Buxo Trinidad & Tobago Limited HSE Management Program

HSE Management standards

Contents
1. 2. 3. 4. 4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 4.10 4.11 4.12 4.13 4.14 4.15 INTRODUCTION ................................................................................................................ 1 HSE OBJECTIVES............................................................................................................. 2 HSE POLICY STATEMENT ............................................................................................... 3 STANDARDS ..................................................................................................................... 4 Leadership and Accountability ........................................................................................... 4 Legal Requirements and Document Control ...................................................................... 5 Risk and Change Management.......................................................................................... 6 Planning, Goals and Targets .............................................................................................. 6 Awareness, Competence and Behavior ............................................................................. 6 Health and Hygiene ............................................................................................................ 6 Communication, Consultation and Participation ................................................................ 7 Business Conduct, Human Rights and Indigenous Affairs ................................................ 7 Design, Construction and Commissioning ......................................................................... 7 Operations and Maintenance......................................................................................... 7 Suppliers, Contractors and Partners ............................................................................. 8 Product Stewardship ...................................................................................................... 8 Incident Reporting and Investigation ............................................................................. 8 Crisis and Emergency Management.............................................................................. 8 Monitoring, Audit and Review ........................................................................................ 9

Appendices

1.

INTRODUCTION

This Health, Safety and Environment (HSE) Management Program provides information concerning the administration and utilization of Buxo Trinidad & Tobago Limited (hereinafter referred to as BTTL) health, safety and environment programs relevant to its daily operations.

Background
The need for this system arose from a discussion between management as certain system deficiencies within the operational systems were observed. The revision of this document annual satisfies Managements commitment to continuously improve its HSE systems.

Scope
The scope of these standards covers all operational aspects and activities that have the potential to affect, positively and negatively, the health and safety of people or the environment. They cover the entire life of the operations from planning through execution. The objectives of these standards are to: Provide a risk based HSE management system framework, consistent with international clients standards, with ISO 14001, OHSAS 18001, and other internationally recognized standards. Set out and formalize expectations for the progressive development and implementation of more specific and detailed HSE management systems at all levels of BTTL. Provide a basis from which to drive continuous improvement towards leading industry practice.

Review and Document Control

These standards shall be reviewed at least every year by the BTTL HSE committee and consultants, if required, revised and reissued in accordance with the document control requirements of BTTLs Legal Requirements and Document Control.

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2.

HSE OBJECTIVES

BTTL shall set the following HSE objectives.

Objective Health Completion of the work without compromise to the health and well being of personnel. Ensure HSE competence of selected contract employees. Safety Development of a safety culture that protects effectively the safety of personnel and those affected by all our operations.

Measure Zero Serious Illness (defined as an occupational illness that requires the patient to leave the operation)

Zero Lost Time Injuries Zero accidents involving injury to personnel and/or company equipment. Zero accidents involving equipment or other company assets Collate statistics monthly and review performance with all staff. Zero harm to the Environment Collection and removal of all waste generated by our services Collate data on hazardous waste disposal (if and when required). Increased hazard reports, reduction compliances. identification in non-

Environment

Delivery of professional service to ensure compliance with both Environmental standards and any specific Client regulations

General

Induct every contracted employee and/or sub-contractor prior to project startup.

Introduce incentives for best project performance.

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3.

HSE POLICY STATEMENT

It is this companys HSE Policy to conduct all operations in a Safe, Healthful and Environmentally friendly manner. The Safety and Health of every person and the protection of the Environment is a fundamental consideration in every business decision and plan. We are equally committed to protect the public, company and/or Clients property, our customers and the Environment from events that could cause harm due to our operations. Our goal is to prevent the occurrence of all work related injuries, illnesses and property losses and to achieve one hundred percent compliance with all applicable HSE regulations that apply to our operations including that of our Clients operations. It is our philosophy that by continuously striving to identify and eliminate unsafe conditions and actions, we shall eventually achieve this goal.

We strongly believe that all accidents can and therefore shall be prevented within our operation, we shall:

Identify, assess and manage risk to human life, company assets and the Environment Strive to achieve leading HSE industrial practice Meet and, where appropriate, exceed applicable legal and Client HSE requirements Develop our personnel and provide resources to achieve our HSE targets Advise on the responsible use of our services. Ensure or work place is drug free.

We will regularly review our HSE performance and meet to develop strategies for improvement; these strategies once agreed upon will be implemented and supported by all personnel.

--------------------------------------------Mr. Philip Buxo Managing Director

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4. 4.1 Intent

STANDARDS Leadership and Accountability

BTTL directors, managers, employees and contractors understand their accountability and demonstrate leadership and commitment to getting HSE right throughout the organization.

The BTTL Board of Directors endorses the HSE Policy and these Standards, seek assurance of compliance and regularly review HSE performance, risk and strategic issues.

Performance Requirements
Managers are accountable for HSE performance of their businesses, the implementation and communication of the HSE Policy and meeting the performance Requirements of these Standards through management systems designed to measure and drive continual improvement in HSE performance. Managers shall provide resources for the effective implementation and operation of HSE management systems and the provision of specialist HSE advice. Managers demonstrate visible leadership and proactive commitment to achieving HSE excellence through personal example, by promoting initiatives, and by frequent work area inspections and reviews. Specific and measurable HSE activities are included in performance plans and appraisal systems for all employees. The HSE accountabilities of employees and contractors are identified, defined documented, and kept up to date, understood and applied. Systems are in place that recognize, reinforce and reward HSE initiatives and desired outcomes. Systems are in place to ensure that employees and contractors are aware of expected HSE behaviors and have a clear understanding of the consequence of inappropriate conduct. Employees and contractors understand that they have the right and responsibility to STOP work or refuse to work in unsafe conditions, and to bring these conditions to the attention of management, who are thereinafter responsible for conducting an enquiry and/or inspection to ensure that all potential or existing hazards and eliminated or made manageable. As a condition of employment, contractors must take all necessary precautions for the safety of all personnel at the work site. All BTTL employees shall comply with the HSE standards of our Clients, as well as federal, state, and local OSHA laws, rules and regulations. In addition, contractors must: Instruct their employees in the applicable Clients Standards and practices. Perform all work in a safe, environmentally sensitive, and workmanlike manner and provide necessary safety equipment for their employees. All injuries, spills/releases and/or incidents, (including property damage) are reported immediately. BTTL project Management will inform and work alongside our Clients ERT to ensure mitigation is achieved

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4.2 Intent

Legal Requirements and Document Control

Relevant legal, regulatory and other HSE requirements are identified, accessible, understood and complied with and an effective HSE control system is in place.

Performance Requirements
Systems are in place to identify and access all applicable HSE Laws, regulations, approvals, licenses, permits, and other requirements and document them in an HSE compliance register. The requirements in the HSE compliance register are assessed, reviewed and kept up to date. Due diligence is demonstrated through documented procedures that ensure the communication of specific requirements, periodic evaluation of compliance, record keeping and reporting. Managers demonstrate visible leadership and proactive commitment to achieving HSE excellence through personal example, by promoting initiatives, and by frequent documented work area inspections and reviews. Specific and measurable HSE activities are included in performance plans and appraisal systems for all employees. The HSE accountabilities of employees and contractors are identified, defined documented, and kept up to date, understood and applied. Systems are in place that recognize, reinforce and reward HSE initiatives and desired outcomes. Systems are in place to ensure that employees and contractors are aware of expected HSE behaviors and have a clear understanding of the consequence of inappropriate conduct. Employees and contractors understand that they have the right and responsibility to STOP work or refuse to work in unsafe conditions, and to bring these conditions to the attention of management, who are thereinafter responsible for conducting an enquiry and/or inspection to ensure that all potential or existing hazards and eliminated or made manageable. .

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4.3

Risk and Change Management

Management will identify all risk within an operation or task to be performed and shall provide specific HSE procedures to minimize eliminate and/or manage its impact on its HSE objectives of the company. A thorough review shall be conducted if or when a change in the scope occurs.

4.4

Planning, Goals a nd Targets

Plans and programs that include designated responsibilities, resources and time frames to achieve HSE goals and targets are in place with systems to monitor and report their progress. Updates and reviews including modifications are included as new developments take place. Business and operations set annual measurable targets, goals and performance indicators that are documented, communicated, monitored and reviewed. HSE performance information is used to review plans, goals, objectives and targets to improve risk management and performance.

4.5

Awareness, Competence and Behavior

Employee inducting programs address relevant and applicable HSE objectives and policies and specifically risk, hazards and controls that are tailored to Clients HSE systems for work. Employees and contractors receive training and development in the recognition, assessment control and elimination of at risk behaviors including HSE consequences of departures from specified operating procedures. On the job behavioral observations are in place that reinforce desired behavior and correct risk behavior.

4.6

Health and Hygiene

Occupational Health and Hygiene assessments are ongoing, monitored and ensure that medical surveillance programs are conducted for all operations task, work environments consistent with exposure risk. Employees have access to adequate medical and first aid services as appropriate to the location and nature of operations. Initiatives are in place to encourage safe and healthy lifestyles. All Medical records are kept Confidential, including drug test results (however they may be reviewed with the employee by a selected committee if found positive for any prohibited substances). Where the application of severity of Risk has not adequately reduced exposure, PPE requirements are identified and applied with appropriate training provide. Properly maintained PPE are provided and made available to all employees.

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4.7

Communication, Consultation and Participation

The HSE policy and relevant operation standards and information on HSE matters, risk, plans and performance are communicated to employees and contractors. Systems provide for consultation and communication, feedback and tracking of follow up actions. Open consultation and communication with all government and authorized agencies and other organizations are maintained in order to contribute to the development of public policy, relevant legislation and educational initiatives.

4.8

Business Conduct, Human Rights and Indigenous Affairs

All activities and operations are conducted in an ethical manner that supports fundamental human rights and respects local and cultural heritage. Systems are in place to ensure employees right to knowledge of all operations and the right of the public to relevant information on operations, which may affect them.

4.9

Design, Construction and Installation

Design, Construction and installation are implemented in accordance with Local technical standards and were necessary international standards of design are used, construction standards and procedures for installation and or start up programs. The public right to know with respect to the environmental impact will remain paramount in all operations management and relevant personnel are fully appraised and are involved in this program and adequate documentation. Design reviews for constructability, operability and maintainability of facilities; equipment and systems ensure that HSE risks and other considerations are effectively addressed (if and when applicable).

4.10 Operations and Maintenance

Systems and procedures are established and maintained to ensure that all operations and maintenance activities area managed and controlled to minimize HSE risks and impacts. Systems and procedures are reviewed regularly to ensure that they continue to be applicable and relevant and effective in controlling the hazards for which they were prepared. Systems are established; documents are maintained to ensure the ongoing integrity of project HSE Standards and equipment integrity. These include maintenance inspection (when applicable). Testing, calibration and certification of equipment at frequencies appropriate for the level of risk associated with the equipment and the manufactures requirements. Systems are in place to test and maintain the availability and effectiveness of protective systems including the management of temporary deactivation.

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4.11 Suppliers, Contractors and Partners

Suppliers, Contractors and Partners are subject to risk based HSE evaluation prior to contractual arrangements being established. Systems are in place that ensures the HSE performance of supplier, contractor and partners and their compliance with BTTLs HSE regulations. Obligations specific in their contracts are monitored and reported. All reporting relationship interfaces for HSE are established and documents between suppliers, contractors and partners.

4.12 Product Stewardship

Systems and programs are in place to ensure that waste is properly disposed. Initiatives are complied with to ensure negative environmental impact existing and new products and services are assessed for their potential to provide HSE benefits or cause HSE impacts over their life cycle. All opportunities are sought to promote products and service technologies that are intrinsically safe, recyclable and efficient in the use of energy resources and materials. Systems are in place to identify, evaluate and respond to HSE related external influences (customer needs and expectations, regulations, voluntary standards and competitor initiatives) that could impact on BTTL business activities.

4.13 Incident Reporting and Investigation

Systems are in place for timely reporting, investigating mitigations and appropriately communication of all HSE incidents. Information gathered from incident investigation is analyzed to identify root cause and monitor trends and reported to management to improve and implement standard systems and practices. Incident investigation processes include the identification and documentation of all factors and underlying causes that contribute to the incident, the controls that were intended to prevent it, the recommendations to award similar outcomes, the analysis of any failures in the controls and the relevant standard of compliance which was not followed.

4.14 Crisis and Emergency Management

Systems are in place to identify potential emergency situations and their impacts including those associated with neighboring or clients activities. Emergency response drills and exercises are complied with, including liaison with relevant authorized organizations e.g. Fire Department, Hospitals etc. that help in emergency response. Resource inclusive of personnel, required for emergency response are identified, trained, maintained and tested also made available for immediate use and response. Performance requirements are constantly upgraded with drills. Procedure and resources are in place to effectively respond to crisis and emergency situations.

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4.15 Monitoring, Audit and Review

HSE performance and systems are monitored, audited and reviewed to identify trends, gaps, measure progress, assess compliance and ensure continuous improvement. Facility and project sites HSE inspections and audits are conducted at frequencies appropriate to the level of HSE Risk systems that are in place to respond too and manage all non-compliances and nonconformities. Annual Management reviews should be conducted to determine continual suitability, adequacy and effectiveness of HSE management systems. HSE policies are reviewed and revise in the light of any changes in national legislation or new technology change.

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