1003_en.pdf

http://eww.snclavalin.com/house-of-policies/corporate_policy_list_en.asp

2.4 LEADERSHIP The GEMS and all environmental initiatives are meant to ensure responsible environmental stewardship by the concerted actions of all personnel. As an employer, SNC-Lavalin shall demonstrate leadership and commitment with respect to GEMS by:

• Taking accountability for the effectiveness of GEMS;

• Ensuring the integration of GEMS requirements into the business processes;

• Ensuring that the resources needed for environmental management are available;

• Communicating the importance of conforming to GEMS requirements;

• Ensuring GEMS achieves its intended outcomes;

• Directing and supporting persons to contribute to the effectiveness of GEMS;

• Promoting continual improvement;

• Supporting relevant management roles to demonstrate their leadership as it applies to their areas of responsibility.

The President and Chief Executive Officer of SNC-Lavalin is responsible for implementing and monitoring SNC-Lavalin’s Environmental Policy. All employees and persons working on SNC-Lavalin’s behalf must share this commitment and are empowered to speak up and act to ensure that our sustainability commitments are met.


3 PLAN

3.1 ENVIRONMENTAL ASPECTS IDENTIFICATION AND ASSESSMENT TO DETERMINE CONTROLS

SNC-Lavalin’s environmental management approach is systematic, and responsive to the dynamic nature of Environmental Aspects. This is accomplished by having all Controlled Sites identify and evaluate the Environmental Aspects generated by their activities to effectively eliminate and/or control the resulting Environmental Impacts.

To help identify Environmental Aspects related to activities being undertaken by SNC-Lavalin, Controlled Sites shall first refer to the Environmental Impact Assessment (EIA) or other similar document. In cases where no such document exists, the following typical Environmental Aspects shall be assessed:

• Atmospheric emissions generation; • Noise and vibration generation; • Wastewater generation; • Water consumption; • Waste generation; • Energy consumption; • Petroleum products consumption; • Use and consumption of chemicals and gases; • Other natural resources consumption; • Work in sensitive areas such as watercourse, forest, protected areas (RAMSAR sites,

archaeological sites, marine protected areas, natural parks, urban and populated environments, etc.).

It should be noted that the above list is not meant to be exhaustive. Controlled Sites are responsible for thoroughly identifying, reviewing and assessing the Environmental Aspects of their Projects. Environmental Aspects identification shall be to the appropriate level of detail for the activity, from proposal preparation to completion of the project, management of an office location or facilities in operation and/or maintenance.

Following the Environmental Aspects identification, Environmental Control Procedures shall be put in place to ensure that all Environmental Impacts are appropriately controlled to levels as low as reasonably practicable or as set out in the Environmental Assessment, or according to the applicable permits and authorizations (see Section 4.5.1).

3.1.1 Environmental Aspects Impacts Register

An active Environmental Aspects Impacts Register shall be maintained to determine the Significant Environmental Aspects (SEA) and their control methods. Controlled Sites shall implement and maintain an Environmental Aspects Impacts Register in consultation with


relevant activity team members. Criteria used to determine SEAs shall be documented. The Environmental Aspects Impacts Register shall be reviewed whenever there are changes in the activities so that SEAs are reflected at all times.

The Environmental Aspects Impacts Register shall at a minimum contain the following information:

• Activities; • Environmental aspects associated with the activities; • Environmental impacts resulting from the aspects; • Assessment of SEAs; • Reference to control measures.

Environmental Aspects Impacts register are provided online on the GEMS SharePoint site.

3.1.2 Project Risk Register

For most Controlled Sites, the same environmental risks are recurrent and can be managed appropriately using the processes outlined in GEMS. However, some Controlled Sites may be in locations where unusually sensitive environments are present. Examples include (but are not limited to) densely populated areas, work near water, work in or near protected areas, work which can have an impact on protected or endangered species. In such instances, the consequence of an environmental incident may be significantly higher than on most Controlled Sites. This would require extra care or precautions to manage the Significant Environmental Aspects so as to ensure compliance with GEMS requirements and all applicable environmental obligations. In order to enable SNC-Lavalin to assess the overall environmental risk profile of its activities, it is these particular risks which must be entered into the Corporate Project Risk Register Stature.

Project Environmental Manager or designated person shall inform the Project Risk Manager or designated person of these particular environmental risks identified in the Environmental Aspects Impacts Register so that he or she can incorporate them into Stature.

The Risk Management Guideline RMG 14 titled Criteria for which Environmental Risks should be included in Stature can be consulted on the GEMS SharePoint site.

3.2 COMPLIANCE OBLIGATIONS IDENTIFICATION All Controlled Sites shall be able to demonstrate knowledge of all applicable Compliance Obligations. These obligations may arise from mandatory requirements, such as laws, regulations, by-laws, permits/license conditions, certificate of authorization conditions or voluntary commitments, such as contractual requirements, industry standards, principle of good governance and community and ethical standards, etc.

In all cases, Controlled Sites shall be guided by the principles of pollution prevention and the 4R principle of Reduce, Reuse, Recycle, and Resource Recovery.


http://csc.snclavalin.com/sites/cop/CoP_GEMS/Documents/Forms/AllItems.aspx?RootFolder=%2fsites%2fcop%2fCoP%5fGEMS%2fDocuments%2f8%20STATURE&FolderCTID=&View=%7bECB48D96%2dA7E5%2d4E2E%2d892E%2dC3B55250AB24%7d

As appropriate, each BU shall ensure:

• A process is established to ensure that permitting requirements are captured early in planning process;

• A Compliance Obligations Register is maintained at all Controlled Sites to identify all environmental obligations. This information shall be communicated to all relevant personnel and other parties as applicable;

• The Compliance Obligations Register shall be reviewed at least annually or whenever amendments to environmental obligations are made;

• Compliance Obligations are met by all Controlled Sites, (see Environmental Compliance Audit in Section 5.2.4).

The Compliance Obligations Register shall include, at a minimum, a description of the obligation, a reference to the obligation’s source and associated Environmental Aspects identified in the Environmental Risk Register.

Examples of Compliance Obligation Registers are provided online on the GEMS SharePoint site under “Examples Cited in GEMS”.

3.3 OBJECTIVES Environmental protection and management is a crucial part of the strategic planning process. Global Environment and Sustainability (GES) establishes, implements, and maintains annual objectives to ensure consistency with the Environmental Policy Statement commitments and continual improvement of environmental performance, as well as the effectiveness of the GEMS.

These objectives consider legal, Significant Environmental Aspects, technology, financial, operational and business requirements.

Progress towards achieving established objectives and targets is monitored by GES and reported to the President and CEO on a quarterly basis.

Sectors and BUs shall comply with the specific objectives and targets set annually by GES. Moreover, each BU may track its progress towards additional environmental objectives and targets based upon their specific needs (e.g. ISO 14001, LEED, ENVISION certifications, etc.).

Corporate Environmental Objectives 2016 (6933.3.1-EN-2016) are presented in Section 1 of this document.


http://csc.snclavalin.com/sites/cop/CoP_GEMS/Documents/Forms/AllItems.aspx?RootFolder=%2fsites%2fcop%2fCoP%5fGEMS%2fDocuments%2f3%2e%20Examples%20Cited%20in%20GEMS%5fExemples%20cit%c3%a9s%20dans%20le%20SMGE%20%2d%202016&FolderCTID=&View=%7bECB48D96%2dA7E5%25

http://csc.snclavalin.com/sites/cop/CoP_GEMS/Documents/Forms/AllItems.aspx?RootFolder=%2fsites%2fcop%2fCoP%5fGEMS%2fDocuments%2f2%2e%20Corporate%20Env%2e%20Objective%202016%2fEnglish&FolderCTID=&View=%7bECB48D96%2dA7E5%2d4E2E%2d892E%2dC3B55250AB24%7d

4 DO

4.1 ROLES AND RESPONSIBILITIES Responsibility for successful implementation of GEMS on Controlled Sites rests with site line management – executives, managers, supervisors.

GEMS environmental approach is communicated by the President and CEO, through to the Sectors, and then to the BUs and site/office management. The following organizational structure illustrates how reporting occurs and the existing interface between Sectors, BUs and upper management:

4.1.1 President & CEO

• Approves the Environmental Policy Statement and standards for the corporation; • Takes ultimate accountability for all Environmental Aspects; • Reviews organizational environmental performance and provides clear direction; • Demonstrates visible environmental leadership.


4.1.2 Executive and Senior Management (Sector Presidents and Business Units

Heads i.e. Executive Vice Presidents, Managing Directors and Senior Vice-President & General Managers)

• Gives formal endorsement of the GEMS within their entity; • Reviews organizational environmental performance and provides clear direction for their

Sector or BU; • Demonstrates visible environment leadership; • Escalates communication of all Level III incidents within 24 hours of occurrence to the

President and CEO.

4.1.3 VP Global Environment & Sustainability

• Proposes to the President & CEO and to senior management the Environmental Policy Statement and Standard Operating Procedures to be enacted;

• Gives GEMS formal approval; • Reports environmental performance metrics as official records to demonstrate

environmental compliance and to continually improve environmental performance, to the Integrated Management Systems EVP;

• Evaluates annually the effectiveness of environmental policies, Standard Operating Procedures, and tools. Provides input and recommendations for improvements or changes;

• Communicates industry best practices, instructions, and develops materials that have broad application throughout the organization;

• Communicates lessons learned throughout the organization; • Conducts audits and reviews at Controlled Sites as required; • Maintains a central environmental database for reporting and storing data for ongoing

reporting requirements.

4.1.4 Sector Environmental Leads

• Communicate GEMS requirements to the BUs; • Provide assistance to BUs and projects regarding environmental staffing as required to meet

Corporate commitments; • Ensure that BUs and Controlled Sites respect all Corporate environmental and sustainability

requirements, with a particular focus on regulatory environmental compliance; • Ensure that BUs and Controlled Sites have proper environmental risk assessment

processes; • Ensure that BUs and Controlled Sites have environmental audit programs; • Ensure that audit findings are addressed in a timely manner; • Ensure that BUs and Controlled Sites report on GEMS’ lagging and leading indicators; • Maintain a mapping of environmental resources available in the Sector; • Collect BUs information pertaining to Sector’s Management Review.


4.1.5 BUs HSSE Managers

• Report to their respective BU Head and also respects the dotted line relationship to the VP Global Environment and Sustainability for standardized “One Company” Environment processes and standards;

• Ensure all SNC-Lavalin Controlled Sites are fully compliant with client requirements, current corporate standards and regulations, and laws governing the project or site jurisdiction;

• Oversee the implementation of GEMS at the BU level supporting the “One Company” approach;

• Ensure that appropriate resources are allocated to projects in order to meet performance requirements;

• Organize management reviews of the BU Environmental Management System; • Ensure all relevant managers and personnel are provided the appropriate environmental

training and instructions relevant to their tasks and duties; • Ensure investigation reports are submitted to VP Global Environment and Sustainability in a

timely manner; • Ensure that data regarding lagging performance indicators is uploaded to the Corporate

HSES database by the tenth of the following month; • Ensure that data regarding leading indicators are filed on GEMS Sharepoint site; • Escalates communication of all Environmental Incidents requiring external assistance and

High Potential Incidents within 24 hours of occurrence to the VP Global Environment and Sustainability.

4.1.6 Risk Managers

• Ensure SEAs are entered in Stature at the proposal stage and updated through to project completion.

4.1.7 Project Managers

• Make determination as early as possible in the proposal or preliminary stages of a project as to whether or not the project is considered a Controlled Site;

• Facilitate site implementation of the GEMS; • Ensure sufficient environmental resources allocation; • Interface with client representatives to ensure ongoing input to the environmental processes

are incorporated and that satisfaction with the results is achieved; • Ensure training requirements are fulfilled; • Periodically attend HSE meetings and ensures correctives actions are implemented; • Establish interface with governing regulatory authorities; • Participate in environmental incident investigations and ensures implementation of

corrective actions following a major incident; • Arrange regular Contractor environmental review; • Review Corporate compliance audits; • Provide visible environmental leadership.


4.1.8 Construction/Operation Managers

• Are accountable for the implementation of GEMS on site; • Ensure that every contractor and its subcontractors realizes the works (at their expenses)

required for the implementation of GEMS on site; • Review JEAs, inspections and incident report and ensure actions are closed out in the

agreed timeframe; • Ensure that an environmental induction training session addressing GEMS requirements is

given to all Employees and people working on SNC-Lavalin’s behalf arriving at site; • Attend HSE meetings and implement action plans; • Actively involved in Corporate audits; • Implement corrective actions resulting from all inspections and audits; • Provide visible environmental leadership.

4.1.9 Project Environmental or HSSE Managers/Coordinators

• Support and monitors site compliance to GEMS; • Provide documentation and support to SNC-Lavalin managers and supervisors on site; • Maintain current daily knowledge of all active areas, records and reports as per

environmental requirements; • Ensure that contractors attend environmental training and have competent resources; • Ensure the necessary supply, maintenance, operation and availability or environmental

equipment such as spill kits, secondary containment, etc.; • Conduct regular environmental site inspections; • Conduct self-evaluations; • Participate in JEAs and maintains records; • Interrupt work if necessary and notifies the Contractor accordingly; • Inform Construction / Operation Manager of environmental issues to ensure compliance

obligations are met; • Conduct environmental incident investigations and follow-up on corrective actions; • Assist the Construction / Operation Manager in the implementation of corrective actions; • Participate in meetings in which environmental topics are discussed; • Communicate Significant Environmental Aspects using posters, notices, etc.; • Assist Contract Administrators’ with Contractors’ contracts so that appropriate

environmental clauses are included.

4.1.10 All SNC-Lavalin Employees

• Be familiar with, Environmental Policy Statement, GEMS’ objectives and requirements; • Participate in environmental training and meetings as required; • Take time to understand Environmental Aspects relevant to their work and managing their

impacts; • Report any environmental incidents to immediate supervisor;


• Request explanations from their immediate superior for environmental measures when

necessary; • Comply with environmental indications and signs; • Be willing to STOP WORK and report activities that have a negative impact on the

environment, regardless of business pressure. Examples include uncontrolled work in watercourses and activities which create releases of hazardous products into the environment;

• Be an example to others and show how correct environmental precautions are taken using one’s actions.

4.2 TRAINING, AWARENESS AND COMPETENCE SNC-Lavalin’s approach to environmental training and competency is to promote continuous improvement. SNC-Lavalin leadership believes in environmental protection as a core value and encourages its personnel and people working on its behalf to work as environmental champions.

All BUs shall ensure that its personnel and people working on its behalf are adequately trained and competent to perform their jobs. In the absence of full competency, sufficient supervision shall be in place.

To ensure success:

• Those who authorize work (managers and supervisors) shall ensure that all personnel are competent (i.e. have the necessary training, qualifications, and experience) for their assigned tasks. At an individual level, environmental competence is defined by:

o Managers – Ability to lead people through the SNC-Lavalin Corporate environmental vision;

o Supervisors – Possessing strong people skills to correct and reward positive behaviour and reinforce compliance;

o All Personnel – Recognize Environmental Aspects/Impacts; take appropriate action.

• Training documentation and records shall be readily available.

4.2.1 Induction Session

All Employees and Contractor personnel shall receive an environmental induction prior to commencing on site work on behalf of SNC-Lavalin to ensure they are capable of performing work in a manner consistent with environmentally safe practices and with a priority placed on due diligence. Specific environmental training for particular projects or office locations shall be added as required to ensure competency and the respect of environmental objectives.

The orientation session shall, at a minimum, cover:

• SNC-Lavalin’s Environmental Policy Statement; • Responsibilities with respect to environmental matters;


• Applicable Compliance Obligations (legal and other requirements); • Possible consequences of not conforming to Compliance Obligations; • Significant Environmental aspects/impacts; • Environmental objectives; • Environmental protection measures; • Environmental incident response processes.

For all visitors who will be accompanied by SNC-Lavalin’s personnel at all time, a brief environmental orientation shall also be included in the HS orientation.

Examples of Environmental Induction Sessions are provided online on the GEMS SharePoint site under “Examples Cited in GEMS”.

4.2.2 Specific Environmental Training

Controlled Sites shall provide specific environmental training to relevant personnel in order to meet site specific requirements.

Examples of such training would be:

• Transportation of Dangerous Goods; • Endangered species identification and habitat protection measures; • Limitation of nuisance in urban setting (lights, dust, noise, vibrations, etc.); • Proper storage of material in damp climates to avoid spoilage or mildew proliferation; • Specific clients requirements (e.g. LEED and ENVISION certifications); • Environmental inspections and auditing.

4.3 INTERNAL AND EXTERNAL COMMUNICATION

4.3.1 Internal Communication

Internal communication shall ensure that environmental information is disseminated to all relevant personnel and that all personnel feel they are able to participate in GEMS through available communication channels. Hence, SNC-Lavalin encourages all personnel and managers to engage in discussions and dialog that promote recognition and understanding Environmental Aspects/Impacts as well as the appropriate mitigation, behaviours, and responses for every Controlled Sites.

4.3.2 Meetings

Information on environmental management shall be communicated to all groups and personnel in a prompt and effective manner. Environmental matters including nonconformities and opportunities for improvement identified during inspections and audits shall be incorporated into regular project meetings.



4.3.3 External Communication

Controlled Sites shall externally communicate information relevant to environmental matters in accordance with SNC-Lavalin Global Corporate Communications requirements and as required by Compliance Obligations.

4.4 DOCUMENTED INFORMATION Controlled Sites shall implement document management systems so as to ensure that:

• Relevant personnel have access to the most recent and approved versions; • Only those having authorization can create, modify, or delete relevant documents; • Documents identification and description are appropriate (e.g. title, date, author, reference

number, etc.); • Documents are reviewed and approved for suitability and adequacy. A revision history index

shall be present on documents; • Relevant records, e.g. Environmental Aspects Impacts Register, Compliance Obligations

Register, training log, monitoring results, minutes of meetings, communication with external parties, inspection and audit reports, environmental incident notification and investigation reports, non-conformities, corrective action, preventive actions register, etc. are stored and readily available to demonstrate compliance to the requirements of the GEMS, legislation, and clients;

• Obsolete or superseded documents are removed from use; • Quality and consistency in documentation, style, appearance, and language is maintained

for all environmental documents.

Should a client require that its document control processes be respected, a Project may follow those processes instead of SNC-Lavalin’s.

4.5 OPERATIONAL CONTROL All SEAs shall be managed by adopting sound environmental management practices.

4.5.1 Environmental Control Procedures

SNC-Lavalin’s Best Environmental Management Practices (6945.2.1-EN-REV01) to mitigate environmental impacts resulting from typical SEAs are presented in Appendix A.

All Controlled Sites shall include these Best Environmental Management Practices (BEMPs) into their environmental control procedures unless legal or other requirements impose more stringent controls.

In unique circumstances, e.g., where SNC-Lavalin’s BEMPs cannot be fully achieved; alternative control measures shall be approved by an environmental specialist.

Sites having unique Environmental Aspects for which the existing BEMPs are not sufficient shall develop their own specific environmental control measures and have them approved by an environmental specialist.


http://csc.snclavalin.com/sites/cop/CoP_GEMS/Documents/Forms/AllItems.aspx?RootFolder=%2fsites%2fcop%2fCoP%5fGEMS%2fDocuments%2f5%2e%20Best%20Environmental%20Management%20Practices%202016&FolderCTID=&View=%7bECB48D96%2dA7E5%2d4E2E%2d892E%2dC3B55250AB24%7d

Controlled Sites which are office locations shall implement measures to manage their Significant Environmental Aspects.

Posters highlighting SEAs and their control measures shall be displayed in a prominent location on all SNC-Lavalin’s Controlled Sites.

Examples of Posters highlighting SEAs and their control measures are provided online on the GEMS SharePoint site under “Examples Cited in GEMS”.

4.5.2 Contractor Management

It is imperative that contracted services be structured in a manner that maintains the integrity of SNC-Lavalin’s Environmental Policy Statement. Although work is contracted out, SNC-Lavalin continues to retain responsibility for environmental incidents on its Controlled Sites. SNC-Lavalin contract management personnel shall ensure that appropriate environmental clauses are included in the Contractor’s contract to ensure proper implementation and execution of GEMS.

BUs, on their Controlled Sites, shall have robust systems to ensure all Contractors are fulfilling their respective environmental responsibilities from project initiation to completion.

4.5.3 Job Environmental Analysis

For specific activities to be performed, a Job Environmental Analysis (JEA) shall be completed in order to ensure that environmental risks are assessed and that the related environmental control measures will be implemented for each task or activities whenever relevant. The existing H&S JSA can be expanded to address SEAs to accomplish the JEA.

All relevant team members shall STOP WORK and reassemble for another JEA if conditions or personnel changes occur during the work shift.

Examples of JEA tools are available on the GEMS SharePoint site under “Examples Cited in GEMS”.

4.6 EMERGENCY PREPAREDNESS AND RESPONSE In the event of an environmental incident, Controlled Sites shall be adequately prepared to react in an efficient and effective manner in order to protect people, the community, the environment, as well as the client’s and the company’s assets.

In the event of a spill, the steps to protecting the environment once the people and community are protected shall consist of:

• Ceasing the activity causing the spill; • Containing the contaminant as much as possible to prevent its migration; • Recovering the contaminant; • Cleaning-up and/or decontaminating the site;




• Disposing of the contaminant and contaminated materials in conformance with applicable

regulations; • Notifying governmental authorities as required by the local legislation.

For all other environmental incidents, the steps shall consist of:

• Ceasing the activity causing the environmental incident; • Applying appropriate remedial actions; • Notifying governmental authorities as required by the local legislation.

Incident notification and investigation reports shall be produced in a timely manner, and effectively communicated to all affected parties as specified in Section 5.1.2.

All BUs Controlled Sites shall have a comprehensive Environmental Incident Response Plan (EIRP). At a minimum it shall contain:

• Roles and Responsibilities; • Plan of the site indicating hazardous substances and spill kits locations; • Internal and external contact list; • Implementation instructions; • Provisions to conduct at least an annual environmental incident drill (documented tabletop

exercises are acceptable).

An adequate number of trained environmental incidents wardens shall be present on-site during all working hours.

Examples of Environmental Incident Response Plan are provided online on the GEMS SharePoint site under “Examples Cited in GEMS”.

4.7 POSITIVE INCENTIVE PROGRAM In order to ensure that all Employees are engaged and committed to the highest level of safety and environmental protection, SNC-Lavalin strongly encourages using Positive Incentive Program on SNC-Lavalin Controlled Sites.

This strategy is designed to include all Employees, including senior management, and encourage positive interactions and immediate feedback. This system focuses on rewarding proactive environmental risk management behaviour inputs in order to improve outputs.

Experience shows any incentive program becomes effective and reinforces behaviour when it meets three criteria:

1) Desirable: Reward schemes are attractive for the target demographic;

2) Attainable : Possible for anyone to achieve a reward;

3) Associating: Must be immediately tied to the specific identified behaviour.



Examples of the use of positive incentive cards to reward good environmental behaviour include:

• Exemplary implementation of the 4Rs principle; • Exemplary implementation of a pollution prevention solution; • Actions to protect a sensitive environment which go beyond applicable requirements; • Reporting and cleaning up small spills; • Identifying and reporting on environmental risks in the field; • Initiatives to protect plants and wildlife; • Using special measures to protect watercourses; etc.


5 CHECK

5.1 PERFORMANCE EVALUATION

5.1.1 Environmental Indicators Definitions for Corporate Tracking

Table 1: Environmental Lagging Indicators

1 “When in doubt, pick the highest level of incidents” 2 Hazardous materials are characterized by their property, being one or more of the following: Explosive, corrosive, flammable, toxic, oxidizing, irritant, environmental hazards. Hazardous chemicals could be but are not limited to: solvents, paints, strong acids or bases, fertilizers, pesticides, detergents, disinfectants, PCBs. 3 A 55 US gallon drum is approximately 208 liters.

Type of Environmental Incidents1

Description

Level I

Situation involving ALL of the following : • No evidence of health risk; • Can be controlled immediately; • Minimal effect on soil or air quality; • Limited effect on local ecosystem; • No risk of contamination of sensitive areas or protected species; • No effect on water well or extraction point for human consumption; • No significant cleanup required other than removal of contaminated material

using spill kit and resources available on site; • Hydrocarbon or hazardous material2 spill of less than 25 liters to land.

Level II

Situation involving ANY of the following: • Poses minor health risk or necessitates precautionary evacuation or fire

department intervention; • Effect on water even if minimal; • Significant but local effect on soil or air quality; • Significant but localized damage to aquatic or terrestrial ecosystem; • Risk of contamination of sensitive areas or protected species; • Effect on water well or extraction point for human consumption which does not

result in closure (based on analytical results); • Cleanup by specialized external resources (excavation, pumping, etc.); • Prosecution unlikely; • Hydrocarbon or hazardous material spill equal or greater than 25 liters and less

than 200 liters3 to land; • Hydrocarbon or hazardous material spill less than 100 liters to water.


Controlled Sites shall be responsible for entering all Environmental Incidents (lagging indicators) into the HSE database on a monthly basis. All data must be entered by the tenth of the following month (i.e. data for January must be entered in the database by the tenth of February). All SNC-Lavalin Employees with a company login have access to this database at:

https://hses.snclavalin.com/Statistics/PeriodSelection.aspx?IndicatorCategoryId=2&IsProjectClo

sed=False

Level III

Situation involving ANY of the following: • Poses immediate threat to human life /security or necessitates site evacuation or

fire department intervention; • Persistent or extensive effect on water, soil or air quality; • Major damage to aquatic or terrestrial ecosystem; • Contamination affects sensitive areas or protected species; • Closure of an extraction point/ water well for human consumption; • Water or soil contamination that spreads outside site boundaries; • Extensive decontamination required by specialized external resources; • Significant or persistent breach of permit / license or consent conditions; • Notice of violation, citation from Regulatory Authorities; • Potential prosecution or prosecution by Regulatory Authorities; • Hydrocarbon or hazardous material spill equal or greater than 200 liters to land; • Hydrocarbon or hazardous material spill equal or greater than 100 liters to water.

Reportable A reportable environmental incident is an incident, regardless of the levels, that must be reported to governmental agencies in the jurisdiction where the Controlled Site is located.

High Potential

An incident involving the discharge of a contaminant or an accident which, had the mitigation measures not been effective or equipment failure had occurred, would have led either to the discharge of a contaminant into the uncontrolled environment or to a significant breach of legal requirements. The threshold is an incident which would have otherwise been a level III incident. Examples include spills which are contained by secondary containment systems which work as designed, and accidents such as the overturning of a fuel truck which does not leak fuel.


https://hses.snclavalin.com/Statistics/PeriodSelection.aspx?IndicatorCategoryId=2&IsProjectClosed=False

https://hses.snclavalin.com/Statistics/PeriodSelection.aspx?IndicatorCategoryId=2&IsProjectClosed=False

Environmental Leading Indicators

Leading indicators records shall be provided to VP Global Environment and Sustainability as indicated below:

1. Completion of all audits identified in the Sectors’ audit programs by year end:

- All Sectors shall submit their annual audit programs by February 12th 2016;

- All Sectors shall submit quarterly updates of their audit programs;

- All Sectors shall submit reports of audits that were conducted on monthly basis.

2. Closing of all nonconformities identified during Corporate Environmental Audits:

- All nonconformities identified during a Corporate Environmental Audit shall be closed within 90 days.

3. Completion of investigations for Environmental Incidents requiring external assistance as well as for Level III and High Potential Incidents:

- Each BU shall attach investigation reports in the HSE database for all incidents requiring external assistance as well as for Level III and High Potential Incidents.

4. Communication of at least one Lesson Learned per BU to all Sectors during the calendar year:

- Lessons Learned shall be approved by the Sector’s Environmental Lead;

- Lessons learned shall be reviewed and approved by the Environmental Leads of the other Sectors prior to being published by the VP Global Environment and Sustainability.

5. Completion of at least two site visits per Controlled Site by Senior Managers (e.g. Group Presidents, Executive Vice Presidents, Managing Directors, Senior Vice Presidents, General Managers and Project Managers):

- Each BU shall submit documented evidence (e.g. minutes of meetings, Senior Managers Site Visit Checklist, etc.) of at least two site visits having an environmental focus during the calendar year.

Except for Environmental Incident investigation reports that shall be uploaded in the HSE database, all other Leading Indicators records shall be uploaded on GEMS SharePoint under

“Leading Indicators Repository 2016“ .

Leading and Lagging Indicators pertaining to Controlled Sites shall be displayed at strategic locations at the site.


http://csc.snclavalin.com/sites/cop/CoP_GEMS/Documents/Forms/AllItems.aspx?RootFolder=%2fsites%2fcop%2fCoP%5fGEMS%2fDocuments%2f4%2e1%20Leading%20Indicators%20Repository%202016&FolderCTID=&View=%7bECB48D96%2dA7E5%2d4E2E%2d892E%2dC3B55250AB24%7d

5.1.2 Environmental Incident Notification and Investigation

An Environmental Incident Notification form shall be completed for all Environmental Incidents caused by SNC-Lavalin’s Employees or by any persons working on its behalf. At a minimum, the following information shall appear on the notification form:

• Date and time of the incident; • Meteorological conditions; • Incident location; • Name of the incident witness; • Type of incident (level I, II, III, reportable, high potential); • Requirement to report to local governmental authorities; • Complete incident description including the nature of the contaminant and an estimate of the

quantity released as well as pictures; • Remedial actions that were taken including pictures; • Name of external firm(s) involved (if any); • Signature of the Controlled Site Environmental Manager or designated person.

The recommended integrated HSSE Incident Notification Form is provided online on the GEMS SharePoint site under “Examples Cited in GEMS”.

For Controlled Sites where SNC-Lavalin is working on behalf of a client, the Construction or Operation manager shall determine whether or not reporting to governmental authorities is an SNC-Lavalin responsibility or a client responsibility. In all cases, the client shall be advised and reporting processes internal to SNC-Lavalin shall be respected.

For all incidents requiring external assistance, as well as for all level III and high potential incidents, an incident investigation process shall be followed to minimize repeat occurrences of a similar or identical incident and to ensure full closure. The investigation report shall include at a minimum:

• Incident description; • Chronology of events; • Investigative team; • Root cause analysis; • Corrective action plan; • Main lessons learned.

The recommended Investigation Report Form is provided online on the GEMS SharePoint site under “Examples Cited in GEMS”.

Investigation reports shall be completed within 30 days following the incident and uploaded in the HSE database. Incident investigations’ findings and recommendations shall be effectively communicated to all affected parties.




All Level III Environmental Incidents shall be reported by line management up the chain of command to the President and CEO within 24 hours of occurrence. Notification to the President and CEO, as well as all subsequent correspondence related to the incident, shall be copied to the EVP Integrated Management System and VP Global Environment and Sustainability.

Other Environmental Incidents triggering an investigation process (Environmental Incidents requiring external assistance and High Potential Incidents) shall be reported to VP Global Environment and Sustainability by BU within 24 hours via e-mail.

The following table summarizes SNC-Lavalin Environmental Incidents reporting.

Table 2: Environmental Incidents Reporting

Type of Environmental

Incident

Notification Form

(within 24 hours)

Investigation Report

(within 30 days)

Entry in HSE Database

(by the 10th of the

following month)

Notify President & CEO, Cc EVP IMS, VP Global Environment and Sustainability

(within 24 hours)

Notify VP Global Environment and

Sustainability

(within 24 hours)

Level I Yes No* Yes No No*

Level II Yes No* Yes No No*

Level III Yes Yes Yes Yes Yes

High Potential Yes Yes Yes No Yes

Any Incident requiring external assistance

Yes Yes Yes No Yes

* Unless deemed necessary by the Controlled Site.

GES shall keep a log of all incidents reported to VP Global Environment and Sustainability.

5.1.3 Monitoring Program

Controlled Sites subjected to environmental monitoring requirements shall develop an Environmental Monitoring Program to ensure they fulfill their obligations. An Environmental Monitoring Program shall include, at a minimum:

• Parameters to be monitored; • Sampling or measurement location; • Sampling or measurement frequency; • Whom to report to; • Reporting frequency;


• Standards to comply with; • Reference documents.

5.1.4 Instruments Calibration

Controlled Sites shall develop procedure(s) to ensure all environmental monitoring instruments either owned by SNC-Lavalin, owned by consultant/contractors or leased which are used on SNC-Lavalin Controlled Sites are functional and calibrated as per their manufacturer’s recommendations.

5.2 EVALUATION AND ASSESSMENTS SNC-Lavalin’s evaluation and assessment program contributes to the company’s objective for continual improvement in environmental performance by evaluating conformance with environmental requirements and GEMS.

The scope and schedule of an evaluation and assessment is based on the importance of the SEAs associated with the activity. When determining the scope and schedule, the following shall be considered:

• Compliance obligations; • GEMS requirements; • Construction and shutdown schedules; • Results of previous audits or inspections; • Corrective actions to be implemented; • New or changing circumstances (internal and external); • Progress towards objectives and targets.

5.2.1 Inspection Program

Every Controlled Site shall implement a documented environmental inspection program so that periodic inspections are carried out to ensure environmental concerns are identified and addressed in a timely manner.

Environmental inspections shall be conducted by the Site Environmental Manager or a designated person who possesses environmental competencies. The frequency of inspections shall be site specific.

Examples of Inspection Checklist are provided online on the GEMS SharePoint site under “Examples Cited in GEMS”.

5.2.2 Self-Evaluation

At a minimum, each Controlled Site shall complete one self-evaluation audit at a minimum on a quarterly basis to validate its conformity to GEMS.

Self-evaluation shall be conducted by the Site Environmental Manager or a designated person who possesses environmental competencies as defined in Section 4.2.



The Corporate Environmental Audit Tool (6952.2.1-EN-REV02) presented in Appendix B shall be used. Items that are not relevant to the Controlled Site shall be marked as Not Applicable (NA). This Audit Tool can be modified to add site specific tabs pertaining to environmental aspects that may not be covered by the thirteen existing tabs.

The Excel version of the Corporate Environmental Audit Tool (6952.2.1-EN-REV02) is provided online on the GEMS SharePoint site.

5.2.3 Internal Management System Audit

To validate their conformity to GEMS all BUs shall conduct at least an annual audit of the management system for each of their Controlled Sites. To that effect, all BUs shall develop an annual audit program for all their active projects. These audit programs shall contain, at a minimum:

• Project name and number; • Date of planned internal audits; • Name of the selected auditor; • Date at which the audit was conducted.

Internal audits shall be conducted by professionals who possess an environmental background or have good environmental knowledge. The auditor shall be independent of the Controlled Site to avoid conflicts of interest and to ensure the integrity of the auditing process.

The Excel version of the Corporate Environmental Audit Tool (6952.2.1-EN-REV02) shall be used for internal management system audits

5.2.4 Environmental Compliance Audit

To validate conformity to their Compliance Obligations, Controlled Sites shall perform Environmental Compliance Audits (ECA) on a periodic basis.

ECAs shall be conducted by professionals who have a robust knowledge of the local environmental legislation applicable to the Controlled Site. The Compliance Obligations Register shall be used as a starting point.

The auditor shall be independent to avoid conflicts of interest and to ensure the integrity of the auditing process.

5.2.5 Corporate Environmental Audit

To validate the sites adherence to the GEMS, the GES function will perform Corporate audits of selected Controlled Sites.

The selection audit criteria include, but are not limited to:

• Limited reporting of lagging/leading indicators; • Concerning incident trends;


http://csc.snclavalin.com/sites/cop/CoP_GEMS/Documents/Forms/AllItems.aspx?RootFolder=%2fsites%2fcop%2fCoP%5fGEMS%2fDocuments%2f6%2e%20Environmental%20Audit%20Tool%202016&FolderCTID=&View=%7bECB48D96%2dA7E5%2d4E2E%2d892E%2dC3B55250AB24%7d

http://csc.snclavalin.com/sites/cop/CoP_GEMS/Documents/Forms/AllItems.aspx?RootFolder=%2fsites%2fcop%2fCoP%5fGEMS%2fDocuments%2f6%20Environmental%20Audit%20Tool%202015&FolderCTID=&View=%7bECB48D96%2dA7E5%2d4E2E%2d892E%2dC3B55250AB24%7d

• Specific EVPs and client request; • Previous Corporate Environmental Audit results.

Corporate environmental audits are also conducted using the Corporate Environmental Audit Tool (6952.2.1-EN-REV02).

To ensure efficiency, GES will select auditors to perform corporate audits based on their environmental knowledge, their geographical locations as well as their independence with respect to the Controlled Site.

Audits performed by GES audit team will count as a management system audit (Section 5.2.3).

Upon completion of the Corporate audit, the report shall be sent to the BU and site management team. Should concerns exist with these audits or reviews, each EVP will be expected to hold their teams accountable to meet expectations.

5.3 NON-CONFORMITY AND CORRECTIVE ACTION Controlled Sites shall have a systematic process to record, manage and correct non conformities identified during, inspections audits or reported to management by Employees or third parties.

All corrective actions shall be tracked and saved as official records and their effectiveness must be evaluated.

Examples of Non-conformity Register are provided online on the GEMS SharePoint site under “Examples Cited in GEMS”.

5.4 VISIBLE ENVIRONMENTAL LEADERSHIP When conducting site visits, SNC-Lavalin senior managers, i.e. Group Presidents, Executive Vice Presidents, Managing Directors, Senior Vice Presidents, General Managers and Project Managers shall demonstrate their visible environmental leadership by asking questions such as:

• What are the key legal environmental compliance parameters that this site must meet and how successful have you been in meeting them?

• Have there been any environmental incidents on the site? How have they been addressed and what lessons have been learned from them?

• Have local residents had any complaints regarding environmental management on the site and have these been satisfactorily addressed? Noise, dust, smells, vehicular traffic, storm water issues, trees & vegetation cut/disturbed, etc.

• How are hazardous materials handled and stored? Are they placed in secondary containment, is it protected from weather? Are all materials properly labeled? Are they in a secure area?



6 ACT

6.1 CORPORATE MANAGEMENT SYSTEM REVIEW The VP Global Environment and Sustainability will perform an annual management review of the GEMS where the system effectiveness is evaluated and adjustments made, as necessary. Items to be reviewed include:

• Results of corporate audits and evaluation of compliance with legal requirements and with corporate requirements or any other requirements to which SNC-Lavalin subscribes;

• Communications from external interested parties, including complaints; • SNC-Lavalin Environmental performance; • Extent to which objectives and targets have been met; • Status of preventive and corrective actions; • Follow-up actions from previous management reviews; • Changing circumstances at SNC-Lavalin; • Recommendation for improvements.

SNC-Lavalin management shall report on a quarterly basis to the HSSE Committee of the Board of Directors of the Corporation.

The VP Global Environment and Sustainability shall organize a yearly meeting of senior BU environment representatives to review GEMS and make improvements thereto.

6.1.1 Resource Allocation Review

All BUs shall provide to VP Global Environment and Sustainability an annual resource allocation review of environmental resources to manage projects according to the requirements of GEMS and to ensure proper oversight. Adjustments are made when necessary to ensure adequacy and appropriateness with regards to the implementation of new initiatives and/or maintenance of ongoing program components.

6.2 SECTOR MANAGEMENT SYSTEM REVIEW On a yearly basis, Sectors shall review the strengths, weaknesses, and suitability of their EMS. This review shall include:

• An evaluation of leading and lagging indicators with respect to targets, historical data, client requirements, etc.;

• An evaluation of both internal and external audits, and inspection reports to ensure the EMS’ performance;

• The status of investigations, corrective measures, and preventive actions; • Any significant issues identified during risk assessments, as well as regulatory

developments; • Reviews of the overall assessment process to ensure adequacy, suitability, and

effectiveness in managing environmental risk.


APPENDIX A

Best Environmental Management Practices

Best Environmental Management Practices (BEMPs)

6945.2.1-EN-REV01 Last printed December 16, 2015 Page 1 of 17

TABLE OF CONTENTS

1. INTRODUCTION .................................................................................................................................... 4

2. ATMOSPHERIC EMISSIONS MANAGEMENT ..................................................................................... 42.1 General ........................................................................................................................................... 4 2.2 Traffic .............................................................................................................................................. 4 2.3 Vehicles and Equipment ................................................................................................................. 4 2.4 Soil and Granular Material .............................................................................................................. 5 2.5 Open Burning ................................................................................................................................. 5

3. NOISE AND VIBRATION MANAGEMENT ........................................................................................... 53.1 General ........................................................................................................................................... 5 3.2 Measurement .................................................................................................................................. 5 3.3 Vehicles and Equipment ................................................................................................................. 5

4. WATER MANAGEMENT ....................................................................................................................... 64.1 General .......................................................................................................................................................... 6 4.2 Process Wastewater ...................................................................................................................................... 6 4.3 Domestic Wastewater .................................................................................................................................... 6 4.4 Surface Water ................................................................................................................................................ 7 4.5 Groundwater .................................................................................................................................................. 7

5. WASTE MANAGEMENT ....................................................................................................................... 85.1 General .......................................................................................................................................................... 8 5.2 Waste Storage ............................................................................................................................................... 8 5.3 Concrete Waste and Sandblasting Residues ................................................................................................. 9 5.4 Biomedical Waste .......................................................................................................................................... 9 5.5 Transportation and Disposal .......................................................................................................................... 9 5.6 Waste Log ...................................................................................................................................................... 9 5.7 Waste Management Examples .................................................................................................................... 10

6. HAZARDOUS MATERIALS MANAGEMENT ..................................................................................... 116.1 General ........................................................................................................................................................ 11 6.2 Hazardous Materials Storage ....................................................................................................................... 11 6.3 Petroleum Product Storage .......................................................................................................................... 11 6.4 Transportation .............................................................................................................................................. 12

7. VEHICLES AND EQUIPMENT MANAGEMENT ................................................................................. 127.1 Refueling ...................................................................................................................................................... 12 7.2 Maintenance ................................................................................................................................................ 12 7.3 Stationary Equipment ................................................................................................................................... 13

8. LIGHTING MANAGEMENT ................................................................................................................. 13

9. RADIOACTIVE DEVICE MANAGEMENT ........................................................................................... 13

10. SOIL PROTECTION ............................................................................................................................. 1310.1 Excavation ................................................................................................................................................... 13 10.2 Contaminated Soil ........................................................................................................................................ 14 10.3 Borrow Pit .................................................................................................................................................... 14

11. FLORA AND FAUNA MANAGEMENT................................................................................................ 14

12. SOCIAL INTERACTION AND ARCHAEOLOGY ................................................................................ 1512.1 Social Interaction ......................................................................................................................................... 15 12.2 Archaeology ................................................................................................................................................. 15

13. ENVIRONMENTAL INCIDENT RESPONSE ....................................................................................... 1613.1 Communication ............................................................................................................................................ 16 13.2 Drill ............................................................................................................................................................... 16 13.3 Spill Kit ......................................................................................................................................................... 16 13.4 Notification ................................................................................................................................................... 16

14. REHABILITATION OF LAYDOWN AREAS ........................................................................................ 17


1. INTRODUCTION

This document outlines SNC-Lavalin’s Best Environmental Management Practices (BEMPs) to mitigate environmental impacts resulting from the environmental aspects of our activities. All Controlled Sites shall include applicable BEMPs into their environmental control procedures unless legal or other requirements impose more stringent controls. In all cases, Controlled Sites shall be governed by permit requirements and applicable environmental impact assessment report requirements.

In unique circumstances, e.g., where SNC-Lavalin’s BEMPs cannot be fully achieved; alternative control measures shall be approved by an environmental specialist.

It should be understood that these BEMPs are primarily designed for construction sites. Sites having unique Environmental Aspects for which these BEMPs are not sufficient or appropriate shall develop their own specific environmental control measures and have them approved by an environmental specialist.

Controlled Sites which are office locations and Operation and Maintenance facilities shall implement measures to manage their Significant Environmental Aspects. The BEMPs presented here can be used as a guideline to develop measures appropriate for Operation and Maintenance facilities and office environment.

2. ATMOSPHERIC EMISSIONS MANAGEMENT

2.1 General All atmospheric emissions generated on site shall respect applicable legal and other requirements.

2.2 Traffic

Vehicle Traffic shall only be permitted on designated roads.

Dust abatement methods shall be used on all dirt access roads. Water shall be used where possible. If water is not available, other alternatives such as wood chips, calcium or magnesium chloride-based brine must be approved by an SNC-Lavalin environmental specialist prior to use. The use of oil as dust suppressant is strictly forbidden.

A truck wheel cleaning system shall be in place at the exit of the site to prevent track-out of mud, dust and dirt on to public roads.

2.3 Vehicles and Equipment

Vehicles and equipment generating abnormal exhaust fumes shall be promptly repaired or tuned.

Vehicle and equipment idling shall be kept to a minimum.

Truck trailers shall be covered with tarps during the transport of bulk granular material.


Equipment likely to emit dust should be equipped with dust recovery systems.

2.4 Soil and Granular Material

Any soil or granular material likely to release dust shall be covered with tarp, geotextile or any other dust control techniques.

2.5 Open Burning

Open burning of any material or waste is strictly prohibited.

3. NOISE AND VIBRATION MANAGEMENT

3.1 General

Noise and vibration generated on site shall respect legal and other requirements.

Noisy activities and activities generating vibrations shall be conducted within time regulated windows, according local legislation or any other specific requirements.

When possible, major noise sources shall be placed as far as possible from sensitive receptors.

When possible, noise barriers for the absorption or reflection of noise shall be installed.

Blasting mats shall be used to prevent debris from flying beyond the blasting area.

3.2 Measurement

If required, noise surveys shall be conducted on a periodic basis by a competent person according to standard methods. Noise surveys shall be documented.

If required, a sonometer and a seismograph shall be available on site. These measurement devices shall be calibrated according to manufacturers’ requirements. A calibration log shall be available for review.

3.3 Vehicles and Equipment

Machinery or equipment (trucks, graders, bulldozers, excavators, cranes, compressors, generators, etc.) not equipped with an adequate muffler systems shall not be permitted on the site.

Site speed limits shall be respected at all times.

Noise from slamming of the rear panels of dump trucks shall be prohibited in urban or noise sensitive areas.

Noisy equipment shall be inspected and maintained on a regular basis.

When possible, electrical equipment, rather than pneumatic or mechanical, should be used on site. Percussion tools should be equipped with anti-noise devices.


When possible, vehicles and equipment should be equipped with variable intensity back-up alarms.

4. WATER MANAGEMENT

4.1 General

Water and wastewater shall be managed according to the applicable legislation and any other site specific requirements.

The site shall implement water conservation, recycling and/or reuse initiatives or programs in order to minimize water consumption.

If required, a water log is maintained up to date on site for the different water usage. The water log should stay available for review.

4.2 Process Wastewater

No wastewater (hydroblasting, hydrotesting, purge, washwater, industrial process, etc.) shall be discharged directly on the ground, to a drainage ditch, to a sewer or in a watercourse.

A designated area for washwater collection shall be available for all equipment including equipment associated with concrete or cement mortars (e.g. concrete mixer truck chutes, concrete pumps, trowels, etc.). Washwater shall be collected in watertight containers or washout pits. Before heavy rains, washout containers or pits shall be covered to avoid an overflow. Washwater shall either be evaporated, reused, treated on site or vacuumed off by a licensed firm.

Where process wastewater treatment is performed on site, the quality of wastewater effluent shall always comply with the applicable regulation and standards.

4.3 Domestic Wastewater

All domestic wastewater shall be collected either in portable toilets or routed to a septic tank, a sanitary sewer system or a wastewater treatment system.

Septic tanks and portable toilets must be emptied on a regular basis and their content shall be disposed of in an authorized site.

The installation of any septic tank, leaching field or system for disposing of domestic wastewater shall comply with local regulatory requirements. In the absence of such requirements, an environmental specialist must approve such facilities.

Where domestic wastewater treatment is performed on site, the quality of wastewater effluent shall always comply with the applicable regulation and standards.


4.4 Surface Water

Any work related to watercourses, water bodies, flood zones or wetlands shall be done in accordance with local regulation and in compliance with environmental best practices for surface water protection.

Locate stockpiles areas as far away from waterbodies as is practical (or as prescribed in the legislation) and outside of areas susceptible to flooding.

Slopes shall be stabilized and silt fences shall be used to prevent sediments from reaching streams, rivers, or other surface water bodies.

Storm water and runoff water shall be directed to on-site sedimentation ponds or a tank equipped with a filtration barrier (mulch, netting, filtering dike, etc.) prior to being discharged into the environment in order to reduce turbidity. Storm water and runoff water discharges to the environment shall always comply with the applicable regulation and standards.

For waterways crossings, the following minimal requirements shall be respected:

• Perform work during the dry season, when possible;

• Limit the number of crossing points;

• Select a crossing point at which the banks are stable and the watercourse is limited in size;

• Maintain the natural flow of the water at all time;

• Avoid crossing permanent water course with vehicles and other equipment;

• Crossings shall be clearly identified

For shoreline protection, the following minimal requirements shall be respected:

• Maintain existing shrubs and limit stump removal within 30 meters of a water body;

• Do not allow any fuel storage in the vicinity of a water body;

• Do not allow any construction site vehicle maintenance or fuel refilling activities in the vicinity of a water body.

4.5 Groundwater For groundwater protection, the following minimal requirements shall be respected:

• Do not allow any fuel and hazardous materials storage in the vicinity of a well;

• Do not allow any construction site vehicle maintenance or refueling activities in the vicinity of a well.

If there is a possibility of groundwater contamination related to specific activities, a groundwater sampling and analysis program shall be carried out as specified in the local legislation.

All groundwater analysis results shall be kept on file.


5. WASTE MANAGEMENT

5.1 General

All waste (non-hazardous, hazardous and biomedical) shall be managed according to the applicable legislation and any other site specific requirements.

Hazardous, non-hazardous and biomedical waste shall be segregated according to their types and compatibility.

The 4Rs principle (Reduce, Reuse, Recycle and Resource recovery) shall be implemented for all waste management activities. Elimination (land filling, incineration) shall be used as a last resort.

Emphasis shall be placed on the following recyclable materials:

• Plastics

• Glass

• Wood

• Wood pallets

• Cardboard and paper

• Concrete and asphalt

• Metals

Management of hazardous wastes shall be carried out in a manner that reduces the possibility of releases to the environment or exposure to persons.

Appropriate, sufficient and well identified containers shall be provided at all times.

All work areas shall be kept clean and free of waste at all times.

No waste shall be permanently left on the site after work is completed.

5.2 Waste Storage

All hazardous and non-hazardous containers shall be properly labeled. All labels must be visible and in good condition.

Hazardous waste storage areas shall be protected from the elements, i.e., equipped with a roof, walls, impermeable floor and an adequate retention capacity.

Hazardous waste shall be stored according to their compatibility.

Bulk hazardous waste stored in roll-off containers shall be covered by an impervious tarp at all times.

Hazardous waste storage tanks shall be protected using devices such as posts, jersey barriers, guardrails, etc. to avoid collisions with vehicles or heavy equipment.


Areas surrounding hazardous waste storage tanks shall be clutter free.

Hazardous waste storage areas shall be located at a safe or legally required distance from a watercourse, a well, a sewer or any other sensitive areas.

Spill kits with sufficient absorbing materials must be located in the vicinity of hazardous waste storage areas.

All waste storage areas must be kept clean.

5.3 Concrete Waste and Sandblasting Residues

Residual concrete from concrete mixer trucks shall be emptied in watertight containers or washout pits in an identified location. Dried concrete left after pouring shall be recovered. Residual concrete may be recycled off-site or reused for other purposes on the site, but shall be removed from site once the work is completed.

Sandblasting residues shall also be recovered and managed according to legislation for disposal.

5.4 Biomedical Waste

Biomedical waste handling and disposal shall be carried out in compliance with all applicable legislation and any other site specific requirements. Biomedical wastes shall be segregated from any other wastes.

It is strictly prohibited to dispose of any biomedical wastes in any container other than dedicated and clearly labeled biomedical waste containers.

Biomedical waste shall be disposed of in authorized sites.

5.5 Transportation and Disposal

Trucks and containers used to transport hazardous waste shall be properly labeled and identified according to local legislation.

Authorized hazardous waste carriers shall be used for the transportation of any hazardous waste. Shipping and disposal documents shall be completed according to local legislation and copies shall be kept on site.

All waste shall be disposed of in authorized sites (e.g. recycling facilities or authorized landfill facilities).

5.6 Waste Log

If required by the project, a waste log for all type of waste generated on site shall be maintained, kept up to date and made available for review.


5.7 Waste Management Examples

Some waste management examples are provided in tables 1 and 2. Please note that waste classification may vary from country to country, always verify with local legislation.

Table 1 - Examples of Waste Management and Disposal Methods for Non-Hazardous Waste Waste

Classification Waste Type Storage Disposal Method

Non-Hazardous Waste

Waste food Trash containers emptied on regular basis

Landfill or composting

Office paper / Cardboard

Dedicated container emptied on regular basis

Reusing or Recycling

Plastic containers Aluminium cans Metal containers (drums, box, cans, etc.) Metal Wood Concrete Brick Tires / rubber inner tubes Glass Asphalt and pavements Dry wall Insulation material (non-asbestos) Electrical wirings Computers, cell phones (not dismantled) Empty printer toner and cartridges

Table 2 - Examples of Waste Management and Disposal Methods for Hazardous and Biomedical Waste

Waste Classification Waste Type Storage Disposal Method

Hazardous Waste

Used oil, hydraulic fluid, diesel, gasoline

Dedicated covered and leak-proof containers properly labeled, protected from the elements and equipped with secondary containment

Recycling Used batteries Recycling Solvents Recycling Paint residues Recycling Oily rags Disposal in an

authorized facility Used Oil filters Recycling Oily water Treatment Fluorescent tubes Recycling

Biomedical Waste

Biomedical waste (needle, soiled bandages, biological waste, etc.)

Dedicated and identified rigid container.

Disposal in an authorized facility


6. HAZARDOUS MATERIALS MANAGEMENT

6.1 General

All hazardous materials shall be managed according to the applicable legislation and any other site specific requirements.

Management of hazardous materials shall be done in a manner that reduces the possibility of releases to the environment or exposure to persons.

6.2 Hazardous Materials Storage

All hazardous material containers such as petroleum products, solvents, paints, cleaning products, chemicals, etc. shall be properly identified with respect to their content and their hazard classification. All labels must be visible and in good condition.

All hazardous materials stored in working and storage area shall be compatible in regard to their hazard classification.

All hazardous material containers shall be placed within secondary containment having a sufficient retention capacity for a potential spill of the product. Hazardous materials containers shall be stored at a safe or legally required distance from any watercourse, well, sewer or any other sensitive areas.

Spill kits shall be available and located in the vicinity of hazardous materials storage areas. Appropriate fire extinguishers must be available in the vicinity of the storage areas and shall be in good working condition.

An up-to-date list of hazardous materials stored on the site shall be made available for consultation. The list shall include estimated quantities of each product. All Safety Data Sheet (SDS) must be available on site and must be kept up-to-date.

Gas cylinders shall be stored in an upright position, in dedicated cages and must be secured by a chain or a strap.

6.3 Petroleum Product Storage

All petroleum product storage tanks shall be properly identified as per their content and their capacity. All labels must be visible and in good condition.

All storage tanks shall be either double-wall or placed within secondary containment device having a sufficient retention capacity for potential spill.

All petroleum product storage tanks shall be stored at a safe or legally required distance from a watercourse, a well, a sewer or any other sensitive areas.

Areas surrounding petroleum product storage tanks shall be clutter free.

All storage tanks shall be protected using devices such as posts, jersey barriers, guardrails, etc. to avoid collisions with vehicles or heavy equipment.


Spill kits and fire extinguishers shall be located in the vicinity of all petroleum product storage tanks.

All petroleum product containers having a capacity less than or equal to 25 liters shall be approved by a standardization authority such as CSA, ULC or any equivalent.

6.4 Transportation

Trucks and containers used to transport hazardous materials shall be properly labeled according to local legislation.

Shipping documents shall be completed according to local legislation and copies shall be kept on site.

7. VEHICLES AND EQUIPMENT MANAGEMENT

7.1 Refueling

On-site refueling of vehicles and heavy equipment shall be carried out either in dedicated areas having an impermeable surface or using an impermeable liner or absorbent sheets.

Refueling activities shall be supervised at all times. A warning sign indicating "No Smoking / Turn-off Engine" shall be posted at all refueling areas.

Spill kits and fire extinguishers shall be available at refueling stations and on fuel trucks.

Refueling activities shall be carried out at a safe or legally required distance from a watercourse, a well, a sewer or any other sensitive areas.

7.2 Maintenance

Vehicles and equipment showing signs of hydrocarbon leakage are prohibited on site. Any such equipment shall be repaired prior to its admission on site.

Regular maintenance (oil change, lubrication, etc.) of vehicles and equipment should be carried out off-site. If mechanical maintenance must be carried out on site (e.g. remote site location), it shall be performed in a dedicated and approved area where measures are taken to avoid any site contamination.

Emergency mechanical maintenance which must be performed outside dedicated areas shall be carried out using impermeable liners to protect the ground and absorbent materials shall be available at all times. Absorbent materials shall also be available on all off road vehicles.

All maintenance activities shall be carried out at a safe or legally required distance from a watercourse, a drainage ditch, a well, a sewer or any other sensitive areas.

Preventive maintenance programs shall be carried out on a regular basis for all vehicles and heavy equipment used on site.


7.3 Stationary Equipment

Stationary equipment (compressors, generators, heating devices, etc.) having diesel or gasoline engines shall be equipped with drip pans.

8. LIGHTING MANAGEMENT

Lighting shall be managed according to the applicable legislation and any other site specific requirements. When working in sensitive areas lighting shall be controlled using a combination of the following control measures when considered safe for the workers:

• Direct lighting to illuminate only the required area; • Use directional light devices; • Use dimmers to control light intensity; • Use high barriers; • Turn off lights when there is no work in progress.

9. RADIOACTIVE DEVICE MANAGEMENT

All equipment containing radioactive sources shall be managed according to the applicable legislation and any other site specific requirements.

All applicable permits and approvals shall be obtained from official authorities for the use of any equipment containing radioactive sources.

All work areas where X-ray activities are carried out shall be well defined, properly identified and shall have a restricted access for workers.

Storage areas used for equipment containing radioactive sources shall be appropriate and adequately identified by appropriate warning signs.

All workers using equipment containing radioactive sources shall be adequately trained and shall possess a valid certificate.

10. SOIL PROTECTION

10.1 Excavation

All activities involving soil stripping, clearing, and excavation shall be limited to current work areas to avoid unnecessary soil surface exposure.

Whenever possible, the topsoil (anticipate at least 30 cm) should be set aside and preserved during excavation work so that it can be reused for resurfacing the soil surface at the end of the project.

When applicable, mitigation measures to limit the accumulation of rainwater in the excavations should be put in place (e.g. earth berm around the perimeter of the excavation).


10.2 Contaminated Soil

In cases where previous soil characterization studies exist and are available for review, these studies shall be consulted prior to any soil excavation. The content and the results of the soil characterization studies shall be taken into account for soil management, especially if there are specific areas where contaminated soil or fill material were identified.

Regular visual inspection shall be performed on the site in order to identify any abnormal odors or stains on the soil surface and excavation walls. When contamination signs are identified, work shall be stopped immediately so that contaminated soils are properly managed.

All contaminated soils shall be stored in leak proof containers or on an impervious surface and protected against the elements in order to avoid any further contamination of soil and water of the storage area and the vicinities.

Contaminated soils shall be subjected to an in-situ treatment or be disposed of at an authorized site. Once contaminated soil has been transported and disposed of off-site, documents shall be kept to confirm that these materials were disposed of in an authorized site.

A log identifying the information related to contaminated soil management such as origin, volume, storage area, contamination level, final disposal, dates, etc. should be kept up-to-date.

10.3 Borrow Pit

All backfill materials shall come from authorized borrow pits.

11. FLORA AND FAUNA MANAGEMENT

Flora and fauna shall be managed according to the applicable legislation and any other site specific requirements.

Damage to the natural environment shall be kept to a minimum and efforts shall be made to avoid permanent damage.

Only non invasive species shall be used and all vehicles shall be free of soil and debris capable of transporting noxious weed seeds or roots onto the site.

When possible, pesticides shall be avoided. For cases where pesticides cannot be avoided, low toxicity, persistence and bioavailability pesticides shall be used.

The boundary of the site shall be clearly defined prior to the project start in order to avoid damage to the vegetation adjacent to the site.

Should specific requirements related to the protection of flora and fauna have been identified, these shall be communicated to site personnel and mitigation measures shall be implemented on the site. Awareness programs related to flora and fauna protection shall be provided to all employees.

Breeding areas for birds or other wild animals must be identified, delimited and mitigation measures must be taken to limit negative impacts to the environment.


It shall be prohibited to:

• Hunt, fish, trap or engage in the trade of wild animals on the site, in campgrounds and in neighboring areas, unless such activities are specifically authorized.

• Cut plant life (trees), harvest or engage in the trade in exotic or medicinal plants on the site, in the campgrounds or in neighboring areas, unless such activities are specifically authorized.

12. SOCIAL INTERACTION AND ARCHAEOLOGY

12.1 Social Interaction

According to the project context, all groups, communities and neighborhoods that might be impacted by the site activities should have been identified by SNC-Lavalin or by the client prior to commencement of work.

Specific social program requirements may have been identified for the project. If this is the case, information pertaining to these requirements shall be communicated to relevant project personnel, and the social programs shall be implemented by the site management team or by the client. In all cases there should be clarity as to whether this is an SNC-Lavalin responsibility, a client responsibility or the responsibility of another project partner. The project team shall determine if a communication plan with the local population is required and develop such a plan if need be. The decision on this matter shall be documented.

In all cases, mitigation measures shall be implemented on site in order to protect the public and third party properties neighboring the site or located in the vicinity of the site area.

It is recommended to use local businesses, as much as possible, for purchasing goods and for providing services as long as such businesses provide the desired degrees of quality and reliability on a competitive basis, in compliance with financial and contractual terms.

A process shall be implemented by the site management team to address all inquiries and complaints formulated by local population in regard to the site activities.

12.2 Archaeology

According to the project context, an archaeological protection program may have been identified for the site. If this is the case, the requirements of the archaeological protection program shall be communicated to all employees and the protection measures identified in the program must be implemented on the site.

When an unexpected archeological discovery such as traces of human occupancy of the land (ancient foundations, etc.) or of any artifacts (ancient vessels, etc.) is found during excavation, the excavation work shall stop and the site management team must be notified immediately. The archaeological discovery shall be documented (nature of findings, location, date, time, name of the person who made the discovery, pictures and actions) and managed according to local legislation.


13. ENVIRONMENTAL INCIDENT RESPONSE

13.1 Communication

An Environmental Incident Response Plan shall be prepared for any site.

The requirements of the Environmental Incident Response Plan shall be communicated to all employees and contractor personnel during the orientation session.

The Plan shall be distributed to all relevant personnel who could be involved in the environmental incident response process.

For Environmental Incidents which are spills, leaks or accidental discharges, the following steps shall be taken; once it is determined there is no risk for responders:

a) Cease the activity causing the spill, leak or discharge;b) Identify the source of the spill, leak or discharge;c) Implement containment measures with a particular focus on ensuring the protection of

environmentally sensitive areas;d) Clean up or decontaminate the contaminated area;e) Complete an incident notification form;f) Dispose of the contaminant and contaminated material in conformance with applicable

regulations.

13.2 Drill

Environmental Incident drills shall be carried out at least once a year by the personnel tasked with incident response duties. Table top and field exercises are acceptable and they shall be documented.

13.3 Spill Kit

Adequate numbers of spill kits shall be available on site. Their contents shall be inspected on a regular basis and renewed as needed.

13.4 Notification

An Environmental Incident Notification form shall be completed for all Environmental Incidents.

At a minimum, the following information shall appear on the notification form:

• Date and time of the incident;

• Meteorological conditions;

• Incident location;

• Name of the incident witness;

• Type of incident (level I, II, III, reportable, high potential);

• Requirement to report to local governmental authorities;


• Complete incident description including the nature of the contaminant and an estimate ofthe quantity released as well as pictures;

• Remedial actions that were taken including pictures;

• Name of external firm(s) involved (if any);

• Signature of the Controlled Site Environmental Manager or designated person.

All environmental incidents must be documented and recorded in the HSE Database by the 10th of the following month.

All Level III Environmental Incidents shall be reported by line management up the chain of command to the President and CEO within 24 hours of occurrence. Notification to the President and CEO, as well as all subsequent correspondence related to the incident, shall be copied to the EVP Integrated Management System and VP Global Environment and Sustainability.

Other Environmental Incidents triggering an investigation process (Environmental Incidents requiring external assistance and High Potential Incidents) shall be reported to VP Global Environment and Sustainability by BU within 24 hours via e-mail.

14. REHABILITATION OF LAYDOWN AREAS

When work activities are completed, the Site shall, at a minimum, be cleared of equipment, unused materials, waste, staining so as to present a satisfactory clean and neat appearance.


APPENDIX B

Corporate Environmental Audit Tool

6952.2.1-EN-REV02 Last printed on 2015/12/21 1 of 21

Project Name:

Site Manager:

Project Number:

Project Location (City and Country):

Lead Auditor:

Audit Team Members:

Audit Date:

Repeating Issues: 0

Total # of Items Tracked: 0

Environmental Audit

#DIV/0!

MET / NOT MET STD

FINAL AUDIT SCORE


Environmental Audit

OK Low Medium High Extreme

X XX XXX XXXX1. Environmental Management 0 0 0 0 0 100% 0 0 0 0 0 02. Atmospheric Emissions 0 0 0 0 0 100% 0 0 0 0 0 03. Noise and Vibration 0 0 0 0 0 100% 0 0 0 0 0 04. Water Management 0 0 0 0 0 100% 0 0 0 0 0 05. Waste Management 0 0 0 0 0 100% 0 0 0 0 0 06. Hazardous Materials Management 0 0 0 0 0 100% 0 0 0 0 0 07. Lighting Management 0 0 0 0 0 100% 0 0 0 0 0 08. Vehicles and Equipment Management 0 0 0 0 0 100% 0 0 0 0 0 09. Radioactivity 0 0 0 0 0 100% 0 0 0 0 0 010 Soil and Excavation 0 0 0 0 0 100% 0 0 0 0 0 011 Flora and Fauna Protection 0 0 0 0 0 100% 0 0 0 0 0 012 Social Interaction and Archeology 0 0 0 0 0 100% 0 0 0 0 0 012 Environmental Incident Response 0 0 0 0 0 100% 0 0 0 0 0 013 Rehabilitation of Laydown Areas 0 0 0 0 0 100% 0 0 0 0 0 014 Site Specific 0 0 0 0 0 100% 0 0 0 0 0 0

0 0 0 0 0 #DIV/0! 0 0 0 0 0 0`

AUDIT SCORING LEGEND DEFINITIONS

0 Site knows about issue, but no action taken Repeating Issues: Multiple instances of1 Site knows about issue and some action taken, but generally not implemented non-compliance with the issue2 Control measures implemented - compliance checked but frequent lapses3 Control measures implemented - occasional lapses occur4 Control measures well implemented - very infrequent lapses5 Full compliance, no more reasonable actions would be expected

RISK OUTCOME and PRIORITYSCORE FINAL SCORE

TOTALS

AT RISK SET STANDARD

SECTION NAME MAXIMUM POSSIBLE ScorePoints

MissedMINIMUM STANDARD

(80%)Ref FINAL SCORERepeating

IssuesImminentDanger


Environmental Audit

50%

60%

70%

80%

90%

100% Environmental Management

Atmospheric Emissions

Noise and Vibration

Water Management

Waste Management

Hazardous Materials Management

Lighting Management Vehicles and Equipment

Management

Radioactivity

Soil and Excavation

Flora and Fauna Protection

Social Interaction and Archeology

Environmental Incident Response

Rehabilitation of Laydown Areas

Section Audit Score (%)


Environmental Audit

0

0

0

0

0

1

1

1

1

1

1

AUDIT SCORE AND MAXIMUM POSSIBLE


Auditor:Audit Date:

Project Number :

COMMENTS

Environmental Management D O I

REP

EATI

NG

ISSU

E(X

)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT

1-4Score Points

Missed Outcome

Environmental Policy

1. 1 The latest version of the Corporate Environmental Policy Statement has been communicated to all employees and contractors x x x N/A 4 N/A N/A N/A

1. 2 A copy of the Corporate Environmental Policy Statement is prominently displayed so as to be seen by all staff and visitors x N/A 3 N/A N/A N/A

Leadership

1. 3Site Management provides visible leadership on the environment by serving as an example to the personnel by taking time to understand the environmental aspects and managing risks

x N/A 4 N/A N/A N/A

1. 4 Site management provides adequate resources, i.e. competent environmental resources, and time to perform necessary environmental mitigation measures. x x N/A 4 N/A N/A N/A

Identification and Assessment of Environmental Aspects

1. 5 An Environmental Aspects Impacts Register allowing to identify and assess Environmental Aspects and refering to environmental control measures is available x N/A 4 N/A N/A N/A

1. 6 The Environmental Aspects Impacts is regularly updated x x N/A 4 N/A N/A N/A

1. 7 Significant Environmental Aspects are entered into the Project Risk Register via Stature as per Risk Management Guideline x N/A 3 N/A N/A N/A

Job Environmental Analysis (JEA)

1. 8 JEAs are performed for specific tasks to ensure environmental control measures are implemented x x N/A 3 N/A N/A N/A

Compliance Obligations (Legal and Other Requirements)

1. 9A Compliance Obligations Register identifying laws, regulations, by-laws, permits/licence/certificate of authorization conditions, contractual requirements, industry standards, voluntary commitments, etc. is available

x N/A 4 N/A N/A N/A

1. 10 The Compliance Obligations Register is updated at least annually or whenever amendments to the environmental obligations are made x x N/A 4 N/A N/A N/A

1. 11 Associated Environmental Aspects to Compliance Obligations are indicated in the Compliance Obligations Register x N/A 3 N/A N/A N/A

1. 12 The site ensures compliance with Compliance Obligations that have been identified x x x N/A 4 N/A N/A N/A

Environmental Objectives

1. 13 There is a clear understanding of the yearly objectives arising from the Global Environmental Management System x N/A 4 N/A N/A N/A

1. 14 Corporate environmental objectives as well as site specific objectives are in place, and are being monitored and reviewed on a regular basis x x N/A 4 N/A N/A N/A

Organisational Structure

1. 15 Roles and responsibilities in terms of environmental management are defined, documented, and communicated x x N/A 4 N/A N/A N/A

Training and Environmental Awareness

1. 16 Induction sessions are provided to all SNC-Lavalin employees and people working on its behalf x x N/A 4 N/A N/A N/A

1. 17

Induction sessions include Environmental Policy Statement, Responsibitlies, Compliance Obligations, implications of not conforming with compliance obligations, Significant Environmental Apects, Environmental Objectives, Environmental Protection measures, Environmental Incident Response processes.

x N/A 4 N/A N/A N/A

1. 18 If required, specific and training sessions are in place (e.g. Transportation of Dangerous Goods, endangered species identification, LEED requirements, etc.) x x N/A 4 N/A N/A N/A

1. 19 Training log is available and up to date x N/A 3 N/A N/A N/A

Ref.

RESULTSSource RISK SCORE

Environmental Audit


Auditor:Audit Date:

Project Number :

COMMENTS


REP

EATI

NG

ISSU

E(X

)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT

1-4Score Points

Missed OutcomeRef.


Environmental Audit

Communications1. 20 Environmental management is incorporated into regular site meetings x x N/A 4 N/A N/A N/A1. 21 Meeting minutes of the above meetings are available x N/A 3 N/A N/A N/A1. 22 Leading and lagging indicators are displayed at strategic locations x N/A 3 N/A N/A N/A1 23 Inquiries, complaints and concerns from external parties are recorded and addressed x x N/A 3 N/A N/A N/A

Control of Documents and Records

1. 24 Procedures are in place to control all documents related to Environmental Management System (e.g., approvals before distribution, withdrawal of obsolete documents, etc.) x N/A 3 N/A N/A N/A

1. 25 All documents / records are readable, easily accessible, and kept in good condition. x x N/A 3 N/A N/A N/A

1. 26 All documents / records are coded as per applicable procedures x N/A 2 N/A N/A N/A1. 27 All documents / records are kept for the duration of the project and then archived. x N/A 2 N/A N/A N/A

Operational Control

1. 28 Updated Environmental Control Procedures are available for all members of the team, including management and supervision x x N/A 4 N/A N/A N/A

1. 29 SNC-Lavalin's Best Environmental Management Practices (BEMPs) are included in Environmental Control Procedures of the site x N/A 4 N/A N/A N/A

1. 30 Posters highlighting the most Significant Environmental Aspects are displayed in prominent location at the site x x N/A 2 N/A N/A N/A

Contractor Management1. 31 Environmental clauses are included in the Contractor’s contract x N/A 4 N/A N/A N/A

Emergency Preparedness and Response / Environmental Incidents1 32 An updated Environmental Incident Response Plan is available x N/A 4 N/A N/A N/A

1. 33 Environmental incidents are properly classified (Levels I, II, III, high potential, reportable) x x N/A 4 N/A N/A N/A

1. 34 Incident reporting and investigations follow GEMS requirements x x N/A 4 N/A N/A N/A1. 35 Duly completed and signed-off incident reports are available on site. x N/A 4 N/A N/A N/A

1. 36 All environmental incidents are entered into the Corporate HSE database by the 10th of the following month

x N/A 4 N/A N/A N/A

1. 37Level III, High Potential Incident and incidents requiring external assistance are communicated immediately to BU HSSE Manager and an investigation report is completed within 30 days followint the incident

x N/A 4 N/A N/A N/A

1. 38 Actions are taken in terms of follow-up and closure plans after an incident x N/A 4 N/A N/A N/APositive Incentive Program

1. 39 Good environmental behaviors are rewarded x x N/A 2 N/A N/A N/AMeasuring and Monitoring Performance

1. 40 An environmental monitoring program is in place x N/A 4 N/A N/A N/A1. 41 Instruments are calibrated and calibration records are available x N/A 4 N/A N/A N/A1 42 Monitoring records, such as sampling results, are easily available x N/A 4 N/A N/A N/A

Evaluation and Assessment (Inspections/Audits)1. 43 Inspections are carried out on a regular basis and are documented x N/A 4 N/A N/A N/A

1. 44 Self-evaluations using the Corporate Environmental Audit Tool are conducted at a minimum on a quarterly basis x N/A 4 N/A N/A N/A

1. 45 Environmental Compliance Audits are conducted by personnel who has robust knowledge of the local legislation to ensure all Compliance Obligations are met x N/A 4 N/A N/A N/A


Auditor:Audit Date:

Project Number :

COMMENTS


REP

EATI

NG

ISSU

E(X

)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT

1-4Score Points

Missed OutcomeRef.


Environmental Audit

Corrective Actions

1. 46Non-conformities and observations identified in self-evaluations, internal/external audits and Environmental Compliance Audits are documented and corrective actions plans are developed to prevent reoccurrence

x N/A 4 N/A N/A N/A

1. 47 Non-conformities are closed in a timely manner x N/A 3 N/A N/A N/AManagement Review

1. 48Environmental Data such as self-evaluations, Environmental Compliance Audits results, environmental objectives progress, changes to the Compliance Obligations, etc.are provided to BU for annual Management Review

x N/A 2 N/A N/A N/A

0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Totals


Auditor:Audit Date:

Project Number :

COMMENTS

Atmospheric Emissions D O I

REP

EATI

NG

IS

SUE

(X)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT 1-

4Score Points Missed Outcome

2. 1 Atmospheric emissions respect applicable legal and other requirements x x N/A 4 N/A N/A N/A2. 2 Approved dust abatement procedures/methods are in place x x N/A 4 N/A N/A N/A2. 3 No visible dust emissions from any source x N/A 3 N/A N/A N/A

2. 4 If required, a Traffic Management Plan is in place at the site x x x N/A 4 N/A N/A N/A2. 5 Driving off designated roads is not permitted on site x N/A 3 N/A N/A N/A2. 6 Truck wheel cleaning system is in place at the exit of the site x x N/A 3 N/A N/A N/A

2. 7 No visible fumes present during engine/equipment operation x N/A 3 N/A N/A N/A2. 8 Heavy trucks are always covered with a tarp when transporting granular materials x x N/A 3 N/A N/A N/A2. 9 Equipment likely to emit dust are equipped with collection systems x N/A 3 N/A N/A N/A2. 10 Vehicle and equipment idling is kept at a minimum x N/A 3 N/A N/A N/A

2. 11 There is no evidence of open pit burning x x N/A 4 N/A N/A N/ATotals 0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

General

Open burning

Vehicles and Equipment

Traffic

Ref.

Source RISK

Environmental Audit

SCORE RESULTS


Auditor:Audit Date:

Project Number :

COMMENTS

Noise and Vibration D O I

REP

EATI

NG

IS

SUE

(X)

IMM

INEN

T D

AN

GER

(X)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT 1-4 Score Points Missed Outcome

General3. 1 All noise/vibration generating activities and equipment have been identified. x x N/A 4 N/A N/A N/A

3. 2 When possible, major sources of noise emissions and vibration are placed as far as possible from sensitive receptors x x N/A 3 N/A N/A N/A

3. 3 Noisy activities are conducted within time regulated windows x x N/A 4 N/A N/A N/A3. 4 If necessary, noise barriers are installed x N/A 4 N/A N/A N/A

3. 5 Noise levels respect applicable regulations and there is no unresolved or recurring complaint x x N/A 4 N/A N/A N/A

Measurements3. 6 If required, noise and/or surveys are conducted x x N/A 4 N/A N/A N/A3. 7 If required, a sonometer is available on site. x x N/A 4 N/A N/A N/A3. 8 If required, a seismograph is available on site x x N/A 4 N/A N/A N/A3. 9 Calibration log is being maintained x x N/A 2 N/A N/A N/A

3. 10 Trucks and off road vehicles are equipped with mufflers x x N/A 4 N/A N/A N/A3. 11 Site's speed limit is being respected x x N/A 3 N/A N/A N/A3. 12 Noise from dump trucks' rear panel is prohibited in urban or sensitive areas x N/A 3 N/A N/A N/A3. 13 Noisy equipment is inspected and maintained on a regular basis x x x N/A 3 N/A N/A N/A

Totals 0 0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Equipment

Ref.

RESULTS

Environmental Audit

Source RISK SCORE


Auditor:Audit Date:

Project Number :

COMMENTS

Water Management D O I

REP

EATI

NG

IS

SUE

(X)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT

1-4Score Points Missed Outcome

General4. 1 The site includes water conservation, recycling and/or reuse initiatives x x x N/A 3 N/A N/A N/A4. 2 If required, a water consumption log is kept x x x N/A 4 N/A N/A N/A

4. 3A designated area for wash water collection is clearly identified and is being used for all equipment associated with concrete or cement mortars (e.g. concrete mixer truck chutes, concrete pumps, trowels, etc.)

x N/A 4 N/A N/A N/A

4. 4 All washwater are adequately managed prior to being discharged x x x N/A 4 N/A N/A N/A

4. 5 Any wastewater type (hydroblasting, purge, washwater, process, etc.) is never discharged directly to the ground, to the drainage ditch, to the sewer or in a watercourse x x N/A 4 N/A N/A N/A

4. 6 All wastewater are managed according to the applicable legislation x x x N/A 4 N/A N/A N/ADomestic Wastewater

4. 7 Domestic and sanitary wastewater is collected either in portable toilets or routed to a septic tank, a sanitary sewer system or a wastewater treatment system x x N/A 4 N/A N/A N/A

4. 8 Septic tanks and portable toilets are emptied on a regular basis and their content is disposed at an authorized site x x N/A 4 N/A N/A N/A

4. 9The quality of domestic wastewater effluent treated on site complies with the applicable standards. x x x N/A 4 N/A N/A N/A

Surface Water4. 10 Ditches/streams at road crossings are protected x N/A 4 N/A N/A N/A

4. 11 Stockpiles are located as far away from waterbodies as practical (or as prescribed in the legislation) and outside areas susceptible to flooding N/A 3 N/A N/A N/A

4. 12 Silt fences are used to prevent sediments from reaching streams, rivers, or other surface water resource x N/A 4 N/A N/A N/A

4. 13Stormwater, water pumped from excavation and run-off water are directed to on-site sedimentation ponds or appropriate stormwater sewer in accordance with applicable standards

x N/A 4 N/A N/A N/A

4. 14 Authorizations were obtained for any work involving watercourse, waterbody, flood plain or wetland x x x N/A 4 N/A N/A N/A

4. 15 Applicable legislation requirements and/or best recognized practices regarding water crossings are implemented x x N/A 3 N/A N/A N/A

4. 16 Applicable legislation requirements and/or best recognized practices regarding shorelines are implemented x x N/A 3 N/A N/A N/A

Groundwater

4. 17 If there is a possibility of contamination related to site activities, sampling and analysis of groundwater is carried out as per the approved procedures x x N/A 3 N/A N/A N/A

4. 18 Groundwater analysis results comply with the applicable standards. x x N/A 3 N/A N/A N/A0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Environmental Audit

Source RISK

Process Wastewater

Totals

Ref.

SCORE RESULTS


Auditor:Audit Date:

Project Number :

COMMENTS

Waste Management D O I

REP

EATI

NG

IS

SUE

(X)

PointsAwarded (0-

5)or N/A

PRIORITY

WEIGHT 1-4

Score Points Missed Outcome

General

5. 1 Properly identified hazardous and non-hazardous waste containers are available on site in sufficient quantities x N/A 4 N/A N/A N/A

5. 2 All labels are visible and in good conditions. x N/A 4 N/A N/A N/A5. 3 All wastes are segregated according to type and compatibility x N/A 4 N/A N/A N/A5. 4 All work areas are well kept clean and free of waste x N/A 2 N/A N/A N/A5. 5 A waste management procedure promoting the 4Rs principles is in place x x x N/A 4 N/A N/A N/A

Storage Area

5. 6 Hazardous waste storage area is protected from the elements, i.e., equipped with a roof, walls, impermeable floor and has an adequate retention capacity in case of spill x N/A 4 N/A N/A N/A

5. 7 A spill kit, containing sufficient absorbant material, is located in the vicinity of the hazardous waste storage area x N/A 4 N/A N/A N/A

5. 8 Hazardous waste storage areas are located at a safe or legally required distance from a watercourse, a well, a sewer, a drainage ditch or other sensitive areas x N/A 3 N/A N/A N/A

5. 9 Hazardous waste storage tanks are protected to avoid collisions with vehicles by either posts, jersey barriers, guardrails, etc. x N/A 4 N/A N/A N/A

5. 10 Bulk hazardous waste stored in containers are covered by an impervious tarp x N/A 3 N/A N/A N/A5. 11 All waste storage areas are kept clean x N/A 2 N/A N/A N/A

Concrete and Sandblasting Residues

5. 12 Residual concrete from concrete mixer trucks is emptied in a watertight container or washout pit x N/A 4 N/A N/A N/A

5. 13 Sandblasting residues are recovered and adequately managed x N/A 2 N/A N/A N/ABiomedical Waste

5. 14 Biomedical waste are stored in identified dedicated containers x N/A 3 N/A N/A N/A5. 15 Biomedical waste are transported off site and disposed of in authorized sites x x N/A 4 N/A N/A N/A

Transportation and Disposal5. 16 Trucks and containers used to transport hazardous waste are proprely labeled x x N/A 3 N/A N/A N/A5. 17 Authorized hazardous waste carriers are used x x N/A 4 N/A N/A N/A5. 18 Shipping and disposal documents are kept on site and readily available x N/A 3 N/A N/A N/A5. 19 Waste are disposed of in authorized sites (e.g. recycling facilities or landfills) x x N/A 4 N/A N/A N/A

Log 5. 20 If required, a waste management and elimination log is maintained x N/A 4 N/A N/A N/A

Totals 0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Ref.

SCORE RESULTS

Environmental Audit

Source RISK


Auditor:Audit Date:

Project Number :

COMMENTS

Hazardous Materials Management D O I

REP

EATI

NG

IS

SUE

(X)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT 1-4 Score Points Missed Outcome

Hazardous Material Storage

6. 1 All hazardous material containers are properly identified with respect to their content and product class x N/A 4 N/A N/A N/A

6. 2 All labels are visible and in good conditions x N/A 4 N/A N/A N/A

6. 3 All hazardous material containers are placed within secondary containment having a sufficient retention capacity x N/A 4 N/A N/A N/A

6. 4A list of hazardous materials stored on the site including the estimated quantity is kept up to date. x x N/A 3 N/A N/A N/A

6. 5 Up-to-date SDS of hazardous materials used on site are available x x N/A 3 N/A N/A N/A

6. 6 Hazardous materials containers are stored at a safe or legally required distance from a watercourse, a well, a drainage ditch, a sewer or other sensitive areas x N/A 3 N/A N/A N/A

6. 7 Spill-kits are located in the vicinity of hazardous materials storage and present in sufficient quantities x N/A 3 N/A N/A N/A

6. 8 Stored hazardous materials are compatible x x N/A 3 N/A N/A N/A

6. 9 Appropriate fire extinguishers are available at the storage site and are in working condition x N/A 3 N/A N/A N/A

6. 10 Gas cylinders are stored vertically in dedicated cages and secured by a chain or strap x N/A 3 N/A N/A N/A

Petroleum Product Storage6. 11 Storage tanks are properly identified as per their content and capacity x x N/A 4 N/A N/A N/A6. 12 All labels are visible and in good conditions x N/A 4 N/A N/A N/A

6. 13 Storage tanks are either double-wall or placed within secondary containment having a sufficient retention capacity x x N/A 4 N/A N/A N/A

6. 14 Storage tanks are stored at a safe or legally required distance from a watercourse, a well, a sewer or other sensitive areas x N/A 4 N/A N/A N/A

6. 15 Storage tanks are protected to avoid collisions with vehicles by either posts, jersey barriers, guardrails, etc. x N/A 4 N/A N/A N/A

6. 16 Areas surrounding petroleum product storage tanks are clutter free x N/A 3 N/A N/A N/A6. 17 Fire extinguishers are located in the vicinity of the storage tanks x N/A 3 N/A N/A N/A

6. 18 Containers having a capacity less than or equal to 25 liters are approved (CSA, ULC or equivalent) x N/A 3 N/A N/A N/A

Transportation

6. 19 Trucks and containers are properly labeled with respect to their content and product class x x N/A 4 N/A N/A N/A

Totals 0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Ref.

SCORE RESULTS

Environmental Audit

Source RISK


Auditor:Audit Date:

Project Number :

COMMENTS

Lighting Management D O I

REP

EATI

NG

IS

SUE

(X)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT 1-


7. 1 Lighting respect applicable legal and other requirements x x N/A 4 N/A N/A N/A

7. 2

In sensitive areas, lighting is controlled by using any of the following when considered safe for workers: Direct lighting to illuminate only the required area, use of directional light devices, use of dimmers to control light intensity, use of high barriers, lights are turned off when there is no wok in progress.

x x N/A 3 N/A N/A N/A

Totals 0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Ref.

Environmental Audit

Source RISK SCORE RESULTS


Auditor:Audit Date:

Project Number :

COMMENTS

Vehicles and Equipment Management D O I

REP

EATI

NG

IS

SUE

(X)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT 1-


Refueling

8. 1 On-site refueling is carried out either in dedicated areas with impermeable surface or using impermeable liner or absorbent sheets x x N/A 4 N/A N/A N/A

8. 2 Spill kits and fire extinguishers are available at refueling stations and on all fuel trucks x x N/A 4 N/A N/A N/A

8. 3Refueling activities are carried out at a safe or legally required distance from a watercourse, a well, a sewer or other sensitive areas x x N/A 4 N/A N/A N/A

8. 4 Refuelling activities are supervised at all times x x N/A 4 N/A N/A N/A8. 5 A "No Smoking / Turn-off Engine" sign is posted at refueling areas x N/A 3 N/A N/A N/A

Maintenance

8. 6 If mechanical maintenance is carried out on site, it is performed in a dedicated and approved area x x N/A 3 N/A N/A N/A

8. 7Emergency mechanical maintenance requiring to be performed outside dedicated area are done using impermeable liners or drip pans to protect the ground and using absorbent

x N/A 4 N/A N/A N/A

8. 8 Maintenance activities are carried out at a safe or legally required distance from a watercourse, a drainage ditch, a well, a drainage ditch, a sewer or other sensitive areas x N/A 3 N/A N/A N/A

8. 9 Absorbent materials are available on all off road vehicles in case of spill x N/A 3 N/A N/A N/A

8. 10 Preventive maintenance on all vehicles and equipment is being carried out on a periodical basis x x N/A 3 N/A N/A N/A

Stationary Equipments

8. 11 All stationary diesel and gasoline equipment are equipped with a drip pan x N/A 3 N/A N/A N/A

Totals 0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Ref.

Source RISK

Environmental Audit

SCORE RESULTS


Auditor:Audit Date:

Project Number :

COMMENTS

Radioactivity D O I

REP

EATI

NG

ISSU

E(X

)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT


9. 1 Permits and approvals have been obtained for the use of equipment containing radioactive sources x x x N/A 4 N/A N/A N/A

9. 2Work areas where X-rays are carried out are well identified and their access is restricted

x x N/A 3 N/A N/A N/A

9. 3 Storage areas for equipment containing radioactive sources are adequate and identified by warning signs x N/A 3 N/A N/A N/A

9. 4 Personel using equipment containing radioactive sources are adequately trained and possess a valid certificate x x x N/A 4 N/A N/A N/A

Totals 0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Ref.

SCORE RESULTS

Environmental Audit

Source RISK


Auditor:Audit Date:

Project Number :

COMMENTS

Soil and Excavation D O I

REP

EATI

NG

IS

SUE

(X)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT


Excavation10 1 Stripping, clearing and excavations are limited to current work areas x x N/A 3 N/A N/A N/A10 2 If required, the topsoil is set aside to be used in final development works x x N/A 2 N/A N/A N/A

10 3 If required, measures to limit the accumulation of rainwater in the excavations are in place (e.g. earth berm around the perimeter of the excavation) x N/A 3 N/A N/A N/A

Contamined soil10 4 Prior to excavation existing characterization studies have been consulted x x x N/A 4 N/A N/A N/A

10 5 Contaminated soils are stored in leak proof containers or on an impervious surface and protected againts the elements x N/A 4 N/A N/A N/A

10 6 Contaminated soils are subject to in-situ treatment or are disposed of at an authorized site x x N/A 4 N/A N/A N/A

10 7 Contaminated soils disposal documents are available x x N/A 4 N/A N/A N/A10 8 A contaminated soil log is kept up-to-date x N/A 3 N/A N/A N/A

Borrow pit10 9 Borrow pits are authorized x x N/A 4 N/A N/A N/A

Totals 0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Ref.

RESULTS

Environmental Audit

Source RISK SCORE


Auditor:Audit Date:

Project Number :

COMMENTS

Flora and Fauna Protection D O I

REP

EATI

NG

IS

SUE

(X)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT


11 1 If required, specific requirements related to the protection of flora and fauna are known and implemented on site x x x N/A 4 N/A N/A N/A

11 2 If required, awareness programs related to flora and fauna protection are presented to all employees x x N/A 4 N/A N/A N/A

11 3 If required, breeding areas for the birds/animals are identified and delimited x x N/A 4 N/A N/A N/A

11 4 Vehicles and equipment entering the site are free of soil and debris capable of transporting noxious weed seeds or roots x x x N/A 4 N/A N/A N/A

11 5 Only non invasive species are used x x N/A 4 N/A N/A N/A

11 6 Pesticides are avoided or low toxicity, persistence and bioavailability pesticides are used. x x N/A 4 N/A N/A N/A

11 7 Unjustified killing/hunting/capturing of animals is prohibited on site x N/A 3 N/A N/A N/A11 8 Unjustified cutting/harvesting of vegetation is prohibited on site x x N/A 3 N/A N/A N/A

Totals 0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Flora/Fauna

Ref.

Environmental Audit

RISKSource SCORE RESULTS


Auditor:Audit Date:

Project Number :

COMMENTS

Social Interaction and Archeology D O I

REP

EATI

NG

IS

SUE

(X)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT


12 1 All groups, communities and neighbourhoods that might be impacted by the construction activities have been identified x x N/A 4 N/A N/A N/A

12 2 If required, specific social programs requirements are known and implemented x x N/A 4 N/A N/A N/A

12 3 If required, communication plans with local population are in place x x N/A 4 N/A N/A N/A

12 4 Measures are in place to protect the surrounding public property x x x N/A 3 N/A N/A N/A

12 5 Local goods and services are used as much as possible x x N/A 3 N/A N/A N/A

12 6 A procedure is implemented to address inquiries and complaints formulated by local population x x x N/A 4 N/A N/A N/A

12 7 If required, an archaeological sites protection program is known and implemented x x N/A 4 N/A N/A N/A

12 8 Any unexpected archeological discovery is properly documented x x x N/A 3 N/A N/A N/A

Totals 0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Social Interaction

Archeology

Environmental Audit

Ref.



Auditor:Audit Date:

Project Number :

COMMENTS

Environmental Incident Response D O I

REP

EATI

NG

IS

SUE

(X)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT


Communication

12 1 Environmental Incident Response Plan requirements are communicated to all employees and contractors's personnel during the orientation session x x N/A 4 N/A N/A N/A

12 2 The Environmental Incident Response Plan is distributed to relevant personnel x x x N/A 4 N/A N/A N/ADrills

12 3 Drills(table top or field exercise) are carried out at least once a year and documented. x x N/A 3 N/A N/A N/A

Spill kit 12 4 Adequate number of spill kits are available on site x N/A 3 N/A N/A N/A12 5 Spill kits content are regularly inspected x x N/A 3 N/A N/A N/A

Notification12 6 All environmental incidents are documented x x N/A 4 N/A N/A N/A

Totals 0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Ref.

Environmental Audit

RISKSource SCORE RESULTS


Auditor:Audit Date:

Project Number :

COMMENTS

Rehabilitation of Laydown Areas D O I

REP

EATI

NG

IS

SUE

(X)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT 1-


13 1 When work activities are completed by a Contractor, the site is cleared of equipment N/A 4 N/A N/A N/A13 2 When work activities are completed by a Contractor, the site is cleared of unused materials

N/A 4 N/A N/A N/A

13 3 When work activities are completed by a Contractor, the site is cleared of waste N/A 4 N/A N/A N/A13 4 When work activities are completed by a Contractor, the site is left free of oil stains N/A 4 N/A N/A N/A

0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Totals

Ref.

Environmental Audit



Auditor:Audit Date:

Project Number :

Reference COMMENTS

Site Specific Permit, Regulation, BMP D O I

REP

EATI

NG

IS

SUE

(X)

PointsAwarded (0-

5)or N/A

PRIORITY WEIGHT 1-


14 1N/A N/A N/A N/A

13 2 N/A N/A N/A N/A13 3 N/A N/A N/A N/A13 4 N/A N/A N/A N/A13 5 N/A N/A N/A N/A

14 6 N/A N/A N/A N/A

14 7 N/A N/A N/A N/A14 8 N/A N/A N/A N/A14 9 N/A N/A N/A N/A14 10 N/A N/A N/A N/A14 11 N/A N/A N/A N/A14 12 N/A N/A N/A N/A14 13 N/A N/A N/A N/A14 14 N/A N/A N/A N/A14 15 N/A N/A N/A N/A14 16 N/A N/A N/A N/A

14 17 N/A N/A N/A N/A14 18 N/A N/A N/A N/A

14 19 N/A N/A N/A N/A14 20 N/A N/A N/A N/A14 21 N/A N/A N/A N/A14 22 N/A N/A N/A N/A14 23 N/A N/A N/A N/A14 24 N/A N/A N/A N/A14 25 N/A N/A N/A N/A

0 0 0 0 100.0%

OK 0X 0

XX 0XXX 0

XXXX 0

Ref.

Totals

Environmental Audit
