COMMUNITY AFFAIRS, HEALTH,

SAFETY, ENVIRONMENT AND

SECURITY PLAN

AUTHORIZED BY:
____________________
Managing Director/CEO

Issue Date: 15TH JUNE 2009

Revision Date: ____N/A_____
Revision Level: ____N/A_____
PROJECT TITLE:

CLIENT:

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 QUALITY POLICY STATEMENT

“We are committed to producing high quality steel

fabricated products and engineering services that
consistently satisfy customer requirements, while
complying with the requirements of ISO 9001:2000
QMS.

We achieve these through the efficient use of

resources, confidence building amongst our
stakeholders and continual improvement of the
system.”

MD/CEO

3
 HEALTH, SAFETY & ENVIRONMENT POLICY

The company believes that good HSE performance is an integral

part of efficient and profitable business management and
therefore committed to executing its activities to ensure safe and
healthy working environment for all employees and the safety of
persons living in the vicinity of the installation. The company’s
goal of no major incident in every project will be achieved by
maintaining proactive HSE programs designed to prevent
Accidents and Incidents. To achieve this, the company is guided
by the following principles;
- HSE is of equal importance as other business activities
- No activity shall be carried out unless considered safe
- Safeguard the health and safety of all employees,
contractors and third parties
- Minimize the impact of activities on the environment.

- Maintain good relationship with host communities and all

stakeholders.
- Enhance security of life and equipment
- Belief that “Every job could be safely done”

- Effective communication of HSE requirements and results

to all stakeholders
- Compliance with all relevant HSE legislations and

requirements.
- Continual improvement of the HSE system.

MD/CEO

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 TABLE OF CONTENTS

S/ PAGE
N
1 GENERAL INFORMATION
1.1 Purpose 7
1.2 Scope 7
1.3 References 7
1.4 Acronyms and Abbreviations 8

2 RESPONSIBILITY FOR COMPLIANCE 9

3 HSE OBJECTIVES AND PROGRAMS 9

3.1 Objectives and Targets 9
3.2 Our Programs 9
3.3 Community Relations Policy 10
3.4 Health 10
3.4.1 First Aid 11
3.4.2 General Rules in an emergency 11
3.4.3 General Rules for Burns 11
3.5 Safety 11
3.5.1 Management Responsibility 12
3.5.2 Fire Fighting Procedure 12
3.5.3 Hazards 12
3.5.4 Personal Protective Equipments (PPE) 13
3.5.5 Factory Safety Rules 13
3.5.6 Safety on Sites 14
3.5.6.1 Works Permits and Clients safety requirements 14
3.5.6.2 The company’s fabrication responsibility 15
3.5.6.3 Sub-Contractors (Steel Erector responsibility) 15
3.5.6.4 Workers orientation 15
3.5.6.5 Personal Protective Equipments (PPE) 16
3.5.6.6 Lifting and Handling Loads 16
3.6 Environment 16
3.6.1 Factory Environment 16
3.6.2 Erection Sites 16

4 HSE PERFORMANCE MEASUREMENT 17

4.1 HSE Metrics 17
4.2 HSE Incentives 17
4.3 Punitive Measures 17
5 ACCIDENT PREVENTION AND MANAGEMENT 17
5.1 Accident Reporting and Investigation 18
5.2 Accident Prevention 18
6 SECURITY 18

5
7 AUDIT, REVIEW AND INSPECTION 19
8 HSE COMMUNICATION 19
9 HSE DOCUMENTATION 19
10 HSE TRAINING 20

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1.GENERAL INFORMATION

1.1 PURPOSE

The purpose of this Health, Safety and Environment plan is to s ensure that we
carry out appropriate actions to comply with all applicable regulations governing
construction, general industry, and client’s requirements and to provide a
standard procedure for all work activities necessary for the enforcement of health
and safety policy, for conducting safety audits and reporting to supervision.
-Provide a standard method of reporting occupational injury, illness or fatality to
client.
-Provide a standard method for storage and disposal of hazardous waste in
accordance with statutory requirements.
-Provide a basic outline for the company and client required employee trainee
and documentation.
-Provide a basic outline for the establishment of site medical and sanitation
facilities and arrangement of outside medical backup.
-Provide for basic fire prevention program and ensure that hazardous, flammable
and combustible materials are handled and stored in accordance with applicable
standards.
-Ensure that all required written procedures are in place and conform to all
required regulations.
-Eliminate or reduce personal injury and damage to properties, materials and
equipments.

1.2 SCOPE

The scope of this Health, Safety and Environment manual include; activities
within the company’s premises, Erection sites and all other areas where the
services of the company are implied.

1.3 REFERENCES

HEALTH, SAFETY & ENVIRONMENT MANUAL

QUALITY MANUAL,
STANDARD OPERATING PROCEDURE,
SITE ERECTION MANUAL
CASHES

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1.4 ACRONYMS AND ABBREVIATIONS

ARMECO - AREWA METAL CONTAINERS LIMITED

GM - GENERAL MANAGER
HOD - HEAD OF DEPARTMENT
DCE - DESIGN & COST ENGINEER
HSE - HEALTH, SAFETY AND ENVIRONMENT
MD/CEO - MANAGING DIRECTOR/CHIEF EXECUTIVE
HQA/QC - HEAD, QUALITY ASSURANCE/QUALITY CONTROL`
JSA - JOB SAFETY ANALYSIS
ALARP - AS LOW AS REASONABLY POSSIBLE
CLOs - COMMUNITY LIAISON OFFICERS
MSDS - MATERIAL SAFETY DATA SHEET
LTI - LOST TIME INJURY
QHSE - QUALITY HEALTH SAFETY AND ENVIRONMENT
CASHES - COMMUNITY AFFAIRS, SAFETY, HEALTH,
ENVIRONMENT AND SECURITY

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2. RESPONSIBILITY FOR COMPLIANCE

The MD/CEO is responsible for ensuring that the entire workforce of the
company and our appointed sub-contractors follow the HSE guidelines.

The HSE Manager is responsible for ensuring that HSE guidelines are followed
within the factory.

For projects and erection sites, the site engineer will review the HSE guidelines
and adapt to suit present work conditions for Project Safety Plan. The site
engineer will also relate with the GM Operations with a view to constantly check
the sufficiency of the safety guidelines adopted.

3. HSE OBJECTIVES AND PROGRAMS

This program details the guidelines for ensuring safety of personnel, care of
materials, safe handling and operation of equipments, safe working habits and
Environmental consciousness or awareness.

3.1 Our Objectives and Targets

• Always review and improve on our past Health, Safety and Environment
performance
• To ensure that all statutory safety requirements relating to the industry are
complied with
• To prevent accidents at work
• Reduce work related injuries
• To develop changes in the attitudes of the employees and obtain their
cooperation for safe work practices
• Improve in Health and Welfare of our own and subcontractors staff
• Increase security awareness amongst our own/subcontractors staff
• Preserve the environmental resources.
.
3.2 Our Programs

The following programs are aimed at achieving our objectives and targets.

• All staff will undergo induction training on their first day of work. This will
be enhanced and reinforced through daily toolbox meetings.
• All equipment to be deployed to the project shall be subjected to pre-
mobilization process and certified.
• All technical personnel on the project shall be certified to possess
appropriate professional competence.
• All key operations shall be subjected to hazard analysis and appropriate
controls shall be implemented during execution.
• Plans and procedures shall be put in place to respond to any emergency
or loss of control.

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 • Scheduled audits, inspections, drills for emergency preparedness and
other programs as a continuous machinery for identifying hazards, unsafe
acts and conditions at the work place shall be carried out.
• Rewards and sanctions scheme will be introduced to ensure compliance
with safety and health rules, regulations and safe work practices.

3.3 Community Relations Policy

It is the company’s policy to maintain mutually beneficial relationships with host

communities.
To achieve this goal, the company will cooperate with and work through the site
engineer and the CLOs in the local communities to ensure that the local
communities are aware of the company activities and to ensure that any conflicts
are resolved in a timely manner.

3.4 Health

The Health and Safety at work Act of 1974 (Applicable in Nigeria) require all
employers to ensure so far as is reasonably practicable that the Health, Safety
and well being are properly preserved and protected. The company will operate a
healthy workplace with no health incidents and improve the health awareness of
its employees.

This will remain the Watchwords of the company’s management. To achieve

personal healthiness, the following shall be observed by all employees on site;

i. Construction materials and equipments shall be appraised to control health

risks. Those proven or known to be injurious to health shall be discarded or
minimized with the use of MSDS control.
ii. Handling of toxic materials or chemicals may result in serious skin disorder,
hence hands must be protected by wearing appropriate hand gloves before
handling toxic metals or chemicals.
iii. All overalls or personal clothing must be clean and free from harmful or
poisonous substances. If clothes are contaminated, they should be
removed and laundered immediately.
iv. Hands should be washed thoroughly after using the toilet.
v. Hands should be washed thoroughly before touching anything meant to be
eaten.
vi. All wounds or cuts must be reported to the medical personnel or site
engineer who will treat or arrange for treatment appropriately.
vii. First aid boxes will be fully equipped and monitored regularly. All medical
and first aid cases will be properly recorded. All illness must be reported to
the medical personnel or the site engineer.
viii. All work areas and toilets must be kept clean at all times. Toilets must be
swept and washed regularly at convenient intervals. Refuse bins must be
located outdoors and covered properly.
ix. There shall be no smoking in the work place, site or office premises.
x. Ensure compliance and enforcement of the prevailing alcohol and drug
law.
xi. Ensure that all personnel, both in the factory and on site are medically fit.

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3.4.1 First Aid
This is the immediate help provided to an injured or seriously ill person before
proper medical attention can be reached. This shall be available in the factory
and at the site. Only qualified personnel who have received basic training in first
aid procedures will administer the first aid.

3.4.2 General Rules in an Emergency

An emergency occurs when an accident leads to severe bleeding, cuts,
fractures, failure to breath, extensive burns, broken bones e.t.c. In the event of
any of the above, the following General Rules will apply

i. Find out if the injured is bleeding, stop the bleeding.

ii. Find out if unconscious person is breathing, if not start artificial respiration
at once.
iii. Do not permit an injured person to sit up or stand until you know how
serious.
iv. Do not move injured person until you are sure it can be done safely.
v. Do not give liquid to an unconscious person.
vi. Keep calm, act quickly, quietly keep by-standers away.

3.4.3 General Rules For Burns

In the event of burn of any nature;
i. Cut clothing from around burned part, do not pull it.
ii. If blisters are present, do not break or prick them.
iii. If burned area is large, call a physician immediately.
iv. Do not apply substance such as grease or salve on burned area.
v. Treat for shock in cases of severe burns.

3.5 SAFETY

All safety policies shall be implemented by all staff and subcontractors and will be
enforced by GM Operation and site engineer in conjunction with top
management.

3.5.1 Management Responsibility

i. Develop guidance by which a safety program will be carried out in all

spheres.
ii. Ensure that all safety policies are understood and carried out by all
personnel.
iii. Ensure that safety warning signs and checklist are in place
iv. Ensure that newly hired employees and subcontractors staff undergo
training on safety before commencement of work.
v. Analyse new projects and jobs for SAFETY. JSA of all jobs must be
properly documented.
vi. Ensure that all personnel in factory and on sites use protective wears
required of them. Personnel must be familiar with equipment or instrument
before operating them.
vii. Review safety program periodically.

3.5.2. Fire Fighting Procedure

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 In case fire is observed, then the following procedure should be initiated.
i. Raise an alarm by shouting “fire, “fire, “fire”. Call fire service
ii. Try to fight fire safely using the available extinguisher, ensuring you have
positioned close to the exit for a quick and safe retreat.
iii. Move quickly (not running) to mustering point
iv. Take roll call
v. Do not re-enter fire area until told to do so.

Remember life is more valuable than any worldly possessions

3.5.3 Hazards

These are conditions with potentials of causing injuries to personnel, damage to

equipment and loss of material. All hazardous areas shall have markings to
identify nature of hazards and type of preventive, protection and /or
precautionary action required.

Hazard checklist
All works shall be examined to see which of the following hazards exist or likely to
Occur;

i. Sudden acceleration and motion

ii. Chemical reaction
iii. Corrosion
iv. Electrical leakage
v. Electrical explosion
vi. Electric shock
vii. Fire
viii. Heat/temperature impact and shock
ix. Pressure
x. Radiation structural damage
xi. Stress concentration
xii. Toxicity
xiii. Vibration and noise
xiv. Power source failure

Corrective measures will be put in place to reduce or eliminate the hazard.

3.5.4 Personal Protective Equipments (PPE)

In addition to all safety measures being observed, there is need to protect the
worker from hazardous situation.

The guidelines include;

i. Establish the need for them by operational/professional requirement,

previous recorded accidents, safety audit, legal requirements and
susceptibility of individuals.
ii. Select equipment based on quality, durability, suitability, non interference
and appearance and general compliance to international standards.
iii. Provide equipments
iv. Enforce their use.
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 Notes:
o Hard hats should be worn reversed only if they are specifically designed
and approved by the manufacturer for that purpose.
o Trouser legs and laces must be tied or taped to avoid tripping hazards.

3.5.5 Factory Safety Rules

In addition to general compliance with Health, Safety and Environment

company wide,

The following rules also apply in the factory;

i. All workers must follow instructions. No short cuts. If in doubt, ask.

ii. Report immediately any condition or practice that might cause injury to
employees or damage to equipment.
iii. Put everything in its proper place. Keep work areas tidy and clean.
iv. Use the right tools and equipments for the job and use them safely.
v. Any accident involving a person or equipment no matter how minor should
be reported promptly. Get First Aid promptly.
vi. Use, adjust, alter or repair equipment only when authorized.
vii. Wear approved personal protective equipment/kit as directed. Keep it in
good condition.
• Eye protection must be worn at all times on jobs or in areas where
danger to the eyes is present.
• Footwear safety shoes are mandatory for all jobs where heavy
lifting and manual work is carried out.
• Head protection helmet or hard hat or other headgear must be worn
when on motor bikes or when working with cranes or areas of
overhead movement of tools and materials or when specifically
required by the safety regulations.
• Protective clothing wears e.g. gloves, apron, booths and some
specialized clothing equipment must be worn as required.
viii. Avoid distracting others. Do not indulge in horseplay.
ix. When lifting, bend your knees, grasp the load firmly and then raise the
load, keeping your back as straight as possible. Get help on heavy loads.
x. Obey all rules, signs and instructions.

3.5.6 Safety on Sites

Every individual working on sites shall take responsibility for safe work
practices, regardless of job title. SAFETY is everyone’s responsibility.

Before start of work, all workers shall attend a structural steel erection best
practice Review for the project.

Weekly safety meetings shall be held and sub-contractor shall be kept

informed in writing about discussions and issues that may affect safe erection
of steel e.g. weather conditions such as wind, access and site conditions.

3.5.6.1 Work Permits and Client’s Safety Requirements

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 Works performed on certain sites require endorsement of work permit by both
parties before commencement while other sites may require validation test by
the client to confirm our safety method and work process before
commencement.

This is to ensure that all concerned know the implication of the job at hand as it
concerns SAFETY requirements.

Potentially hazardous areas such as; Oil Fields, Petroleum Product and
Refining plants, Electrical Distribution system, Toxic Flammable liquid/ gas
storage areas require extreme attention to details while filling the work permit.

If conditions are adverse, the work permit will not be signed till conditions
improve or adequate safety measures are in place that do not compromise our
SAFETY standards.

If during the work, conditions change and become unsafe then the work must
stop. While the client’s representative is advised accordingly.

3.5.6.2 The company’s Fabrication Responsibility

The company shall be responsible for:

i. Providing detailed connection information to ensure that the structure can
be safely erected.
ii. Providing where required, safety attachments or anchor points

3.5.6.3 Sub-Contractor’s (Steel Erector) Responsibility

The steel erector shall be responsible for:

i. Ensuring workers are suitably qualified, adequately trained and with
sufficient
experience to safely perform the assigned work.
ii. Inform the company about access needs to the site specific work areas.
iii. Pre-planning work activities to ensure that workers are not required to
work under unsafe or suspended loads.
iv. Developing site specific work instructions and procedures that identify
access and area needs.
v. Ensuring that requirements for moving loads over working areas are met.
The erector must comply with the general and specific requirements of
lifting and handling loads.

3.5.6.4 Workers Orientation

Prior to starting work, all workers shall attend site orientations and daily Tool
Box meetings to be informed of and become familiar with:
• Site rules and regulations
• Erection plan and procedures
• Equipment to be used
• Hazard assessment
• Work area and emergency procedures (including the rescue plan)
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 • Work areas of other trades and the need to communicate planned
work activities them when working in close proximity

Site CASHES meeting will be held with the management once a month. This
meeting is exclusive to the Tool box meetings held every day.

3.5.6.5 Personal Protective Equipment (PPE)

See 3.5.4 above

3.5.6.6 Lifting and Handling Loads

• Manual handling of loads or materials by workers should be minimized.

• Sub-contractors must provide, where reasonably practicable, appropriate
equipment to help workers lift, lower, push, carry, handle or transport
heavy or awkward loads.

3.6 Environment

In order to ensure that work environment is safe, conducive and preserved

both in the factory and sites, the following actions are mandatory.

3.6.1 Factory Environment

• Clean all work areas before and after work daily.
• Clean all equipments at regular intervals
• Arrange properly all materials and tools.
• Clean roof gutters and factory drainages at regular intervals.
• Empty waste bins at regular intervals
• Mow factory lawns at regular intervals
• Keep grasses low at all times
• Carry out fumigation against insects, rodents, reptiles and other pests at
regular intervals.

3.6.2 Erection Sites

• Clean all work areas regularly as required.
• Store all supplies such as bolts in proper containers and set away from
areas where they can pose tripping hazards.
• Do not leave loose bolts and nuts lying on steel or on ground.
• Do not string hoses through high traffic areas or stairs. Instead, hang
hoses up to eliminate the hazard.

4. HSE PERFORMANCE MEASUREMENT

4.1 HSE Metrics

The following statistical records shall be maintained and reported on a weekly

basis during project execution and will be documented in the minutes from the
weekly review meetings;
• .Man-hours
• Lost time accidents
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 • LTI frequency
• Recordable medical treatment cases/frequency rate.
• Material losses/ damage
• Environmental incidents
• Community related disturbances Los time
• Communication issues
• First aid cases
• Hazards
• Medical or health statistics i.e occupational health

4.2 HSE Incentives

HSE incentive shall be in the form of souvenir to staff and subcontractor’s

personnel who participate in achieving nil Lost Time Injury within the
schedule period. The type and magnitude shall depend on management
decision, to be reviewed upwards when higher LTI free man-hours are
achieved.

4.3 PUNITIVE MEASURES

Breach of HSE rules shall be viewed seriously. To this, the following

guidelines are set by management to forestall recurrence
• First offender – Oral Warning
• Second offender – Written warning
• Third offender – Written warning
• Fourth offender – suspension.

5. ACCIDENT PREVENTION AND MANAGEMENT

It is a known fact that accidents result in suffering, pain and death to victims and
their families while the company suffers loss of time, money and materials,
machine and equipment damage. Government also incur losses when accident
occur at work.

Consequently, it is our desire to prevent accidents in all our operations. No

efforts shall be spared in order to achieve this objective.

5.1 Accident Reporting and Investigation

One of the weapons which the company will use in preventing accident is the
investigation of any accident that may occur.

The primary purpose of this exercise is to determine the cause(s) and use these
facts to prevent reoccurrence. Hence, it is therefore a matter of policy of the
company that every employee is expected to report immediately to his supervisor
or site engineer any accident which occur to him, his fellow employee or any
machine/equipment in his place of work. The supervisor/site engineer in turn is
expected to investigate the accident to determine its circumstances. He should
correct any unsafe acts that were responsible for the accident. The corrective

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 actions will be discussed with other work groups/areas during the review meeting
or sooner depending on the severity of the incident and the need for others to
learn from it.

Where such cause can not be immediately rectified, he should make

recommendations to Management on what measures to be implemented in order
to forestall a similar mishap occurring in the future. Employees are mandated to
cooperate during the investigation.

5.2 Accident Prevention

Apart from ensuring that all rules and practices aforementioned are properly
followed, accidents are also prevented through Job Analysis to uncover potential
hazards inherent either in individual jobs or projects to be undertaken. The jobs
to be analyzed are broken down into successive steps, potential hazards are
identified and ways to eliminate them and prevent accidents are developed.

The accident report is therefore documented for future reference.

6. SECURITY

The company intends to manage security affairs as an integral part of its HSE
program and as part of company’s business to eliminate injuries and losses of
materials, property of all staff, client, third party and all personnel involved in her
activities.

The company will employ adequate number of experienced security guards.

Access to project work sites will be controlled to prevent unauthorized entry as
follows;
• Access will be allowed to only those persons that have official business
and possess valid induction badge with valid photo identification badge.
• Only staff that has completed the minimum induction safety training
would receive access badge.
• Security personnel at the work site will be linked by GSM handset.
• All staff shall be with PPE appropriate for the activities carried out.

7. AUDIT, REVIEW AND INSPECTION

The site engineer will regularly conduct HSE Audits and inspection. These audits
shall determine the level of compliance with HSE goals and procedures for the
project.
Corrective actions for all non-conformities shall be outlined in the audit report.
Serious accidents or incidents will trigger a non-scheduled investigation. It is the
goal of the project to close out non-conformities within one week where applicable.
Routine inspections shall be carried out in the course of the project. The
inspections shall be in two forms e.g pre job inspection and post job inspection.
The inspections shall cover but not limited to the following areas; personal
behavior, hazardous area, power tools, hand tools, electrical equipments, hoses
and connections, safety slings, housekeeping, PPE and warning lights.

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 Review of audit findings shall be carried out during HSE meetings. This will be a
forum where learning points are communicated to project personnel and used to
improve the HSE management of the project.

8. HSE COMMUNICATION

HSE activities shall be communicated to all site personnel and relevant

stakeholder to the project. Communication shall be effected through daily tool box
meetings and weekly general meetings.
Safety meetings will normally be held regularly based on the project duration and
will be chaired by the site engineer. A nominated safety officer shall be responsible
for ensuring that minutes are taken of all safety meetings.

9. HSE DOCUMENTATION

All related HSE issues shall be documented and maintained at the site and the
company’s office.
Documentation and records shall include:
• Reports of progress towards meeting objectives and targets
• Training records.
• Inspection and review reports
• Non-conformance and corrective actions
• Environmental and injury incidents and investigation report.
• Maintenance records
The project QHSE coordinator is responsible for ensuring compliance with these
system and procedures.

10. HSE TRAINING

The workers orientation (3.5.6.4) together with the daily tool box meetings and the
weekly general meetings form the core training for the personnel on site.

The site engineer is responsible for identifying further training needs as project
progresses and see to its implementation.

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