Classification: SAFETY PROGRAM. Accountabilities

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SHE Department, Ontario Operations

Program #SAF-CON-P-01 Page: 1 of 21

Effective Date: November 2010 Revision: 1

Contractor SHE Management Program

Classification: SAFETY PROGRAM

Next Revision: November 2013 Authorization Cover Letter

Responsible Person: Manager of Safety Training Code:

Target Audience: Ontario Operations Key words: Contractor, Training, Contract, Accountabilities

Revision # DATE NATURE OF

CHANGE

PAGE INSERTED, REPLACED, REVISED OR CANCELLED

R1 November, 2010 _Changed _{-All Vale Inco references, to Vale}

* Includes updating of format & name change to all forms and related documents to the program.

-3.1.1.4 Accountabilities for Reporting All Injuries and ---- Incidents to ‘and Illnesses’.

Added -3.1.1.5 Accountabilities for reporting Envirn. occurrences -3.2.4 For Environmental Field Work & Studies

-Definition ‘Fit for Employment’

-Under section 3.1.1.1 ‘Provide personnel who are ‘fit’ to perform the work without risk to themselves or others.’ Deleted -1.3 Ontario Operations Seven Safety Principles

Communication of Document:

Please indicate ONE of the following:

Communication as per Communication Matrix

Communication Not Required. Please indicate reasoning ______________________________________

X Other (please specify): Managers, GM’s, Project Managers. Managers to copy designated

contact persons in their area

Authorization of Updated Contractor SHE Management Program, including all related forms & documents:

Reviewed By (Print Name): Fred St. Jean

Responsible Person (Print Name): T.Van Kempen

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Next Revision: November 2013

Table of Content

1.1 Purpose ... 3

1.2 Context ... 3

1.3 Ontario Operations Occupational Safety, Health & Environment Policy... 3

1.4 Guiding Documents ... 3

1.5 Definitions ... 4

2. CONTRACTOR SHE MANAGEMENT PROGRAM ... 5

2.2 Contractor Pre-qualification ... 7

2.3 Contractor SHE Policy Submission ... 7

2.4 Contractor SHE Program... 7

2.5 Contractor Task Specific Procedures ... 8

2.6 Contractor Orientation & Training ... 8

3. EXECUTION OF THE PROGRAM... 9

3.1 General Accountabilities ... 9

3.1.1 Contractor General Accountability ... 9

3.1.1.1 Contractor Employees ... 10

3.1.1.2 SHE Coordinator ... 10

3.1.1.3 Supervisors Trained in SHE ... 10

3.1.1.4 Accountabilities for Reporting All Injuries and Illnesses... 10

3.1.1.5 Accountabilities for Reporting Environmental Occurrences ... 11

3.1.2 Vale’s General Accountability ... 11

3.1.2.1 Designated Contact Person Accountabilities... 11

3.2 Specific Accountabilities ... 12

3.2.1 Jobs which are not surface Construction Projects (underground jobs, maintenance jobs) ... 12

3.2.2 For jobs which are surface Construction Projects, and Vale is the Constructor: ... 13

3.2.3 For jobs which are Construction Projects, and the contractor is the Constructor: ... 13

3.2.4 For Environmental Field Work and Studies ... 14

3.3 Monitoring & Auditing... 15

3.4 Post Job Performance Evaluation ... 15

4. TASK SPECIFIC PROCEDURES... 16

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Purpose

The purpose of this management program is to have contract field employee’s work within standards that are equal to or better than Vale standards.

1.1 Context

Ontario Operations of Vale is committed to safety, health and the environment. We will not compromise the health or safety of any employee, contractor or the public for the achievement of any other organizational goal. Our SHE commitment is evidenced by our Seven Safety Principles, Occupational SHE Policy and this Contractor SHE Management Program

1.2 Ontario Operations Occupational Safety, Health & Environment Policy

The Ontario Operations of Vale endorses the principle of sustainable development and recognizes that it includes commitments to safety, health and the environment through a balanced approach to economic, technical and social issues.

The Ontario Operations Safety, Health and Environment Policy is a statement of our commitment to achieve world-class performance. We will not compromise the health or safety of any employee or the public for the achievement of any other organizational goal. Our business is Safe Production and this shall be integrated into all aspects of our operations.

We must be clear in our understanding of our duties and responsibilities as employees of the Ontario Operations. We will comply with and where appropriate, surpass the requirements of Legislation, Corporate and Ontario Operations’ Policies. To this end, our Safety, Health and Environment program provides direction for the organization individually and collectively to participate in the recognition, assessment and control of workplace hazards.

1.3 Guiding

Documents

The following guiding documents were used as the basis of the SHE Contractor Management program and should be referenced as required for its implementation.

• SHE Management System (SHEMS) • Principles of Sustainable Development • Corporate Contractor SHE Guidelines • Occupational Health and Safety Act

• Regulations for Mines and Mining Plants, Construction Projects and Industrial Establishments • Environmental Protection Act

• Fisheries Act

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1.4 Definitions

Accountability & Responsibility: Responsibility is the duty to self. Accountability is the duty to

someone else Accountability is the reporting part of responsibility“ It must not only be done” (responsibility) but “be seen to be done” (accountability) There is a responsibility to do the right thing, and being

accountable means proving that one has done so to the interested parties

Bidding (Tendering): The act of issuing a formal, documented request (bid call) to contractors to

submit prices for doing a Job. Competitive bidding in Canada is governed by common law (case law).

“Constructor”

Is defined in the Occupational Health and Safety Act.

The duties of the Constructor are prescribed by the Regulations for Construction Projects. The entity of “Constructor” only exists for a Construction Project.

Not every job that contractors do on Vale property is a Construction Project. To determine whether a job is a Construction Project, refer to the definitions in the Act for “Construction” and “Project”, and consider them in conjunction. (For example, underground work is not a Construction Project, as it is specifically excluded in the definition of Construction).

Generally, the Constructor has overall control of the Construction Project and all the employers on it. The Constructor must ensure that all workers on the Construction Project comply with all provisions of OHSA and the Regulations for Construction Projects, and has the broad duty to ensure that the health and safety of workers on the Construction Project is protected.

Contract: A contract is a document. (Work is sometimes incorrectly referred to as a contract). A

Contract is a legal and commercial agreement between two or more parties.

A contract describes Work to be done and the terms of payments, as well as the terms and conditions for doing the Work.

“Contractor” shall mean any person, firm or corporation including suppliers of materials and

equipment working at the site and with whom the site has an agreement, contract or purchase order to do work.

Ellipse Purchase Order: A document that is a legal request for the vendor to supply the

requisitioned Work as described on the approved Purchase Requisition.

Ellipse Purchase Requisition: A request to management to approve the funds for paying for the

Work. The funds are authorized when the Purchase Requisition is approved by the appropriate management level for the cost centre where the Work is being done.

Fit for Employment: The applicant is found able to perform the essential functions of the job.

Job: A finite, discernable unit of Work done by one contractor (vendor).

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practices and policies that contribute to the well-being of the Environment, Economy and Society to address the needs of Customers, Suppliers, Shareholders, Employees, Government, the General Public and the Communities in which we operate, without compromising the ability of future generations to meet their own needs.”

Project: A collection of one or more Jobs that are associated and together intended to result in a

finished structure.

“Site”: shall mean the location or locations of the work.

“Sub-contract” shall mean the contract in whatever form it may take (Including purchase orders)

which governs the relationship between contractor and sub-contractor or between sub-contractor and its sub-contractor.

“Sub-contractor” shall mean any person to whom the contractor contracts any portion of the work

or any person to whom a sub-contractor contracts any portion of the work.

Work: The service done.

2. CONTRACTOR SHE MANAGEMENT PROGRAM

Ontario Operations Contractor SHE Management Program is the alignment of the Contractor SHE

performance to Ontario Operations SHE principles and policies. This is to be achieved by a systematic process of managing SHE throughout the bidding and performance of work processes. This generally includes:

• Contractors will be required to pre-qualify prior to bidding for work at Ontario Operations.

• Once pre-qualified, contractors will be required to submit a SHE policy and program prior to job award and subsequently a detailed site specific plan before commencing any work.

• During work being performed the contractor and Vale will be expected to perform periodic monitoring and auditing appropriate to the scope and nature of the work performed.

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2.1 Contractor SHE Flowchart

SHE prequalification examined by Contract Administration

Job is Tendered

Executing the work in compliance with the Contractor SHE policy, program & procedures

On going monitoring of SHE performance to plan

SHE performance evaluation at job

completion

Successful Contractor submits safety, health and environment program for the job

Contractor Orientation & Training Contractor submit task specific SHE procedures

Master Bidders list developed by Contract Administration

Job Bidders list developed by Contract Administration & Project Team

If not acceptable don’t add to bidders list

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2.2 Contractor

Pre-qualification

Ontario Operations selects its contractors on their ability to manage Safety, Health and Environment in addition to satisfying other keys requirements.

Pre-qualification of contractors establishes their eligibility to be considered for selection and inclusion on specific contract bidders lists.

The objectives of the SHE pre-qualification of potential contractors and sub-contractors are:

• To determine and evaluate the SHE principles, policy, program of all contractors who apply for pre-qualification

• To use the information gathered to pre-qualify contractors that meet Vale’s standards for eligibility and remove those who don’t meet these standards.

The Contractor must complete a Contractor’s pre-qualification form (Appendix1) to be considered for inclusion on the bidders list

The pre-qualification process includes an ongoing review of activity to qualify or re-qualify competent contractor based on assessment of current performance information

2.3 Contractor SHE Policy Submission

The contractor will be required to submit their SHE Policy and Program to Ontario Operations Contract Administration for pre-qualification.

2.4 Contractor SHE Program

Subsequent to the tendering of the work and prior to the job award, the contractor will be required to submit a detailed SHE program for the job. Refer to Contractor Specific Safety Form (under Forms listed below) for guidance on the SHE program. The evaluation of the contractor safety program will be based on the

Ontario Operations Contractor Integrity Profile model as outlined below.

The integrity profile is a sequenced depiction of the process of how Contractors respond to their Safety program, hazards, accidents, incidents etc.

In dealing with an incident the consequences of the incident are increased along the sequence. It is most preferable to have the Contractor operating in the Prevent or Protect mode.

Contractors detailed SHE program for the job scoring less than 80% based on the integrity profile below will be requested to review and upgrade their program prior to proceeding with work. If a 80% score is still not achieved the contactor will be disqualified for the job.

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Ontario Operations Contractor Integrity Profile

# Element

Score

1 Prevent

:

Management systems or activities that provide the foundation to pro-actively control SHE aspects. Examples: Hazard Identification and Risk Assessment, Comprehensive safety, health and environment policy program, project plan & schedule, safety resources, project PHA, qualified supervision

50%

2 Protect:

Specific policies/procedures to protect against known potential hazards Examples: Fall arrest, lock & tag, confined space, PPE, overhead work, hoisting,

30%

3 Detect & Control:

Immediate activities to detect hazards and prevent an incident from occurring Examples: Inspection, spot job observations and temporary procedures.

15%

4 Respond & Recover:

Activities for injury treatment/site restoration plans after incident occurs

Examples: injury treatment, site restoration, emergency response, incident investigation

5%

2.5 Contractor Task Specific Procedures

The Contractor selected to perform work will be required to submit procedures on how to complete the job safely. Procedures are to be reviewed by the Site Contact Person with input from appropriate SHE personnel. Reference Task Specific Procedures (page 17) for guidance.

2.6 Contractor

Orientation & Training

Each contractor employee working on Vale Ontario Operations property must complete orientation and training depending on the location of the work. The following is a guideline (but not a comprehensive list) of the

requirements to work on Vale property:

Plant Surface Work Only

o Proof of WHMIS

o Proof of General Indoctrination o Site Specific at Plant

o For CCNR: Carbonyl Awareness Training

o For CCNR: Breathing Air Mask Training (Soucie Salo)

Mines Surface Work Only o Proof of WHMIS

o Proof of General Indoctrination o Site Specific at Mine

Mines Underground Construction (Civil, Mechanical, Electrical)

o Proof of WHMIS

o Proof of Underground Indoctrination o Proof of Mine Induction Program

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o Proof of Government Common Core (appropriate for type of work) o Site Specific at Mine

Mines Underground Drilling, Blasting or Mucking

o Proof of WHMIS

o Proof of Underground Indoctrination o Proof of Mine Induction Program

o Proof of Government Common Core (appropriate for type of work) o Site Specific at Mine

3. EXECUTION OF THE PROGRAM

The intent of this program is for Ontario Operations to hire only contractors with a track record with compliance to applicable Safety, Health and Environmental (SHE) laws and principles, as is evidenced by their performance (New contractors without a safety performance record will be pre-qualified on all elements). This program applies to all contractors and sub-contractors performing work on all Ontario Operation sites. The program also applies to large consulting firms with employees performing work on all Ontario Operation sites. Whether the contractor work is related to a large-scale project or a small job every contractor and their employees must work in compliance with this Contractor SHE Management program and all relevant regulatory requirements.

Contractors and Vale have specific accountabilities (refer to Section 3.2) for each of four different categories of contractor work;

a) For jobs which are underground work or surface maintenance work, and not surface construction work, and where the Regulations for Mines and Mining Plants apply;

b) For jobs which are surface construction work, where Vale is Constructor, and Regulations for Construction Projects apply;

c) For jobs which are surface construction work, where a contractor is Constructor, and Regulations for Construction Projects apply;

d) For environmental field work (consultants).

Despite these specific accountabilities, there are general accountabilities for both contractors and Vale, which apply to all three categories of contractor work.

3.1 General

Accountabilities

3.1.1 Contractor General Accountability

VALE Ontario Operations will hold the contractor accountable for the health and safety of all employees and the protection of the environment as may be affected by the contractor’s activities on Vale property. Every contractor and their sub-contractor(s) shall have Safety, Health & Environment Policy and Program elements to support their policy.

The contractor shall develop and maintain an SHE policy for the workplace that will include statements of: • Commitment to SHE (Principles and Policy)

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• Employee Accountability • Employee Training

3.1.1.1 Contractor Employees

It is expected that Contractors will:

• Hire and use employees that are qualified and competent in the job skills, work practices, and procedures necessary to safely perform their jobs.

• Provide personnel who are ‘fit’ to perform the work without risk to themselves or others.

• When required provide personnel that have the appropriate certification to do the work they are performing.

• Provide personnel that have the training required by legislation.

• Provide personnel who have received the contractor safety orientation information provided by NORCAT and Vale

• Document that contract personnel have received the required training.

• Provide personnel that work to safety standards as prescribed by the safety orientation, rules and job procedures.

• Report to Vale hazards of their work or hazards found during their work for which appropriate control measures do not exist.

• Report all contract employee injuries / occupational illnesses / incidents or conditions to Vale and any other relevant agencies within the required time frames.

• Organize any joint health and safety committee, where required by legislation (e.g. JHSC). Provide the necessary resources for such a committee and check that it is fulfilling its mandate.

3.1.1.2 SHE Coordinator

When specified by the scope of work, the contractor shall appoint a competent SHE coordinator who: • Is qualified to implement the SHE program due to his or her knowledge, training and experience • Is familiar with applicable legislation and the provisions of this contractor’s safety program

• Has knowledge of any potential or actual danger to safety, health or the environment in the workplace.

3.1.1.3 Supervisors Trained in SHE

All contractor supervisors shall be competent to enable them to implement the SHE program and meet their responsibilities under applicable legislation and the SHE program.

This competency is based on the following criteria: • Knowledge

• Experience • Qualification

3.1.1.4 Accountabilities for Reporting All Injuries and Illnesses

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procedures. The Contractor will follow up with a written report to Vale describing the accident / incident causes and corrective actions.

3.1.1.5 Accountabilities for Reporting Environmental Occurrences

The Contractor will report environmental occurrences to appropriate regulatory agencies and Vale according to site specific procedures. The Contractor will clean up spills and other releases according to contractual terms, regulatory requirements and site specific procedures as applicable. The

Contractor will follow up with a written report to Vale describing the accident / incident causes and corrective actions.

3.1.2 Vale’s General Accountability

3.1.2.1 Designated Contact Person Accountabilities

Vale will assign a designated contact person for every Contractor working on Vale property. This responsibility will lie with the Project Manager or another member of supervision or management. The minimum training for the designated contact person shall include an understanding of the Occupational Health & Safety Act and the Regulations for Mines and Mining Plants and if applicable, the Regulations for Construction Projects.

The designated contact person accountabilities include;

• Application of the Contractor SHE Management Program and OHSA requirements. • Set SHE expectations for the contractors.

• Conduct internal audits to determine SHE program and performance and implement corrective actions when necessary.

• Call to account for infractions of company SHE policies, standards, codes of practice and guidelines and implement corrective actions when necessary.

• Ensure environmental remediation is conducted appropriately where Vale is the owner of the materials spilled or released to the environment at any location. Ensure any spills on Vale property of materials owned by the contractor are reported to Vale and to any regulatory agencies as required by the regulations and cleaned up appropriately.

• Safety deliverables are included in the scope of projects.

• Create, track and report the number of contractor incidents, first aid cases, medical treatment and lost time injuries.

• Complete final safety performance evaluation.

• Communicate and address all concerns, infractions and sub-standard performance to the contractor management.

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3.2 Specific

Accountabilities

3.2.1 Jobs which are not surface Construction Projects (underground jobs,

maintenance jobs)

• Vale is an “employer” under the OHSA, as defined in the Act.

• The Regulations for Mines and Mining Plants apply for this type of work at Vale in almost all cases. • Vale must take a “hands-on” (duly diligent) approach to the employees of a contractor

• As an employer, Vale must make certain that the prescribed regulations for safety in the workplace have been complied with before work is undertaken by either employees or independent contractors. • As an employer, Vale’s duties under OHSA include:

o Duty to provide a safe workplace

o Duty to provide information and educate workers

o In situations where the contract does not require that the contractor provide supervision for its workers, Vale must plan for the competent supervision of work.

o Obligations respecting policy and programs o Duty to take every reasonable precaution

• Some fundamental concepts for Occupational Health and Safety due diligence for employers include: o Knowing workplace hazards

o Having a proper system to prevent the non-compliance with OHSA or its Regulations o Having a functioning safety system

o Ongoing communication and coordination of work o Pre-qualification and hiring processes:

Ensure that the contractor has an SH&E policy and detailed program Confirm that contractor employees have appropriate training

Enquire if any record of conviction under OHSA for contractor or supervisors Determine if proper level of supervision

Retain the right of approval of sub-contractors and replacement if necessary o Monitoring after hiring:

Confirm that contractor employees have appropriate training before work starts Inform contractor of foreseeable risks or hazards in the workplace before start of work Monitor contractor from time to time as work progresses, and advise contractor of

violations of safety, and remove contractor if necessary for such violations

• As the owner of some materials handled by Contractors, Vale and the Contractor are jointly liable under the Environmental Protection Act for cleanup of any spills of these materials caused by the Contractor. Vale must take a “hands-on” approach to ensuring spills are properly cleaned up. The Contact Person must have knowledge of the requirements of any applicable site-specific Spill Prevention and Contingency Plans.

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3.2.2 For jobs which are surface Construction Projects, and Vale is the

Constructor:

• The Regulations for Construction Projects apply.

• Vale must take a “hands-on” (duly diligent) approach to the employees of a contractor. • Some due diligence steps for Vale as Constructor:

o Appoint project managers who are trained and experienced in the responsibilities of OHSA and Regulations for Construction Projects

o Have sufficient “competent” supervisory people, as defined under OHSA

o Supervisors or the project manager should exercise full control over the sub-contractors o Have a safety policy and program to implement the policy

o File Notice of Project if applicable

o Have regular site meetings to organize the work and review safety, including sub-contractors, and keep minutes of the meetings

o Keep documentation of enforcement of compliance with policies, regulations and discipline. o Assess the requirement for any specialized training, and ensure sub-contractors and their

employees receive such training.

3.2.3 For jobs which are Construction Projects, and the contractor is the

Constructor:

• The Regulations for Construction Projects apply.

• Vale must take a “hands-off” approach to the employees of a contractor.

• Some practical steps for Vale, as owner, to take when retaining a contractor as Constructor include: o Pre-qualification and hiring processes:

Make reasonable enquiries to ensure that the Constructor has an H&S policy and detailed program

Make enquiries if any record of conviction under OHSA for Constructor or Constructor’s supervisors

Determine if Constructor has the proper level of “competent” supervision

Determine if Constructor has training program for employees and whether it will provide training to subcontractors

Determine if Constructor has practice of holding regular pre-job and site meetings with workers and if this is sufficient

Determine if Constructor has policy of termination of subcontractors not complying with OHSA or its Regulations, or rules or policies of the owner or constructor

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• To maintain the Contractor as Constructor, Vale must avoid:

o Vale project managers or coordinators having day-to-day involvement in the running of the project, o Holding weekly meetings with sub-contractors,

o Issuing daily work permits, o Scheduling work areas,

o Reviewing scopes of work or safety procedures with sub-contractors, o Controlling safety training of sub-contractors,

o Directing clean-up and resolving problems, o Coordinating schedules of sub-contractors.

3.2.4 For Environmental Field Work and Studies

• Depending on the nature of the work and/or the location of the work, the Regulations for Industrial Establishments may apply in place of, or in addition to the Regulations for Mines and Mining Plants. Each situation should be considered carefully based on the details of the work.

• Vale must take a “hands-off” approach to the employees of a contractor. If the field work is done jointly between Vale and consultant/contractor employees, this approach may be modified.

• Some practical steps for Vale to take when retaining a consultant or contractor for environmental field work and studies:

o Pre-qualification and hiring processes:

Make reasonable enquiries to ensure that the Contractor/Consultant has an H&S policy and detailed program

Make enquiries if any record of conviction under OHSA

Determine if Contractor/Consultant has the proper level of “competent” supervision Determine if Contractor/Consultant has training program for employees and whether it will

provide training to subcontractors

Determine if Contractor/Consultant has practice of holding regular pre-job and site meetings with workers and if this is sufficient

Determine if Contractor/Consultant has policy of termination of subcontractors not complying with OHSA or its Regulations, or applicable rules or policies

• Vale generally must avoid:

o Vale project managers or coordinators having day-to-day involvement in the running of the project, o Holding weekly meetings with sub-contractors,

o Issuing daily work permits, o Scheduling work areas,

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o Reviewing scopes of work or safety procedures with sub-contractors, o Controlling safety training of sub-contractors,

o Directing clean-up and resolving problems, o Coordinating schedules of sub-contractors.

3.3 Monitoring & Auditing

The contractor shall, as specified in the safety, health and environment plan, conduct periodic inspections and audits appropriate to the scope and nature of the work and report findings to Vale. In addition, Vale’s Ontario Operations may elect to inspect, audit and monitor the contractors work site to assess the effectiveness of the contractor SHE program. See Contractor Audit Template listed under forms.

Contractor SHE requirements and performance should be compared to targets as set out in the Contractor SHE program and procedures.

On a regular basis, contractors working on site should be visited by the designated contact person or a designate, and more frequently if the nature of the work warrants. SHE concerns, compliance to PPE standards, infractions and sub-standard equipment and work practices should be reviewed, acted upon and communicated.

The designated contact person serves in an oversight role for these activities. This oversight role does not involve direct supervision, instruction, discipline or management of a contractor’s personnel but rather the expected compliance to their SHE plan. Inspections and audits should also examine the co-ordination of the contractors’ activities, in relation to the plant’s operation and schedules agreed upon with site operating supervision, whenever the contractors’ activities may affect production.

Given the importance of contractor SHE management a “Zero Acceptance” for non-compliance must be enforced whenever an SHE non-conformance occurs. It is important that responsibility for taking appropriate corrective and/or disciplinary action with a contract employee rests with the contractor supervisor or manager.

3.4 Post

Job

Performance Evaluation

After completion of every job, the designated contact person must evaluate the Contractor performance using the appropriate form. The completed form and other pertinent information are to be submitted to Contract

Administration for future pre-qualification. The link to this form can be found below.

The post job evaluation should assess the following items:

• Demonstrated commitment to safety, health and environment • The contractor's accident statistics and accident reports • The level of co-operation with all workplace parties • The results of inspections and job observations

• Any orders or comments from the government inspectors • Assessments from the worker representatives or the committee

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4. TASK

SPECIFIC

PROCEDURES

The following list of items should be considered when developing task specific procedure. This list is not

comprehensive but implies a guideline.

• Significant task-specific health and safety risks and hazards;

• Significant task-specific environmental aspects and impacts;

• Relevant legal and other requirements; • SHE rules associated with the following:

• Inspecting, using and maintaining personal protective equipment

• Driving on property (speed limit, use of seat belts, right-of-way, traffic patterns)

• Using cellular telephones • Housekeeping

• Training and qualifications

• Security (sign-in and out); access; personal and vehicle passes

• Work permits,

• Safe work practices for confined space entry and rescue; lockout/tag out; hot work (burning, welding and cutting); excavations/buried lines; breaking lines; working at heights; fall protection, barricading or roping off, guarding and any other safe work practices as applicable

• Smoking • Drugs • Alcohol

• Procedures for reporting accidents, incidents and injuries

• Reporting spills and leaks, including cleanup and disposition of contaminated material

• Reporting hazards (including bringing

materials/chemicals on-site, availability of material safety data sheets)

• Reporting to the SHE representative (method, alternate if unavailable, requirements) • Emergency alarm activation and response • Fire alarm activation and response

• Review of procedures prior to infrequent/hazardous work

• Work performed outside of normal working hours • Working alone

• Locations of fire and emergency protective

equipment (e.g. fire extinguishers, alarms, emergency eyewash and shower stations, et cetera)

• Standard for pipeline identification • Asbestos management

• Waste management (e.g. recycling) and disposal • House keeping

• Guidelines for using (or not) facility equipment (mobile equipment, overhead cranes and lifting devices, fire extinguishers, et cetera)

• Requirements for first aid; responsibility for obtaining external emergency response (i.e. fire, police, ambulance/hospital)

• Compressed gas cylinders • Flammables combustibles • Emergency preparedness

• Use of personal protective equipment • Portable tools and equipment • Other (Specify)

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5. FORMS

• PRE-QUALIFICATION PROFILE & QUESTIONNAIRE

• CONTRACTOR SPECIFIC SAFETY FORM

• EVALUATION OF CONTRACTOR SHE PERFORMANCE

• SHE AUDIT TEMPLATE

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REVISION CONTROL INFORMATION: Next Revision Date 2013

Revision

# DATE

NATURE OF CHANGE

PAGE INSERTED, REPLACED, REVISED OR CANCELLED APPROVED BY DOCUMENT OWNER Update/ Changed

-Changed all Vale Inco to Vale

-Formatted to match Controlled Document format (including applicable forms)

-All Vale Inco references, to Vale

* Includes updating of format & name change to all forms and related documents to the program. -Changed HSE to SHE

-3.1.1.4 Accountabilities for Reporting All Injuries and ----Incidents to ‘and Illnesses’.

Added -Health and Environment to areas which were missing these references

-3.1.1.5 Accountabilities for Reporting Envirn. Occurrences

-3.2.4 For Environmental Field Work & Studies

R1 Novermber 2010

Deleted -1.3 Ontario Operations Seven Safety Principles

Manager of Safety, Ontario Operations