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Page 1: Sustainable development, health, safety and environment

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Sustainable development, health, safety and environment requirements - annex

to the contract

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Table of contents

1 OBJECTIVE ....................................................................................................................................................... 3

2 EXPECTATIONS .............................................................................................................................................. 3

3 GENERAL .......................................................................................................................................................... 4

3.1 HAZARDOUS WORKS AND HAZARD ZONES ................................................................................................... 4 3.2 EXPLOSION HAZARD ZONES (EX ZONES) .................................................................................................... 6 3.3 PRELIMINARY RISK ASSESSMENT ................................................................................................................. 6 3.4 LIFE SAVING RULES ..................................................................................................................................... 7 3.5 SD & HSE PRE-SCREENING AND PRE-QUALIFICATION ............................................................................... 8 3.6 TRAINING ON LOCATION ............................................................................................................................... 8 3.7 INSTRUCTIONS IN CASE OF EMERGENCY ..................................................................................................... 9 3.8 REPORTING AND RECORDING EVENTS ......................................................................................................... 9 3.9 WORKPLACE ORDERLINESS AND CLEANLINESS ........................................................................................... 9 3.10 ENVIRONMENT ......................................................................................................................................... 10 3.11 HAZARDOUS SUBSTANCES....................................................................................................................... 10 3.12 MARKING THE WORK PERFORMANCE LOCATION ..................................................................................... 12 3.13 PERMIT TO WORK .................................................................................................................................... 12 3.14 PERSONAL PROTECTIVE EQUIPMENT ....................................................................................................... 13 3.15 WORK EQUIPMENT ................................................................................................................................... 13 3.16 ENERGY ISOLATION/SHUTTING OFF AND PROHIBITION SIGNS ................................................................. 14 3.17 LIFTING WEIGHT ....................................................................................................................................... 14 3.18 WORK AT HEIGHT ..................................................................................................................................... 14 3.19 DIGS ......................................................................................................................................................... 15 3.20 ENTRANCE INTO CLOSED (CONFINED) SPACES ....................................................................................... 15 3.21 WORK WITH FIRE ...................................................................................................................................... 15 3.22 SD & HSE SUPERVISION AND SANCTIONS .............................................................................................. 18 3.23 HANDOVER OF COMPLETED WORK FROM THE SD & HSE ASPECT ........................................................ 19

4 SD & HSE MEASURES WHEN PERFORMING MINING WORK IN WELLS FOR THE PURPOSES OF THE EXPLORATION AND PRODUCTION ............................................................................................. 19

4.1 GENERAL .................................................................................................................................................... 19 4.2 DESCRIPTION OF POSSIBLE SIGNIFICANT EFFECTS ON THE ENVIRONMENT .............................................. 20 4.3 WELL ABANDONMENT ................................................................................................................................. 21

5 SPECIFICATIONS RELATED TO REFINERIES ...................................................................................... 22

6 CONTRACTOR OBLIGATION ..................................................................................................................... 22

7 TERMS AND ABBREVIATIONS .................................................................................................................. 24

8 APPENDICES ................................................................................................................................................. 26

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1 OBJECTIVE

The goal of the SUSTAINABLE DEVELOPMENT, HEALTH, SAFETY AND ENVIRONMENT - ANNEX TO THE CONTRACT (hereinafter: SD & HSE Annex) is to familiarise the contractors (hereinafter: Contractors) with hazardous work at INA Group companies and the rules regarding health, safety and environment protection (hereinafter: SD & HSE) which they shall follow when performing contracted work in order for the work to be performed in a manner safe for the people, environment and property. The SD & HSE Annex shall be applied together with the basic contract when contracting hazardous work if the works are categorised as high and medium risk. The risk category shall be determined based on the type of works and the hazard zone in which the works are performed and based on the severity of the injury that has occurred. In case the legal requirements are stricter, these regulations shall be applied.

2 EXPECTATIONS

(1) The contracted works shall be carefully planned, hazards shall be identified, risks shall be assessed and controlled for the entire duration of the contract;

(2) If the works are categorised as high and medium level of risk, the SD & HSE pre-screening and prequalification procedure shall be applied;

(3) The contractor shall prepare an SD & HSE Plan, based on information from the previous risk assessment, for high risk works, and shall submit it no later than during the pre-mobilisation phase;

(4) The main Contractor is responsible for its subcontractors and shall:

inform of and clarify INA Group companies SD & HSE requirements to the subcontractors;

supervise the works performed by subcontractors;

prescribe penalties or sanctions to its subcontractors for breaching SD & HSE regulations;

ensure that every subcontractor's employee has appropriate qualifications and is trained and competent for performing the works;

ensure that every subcontractor's employee is familiar with hazards regarding the work and work process: potential fires, explosions or discharge of hazardous substances;

ensure that every subcontractor's employee is familiar with and understands the safety rules on location: emergency procedures, safe work, etc.;

ensure and document that every subcontractor's employee has attended training and has accepted the said instructions;

ensure that every subcontractor's employee follows the safety rules and applies safe work procedures;

establish a program ensuring that subcontractor's employees working in processing facilities and handling hazardous substances are trained and not enhazarded by external influences;

warn the contract owner of any hazard arising from subcontractor's work or of any hazard determined during the performance of works;

ensure that general principles of prevention (elimination, substitution, redesign, isolation, administrative measures and personal protective equipment) are applied to minimize or eliminate the risk;

ensure that every subcontractor's employee has adequate personal protective equipment (PPE), and group equipment if necessary;

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ensure that only persons employed at the worksite and persons with authorised workplace entry have access to the worksite.

(5) The competent organisational unit/person responsible for SD & HSE of the worksite owner shall provide support in compliance with the aforementioned contractual conditions.

(6) The following conditions shall be taken into account when hiring subcontractors and defining the maximum number of subcontracting levels:

the main contractor shall introduce the subcontractors at least 3 days before beginning work;

limitation of the number of subcontracting levels with regard to the main contractor. In case when SSC is the main contractor, a maximum of 2 additional subcontracting levels are possible;

in case of investment works, 2 levels below the main contractor (a total of 3 levels below the organisational unit managing the investment works) are acceptable. Exceptions to this rule are arranged by the main contractor with the contract owner;

the main contractor may not include subcontractors for its main contracted activity.

(7) All contractor employees shall attend education on location specificity.

(8) Contractors shall participate in worksite takeover. The following shall participate in the worksite takeover process:

responsible persons of the main contractor and subcontractor

maintenance organisations

responsible person of the plant/ organisational unit of the work site;

in case of investment works, responsible person of the organisational unit in charge of investment, e.g. project manager;

representative of the competent organisational unit/persons responsible for the work site

representatives of other organisational units included in the works with regard to the area or business operations.

(9) The works may begin only with an obtained valid Permit to work.

(10) The contractor shall continuously perform supervision of its employees and subcontractor employees in order for the work to be performed in accordance with the SD & HSE Plan and the Permit to work. By complex works, the contractor's ensuring 24-hour supervision at the works performance location by SD & HSE experts.

(11) In case of nonconformities determined during supervision, the supervision team may impose penalties/sanctions;

(12) The worksite owner, the contract owner and the contractor representative shall survey the worksite and determine the conclusion of work, and shall sign the minutes of takeover thereof;

(13) The contractors are evaluated on the basis of fulfilled SD & HSE requirements.

3 GENERAL

3.1 Hazardous works and hazard zones

(1) The following activities are considered hazardous works within the meaning of SD & HSE:

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No Work type including:

I Works in digs and work at height

All activities in technological areas/technological environment including digs at least 0,8 m in depth with respect to the original level, regardless of the nature of work (manual labour or work with machines) and reasons (digging, foundations for any structure, drilling, landscaping, etc.)

All work performed at height require:

- a fixed work platform with railing at least 1 meter high and other legal requirements;

- use of equipment for work or protection for work at height

II Works with chemical or biological substances

- Work regarding opening equipment containing hazardous work substances, deposits and substances which in contact with fresh air lead to spontaneous combustion

- Chemical cleaning/washing/rinsing

- Use of hazardous chemicals (explosive, flammable, self-reacting, oxidizing, organic peroxides, pyrophoric chemicals which release flammable gas in contact with water, toxic, irritant, abrasive, CMR (carcinogenic, mutagenic and reprotoxic), hazardous for the environment for cleaning/washing/rinsing of technological containers/equipment.

III Works in the field of ionizing and non-ionizing radiation

- measuring of wall thickness, non-destructive testing, e.g. radiography and similar.

IV Works in the vicinity of high-voltage electric installations

all installations above 1 000 V

V Works with explosive and highly flammable substances

- work with open flame, flame cutting and welding, arc welding, sander cutting and drilling, soldering, full annealing, heating of isolation(s);

- work using internal combustion engines;

- work using pneumatic tools;

- all other work techniques producing heat that may cause spark, fire and explosion.

VI Works in areas enhazarded by explosive atmosphere

work in technological facilities, storage areas in accordance with the Ex manual

VII Works with machines and devices with increased hazard

-Construction machinery

-High-pressure or mechanical cleaning/washing/rinsing

VIII Works on assembling and disassembling heavy parts and/or assemblies

-lifting above equipment/technology in ex-zones,

-lifting special weight, such as constructions, mobile cranes and similar.

IX Works in closed spaces

- tanks, tunnels, municipal and other technological containers, containers, columns, reactors, separators, ventilation shafts, sewerage etc. Entry/work in closed areas means that any part of the body is inside a closed space.

Work in digs including entry into pits, ditches, mounds deeper than 1.20 m.

X Work on installation and dismantling

scaffolding, pipelines, bearing constructions, equipment in the work process

XI Works with hazard of drowning diving work, placing protective dams

XII Works during digging, cleaning underground and in tunnels

related to item related to item IX (work in a closed space)

XIII Works during diving using pressurised air

work during diving, work in spaces where the oxygen concentration is lower than 17% GVI

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(2) Hazardous area is any INA Group operative area where there are hazardous substances or hazardous energy sources which have the potential to cause damage. The division of the areas enhazarded by an explosive atmosphere at INA Group locations into hazardous areas (EX zones) is implemented on the basis of frequency and duration of the occurrence of an explosive atmosphere.

3.2 Explosion hazard zones (EX zones)

(1) In the hazard zones is not allowed:

storage and use of tools, devices and equipment with manual, mechanical, pneumatic, rotating and similar drive and ignition which may cause a spark or otherwise release heat,

smoking and use of open fire in any form,

storage of oxidizing, reactive or self-igniting substances,

disposal of flammable and other substances which are not intended for the technological process,

access to vehicles that might produce sparks during operating,

wearing clothes and footwear which may be charged with static electricity, e.g. synthetic clothing and footwear without anti-static protection and similar, except in zone 2 if otherwise provided by a special regulation,

use of devices and equipment which are not properly protected against static electricity, if there is a possibility of them becoming charged with static electricity.

(2) All work in hazard zones are performed under special supervision of PEX protection experts and HSE experts.

3.3 Preliminary risk assessment

1. STEP: Hazard analysis

2. STEP: Determining the level of risk

The risk level is determined on the basis of the type of works and hazard of the area on the location where works are performed and on the basis of the severity of injury which occurred during similar work activities at INA Group:

(a) Determining the level of risk based on the area where the work is performed

Risk level Hazardous work Non-hazardous

work

Hazardous area High risk Medium risk

Outside hazardous area Medium risk Low risk

(b) Determining the level of risk based on the severity of the injury

Assessed Risk Level

Description of Risk Level Actions

XIV

Works performed during traffic at roads and railways

and other works not listed under I-XIII

- Work performed during traffic at roads and railways

and other work: maintaining roads, green areas using chainsaws, lawnmowers, trimmers and similar.

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Low Minor injuries that do not affect the working ability of workers, first aid without sick leave- NLTI (MTC, FAC, RWC)

Undertake the activity with the existing controls in place.

Medium

Minor injuries affecting the work capacity (recovery of workers for more than one business day with no permanent disability-LTI)

Additional controls may be needed.

High

Serious injury that affects the working capability of workers (hospitalization of worker and recovery for a long period with or without permanent disability)

Group injury (two or more workers in the same accident, regardless of the severity of injury

Fatal injury (Instantaneous or in the period of three months after the injury)

Controls will need to be in place before the activity is undertaken.

(c) Determinating the total risk of level

The total risk of level is a combination of a) and b),

3. STEP: Control the Risk

(1) After the required basic and special occupational safety rules have been applied, the remaining risk of activities at the workplace is assessed.

(2) Detail the control measures that will implement to eliminate or minimise the risk.

Hierarchy of Control

Most effective (High level)

Least effective

(Low level)

Elimination: remove the hazard completely from the workplace or activity

Substitution: replace a hazard with a less dangerous one (e.g. a less hazardous chemical)

Redesign: making a machine or work process safer (e.g. raise a bench to reduce bending)

Isolation: separate people from the hazard (e.g. safety barrier)

Administration: putting rules, signage or training in place to make a workplace safer

(e.g. induction training, highlighting trip hazards)

Personal Protective Equipment (PPE): Protective clothing and equipment (e.g. gloves,

hats)

4. STEP: Monitor and Review Controls

During the execution and after the completion of the work, it is necessary to review the proposed measures to determine whether they have an impact on risk reduction and need to be planned in the future.

3.4 Life Saving Rules

(1) Every employee working at INA Group Companies shall be familiar with the Life Saving Rules (Appendix 1);

(2) The location owner shall ensure that all contractor employees are familiar with these Rules, and that failure to follow them may result in taking actions (Appendix 2).

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3.5 SD & HSE pre-screening and pre-qualification

SD &HSE pre-screening must be performed prior to the selection of the Contractor:

- In case of a low risk level, the Bidder shall not be subject to pre-screening or pre-qualification from the SD & HSE aspect, but shall be obliged by a Statement that they and their subcontractors shall comply with the legal requirements and INA Group SD & HSE requirements;

- In case of a medium risk level, the potential contractor shall be subject to pre-screening and pre-qualification in accordance with minimum expectations: the existence of necessary permits/authorisations for the performance of certain works, evidence of employee qualifications and medical fitness with regard to the type of work, SD & HSE indicators (serious incidents caused by own fault) in the previous three years. The Bidder with the best bid shall prove the existence of safety management systems, which shall be sorted by relevance as follows:

(a) Certificate on Contractor safety SCC** SCCp or

(b) OHSAS 18001 and ISO 14 001 (both of them together) certificates or

(c) A successful pre-qualification audit implemented by an accredited, certification authority contracted by INA Group (renewed within two years), or

(d) A successful pre-qualification audit based on pre-qualification supervision (valid for two years) and post-evaluation by INA Group companies, or

(e) If the Bidder is on the list of MOL Group contractors which shall not be subject to pre-qualification.

- In case of a high risk level, the Bidder with the best bid, in accordance with the proposal by the Evaluation team, shall be subject to pre-screening and pre-qualification by proving the established SCC** or SCCp certification for the company and workers. In case of need, pre-qualification audit is carried out in agreement with the Bidder.

3.6 Training on location

(1) Every contractor and subcontractor employee performing work at INA Group locations shall take part in SD & HSE training. Without performed training and passed examination, the contractor and subcontractor employees shall not begin work performance. Training refers to specific procedures and hazards to which employees are exposed when performing their work. Training shall cover at least the following areas:

Worksite organisation, general information,

Sources of hazard at the worksite,

Possible risks at the worksite,

Code of conduct, rules for work performance,

Rules of conduct in an emergency situation (emergency response, providing first aid, evacuation, etc.),

Supervision,

Training results are documented in a record.

(2) In addition to the introductory training, the contractors shall discuss SD & HSE issues with the competent organisational unit/person in charge of SD & HSE:

at tool box meetings,

at weekly meetings,

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at daily and coordination meetings, and

at the work site before the Permit to work is issued.

3.7 Instructions in case of emergency

(1) An emergency is an event which may present hazard for the safety and health of people, hazard for property or have a negative effect on the environment;

(2) Emergencies are considered to be:

Work-related injuries;

Fire and explosion;

Adverse effect on the environment (leakage, spillage, release of hazardous substances into work environment...);

Production losses, equipment and facility damage;

Near miss situations with possible consequences for people, equipment or the environment.

(3) Every employee shall immediately report the detected hazard to the manager responsible for the location where the hazard has been detected.

In case of an emergency:

(1) Stop work;

(2) Turn off/close all sources of possible ignition - internal combustion engines, electrical equipment, gas lamps, fire hoses in use, turn off machines and equipment, ventilation, etc.;

(3) Follow instructions;

(4) Endorsement by the Permit to work signatory is required in order to continue work.

3.8 Reporting and recording events

(1) INA Group companies records and reports on all events which occurred at the worksite, and the contractor and subcontractor shall report and participate in all activities concerning the event which occurred during work performance.

(2) The contractors and subcontractors shall report on a monthly basis with regard to incidents, injuries etc. in accordance with the table listed in Appendix 3.

3.9 Workplace orderliness and cleanliness

(1) Maintain the workplace, building, space in which you are accommodated and equipment clean. Clean any spillage immediately.

Passages and walkways shall be clean, cables and pipes shall be 2 m above the head,

Do not block access to the emergency exit, firefighting equipment, electrical distribution cabinets, etc.,

Materials shall be stored and kept near the ground in an orderly manner, stable on the designated places,

Flammable waste shall be placed in metal containers with lids far from flammable sources,

Waste material shall be sorted at the place of origin and placed in properly marked containers (marked with the name and key number of waste),

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Cylindrical items shall be blocked in order to prevent their uncontrolled movement, full gas cylinders shall be separated from the empty ones, held in place by chains in order to prevent turning over, and shall have caps on cylinders,

Places for washing and food consumption shall be clean, hygienic and in good condition,

Food shall not be kept and consumed on work surfaces, but on places intended for food consumption during work performance,

Keep sanitary facilities clean.

3.10 Environment

(1) All materials and chemicals used by the contractor during work on location shall be properly stored in order to disable any spillage. The contractor shall take appropriate measures to prevent leakage and/or spillage into the environment;

(2) The contractor shall place the equipment for repairing small environmental pollution (spillage of up to 5 litters) at the worksite: dispersant, absorbent, agents for oil, petroleum and petroleum products collection from dry surfaces, shovel, broom, metal paddle, absorbent cloth in rolls, stainless material container;

(3) Fuel transfer pumps shall be used in accordance with the manufacturer instructions in order to prevent fuel spillage on surfaces during refuelling;

(4) The contractor shall rationally use the natural resources and energy in such manner which is most favourable for the environment (e.g. rational use of water);

(5) All wastewater produced by the contractor's work performance shall be filtered at the wastewater treatment plant, if such a plant is available or they enter the sewerage system on location;

(6) The contractor shall install and maintain the properly marked containers for waste produced in the work process, and shall dispose it in accordance with legal regulations and contractual obligations;

(7) The damaged exhaust systems on vehicles, machines and equipment with internal combustion shall be fixed before entering the worksite, and in case damage occurs during work, they shall be excluded from use until they are fixed;

(8) After completion of work, the worksite shall be cleaned and the remaining material shall be removed.

3.11 Hazardous substances

(1) Hazardous substances are substances with an adverse effect on people's health and/ or environment;

(2) A hazardous work substance shall not be brought to the worksite before prior approval

(3) The contractor shall:

in cooperation with the location owner, arrange a place for storage of hazardous substances at the worksite and the maximum amount that may be brought to the worksite;

submit a list of hazardous substances with the corresponding Material Safety Data Sheets for each hazardous chemical;

have a Material Safety Data Sheet (MSDS) for each chemical, which shall be entered into the Chemical Registry related to legal regulations. The MSDS shall contain the class and date of registration in the Chemical Registry;

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all hazardous chemicals shall be marked with clearly highlighted pictograms/warning signs showing the hazardous properties of the chemical;

in cooperation with the competent organisational unit/person in charge of SD & HSE, shall appropriately mark all locations at the worksite where hazardous substances are placed and provide fire extinguishers.

(4) Employees working with hazardous substances shall:

be informed on the presence of hazardous substances at their workplaces - instructions for work with hazardous substances shall be available to all employees;

during work with chemicals they shall wear appropriate protective clothing, footwear and other protective equipment in accordance with the valid work safety regulations, and in accordance with the activity they perform;

be professionally qualified, that is, have the necessary knowledge on protection against hazardous chemicals with which they work;

depending on the characteristics of hazardous chemicals, have responsible employees with university degrees in the appropriate field supervising all parts of work with hazardous chemicals, with required knowledge on protection against hazardous chemicals;

perform medical examinations before beginning work with hazardous chemicals and mandatorily send them to periodic medical examinations, in accordance with the occupational safety regulations and hazard assessment;

have equipment for work with hazardous chemicals which is resistant to the effects of chemicals which it comes into contact with;

have secured means for administering first aid and providing decontamination;

have premises intended for maintaining employees' general hygiene;

have containers for contaminated personal protective equipment.

(5) The following instructions shall be clearly visible at the workplace where chemicals are handled:

short instructions on means of protection that shall be used;

instructions on procedures in case of exposure to chemicals;

instructions on the manner of administering first aid in case of an accident, as well as means of providing first aid and means for decontamination and removal of hazardous chemicals;

next to the first aid kit, there shall be a list of antidotes, medicines and other remedies that shall be applied on the poisoned/injured person;

short and clear instructions on the manner of informing responsible persons and government bodies or departments in case of an accident;

means of wireless communication within the reach of employees during field conditions i.e. transport of chemicals;

list of employees who are trained for administering first aid.

(6) Storage of hazardous chemicals:

when storing chemicals, it is necessary to keep account of their compatibility, and they shall be placed in a cabinet or on shelves so as to disable their interaction.

adequate ventilation, natural or artificial, shall be provided in the warehouse. Concentration of hazardous substances in the storage cannot be larger than the exposure limit value/short-term exposure limit values (ELV/SELV).

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appropriate absorbents (sand, sawdust, Peet-sorb, Can-sorb...) shall be within reach in the hazardous chemicals warehouse for collecting spilled chemicals, as well as a shovel and a broom

large mobile or freestanding containers in which hazardous chemicals are stored shall be placed in an impermeable walled place.

around each container or group of containers, a fire wall shall be placed, which is large enough to contain the liquid corresponding to the volume of the largest container in the storage space. Between individual containers, there shall be enough space for access in case of fire or other accident.

sources of ignition shall be sufficiently removed from the place of flammable substances storage

concentrations of hazardous chemicals in the air around the nearest residential buildings or places where people gather or stay shall not exceed the permitted concentrations in the environment - regulated by special regulations

hazardous chemicals acting in form of gas shall be stored at sufficient distance from the nearest residential building, apart from buildings in which employees of the legal or physical person owning the storage work.

3.12 Marking the work performance location

(1) Each person performing work hazardous for others or which creates hazard is responsible for placing and maintaining an appropriate barrier.

(2) Tapes only provide visual warnings ("psychological barrier"), they do not provide physical protection. Tapes shall be placed at a distance of 1.5 m from the place with hazard of falling and, if this is not possible, a protective fence shall be placed.

(3) A protective fence shall be placed in case there is hazard of a worker falling from a height into depth or into digs through openings.

(4) Protective fences are required around:

Places where there is a possibility of equipment or materials falling on workers passing that way,

Digs,

Opening in floor, raised floors or roofs,

Hazard zones under the places where work at height is performed,

Areas where cranes and loads swing,

Radiographic hazard zones.

(5) Signs shall be used with barriers so as to identify a specific hazard which exists.

(6) Lights/flashing signs shall be used on barriers in poorly lit areas where traffic is expected at night, and they shall be distinguished from a distance.

(7) In case hazard for traffic safety arises, mobile signs banning all vehicles shall be temporarily placed on the road.

3.13 Permit to Work

(1) Work may only begin after obtaining a valid Permit to Work. The Permit to Work is a written document prescribing the measures and conditions for performing work at a specific location, for a specific period;

(2) The Permit to Work provisions and requirements shall be followed at all times;

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(3) Each issued Permit to work forms an integral part of the technical documentation at the worksite, and shall be posted at the worksite;

(4) The Permit to work shall be issued for every work activity;

(5) The Permit to Work shall be issued and signed by all participants listed in the Permit. Each signatory shall keep their copy of the Permit;

(6) The Permit to Work shall be issued only for one type of work and exclusively for one contractor. If several contractors perform hazardous work, each contractor is issued a separate Permit to Work with obligatory activity coordination;

(7) The Permit to Work is valid only for time period listed in it;

(8) The Permit Issuer can extend the permit validity only if the permitted work has not been completed in the given deadline and if circumstances have not changed.

(9) Upon work completion, the Permit to Work shall be closed by the representatives of the issuer and the recipient, and shall contain the reason for closing, the date and time of closing.

(10) After completion of work, the contractor shall clean the location from the remaining materials and work tools, and only after that can the Permit to Work be closed and the work handover performed.

3.14 Personal protective equipment

(1) Starting work without the required personal protective equipment (PPE) is prohibited;

(2) The Contractor shall provide the employees with adequate PPE in accordance with the hazard assessment and shall continuously monitor its use;

(3) During work, the employee shall:

continuously use the required PPE;

maintain the PPE in proper condition;

inform the immediate work manager with regard to failures and damage of PPE;

3.15 Work equipment

(1) For the employees, the Contractor shall provide and maintain functioning, work-adjusted and safe work equipment which shall not enhazard their safety and health, property and natural environment during operation;

(2) The work equipment in use shall have the manufacturer's label placed on a visible location;

(3) If worker safety is not ensured by constructional designs, appropriate technical protective measures (protection, protective devices, etc.) shall be taken in order to prevent workers from entering a hazard area of work equipment during operation;

(4) The work equipment shall match the type and method of work task performance, i.e. it shall be appropriately adapted for this use, so that its use does not enhazard employee safety and health;

(5) The work equipment can be used only for work tasks and under the conditions for which it was intended;

(6) After installing or moving and before the start of operation, the work equipment shall be checked by the authorised person and authorisation shall be given for its putting into operation or, when provided by a special regulation, the authorised person shall issue a document showing that the work equipment has been properly installed and that it can be used in accordance with the instructions;

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(7) Before beginning work and after every change that might affect the safe use of the work equipment, workers shall be warned of hazards that might arise or which are a consequence of other work equipment operation in their immediate surroundings, which is not directly used by the workers;

(8) The work equipment shall be equipped with a safety device for complete and safe stopping of moving parts;

(9) The work equipment shall be equipped with appropriate protection against direct or indirect effect of electricity.

(10) Machines with increased hazards shall be tested, and testing documentation shall be available at the worksite.

3.16 Energy isolation/Shutting off and prohibition signs

(1) Energy isolation/shutting off is a procedure of separating/isolating an energy source from the system on which it operates, in order to protect workers during maintenance of equipment, devices, facilities, etc.;

(2) An energy source is any form of electric, mechanical, hydraulic, pneumatic, chemical or thermal energy;

(3) Energy isolation is performed mostly by installing lockout devices (blinds), by closing valves, cutting off electric energy supply, a mechanical clutch, etc.;

(4) Energy isolation is performed in accordance with a prepared energy isolation list with inventory for all possible hazardous energy sources and isolation method for each of them.

(5) The responsible person at the location and/or a person authorised by them is responsible for performing energy isolation/shutting offs.

3.17 Lifting weight

(1) Lifting equipment (including anchored cranes (bridges), mobile cranes, car lifts, forklifts) shall be used only by the staff trained for the subject activity in accordance with the law, while the equipment shall be operational and tested before it is introduced at the worksite and documented at the workplace;

(2) The speed of movement of the load lifting equipment is limited to 10 km/h.

3.18 Work at height

(1) Work at height is generally considered to be all work performed at places 1m above ground or at lower levels, and where there is hazard of falling from height.

(2) For works performed at 3m and higher, a Permit to Work valid no longer than 1 shift shall be issued.

(3) The most common hazards and risks of working at height are:

Hazard of falling from height into depth, falling through opening or constructions;

Hazard of injury while handling work materials and equipment;

Hazard of adverse effect on health due to work in a non-physiological body position;

Hazard of adverse effect on health due to harmful weather conditions;

Other types of hazard, depending on the work performed - fire, harmful

substances, radiation;

(4) When performing work at height, tested and operational protective equipment shall be used as prescribed;

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(5) Physical and psychophysical ability of workers working at height shall be periodically checked, at least once a year at a licensed occupational medicine specialist.

3.19 Digs

(1) A Permit to Work shall be obtained before working on digs. The digging method shall ensure the safety of the existing surface and underground facilities in the vicinity.

(2) In case any hazard occurs, work shall be immediately stopped and the Permit to Work Issuer shall be informed.

3.20 Entrance into closed (confined) spaces

(1) A closed space is a confined space which is sufficiently large for the worker to enter and work in, and has confined entrance or exit openings.

(2) Closed spaces shall only be entered with a valid Permit to Work for closed spaces, and after measurement of chemical harmfulness and explosiveness has been performed;

(3) An issued Permit to Work for closed spaces is valid only for the duration of work, and no longer than 1 shift;

(4) The required tools and equipment for work in closed spaces are an integral part of the Permit to Work.

3.21 Work with fire

(1) A Permit to Work with fire is required for every work that generates high temperatures or potential sources of ignition in an area where flammable fumes, gases or materials may be present. The Permit for work with fire is issued by a fire protection expert who prescribes measures to be followed during performance of work;

(2) The Permit for work with fire is valid for work for which it has been issued, and no longer than shift day;

(3) The place where an open flame shall be used (welding, gas cutting, soldering) shall be cleaned from flammable materials (wood, paper, flammable liquids, dry vegetation, etc.);

(4) Apart from workers performing work with fire, a fireman shall also attend such work if it is defined by the permit;

(5) At the place where work with fire is performed, at least one fire extinguisher shall be placed (or more if it is required by the Permit for work with fire);

(6) The area where work is performed shall be properly prepared (cellar and opening covering, watering, cleaning) in accordance with the Permit;

(7) Shafts and drains shall be covered in order to prevent presence of flammable gases if it is required by the Permit;

(8) In the area where work with open fire or repairs on devices with "Ex" performance are performed, other work, due to which ignition of gases, fumes or liquids could occur, shall not be performed;

(9) In areas with hazard of fire or explosion, the use of tools producing sparks, electric tools with general performance or any other tools which can produce sparks is prohibited without the Permit for work with fire.

GAS (AUTOGENOUS) CUTTING AND WELDING EQUIPMENT

(1) Steel cylinders shall be marked with a label indicating the owner - company;

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(2) Steel gas cylinders shall always be kept fastened to the wall with clamps or on special carts protected from falling;

(3) Cylinders shall be at distance of at least 3 m from the place of welding;

(4) It is best to keep the cylinders outside of work areas, but protected from sunlight, frost or rain;

(5) The acetylene cylinder shall be placed upright or under an angle not smaller than 45 degrees with regard to the horizontal surface;

(6) Before beginning work, it is shall be checked whether rubber gas supply hoses are in good condition and whether they are sufficiently flexible, whether they are of appropriate colour for a specific type of gas (blue for oxygen, red for flammable gas), whether they are impervious, especially at joints, whether they are connected to connection points with appropriate clamps (never with wire), and whether they are protected against sparks and hot items, as well as against damage on passageways;

(7) If gases from steel cylinders are used for welding and cutting, the cylinders shall have protective devices against flashback - check valves. Check valves (dry circuit) shall be placed on the cutter at rubber hose attachment points, as well as on reducer valves;

(8) Welding areas can be permanent or temporary;

(9) Permanent welding areas are considered to be areas where welding is performed constantly or with short breaks during the technological production process or workshops.

(10) Temporary welding areas are considered to be areas where welding is performed as needed or at the time specified in an authorization/Permit;

(11) Permanent welding areas:

Permanent welding areas shall be inflammable or have a construction resistant to fire at least 1 hour (F 60), completely free from every combustible and flammable content, and adequately separated from the neighbouring areas;

In case welding is performed using acetylene and oxygen, cylinders shall be secured from falling. Cylinders shall be placed at a distance of at least 2 meters from heating devices (radiators and similar) or 10 m from sources of open flame. The number of cylinders shall not be larger than the daily consumption of each user;

Spare oxygen and acetylene cylinders shall be stored in an authorized storage space and shall be mutually separated and placed in a covered space or in special areas corresponding to technical standards for gas storage;

(12) Temporary welding areas:

Welding authorization contains / Permit: name of authorization issuer; number and date of authorization issue; title of organization or company in which welding, operation, separation is performed; welding area; description of work; time of welding performance from - to; measures which shall be taken in order to safely perform welding; required equipment and number and type of fire extinguishers; final check of performed work; first and last name of the work manager; first and last name and signature of persons authorized for issuing authorizations;

In case when authorization validity expires, and welding is not completed, the welding contractor manager (hereinafter: work manager) shall request an authorization validity extension, and employees authorized for issuing authorizations shall inspect the welding area again, and when it has been determined that the prescribed conditions have been met, they shall extend the authorization / Permit;

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Welding authorization / Permit are issued in at least two copies. The first copy is submitted to the work manager, while the other is kept in the authorization issuer documentation;

Authorized persons issuing the authorization / Permit for performing welding shall issue the authorization once it has been determined that the appropriate fire and PEX protection measures have been prescribed and taken;

The Welding authorization / Permit shall not be issued in the following cases:

- for areas not prepared for welding;

- in areas with devices for automatic fire extinguishing if such devices are not blocked or if they can be damaged during welding;

- when there is hazard of explosions due to mixing flammable gases, fumes or dust with air, insufficiently cleaned tanks, containers, installations and other parts of facilities in which substances which may create explosive mixtures or are hazardous due to fire or explosion were stored;

- when welding is to be performed in an area located near stored large quantities of easily flammable or explosive substances or other flammable materials, which would directly hazard or cause large scale hazard for property.

The contractor and work manager and authorized persons of the company in whose building / location welding is performed are directly responsible for safe welding performance, within respect to fire and explosion protection;

Welding can be performed by employees who are qualified for handling and use of welding equipment and familiar with fire protection measures which shall be taken during welding;

Welding shall be performed under supervision of the work manager on location, in a manner and time specified for welding in the authorization;

After obtaining welding authorization, the work manager shall check the fire and explosion protection measures taken on location provided for welding, as well as determine whether the possibility of causing fire or explosions in neighbouring areas and spaces, especially under, over or on the sides of the welding location has been excluded. To this end, the work manager shall take measures for eliminating possible deficiencies before beginning work (removal of flammable materials, closing all openings, placing protective elements on all sides of the welding location, determining the remaining concentration of flammable gases, fumes or dust, establishing firefighting duty and similar);

Upon welding completion, the work manager shall check whether work performed has created potential hazard of fire;

Workers performing welding shall weld only on those locations, in a manner and time determined in the authorization;

After welding is completed, handover is performed in which the work manager and authorized person of the company in whose building or location welding was performed participate;

Handover from the previous paragraph is performed using the minutes of handover, that is by signing on location for final check of performed work determined in the welding authorization;

If it is determined that there is hazard of fire after the performed welding, responsible persons shall take appropriate measures to eliminate such hazard or to keep it under control (e.g. presence of fire fighters at the welding area is ensured);

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The initiated welding shall be stopped by authorized persons when work conditions with regard to fire or explosion protection or the nature of welding have been changed;

Welding shall be continued when fire or explosion protection measures have been taken, and when welding authorization has been amended and recertified;

In case work conditions or the nature of welding have been significantly changed, a new welding authorization / Permit shall be requested;

In temporary welding locations no more than two oxygen cylinders and two acetylene cylinders (working and spare) shall be kept.

3.22 SD & HSE supervision and sanctions

(1) In addition to continuous communication on location between the worksite representative and the Contractor, work performance supervision from the SD & HSE aspect shall also be performed;

(2) Supervision shall be performed in order to determine whether the work is performed in accordance with the agreed SD & HSE Plan and Permit to Work;

(3) All worksite activities shall be regularly supervised:

by the competent organisational unit/person in charge of SD & HSE;

by OHS/FP experts;

by responsible persons of the Contractor.

(4) The responsible persons of the contractor shall perform supervision at least once a day, and keep a record thereof;

(5) The contractor shall appoint a person responsible for supervision that shall continuously supervise compliance with SD & HSE rules;

(6) The person who has detected a breach of SD & HSE rules shall immediately verbally warn the contractor on location and request immediate elimination of irregularities. In case of failure to act according to the verbal warning, the competent organisational unit/person in charge of SD & HSE shall be informed. In case of nonconformities determined during supervision, the following penalties/sanctions shall be imposed:

Stopping work / works

Revoking the Permit to Work

Repeated training in the SD & HSE field

Written warning

Removal from location

Fines (Appendix 4)

Placing the Contractor on the List of unreliable contractors

(7) By paying a penalty (i), the contractor shall not be exempt from further sanctions due to breach of agreement, and/or more serious legal consequences determined by relevant regulations;

(8) If the supervision team repeatedly determines facts for imposing a penalty on location where supervision is performed, the penalty may be imposed several times;

(9) In case there are several deficiencies (penalty facts) on location at the same time, the penalty is imposed for each deficiency separately;

(10) Nonconformities determined during supervision shall be removed by the contractor/subcontractor in the agreed deadline, regardless of imposing the penalties.

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3.23 Handover of completed work from the SD & HSE aspect

(1) Work is considered completed when the worksite has been controlled by the work site representative and the Contractor representative, which shall determine that:

the work is completed

the worksite has been cleaned

the unnecessary materials and equipment have been removed

(2) The Permit to Work shall be closed and the Minutes of Handover shall be signed.

4 SD & HSE MEASURES WHEN PERFORMING MINING WORK IN WELLS FOR THE PURPOSES OF THE EXPLORATION AND PRODUCTION

4.1 General

(1) A review of technical solutions for health, safety and environment protection (SD & HSE) measures for work in wells, whether it is a new well or work over, including regular maintenance of well equipment, hydro-dynamic measurement in wells, capital work over of formation, work on stimulation of hydrocarbon reservoirs and fracturing, based on specific and detailed technical-technological description of mining work in the well, determining risk of operations performed, specificities of the location on which work is performed, on the rules of occupational safety, environment and fire protection defined by the valid regulations in the above mentioned areas.

(2) Performance of mining work over work in the existing wells and implementing protection measures at the well is performed in accordance with the Additional mining work over project (TEMPLATE) and the Simplified mining project (MWP/Mining Work Programme) for each well (Company project documents).

(3) The mining work supervisor in the well is the official representative of the client, appointed by the responsible person of the company. The supervisor is authorized and responsible for continuous technological and financial supervision of mining work performance, supervision of protective measures implementation listed in company project documents, and for certifying conformity of the accompanying material and financial documents with the approved cost estimate.

(4) Technical protection measures during well construction shall be in accordance with the measures prescribed in the mining project for each drilling rig;

(5) If hazardous substances are used which can cause damage to the environment and/or hazard the life and health of people, handling such substances shall be performed in a closed process and such substances shall be kept and disposed of in accordance with valid regulations in a safe manner so there is no hazard for or damage to the environment;

(6) Great care shall be given to storing chemicals and fuel in such a manner so as to prevent any possible surface contamination of the well workspace;

(7) Disposal of hydrocarbon, oil and solid waste material is not permitted in the drilled material landfill on location;

(8) PHD foil shall be placed in the pit and the area for temporary placement of solidificates.

(9) Condition of the environment shall be monitored:

in the well construction phase

during restoration of the pit

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after abandonment of the drill pit or location

(10) Before beginning restoration, analysis of fluids from the pit shall be performed in order to select an appropriate technological procedure, which is the most favourable with regard to the ecological and economic aspect. At the same time, samples of water from the piezometer and encircling canal shall be taken, and analyses shall be made as for baseline condition.

(11) Hazards during work performance on planned mining work and in further technological process are:

hazards of mechanical injury,

hazards of performing work at height (the most demanding workplace - derrick man on the drilling rig),

hazards of falls and slipping,

hazards of using tools and devices for work with increased hazard,

hazards of work in confined, open parts of the pipeline, digs deeper than 1.2 m (falls and slipping),

hazards of high pressure,

hazards of static electricity and atmospheric discharge,

electricity hazards,

hazards during work with liquid nitrogen

hazards when working with hazardous substances and harmful materials (when performing possible chemical cleaning of perforations with HCI there is a hazard of effect of hazardous substances and chemicals by incorrect acid use)

hazards of noise and vibrations (on facilities where work is performed the noise and vibration source may also be the rig and aggregates when performing column cemnting).

4.2 Description of possible significant effects on the environment

(1) Effect of mining work operations is possible in the phase of rig delivery on location, rigging up and dismantling - rig transport phase.

(2) Noise occurring during work performance can have an adverse effect on the fauna with regard to its avoidance of those areas and possible migrations.

(3) Increased noise levels at the surveyed areas shall temporarily be caused by the operation of the workover rig on the well at 50 dB(A) and operation of the aggregate during column cementing. The main effect of the noise shall be at the worksite itself and workers shall be the exposed to it the most.

(4) Before beginning work, it shall be determined whether there are enhazarded species that permanently or occasionally inhabit the work area, and movement of these animal species shall be constantly monitored so that there is no adverse effect on the fauna.

(5) During mining works, no release of harmful gases into the atmosphere is expected, except the exhaust gases of the machinery.

(6) Mover operation may also cause dust to rise from the ground, but that effect is only possible during an extremely dry and windy period and is as such short and temporary, and therefore does not present a significant effect on the air quality. In that case, use of disposable protective masks is recommended.

(7) During regular performance of operations, no effect on surface or underground waters is expected. Interaction of fluids with the environment along the wellbore is prevented

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by equipment/casing the wellbore with pipes, and by safety well system and intervention well killing system on the surface (in case of fluid blowout). Keeping in mind the listed facts, there is no possible effect on ground waters. The tightness of the system is tested during drilling/work over by controlling pressure at the wellhead.

(8) In case of accidents, there is a possibility of hazarding the water lines, but in those cases actions shall be taken in accordance with the Operative plan for implementation of water protection measures in cases of unexpected contamination and Emergency evacuation and rescue plan in which procedures for prevention of contamination spreading, restoration and return of land / water lines in the original condition are described in detail. The aforementioned plans are always available at the worksite and workers are trained for taking action when accidents occur, and a company authorised for restoration is always hired.

(9) During transport and operation of machines, certain quantities of waste oil are expected to be produced (13 02 05*, 13 02 08*). Despite special attention which shall be paid to supplying the machinery with fuel, as well as during manipulation of fresh and waste oil, accidents occurring due to their spillage can be expected, which shall be promptly dealt with. This includes evacuation - removal of contaminated earth to the nearest Company central disposal pit (CDP) and removal of waste oil organised by the Contractor through a company authorised for collection of waste (there are barrels for collection of waste oil on the rig).

(10) For each operation, hazardous and harmful substances which may cause damage to the environment and/or hazard life and health of people shall be defined. Handling such substances shall be performed in a closed process in a secure manner so that hazard and damage to the environment does not occur.

(11) Before disposal the waste material shall be sorted into useful components and according to nature of the hazard - to non-hazardous and hazardous waste, depending on whether it contains hazardous substances or not.

(12) Mining work supervisor shall supervise the implementation of environmental protection performed by the Contractor in accordance with the aforementioned documents, and upon work completion, the responsible person at the location shall be informed of the possible irregularities before well handover by the Contractor.

(13) The Contractor shall keep records on all activities regulated by legal regulations in the field of environmental and water protection and waste management.

4.3 Well abandonment

(1) After completion of hydrocarbon exploitation, the procedure of well abandonment, removal of facilities, plants and devices on the exploitation field is performed. All decisions and the works shall be coordinated with the well abandonment technology described in the mining project.

(2) In case of mining work of abandonment of the wellbore, quality technical solutions ensuring mutual isolation of hydrocarbon formations and water-bearing formations shall be applied. Piping shall be cut to the depth of 1.5 m, and the wellhead shall be closed by welding a protective panel which is placed on the external piping.

(3) In case of well workspace work over, quality solutions eliminating the possibility of hazard for people, property and environment and ensuring the use of space for different purposes shall be applied.

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5 SPECIFICATIONS RELATED TO REFINERIES

(1) INA refineries are fenced and supervised by security guards and are placed under video surveillance. Official entrances are used for entrance of persons and vehicles into INA refineries, following internal documents;

(2) Only persons with a valid ID card may enter INA locations. This includes visitors and persons delivering material to construction site;

(3) Contractor ID cards are obtained by the person responsible for work supervision, and upon completion of the contracted work the person shall return the ID card. ID cards shall be worn at all times and shall be presented upon request. The ID card shall be used only by the person to whom it was issued, and any misuse is punishable;

(4) Entrance of contractor vehicles is possible only with an issued Vehicle Entrance Permit;

(5) All contractor equipment and tools brought in and out shall be documented and reported to the security guard;

(6) Failure to follow safety rules shall lead to disciplinary procedures and application of measures, including prohibition of entrance and work performance on location;

(7) Parking and leaving the vehicle unattended is prohibited on all roads within hazard zones;

(8) Observe the traffic signs and speed limits;

(9) Only the qualified person with valid vehicle/machine driving license can operate/ handle it;

(10) In case of road work, the Contractor shall place required traffic information signs.

(11) In case the alarm is sounded, when evacuation shall be performed, follow the instructions by responsible persons and evacuation signs. The evacuation manager shall direct you in company of another person from the place where the event occurred to the emergency meeting point. Evacuation code of conduct is an integral part of the training specific for the worksite before beginning work.

6 CONTRACTOR OBLIGATION

The Contractor shall:

(1) Possess evidence of worker training for performance of specific type of work at the work location - evidence of professional training, safe work and fire protection competence;

(2) Submit a doctor's certificate for workers who perform jobs with special conditions;

(3) Regularly hold a preparatory safety meeting before every shift/start of more complex operation which, due to their complexity and risk, additionally hazard safety of people and environment;

(4) Perform works in accordance with the issued Permit to Work

(5) Possess all documentation at the facilities prescribed by law - general ledgers, technological documentation, regulations, safe work instructions for all operations and all work phases with technological schemes and element labels, procedures (ISO), attests, certificates, control sheets with inspection deadlines, certificates on functionality of tools and devices with increased hazard, certificate on noise level tests;

(6) Perform obligatory technical controls and adjustments of safety elements and devices in accordance with the regulations and manufacturer instructions;

(7) Perform functionality tests and prescribed measurements;

(8) Properly maintain work tools;

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(9) Ensure and monitor the use of personal protective equipment;

(10) Mark the work areas with required prohibition, warning and information signs;

(11) Organise and ensure provision of first aid to workers in case of work related injuries or sudden illnesses, until their referral to treatment at a health institution.

At least one of the workers working at each worksite or temporary worksite where there are up to 20 workers shall be trained and nominated to administer first aid, and one additional worker shall be nominated for every 50 additional workers.

(12) Report all incidents as they occur, and once a month submit an incident report, in accordance with Appendix 3.

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7 TERMS AND ABBREVIATIONS

TERMS AND ABBREVIATIONS Description

Occupational exposure limit values (OEL)

is the threshold of the average time measured concentrations (average concentration) of substances (gases, fumes, aerosol, dust) in the air at the place of work in the worker's breathing zone compared to a specific target period

SD & HSE incident

Unplanned event or a series of events resulting in, or which could result in injury, illness or damage to (loss of) property, damage to the environment or the company's image.

High potential incident (HiPo) Incident with consequences classified as PEAR3 or lower, including potentially hazardous situations which could have resulted in level 4 or 5 consequences.

SD & HSE Sustainable development and health, safety and environment protection.

Work-related injury

Every injury sustained by an employee at work or in connection with organized work is considered a work-related injury (during travel for work purposes, handling materials, transport of materials, cleaning, organised meal at the workplace, during medical examinations or any other activity organized by the employer during work activities, regardless of date, time and location, or degree of employee's involvement in work.

Any injury taking place when an employee is being transported from home to workplace or vice-versa is not considered to be a work-related injury, unless such injury happens in a vehicle owned or leased by INA.

Injuries on the way to and from work must be specifically recorded and statistically monitored in accordance with the Croatian legislation.

Lost Time Injury

(LTI)

Injury at work or related to work after which the injured person is not able to work at least one full shift at his or her workplace. Fatalities are included.

Non-LTI work injuries

A work related injury that does not require the injured person to be absent from work including First Aid Case, Medical Treatment Case and Restricted Workday Case.

Non-work related injuries

All injuries of employees not related to work organized by the employer. Any injury taking place when employee is transported from home to workplace and from workplace to home is considered to be non-work related injury, except the injury happens with a vehicle owned or leased by the employer.

PEX- responsible person is the main expert on anti-explosion protection

SD & HSE Plan

The SD & HSE Plan contains general SD & HSE information specific for the location and area, description of emergency procedures, list of roles and responsibilities, and it is delivered by the contractor in the pre-mobilization phase at the latest.

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Near-miss

A near-miss is an incident which potentially could have caused injury or occupational illness and /or damage (loss) to people, assets, the environment or company reputation, but which did not.

Prior risk assessment

The worksite owner shall perform prior risk assessment and submit it as a part of the tender documents. The potential contractor shall use the prepared document as a basis for the preparation of the SD & HSE Plan

Road Accidents

.

Any event which included a (registered) motor vehicle (owned or rented by the employer or vehicle owned by an employee), during performance of work tasks, and during which injuries, death and property damage occurred, regardless of who was injured, whose property was destroyed and where event occurred, and regardless of who is guilty. In case there were no fatalities/injuries, property damage which occurred in the following cases (regardless of repair costs) shall also be considered an accident:

- Collision between moving vehicles,

- Impact with stationary object,

- Accidents without collision/impact - events which include vehicle overturn, derailment, vehicle spinning, running off road

Road Incidents

.

Any event with involvement of a registered road motor vehicle (owned or leased by employer and employees’ owned vehicle) during execution of working duties that result in material damage only (apart from the three road accident categories), shall be considered as road incident

Work equipment

-devices, facilities, means of transfer and transportation of load and tools,

-scaffolding and other tools for temporary work at height

Restricted Workday Case

(RWC)

A case which is not as serious as LTI, but work is restricted so the employee has been transferred to a less demanding workplace.

Medical Treatment Case

(MTC)

Cases that are not severe enough to be reported as Lost Time Injury or Restricted Workday Case but are more severe than requiring simple First Aid Cases

First Aid Case

(FAC)

Case that are not sufficiently serious to be reported as medical treatment or more serious cases but nevertheless require minor first aid treatment, e.g. dressing on a minor cut, removal of a splinter from a finger. First aid cases are recordable incidents.

Fatality

Death resulting from work related injury or occupational illness, including the fatalities due to accidents caused to third parties. Company employees, contractor employees and 3rd parties are reported separately.

Worksite owner Person/organisational unit responsible for the area where work is performed.

Contract owner Person/organisational unit responsible for defining, concluding and monitoring contract implementation.

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SD & HSE Sustainable development, health, safety and environment protection

8 APPENDICES

Appendix Appendix title

Appendix 1 Life Saving Rules

Appendix 2 Measures in case of failure to follow Life Saving Rules

Appendix 3 Performance indicators

Appendix 4 Contractor information on supervision in the field of SD & HSE and prescribed penalties

Appendix 5 HSE Policy at INA Group

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Picture and short description Detailed description Duty

Smoking is allowed only in designated areas.

Smoking or use of matches or lighters may lead to combustion of flammable materials or cause explosion. Smoke in designated and marked areas in order to avoid fire or an explosion hazard. Equipment that is or can be a source of combustion (such as sander, drill, welding equipment, etc.), which is used within the hazard zone (e.g. technological zone), represents hazard and may not be used without a valid permit to work and implemented fire protection measures.

As a worker I shall:

- be informed on where smoking areas are located;

- act and report in case I see that someone is smoking outside designated areas;

- avoid using sources of ignition in technological zones if I do not possess a permit to work and if fire protection measures have not been implemented.

As the operator/ manager I shall:

- inform personnel on where smoking areas are located;

- ensure that the permit to work in case of performance of hazardous work is obtained;

- inform personnel of hazards and rules during performance of hazardous work.

Request permit to work and follow all regulated measures

The Permit to work describes hazards which can arise during work and in which way can these hazards be controlled/mitigated in order to be safe. Permit to work is issued before beginning of performance of the following work:

• entrance into closed space

• high-temperature work

• critical lifts

• work at height and/or above water

• groundwork

• maintenance work with increased

risk (e.g. simultaneous work, work on systems/equipment under high voltage, opening containers/equipment with hazardous contents, bypassing and overriding protective critical equipment/systems, high-pressure cleaning, etc.)

This list is considered to be the minimum, while other activities may be included in the permit to work and defined at local level. Performance of work different than regulated in the permit to

As a worker I shall:

- check with the supervisor if it is safe to start work;

- check with the security guard if I can enter a closed space;

- follow instructions in the permit to work.

As the closed space entrance security guard I shall:

- authorized and monitor access to the closed space;

- possess a means of communication with people in the closed space;

- be familiar with emergency rescue measures and apply them if necessary.

As the operator/ manager I shall:

- check whether the permit to work requirements have been met

- ensure presence of security guards while people are in restricted area;

- check whether work atmosphere tests are performed in accordance with the permit to work;

- confirm that it is safe to begin work.

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work, is considered as work without the permit to work.

Check energy source isolation before beginning work

Isolation protects you against the hazard of different energy sources which may be present at every place of work. Typical potentially hazardous energy sources are electricity, static electricity (e.g. capacitor discharge magnetizers), high pressure, hazardous substances, toxic gases, chemicals, hazardous liquids/steam, radiation or mobile/rotating machine parts (e.g. springs) etc.

As a worker I shall:

- be familiar with insulation protecting me from harm;

- check with supervisor if insulation has been placed;

- check with the supervisor if it is safe to start work.

As the operator/ manager I shall:

- be aware which are hazardous energy sources at the location, and inform the staff about them;

- check whether all hazardous energy sources are isolated, and whether insulation function properly (e.g. clasps, fuses and manual vent covers);

- check there is no stored energy and other hazards;

- confirm that it is safe to begin work.

Use functioning PPE during work at height, exposure to hazardous substances or atmosphere

Personal protective equipment (PPE) are protective equipment against falling from height (protective ropes and belts) and protective equipment for respiratory organs (except masks for protection against dust). Always use protective equipment against fall from height when working at height of 2 meters or more. Safe environment includes scaffolding, steps or raised platforms with railing and lifting mechanisms. Respiratory organ protective equipment shall be worn if you are or could be exposed to hazardous substances or atmosphere (e.g. low level of oxygen or space is filled with nitrogen), as stipulated in permit to work.

As a worker I shall:

- be familiar with protective equipment against fall from height to use and how to use it;

- be familiar with respiratory organ protective equipment to use and how to use it;;

- check equipment before use, during work at height outside of safe environment, always use fall arrest system;

- refuse work if you don't know how to use PPE.

As the operator/ manager I shall:

- check whether PPEs for work at height and exposure to hazardous substances or atmosphere are available, and if staff is trained to use them;

- verify if anchor points are available is protective equipment against fall from height will be used;

- check whether it is safe to begin work at height or in hazardous or potentially hazardous atmosphere.

When performing specific work or in specific work environments, the atmosphere shall be tested in order to prevent explosions and/or ensure that other people at the location can breathe the air safely. An example of such work is entrance into closed space and high-temperature work where initial gas testing is required and where continuous testing is necessary.

As a worker I shall:

- check with the supervisor if work atmosphere testing has been performed;

- check with the supervisor if it is safe to start work;

- use functioning personal gas detector, if permit to work or location regulations so required;

- stop work if I sense smell or if personal gas detector signals alarm.

As the operator/ manager I shall:

- check whether qualified staff has performed work atmosphere testing, according to permit to work;

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Perform work atmosphere tests whenever necessary

- ensure availability of functioning gas detectors;

- if necessary, request additional work atmosphere testing;

- confirm that it is safe to begin work.

Do not perform wok in digs which are not properly secured

Regardless of how safe a dug trench or pit looks, they can always turn in a death-trap due to rainfall or materials placed nearby. Support of side walls can save your life.

As a worker I shall not:

- enter a dig deeper than 1.2 meters (approximately chest level) if not properly secured (support or leaning walls).

As manager/supervisor I shall:

- ensure that all digs deeper than 1.2 meters are properly secured;

- ensure that all digs deeper than 1.2 meters are considered a closed space.

Do not remove safety signs and protective devices without authorization

All protective devices, such as devices/valves for emergency process shutdown, LOTO devices (locking switches, vents, etc.), breaking system, safety valves, fire and smoke detection systems, level measurement devices, alarms, crane operating systems shall be operational in order for you and other people to be safe.

As a worker I shall not:

- bypass or turn off protective devices without supervisor's approval;

- remove safety signs.

As the operator/ manager I shall:

- know which protective devices are at the workplace and inform staff about them;

- verify that authorisation for bypassing/shutting off of protective devices does not hazard safety of persons, property and environment;

- provide necessary temporary control measures in case protective devices have been bypasses/turned off.

Road or passage directly under the lifted load is not safe since load may fall on you. Use of damaged or unsuitable lifting equipment, as well as incorrect lifting, greatly increases the risk of falling load. Some load lifting operations include increased hazard (such as lifting heavy loads near crane capacity or above critical technological areas) are called critical lifts.

As a worker I shall:

- Be sure I do not cross the area where there is hazard of lifted load, regardless whether the area is marked with tape or cordoned or not;

- Follow instructions of the signalist.

As the operator/ manager I shall:

- When necessary, ensure presence of the signalist (e.g. blind lift, critical lift);

- Ensure that load lifting area is secured with tape or cordoned;

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SD & HSE Annex to the Contract Appendix 1

Life Saving Rules

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Do not break the safe load lift rules

- Ensure free lift of load;

- Verify that binding and lifting of load is performed by experts;

- Ensure use of appropriate binding equipment;

Ensure that no one passes below the lifted load.

Work under influence of alcohol or narcotics is forbidden

Consumption of alcohol, illegal substances and abuse of legal substances shall not only decrease your ability to perform tasks in a safe way, but shall also expose your colleagues to increased risk.

As a worker I shall:

- Inform the supervisor if I take medication that may influence my work. If I am not sure of this, I shall ask the supervisor where I can seek medical assistance.

- Avoid consumption, storage, sale or distribution of illegal narcotics

- Report every abuse of alcohol or narcotics

- Avoid risk if I do not feel fit to work

As the operator/ manager I shall:

- Allocate work to persons able to work

- Immediately remove persons under the influence of alcohol or narcotics from the place of work.

Follow the Basic safety rules and act in case of their breach

By following the Basic safety rules we save lives. Those who chose not to follow the Basic safety rules have chosen not to work for the INA Group.

As a worker I shall:

- Refuse any activity requiring breach of Basic safety rules

- Act and report in case someone breaches the Basic safety rules

As the operator/ manager I shall:

- Ensure a safe workplace and activity in accordance with Basic safety rules

- Supervise compliance with Basic safety rules

- Act in case someone breaches the Basic safety rules and apply appropriate consequences.

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SD & HSE Annex to the Contract Appendix 2

Measures in Case of Violation of Life Saving Rules

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Contractor/subcontractor

Smoking Permit to

Work

Energy

source

isolation

Work at

height and

hazardous

atmosphere

PPE

Work

atmosphere

testing

Digs Safety signs Critical lifts Alcohol/drugs

Intentional violation Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

Unintentional violation

(1st time)

Penalty and removal from location

Penalty and written warning

Penalty and written warning

Penalty and written warning

Penalty and written warning

Penalty and written warning

Penalty and written warning

Penalty and written warning

Penalty and removal from location

Unintentional violation

(repeated)

Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

Penalty and removal from location

The fine is defined in Appendix 4, Contractor information on supervision in the field SD & HSE and prescribed penalties.

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SD & HSE Annex to the Contract Appendix 3

Performance Indicators

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SD & HSE Annex to the Contract

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4 Contractor information on supervision in the field of SD & HSE and

prescribed penalties

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No. Supervision requirements/Determined nonconformities

Measures taken *Penalty amount

1 2 3 4

1. Documents

1.1. List of work places with Special work conditions and the evidence of medical fitness

Demobilisation and removal of deficiencies (missing documentation, worker has not undergone examination ...)

HRK 3,000.00

1.2. Safety-at-Work Training Demobilisation and removal of deficiencies (missing documentation, worker has not undergone training)

HRK 500.00

worker

1.3. Evidence of workers' location risk awareness

Demobilisation and removal of deficiencies (missing documentation, worker did not attend education)

HRK 500.00

worker

1.4. Initial fire extinguishing training Demobilisation and removal of deficiencies (missing documentation, worker has not undergone training)

HRK 500.00

worker

1.5. Trainees' first aid certificates Demobilisation and removal of deficiencies (missing documentation, worker has not undergone training)

HRK 1,000.00

1.6. List and certificates of testing the machinery and devices with increased risk

Demobilisation and removal of deficiencies (missing documentation, not available...)

HRK 1,000.00

1.7. Construction site registrations Demobilisation and removal of deficiencies (construction site not registered, missing document at construction site ...)

HRK 1,000.00

1.8. Work plan Demobilisation and removal of deficiencies (missing documentation, not available...)

HRK 1,000.00

1.9. Decision on the appointment of construction site manager

Removal of deficiencies (missing documentation, not available...)

HRK 1,000.00

1.10. Record of supervision Removal of deficiencies (missing documentation, not available...)

HRK 1,000.00

1.11. Decision on the appointment of responsible person for OHS

Removal of deficiencies (missing documentation, not available...)

HRK 1,000.00

1.12. Evidence of professional training Demobilisation and removal of deficiencies (missing documentation, worker has not undergone training)

HRK 3,000.00

1.13. Safety Data Sheets SDS Removal of deficiencies (missing documentation, not available...)

HRK 1,000.00

1.14. Work instructions Removal of deficiencies (missing documentation, not available...)

HRK 1,000.00

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1.15. Gas installations testing

Demobilisation and removal of deficiencies (missing documentation, technical gas cylinders are not labelled, gauge and supply damage...)

HRK 3,000.00

1.16. Decision on the appointment of Coordinator I/II

Removal of deficiencies (missing documentation, not available...)

HRK 1,000.00

1.17. Log file Removal of deficiencies (missing documentation, not available...)

HRK 1,000.00

2. Maintenance, cleanliness at location

2.1. Work space Removal of deficiencies (cleanliness not acceptable)

HRK 500.00

2.2. Areas of workers' movement Removal of deficiencies (slippery floor, bumps, damage ...)

HRK 1,000.00

2.3. Roads

Removal of deficiencies (road passability, traffic regulation deficiencies, traffic signs...)

HRK 1,000.00

2.4. Evacuation routes

Removal of deficiencies (emergency exits and emergency evacuation exits are not available ...)

HRK 1,000.00

2.5. Dining rooms

Removal of deficiencies (no minimum hygiene standards, no facility/premises provided...)

HRK 1,000.00

2.6. Resting rooms

Removal of deficiencies (no dressing rooms, facility for socialisation, resting premises...)

HRK 500.00

2.7. Utility rooms

Removal of deficiencies (missing dressing room, sink and bathroom, toilet, hygienic materials, water...)

HRK 1,000.00

3. Prescribed measures

3.1. Smoking ban Demobilisation (smoking in prohibited places)

HRK 500.00

worker

3.2. Ban on alcohol and narcotics consumption

Demobilisation (import and consumption at location)

HRK 500.00

worker

3.3. Permits to work

Demobilisation and removal of deficiencies (lack of permit, work without appropriate permit, work outside time period, , noncompliance with prescribed work conditions and PPE ...)

HRK 5,000.00

3.4. Safety signs Removal of deficiencies (not provided or certain safety signs are missing ...)

HRK 2,000.00

4. Hazardous working material

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4.1. Transport

Demobilisation and removal of deficiencies (vehicle not intended for transport of hazardous materials (ADR), functionality and use of grounding installations...)

HRK 5,000.00

4.2. Storage Demobilisation and removal of deficiencies (arrangement of hazardous materials, cleanliness, access...)

HRK 2,000.00

4.3. Labelling Removal of deficiencies (area not marked with safety signs ...)

HRK 1,000.00

4.4. Work procedure Removal of deficiencies (no work instructions...)

HRK 500.00

4.5. Technical gases Removal of deficiencies (nonconforming storage, transport and use of cylinders..)

HRK 5,000.00

5. Entrance into closed area and to places with increased hazard

5.1. Supervision official Removal of deficiencies (not appointed or not available at location ..)

HRK 2,000.00

5.2. Rescue team Demobilisation with removal of deficiencies (sufficient number of rescuers not provided ...)

HRK 5,000.00

5.3. Dig stability

Demobilisation and removal of deficiencies (the trench is not protected against collapsing, emergency exit is not ensured, there are no safety signs nor safety railing ...)

HRK 5,000.00

5.4. Communication Removal of deficiencies (worker missing at the vessel or column opening ...)

HRK 1,000.00

6. Works exposed to fire, fire protection

6.1. Fire extinguisher Removal of deficiencies (functionality, availability ..)

HRK 3,000.00

6.2. Flammable materials Demobilisation and removal of deficiencies (not removed, isolated, protected ...)

HRK 5,000.00

7. Work area /location

7.1. Fencing and marking Removal of deficiencies (missing safety signs, mechanical protection, psychological obstacles ...)

HRK 1,000.00

7.2. First aid Removal of deficiencies (missing first aid cabinet, list of workers ...)

HRK 1,000.00

7.3. Coordinator I/II Removal of deficiencies (not appointed or not available at location ..)

HRK 1,000.00

7.4. Works Manager/Supervisor Removal of deficiencies (not appointed or not available at location ..)

HRK 1,000.00

8. Personal protective means and equipment

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8.1. Appropriate

Removal of deficiencies , demobilisation in case of repeated deficiencies (not useful for certain hazard, not antistatic , fire resistant, resistant to acids, hydrocarbons, full body protection, CE marking ...)

HRK 1,000.00

8.2. Use

Removal of deficiencies , demobilisation in case of repeated deficiencies (workers without PPE at location, do not use certain protective means and equipment ...)

HRK 500.00

worker

8.3. Functionality Removal of deficiencies (damaged equipment, shelf life expired ...)

HRK 1,000.00

9. Work at height

9.1. Fences, pedestals and access Demobilisation and removal of deficiencies (fence, walkway, access, pedestal, lacing dimensions ...)

HRK 2,000.00

9.2. Scaffolding Demobilisation and removal of deficiencies (stability, marking, fence, walkway, vertical access dimensions ...)

HRK 2,000.00

9.3. Ladder Demobilisation and removal of deficiencies (stability, use, ...)

HRK 2,000.00

10. Material movement, crane work

10.1. Stability Demobilisation and removal of deficiencies (of fixed/mobile crane and cargo ...)

HRK 5,000.00

10.2. Signalist Removal of deficiencies (not available at location ...)

HRK 1,000.00

10.3. Area marking

Removal of deficiencies (missing safety signs, mechanical protection, psychological obstacles ...)

HRK 1,000.00

10.4. Transport Demobilisation and removal of deficiencies (unaccompanied, missing signalisation, road block, notification)

HRK 2,000.00

11. Electrical equipment, electric machinery

11.1. Functionality Demobilisation and removal of deficiencies (damaged isolation, switches, sockets, housings, fuses, no grounding ...)

HRK 5,000.00

11.2. Direct contact protection

Demobilisation and removal of deficiencies (all equipment under voltage but lacking: isolation, partition/housing, is not out of arms/body length, has no additional protection through differential current devices ...)

HRK 2,000.00

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SD & HSE Annex to the Contract

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11.3 Indirect contact protection

Demobilisation and removal of deficiencies (safety extra low voltage (SELV), protective extra low voltage (PELV), functional extra-low voltage (FELV), i.e. alternating current voltage <25V and direct current voltage <60V are not used in closed spaces ...)

HRK 2,000.00

12. Pneumatic and hand tools

12.1. Functionality Removal of deficiencies (tool damage, inadequate tools ...)

HRK 1,000.00

12.2. Tool use Removal of deficiencies (use of non-sparking tools in Ex-Zone, ...)

HRK 2,000.00

13. Environmental protection

13.1. Waste management

Demobilisation and removal of deficiencies (waste is not collected, separated, managed and R and D methods are not used...)

HRK 1,000.00

13.2. Pollutant emission Demobilisation and removal of deficiencies (uncontrolled emission into the sewage, air and soil ...)

HRK 3,000.00

13.3. Environmental measures for pollution prevention

Demobilisation and removal of deficiencies (no preventive and protective measures for water, air and soil)

HRK 2,000.00

*

(1) Amount of penalties has been unambiguously defined for each of the determined nonconformities;

(2) By paying the penalty (i) the contractor shall not be exempt from further sanctions due to the breach of agreement, and/or serious legal consequence determined through relevant legislation;

(3) If on several occasions the supervision team determines facts which are cause for pronouncing a penalty at the supervised location, the penalty may be pronounced several times;

(4) If several deficiencies (facts cause for penalty) exist simultaneously at a location, the penalty shall be pronounces for each deficiency, individually.

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SD & HSE Annex to the Contract

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INA Group HSE Policy

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