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This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

PROJECT HSE PLAN (Health Safety & Environment)


PACKAGE 2A

00 REV.

04-SEP-2009 DATE

IFR/IFR - ISSUED FOR REVIEW/FOR REVIEW COMMENTS REVISION MEMO

P. DI RUBBO

M.S.BONINSEGNA/O.DI FAZIO/ G. DORE

G.DORE/A. PERACCINI

WRITTEN BY (name & visa)

CHECKED BY (name & visa)

APPROV./AUTHOR. BY (name & visa)

DOCUMENT REVISIONS

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INDEX Page
This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

1. 1.1. 1.2. 1.3. 1.4. 1.5. 1.6. 2. 3. 3.1. 3.2. 4. 4.1. 4.2. 4.3. 5. 5.1. 5.2. 5.3. 5.4. 5.5. 5.6. 5.7. 5.8. 5.9. 5.10. 6. 6.1. 6.2. 6.3. 6.4. 6.5. 6.6. 6.7. 6.8.

INTRODUCTION Project Description Plant Location Work Location Considerations Project HSE Management System Purpose of this Document Acronyms HSE POLICY GOALS AND TARGETS Goals Project Targets RESPECT OF LAWS AND REGULATIONS National and International Laws OWNER HSE Regulations Industry Standards ORGANIZATION AND RESPONSIBILITIES Program Director Project Director Project Manager Project HSE Manager Project HSE Coordinators Site Manager Site HSE Manager Site Discipline Supervisors Expert for Compliance with Local Laws and Regulations Manager/Person in charge at Site TPIT OFFICES AND PREMISES FACILITIES Head Office and Premises Risks Evaluation Smoking Rule Environmental Friendly Initiatives Environmental Aspects and Mitigations Emergencies Sick Bay and First Aid The Identification Form of Foreign Premise or Safety Operating Plan

5 5 6 6 7 7 8 9 15 15 15 18 18 18 19 20 20 20 20 20 21 21 21 21 21 22 23 23 23 23 23 24 24 24 24

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7. 8. 8.1. 8.2. 8.3. 8.4. 8.5. 8.6. 9. 9.1. 9.2. 9.3. 9.4. 9.5. 10. 10.1. 10.2. 10.3. 10.4. 10.5. 10.6. 11. 12. 13. 13.1. 13.2. 13.3. 14. 15. 16. 16.1. 16.2. 16.3. 16.4. 16.5. 16.6. 16.7.

SAFETY CONCEPT ACTIVITIES Design Review Meeting Process Design, Engineering and Procurement Phases Construction / Pre-Commissioning Phases Pre-commissioning Awareness Program Accidents Management OCCUPATIONAL HEALTH Medical Fitness, Services and Tests Personnel Protective Equipment (PPE) Occupational Risks Non-occupational Risks Driving Risks SUBCONTRACTORS MANAGEMENT Qualification and evaluation Project HSE organization Site HSE Plans Incentive Plans Job Hazard Analysis (JHA) Behaviour Based Safety (BBS) CORPORATE SOCIAL RESPONSIBILITY (CSR) MANAGEMENT SYSTEM SECURITY MANAGEMENT SYSTEM SYSTEM PERFORMANCE CHECKING HSE Performance Indicators Audit Consumptions and Environmental Emissions Data MANAGEMENT OF CHANGE CONNECTION REFERENCES AND PROCEDURES SAUDI ARABIAN LEGISLATION CONNECTION Constitutional Law Human Rights Litigation and Court Procedure Administrative / Public Law Criminal Law Civil Law Commercial Law

25 26 26 26 29 32 32 32 34 34 34 35 35 35 36 36 36 37 37 37 37 38 38 38 38 39 39 40 41 42 42 42 42 42 42 42 43

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

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16.8. 16.9. 16.10. 16.11. 16.12. 16.13. 16.14. 16.15. 16.16. 16.17. 16.18. 16.19. 17.

Company Law Labour Law Health Law Mining Law Tax Law Banking Law Communication and Media Law Environmental Law Intellectual Property Law Arbitration Law Energy Law E-C Commerce LAW SOURCES

43 43 43 43 43 43 44 44 44 44 44 44 45

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1. 1.1.
This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

INTRODUCTION Project Description The Jubail Export Refinery (JER) Program is a grass root refinery to be implemented in Jubail, KSA, to process 400,000 BPSD of Arabian Heavy Crude Oil for the production of gasoline, diesel, jet fuel, petroleum coke, fuel oil, liquid sulphur and aromatic products for export. The Owner is SATORP, a Company participated 62.5% by Saudi Aramco (25% to be floated in the Saudi stock market) and 37.5% by Total. The Owner has split the scope into 13 Packages. TECHNIP ITALY S.p.A. named hereinafter TPIT the company organized and existing under the law of Italy, whose registered Head Office in Viale Castello della Magliana n 68, 00148 Roma, Italy, has been awarded as EPC Contractor a LSTK Contract basis for the Package 2A Conversion Units as detailed below: Distillate Hydrocracking (DHC), cap. 59,000 BPSD, licensed by Chevron Lummus Mild Hydrocracking (MHC), cap. 59,000 BPSD, licensed by Chevron Lummus Fluid Catalytic Cracking (FCC), cap. 32,700 BPSD, licensed by Axens LPG Selective Hydrogenation (SHU), licensed by Axens Sulphuric Acid Alkylatin (SAA), cap. 12200 BPSD, licensed by DuPont Stratco Sulphuric Acid Regeneration (SAR), cap. 110 MT/D, licensed by MESC Unsaturated Gas Plant (UGP), open earth technology.

and described in the Contract Documentation, Volume 2 Section 1: General scope of the Work. TPIT has been also awarded a second package named 5A subject of another dedicated Project HSE Plan. The activities connected with package 2A project will be executed according Owner expectation in compliance with the JER OOK(Outside of Kingdom) LSTK Contract n 3000235420 and JER IK(Inside Kingdom) LSTK Contract n 3000235421. The OOK (E+P) contract has been signed by TPIT which will divide the execution work between two operating center: Rome (ROC) and Paris (POC) under one integrated Directorate in Rome common to Package 5A covered by other contract. POC will perform the detail engineering and requisitioning for the DHC Unit; ROC will perform the activities for the other units. Both POC and ROC will subcontract part of their works to TPIL (India). The IK (Construction, Pre-commissioning and assistance for Commissioning/Startup on man hours basis) contract has been signed by Technip Saudi Arabia LTD named hereinafter TPSA the company having offices at Dhahran Street Postal code 31952 Al-Kobar, PO box 30893 Saudi Arabia. A General construction Subcontractor will be selected to perform all civil works, mechanical erection and electrical/instrumentation erection works.

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1.2.

Plant Location Jubail Export Refinery (JER) is in Al Jubail, industrial city and port city in Saudi Arabia, located in Eastern Province (Ash Sharqiyah Province) on the Persian Gulf coast, 100 km northwest of Dammar. An ancient center of the Eastern Province and a caravan junction, the city of Jubail was famed for pearling. Said oil producing area, it was found suitable as the site of the worlds largest petrochemical complex and major sea port. As of today, Jubail is a major industrial city custom built over the last decade as a location for major primary and secondary industries including refineries, petrochemical complexes, and steel mills. Jubail with 220,000 inhabitants (2004 estimate), on the Persian Gulf coast is among the best planned cities in Saudi Arabia, housing even a number of artificial beach lagoons, with highways connecting all city quarters. Planned industrial city, Al Jubail contains an oil refinery, a steel mill and one of the worlds largest desalination plants, which also generates electric power. In addition to refined oil products and steel, petrochemical products such as plastics and fertilizers are manufactured and exported. Other industries have been created to manufacture consumer goods and support the activities of the primary oil and gas-based ventures. This large industrial complex on the Arabian Gulf, along with Yanbu, its twin on the Red Sea, stands as a symbol of the governments vision of Saudi Arabias future development. The Royal Commission for Jubail and Yanbu was established to plan and administer all installations in these two cities. One of many advantages of industrial city of Jubail is the network of modern and broad roads implemented in accordance with the best engineering specifications. All roads are equipped with lighting and pavements, Jubail is well connected through express ways to all major cities in Kingdom. Detailed information are reported on Owner General Project Information Volume 2 Section 4 Attachment: JER/TCF Instruction to Jubail 2271 TF-955-RT-1000-0012.

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

1.3.

Work Location Considerations Saudi Arabia is one of the driest countries in the world and Jubail City has extreme desert climatic conditions with a hot summer/mild winter. Winter nights can be cool with temperature dropping as low as 4 deg C. Temperature in summer can exceed 50 deg C. High Humidity occurs during summer months like in any other coastal area. Rainfall is almost negligible. The climate is principally determined by southerly shift in wind patterns during winter months.

Consequently: Weather is characterized by critical situation that requires more care on safe working practices.

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1.4.

Project HSE Management System TECHNIP has put into force a Health, Safety and Environment (HSE) Management by mean of an integrated HSE Management System that includes together with Safety Health and Environment or its scope of the work and in compliance with OWNER requirements reported in the doc 2271 AAA JSM 701: HSE Requirement. The Project HSE Management System will operate during all Project life in order to assure that the activities and deliverables could guarantee the: Assessment of the adequacy and completeness of the design standards and procedure adopted for the Project, with particular attention to safety and environmental aspects; Identification of the potential hazards and environmental pollution sources which might arise during plant construction and Pre-commissioning phases; Verification that mitigating measures to reduce a specific hazard or pollution source have been taken into account.

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

The system has been tailored in accordance with TPIT HSE Management System already operating according OHSAS 18001:2007 and ISO 14001:2004 requirements. TPIT HSE Management System is certified by Bureau Veritas. 1.5. Purpose of this Document This PROJECT HSE Plan describes TPIT HSE Management System established for the project and represents a general reference deliverable for all personnel involved in the Project. The document has been arranged with the purpose of identifying general behavioural basis and refers to other documents and deliverable for detailed description of specific activities and topics. It defines the Objectives Organization, Preparations and Methods that are applicable to all TPIT activities for the project in compliance with the requirements, relevant instructions, standards and regulations specified in the Contract as requested. Said Objectives, Organization, Preparations and Methods will be implemented as a line responsibility by active participation of all people involved through the organization. All the activities which need to be undertaken are herein defined to ensure that the Plant is designed, manufactured, constructed and installed safely and in order to meet said aims included the identification and control of HSE risks, which could arise during each stage of the Project. This plan covers all phases of the Project. Whilst the minimum standard that will be accepted is to comply with all applicable laws and regulations, the ultimate goal of the Project HSE Plan is to aim for HSE standards to eliminate injuries to humans and damage to facilities, materials and the environment.

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This document is prepared under the responsibility of the Project HSE Manager. It is written by the Project HSE Manager, checked by Project HSE (Discipline) Coordinators, approved by TPIT HSE Manager, authorized by Project Manager and/or Project Director and submitted to OWNER for review and acceptance. This Project HSE Plan is a live document that, if necessary, may be subject to review and development by the Project HSE Manager and his team in order to continuously improve performance, throughout the Projects duration.

1.6.

Acronyms HO HSEMS LSTK PD PM PHSEC PHSEM SDS SGSS SHSEM SM Head Office Health, Safety and Environment Management System Lump Sum Turn Key Project Director Project Manager Project HSE Coordinator Project HSE Manager Site Discipline Supervisor Sustainable Development Management System Site HSE Manager Site Manager

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2.

HSE POLICY The TPIT integrated HSE Policy form the basis for their plan and its implementation on this Project. It is here following attached (Fig. 1 TPIT HSE Policy). HSE Policy is totally shared by Project Director and by Project Manager on behalf of TPIT CEO. The TPIT Policy Statement on Health, Safety and Environmental (HSE), that will be displayed at Site premises, is considered as a TPIT Project value not subject to compromise. Moreover, the TPIT Project HSE Policy is fully in agreement with the Owner Policy on Design Safety as outlined in the following OWNER Statement ( the engineering and the construction have to be carried out with safety as a prime consideration), with Saudi Aramco loss Prevention Policy and Program as outlined in the document JER Construction Safety Manual (SACSM) and in fully agreement with : Saudi Aramco Loss Prevention Policy here below attached as Fig. 2, Total HSE Quality charter attached as Fig. 3 Total/Saudi Aramco Code of Conduct Philosophy attached as Fig. 4. Satorp Safety Statement attached as Fig 5

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

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Fig. 1

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Saudi Aramco Loss Prevention Policy


The Company is committed to prevention of accidents to minimize loss of life or bodily injury to its employees and damage to its physical assets. In fulfilling this commitment, which is essential to and equally important as production objectives, the Company will take every reasonable measure to provide and maintain a safe and healthful work environment for its employees and protect the public against foreseeable hazards resulting from operations. Loss in productivity and property resulting from accidental occurrences can be minimized through good management. Loss prevention is one aspect of this process and is the direct responsibility of management. All management functions will comply with loss prevention requirements applicable to the design, operation and maintenance of facilities and equipment. When conformity with any of these requirements would not be practicable or cost effective, a grant of variance will be sought. Reviews for compliance with this policy will be performed on a selective basis.

Fig. 2

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Fig. 3 TECHNIP ITALY S.p.A. - 00148 ROMA - Viale Castello della Magliana, 68

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Fig. 4

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Fig. 5

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3. 3.1.
This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

GOALS AND TARGETS Goals The following HSE Goals are to ensure excellence in HSE performance and they are summarised as The Zeros and derive directly from TPIT policy: ZERO Incidents for the people and for the property ZERO Occupational Illnesses ZERO Releases or spills to the Environment ZERO Adverse impact to the Community ZERO Process Incidents.

3.2.

Project Targets In relation to the Jubail Export Refinery Project the following HSE Targets drive the activities performed on the Project.
Activities Performance under control Targets Two (2) executed controls during process design phase (Verification Procedure
for HSE Process Design Criteria 2365 PP 205 ).

Monitoring

Quality level of Process HSE Design HSE Management Quality level of Engineering HSE Design

Audit

Two (2) executed controls for each involved engineering discipline


(HSE Design Quality Control Procedure 1000 PA 2510).

Site HSE Audit Score Management Commitment HSE field survey HSE Steering Committee Project Personnel to receive basic training on HSE Management System applied to the project

Over 80% Weekly Monthly Participation at training sessions vs. 100% people involved in the project activities.

Audit Records Records

Orientation and training

Records

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Activities
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Performance under control Risk to personnel with reference to recognized risk Periodical drills execution

Targets 100% close out of HAZOP actions. 2 per year 100% classification and collection in dedicated and separated bins available at Project HO Offices. 0.025 as LTIR (*) 0.1 as TRIR (**)

Monitoring

Risk Management Emergency

Records Records

Environmental Management

Recycling and reuse of Project waste.

Audit

Safe Working

LTIR (*) and TRIR (**).

Records

(*) LTIR (Lost Time Incident Rate) =

No. of cases with lost workdays x 200.000 Exposure time of employees, hours

(**) TRIR (Total Recorded Incident Rate) =

No. of recorded incidents x 200.000 Exposure time of employees, hours

Recordable Incidents include also minor work - related injury cases (without lost workdays) such as: medical treatment case requiring a physicians intervention loss of consciousness temporary restriction of work or motion need for sutures

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3.2.1.

Specific Targets On the basis of the above Goals and as the activities evolve, the Project Director and the Project Manager and the Site Manager shall be responsible for identifying, together with the Project HSE Manager and the Site HSE Manager, any additional indicator to be satisfied during the life of the project. Such indicators and parameters for their measurement are used to define specific targets.

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

Specific targets on Health and Safety will be established on the basis of information gathered from design and site risk analyses. Specific targets on the Environmental protection will be established on the basis of real situations at Site regarding waste material, scrap production or spillage, emissions and from the results of the establishment of the Project Environmental Program for the project as described in para 8.3.2.

Such targets, together with parameters for measuring whether they are reached, shall be divulged to all personnel involved in the related activities. Periodic verification as to their achievement shall also be carried out under the responsibility of the Project Manager.

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4. 4.1.
This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

RESPECT OF LAWS AND REGULATIONS National and International Laws

TPIT shall comply and ensure compliance by any of its SUBCONTRACTORS with all applicable Saudi Arabian Government (SAG) laws, international laws and regulations throughout the performance of the CONTRACT, and in particular the laws and regulations relating to:

Health, Safety and Environment Product Safety Market Surveillance Practices Rights Personnel; Logistics; WORK Environmental the PLANT, the WORKSHOPS and the WORKSITE;

A list of applicable Saudi Arabian law, is reported at para 16. Said list not completed but can be preliminary assumed as reference. Environmental laws list will be also included in HSE Today Database available for all personnel. The herein para 17 report the list of Saudi Arabian Source of Law. 4.2.
OWNER HSE Regulations

TPIT shall comply and ensure compliance by any of his SUBCONTRACTORS with OWNER general regulations and OWNER safety and environmental requirements specified elsewhere in the CONTRACT, including project Specific applicable Standard In particular the explicit requirements included in :

JSD -1900-03 Safety Concept JERES B series JERES-C-103

and in general all the requirements included in :


Project Specification and Standards

1. 2. 3. 4.

JERES/JERMS/JEREP/JERESD/JERITP/JEREF/JERGI JSD Job Design Specifications JSS Job Supply Specification STC Standard Construction Drawings

Project Procedures

1. JSM JER Procedures

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Codes and Manuals

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

1. JER Construction Safety Manual 2. JER Sanitary Code


Project Specification and Standards

1. Drawings 2. Functional Design Specifications 3. Technical Notes TPIT shall be liable for any breach of this regulation and requirements by his personnel and his SUBCONTRACTORS personnel. 4.3.
Industry Standards

TPIT shall comply and ensure compliance by any of his SUBCONTRACTORS with the applicable industry standards and good practices.

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5.

ORGANIZATION AND RESPONSIBILITIES

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

TPIT has established clearly defined roles, responsibilities and job description for all personnel assumed to perform the Work accorded its procedure and OWNER expectation. The staff and resources assigned to the project are reported in the issued Project Organization Chart and all the TPIT personnel involved in the project activities are responsible for managing and reviewing HSE strategies, policies and performance reported in the Project Organization Chart issued for the project. The typical commitment of some key positions, regarding HSE issues, is summarized here following. A more detailed description of duties and responsibilities are included in the relevant following TPIT documents: SGSS Manual 1000.MH.0002,, Procedure Safety, Security, Environment and Health Site 1000.PA.8019.01, Start up HSE Procedure 1000.PA 9009 and Technological Risk Assessment and Environmental Procedure 1000.PA.2002 5.1.
Program Director

The Program Director has the responsibility for the final decision on the project strategies. He is the TPIT(Contractor) Representative and is the overall responsible for the project activities, HSE included. 5.2.
Project Director

He has the responsibility for the active participation of all levels of management and supervision on the realization of HSE pools and targets and collaborates with Program Director to finalize the decision on the project targets. 5.3.
Project Manager

The Project Manager is responsible of taking all decisions necessary for project implementation in compliance with HSE Policy of TPIT and with HSE applicable requirements to ensure that the communication takes place regarding the effectiveness of HSE Management System. Furthermore he is responsible of the correct preparation of the Safety Operation Plan or Identification Form of Foreign Premises or POS doc. n 2365 PP 550 as for Italian law and of its up dating for the incoming modification. 5.4.
Project HSE Manager

A Project HSE Manager will be assigned in both the operating center : Rome and Paris. They will have the role of HSE advisor on all the activities of the Project by the monitoring and verification of the Project HSE Plan effective implementation, of identifying improvement opportunities and of maintaining close contact with OWNER on the matter. They are assisted on Environmental activities for the Project by Project HSE Officer dedicated to environmental issues where necessary .

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5.5.

Project HSE Coordinators

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The Project HSE Coordinators are the Department (Process, Engineering, Construction, and Start-up) referents for Project HSE activities related to the scope of the work and are responsible for the technical quality and completeness of the relevant HSE deliverables issued for the project. In particular they are responsible for cooperating with the Project HSEM in identifying project improvement opportunities, for preparing the relevant part of the Project HSE Plan for his discipline and for its implementation during Project execution. 5.6.
Site Manager

The Site Manager is the most senior level of management at site delegated by the Project Director/Manager to act on behalf of The TPIT for all Construction and Precommissioning activities at site. In line with this duty the Site Manager is the overall manager responsible for the implementation of the site SHE program and accountable for SHE performances at site, in conformity with OWNER and TPIT requirements. 5.7.
Site HSE Manager

His focus is Construction and Pre-Commissioning HSE activities at the work place including work conditions, proactive safe work planning on site, use and storage of hazardous and toxic materials, consistent use of personal protective equipment, routing inspection of tools and equipment, environmental protection and emergency response equipment and training. He reports hierarchically to the Site Manager and has the responsibility to coordinate the activities of site HSE Staff appointed to the project. 5.8.
Site Discipline Supervisors

The Discipline Supervisors are the first line of contact with the craft employee/worker. In line with this duty they are responsible to directly ensure the application of the Site HSE program for Construction and Pre-commissioning activities. 5.9.
Expert for Compliance with Local Laws and Regulations

The Site Manager will select a staff professional who will be in charge also for the management of all the laws and regulations related to project activities. He is the responsible for the Site Project file on the matter. Books, Specification and Manual will be under his direct control with reference to their applicable issue. He will notify the occurring modification at laws and regulations and inform all project relevant personnel about those modifications. Furthermore he is the reference interface during inspection performed by Government, if any.

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5.10.

Manager/Person in charge at Site

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He is assigned by the TPIT at Site and his duty is to ensure compliance with Italian law, rights and requirements on Safety, Health and Environmental with regards to TPIT Italian Personnel, D. Lgs 9 aprile 2008, n. 81 and followed modifications and integrations included. He retains final responsibility for the Emergency Plan at Site and has the responsibility for the implementation of Safety Operation Plan or Identification Form of Foreign Premises or POS doc. n 2365 PP 550.

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6. 6.1.
This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

TPIT OFFICES AND PREMISES FACILITIES Head Office and Premises

The work of all personnel operating at TPIT Head Offices and Premises included OWNER and visitors, is managed by the regulation reported on the TPIT document "Guidelines and rules for the Safety and Health of Employees". 6.2.
Risks Evaluation

With reference to the Occupational Health protection aspects, the Document on Safety and Health during the work 1000.GS.5501 is available at TPIT Head Office and Premises. 6.3.
Smoking Rule

As per Italian law smoking is forbidden inside all the TPIT Building; however external dedicated smoking areas are available. 6.4.
Environmental Friendly Initiatives

In line with the commitment for Environmental protection, TPIT has implemented several environmental friendly initiatives in the offices. Separate Waste Collection is applied in Head Office buildings for municipal wastes such as Paper/Cardboard, Multimaterials (glass, plastic, metals), Organic garbage (Canteen A) and special waste (hazardous and non hazardous) such as batteries, neon lights, used cartridges. Low consumption equipment is used (PC, monitors, lights) in TPIT Offices. Renewable electric energy RECS (Renewable Energy Certificate System) certified is used in TPIT Offices and a quote of Renewable Energy is directly produced by two Photovoltaic Units located over TPIT Buildings. Biodegradable Plastic Cups are in use in TPIT Offices and Canteen A. High-quality environmental friendly recycled paper is available to all personnel. Same environmental friendly initiative, where is possible, are put in place time by time in the Premises.

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6.5.

Environmental Aspects and Mitigations

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All the TPIT H.O. Offices activities, project activities included, are analyzed and the relevant mitigations are identified according their criticalities as resulted. The study is reported in the document Significance Analysis and Ranking of Environmental Aspects in Rome Head Office doc. n 1000.GS.5502, periodically prepared and including the intervention actions that have to be put in force to obtain the mitigation and as a minimum: raw material consumption (i.e. paper, toner, stationery, etc); water and energy consumption; transports emissions; wastewater production; waste (non-Hazardous and Hazardous) management. The relevant mitigations are identified according their criticalities and monitored as detailed into doc. Intervention Plan for the resolution of Environmental Aspect 1000.GS.5506 in line with ISO 14001:2004 requirements. Same attention is given to Site activities as detailed in para 9.1 6.6.
Emergencies

An Emergency Plan describes procedure to manage dangers or risks for workers health or Company property and drills, even when not associated with fire or flame hazard, directed by a dedicated TPIT Safety Officer who, when necessary, requests the intervention of the Emergency Squad, the Floor Assistants, and orders evacuation of buildings, co-ordinating the intervention of external structures (Fire Brigade, Red Crescent, Local Health Dept). 6.7.
Sick Bay and First Aid

On working days and during normal working hours, a first aid and prevention service is available to staff at the TPIT Infirmary, managed by qualified personnel and supervised by an authorized physician. 6.8.
The Identification Form of Foreign Premise or Safety Operating Plan

All information on Occupational Health protection aspect at the site office and premise will be available by a main HSE document that will be issued for the premise:

The Identification Form of Foreign Premise or Safety Operating Plan

This document, specifically requested by Italian regulatory on the matter, will be written in Italian language Safety Operation Plan or Identification Form of Foreign Premises or POS doc. n 2365 PP 550. This form reports the list of activities that have to be carried on and of facilities that have been foreseen to guarantee all the work protection aspects in the Premise. Particular attention is dedicated to information and training to the personnel on the precaution to be taken in terms of occupational health during the execution of the Project Activities. A record about this executed training will be reported in the Form.

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7.

SAFETY CONCEPT

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The HSE fundamental principles/requirement to be followed on all the phases of the activities are illustrated in document Safety Concept that will be issued for the project according the requirements reported in 2271 AAA JSD 1900-03 that remains in any case a reference document for the Safety Concept Statements that have to be implemented for JER Package 2A Conversion Project .

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8.

ACTIVITIES

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

The most significant and representative HSE activities and deliverables that will be carried out and issued by TPIT for its EPC contract duty on Project Design, Engineering, Procurement and Construction included pre Commissioning phases are here in described. TPIT will operate in compliance with its Procedures/Standards customized for the project and with all applicable Safety Specifications available by OWNER. All the issues here in described will be carried out under TPIT responsibility at ROC and POC offices according their internal distribution of the work and will be relevant to Home Offices and Job and/or Premises Site commitments. Deliverables, reporting activities that will completed at site, could be object of review/enrichment according the specific needs that could arise in the field. 8.1.
Design Review Meeting

TPIT shall prepare for and participate together the Owner in two formal Key Design Review Meeting at approx. 60% and 90% design completion (Schedule B para.6.22).The meeting will be conducted in the Design Office and the purpose of said meeting is to determine compliance of TPIT proposed design with contractual requirements and related documentation, including HSE design issues ( Schedule B para.6.22) TPIT Project Management will communicate in due time the agenda of said meeting to permit Owner personnel to be involved. 8.2.
Process Design, Engineering and Procurement Phases

Furthermore periodical meeting will be held by PM with all the discipline co-ordinators in order to facilitate the resolution of any obstacles at the rolling out of the activities. The TPIT HSE Management will be involved if necessary. 8.2.1. HAZOP / SIL Review The Hazard and Operability (HAZOP) study is a systematic analysis of the process in order to identify deviations and their causes from intended design. The study uses a guideword approach and a brainstorming technique with an independent Hazop Leader. In accordance with ISA S84.01 and IEC61511 (Functional safety of electrical/electronic/programmable electronic safety-related systems) a SIL (Safety Integrity Level) is evaluated for each SIF (Safety Instrumented Function). Preliminary HAZOP/SIL review has been developed during FEED phase of Project; the Preliminary HAZOP/SIL review identified a number of recommendations aimed to increase the safety and operability of the systems. The majority of the recommendations were followed up and closed during the FEED phase of the Project and relevant actions implemented in the Project FEED Documentation. The non closed recommendation, including those relevant to Detail Design, were addressed to the EPCC phase.

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This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

The initial SIL Classification developed during the HAZOP and SIL Review Sessions has been verified according to the resolution of the HAZOP and SIL Recommendations that in some cases affect the SIL Classification. The updated SIL Classification is given in the document SIL List. As part of the Flare Study developed during the FEED Stage of JER Project a number of additional requirements were identified for SIFs aimed to reduce the relief loads to the flare. The highest SIL Level resulting between Flare Study and SIL Classification shall be applied. During EPCC phase of project the SIL list will be issued and will be upto date after every issue of the Cause and Effect Diagram. Finally during detailed engineering phase a full Detailed HAZOP/SIL Review shall be developed on all systems in Project scope of work. For more details refer to Detailed HAZOP/SIL Review during EPC phase procedure (2271.AAA.JSM.202).
8.2.2. Technological Risk Analysis (TRA) The TRA is a formalized methods for analyzing and identifying hazards and assess the risks, in order to define the appropriate mitigation means and measures. The study was performed during FEED activities. During the Study a number of recommendations, aimed to increase the safety of the systems, raised out. The majority of the recommendations were followed up and closed during the FEED phase of the Project and relevant actions implemented in the Project FEED Documentation. During the Detailed Engineering Activities the TRA will be in case updated/validated taking into consideration the changes with respect to FEED design, and the FEED non closed recommendation will be properly followed up.

8.2.3.

Building Risk Assessment


The study is addressed to evaluate risk related to plant building and give input to building design to withstand those risks. Building Risk Assessment (BRA) studies are performed at different phases of the project as follow: FEED BRA: to evaluate risk and to ensure proper building design even during initial design stage Detailed Engineering BRA: to check the previous results and to update them taking into account changes in layout, changes in process condition and changes in building functionality.

8.2.4.

Fire Fighting Particularly, the safety design deliverables are listed here below: 1. Data sheets of fixed and mobile fire fighting equipment

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2. 3. 4. 5. 6. 7.

9. 8.2.5.

Data sheets of flammable/Toxic gas detectors Fire protection coverage layouts (overlaid on plot plan) Hydraulic calculations relevant to fire water fixed systems Fire & gas detection layouts (overlaid on plot plan) Cause and effect chart Safety and fire equipment location drawings. They will show: mobile an portable fire extinguishers hydrants, monitors, hose boxes safety showers and eyewash Fire Protection and Gas Detection Systems Layouts (inside buildings)

Passive Fire protection Fireproofing will be apply to structural steel supports of equipments, piperack, etc. to reduce significantly the heat influx to the item support being protected. The passive fire protection philosophy is based on Project Specifications

Passive Fire Protection Layout (Fire Hazardous zone) will be issued.

8.2.6.

Noise Study The Noise Study is a systematic analysis to evaluate the expected noise levels inside the working areas. The study will be issued during the detailed engineering phase and considers the noisy equipment in normal operation, identifies noise sources of plant and provides the evaluation of the overall sound pressure level. The Following deliverables will be issued:

Noise Assessment Study (Noise Map) Job Design Specification for Acoustic Insulation

8.2.7.

Hazardous Area Classification The Hazardous Area Classification is a systematic identification of hazardous area to assure that all equipment will be suitable for the hazard classification designated for its location. For more details refer to Safety Concept ( see previous para 7.0 ).

8.2.8.

3D Model Review TPIT will execute the 3D Model Review. Side activity is a CAD technique to ensure the compliance with appropriate standards and verify the operability, maintenance, safety and ergonomic implementation of the plan design. This review will incorporate ergonomics and safe maintenance principles (manual sampling minimisation, powered operation on heavy equipment, platforms to mitigate falls, etc..), and consists in a walk through into a 3D electronic model with the use of BAP (Bentley Auto Plant).A checklist is followed.

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The review is conducted by the Piping Project Engineer and the Piping Co-ordinator, and it is carried out in separated sessions according the plant design progress. Each session take 1-week time and takes place at TPIT premises.
This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

8.2.9.

Material Supplies Duties All the Suppliers will be responsible for forwarding activity related to their supply and are requested to be in compliance with CONTRACT expectation with reference to HSE issues. These requirements will be reported in the documents that are included in the order package. In particular, each Supplier shall comply with HSE requirements during all the phases of its operation, and shall ensure, in general, all and necessary works and facilities in order to observe the contract timing and to achieve transport progress according.

8.3.

Construction / Pre-Commissioning Phases

The following indicated documents will be issued in order to manage the HSE activities for the Construction and pre-commissioning phase. They will cover exhaustively the requirements indicated in the OWNER HSE Regulations as reported in previous para 4.2 and in particular in the JER General Instructions (JERGI), JER Construction Safety Manual (JERCSM), in the Contract Schedule D and Schedule B and reference documentation. The documents will be prepared in compliance with contractor requirement and will be submit to OWNER, for comment and approval before the beginning of the project construction activities. TPIT shall ensure full implementation of the program by its qualified full-time Site HSE Officer, who will be committed to coordinate all the activities therein reported. The commitment will be transferred to each craft or crew supervisors by each subcontractor. 8.3.1. Loss Prevention Program (JERCSM and Schedule D para 1, section 1) or Site HSE Plan ,doc n 2365-AAA-PP851-0 Loss Prevention Program or Site HSE Plan for construction and pre-commissioning phases of the project represents the mother document that defines the specific essential measures that will be put in force with reference to HSE protection/prevention of all the people involved at job site. The document shall address the topics reported on para 1.3.1 of JER CSM as minimum and its content will be extended to include the Environmental requirements and expectation ,in particular will be there in reported the reference to Construction Environmental Management obligations.The procedures that have to be followed at Site will be there in attached , same of them are prepared in a draft form and will be reviewed, finalized and issued by Construction Site Management ; for instance : Emergency and Evacuation Plan-PP854,Traffic Plan-PP855,Site Security PlanPP 856,Site Incentive Plan-PP857,Site Structure Working PlatformPP858,Site Work Permit Procedure PP859. Any additional measure that TPIT and Owner may determine to be reasonable and necessary to protect against the injury or death of any person or damage or loss of any property during the execution of work can be included .

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8.3.2.

Environmental / Social Management Plan (ESMP) or Environmental Statement (EMS)

Method

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This document ESMP or EMS will be prepared since the first phases of activities. According Owner requirement the last revision of the Environmental and Social Impact Assessment (ESIA) will be used as a basis for its preparation . The ESMP or EMS arguments will clarify the method that TPIT intends to follow to achieve environmental acceptability as requested in para. 10 Schedule D ( Environmental Method Statement ) and shall illustrate the Project Environmental Program describing of all activities and deliverables to be used to ensure compliance with all applicable laws, regulation , guidelines and terms and condition or approval applicable for the detailed design, construction and pre commissioning phases of the project. Further more the Plan will be enriched with the Analysis of all the environmental aspects arising during Construction and Pre-Commissioning phases of the Project that TPIT will conduct according its procedure Assessing the Significance of Environmental Aspects and Related Mitigation 1000 PA 5502. Said Aspects will be duly analysed and the associated Environmental impact and related Significance will be assessed and relevant Ranking values will be assigned. Said Analysis will be integrated part of ESMP or EMS or reported in a dedicated document there in attached. Environmental Aspects that shall be analysed, in normal, abnormal and emergency conditions, are, as a minimum: consumptions (raw materials, energy, water, fuel); emissions to air (pollutants and dust); water soil; hazardous substances management; non-hazardous and hazardous waste management; noise, light emissions and other specific environmental aspects related to Site Environmental characterisation. The result of said Analysis will permit to identify the measures to prevent/mitigate/minimize the negative effects of the environmental aspect studied.(see following Site Hazard Identification Plan para 8.3.5)

8.3.3.

Pollution Contingency Plan (PCP) Schedule A para 17.1 / schedule B para 6.19, doc n 2365-AAA-PP854-0

This Plan will be prepared to describe, identify and control environmental hazards that may be encountered or caused during construction and pre-commissioning activities. PCP together with Waste Management Program (WMP) for liquids and solids (see following para. 8.3.4) will permit to finalize the previous study on Environmental Aspects Analysis and its final Action plan for the implementation of surveillance and measurement of defined mitigations for negative environmental effects (previous paragraph 8.3.2) . Action Plan that will be integrated part of Hazard Identification Plan (see following para 8.3.5) together with the other mitigation measures on Health and Safety for Site Hazards .

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8.3.4.

Waste Management Program (Schedule D para 3 Section 2),doc n2365AAA-PP853-0

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The document will details sources and disposal methods for all liquid and solid waste according to design basis on environmental protection requirements. The WMP will comply with Applicable/Reference Documentation including OWNER documents, codes, manual, standards and General Instruction and will contain details on environmental manage covering the following subjects as minimum: General Information on Scope of Work Organization and Responsibility Accident Detection, Reporting, Analyzing and Coordinating activity Waste Management Fire Emissions Environmental Emergency

A log reporting the identified risk and relevant prevention measures facing all identified type of waste will be included . Information reported in the WMP will be useful for the finalization of the Pollution Contingency Plan, to which is directly connected . 8.3.5. Site Hazard Identification Plan (HIP),doc n 2365-AAA-PP-852-0 The Site Hazard Identification Plan (HIP) will be prepared for the Project with the scope of collecting Site information coming from the Hazard Identification process, regarding:

General site hazardous characteristics, health, safety and environmental risk; Eventual critical tasks arising from Constructability General hazard arising from critical site phases (shut down, construction/precommissioning overlap etc.).

Identified measures for the implementation, surveillance and measurement of level mitigation of risks related to Health and Safety are here in reported as required in the para 1.3.2 of Construction Safety Manual .The content of the Site Hazard Identification Plan will be extended to environmental hazards and will include the Interventions for the implementation, surveillance and measurement of the mitigation measures resulting from environmental analysis according previous para 8.3.2 8.3.6. Constructability Report TPITs Area Construction Coordinator will chair a formal constructability session. Constructability is the optimal use of construction know-how and experience in planning, design, procurement and field operations to achieve overall project objectives. A complete report will issued Constructability workshop called key-to-build workshop has the final objectives to implement a constructability program ( schedule B para 6.30 ) which: Maximizes safety of field activities
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Optimizes overall project costs and schedule In tune with the ongoing work being performed by the construction network, it ensures that the loop is closed, i.e. the lessons learned on the project are being transferred to the manual and are becoming an item for the workshops

The objectives of a Project Constructability Program must encourage teamwork, creativity, new ideas, new approaches, and should emphasize total project integration, not the optimization of individual parts (joint participation by construction, engineering, procurement groups and OWNER. A complete report will issued including as minimum all constructability issues considered, ideas to be implemented and expected schedule impact Further more the report will include the action plan that each involved Discipline Department has to apply in order to close all the critical findings resulting from the meetings. 8.4.
Pre-commissioning

TPIT will applies specific procedure to manage overlap between Construction and Precommissioning activities with particular reference to: energized system communication; area and system identification and segregation; work permit procedure and lock-out / tag-out procedure. Those procedures will be detailed for Pre-commissioning phase and where project activity will involves areas not fully under control of TPIT, appropriate interfaces will be developed to define clear responsibilities at all stages of pre-commissioning, activities. Not less than 60 days prior Pre-Commissioning Starts, a revision of the PCP will be prepared, updating Pre-commissioning/Commissioning data where needed.(Schedule B.6.19) 8.5.
Awareness Program

An HSE dedicated Awareness Program will be established for the project during H.O. activities as part of usual TPIT training and induction activities for all company personnel, executed at H.O. and at Site.All the people involved on the project will be invited to participate and all the efforts will be made to maximize the participation.The program will include the explanation of HSE project and general issues/objective/deliverables with the final scope to obtain the friendly be behaviour on HSE sensitive topics. Awareness Program will include the application of a specific TPIT induction program named Pulse. This initiative was born to be implemented in all the TP group and will have a dedicate application on this project in order to promote a climate and focus in the organization that demands positive and proactive HSE responses for its employees.

8.6.

Accidents Management

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This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

TPIT will be responsible for reporting accidents to the Owner. Construction Safety Manual in the section 3.0 covers these reporting requirements and the principles behind accident investigation. According Technip Corporate internal procedure the tool named Synergy will implemented in the project .Said tool allows to record and communicate accidents events by a dedicate data base and will be applied for TPIT internal use . Further more according Technip Corporate Internal procedure the process and tool named Kelvin Top Set will be used to investigate incident when occurring. Top Set operates by a structured process based on systematic investigation method, traceable and running back through the same route again .Owner and Subcontractor could be involved as necessary.

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9. 9.1.
This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

OCCUPATIONAL HEALTH Medical Fitness, Services and Tests

TPIT and SUBCONTRACTORS personnel shall take pre-employment and regular approved medical check-ups suitable to their work conditions. Fitness certificates shall be maintained and provided upon request. Medical check-ups shall be given by a licensed company medical officer. Suitable and sufficient medical facilities will be provided at job site, including the adequate ambulance services. These medical facilities will be available for subcontractor employees and for TPIT personnel. As necessary and managed by qualified personnel. These arrangements and facilities will be subject to review and agreement by TPIT and will be part of the subcontract award process. Furthermore:

Medicines dispensed have to the strictly under control. A register reporting each item with the relevant expiry date has to be kept under the Doctor responsibility. Disinfection procedures instructions for ambulance have to be maintained and enforced. All the personnel who will be assigned in specific critical works (example at higher elevation, in explosion hazardous site and in confirmed space) will be submitted at medical dedicated special tests to assess their fitness for the role. Said assessment has to be periodically repeated on the based of programmed employment turnover, especially if they have get over a serious illness.

9.2.

Personnel Protective Equipment (PPE)

TPIT has agreed with a very committed policy governing Personnel Protective Equipment (PPE) TPIT shall provide PPE to his personnel in accordance with a recognized international standard and OWNER regulations (see JER Construction Safety Manual: Personal Protective Equipment) and shall ensure that SUBCONTRACTORS do the same. TPIT shall ensure that his personnel and SUBCONTRACTORs personnel always wears the Personnel Protective Equipment (PPE) required for the type of work being carried out in addition or in place of basis PPE required for all personnel. Suitable PPE shall be reviewed regularly according to risk evaluations TPIT shall ensure his employees understand the need for PPE and that they are provided with instruction as necessary in its use.

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9.3.

Occupational Risks

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

TPIT and SUBCONTRACTORS shall ensure that occupational health hazards related to construction activities have been identified and preventive measures have been taken implemented. TPIT and SUBCONTRACTORS shall ensure that every substance, product and material considered as hazardous by local regulation or international standards of reference is clearly identified, quantified and known by all personnel. Hazard Communication sessions will be programmed for the scope. Material Safety Data Sheet (MSD) shall be available in English and if possible in local language(s) on the WORKSITE to all personnel. Excessive working time and insufficient rest time have to be considered as occupational risks. TPIT and SUBCONTRACTORS shall adapt working time of personnel to climate, environmental and living conditions. 9.4.
Non-occupational Risks

TPIT and SUBCONTRACTORS shall ensure that preventive measures are implemented to mitigate health risks that are not directly related to his work, such as hygiene and environmental conditions, domestic and security hazards. Preventives measures shall cover TPIT and SUBCONTRACTORS facilities, offices, catering premises and housing. 9.5.
Driving Risks

TPIT and SUBCONTRACTORS shall define his own driving policy and ensure that his personnel and SUBCONTRACTORs personnel adhere to it. In the absence of any written policy or if there are inherent weaknesses in the TPIT and SUBCONTRACTORS policy, the OWNER current policy concerning vehicles and driving shall apply (see Construction Safety Manual Transportation para 7.1.4 )

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10.

SUBCONTRACTORS MANAGEMENT SUBCONTRACTORS and their SUBCONTRACTORS are fully integrated into the overall Project management system, including the implementation and management of the Project HSE System.

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

10.1.

Qualification and evaluation

Qualification All SUBCONTRACTORS will be assessed and evaluated for their ability to conform to COMPANY and CONTRACTOR HSE requirements and for their HSE management capability and performances over the past 3 years, as minimum. The qualifications process will be performed according the following steps:
-

Issue of a prequalification questionnaire Clarification meeting when necessary Pre-award audit if necessary

All SUBCONTRACTORS who cannot demonstrate an acceptable level of HSE performances, as resulting by the above qualification steps, will not be approved for any project work or service activities.

Evaluation TPIT shall be responsible for all HSE matter related to the Work, including that of all SUBCONTRACTORS involved in the project. The SUBCONTRACTORS will be monitored and valued on the basis of their HSE deliverables structure and of relevant implementation during the execution of the work.

10.2.

Project HSE organization

Each SUBCONTRACTOR will have staff and resources responsible for adherence to HSE Plans and Procedures and will work with TPIT, to this end, on a day to day basis. All SUBCONTRACTORS will designate contractually obligated HSE organization figures, which are to be approved by TPIT prior to their deployment in order to coordinate the enforcement of the HSE Program and to support their line managements implementation of the HSE program. The SUBCONTRACTOR will ensure that one HSE Officer is available for 1/80 workers, as a minimum. Within the HSE team of SUBCONTRACTORS dedicated competent person must be provided. See JERSCM requirements and Owner competent Dep.t Recommended Parties for more detailed information.

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10.3.

Site HSE Plans

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

Each SUBCONTRACTOR will be responsible for the preparation and implementation of its own Site HSE Plan and procedures for its areas of operations, which will be in accordance with TPIT Site HSE Plan for Construction and Pre-commissioning and with OWNER Oil requirements, that will be transmitted by TPIT to all SUBCONTRACTORS to meet operational HSE requirements for their scope of supply. In particular all the SUBCONTRACTORS shall be aware of all health, safety and environmental requirements, procedures and deliverables (TPIT and OWNER) applicable to their specific involvement. 10.4.
Incentive Plans

Incentive Plans have to be finalized with all the Subcontractors to encourage proactive approach for HSE by each of them. Said Plans have to be a dedicate line item with in the Programs and relevant Budgets. 10.5.
Job Hazard Analysis (JHA)

All work needs to be reduced to a simple task or job to be performed by a small group of workers. All the aspects of the work will be considered, both of a common as extraordinary nature. The Task/Job will be described in the form to be utilized for the development of a Job Hazard Analysis. Each SUBCONTRACTOR has to execute the Site Job Hazard Analysis that has to be submitted to TPIT Site HSE Manager and TPIT Site Manager for verification and review. The JHA will put into force a process that starting with the hazard identification will remove or mitigate the connected risks in a way that is as safe as reasonably practicable. Each SUBCONTRACTOR remains the final responsible for the analysis completeness and its results application. Furthermore the TPIT. Discipline Supervisors will be consulted for JHA acceptability and/or completeness. 10.6.
Behaviour Based Safety (BBS)

BBS procedure already operating at all TPIT sites, will be apply at project construction site. Subcontractors have to be in due time informed and trained on the initiative and will be asked to put all its efforts for a real involvement of all their person working at site.

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11.

CORPORATE SOCIAL RESPONSIBILITY (CSR) MANAGEMENT SYSTEM

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

In compliance with the procedures of its CSR Management System, already operating since 2004 in TPIT according SA 8000 standard, the fundamental values such as Human and Workers Rights will be implemented with a spirit of continual improvement also on this project involving:

all the project people and the project supply chain.

This commitment substantially involves compliance with the rules contained in the said International Standard SA 8000 (available in www.sa.intl.org) for the defence of Human Rights and to promote labour as a tool of Social Progress, in particular the criteria on Health and Safety will be pursued joint those on HSE here in reported.

12.

SECURITY MANAGEMENT SYSTEM

A well-structured chain of command and control shall be provided for a high level of security condition. TPIT and its Subcontractors will be requested to appoint a full time Site Security Officer who will be in charge of the security measures within its areas. Security measures and procedures shall cover all the working areas of the project , for instance living camp ,offices, lay down and must be in compliance with the security procedures and measures defined by Site Security Manager appointed by Owner.

13.

SYSTEM PERFORMANCE CHECKING

During the phases of project design, procurement, construction, and Precommissioning HSE activities will be checked against the degree of effectiveness and efficiency of the System. Audits and Inspections will be performed. 13.1.
HSE Performance Indicators

Evaluation of the effectiveness and efficiency of the HSE Management System in force is based on overall indicators of its application to the project peculiarities. As part of this approach, TPIT has identified several significant areas of concern:

The observance of requirements Reviews Monitoring activities

Through the analysis of these areas some indicators have been identified, such us: information on utilities consumption, emissions, expenses correlated with Job Site Activities: Construction, Pre-commissioning, Offices etc. They will characterize the project and will be published internally.

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13.2.

Audit

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

Audits will be executed according to the Audit schedule prepared by the Project HSE Manager and will be performed about 25% and 65% of site construction activities progress, in any case the first one at mechanical erection activities fully in progress and the last one in due time with construction timing completion to permit the closure of all the findings resulting from the visit .The activity of verification of performances addresses internal activities (at Home Office and at Site) as well as external parties such us inspections, assessment or pre-qualification on vendors/ SUBCONTRACTORS, as required by project needs. Personnel in charge for execution of the Audit/inspection, will prepare the relevant report that will be submitted to TECHNIP HSE Manager for approval in due time before its issue. The HSE aspects of activities performed at Site are subject to inspection of the Site HSE Manager. An inspection schedule, which shall cover every activity area and each SUBCONTRACTOR, will be prepared and kept updated by the Site HSE Manager. Said schedule will cover maintenance and other requirements for electrical tools and equipment, construction equipment and motor vehicles. 13.3.
Consumptions and Environmental Emissions Data

In order to implement an effecting EMS at Site, a set of environmental indicators have been selected, with reference to Global Reporting Index edition 3, and will be monitored at Site on a monthly basis as reported below:

Consumptions: Water Fuels Electricity Environmental emissions Waste water Solid waste production (Inert, Municipal, Industrial, Hazardous) % Recycling % Separate Collection Environmental expenses

Monitoring results will guide the implementation of the environmental management system. Details and forms for the monthly, data collection will be available at site.

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14.

MANAGEMENT OF CHANGE

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

TPIT shall maintain procedures for planning and controlling changes, both permanent and temporary, in people, equipment and working procedures to avoid any adverse HSE consequences. These procedures shall address:

Identification and documentation of change Responsibility for reviewing and recording the potential hazard from the change

Approval and implementation of change including adequate communication as necessary.

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15.

CONNECTION REFERENCES AND PROCEDURES

JER 004 LSTK (PACKAGE 2A) Contract JER 004 LSTK (PACKAGE 2A) Contract JER/TCF Instruction to Jubail HSE Requirements Detailed HAZOP/SIL Review during EPC Phase Loss Prevention Program TPIT SGSS Manual TPIT Verification Procedure for HSE Process Design Criteria TPIT HSE Design Quality Control Procedure TPIT SGSS Start-up HSE Procedure TPIT Document on Safety and Health during the Work TPIT Guideline and rules for the Safety and Health of Employees Functional Safety of electrical/Electronic Programmable electronic safety related system TPIT Procedure Safety, Security, Environmental and Health Site TPIT Safety Operation Plan or Identification Form of Foreign Premises or POS TPIT Assessing the Significance of Environmental Aspects and Related Mitigation . TPIT Significance Analysis and Ranking of Environmental Aspects in Rome Head Offices TPIT Intervention Plan for the resolution of Environmental Aspect in Rome Head Offices

3000235420 3000235421 2271-TF-955-RT-1000-0012 2271-AAA-JSM-701 2271-AAA-JSM-202 LPP (PP-851) 1000-MH-0002 2365-PP-205 1000-PA-2510 1000.PA 9009 1000.GS 5501 1000.MH 5502 ISA S84.01 IEC 61511 1000.PA.8019.0 2365.PA.5501 1000. PA. 5502

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

1000-GS-5502

1000-GS-5506

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16. 16.1.
This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

SAUDI ARABIAN LEGISLATION CONNECTION Constitutional Law

Basic Law of Government Law of Regions Law of the Council of Ministers Law of the Judiciary Saudi Arabia Constitution Shura Council Law The Basic Law 16.2.
Human Rights

Human Rights Commission Regulation 16.3.


Litigation and Court Procedure

Code of Law Practice Law of Procedure before Shariah Courts Law of the Board of Grievances Law of the Bureau of Investigation and Public Prosecution Law of the Judiciary 16.4.
Administrative / Public Law

Arms and Ammunitions Regulations Government Lease and Evacuation of Real Estate Regulations Government Tendering & Procurement Regulations Government Tenders and Procurement Law Implementing Regulations of Government Tender and Procurement Law Law of Provinces Shura Council Internal Regulations Social Insurance Law The Law of the Council of Ministers 16.5.
Criminal Law

IT Criminal Act Law of Combating Money Laundering Law of Criminal Procedure 16.6.
Civil Law

Law of Real Estate Ownership and Investment by Non-Saudis Regulation of Ownership and Investment in Real Estate by Non-Saudis

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16.7.

Commercial Law

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

Foreign Investment Act Foreign Investment Act The Executive rules of Foreign Investment Act The Law of Commercial Data The Law of Commercial Register GCC Common Law on Anti-dumping and Countervailing Measures and Safeguards The Unified Law of Combating Dumping Compensational Measures and Safeguard Precaution by the States of the Cooperation Council of the Gulf Arab States 16.8.
Company Law

Competition Law 2004 Cooperative Insurance Companies Control Law Cooperative Insurance Companies Control Law Implementing Rules for the Cooperative Insurance Companies Control Law Law on Supervision of Cooperative Insurance Companies The Law of Commercial Books 16.9.
Labour Law

Labour Law 2005 Public Pension Agency Act 16.10.


Health Law

Cooperative Health Insurance Law The Law of Private Laboratories 16.11.


Mining Law

Mining Investment Law 16.12.


Tax Law

Corporate Income Tax Income Tax Law 16.13.


Banking Law

Anti-Forgery Law Banking Control Law Currency Law Kingdom of Saudi Arabia Capital Market Law Law of Saudi Credit and Savings Bank Regulations for Investment Funds Regulations for Money Changing Business

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Rules for Enforcing Provisions of the Banking Control Law 16.14.


This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

Communication and Media Law

Law of Press Establishments Law of Printed Materials and Publication 16.15.


Environmental Law

General Environmental Law/Rules for Implementation - 28 Rajab 1422H Royal Commission Environmental Regulation RCER 2004 Royal Commissioning Environmental Penalty System RCER 2006

16.16.

Intellectual Property Law

Copyright Law Law of Patents, Layout Designs of Integrated Circuits, Plant Varieties, and Industrial Designs Implementing Regulations The Law of Trade Marks 16.17.
Arbitration Law

Law of Arbitration 16.18.


Energy Law

Natural Gas Investment Taxation Law 16.19.


E-C Commerce

Electronic Transactions Act

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17.

LAW SOURCES

This document is property of SATORP and shall not be disclosed to third parties or reproduced without permission of the owner.

Ministry of Higher Education Bureau of Experts Council of Ministers Capital Market Authority Majlis Ash Shura (National Consultative Council) Ministry of Education Ministry of Agriculture Ministry of Commerce and Industry Ministry of Communications and Information Technology Ministry of Economy and Planning Ministry of Finance Ministry of Foreign Affairs Ministry of Health Ministry of Justice Ministry of Municipal and Rural Affairs Ministry of Petroleum and Mineral Resources Ministry of Transport Saudi Arabian Information Resource Saudi Arabian Monetary Agency Telecom Act (Arabic) Presidency of Meteorology and Environment (PME) Royal Commission for Jubail and Yanbu (RCJY)

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