S-000-1654-001_C05.PDF

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© This document is the property of Dolphin Energy Limited. No part of this document will be reproduced or transmitted in any form or by any means, or used for any purpose other than that which it is specifically furnished without the written consent of Dolphin Energy Limited.

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UPSTREAM AND COMPRESSION

FACILITIES

Rev. Issue _Date Purpose/Description of Revision Prepared Reviewed Approved Company

A01 06FEB04 1st_{Issue For Approval} _{H. Simon} _{M. Harada K. Kamiyama}

A02 09MAR04 2nd_{Issue For Approval, Revision of all Pages} _{H. Simon} _{M. Harada K. Kamiyama}

A03 23MAR04 3rd_{Issue For Approval, Revision as Highlighted} _{H. Simon} _{D. Crawford K. Kamiyama}

A04 30MAR04 4th_{Issue For Approval, Revision as Highlighted} _{H. Simon} _{D. Crawford K. Kamiyama}

C05 30MAY04 Approved For Construction H. Simon D. Crawford K. Kamiyama

Contractor Document. No. S-000-1654-001<C05>

Company Document No. RL0-0000-FPG-50001 Document Class. 1

Area: MULTI AREA RAS LAFFAN

Discipline: CONSTRUCTION Document Type: PLAN

Commitment Number: UCB 15-01

Document Title:

Construction HSE Plan

RELEASED

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Note:

A revision line in the right hand margin denotes revisions.

REVISION HISTORY

REV DATE DESCRIPTION

A01 06FEB04 1st Issue For Approval

A02 09MAR04 2nd Issue For Approval, Revision of all Pages A03 23MAR04 3rd_{Issue For Approval, Revision as Highlighted}

A04 30MAR04 4th Issue For Approval, Revision as Highlighted

C05 30MAY04 Approved For Construction with Revision as Highlighted

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1.5.6.4 HSE Specific Training... 53

1.5.6.5 Skill Certifications... 54

1.5.6.6 Training Facilities ... 54

1.5.7 Site Security & Access Control ...54

1.5.8 Traffic Management & Transportation...55

1.5.9 SIMOP’s & Operation Control ...57

1.5.10 HSE Communication & Meeting...58

1.5.10.1 HSE Committee Meeting ... 58

1.5.10.2 Pre-Construction Meeting ... 61

1.5.10.3 Toolbox Meeting ... 61

1.5.10.4 Ad-Hoc Meeting... 62

1.5.11 HSE Promotion & Incentives ...62

1.5.12 Smoking, Drugs & Alcohol Policy ...63

1.5.13 First Aid & Medical ...64

1.5.14 Worksite Safety...66

1.5.15 Safety Register...66

1.6 HSE PERFORMANCE MONITORING AND IMPROVEMENT...67

1.6.1 HSE Improvement Methodology (PDCA & CI Cycle) ...67

1.6.2 HSE Performance Indicators and Benchmarks...67

1.6.3 Measurement and Feedback...71

PART 2 HEALTH & SAFETY PROGRAM ... 76

2.2 HAZARD IDENTIFICATION AND RISK ANALYSIS ...76

2.2.1 Hazard Identification ...76

2.2.2 Risk Assessment and Analysis ...78

2.2.3 Method Statements and Risk Assessments...79

2.2.4 Hazardous Work Plans ...81

2.3 HEALTH & SAFETY OBJECTIVES AND TARGETS ...81

2.4 RELATED HEALTH & SAFETY DOCUMENTS ...82

2.4.1 Hazard Identification & Risk Analysis Log...82

2.4.2 Standard Safe Operating Procedures...82

2.4.2.1 Tools and Equipment... 82

2.4.2.2 Fixed Machine Tools... 83

2.4.2.3 Compressed Gas Cylinder Handling ... 84

2.4.2.4 Isolation, Lock Out and Tag Out ... 85

2.4.2.5 Ladders and Lightweight Staging... 86

2.4.2.6 Mobile Work Platforms... 87

2.4.2.7 Scaffolding ... 87

2.4.2.8 Roof Access ... 87

2.4.2.9 Lifting and Rigging ... 87

2.4.2.10 Personal Protective Equipment... 88

2.4.2.11 Welding and Gas Cutting ... 89

2.4.2.12 Radiography/X-Ray... 92

2.4.2.13 Working at Height... 93

2.4.3 Permit to Work ...94

2.5 IMPLEMENTATION AND OPERATION ...96

2.5.1 Fire Prevention & Protection ...96

2.5.2 Manual Lifting...99

2.5.3 Explosive Handling and Control...99

2.5.4 Hazardous Substance and Materials...100

2.5.5 Off Site Safety...100

2.5.6 Plant and Equipment Inspection and Maintenance...101

2.5.7 Working Below Ground...102

2.5.8 Camp (Health, Safety, Environment and Security) Facilities Design and Construction...103

2.5.9 Housekeeping, Sanitation and Hygiene...105

2.5.10 Catering, Food Supply and Hygiene ...106

2.5.11 Thermal Stress...107

2.5.12 Confined Space Entry...107

2.5.13 Scaffold Erection, Dismantling, Alteration and Inspection...108

2.5.14 Office Safety and Safe System of Work...109

2.5.15 Laboratory Safety...112

2.5.16 Gas Detection...113

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PART 3 ENVIRONMENTAL MANAGEMENT PROGRAM... 116

3.1.1 Purpose ...116

3.1.2 Scope ...116

3.1.3 Data Management and Communication with Interested Parties ...117

3.2 ENVIRONMENTAL ASPECTS AND POTENTIAL IMPACTS...118

3.3 ENVIRONMENTAL OBJECTIVES AND TARGETS...119

3.4 RELATED ENVIRONMENTAL DOCUMENTS...119

3.4.1 Waste Management Procedure - Overview...120

3.4.1.1 Scope and Principle ... 120

3.4.1.2 Waste Classification and Disposal Option... 121

3.4.1.3 Waste Storage... 122

3.4.1.4 JGC’s Commitment... 124

3.4.1.5 WMP for Interim Operations (SIMOP, Start Up and Commissioning) ... 125

3.4.2 Chemical Management Procedure - Overview ...125

3.4.2.1 Selection of Chemicals... 126

3.4.2.2 Identification of Hazardous Chemicals ... 126

3.4.2.3 Storage of Chemical ... 127

3.4.2.4 Date and Record Keeping... 127

3.4.2.5 Personnel Training ... 127

3.4.2.6 Spill Prevention Measures... 128

3.4.2.7 CMP for Interim Operations (SIMOP, Start Up and Commissioning) ... 128

3.4.3 Spill Contingency Procedure - Overview...128

3.4.3.1 JGC’s Commitment... 129

3.4.3.2 Preventive & Control Measures ... 129

3.4.3.3 Monitoring... 130

3.4.3.4 Training... 130

3.4.3.5 Response, Notification and Report... 130

3.4.4 Environmental Monitoring - Overview ...132

3.4.4.1 Waste Quantity (Generation & Disposal) (Refer to WMP and Appendix 14)... 132

3.4.4.2 Environmental Effects Monitoring... 133

3.4.4.3 Environmental Compliance Monitoring (Refer to Appendix 16) ... 133

3.4.4.4 Report and Programs for Follow up Action... 134

3.4.4.5 Training... 134

3.4.4.6 Calibration of Monitoring Equipment ... 134

3.4.5 Environmental Emergency Response and Preparedness ...135

3.4.6 Industrial and Employment Benefits ...135

3.4.6.1 Employment and Benefits ... 136

3.4.6.2 Training and Education ... 136

3.4.7 Environmental Audit and Inspection...137

3.4.8 Environmental Impact Assessment Procedure - Overview...138

3.4.9 Protection of Rare & Endangered Species Procedure...138

3.4.9.1 Identification of Rare and Endangered Species ... 139

3.4.9.2 Rules and Regulations ... 140

3.4.9.3 Planning and Scheduling of Construction Activities ... 140

3.4.9.4 Inspection and Notification ... 141

3.4.9.5 Protection and Prevention Measures ... 142

3.4.9.6 Training... 142

3.5 ENVIRONMENTAL PROTECTION PLAN - Overview ...143

3.5.1 Site Preparation Activities ...143

3.5.1.1 Flora and Fauna (Site Preparation) ... 145

3.5.1.2 Atmospheric Resources (Site Preparation) ... 146

3.5.1.3 Groundwater Resources (Site Preparation)... 147

3.5.1.4 Historical, Cultural and Archaeological Resources (Site Preparation) ... 148

3.5.2 Gas Plant Construction Activities ...148

3.5.2.1 Flora and Fauna (Construction Activities)... 149

3.5.2.2 Atmospheric Resources (Construction Activities)... 150

3.5.2.3 Groundwater Resources (Construction Activities) ... 151

3.5.2.4 Historical, Cultural and Archaeological Resources (Construction Activities)... 152

3.5.3 Linear Construction Activities (Spools, Waste water pipeline etc.) ...152

3.5.3.1 Flora and Fauna (Linear Construction Activities) ... 152

3.5.3.2 Atmospheric Resources (Linear Construction Activities) ... 154

3.5.3.3 Groundwater Resources (Linear Construction Activities)... 154

3.5.3.4 Historical, Cultural and Archaeological Resources (Linear Construction Activities) ... 155

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3.5.4 Reinstatement & Site Rehabilitation ...156

3.5.4.1 Flora and Fauna (Reinstatement)... 156

3.5.4.2 Atmospheric Resources (Reinstatement)... 157

3.5.4.3 Groundwater Resources (Reinstatement) ... 157

3.6 ADDITIONAL IMPLEMENTATION AND OPERATION MEASURES ...157

3.6.1 Vehicle Maintenance & Refueling...157

3.6.1.1 Vehicle Maintenance Facilities ... 157

3.6.1.2 Fuelling Facilities... 158

3.6.1.3 Fuel Storage Areas ... 158

3.6.1.4 Refueling Areas... 158

3.6.2 Air Emission Control...159

3.6.3 Noise Control ...159

3.6.4 Protection of Archaeological Resources...160

REFERENCES ... 161

Appendix 1: CHP Formation ...162

Appendix 2: Construction HSE Deliverables...163

Appendix 3: Construction HSE Organization...166

Appendix 4: Typical Emergency Response Flow Chart ...167

Appendix 5: HSE Training Matrix (Construction Phase) ...168

Appendix 6: Field HSE Committee Organization...171

Appendix 7: HSE Key Performance Index ...172

Appendix 8: Table for Hazard Register ...179

Appendix 9: Definition of Consequences and Severity of Risk...180

Appendix 10: Risk Assessment Matrix...183

Appendix 11: PTW Application and Distribution Flow Chart...184

Appendix 12: Environmental Aspect/Impact Management ...185

Appendix 13: SCENR’s Permit Conditions for Construction and JGC’s Management Program...187

Appendix 15: Spill Response Chart ...193

Appendix 16: Environmental Monitoring Program ...194

Appendix 17: Rare and Endangered Species ...200

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ABBREVIATION

ALARP - As Low As Reasonably Possible

BAT - Best Available Technique

BATNEEC - Best Available Technologies Not Entailing Excessive Costs BPEO - Best Practical Environmental Option

CEMP - Construction Environmental Management Plan CHP - Construction Health, Safety and Environmental Plan CSOP - Construction Safe Operating Procedures

DOLPHIN - Dolphin Energy Limited

EBS - Environmental Baseline Studies EIA - Environmental Impact Assessment

EMP - Construction Environmental Management Plan

HAZMAT - Hazardous Material

HSE - Health, Safety and Environment H&S - Health and Safety

IMDG - International Maritime Dangerous Goods

JGC - EPC Contractor (as represented by the appointed JGC Site Representative) JGC EMS - JGC’s Corporate Environmental Management System

KPI - Key Performance Indicator

MSDS - Material Safety Data Sheet

OSHA - Occupational Safety and Health Administration of the United States of America PPE - Personal Protective Equipment

PTW - Permit To Work

RLC - Ras Laffan Industrial City

SCENR - Supreme Council for the Environment and Natural Reserves SOP - Standard Operating Procedure

QP - Qatar Petroleum

VEC - Valued Environmental Component

WMP - Waste Management Procedure

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FOREWORD

This document covers the Health, Safety, and Environment (hereinafter referred to as HSE) and Security requirements for the construction of Dolphin Upstream and Compression Facilities Project in Ras Laffan Industrial City in Qatar.

The Construction Health, Safety and Environmental Plan, hereinafter referred to as CHP, is arranged into three parts as follows:

PART 1 - OVERVIEW OF HSE MANAGEMENT PROGRAM

This part of the CHP presents the high level HSE goals, objectives and philosophy JGC will implement in complying Contractual commitments as an EPC Contractor for the Dolphin Energy Project. It will consist of the following components:

INTRODUCTION

HSE POLICY AND STATEMENT HSE OBJECTIVES AND TARGETS HSE SCOPE AND REQUIREMENTS

HSE ORGANIZATION AND RESPONSIBILITIES RISK ASSESSMENT AND MANAGEMENT HSE IMPLEMENTATION AND OPERATION

ASSESSMENT, ASSURANCE AND IMPROVEMENT HSE PERFORMANCE MONITORING AND IMPROVEMENT MEASUREMENT AND FEEDBACK

PART 2 - HEALTH AND SAFETY MANAGEMENT PROGRAM

This part of the CHP details specific Health and Safety requirements and standards, hereinafter referred to as H&S Management Program JGC will put in place throughout the Construction Phase. It will consist of the following components:

INTRODUCTION

HAZARD IDENTIFICATION AND RISK ANALYSIS RELATED HEALTH & SAFETY DOCUMENTS H&S IMPLEMENTATION AND OPERATION

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PART 3 - ENVIRONMENTAL MANAGEMENT PROGRAM

This part of the CHP details specific Environmental requirements and standards JGC will put in place in complying with Permit Conditions of SCENR, RLC Environmental Requirements and Dolphin EIA Report. This part of the CHP will consist of the following component:

INTRODUCTION

ENVIRONMENTAL ASPECTS AND POTENTIAL IMPACTS RELATED ENVIRONMENTAL DOCUMENTS

ENVIRONMENTAL PROTECTION

ENVIRONMENTAL IMPLEMENTATION AND OPERATION

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CHP Formation

PART 1

GENERAL HSE IMPLEMENTATION PROCEDURES

• Management of Change Procedure • HSE Audit & Inspection Procedure • HSE Emergency Response &

Preparedness Procedure

• HSE Incident/Accident Investigation & Reporting Procedure

• HSE Training Program

• HSE Communication Procedure / Meeting Schedule

• HSE Promotion and Incentives Procedure • First Aid and Medical Facilities

• Site Security & Access Program • Traffic Management & Transportation

Procedure

• SIMOPs and Operation HSE Control Procedure

• Smoking, Drugs & Alcohol Control Procedure

• Contractor Management

PART 2

CONSTRUCTION H&S PROCEDURES

• Hazard Identification & Risk Analysis Procedure & Log

• Standard Safe Operating Procedure • Permit to Work Procedure

• Fire Prevention & Protection Procedure • Manual Handling & Lifting Equipment

Procedure

• Explosive Handling & Control Procedure • Off Site Safety Procedure

• Plant & Equipment Inspection & Maintenance Procedure

• Housekeeping, Sanitation & Hygiene Procedure

• Thermal Stress Prevention Procedure • Confined Space Entry Procedure

• Scaffold Erection, Dismantling, Alteration & Inspection Procedure

• Heavy / Awkward Lifts

PART 3

CONSTRUCTION ENVIRONMENTAL PROCEDURES

• Waste Management Procedure • Chemical Management Procedure • Spill Management Procedure • Environmental Monitoring Procedure • Industrial & Employment Benefits

Procedure

• Environmental Protection: o Site Preparation o Plant Construction

o Onshore Pipeline and Cable Laying o Reinstatement and Rehabilitation • Vehicle and Construction Plant Refueling

Procedure

• Noise Control Procedure • Air Emission Control Procedure • Protection of Rare and Endangered

Species Procedure

• Protection of Archaeological Resources

Supreme Council of the Environment and Natural Reserves Environmental

Standards Ras Laffan Industrial City HSE Regulations

Dolphin HSE Requirements and EIA

Report

JGC Project HSE Plan and JGC EMS (ISO14001) CHP Construction HSE Improvement Plan

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JGC - HSE Policy for Dolphin Project

JGC Project Management is committed to providing a safe and healthful place of work and to protecting the environment in the location of operations.

To meet this commitment, JGC policy is to promote high standards in safety performance, health preservation, environmental care and security through developing and maintaining the appropriate HSE plans and procedures covering such elements as assessments, education, motivation, participation, implementation and accountability.

JGC’s policy consists of the following seven principles:

• Commitment to providing safe and operable plants and facilities, which impose minimum practical environmental impact.

• Personal safety and the protection of the environment are paramount. • All accidents and injuries can be prevented.

• All tasks will be planned and performed with concern for the safety and security of the staff and the protection of the environment.

• All employees, including vendors’ and subcontractors’, are responsible for their own and their colleagues’ HSE at work.

• Management will train employees to work safely.

• Full cooperation and liaison will be offered to Dolphin, statutory authorities and local communities.

This policy will provide assurance that the applicable legislation, approved codes of practice, and Dolphin’s requirements will be complied with.

________________________________ ___________________________________ Name of Project Manager Date

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Dolphin Energy Ltd QHSE Policy

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OVERVIEW OF HSE MANAGEMENT PROGRAM

PART 1

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PART 1 OVERVIEW OF HSE MANAGEMENT PROGRAM 1.1 INTRODUCTION

1.1.1 Planning

JGC will maintain plans for achieving the Health, Safety and Environmental objectives, the associated activities, risk reduction measures, performance improvement, management of change and preparedness for emergencies.

Significant Risks Strategic Objectives Construction HSE Plan Procedures & Method Statements 1.1.2 HSE Principles

JGC gives top priority to the management of HSE. JGC employees and Subcontractors working in the Dolphin Upstream and Compression Facilities Project are responsible for exemplary HSE performance. Good HSE performance in the protection of the environment and the health, safety and security of everyone who works for JGC are critical to the success of the project

JGC manages its Health and Safety within the framework of OSHAS 18001 and for the Environment; it is managed in accordance with JGC’s Corporate EMS, which is in compliance with ISO 14001.

JGC recognizes that HSE management is a line management function and responsibility, the principles of which JGC and its Subcontractors will observe and comply. JGC will take direct responsibility to lead and direct the Project workforce into achieving the HSE objectives and targets.

The following sets out the HSE principles to be applied. All work will be undertaken in a responsible manner. Decisions will be made with full consideration for Health, Safety, Environmental, and Security factors:

1.1.2.1 Providing a Safe and Healthful Place of Work

As a principle, this is a clear affirmation that accidents and harm to people will be unacceptable in JGC Project operational culture. Our target is Zero incidents and accidents to achieve our objective of ‘providing a safe and healthful place of work’.

It is recognized that incidents will occur, and line management will investigate any incidents that do occur and a report issued but our objective is clear, we will provide a safe and healthful place of work.

1.1.2.2 Minimize Emissions and Waste Generation

The objective is to minimize emissions and waste generation. The power in this statement lies in the word “minimize”. This is a realistic acceptance that some emissions and wastes will arise. It implies justification of decisions taken during the Construction, SIMOPs and Operation phases and requires that

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emissions and wastes shown to have been identified, will be minimized, to demonstrate that no permanent damage or harm to the environment has occurred.

1.1.2.3 Good Engineering Practice and Established Available Industry Practices

JGC will seek Health, Safety and Environmental excellence. The success of the project will be judged on its HSE performance. This will bring cost benefits to the Project and thus making provision for HSE becomes an integral part of the project.

Full consideration of HSE during the Construction Phase and ongoing proactive HSE culture will lead to achievement of this objective.

To achieve the desired excellence and improve on safety performance, JGC will develop a behavioral based change program requiring the active involvement of managers, supervisors and workforce. This document describes JGC’s commitment towards complying with applicable and current SCENR Legislations, RLC Regulations and Dolphin’s HSE Requirements.

In order to fully implement and realize the requirements of JGC Project HSE Policy and HSE Objectives and Targets, it will be essential for JGC to:

• Educate and train all JGC employees and Subcontractor’s personnel participating in the Project construction;

• Provide leadership guidance and example in order to motivate all JGC employees and Subcontractor’s personnel to ensure their constant awareness of the objectives; and

• Properly engineer the facilities and plan the execution all construction activities.

1.1.3 JGC HSE Objectives Health

• Giving due consideration to the design of a healthful work environment for the workforce. • Preparing and implementing a comprehensive sanitation and waste management plan for the

site.

• Enforcing a strict policy of no drugs and regulating the use of alcohol. • Ensuring that the site staffs are physically fit for the work.

• Preventing the project workforce from being exposed to conditions adverse to their health.

Safety

• Provision of competent supervisory personnel

• Giving the highest priority to the supply and installation of safe facilities and equipment • Striving towards an incident-free workplace.

• Establishing safety procedures and practices covering all operations. • Educating and training the staff to work in a safe manner.

• Motivating the staff not only to complywith the applicable procedures and plans, but also to take an active role in improving safety.

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Environment

• Giving highest priority to the protection of the environment.

• Striving to reduce environmental risk to a level that is as low as reasonably practicable. • Minimizing the production of waste and the consumption of materials, fuels and energy. • Educating and training the staff in environmental matters.

• Establishing waste management procedures.

Security

• Safeguarding lives and property of RLC, Dolphin, JGC and Subcontractors.

• Providing guidelines and procedures for the detection and prevention of crime, drugs and alcohol abuse.

• Establishing good relationships with local communities.

• Closely liaising on security matters with RLC, Dolphin and Subcontractors.

1.1.4 HSE Management Strategy

JGC HSE Management strategy is based upon JGC’s Corporate EMS (ISO 14001) and the framework of OSHAS 18001.

These are in turn based on the HSE “Safe Systems of Work” JGC will develop as JGC’s HSE operating procedures and work instructions and which JGC’s Subcontractors will be expected to follow. A flow chart on JGC CHP (CHP) formation is demonstrated in Appendix 1 and all HSE deliverables to be developed under the umbrella of the CHP are listed in Appendix 2.

JGC Project HSE Plan sets out the principles with which the CHP will comply, the statutory regulations from SCENR and HSE requirements from RLC and Dolphin form the Principle Rules and are considered

mandatory requirements to be followed during Construction, SIMOP’s and Operational Phases.

JGC will ensure all its employees and Subcontractor personnel are trained in the Principal Rules, understand them and observe them at all times.

JGC’s Commitment

JGC will take direct HSE responsibility and exercise formal HSE control over the Subcontractors’ workforces, equipment and materials during Construction, SIMOP’s and Operation Phase.

HSE Legislation, Standards, Guidance and Codes of Practice

JGC will observe and comply with all current and applicable HSE legislation, regulations and standards of the State of Qatar, SCENR, RLC and Dolphin.

In support of the above, best available techniques (hereinafter referred to as BAT) will be adopted. This involves adopting current safety standards from United Kingdom HSE Executive, United States of America Occupational Safety and Health Association (OSHA) and Basel Convention standards for Control on Transportation of Hazardous Waste.

Where such application is required, JGC will observe and comply with the processes, systems and recommendations contained therein to meet or exceed those requirements.

In addition to the framework and requirements of OHSAS 18001 and ISO 14001 respectively, JGC will

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observe and comply with JGC Corporate EMS and QMS.

1.2 HSE POLICY AND STATEMENT

The purpose of JGC Policy Statement is to clearly and concisely communicate JGC’s systematic and pro-active management approach in their commitment towards HSE for all JGC employees and Subcontractors.

JGC Policy Statement is derived from JGC’s Corporate HSE Policy. The HSE Policy clearly addresses HSE objectives specifically. It will be informed to all JGC employees and Subcontractors personnel, displayed on HSE notice boards, training centers and welfare facility areas.

Copies of JGC Policy Statement will be provided to Dolphin, Subcontractors and interested third parties. The JGC HSE policy addresses HSE objectives specifically related to the following areas:

• Personnel development, skills training and competency; • Minimization of losses;

• Management control; • Standards;

• Method of implementation; • Promoting a positive HSE culture; • Auditing and assessment; and • Continuous improvement.

The policy statement is signed by JGC Project Manager, and arrangements will be made to communicate it to all JGC employees and Subcontractors personnel during HSE Orientation prior to beginning of work. This HSE policy, including the requirements of the CONTRACT, has been reviewed to form the basis for JGC to develop a project-specific CHP.

A key feature seen by JGC of the CHP will be the assurance process through which JGC will demonstrate that the CHP is in place and fully functional throughout Construction Phase, SIMOP’s and Operational phases.

This CHP will define how JGC manage the three core requirements for the performance of safe, healthful and environmentally friendly work.

• Security and control of an environmentally safe and healthy work site.

• Positive identification and certification of all plant and equipment and powered tools on the work site.

• Identification, training, supervision and support of all personnel on the work site

The JGC CHP will typically contain procedures that address the key HSE Processes as follows:

1.2.1 Leadership and Accountability

HSE leadership by demonstration and example is an essential requirement for improving safe behaviors

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All members of JGC, from the most senior level, will be expected to demonstrate positive HSE behavior at all times.

JGC’s Site Management will adopt a proactive leadership role in creating and managing the CHP. Senior managers will be involved in proactive two-way communication on HSE matters, through HSE committees for example.

JGC will devote a significant proportion of their management time on HSE matters and the requirements of the CHP.

1.2.2 HSE Assurance

• Auditing and management review;

• Work practices, written procedures and rules; • Method statements;

• HSE inspection and review of the workplace; and • Operational control and site supervision.

1.2.3 HSE Behaviors

• Promoting a positive HSE culture; • Continuous improvement; and

• Induction and training for the entire workforce to ensure competency in management, technical and HSE.

1.2.4 HSE Risk Management

• Pre-construction HSE reviews; • Risk identification and assessment;

• Task risk assessments (Job safety analysis); • Risk management; and

• Security procedures and control of the worksite.

1.2.5 HSE Crisis and Emergency Management

• Emergency response procedures;

• Provision of emergency response personal equipment and systems; • Incident management team; and

• Incident management plan.

1.2.6 HSE Major Incident and High Potential Incident Reporting

• Accident and incident reporting procedures and systems; • Incident investigation guidelines and procedures; and

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• Publication of findings and lessons learned.

1.2.7 HSE Performance Targets

• Compliance with KPI’s, standards and permits; • Setting HSE objectives and targets;

• HSE performance data; and

• Measurable and realistic HSE performance targets for HSE incentive schemes.

1.2.8 HSE Reporting Requirements

• HSE and KPI’s reporting procedures;

• Action monitoring of HSE related remedial actions; • HSE Reporting Definitions; and

• Publish performance and definitions available to the workforce in training programs and at the workplace.

1.2.9 Health Management

• Pre-employment medical fitness confirmation;

• Proactive approach to determination of industrial illness;

• Demonstration that personnel are competent and fit at all times; and

• Demonstration that in the performance of the work, personnel are not under the influence of alcohol or illicit drugs (or inappropriate use of licit/prescribed drugs).

1.2.10 HSE Management

The JGC CHP defines:

• Roles, responsibilities, relationships and reporting lines;

• A system of safety representatives, committees, meetings and toolbox talks, enabling all personnel to participate in HSE matters;

• A system to involve the participation of all in HSE matters, including workers and management inspections to ensure the proper functioning of controls;

• A system to ensure changes to the organization are controlled;

• The extent of support available to the Project from the corporate organization; • Arrangements for the communication of policy; and

• Arrangements to secure employee competence through training and on-the-job evaluations and task observations.

JGC will take full responsibility for the work site and will:

• Ensure the co-ordination of all Subcontractors working within the construction site and other

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related sites;

• Ensure that all personnel comply with the HSE plan and any site specific rules;

• Take steps to ensure only identified, trained and authorized personnel are allowed on sites, and camp premises;

• Display suitable notices to remind employees of HSE requirements; • Supply to Dolphin any information relating to HSE as required;

• Ensure that all JGC employees and Subcontractors personnel are properly behaved and managed, so that no disturbance is caused to adjacent residents, their property or to any public facilities; and

• Designate responsibilities for field personnel to include: - Compliance with specification

- Implementation of HSE plan - HSE issues

- Social and security issues

All managers and supervisors will be trained in the requirements; copy of the CHP and its supplementary procedures will be made readily accessible to all interested third parties.

JGC will notify Dolphin both orally and in a written statement immediately after discovering, or receiving a report relating to any of the following events that occur under the EPC Agreement.

• The release of a Hazardous Chemicals or Hydrocarbons of more than 1 barrel or any other Hazardous Substances or Materials;

• The receipt by JGC or any of its Subcontractors of notice of any alleged violation of any HSE Regulations or of any action on JGC by any governmental authority;

• Any inspection or notice of inspection of work or a work site related to the EPC Agreement by any governmental authority;

• Any proceedings being commenced or threatened, alleging any failure by JGC or any of its Subcontractors to comply with any HSE Regulations or alleging potential responsibility for the release of a Hazardous Material;

• The death of any employee of JGC or its Subcontractors or third party while performing work under the EPC Agreement;

• The injury of any employee of JGC or its Subcontractors or third party while performing work under the EPC Agreement where a lost work time incident (LTI) has occurred;

• Any suspected personal health issues occur under the EPC Agreement; and • Any incident as defined in the EPC Agreement.

1.3 HSE SCOPE AND REQUIREMENTS

This CHP is developed and is consistent with JGC’s scope of work in constructing the Dolphin Upstream and Compression Facilities Project, including temporary facilities and areas in compliance with current

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applicable HSE legislations, regulations and standards.

The following sets out current and applicable HSE legislation, regulations and standards.

1.3.1 State of Qatar and Supreme Council of the Environment and Natural Reserves Laws

• FINAL SCE STANDARDS, 9 June 2003

• State of Qatar Environmental Protection Standards

• EIA Policy & Procedures, Environment Department, Ministry of Municipal Affairs & Agriculture, State of Qatar 1998

• Rules on Transboundary Movements of Hazardous Waste (Draft), Environment Department 1997

1.3.2 Qatar Petroleum

• QP HSE Regulations

• QP Safety Regulations for Contractors, Rev 1, Nov 96 • QP Corporate Philosophy for Fire & Safety, Rev 1, Jan 01

1.3.3 Ras Laffan Industrial City

• Procedure for Use of the Consolidated Permit to Work for RLC Common Areas, Rev A1, June 98 • Environmental Guidelines & Environmental Protection Criteria for RLIC, Rev 6, June 2002 • Permit to Work for RLIC Common Areas, Rev A1, Will 98

1.3.4 Dolphin Energy Limited

• EPCC Agreement (particularly Exhibit L and its requirements)

• PMS-PG-UF-05 REV A02 HEALTH SAFETY & ENVIRONMENT MANAGEMENT PLAN. • GS ENV 121 Environmental Impact Assessment Onshore Activities

1.4 HSE ORGANIZATION AND RESPONSIBILITIES 1.4.1 Site HSE Organization and Resources

JGC’s Site Manager holds the ultimate responsibility in ensuring the development and implementation of all HSE systems and programs.

JGC’s HSE Team, lead by JGC’s Site HSE Manager, reports directly to JGC Site Manager. JGC Site HSE team is responsible to develop, implement, monitor and maintain all HSE systems and programs in consistent with all current applicable HSE legislations, regulations and standards listed above. They will work together as a team through line organization and assist JGC through organizing and conducting HSE trainings, promoting HSE through promotion and incentive programs and provide professional and sound HSE advice.

HSE Resources

JGC will provide one (1) HSE personnel to one hundred (100) employees employed including Subcontractors personnel; the total number of HSE resources will include Subcontractors HSE personnel,

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to ensure adequate supervision of the construction activities, plant, equipment and materials. The responsibilities of JGC’s HSE Team are briefly described as follows:

• JGC’s Site Manager is responsible for implementing and enforcing this execution plan.

• JGC’s Site HSE Manager, assisted by HSE Officers, Environmental Coordinator and HSE Supervisors, is responsible for administering and monitoring this CHP and actively directing the HSE performance aspects of construction activities and operations.

• JGC’s Construction Manager is responsible for ensuring the health and safety of JGC employees and Subcontractors workforce and the protection of the environment in the process of executing construction activities and operations.

• JGC’s Construction Superintendent and Field Engineers are responsible for executing construction activities and operations incompliance with the systems and procedures developed in this CHP.

• All employees are responsible for complying with the directives, programs and procedures developed through the activities outlined in this plan.

Appendix 3 shows a typical JGC’s Construction HSE Team Organization. The actual field construction HSE organization in line with Appendix 3 will be submitted, agreed and updated prior to Main construction activities start.

1.4.2 Roles and Responsibilities

It is everyone’s responsibility to ensure JGC and Dolphin HSE policies are observed and adhered during the Construction Phase. In order to have a structured order of responsibility, HSE responsibilities of all JGC employees and Subcontractors are listed as follows:

JGC’s Site Manager

The Site Manager is responsible for all site HSE matters and for giving direction in HSE directing and planning. Assisted by JGC’s Construction Manager, Administration Manager and Site HSE Manager, this CHP and its supplementary procedures/programs will be developed and implemented. JGC Site Manager will act as follows:

• Assume full responsibility for HSE on the project and maintain liaison with JGC General Manager in the Middle East District.

• Plan and direct the site HSE program.

• Promote HSE by enthusiastically advocating the program.

• Delegate responsibilities for the various HSE functions and authority, for departmental and craft HSE promotion.

• Require full HSE compliance by all JGC employees and Subcontractors personnel.

• Establish the site HSE rules with special attention to unusual operations and HSE requirements of Dolphin.

• Maintain a current awareness of the Construction HSE performance status and HSE morale.

• Establish disciplinary actions necessary to develop a good, functioning HSE program.

JGC’s Site HSE Manager

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The Site HSE Manager is responsible for developing, implementing and maintaining the HSE Program. Being the HSE Administrator, the Site HSE Manager will function as an advisor / consultant to JGC and Subcontractors in establishing and maintaining compliance with current applicable legislations, regulations and requirements of The State of Qatar, RLC and Dolphin.

The specific responsibilities of JGC Site HSE Manager will include but not limited to:

• Coordinating site HSE efforts with RLC, Dolphin, JGC and Subcontractors.

• Keeping Dolphin and JGC aware of the progress of the HSE program and making recommendations for site-related HSE improvements.

• Administering site health, safety and environmental and security policies and procedures within

the framework of this CHP with particular emphasis on potentially hazardous operations and the protection of the environment.

• Proposing programs to implement the accomplishment of short and long-range site HSE objectives and initiate the motivation for employee participation needed to obtain these objectives.

• Preparing and distributing necessary HSE reports and records.

• Maintaining a continual audit and inspection program and reporting the findings and recommendations to the appropriate supervisor or Subcontractor for prompt correction.

• Planning and coordinating site HSE meetings, trainings and promotional/incentives program.

• Coordinating site first aid, medical and emergency services with relevant local authorities and affected third parties such as RLC and neighboring contractors.

• Investigating all accidents, injuries, fires, property damage, and other HSE-related incidents and

issuing the required reports.

• Being responsible for the classification of occupational injuries/illness and following up on the control and management of all cases.

• Assisting Subcontractors in developing their HSE programs to meet with Authority, Dolphin and

JGC HSE requirements.

• Evaluating the need for and requisitioning of HSE equipment needed on the job, and ensure HSE equipment meet with applicable standards and maintain in good condition.

• Effectively displaying and maintaining publicity materials on site bulletin boards, posters, safety

signs and banners and distributing safety literature.

• Administering and/or monitoring all HSE related programs developed under the umbrella of this CHP.

• Administering and monitoring construction waste that will affect the environment in accordance

with the conditions and requirements of SCENR, RLC and Dolphin.

• Maintaining knowledge of current state-of-the-art concepts of accident prevention and continually contributing to upgrading the site HSE effort.

• Know the requirements of all applicable HSE agreements as stated in the Contract and all current

applicable HSE legislations, regulations and standards.

JGC’s Construction Manager

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The Construction Manager is responsible for the safe operation of all construction activities undertaken. He will ensure the safety and health of the workforces are protected and the environment is preserved through the implementation of the CHP.

The specific responsibilities of JGC Construction Manager include:

• Ensuring the instigation of construction related risk assessments to ensure all hazards are identified and subsequent risks mitigated to ALARP, communicating all findings and residual risks to appropriate personnel

• Planning, monitoring and ensuring all construction activities and operations conform to applicable legislations, regulations and standards in respect of construction work.

• Ensuring construction activities and operations are performed in the best available technique ‘BAT’.

• Coordinating with Dolphin, JGC Site HSE Manager and Subcontractors to secure a safe and healthy working environment.

• Ensuring immediate corrective actions and mitigation measures are immediately implemented when requested by JGC Site Manager, JGC Site HSE Manager and Dolphin.

• Planning for prompt incident/accident investigations and that root cause(s) are determine and corrective and preventive actions are implemented.

• Conducting regular HSE meetings with Dolphin, JGC Site Staff and Subcontractors in planning and promoting site HSE.

• Ensuring competency of JGC Site Staff and Subcontractors and ensuring the workforce received adequate HSE training to work on site.

JGC’s Administration Manager

The Administration Manager is responsible for the safety within the office and accommodation camp and the security of the work site.

The general responsibilities of JGC Administration Manager will include:

• Forming preliminary field administration plans in staffing JGC’s HSE Team, Medical Team and Security Team.

• Supervising and directing all administrative services such as employment benefits, personnel control, general affairs, medical including first aid, security, and camp operation.

• Assisting JGC’s Site Manager in keeping a cooperative relationship relevant Local Authorities, RLC and Dolphin concerning HSE.

• Coordinating all industrial relation services with relevant local authorities, police, hospital, fire department and the local media.

• Establishing and coordinating communication procedure for the field construction work including telephone, telex and fax as required.

• Performing general function inherent in all managerial position with respect to HSE management.

• Familiar with the requirements of all applicable HSE agreements as stated in the Contract and all

current applicable HSE legislation and regulations.

In addition to the above responsibilities, JGC Administration Manager will be specifically responsible for

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all camp operation and controls housekeeping, maintenance, safety, security, fire protection, canteen operation, recreation, etc. in cooperation with JGC’s Site HSE Manager.

The specific HSE responsibilities of JGC Administration Manager for camp operation will include but not limited to the following:

• Establishing preliminary camp operation plans including staffing organization, HSE and security

system/procedures, etc.

• Establishing comprehensive procedures covering methods and techniques on housekeeping, safety, security, fire protection and other functions.

• Analyzing site manpower forecast requirements for HSE and Security.

• Administration support to assist JGC Site HSE Manager in protecting personnel health and hygiene and general camp operation and recreation needs.

• Planning and implementing personnel/vehicle entry control at the camp gate.

JGC’s Site HSE Officer

The Site HSE Officer will report directly to JGC Site HSE Manager and will assist in implementing and monitoring the CHP. The specific responsibilities of JGC HSE Officer will include but not limited to:

• Take a proactive approach to the implementation of the HSE culture within JGC and contractor personnel

• Implementing and monitoring the CHP and all procedures/programs developed under the umbrella of this CHP.

• Coordinating with HSE Supervisors (JGC and Subcontractors) in enforcing the CHP and all supplementary procedures and programs.

• Familiar with all applicable HSE legislations and regulations and the requirements of this plan.

• Inspect construction area frequently to identify hazards, non-conformance and non-compliances.

• Take appropriate corrective actions and prepare such reports to JGC Site HSE Manager.

• Coordinating with JGC Construction Manager, Supervisors and Foremen in respect of

construction activities concerning HSE matters.

• Maintaining inspection program and report findings and recommendations to JGC Site HSE Manager, JGC Construction Manager and Subcontractor for prompt corrective action.

• Conducting and participate in job safety meetings. • Assisting Site HSE Manager in training the workforce.

• Coordinating site first aid, rescue and emergency services.

• Investigate into all incidents/accidents as defined in the CHP and ensure such reports are timely submitted to JGC Site HSE Manager.

• Maintaining publicity materials on site bulletin boards, posters, safety signs, banners and suggestion box on a regular basis.

JGC’s Environmental Coordinator

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The Environmental Coordinator is responsible for the field implementation and maintenance of Part 1 and 3 of this CHP. He will report directly to JGC Site HSE Manager and assist in implementing and monitoring the CHP and coordinating all field activities pertaining to Environment in maintaining compliance with SCENR, RLC and Dolphin environmental legislations, regulations and standards.

The specific responsibilities of JGC Environmental Coordinator will include but not limited to the following:

• Preliminary works to ascertain and evaluate the approved / licensed waste receiving facilities internally and external to the State of Qatar, with respect to all identified construction Waste Streams (refer to Appendix 14)

• Administering, implementing and maintaining Part 1 and 3 of this CHP and all environmental

procedures and programs developed under the umbrella of the CHP.

• Ensuring compliance with applicable environment legislations and regulation through regular inspection of the construction worksite and the environment.

• Overseeing the monitoring of impacts and effects on the environment including water and air

quality and minimizing of waste production from identified waste streams.

• Conducting environment awareness training to all JGC Staff and Subcontractor’s employees.

• Coordinating environmental matters with RLC, Dolphin and JGC.

• Planning and implementing environmental inspection program and make recommendations in

improving the site environment.

• Participating in all HSE meetings.

• Coordinating field environmental emergency responses such as spillages, leakages and discharges of chemical, sewer and hazardous waste with RLC, Dolphin and neighboring contractors.

• Investigate into all environmental incidents and report such to JGC’s Site HSE Manager.

• Displaying, maintaining and distributing environmental awareness materials such as posters, signage, banners and literatures to the workforce and on bulletin boards to create awareness.

• Familiar with all current applicable environmental legislation, regulations, requirements, standards and policies of SCENR, RLC, Dolphin and JGC.

HSE Supervisors (JGC and Subcontractors)

The specific responsibilities of both JGC and Subcontractors HSE Supervisors will include but not limited to the following:

• Coordinating site HSE efforts with the workforce.

• Performing daily inspection and take necessary actions to eliminate / minimize hazards and risks identified.

• Participating in site HSE meetings including toolbox meeting and pre-work instruction meeting.

• Coordinating site first aid, rescue and emergency services.

• Assisting incident/accident investigation and collecting of information in assisting incident/accident investigation.

• Evaluating need and requisite for safety, first aid, and fire protection equipment needed on the

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job.

• Ensuring safety equipment meets with applicable standards and always maintain in good operational condition.

• Familiar with the all applicable HSE legislations and regulations.

JGC’s Construction Superintendent

JGC Construction Superintendent is directly responsible for controlling the activities and operations during the construction of the project. JGC Construction Superintendent plays an important role in ensuring this CHP is complied with during execution of construction activities and operations.

JCG Construction Superintendent will plan his activities and operations to avoid conflicting and incompatible work to reduce hazards and risk and to minimize impacts on the environment.

The specific responsibilities of JGC Construction Superintendent will include but not limited to the following:

• Reviewing all work and all new personnel for HSE needs. Complete familiarization with HSE

requirements is an integral part of the total job responsibility.

• Monitoring of HSE attitudes of the workforce toward HSE.

• Insisting on compliance with all HSE legislation and regulations before and during the execution of construction activities and operations.

• Conducting regular HSE inspections and arrest hazards and risks identified at time of inspection.

• Organizing and conducting regular site HSE meetings and other activities to perpetuate HSE consciousness.

• Ensuring workforce receive adequate HSE training before work commencement.

• Initiating plans to ensure proper and safe tools, materials, and equipment necessary for the performance of construction work are provided to the workforce.

• Assisting in incident/accident investigations to ensure proper reporting and documentation and ensure prompt mitigation measures are made arrest the cause after an accident to eliminate recurrences.

• Planning construction activities and operations with other supervisory personnel performing work within, or adjacent to their assigned work areas.

• Monitoring Subcontractor’s compliance with the CHP.

• Familiar with all current applicable HSE legislations and regulations.

JGC’s Field Engineer

The Field Engineer is not directly responsible for the craftsmen. He will work in conjunction with JGC Construction Superintendent in ensuring only the best possible safety practices are observed by the workforce. This responsibility will extend to the Subcontractors working under his direction.

JGC Field Engineer is responsible for the following:

• Confirming that vendors, engineering consultants, or field parties are made aware of the CHP and the need for individual cooperative compliance with the program.

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• Coordinating the activities of Subcontractors in area of his responsibility and monitoring their

activities to ensure that construction proceeds in accordance with current applicable HSE legislations and regulations.

• Setting good example by giving every indication of personal interest in and participating in the Construction HSE program and keeping up to date with site procedures and all HSE activities.

• Familiar with all current applicable HSE legislations and regulations.

Site Supervisors (JGC and Subcontractors)

The HSE compliance and adherence by the workforce lies directly under the responsibility of the Site Supervisors. Site Supervisors are responsible for instilling HSE awareness into his workforce. The specific responsibilities of the Site Supervisor will include but not limited to the following:

• Familiar with all applicable HSE requirements stipulated in this CHP and all its supplementary procedures and programs.

• Incorporating HSE procedures into routine construction activities and operations and ensure

workforce is made aware of and implement such HSE procedures.

• Conducting regular HSE meetings with the workforce.

• Conducting daily site HSE inspections to identify and correct any existing unsafe conditions.

• Coordinating construction activities and operation with site HSE supervisors in ensuring such

works are being carried out in a safe manner.

• Correcting any unsafe acts immediately without taking of unnecessary risks.

• Ensuring new employees have received adequate HSE training and that proper instructions have been given before they are allowed to commence work.

• Commending the workforce in eliminating hazards at site.

• Reporting of incident/accidents, unsafe conditions and defects in equipment to Site HSE Officers/Supervisors and ensure the affected area is not disturbed until the completion of investigation.

• Setting a good example by setting pace in observing the CHP.

Workers (Subcontractors)

• Using of correct and proper tools and equipment for the job (no modifications to their intended design function).

• Using of and proper wearing of personal protective equipment provided.

• Do not commence working on an activity or an operation without first having attended the necessary training on both HSE and its operation.

• Do nothing to endanger self or work colleagues.

• Keeping of tools and equipment in proper storage area.

• Inspecting of tools/equipment for defects and damage before use and report any defects to supervisor.

• Refrain from horseplay and abuse of safety devices, equipment and welfare facilities.

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• Reporting of incident/accidents, near misses or hazardous conditions immediately to immediate

supervisor.

• Read and understand the JGC HSE rules and take note of special safety precautions in restricted areas.

• Obeying of all posted warning signs and barricades erected.

• Following of instructions demanded from supervisors. If in doubt, ask questions.

• Never commence an activity or an operation without a valid work permit.

• Cooperate with HSE Personnel. They are on the job for your HSE.

• Know emergency procedures (siren codes, assembly points, wind socks, etc.). These

procedures will save your life.

1.4.3 Competent Person

Competent persons will be appointed for various functions to facilitate the implementation of this CHP and its supplementary procedures and programs developed thereafter.

Competent persons will play an important role in ensuring construction activities and operations are safely executed without causing risk to the health and safety of the workers and adverse impact to the environment.

Selection of Competent Persons

All competent persons will be selected based on the following:

• Knowledge of JGC’s HSE requirements;

• Knowledge of JGC / Dolphin’s contract requirements;

• Knowledge of current and applicable HSE local legislation and regulation;

• Specific HSE programs, procedures and obligations they are directly responsible; and

• Immediate knowledge of the subject, either by years of experience in the specific field, formal education, or specialized training pertaining to:

- Job activity being performed.

- Operation and use of specific equipment. - Potential hazards associated with specific jobs. - Safety, health and environmental standards.

Designated Activities

The following activities that requires the attendance of a Competent Person includes:

• Heavy lifting operation inspection.

• Scaffolding certification for used, erection, alteration and dismantling.

• Temporary electrical assurance grounding inspection.

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• Shoring inspection for deep excavations (> 1.6m).

• Atmospheric testing and issuing of confined space entry permit.

• Supervise and authorize tag out / lockout operation and issuing permit.

• Supervise and authorize hot work operation and issuing permit.

Review and Assessment

Regular HSE Audits and Inspection will be scheduled regularly to review and assess the competency of appointed Competent Person.

Competent Persons found to have compromised HSE requirements will be subjected to re-training or removal of responsibilities as recommended by the Audit and Inspection Committee.

1.5 HSE IMPLEMENTATION AND OPERATION 1.5.1 Management of Change

Change in work process, plant or part of it (modification) and equipment and to the design parameters or design can favorably or adversely impact HSE performance or the assumptions, results and conclusions of the studies.

The purpose and objectives to control the introduction of changes in key personnel (HSE, Management, Supervisory Staff and Machinery Operators), construction plant and equipment, work procedures and designs of approved work methods during the Construction Phase that will inadvertently affect the HSE performance of a specific task when not properly addressed.

A detail Management of Change Procedure (Doc. Ref. No.: S-000-1654-101) will be developed and implemented throughout the Construction Phase.

The 4 elements listed below will form part of the change management control procedure. • Identification/Notification of Change

Any proposed changes will be informed through re-submission of work method statement or relevant documents.

• Assessment of Change

A competent person within JGC will assess for potential or adverse impact on HSE. The assessor’s name, job title, and signature will be on the assessment sheet.

• Communication and Approval of Change

All changes identified will be communicated within JGC. Changes with the potential for adverse HSE impacts will require workshops (ad-hoc risk assessment meeting) to re-assess the hazards and risks involve. All Changes will be approved by JGC Site Manager, JGC Construction Manager and JGC Site HSE Manager.

• Documentation

All changes will be clearly documented to allow traceability in accordance with the Audit programme

This management of change control procedure will form part of the HSE Orientation program.

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1.5.1.1 Assessment, Assurance and Improvement

To promote good HSE management, JGC will develop and implement an incentive scheme in which JGC employees and Subcontractors personnel will receive reward or penalty for work assessed against predetermined standards.

The HSE incentive schemes will be based on Key Performance Indicators (KPI’s) outlined in Section 1.6. The purpose of the scheme is to promote continuous improvement of HSE standards based on the KPI’s. JGC will continuously monitor and report upon HSE performance. All hazards and HSE non-conformances will be reported.

A quality management system is required to ensure that work is performed in accordance with the standards as specified in the EPC Agreement.

Inspection of work systems and processes employed will be carried out by JGC and Dolphin. These are essentially discrete activities.

It is thus necessary that work is inspected and signed off as to acceptable quality standards.

HSE assessment will be carried out in accordance with the CHP and its supplementary procedures. Audit observations will demonstrate management commitment to HSE performance. All HSE assessment tasks will be carried out by JGC Site HSE Team.

The incentive scheme involves an assessment of the effectiveness of HSE procedures and how well they are implemented, to this end, JGC will:

- Encourage personnel to report hazards and non-conformances in a blame free environment; - Conduct task observations to ensure compliance with procedures and understanding of

instructions;

- Monitor the effectiveness of risk control measures;

- Define and carry out an audit, review, and worksite inspection program; - Provide reports for assessment;

- Inspect vehicles and construction plant condition;

- Manage actions arising from inspections, reviews, and audits; - Audit and review HSE activity;

- Identify and report key performance indicators (KPI’s); - Monitor incident frequency rates;

- Report weekly upon all activity, identifying work completed; - Work only to pre-submitted method statements;

- Stop work in the presence of uncontrolled hazards; - Submit hazard, near miss and incident reports; - Provide competent personnel for all tasks; - Report on the performance of HSE Inspectors;

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- Prepare method statements for all non-routine and critical tasks, submitting these to the Dolphin Employee Representative;

- Provide CV’s and job descriptions for all persons employed in HSE roles (JGC Site HSE Manager, JGC Site Safety Officer and JGC Environmental Coordinator and HSE Inspectors); - Attend HSE meetings; and

- Analyze performance indicators and action items and consider how the management system might be modified to improve future performance.

JGC will audit Construction and HSE activities and provide audit reports to JGC Management. The audit report will consider:

- Multi-work face arrangements.

- Aims. - Scope. - Standards. - Controls. - Corrective actions. - Management reviews The JGC assessment team will:

• Monitor the standards of HSE performance for each area construction crew. Inspections will focus primarily on the identification of unacceptable actual or potential impacts and will also consider non-compliance with the HSE management system or policy standards.

• Perform audits on the operation of the JGC’s HSE management system.

• Perform an audit(s) at project milestones to ensure that the completed work complies with the HSE requirements of the design.

• Review JGC risk assessments for coverage (required as part of the method statement)

1.5.1.2 Risk Assessment and Management

All Health, Safety, Environmental and Security hazards, effects and threats associated with JGC’s Construction Activities will be identified, their risks assessed and measures taken to reduce the risks to As Low As Reasonably Practicable (ALARP). As Low As Reasonably Practicable in this sense implies that further risk reduction would be physically impracticable or that the cost to implement the risk reduction would be grossly disproportionate to the benefit gained.

S-000-1654-001_C05.PDF

UPSTREAM AND COMPRESSION

FACILITIES

Construction HSE Plan

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