critical risk control

GROUP PROCEDURE

Critical Risk Control

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Uncontrolled when Printed

OVERVIEW

This document provides the mandatory requirements to support implementation and conformance with Critical Risk Control element of the CBH Integrated Management System (IMS).

Contents

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

2. WORKING AT HEIGHTS ...................................................................................................................................... 10

3. CONFINED SPACE .............................................................................................................................................. 11

4. FIXED EQUIPMENT AND ENERGY ISOLATION ................................................................................................ 13

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5. MOBILE PLANT .................................................................................................................................................... 15

6. HEAVY AND LIGHT MOTOR VEHICLES ............................................................................................................ 17

7. RAIL ...................................................................................................................................................................... 19

8. DUST EXPLOSIONS AND FIRE .......................................................................................................................... 20

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9. ELECTRICITY ....................................................................................................................................................... 21

10. DANGEROUS GOODS ......................................................................................................................................... 22

11. FUMIGATION ........................................................................................................................................................ 23

12. TARPAULINS ....................................................................................................................................................... 24

13. CRANES AND LIFTING OPERATIONS ............................................................................................................... 26

14. STEVEDORING .................................................................................................................................................... 28

15. DOCUMENT CONTROL ....................................................................................................................................... 29

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1. INTRODUCTION

The health and safety of all CBH employees is paramount when conducting business activities across all our sites. Through our shared experiences and analysis of our incidents, we have identified where our greatest risk exposure to potentially fatal or permanently disabling injuries are for our employees and Contractors. From those insights, we have determined CBH’s Critical Risks and defined the Critical Controls required to keep our people safe.

Our focus is always to leverage the “Hierarchy of Controls” to eliminate all risks. When this is not possible, the Critical Risk Control (CRC) Group Procedure provides the mandatory controls that shall be implemented for tasks involving Critical Risks. A Critical Control is crucial to preventing or mitigating the consequences of a high severity event. The absence or failure of a Critical Control would significantly increase the consequence despite the existence of other controls.

All personnel working on a CBH sites are required to understand our Critical Risks and how they are managed. It is everyone’s responsibility to manage tasks involving Critical Risks effectively, so we achieve our safety vision: that everyone returns home safety at the end of every day.

Objectives

The Critical Risk Control (CRC) Group Procedure contains a set of mandatory minimum health and safety requirements that apply to all CBH operations and projects. The CRC Group Procedure defines the Critical Controls required to manage CBH identified Critical Risks.

The CRC Group Procedure does not replace the Health and Safety elements of the CBH Integrated Management System (IMS). It has been designed to emphasise the most crucial requirements in the system to manage risks which have the potential to cause fatal or permanently disabling serious injuries.

The CRC Group Procedure is a practical reference to assist with implementing the required Critical Controls into every element of planning and execution of work that involves Critical Risks. No Critical Risk activities shall be completed where an individual is working alone.

Scope

The Critical Risk Group Procedure is applicable to all employees and Contractors across all CBH Sites

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Critical Controls

Critical Controls are essential in preventing fatalities or permanently disabling serious injuries. The failure of a Critical Control has the potential to trigger a significant incident, hence they must always be effectively implemented across the entire business.

When Critical Controls are found to be ineffective, the work activity should not start and/or must be stopped immediately

Work should only proceed when effective controls have been identified and are in place, consistent with CBH Safe System of Work Requirements. The “Hierarchy of Controls” should be used to maximise the effectiveness of critical controls with an emphasis on Elimination

Exemptions

Where a part of the business deems it is not reasonably practicable to meet one or more of the requirements defined within this Group Procedure, they can apply for a dispensation for a specific period which requires endorsement by the relevant Area/General Manager. The dispensation must be documented by completing a High Level Risk Assessment, which outlines:

• The reason for the request

• The part of the business that the dispensation applies to

• The specific duration of the dispensation

• An assessment of the risk of not complying with the CRC requirement defined in this document, and

• Other controls that will be put in place as an alternative.

Process Flow

Identify Critical Risks

Identify Critical

Controls

Document and define

Critical Control

Performance

Requirements

Implement Critical

Controls

Verify Critcial Control Field Performance

Report on Critical Risk Performnce

Review and Improve

Critical Risk Management

Systems

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Roles and Responsiblites

Role Responsibilities

Chief Operations Officer ▪ Monitor the implementation and performance of the Critical Risk Program. Shall be consulted and approve any changes to the program structure, framework, performance.

Head of Health, Safety and Environment

▪ Manages the implementation and performance of the Critical Risk Program. Shall be consulted and recommend any changes to the program structure, framework, performance.

Critical Risk Owners ▪ Ensures the implementation and performance of the Critical Risk Program within the business. Shall be consulted and recommend any changes to the program structure, framework, performance.

▪ Shall ensure that a Risk Reduction Plan is developed and maintained for relevant Critical Risks

Critical Risk Specialist ▪ Establish and maintain the Critical Risk Program in line with the requirements of this procedure.

▪ Review, recommend and implement continuous improvements to the Critical Risk Program.

▪ Provide advice, support and direction to Critical Risk Owners, Senior Management and Zone personnel on the implementation of this procedure

▪ Review this procedure annually inclusive of the systems and processes referred to in this procedure, and resources that support Critical Risk management.

References

Table 1: External References

Reference

International Council on Mining & Metals Critical Control Management Implementation Guide

Table 2: CBH References

Reference STORE ID

Critical Risk Control Standard STORE-1473931053-249

https://www.icmm.com/website/publications/pdfs/health-and-safety/9722.pdf

https://cbh4.sharepoint.com/sites/store365/_layouts/15/DocIdRedir.aspx?ID=STORE-1473931053-249

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Definitions

Term Definition

Critical Lift A Critical Lift is defined as follows:

▪ The load, including rope, block, rigging etc are greater than 80% of the crane’s capacity.

▪ Complex tilt up and pre-cast concrete lifts.

▪ Lifts involving personnel cages.

▪ Lifts over and around powerlines.

▪ Lifts at maximum load rates.

▪ Single lifts of multiple loads at different heights (staggered lift).

▪ Any lifting of hazardous materials.

▪ Lifts over facilities whereby personnel may be endangered.

▪ There are multiple cranes involved in the lift, and

▪ Loads being lifted through tight or restricted spaces.

Fixed ladder Australian Quarantine and Inspection Service

Hazardous Area An area in which an explosive atmosphere is present, or may be expected to be present, in quantities such as to require special precautions for the construction, installation and use of equipment (AS/NZS 60079.14:2017).

HVA Heavy Vehicle Accreditation

HVO High Voltage Switching Operator

Intrinsically Safe Electrical apparatus in which all the circuits are intrinsically safe.

JSA Job Safety Analysis

LEL Lower Explosives Limit

Lifting Gear Components or equipment used between lifting device and the load being lifted, which are not an integrated part of the lifting device. E.g. shackles, slings, chains, ropes

Mobile Plant Any vehicle that operates on a CBH site is considered mobile plant. These vehicles include but are not limited to:

• Heavy Vehicles,

• Light Vehicles,

• Front End Loaders,

• Road sweepers,

• Cranes, Forklifts and Skid Steers

T&Cs Terms & Conditions

WA Western Australia

OEM Original Equipment Manufacturer

Operational Control Point

One of the key controls to minimise work carried out in the high-risk area, established as a minimum of 5m upwind from the high-risk area, defined as the area between the vehicle and the injection point as well as the inside of the vehicle.

PDG Project Delivery Group

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Term Definition

PPE Personal Protective Equipment

P&ID Piping and Instrumentation Diagram

Platform Ladder A Platform Ladder is a self-supporting portable ladder that is non-adjustable in length, with a platform provided at the highest intended standing level that prevents falls from the platform with a drop bar, self-closing gate or similar.

Portable Ladder A ladder that can readily be moved or carried, usually consisting of side rails joined at intervals by step, rungs, cleats, or rear braces.

Secure Working Platform

A non-mobile platform or area that has:

• A surface that is structurally capable of supporting all persons and things placed on it

• Barriers around its perimeter and any openings to prevent a fall

• An even and readily negotiable surface and gradient

• A safe means of entry and exit.

Simple Isolation • Four or less isolation points

• Low residual risk outcome in a Risk Assessment

• Require a suitable risk assessment (Take 5 or JSA) but do not require a Permit.

Example: routine maintenance work performed by individual maintenance workers or small groups.

SARF Site Access Request Form

SOP Standard Operating Procedure

VTS Vehicle Tracking System

VOC Verification of Competency: A practical assessment of an individuals’ ability to operate a specific mobile plant, tool or perform a process within a CBH work site.

Work at Height Risks to health and safety associated with a fall by a person from one level to another that is reasonably likely to cause injury to the person or any other person.

• As a minimum, falls risk of 2m or more must be treated as work at height, but may also be the risk of a fall:

• In or on an elevated workplace from which a person could fall;

• In the vicinity of an opening or surface through which a person could fall;

• In the vicinity of an edge over which a person could fall;

• On a surface through which a person could fall; or

2 x 2 x 2 Rule When working above 2 metres, within 2 metres of an open edge or where there is a risk of falling more than 2 metres a working at heights permit is required

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Information Management

System Description

SHARE SHARE (Safety Health Audit Risk and Environment) is the CBH online database for all Safety, Environmental and Quality recordings, and enables staff to view and report trends, active and inactive items, assign, escalate and share investigation responsibilities. Events may be entered as a Hazard, Incident or Action depending on specifics.

CRM Customer Relationship Management. Used by BRMs/Fertiliser Team and GSC to manage grower accounts.

IBIS Stock management system. Stores delivery data and stock ownership data.

SAP Enterprise management system used for accounting, credit management, invoicing, procurement and HR management.

TPS Trading Position Summary. Spreadsheet used to evaluate and monitor financial position and risk.

Power BI Tool for data analysis and quick view of data. Used by BRM, GSC and Fertiliser team

Communication

The document owner is responsible for communicating and making available this document to all stakeholders. The document is available to all staff on the company intranet.

Compliance Management

CBH are required to comply with international and national legislated requirements, accreditations and standards. To achieve this staff are required to comply with all Policies, Procedures and Work Instructions provided to them. Regular reviews and audits will be performed by internal and external parties as required to ensure compliance is being achieved. If a non-compliance or breach is identified the Chief Audit and Risk Officer and the Group Risk, Quality and Assurance Manager must be notified as soon as practically possible.

Change Management

Changes to this document shall be managed, reviewed and updated as described in the Document Control Content and Records Management Group Procedure.

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2. WORKING AT HEIGHTS

Life Saving Rule

Do not work outside an elevated walkway or platform without an approved fall prevention system in place.

Application

This Group Procedure applies to any task where there is a risk of fatality or significant incident from falling or objects dropped from height. This applies to all work carried out above 2 metres without fixed platform and handrails.

Critical Controls

Hazard Risk and Change Management Group Procedure

When traversing platforms or ladders at height, individuals shall carry out task-based risk assessments (take 5 or JSA). Key risks to consider include equipment condition and weather conditions.

Permit to Work Group Procedure – Working at Heights

Working at Heights Permit

▪ Always apply to 2 x 2 x 2 rule – when you need to work above 2 metres, within 2 metres of an open edge or there is a risk of falling more than 2 metres where this is a risk of serious injury (i.e. impalement risks) you need to have a Working at Heights permit.

▪ If there is a chance of dropped objects an exclusion zone that is taped and signed below the work area shall be in place. Controls shall consider securing of tools such as using lanyards, drop sheets or larger exclusion zones.

▪ You must have an approved working at heights permit prior to accessing a roof

Platform/ Fixed and Portable Ladders

▪ Platform Ladder levels shall be enclosed when the platform is used for work e.g. use of self-closing gates or drop bars

▪ When climbing portable ladders, three points of contact shall be maintained at all times.

▪ Portable ladders shall be inspected prior to use and used in accordance with AS/NZS 1892.5:200 Portable ladders - Selection, safe use and care

▪ If conducting work of a ladder where three points of contact cannot be maintained at 2 metres or more a working at height permit and fall prevention mechanisms should be in place.

Scaffolding:

▪ Always make sure that scaffolding has been inspected by a competent person within the last 30 days. Check the Scaff Tag and if it not current (inspected within the last 30 days) then the scaffolding is not to be used

Working Outside Handrails, Fixed Platforms or Elevated Work Platforms

▪ You must have an approved working at heights permit prior to undertaking the work

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▪ Any personnel required to work outside handrails, access platforms or elevated work platforms, EWP’s shall be trained and competent in working at heights and or have a current High-Risk Work License (EWP).

▪ You must have a documented emergency response plan in place for the work

▪ Personnel must maintain 100% hook up at all time during when working at heights

3. CONFINED SPACE

Life Saving Rule

Do not enter a confined space without an approved confined space entry permit.

Application

This Group Procedure applies to any task where persons are entering or conducting tasks within a confined space and where there is a risk of a fatality from unsafe oxygen levels, airborne contaminant or engulfment, dangerous wildlife or where an incidents’ consequence/s are more severe due to restricted access.

Critical Controls

Confined Space Entry Documented Process

There shall be a documented Confined Space Entry process that includes:

• Isolation requirements for the confined space

• Requirements for breathing apparatus

• Sign-in and sign-out of all persons entering the confined space

• Communication equipment

• Safety specifications of equipment to be taken into the confined space

• Rescue plan and equipment

• Additional ventilation (where applicable), and

• A completed Job Safety Analysis or specific Work Instruction for the task.

Permit to Work Group Procedure – Confined Spaces

▪ Procedures and processes to conduct hot work and cleaning (e.g. abrasive blasting, water cleaning) inside of a confined space shall be reviewed and authorised by the permit issuer prior to entry in accordance with AS 2865-2009: Confined spaces.

▪ A Confined Space permit shall be in place and filled out in its entirety including:

• Rescue Plans shall be in place and understood by personnel entering the confined space prior to work commencing

• The atmosphere within the Confined Space shall be confirmed to be safe prior to entry with ventilation techniques employed where necessary. Atmospheric testing prior to entry shall be carried out and include oxygen levels, contaminants, temperature extremes and flammable substances.

• Continuous atmospheric monitoring of the confined space shall be undertaken whilst personnel are in the confined space

• While work is being conducted in a confined space the concentration of any flammable gas, vapour or mist in the atmosphere of the space is required to be less than 5% of its Lower

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Explosives Limit (LEL). If at any time the concentration of flammable gas is greater than or equal to 5% of its LEL, all workers shall be immediately removed from the confined space.

▪ Personnel shall inspect the confined space for fauna such as snakes prior to commencing confined space entry. Isolations detailed on an isolation permit shall be in place and confirmation that energy has been released and controlled prior to entry into a confined space

▪ All personnel entering a confined space shall have Personal Protective Equipment, PPE for Confined Space Entry as defined in the Permit to Work Group Procedure and PPE shall be worn at all times during a confined space entry.

Training and Competency

▪ All persons required to work in a confined space, to act as a standby person, or to conduct/monitor for hazardous atmosphere in the confined space for clearance purposes, shall hold the applicable current National Competency

▪ The standby person will have no other duties and shall always be continuously positioned outside the confined space entry point while personnel are within the space.

Confined Space Warning Signs

▪ Confined spaces shall be identified, and signs erected at the entry points denoting authorised entry only in accordance with AS 1319-1994: Safety signs for the occupational environment.

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4. FIXED EQUIPMENT AND ENERGY ISOLATION

Life Saving Rule

Do not work on or enter any plant or equipment which has not been isolated from all sources of energy unless specifically permitted by an approved procedure for operating, testing, commissioning or hygiene purposes.

Application

This Group Procedure applies to all fixed plant equipment including stackers, trippers and conveyors used on CBH sites and all isolations required across the business including but not limited to Electrical, Mechanical, Fixed Plant and Equipment and Mobile Plant.

Critical Controls

Fixed Equipment Standards and Maintenance Schedules

▪ All new or replacement fixed assets shall be designed, procured and maintained in line with CBH Engineering Design Standards for fixed equipment & the maintenance procedures detailed in the SAP Maintenance module.

▪ All fixed equipment parts and spares shall be procured in line with the parts lists defined by the fixed equipment design standards. If parts are required that do not comply with these requirements, then the Engineering and HSE Management of Change processes shall be undertaken prior to procurement.

▪ Guarding shall be installed and maintained where risk of harm exists through inadvertent exposure to moving parts or projectiles. Guarding shall meet the relevant Australian Standards or shall be subject to a risk assessment as required by the Engineering Management of Change Process and shall include consultation with operational area representatives.

▪ All controls systems shall be constructed and maintained in line with the requirements of the design standard quoted in the Engineering Management Plan

▪ Any changes to fixed equipment or plant shall be approved under the Engineering and HSE Management of Change process prior to changes being implemented

▪ Maintenance and inspections schedules shall be developed for all fixed equipment and plant including safeguards such as guarding and interlocks and shall managed within the SAP Maintenance module

▪ For safety critical maintenance issues, hazards shall be entered into SHARE and the equipment shall be made safe and tagged with an out of service tag. Non-critical maintenance issues shall be managed via the Maintenance Notification process within SAP.

Maintenance of Fixed Equipment

▪ Only trained and competent people are to work on fixed equipment or fixed plant. Operations personnel shall be trained in the relevant Standard Operating Procedure (SOP) for the task they are performing. Maintenance personnel shall have the appropriate trade qualification and follow the relevant maintenance work instruction for the task.

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Prior to undertaking work on fixed equipment or plant a task-based risk assessment (Take 5 or JSA) shall be undertaken prior to work commencing.

Permit to Work Group Procedure

▪ Working on live equipment during commissioning and testing shall only be undertaken by trade qualified personnel and be undertaken in compliance with the Permit to Work Group Procedure. At a minimum a JSA shall be undertaken prior to undertaking live work.

Approval to Access Operational Sites

▪ CBH owned or operated sites shall ensure all personnel visiting site are managed under the Site Access Request Form (SARF) process. Communication with the Area Manager shall also occur prior to arriving on site.

▪ Management of visitors shall be in line with the requirements of the Personal Health and Safety Standard.

▪ Inductions for Growers and other Third Parties accessing CBH sites during harvest shall be conducted and information on CBH safety requirements and standards shall be communicated.

Permit to Work Isolation

All Isolations:

▪ Only trained, experienced and competent operations personnel and tradespeople are to undertake isolations

▪ Always plan isolations in line with the requirements of the Permit to Work Group Procedure and consult applicable as-built drawings, schematics, P&ID's (process & Instrumentation diagrams) and wiring diagrams.

▪ Authorised Isolators shall check for zero energy and confirm all appropriate isolations are in place prior to any work commencing

▪ Harvest casuals shall only place their personal isolation lock and tag under the direct supervision of a CBH authorised isolator.

Simple Isolation:

▪ Simple isolations involving four or less isolation points and assessed as low risk as per the Permit to Work Group Procedure do not require a permit but do require a Take 5 or JSA to be completed.

Complex or Permit Isolations:

▪ Isolations defined as complex or group isolations in the Permit to Work Group Procedure including fumigation isolations, shall only be undertaken by personnel trained and competent as Authorised Isolators.

▪ When undertaking isolation activities where there is a risk of arc flash occurring approved arc flash PPE of adequate category rating shall be worn at all times

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▪ HV switching shall only be completed by an approved High Voltage Operator (HVO) and shall only commence when an authorised switching program is in place. When re-energising high voltage equipment an approved switching program shall be used by an authorised HVO

▪ All fumigations shall be undertaken in line with the requirements of the isolation section of the Permit to Work Group Procedure

▪ All fixed equipment shall be maintained in accordance with the relevant Preventative Maintenance, PM schedule to ensure the integrity of isolation capabilities of the equipment is maintained.

5. MOBILE PLANT

Mobile plant includes, but is not limited to front-end loaders, stackers, and drive-over-grids (DOGs) and heavy vehicles such as Intrasilo and Road Transport Contractor vehicles on CBH sites. Note that this excludes light vehicles for further information see section 6 of this procedure.

Life Saving Rule

Do not enter any mobile plant exclusion zone without three-step protection in place:

1. Hand brake is on

2. Vehicle is in neutral

3. Operator has hands off controls.

Application

This Group Procedure applies to all mobile plant used on CBH sites including heavy vehicle movements to deliver or receive grain

Critical Controls

Vehicle and Traffic Management Group Procedure

▪ All CBH sites shall have signage for the control of mobile plant and vehicle movements in accordance with the requirements of the Vehicle and Traffic Management Procedure

▪ A risk assessment shall be completed for mobile plant and vehicle movements to determine barricading and exclusion zone requirements. Access to designated exclusion zone shall be controlled and managed. No one will enter an exclusion zone without approval from the employees undertaking the work

▪ Pre-start meetings at all sites shall discuss mobile plant movements for the site and what controls shall be implemented to control Mobile Plant risks

▪ All heavy vehicles services, including non-grain related heavy vehicles such as freight services, shall comply with the requirements of the Contractor Management Standard. This shall include ensuring that all drivers are aware of CBH site requirements prior to accessing CBH owned sites.


▪ Always consider plant and vehicle movement during task-based risk assessments such as Take 5 or JSA’s

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Inductions Training and Competency

▪ CBH shall communicate pedestrian and mobile plant interface and safety requirements and minimum standards to any third party (such as grower transport providers) operating mobile plant on a CBH controlled site

▪ Each site must ensure drivers are licensed, trained, assessed as competent and authorised to operate in accordance with the vehicle and route safety requirements.

Maintenance and Inspection of Mobile Plant

▪ All CBH mobile plant and heavy vehicles shall be maintained in accordance with OEM requirements and the maintenance schedule shall be in SAP

▪ Pre-start inspections shall be conducted and documented prior to operating mobile plant.

Grain Receival SOP and Outload Grain SOP

▪ All personnel onsite shall adhere to the requirements of the Grain Receivals and Outload Grain SOP's

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6. HEAVY AND LIGHT MOTOR VEHICLES

Heavy and light motor vehicles include but are not limited to cars, cartage or specialist equipment trucks such as water or concrete trucks and may be owned / used on CBH sites by CBH personnel, contractors and lessees, suppliers and customers (growers), or where heavy and light motor vehicle requirements are contractually required.

Life Saving Rule

Handheld operation of mobile phones is not permitted when driving a vehicle.

Application

This Group Procedure applies to all motor vehicle operation for work related purposes including:

• Passenger vehicles used by personnel to drive between sites

• Heavy vehicles used to transfer grain, and

• All other heavy vehicles including gang trucks, maintenance trucks, civil works, pest control trucks and earth moving trucks.

Critical Controls

Vehicle and Traffic Management Group Procedure

Journey Management

▪ Journey Management Plans shall be in place where the following applies:

• Travel to site is not part of primary employment

• Where a person is travelling alone or where multiple persons are travelling in a single vehicle

• Where adverse weather or conditions present increased journey risk.

• Journey Management Plans are not required if vehicles are travelling in a convoy.

Vehicle and Fleet Specifications

▪ CBH heavy vehicles shall be procured in accordance with the Heavy Vehicle Fleet Specification

▪ CBH light vehicles shall be purchased or hired in line with the requirements of the CBH light vehicle specification

▪ All light and heavy vehicles shall be maintained in accordance with original equipment manufacturer, OEM requirements. Heavy vehicles shall have a maintenance schedule in SAP and light vehicles shall be maintained in accordance with the fleet providers maintenance schedule.

▪ The CBH light vehicle fleet provider shall ensure that a maintenance and service system is in place and that records of maintenance activities are kept.

Vehicle Operation

▪ Pre-start inspections of light and heavy vehicles shall be undertaken and documented daily

▪ Vehicle operators shall ensure that they are not fatigued prior to driving CBH vehicles. Drivers shall also ensure that they are taking adequate rest breaks to manage fatigue when driving on CBH business

▪ Handheld operation of mobile phones shall not be permitted when driving a CBH vehicle

▪ A drug and alcohol screening program shall be in place that includes pre-employment, random and post incident testing.

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▪ All CBH personnel shall undertake driver training in SuccessFactors prior to operating CBH light vehicles

▪ Prior to operating heavy or light vehicles, drivers shall have the appropriate license and where required undertake further training such as Chain of Responsibility, HIAB or Heavy Vehicle Accreditation training and medical requirements.

Heavy Vehicle Accreditation

▪ Daily Trip Recording Sheets (DTRS) shall be kept up to date by CBH personnel working as Heavy Vehicle Accreditation, HVA operators

▪ Non HVA fatigue guidelines contained in the Personal Health and Safety Standard shall ensure that an HVA operator is appropriately rested prior to undertaking HVA operations.

Contractor Heavy Vehicle Critical Controls

Journey Management and Planning

▪ HVA Contractors shall ensure that journey plans are in place for all work conducted for CBH. These plans shall ensure that each route is assessed for route hazards with trip plans established and progress against plans monitored


▪ HVA Contractors shall ensure all personnel including Subcontractors are appropriately trained, licensed and competent to undertake Heavy Vehicle Transport

▪ HVA Contractors including their subcontractors shall ensure that a CoR system is in place for their operations that includes the following minimum requirements:

• Ensure that personnel in the transport chain are trained and made aware of their obligation under CoR legislation

• Vehicles are suitable for the task

• Loads are positioned correctly

• Appropriate restraint equipment is used

• Adequate load restraint is applied, and

• Driver hours and fatigue are appropriately managed.

Vehicle and Fleet Specifications

▪ HVA Contractors including their subcontractors shall ensure the following specifications are in place for all heavy vehicles:

• Heavy vehicles are speed limited, with vehicle speeds and transit times monitored by on-board GPS technology

• Ensure heavy vehicles are fitted with on-board GPS fatigue monitoring devices and fatigue management plans are in place and adhered to

• Ensure that heavy vehicle equipment is fitted with controls to prevent falls from height whilst accessing prime-movers and vehicle trailers for loading or unloading activities

• Ensure engineering controls such as anti-rollover braking systems are fitted to all assessed at-risk heavy vehicles.

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Vehicle Operation

▪ All HVA Contactors including their subcontractors shall ensure pre-starts are conducted and documented daily and vehicle maintenance records are maintained and available if requested by CBH

Heavy Vehicle Accreditation

▪ All HVA Contractors shall ensure all drivers including subcontractors complete daily log sheets that detail hours of work versus hours of rest. These shall be made available for review at the request of CBH personnel.

7. RAIL

CBH rail operations are part of our routine tasks and activities which require minimum mandatory controls to be applied to ensure these operations are executed safely.

Application

This Group Procedure applies to all rail operations on CBH sites.

Critical Controls

Outload Grain and Receive Grain SOP

▪ All rail activities are to be completed in accordance with the Outload and Receive Grain SOP’s.

▪ Prior to out loading or receiving grain under power, a prestart must be conducted with WATCO and this shall be documented by WATCO and CBH

▪ No person shall be on a garner bin or over rail infrastructure whilst a train is shunting under power.

▪ Track isolation required for CBH infrastructure maintenance shall be performed by an authorised Protection Officer/Yard Card.

▪ When discharging in motion physical exclusion zones and barriers shall be established to prevent fouling of live tracks or personnel straying onto live tracks.


▪ CBH personnel working within 5 meters (exclusion zone) of rail lines shall have a valid Track Access Permit.

▪ Only personnel trained and deemed competent (Protection Officer or Yard Card) with a valid Track Access Permit card shall undertake track isolations (shunting/maintenance/other direct rail activities)

▪ Only authorised personnel can enter the 3 meters danger zone from outer most edge of track.

▪ Fitness for work is confirmed for all personnel conducting rail activities (alcohol, drugs, fatigue).

Maintenance of CBH Rail Assets

▪ All rail maintenance issues shall be reported to line managers.

▪ All CBH operated private sidings shall have an inspection and maintenance program in place.

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8. DUST EXPLOSIONS AND FIRE

CBH is one of Australia’s largest grain transport and storage organisations and as a result of our activities we generate a large amount of grain dust which, when left in our storages to build up to unsafe levels, can result in fires and or grain dust explosions.

Application

This Group Procedure applies to all CBH sites.

Critical Controls

Management of Dust Fuel Loads

▪ Hygiene schedules for all hazardous areas shall be developed and input into SAP. Hygiene schedules shall be complied with to ensure that dust build up does not reach a potentially explosive level

▪ Dust loads shall be monitored and where there is a potential for dust explosion to occur hygiene and dust removal activities shall be undertaken.

Permit to Work Group Procedure – Hot Work

▪ When working in hazardous areas or where there is a risk of fire or dust explosion the following shall apply:

• All hot work outside designated areas approved for hot work (e.g. workshops) shall be undertaken under a Hot Work Permit as defined in the Permit to Work Group Procedure

• Contractors required to work in hazardous areas or where there is a risk of fire or dust explosion shall ensure they have an approved dust mitigation plan prior to work commencing

• CBH and Contractor personnel required to work in hazardous areas shall be inducted into the area, including a review of control measures in the area used to mitigate fire and dust explosions.

Electrical and Fixed Equipment Standards

▪ Electrical and fixed equipment in hazardous areas shall meet the requirements for Dust Ignition Protection as defined in the electrical and fixed equipment design standards

▪ All mechanical and electrical equipment shall be installed and maintained as per the relevant manufacturer and/or hazardous area certification requirements as defined in the electrical and fixed equipment standards

▪ All conveyors and elevators shall have misalignment and under speed sensors installed as required by the relevant fixed equipment standard in hazardous areas to prevent friction related ignition sources

▪ All mechanical and electrical equipment located in a hazardous area shall have preventative maintenance activities undertaken to prevent failure leading to potential ignition sources

▪ Portable equipment used in hazardous areas (such as UHF radios) is required to be intrinsically safe.

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9. ELECTRICITY

Application

This Group Procedure applies to all electrical work on CBH Sites.

Critical Controls

Fixed and Mobile Electical Equipment Standards

▪ Residual Current Devices shall be installed on all fixed equipment in line with the requirements of relevant Australian Standards and as defined by the CBH Design Standards and Equipment Specifications for fixed equipment.

▪ All Enhance, Sustain and Expansion work on fixed and mobile electrical equipment shall be undertaken in compliance with the CBH Design Standards

▪ Preventative maintenance schedules shall be developed and followed for all fixed and mobile electrical equipment

▪ Any changes to fixed electrical equipment shall be approved under the Engineering and HSE Management of Change process prior to changes being implemented

▪ All procurement of electrical fixed equipment shall be undertaken in line with the CBH Standards.

SOP Electrical (LV and HV) Works

▪ Portable Residual Current Devices shall always be used on all portable electrical equipment including hand tools.

▪ All portable and mobile electrical equipment shall be inspected prior to use

▪ Arc Flash PPE of the appropriate Arc Flash PPE Category rating shall always be worn when there is a risk of arc flash occurring.

High Voltage Equipment

▪ Access to secure high voltage areas shall be restricted to authorised high voltage trained electrical personnel by restricting access to electrical keys to authorised personnel only. A register of keys and who they have been issued to shall be kept

▪ High Risk High Voltage electrical equipment shall be signed in accordance with legislative requirements and the requirements of the Electrical (LV and HV) Works SOP.

Qualified and Competent Personnel

▪ Only appropriately qualified electrical personnel shall undertake electrical work on electrical equipment

▪ Only appropriately trained, qualified and passed out High Voltage Switching Operators (HVO) shall be allowed to operate HV switchgear

▪ All electrical personnel shall be trained and competent in electrical work in hazardous areas as defined by the Electrical (LV and HV) Works SOP

▪ Any personnel undertaking electrical work shall ensure they are fit for work and are not under the influence of drugs or alcohol, not fatigued or unfit to undertake the work.

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10. DANGEROUS GOODS

Application

This Group Procedure applies to all Dangerous Goods stored on CBH sites.

Critical Controls

Dangerous Goods Storage Compounds

▪ Access to Dangerous Good Storages shall be limited to essential personnel only

▪ Dangerous Goods Storages used to store fumigants shall have a current Dangerous Goods license issued by Department of Mines, Industry Regulation and Safety (DMIRS)

▪ Fumigation dangerous goods shall only be stored in storages that have been issued with a dangerous goods license issued by DMIRS

▪ Compliance checks on Dangerous Goods Compounds shall be undertaken in alignment with Protect Grain SOP section 6.2 and section 7.1.3

▪ Dangerous Good Compounds shall be appropriately signed, placard and always kept secure and locked as required under the relevant Dangerous Goods legislation

▪ Physical barriers as approved by the relevant Dangerous Good License for the Dangerous Goods Compound shall always be in place

▪ Self-contained breathing apparatus, SCBA shall be available at the compound whenever it is in use. No personnel shall enter a Dangerous Goods Storage Compound unless SCBA is present.

▪ Calibrated personal monitoring devices shall be worn when entering Dangerous Goods Compounds.

Dangerous Goods Transport

▪ Transport of dangerous goods shall be conducted in line with the requirements of the Protect Grain SOP and shall ensure that all transport activities comply with the requirements of any dangerous good license issued to CBH

▪ Transport of dangerous goods shall be conducted in line with the requirements of the Protect Grain SOP and shall ensure that all transport activities comply with the requirements of any dangerous good license issued to CBH

▪ CBH personnel transporting dangerous goods shall be appropriately trained and competent to do so.

▪ Grain Protection personnel shall be trained and competent to a minimum Level 3 Grain Protection Officer prior to transporting dangerous goods for fumigation.

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11. FUMIGATION

Life Saving Rule

Do not enter a grain storage or any area under fumigation unless authorised by a Licenced Fumigator.

Application

This Group Procedure applies to all fumigations completed by CBH and includes working adjacent to storages under fumigation.

Critical Controls

Protect Grain SOP

Competent and Trained Pest Control Personnel

▪ All personnel undertaking fumigation activities shall have at a minimum a Grade 3 competency as a Grain Protection Officer

▪ All Grain Protection personnel shall be trained and competent in the use of SCBA and shall be clean shaven at all times.

▪ All Grain Protection personnel shall participate in a minimum of 3 fumigation related emergency response drills annually.

Leak Testing Prior to Fumigation

▪ All storages to be fumigated must pass a leak test as required by the Protect Grain SOP.

▪ Under no circumstances shall a storage that has failed its leak test be placed under fumigation.

Restricted Access to Areas Impacted by Fumigation

▪ Exclusion zones shall be established for all fumigation activities as required by the Protect Grain SOP with access controlled at the Operational Control Point

▪ Adequate signage and barricading shall be in place for all fumigation activities that advise non-Grain Protection Personnel of the risk of fumigation within the area.

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12. TARPAULINS

Application

This Group Procedure applies to all handling of Tarpaulins on CBH sites.

Critical Controls

Store Grain SOP

▪ All Tarping activities shall be risk assessed in line with the relevant SOP’s, Specifically, risk assessments shall cover:

• Wind speed-The level of risk assessment required to be completed prior to tarping commencing is referenced in the table below

• The number of personnel on site to safely undertake tarping activities, prior to commencement

• Means of edge protection when operating on open bulk heads

• Equipment to control tarp movements is in place and available prior to commencing tarping activities.

▪ If the risk assessment determines there are insufficient personnel on site to allow the safe execution of tarping activities, then tarping work shall cease in line with the stop work section of the Personal Health and Safety Standard

▪ Contractor Tarping companies shall have tarping systems and practices in place that are approved by the Grain Covers & Portable Infrastructure Manager prior to commencing tarping activities

▪ All tarping activities are to be supervised by experienced and trained personnel.

▪ No person shall walk on an unsecured tarpaulin on a stack.

▪ Personnel shall minimise time spent on tarpaulins laying loose on the ground in an uncontrolled state prior to folding. After folding each section personnel are to walk back down the side of the tarpaulin to minimise time spent on the unsecured tarpaulin on the ground.

▪ Where plant is used for handling and pulling tarpaulins, exclusion zones shall be in place and access to the work areas controlled

▪ Once tarps are removed, they shall be folded, rolled and stored as soon as it is safe to do so.

- Speed - Instruction

▪ (A) Below 30 km/hr winds

▪ A Personal Risk Assessment or “Take 5” will be performed to determine whether it is safe to proceed and to specify the required controls. The risk assessment will consider all weather conditions, experience level of personnel and physical capability of personnel

▪ (B) Between 30 and 45 km/hr winds

▪ A formal JSA must be completed to determine whether it is safe to proceed and to specify the required controls. In addition to considerations in (A) above, the JSA will explicitly consider:

wind direction

adequate number of personnel available to perform the task

use of a fan to remove air and “cryovac” the stack

the material of the tarp (e.g. PP tarps have a lower wind tolerance than PVC)

▪ (C) Between 45 and 60 km/hr winds

▪ A formal JSA must be completed to determine whether it is safe to proceed and required controls. In addition to considerations in (A) and (B) above, the JSA will consider:

A critical mandatory control will be to either:

• double the crew size to a minimum of 10 people or

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- Speed - Instruction

• to use machines to pull the tarps

▪ Tarping should be limited to pulling “with the wind” defined as the wind to be coming from +/- 45 degrees behind the tarpaulin to be pulled (i.e. if the stack is oriented north to south, the wind would need to come from between North West and North East)

▪ (D) Above 60km/hr winds

▪ No tarping activities shall be carried out when the wind is above 60 km/hr (defined as “gale force” winds by the Bureau of Meteorology)

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13. CRANES AND LIFTING OPERATIONS

Application

The Group Procedure applies to all cranes and lifting equipment and includes CBH owned, hired or contracted operators, equipment cranes such as but not limited to mobile, vehicle mounted, overhead and overhead travelling cranes.

Critical Controls

Permit to Work Group Procedure – Critical Lifts

▪ A documented lift plan for critical lifts is required that specifies the minimum competencies of persons who develop and approve lift plans. The lift plan shall include:

• Load data e.g. total weight, height of lift, item to be lifted.

• Equipment data e.g. manufacturer, model, size, jib length.

• Rigging data e.g. sling diameter, sling configuration, hook type, weight, capacity; lift computation e.g. boom length, size of outrigger footplates, radius of lift, centre of gravity, wind speed, and

• Proximity to hazards e.g. energised power lines, ground stability, people or other equipment.

▪ Critical lift plans shall be developed in accordance with the Permit to Work Group Procedure. Crane capacity, rigging and lifting equipment shall be risk assessed prior to work commencing

▪ Appropriately rated and fit for purpose rigging equipment and lifting points shall be considered during the pre-task planning activities e.g. JSA, HLRA or Critical Lift Permit

▪ A check shall be conducted prior to the lift to ensure that the load being lifted is within the rated capacity of the crane and lifting attachments/rigging equipment and is also within limits set out in the lift plan.

▪ Barricades or an exclusion zone shall be established around the crane that covers the entire working (including machine radius) area (Tail swing, drop zone) where there is a risk of a load falling and striking a person to prevent entry of unauthorised personnel.

▪ Loads shall not swing over people or occupied buildings and no person shall be under a suspended load or in a position where they could be struck by a falling load, be placed between the load and the crane or between the crane and a structure.

▪ Trial lifts shall be conducted for every lift (e.g. check/taking load and checking clearances).

▪ With exception of pick and carry operations, no lifting shall be carried out without outriggers deployed, locked and only used in line with the OEM standards.

▪ The operator shall not leave the crane controls while a load is suspended.


▪ Personnel shall be trained and have the appropriate High-Risk Work License for all lifting activities including planning and execution of standard and critical lifts

▪ Crane operators shall undertake a CBH Verification of Competency for the specific crane being operated.

Procurement of Lifting Services

▪ PDG contracts and operations procurement mechanisms shall include risk management and pre-task planning for lifting activities

▪ PDG and operations contracts and procurement mechanisms shall define required competencies for lifting and rigging activities

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Certified Cranes & Lifting Equipment

▪ The safe working load (SWL) or working load limit (WLL) shall be clearly identified and marked on all relevant lifting equipment and shall not be exceeded.

▪ All lifting equipment shall be identifiable with a unique identity code or number (excluding shackles).

▪ All lifting hooks (except for grab and chain shortening hooks) shall be fitted with a safety latch to prevent the load from accidentally detaching, unless otherwise specified in a risk assessment approved by the Senior Site Official.

▪ All rigging connections and lifting equipment are to be inspected prior to use.

▪ Lifting equipment shall not be operated with an inoperable or defective safety device.

▪ Overhead cranes will have audible travel alarms

▪ All cranes and components will comply, and be maintained with manufacturer and regulatory requirements

▪ All cranes shall be fitted with load cells (to indicate load weight) and tilt indicators with visible displays and be maintained and calibrated to OEM requirements.

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14. STEVEDORING

Application

The Group Procedure applies to all mooring, berthing and stevedoring activities by CBH owned, hired, labour hired or contracted operators.

Critical Controls

ABS Mooring Procedure

▪ A risk assessment for Mooring, Berthing and Loadout activities shall be undertaken and consider the following at a minimum:

• Parting mooring lines

• Rescue and recovery requirements for Man Overboard incidents

• Snap zones

• Use of mobile plant for line hauling during mooring and berthing activities

• Personal Floatation Devices that automatically inflate upon entry into water shall be worn at all times during Mooring activities

• Use of mobile plant to haul lines shall be in compliance with the mooring procedure. Prior to hauling lines with mobile plant, a sacrificial line shall be installed to prevent mobile plant being hauled over side.

• Stevedore personnel shall only access a vessel by a gangway that is inspected and approved by an ABS supervisor. This inspection and approval shall be documented

• Audible alarms shall be installed and operational on ship loaders prior to loadout commencing. If the audible alarms are not operational, loadout operations shall cease immediately.


▪ Only personnel that are trained and competent in the requirements of the Mooring Procedure shall undertake mooring, Berthing or Loadout Activities

▪ Mobile Plant operators shall have an appropriate High-Risk Work License prior to operating mobile plant.

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15. DOCUMENT CONTROL

Authorities

Approved By Chief Operations Officer Approval Date 30/09/2020

Review Frequency Annually Next Review Date 30/09/2021

Owner Head of Health and Safety and Environment

Custodian Critical Risk Specialist

Division Operations Department Safety and Environment

Review History

Version Date Author Description of Revision

4.1 20/07/2020 Critical Risk Specialist Draft, in development, content transferred from Critical Rik Control Standard, content reviewed, issued for review

4.2 22/07/2020 Chief Operations Officer Approved

5.0 05/08/2020 Head of Health and Safety and Environment

Final, issued for use, published

5.1 30/09/2020 Critical Risk Specialist Minor amendments based on consultation period feedback from the business

6.0 30/09/2020 Head of Health and Safety and Environment

Approved, issued for use, published

critical risk control

Documents