2018

Health Safety & Environmental

Management System

SAFETY DEPARTMENT
CORPORATE OFFICES
P.O. BOX # 46071,
FAHAHEEL-64011
KUWAIT
TEL- 23919220, 23916767
FAX- 23914666

“a company committed to safety

excellence”

Paper copies are uncontrolled. El Eman Construction Est. (ELEMAN)

No reproduction in any form without the written permission of the copyright owner.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 2 of 64

Table of Contents
INTRODUCTION ..........................................................................................................................................6
SCOPE.........................................................................................................................................................6
TERMS AND DEFINITIONS ............................................................................................................................6
HSEMS ELEMENTS .......................................................................................................................................8
1.0 GENERAL REQUIREMENTS .................................................................................................................8
1.1 Leadership and Commitment............................................................................................................................ 8
1.1.1 Management Commitment and Leadership .....................................................................................................8
1.1.2 Management Representatives ..........................................................................................................................9
1.1.3 Employee Participation .....................................................................................................................................9
1.1.4 Commitment Statement ...................................................................................................................................9
2.0 POLICY ............................................................................................................................................10
2.1 Procedure ....................................................................................................................................................... 10
2.2 HSE Policy Statement...................................................................................................................................... 11
2.3 Environmental Policy Statement .................................................................................................................... 12
2.4 Drug and Alcohol Policy Statement................................................................................................................. 13
3.0 PLANNING ......................................................................................................................................14
3.1 Hazard Identification ...................................................................................................................................... 15
3.1.1 Defining Hazards .............................................................................................................................................15
3.1.2 Identifying Hazards .........................................................................................................................................16
3.1.3 Continued Hazard Identification .....................................................................................................................16
3.1.4 Recording Hazard Identification Data.............................................................................................................16
3.1.5 Certification of Hazard Assessment ................................................................................................................17
3.1.6 Review of Hazard Assessment ........................................................................................................................17
3.2 Risk Assessment (Refer to Procedure No. - ELEMAN/HSE/PR/GE/03) ............................................................. 17
3.2.1 Risk Assessment Procedure .............................................................................................................................17
3.2.2 Risk Assessment Matrix ..................................................................................................................................17
3.3 Risk Control .................................................................................................................................................... 18
3.3.1 Hierarchy of Controls ......................................................................................................................................18
3.3.2 Risk Controls ...................................................................................................................................................19
3.3.3 Emergency Control of Hazards........................................................................................................................19
3.3.4 Job Safety Analysis (JSA) .................................................................................................................................19
3.3.5 Field Level Risk Assessment (FLRA) .................................................................................................................19
3.3.6 PPE Assessment & Matrix ...............................................................................................................................19
3.3.7 Site Specific HSE Plan (SSHP) ...........................................................................................................................19
3.4 Legal and Other Requirements ....................................................................................................................... 20
3.4.1 Legal Requirements ........................................................................................................................................20
3.4.2 Other Requirements ........................................................................................................................................20
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 3 of 64

3.4.3 Means of Tracking Requirements ...................................................................................................................21

3.4.4 Review of Requirements .................................................................................................................................21
3.4.5 El Eman Construction Est. (ELEMAN) Safety and Health Compliance Matrix .................................................22
3.5 Written Safety and Health Goals, Objectives and Programs ........................................................................... 24
3.5.1 Safety and Health Goals..................................................................................................................................24
3.5.2 Objectives and Safety Programs .....................................................................................................................25
3.5.3 Written Annual Goals for 2015 .......................................................................................................................25
4.0 IMPLEMENTATION & OPERATION ...................................................................................................26
4.1 Overview ........................................................................................................................................................ 26
4.2 Structure and Assignment of Responsibilities ................................................................................................. 26
4.2.1 Health, Safety & Environmental Management System Organization Chart ...................................................26
4.2.2 Documentation and Communication ..............................................................................................................28
4.3 Training, Awareness and Competency (Refer to Procedure No. - ELEMAN/HSE/PR/GE/04 & 05) ................... 29
4.3.1 HSE Competency Assurance Process ...............................................................................................................29
4.3.2 Identification of Training and Competency Needs ..........................................................................................30
4.3.3 Training Records .............................................................................................................................................30
4.3.4 Delivery of Induction, Transfer & Refresher Training ......................................................................................30
4.3.5 Training Documentation .................................................................................................................................30
4.3.6 Supervisor Safety Management Training........................................................................................................30
4.3.7 El Eman Construction Est. (ELEMAN) Training Matrix ....................................................................................31
4.3.8 Short Service Employee Program ....................................................................................................................31
4.4 Consultation and Communication .................................................................................................................. 32
4.4.1 Open Door Policy.............................................................................................................................................32
4.4.2 Behavior Based Safety Program (BBS) ............................................................................................................33
4.4.3 Incident Notice Form .......................................................................................................................................33
4.4.4 Weekly Safety Meetings .................................................................................................................................33
4.5 Document and Data Control ........................................................................................................................... 33
4.5.1 Document Format ...........................................................................................................................................34
4.5.2 Reviewing ........................................................................................................................................................34
4.5.3 Control ............................................................................................................................................................34
4.5.4 Document Distribution ....................................................................................................................................34
4.6 Operational Control ........................................................................................................................................ 36
4.6.1 Compliance with Legal and Other Requirements ............................................................................................36
4.6.2 Identified Hazards and Risks ...........................................................................................................................36
4.6.3 Management of Change (MOC) (Refer to Company Procedure # ELEMAN/HSE/PR/GE/08) ..........................36
4.6.4 Purchase of Goods and Services......................................................................................................................37
4.6.5 Systems to Control Access or Exiting Customer's Premises .............................................................................37
4.6.6 Background Checks Prior to Issuing Identification Cards ................................................................................37
4.6.7 Company Employee Identification System ......................................................................................................37
4.6.8 Hazardous Materials .......................................................................................................................................37
4.6.9 Control of Hazardous Materials for Client Locations ......................................................................................38
4.6.10 Reporting of Hazardous Conditions, Security Incidents or Injuries .................................................................38
4.6.11 Fire Fighting - Incipient Policy .........................................................................................................................38
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 4 of 64

4.6.12 Disciplinary System .........................................................................................................................................38

4.6.13 Impairment .....................................................................................................................................................39
4.6.14 General Safety Standards and Guidelines .......................................................................................................39
4.6.15 Facility Equipment and Working Conditions ...................................................................................................41
4.6.16 Lone Workers Policy ........................................................................................................................................41
4.6.17 Lifting and Handling Loads .............................................................................................................................42
4.6.18 Fatigue Management .....................................................................................................................................42
4.6.19 Safe Journey Management (SJM) Policy .........................................................................................................43
4.6.20 Driving Safety ..................................................................................................................................................43
4.6.21 Vehicle Requirements .....................................................................................................................................45
4.6.22 PPE ..................................................................................................................................................................46
4.6.23 Preventative Maintenance Program for Tools and Equipment.......................................................................46
4.7 Emergency Preparedness................................................................................................................................ 49
4.7.1 Preparedness Requirements ...........................................................................................................................49
5.0 CHECKING & CORRECTIVE ACTIONS .................................................................................................51
5.1 Key Performance Indicator Measuring and Monitoring .................................................................................. 51
5.1.1 Health and Safety Key Performance Indicators (KPI) ......................................................................................51
5.1.2 Monitoring ......................................................................................................................................................52
5.2 Incidents, Reporting, Non-Conformance and Corrective Actions (Refer to Procedure No. -
ELEMAN/HSE/PR/GE/12) ........................................................................................................................................... 52
5.2.1 Reporting Policy ..............................................................................................................................................53
5.2.2 Investigations of Incidents & Non-conformances ...........................................................................................53
5.2.3 Incident Reporting Matrix ...............................................................................................................................53
5.2.4 Incident Review Team and Incident Investigation Report...............................................................................54
5.2.5 Field Incident Report Form ..............................................................................................................................54
5.2.6 Incident Notice Form .......................................................................................................................................54
5.2.7 Corrective Actions ...........................................................................................................................................54
5.2.8 Accompanying Employees to Medical Treatment...........................................................................................55
5.2.9 Incident Classifications ....................................................................................................................................55
5.2.10 Injury Classifications .......................................................................................................................................55
5.2.11 Return to Work - Light/Restricted Duty Procedure .........................................................................................56
5.3 Records and Records Management ................................................................................................................ 59
5.3.1 Access to Medical Records ..............................................................................................................................59
5.3.2 Records Filing and Accessibility .......................................................................................................................60
5.3.3 Key Records Retention ....................................................................................................................................60
5.4 Inspections ..................................................................................................................................................... 61
5.4.1 Formal Annual Inspection ...............................................................................................................................61
5.4.2 Routine Site Inspection....................................................................................................................................61
5.4.3 Conducting Inspection.....................................................................................................................................61
5.4.4 Corrective and Preventive Actions ..................................................................................................................62
6.0 MANAGEMENT REVIEW ..................................................................................................................63
6.1.1 Safety Management System Review...............................................................................................................63
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 5 of 64

6.1.2 Management Meetings ..................................................................................................................................63

SPECIFIC SAFETY PROGRAMS .....................................................................................................................64
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 6 of 64

Introduction

The El Eman Construction Est. (ELEMAN) Health, Safety & Management System has been developed to provide a
systematic approach to safety and health in order to have an incident free culture of safety.

Scope

This HSEM Management System applies to all operations conducted by El Eman Construction Est. (ELEMAN). Any new
acquisition, project, joint venture or contract controlled by El Eman Construction Est. (ELEMAN) shall follow its
requirements.

Terms and Definitions

Audit — the systematic and documented process for obtaining audit evidence and evaluating it objectively to determine
the extent to which the audit criteria are fulfilled.

Audit program — a set of one or more audits planned for a specific time frame and directed towards a specific purpose.
Note: An audit program includes all activities necessary for planning, organizing, and conducting the audits.

Competence — demonstrated ability to apply Health, Safety & Environmental Management System knowledge and skills.

Continual improvement — the process of enhancing the Health, Safety & Environmental Management System to achieve
ongoing improvement in overall safety management performance.

Contractor — an organization or individual providing services to another organization in accordance with agreed-upon
specifications, terms, and conditions.

Document — a medium containing information related to the safety and health management system.

Employee — a person employed by the organization or a person under the day-to-day control of the organization.

Employee representative — a non-managerial employee who is:

(a) A representative of other employees according to the requirements of law or collective agreements; or

(b) Selected by non-managerial employees for other reasons.

Ergonomics — integrated knowledge derived from the social and technical sciences, used to match jobs, systems,
products, and environments with the physical and mental attributes of the people involved.

Hazard — a source of potential harm to an employee.

Incident — an occurrence, arising in the course of work, that could result in an injury or illness (includes near misses).
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 7 of 64

Legal requirements — requirements of applicable OHS federal, provincial/territorial, and municipal laws, regulations, and
bylaws, and where applicable, provisions of the organization's collective agreements that relate to health and safety.

Organization — a company, operation, undertaking, establishment, enterprise, institution, or association, or a part or

combination thereof, that has its own management. An organization may be incorporated or unincorporated, public or
private.

Other requirements — other occupational health and safety provisions to which the organization subscribes.

Procedure — a documented method to carry out an activity.

Process — a set of interrelated or interacting activities, that transforms inputs into outputs.

Record — a document that states results achieved or provides evidence of activities performed.

Risk — a combination of the likelihood of the occurrence of a hazardous event and the severity of harm caused by the
event.

Safety health and safety management system (HSEMS) — part of the overall management of the organization that
addresses occupational, health and safety hazards and risks associated with its activities.

System — a set of interrelated or interacting elements.

Workplace parties — managers (including supervisors), employees, and employee representatives.

Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 8 of 64

HSEMS Elements

The following is a general listing and description of the El Eman Construction Est. (ELEMAN) Health, Safety &
Environmental Management System(HSEMS) elements and their application.

1.0 General Requirements

1.1 Leadership and Commitment

1.1.1 Management Commitment and Leadership

Senior management of El Eman Construction Est. (ELEMAN) shall provide leadership for safety and health activities and
assume overall responsibility for the HSEMS. This responsibility includes:

• Establishing, actively promoting, and maintaining the HSEMS;

• Providing appropriate financial, human, and organizational resources to plan, implement, check, review, and
correct the HSEMS;
• Defining roles, assigning responsibilities, establishing accountability, and delegating authority to implement an
effective HSEMS;
• Establishing and implementing an safety and health policy and measurable objectives;
• Reviewing the organization's HSEMS at planned intervals;
• Ensuring that employees and employee representatives are consulted; and
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 9 of 64

• Encouraging active participation on the part of employees and contractors in the establishment and
maintenance of the HSEMS.

1.1.2 Management Representatives

The El Eman Construction Est. (ELEMAN) senior management shall, if warranted due to company workforce size,
designate one or more representatives of management who, irrespective of other responsibilities, shall have defined
roles, responsibilities and authority for ensuring that this HSEMS is established, maintained and reviewed to support:

• Effective processes to identify and eliminate or control work-related hazards and risks;
• Reporting on the performance of the HSEMS to senior management, employees, and employee representatives
(if present) as appropriate for review and as the basis for improvement.

1.1.3 Employee Participation

Employee participation is an essential aspect of the HSEMS. El Eman Construction Est. (ELEMAN) shall provide employees
and employee representatives, if warranted due to company workforce size, with time and resources to participate
effectively in the development of the safety and health policy and in the process of HSEMS planning, implementation,
training, evaluation, and corrective action; and encourage employee participation by providing mechanisms that:

• Support employee participation, such as identifying and removing barriers to participation;

• Establish workplace health and safety committees or employee representatives where required by legislation
and, where applicable, collective agreements or other requirements; and
• Ensure that employees and employee representatives are trained in, and consulted on, all aspects of HSEMS
associated with their work.

1.1.4 Commitment Statement

The El Eman Construction Est. (ELEMAN) Health, Safety & Environmental Management System (HSEMS) is driven by
leadership and commitment from senior management and its readiness to provide resources for HSE matters. El Eman
Construction Est. (ELEMAN) is committed to providing a productive, safe and healthy work environment for our
employees, contractors, clients, customers and visitors.

Our commitments are communicated to all employees, contractors and suppliers and include:

• To instill a corporate culture where harm to our staff through work is totally unacceptable;
• To be proactive in assessing health, safety and environmental hazards for new business, new and existing work
systems, practices and equipment;
• To encourage team problem solving at all levels of the organization to implement work practices that continually
improve safety, environmental standards and productivity;
• To report and investigate incidents and implement systems and practices that prevent reoccurrence;
• To ensure compliance with legal requirements and industry standards;
• To train managers and employees to competently perform work described in safe work procedures;
• To provide information to all employees, contractors and customers that inform them of health safety and
environmental issues relevant to El Eman Construction Est. (ELEMAN) operations;
• To ensure products are safe and without adverse environmental impact.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 10 of 64

• All El Eman Construction Est. (ELEMAN) staff have a responsibility for implementing this Health, Safety &
Environmental Management System by striving to achieve a zero tolerance towards hazards, incidents and
injuries.
• We continuously improve safety and health management by setting objectives, plans and performance
measures and regularly reviewing progress against the targets set.
• We involve our staff in safety and health management through training and by contributing in identifying,
assessing and controlling hazards.

2.0 Policy

OBJECTIVE
The objective of the El Eman Construction Est. (ELEMAN) HSEM Policy is to state its commitments to provide safe and
healthy working conditions. It outlines the steps that are taken to meet these commitments and provides the framework
for the El Eman Construction Est. (ELEMAN) HSEM Management System.

RESPONSIBILITIES

Corporate Management
• Adopts the El Eman Construction Est. (ELEMAN) HSE Policy and all legal requirements;
• Requires that the policy be distributed to all operations for display;
• Supports the implementation of the policy throughout all operations.

Managers and Supervisors

• Discusses the policy during induction orientation;
• Communicates the requirements of the policy to all employees through safety & tailgate meetings;
• Ensures the posted policy is current and easily visible.

All Employees
• Comply with the requirements of the policy and support implementation of the policy.

2.1 Procedure
In consultation with employees and employee representatives, El Eman Construction Est. (ELEMAN) shall establish and
maintain the safety and health policy and shall ensure that the policy:

• Is appropriate to the nature, scale, and safety and health hazards and risks associated with El Eman Construction
Est. (ELEMAN) activities;
• Includes a commitment to comply with applicable safety and health legal requirements and other requirements;
• Includes a commitment to protect employees and to ensure continual improvement;
• Provides the framework for setting and reviewing safety and health objectives and targets;
• Is documented, implemented, and maintained;
• Is posted and communicated to all employees;
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 11 of 64

• Is available to external interested parties, as appropriate;

• Is discussed during safety meetings on an as-needed basis and is included in all site specific HSE plans which are
received by employees; and
• Every year the policy is reviewed for relevance and appropriateness to our company and amended as
appropriate and disseminated again.

2.2 HSE Policy Statement

We are committed to comply with all applicable safety, health and environmental legal requirements. We are committed
to our guiding principles which include ensuring that Health Safety and Environment is first – never compromise on the
health & safety of our customers and our people and to manage responsibly the impact that our business has on the
environment. The following points summarize our employee’s commitments to Health and Safety:
• Comply with HSE regulations and related El Eman Construction Est. (ELEMAN) policy and procedures.
• Use all required personal protective equipment where indicated.
• Decline to operate any machinery or equipment without proper instruction regarding safety and general
operation.
• All employees shall report unsafe conditions and/or hazards to their supervisors promptly.
• Follow all El Eman Construction Est. (ELEMAN) HSE Procedures and Practices.
• Promptly report all injuries/incidents and work related diseases and actively participate in the Return to Work
process in accordance with our Return to Work Policy.
• Attend all required health and safety training.
• Follow safe work instructions and assist in prevention.
All El Eman Construction Est. (ELEMAN) Managers and Supervisors are committed to take ownership of their areas of
responsibility by ensuring that the following important activities occur:
• Accept direct responsibility and accountability for all matters relating to HSE for the employees and/or
contractors they supervise directly and/or indirectly.
• Deal promptly with employees’ Health and Safety concerns and advise employees of actual and potential
hazards that are known by the manager or supervisor.
• Maintain and ensure transfer of knowledge of all duties and obligations under all relevant legislation, client
requirements and El Eman Construction Est. (ELEMAN) policies and procedures.
• Ensure that employees use Personal Protective Equipment as prescribed in addition to following all safety
procedure and practices.
• Provide appropriate training in use of equipment, safe work practices and procedures and handling of hazardous
materials.
• Ensure that all contractors, suppliers, vendors and other visitors adhere to all El Eman Construction Est.
(ELEMAN) policies and procedures.
• Investigate accidents/incidents and perform workplace inspections.
• Review any accident investigation and facilitate the corresponding corrective action plan.
• Assist any injured employee to the fullest possible extent including facilitating the Return to Work process in
accordance to our Corporate Return to Work policy.
• Continue to improve our Health, Safety & Environmental Management System and operational standards in all
sites.
• Take every other reasonable precaution to protect employees.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 12 of 64

• Implement and enforce Health and Safety rules, regulations, policies, procedures and prescribed instructions.

This policy is to be posted in all El Eman Construction Est. (ELEMAN) facilities by the site supervisor.

2.3 Environmental Policy Statement

El Eman Construction Est. (ELEMAN) recognizes that environmental concerns are of critical importance. El Eman
Construction Est. (ELEMAN) encourages its employees to join with the company in full acceptance of and compliance with
this policy. We will create procedures that fully comply with federal, state and local regulations. We will provide
adequate training to our employees to ensure our workers are aware of these procedures and are capable of following
them.

Protection of the Environment

We will employ practical measures to protect the environment. We will conserve and protect the water, air, and land
resources we use. We will strive to eliminate any releases to land, air or water that may harm human health or the
environment. Continuous improvement in our environmental performance will be a principal objective.

Waste Management Policy Statement

We will work to prevent waste and pollution at the source whenever possible. New facilities and improvements of
existing operations will use processes designed to minimize the environmental effects of our operations and will
incorporate functional pollution control equipment. (Refer to Company’s Waste Management Procedure)

Recycling and Waste Disposal

We will support recycling programs where practical and will use environmentally safe treatment and disposal practices
for waste that is not eliminated at the source or recycled. (Refer to Company’s Waste Management Procedure)

Compliance
We will manage existing facilities so that we meet or exceed legal requirements. We will implement programs and
procedures to satisfy compliance. We will conduct compliance audits and monitor procedures and practices to evaluate
our performance.

Disclosure
We will inform our employees of our progress in environmental issues. We will cooperate with the authorities and
regulatory agencies in responding to inquiries. We will encourage our employees to report to the Company conditions
that they reasonably believe could be harmful to the environment or pose health or safety hazards so the Company can
initiate prompt corrective actions.

Commitment
Management will consider the environmental and cultural implications of its decisions.

This policy is to be posted in all El Eman Construction Est. (ELEMAN) facilities by the site supervisor.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 13 of 64

2.4 Drug and Alcohol Policy Statement

Any employee or contractor on duty or on company property who possesses, sells, receives, is impaired or is determined
to have measurable levels of any alcohol or illegal drug in their blood or urine (no matter the amount), post drug/alcohol
screen, will be subject to immediate disciplinary action or contract dismissal.

Any employee or contractor involved in a job related incident while on duty or involving company equipment will be
subject to a post-incident drug/alcohol screen.

If an employee or contractor returns to work following an absence of more than 90 days a return to work screening shall
occur. Follow up drug screening shall be applied when appropriate as determined by management.

We reserve the right to conduct random drug and alcohol screenings on employees and contractors who perform safety-
sensitive functions, such as driving company property or entering any worksite. Additionally, we also reserve the right to
conduct unannounced random drug and alcohol screening on employees or contractors entering any worksite. We will
require an employee or contractor to submit to a drug/alcohol screen if we have reasonable suspicion to believe that
he/she has violated the prohibitions concerning alcohol and/or controlled substances based on observations concerning
the appearance, behavior, speech or body odors of that person.

Contractors or employees maintaining or using prescribed medications shall report the circumstances and effects to their
supervisor. Some types of medications could have undesirable effects, and these can create a safety risk and endanger
other contractors.

Periodically, unannounced inspections will be made of persons entering or leaving company work sites by authorized
company representatives. Entry onto company or client property is deemed to have provided consent to an inspection of
a person, locker, vehicle, or any other personal effects.

Any refusals to submit to a drug/alcohol screen will be treated as a positive test, resulting in immediate contract dismissal
or disciplinary action, up to and employment termination. The contractor or employee refusing to submit to the test will
be asked to sign a refusal document. If they refuse to sign the document, it will be noted and kept on file.

Drug and alcohol screening will be performed by an approved and qualified medical clinic with a medical review officer
authorized to perform the tests. All results are treated with confidentiality.

If another contractor or employee comes to management with concern regarding another contractor or employee in
reference to alcohol or substance abuse, we will treat that with discretion and confidentiality. We will pursue
investigation and decide accordingly whether a drug and or alcohol screen is the appropriate step to take.

All contractors and employees are subject to the policies explained above.

This policy is to be posted in all El Eman Construction Est. (ELEMAN) facilities by the site supervisor.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 14 of 64

3.0 Planning

OBJECTIVES
• To identify, assess, record and control risks in the workplace for routine and non-routine activities while ensuring
employees are involved during risk management processes;
• To eliminate, as far as is practicable, the risk of human injury, illness or damage to property;
• To promote planning as a means of achieving continuous improvement in our safety and health performance by
utilizing risk management procedures when establishing our annual safety and health objectives.

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager

• Introduces planning and risk management procedures and assists site managers with implementation;
• Determines risk levels for identified hazards and continually reviews legal and other requirements;
• Utilizes risk management procedure results when establishing El Eman Construction Est. (ELEMAN) annual safety
and health objectives.

Managers and Supervisors

Implements planning and risk management procedures and ensures employees are involved.

Employees
Provide input to risk identification and assessment and follow risk control procedures.
HSE PLANNING PROCESS OVERVIEW
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 15 of 64

3.1 Hazard Identification

OBJECTIVES
• To provide guidelines for identifying workplace hazards;
• To ensure the potential hazards of new processes and materials are identified before they are introduced into
the workplace;
• To identify the jobs/tasks which require risk assessment.

RESPONSIBILITIES
El Eman Construction Est. (ELEMAN) Safety Manager, site managers, supervisors and employees as identified specific
reference procedures and safety programs.

HAZARD IDENTIFICATION PROCEDURE

El Eman Construction Est. (ELEMAN) operations personnel notify the El Eman Construction Est. (ELEMAN) Safety Manager
if a new project is to begin. The El Eman Construction Est. (ELEMAN) Safety Manager then conducts a baseline worksite
hazard assessment which identifies the various tasks that are to be performed and the accompanying identified hazards.
Inputs into the baseline hazard identification include, but are not limited to:

• Scope of work
• Legal and other requirements
• Previous incidents and non-conformances
• Sources of energy, contaminants and other environmental conditions that can cause injury
• Walk through of work environment

3.1.1 Defining Hazards

A hazard is anything with the potential to harm life, health or property. Classifications of workplace hazards are divided
into six groups:

• Physical hazards such as noise, electricity, heat and cold

• Chemical hazards such as toxic gases, noxious fumes and corrosive liquids
• Ergonomic hazards such as the height of a workbench, the shape of a vehicle seat
• Radiation hazards, for example, from x-ray machines, high powered lasers, radioactive materials
• Biological hazards such as syringes containing potentially infected blood, etc.
Hazards identifications (as examples) are to include:
• Working Alone
• Thermal Exposure
• Isolation of Energy
• Hearing Protection
• Blood borne Pathogens
• Confined Spaces
• Driving
• General Safety Precautions
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 16 of 64

3.1.2 Identifying Hazards

A complete inspection of all work site tasks will be carried out by the Safety Manager in conjunction with employees. This
will develop an inventory of all of the tasks conducted throughout the work site. Examples of types of tasks: grinding
metal samples; transporting material from one area to another; decanting and mixing paints and solvents; operating
machinery such as cranes, hoists and fork lift trucks; undertaking repair work inside confined spaces (such as holding
tanks); undertaking cleaning and housekeeping work or spraying chemicals.

Additional areas for hazard identification include:

• Activities of all persons having access to the workplace including contractors and visitors.
• Infrastructure, equipment and materials at the workplace
• Changes or proposed changes in El Eman Construction Est. (ELEMAN), its activities or materials
• Modifications to the HSEMS including temporary changes and their impacts on operations, processes and
activities.
• The design of work areas, processes, installations, machinery, operating procedures including their adaption to
staff capabilities.

3.1.3 Continued Hazard Identification

At existing locations employees shall be continually involved in the identification of hazards. Unidentified hazards are to
be reported immediately and assessed for risk. Additional sources for ongoing hazard identification shall include:

Routine Activities

• Job Hazard Analyses

• Field Level Risk Assessments
• Ergonomic assessments
• Industrial hygiene surveys
• Workplace Inspections
• Purchasing and procuring
• Job observations
• Audits
• Document review
Non-routine Activities

• Accident/incident investigations
• Following emergency situations
It is also necessary to consider future tasks or situations that involve a change to the existing premises or process, or
those which are non-routine.

3.1.4 Recording Hazard Identification Data

Once gathered, the hazard identification data will be recorded by the Safety Manager on the Worksite Hazard
Assessment form. It shall be dated and signed.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 17 of 64

3.1.5 Certification of Hazard Assessment

The El Eman Construction Est. (ELEMAN) Safety Manager signs the certification portion of Worksite Hazard Assessment
Form and includes it within the site specific HSE plan.

3.1.6 Review of Hazard Assessment

Hazard assessments are formally reviewed annually.

3.2 Risk Assessment (Refer to Procedure No. - ELEMAN/HSE/PR/GE/03)

OBJECTIVES
• To assess the risk posed by each identified hazard
• To prioritize the risks so recommended risk controls can be assigned

RESPONSIBILITIES
El Eman Construction Est. (ELEMAN) Safety Manager, site managers, supervisors and employees as identified specific
reference procedures and safety programs.

3.2.1 Risk Assessment Procedure

Each identified hazard is assessed for risk based on potential consequences of effecting injury to people, damage to
assets, the environment or reputation of El Eman Construction Est. (ELEMAN). The frequency of risk exposure is then
considered.

Following risk assessment steps each risk assessed becomes classified as low, medium or high in accordance with the El
Eman Construction Est. (ELEMAN) Risk Assessment Matrix shown below.

3.2.2 Risk Assessment Matrix

The risk level of the hazard is recorded with the associated task on the worksite hazard assessment portion within the site
specific HSE plan for the job site.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 18 of 64

RISK ASSESSMENT MATRIX

3.3 Risk Control

OBJECTIVES
• To provide guidelines to control identified and assessed risks;
• To emphasize the importance of understanding the hierarchy of controls for the effective elimination of
identified risks within our workplaces.

RESPONSIBILITIES
El Eman Construction Est. (ELEMAN) Safety Manager, site managers, supervisors and employees as identified specific
reference procedures and safety programs.

3.3.1 Hierarchy of Controls

El Eman Construction Est. (ELEMAN) shall use the following priorities when determining controls to identified hazards:

• Elimination
• Substitution
• Engineering controls
• Signage/Warning and or administrative controls
• Personal Protective Equipment
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 19 of 64

3.3.2 Risk Controls

Risk assessed hazards are compiled with risk control methods including engineering or administrative controls and PPE
required into the Worksite Hazard Assessment of the site specific HSE plan. No work will begin before the worksite
hazard assessment is completed. Additionally, no risk assessed as High (Intolerable) shall be performed.

3.3.3 Emergency Control of Hazards

Only those employees competent in correcting emergency controls of hazards may be exposed to the hazard and only
the minimum number of competent employees may be exposed during hazard emergency control. An example is a gas
leak in a building. Only those competent personnel with training on fire safety, gas supply shut off and other related
controls will attempt to resolve the emergency control of a hazard. El Eman Construction Est. (ELEMAN) will make every
possible effort to control the hazard or under the supervision of client emergency response personnel in every
emergency.

3.3.4 Job Safety Analysis (JSA)

For those jobs with the highest injury or illness rates, jobs that are new to our operation, jobs that have undergone major
changes in processes and procedures or jobs complex enough to require written instructions will have a Job Safety
Analysis performed. JSAs are to be maintained in the Safety Manager’s office for reference.

3.3.5 Field Level Risk Assessment (FLRA)

Prior to beginning any work task a Field Level Risk Assessment shall be conducted. The senior or designated person of the
work team will conduct the FLRA with the participation of other employees. The FLRA shall be documented and
submitted to the designated supervisor after the task is completed.

3.3.6 PPE Assessment & Matrix

Personal Protective Equipment shall be identified via the El Eman Construction Est. (ELEMAN) PPE Hazard Assessment
Certification Form which shall be signed and dated by the Safety Manager.

3.3.7 Site Specific HSE Plan (SSHP)

Each work location has a site specific HSE plan.

Each employee reporting to a location shall receive a documented orientation from a El Eman Construction Est. (ELEMAN)
supervisor that includes the SSHP for that site.

The SSHP contains the El Eman Construction Est. (ELEMAN) Health and Safety Policy, site specific safety requirements as
well as a PPE matrix and a signed site specific worksite hazard assessment for that location, which the El Eman
Construction Est. (ELEMAN) has a responsibility to provide.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 20 of 64

3.4 Legal and Other Requirements

OBJECTIVES
• To describe the process developed to identify and have access to legal and other requirements;
• To keep the information up to date and to communicate these requirements to those with compliance
responsibilities.

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager

• Identify and ensure access to legal and other requirements.
• Identifies, tracks and monitors legal and other requirements for work performed;
• Provides updates and ensure accuracy and completeness of the El Eman Construction Est. (ELEMAN) HSEM
Compliance Matrix and communicates requirement changes to the site manager and supervisors.

Site Manager and Supervisors

• Notifies the El Eman Construction Est. (ELEMAN) Safety Manager of new projects and communicates
responsibilities to our employees;
• Communicates facility and operational changes to the El Eman Construction Est. (ELEMAN) Safety Manager.

Employees
• Follows all legal and other requirements.

PROCEDURE
El Eman Construction Est. (ELEMAN) operations personnel notify the El Eman Construction Est. (ELEMAN) Safety Manager
if a new project is to begin.

The El Eman Construction Est. (ELEMAN) Safety Manager then conducts an analysis which identifies the legal and other
requirements that apply to the scope of work being performed.

Employees are to have ready access to the current safety and applicable legislation as required. The bulletin board shall
be utilized for this purpose.

3.4.1 Legal Requirements

• Regulatory statutes applicable to the jurisdiction
• Hazard or industry specific statutes and regulations
• Municipal laws/regulations/by-laws
• Collective Agreements (e.g. those containing provisions for personal protective equipment)

3.4.2 Other Requirements

• Client requirements
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: General Manager Issuing Dept: Safety Page: Page 21 of 64

• Agreements with contractors

• Industry and trade association codes
• Standards that must be adhered to in the organization – e.g. ACGIH Threshold Limit Values
Identified legal and other requirements are listed on the El Eman Construction Est. (ELEMAN) HSEM Compliance Matrix.

Legal and other requirements are incorporated into the Worksite Hazard Assessment which is included in the site specific
HSE plan for the project.

3.4.3 Means of Tracking Requirements

Establish means of tracking all of the above (through internet, e-mail, safety bulletin boards etc)
• El Eman Construction Est. (ELEMAN) subscribes to those identified information services as required to be
continually informed of regulatory scope changes.
• El Eman Construction Est. (ELEMAN) uses the internet to check on safety and health new or revised legislation
for the scope of work being conducted.

3.4.4 Review of Requirements

Legal and other requirements are reviewed annually.
3.4.5 El Eman Construction Est. (ELEMAN) Safety and Health Compliance Matrix

CITATION OR RESPONSIBLE OPERATIONAL

ASPECT LOCATION COMPLIANCE OBLIGATION OR TASK FREQUENCY RECORDS
STANDARD PARTY CONTROL
U.S. Occupational Safety and Health Training
Overall Health & Safety All Operations 29 CFR 1910 Continuous Entire Organization Inspections
Standards Inspections

Safety Mgr
Employer shall establish a written Exposure Blood borne Training
Blood borne Pathogens All Operations 29 CFR 1910.1030 Continuous Supervisor
Control Procedure. Pathogens Program SSHP Receipt
Employee

Requirements to protect employees from the None Supervisor Confined Spaces

Permit Confined Spaces All Operations 29 CFR 1910.146 SSHP Receipt
hazards of permit-required confined spaces. Precautionary Employee Program

As new Training
Ensure that hazards of all chemicals are
Hazard Communication All Operations 29 CFR 1910.1200 chemicals are All employees HAZCOM Program
transmitted to employees. SSHP Receipt
introduced

HAZWOPER
Emergency response operations for releases Supervisor Training
HAZWOPER All Operations 29 CFR 1910.120 Precautionary Program
of hazardous substances. Employee SSHP Receipt
SSHP

Safety Mgr
Protective equipment shall be provided, PPE Program
Personal Protective used, and maintained whenever hazards are Project Mgr Training
All Operations 29 CFR Subpart I As Required SSHP
Equipment capable of causing injury or impairment to Supervisor SSHP Receipt
any part of the body. Training
Employee

The employer shall be responsible for the Supervisor Respiratory

Respiratory Protection All Operations 29 CFR 1910.134 establishment and maintenance of a Precautionary SSHP Receipt
Employee Protection Program
respiratory protection program.

An emergency action plan must be Emergency

Emergency Response Plan All Operations 29 CFR 1910.38 As Required Safety Manager SSHP Receipt
established and in writing. Response Program

Project Mgr
Protection for working over 6’ above lower Fall Protection
Fall Protection All Operations 29 CFR 1926.503 Precautionary Supervisor SSHP Receipt
working surface. Program
Employee
CITATION OR RESPONSIBLE OPERATIONAL
ASPECT LOCATION COMPLIANCE OBLIGATION OR TASK FREQUENCY RECORDS
STANDARD PARTY CONTROL
Environmental Compliance CFR Title 40: Safety Manager El Eman As per El Eman
U.S. Environmental Protection Agency
All Operations Protection of As Required Construction Est. Construction Est.
(Federal) Protection of Environment Project Manager
Environment (ELEMAN) EMS (ELEMAN) EMS

As specified by Follow individual client safety and SSHP SSHP

Client HSE Compliance Client Specific Continuous All Employees
client environmental requirements Inspections Inspections

Federal, state and

Vehicle Operation community driving Follow all provincial and local vehicle Training
All Operations Continuous Manager Human Resources
Compliance laws and operating laws and regulations License Verification
regulations
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 24 of 64

3.5 Written Safety and Health Goals, Objectives and Programs

OBJECTIVES
• To establish and maintain proactive documented safety and health objectives within El Eman Construction
Est. (ELEMAN);
• To have objectives consistent with our safety policy and our commitment to continual improvement.

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager

• Develops the safety and health objectives for El Eman Construction Est. (ELEMAN) on an annual basis.
• Occupational health and safety objectives and targets

Site Manager and Supervisors

Train employees on objectives.

Employees
Provide input into objectives planning through involvement.

3.5.1 Safety and Health Goals

The El Eman Construction Est. (ELEMAN) Safety Manager identifies goals by:
• Aligning objectives with El Eman Construction Est. (ELEMAN) policy, legal and other requirements, hazard
abatement procedures
• Making objectives specific, measurable and achievable
• Gathering input from employees and interested parties
• Incorporating Management Review procedure results
Examples of goals include:
• Reduction of risk levels
• Elimination or reduction in frequency of undesired incidents
• Implementing additional features of the El Eman Construction Est. (ELEMAN) HSEM Management System
After goals are identified the El Eman Construction Est. (ELEMAN) Safety Manager prioritizes them and establishes
a scope, objective, time scale, and target, responsibilities and resources requirements for each identified objective
and provides a safety management program.

Performance against developed goals is measured by and communicated to employees in memos, safety meetings
and other as-needed methods.

Developed goals are reviewed and modified on a quarterly basis. If circumstances have changed since the original
formation of goals adjustments may be made and documented.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 25 of 64

Progress on achieving goals is reviewed as part of the Key Performance Indicator procedure and Management
Review procedure.

3.5.2 Objectives and Safety Programs

To establish and maintain management programs to achieve identified safety and health goals.

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager

• Develops, documents and communicates the safety and health management programs to achieve
identified safety and health objectives;
• Monitors progress towards objectives;
• Updates and revises safety and health management programs accordingly.

Site Manager and Supervisors

Implement safety management programs.

EMPLOYEES
Follow requirements of safety and health management programs.

PROCEDURE
The El Eman Construction Est. (ELEMAN) Safety Manager establishes safety and health management programs
based on objectives and responsible parties are notified of their requirements.

Where significant modifications in working practices, processes or equipment are expected the management
program will provide for new hazard identification and risk assessments.

Progress for safety and health management programs is reviewed as part of the Key Performance Indicator
procedure and Management Review procedure and shall be evaluated quarterly.

3.5.3 Written Annual Goals for 2015

PROGRAM TARGET
SCOPE RESPONSIBLE PARTIES RESOURCES
OBJECTIVE & TIME SCALE
100% Training
All Operations Training Compliance Compliance by President Time | Training
30/01/2015
Implement HSEMS
All Operations HSEMS Implementation Documentation by President Time | Administrative
30/01/2015
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 26 of 64

4.0 IMPLEMENTATION & OPERATION

OBJECTIVES
• To define and communicate roles, responsibilities, and authorities necessary to establish, implement, and
maintain the HSEMS
• To communicate the safety and health policy, objectives and targets, and other elements of the HSEMS to
employees and contractors
• To ensure employees are appropriately trained
• To establish procedures to handle safety and health inquiries from interested parties
• To identify and describe the core elements of the HSEMS
• To control safety and health documents and procedures
• To maintain documented procedures to control operations that could impact safety and health
• To have an effective emergency preparedness and response plan

RESPONSIBILITIES
All responsibilities are identified within each of the Implementation and Operation procedures.

4.1 Overview
Through effective implementation and operational controls El Eman Construction Est. (ELEMAN) benefits by:
• Providing a framework for a systematic and integrated approach for safety and health management which
allows the HSEMS to become part of the fabric of our business
• Making the HSEMS "system" dependent and not "person" dependent
• Promoting sound safety and health management which becomes a means of doing business and not an
end in and of itself
• Positioning El Eman Construction Est. (ELEMAN) as a safety and health leader.

4.2 Structure and Assignment of Responsibilities

4.2.1 Health, Safety & Environmental Management System Organization Chart

PRESIDENT

OPERATIONS MGR SAFETY MGR

Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 27 of 64

OBJECTIVES
• To define roles, responsibilities and authorities are documented and communicated;
• To ensure adequate resources are provided to enable safety and health tasks to be performed.

RESPONSIBILITIES

President
Ultimate authority and responsibility for the HSEMS lies with the President. The President ensures that adequate
resources are available to accomplish the goals of the El Eman Construction Est. (ELEMAN) HSEMS and that the
system is incorporated in the day-to-day conduct of business.

Safety Manager
The El Eman Construction Est. (ELEMAN) Safety Manager is responsible for ensuring development, implementation
and maintenance of the Health, Safety & Environmental Management System within El Eman Construction Est.
(ELEMAN) operations. This position reports to the El Eman Construction Est. (ELEMAN) President for responsibility
of performance. Responsibilities include, but are not limited to:

• Sets an example for employees to follow by incorporating safe work practices in all aspects of their
activities and following all El Eman Construction Est. (ELEMAN) and client safety policies and procedures
• Conducts incident analysis to identify incident trends
• Ensures that investigations are conducted and conducting site inspections
• Acts as a liaison between management and outside agencies
• Assures training programs are established and tracked for employees and supervisors
• Develops technical guidance and programs to identify worksite hazards
• Ensures corporate compliance with legal and other requirements.
• Monitors health and safety, environment and quality assurance policies, procedures, protocols and legal
requirements and assists site management in implementation
• Liaison with client’s Health and Safety dept, governmental agencies (i.e. Public Health, etc.).
• Ensures due diligence records are maintained incl. audits are conducted
• Monitors and address all program shortcomings
• Performs all risk management requirements including workers compensation procedures are followed
• Prepares reports including key performance indicators to management and to the client as needed
• Monitors corrective actions determined from audits, inspections, etc.
• Central point of contact for units in regards safety concerns

Operations Management Members

These positions reports to the El Eman Construction Est. (ELEMAN) President.

• Setting an example for employees to follow by incorporating safe work practices in all aspects of their
activities and following all El Eman Construction Est. (ELEMAN) and client safety policies and procedures;
• Investigating (or assisting in) incidents;
• Enforcing all El Eman Construction Est. (ELEMAN) and client safety rules, policies or procedures in a
consistent manner;
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 28 of 64

• Ensuring weekly safety meetings are conducted and documented;

• Incorporating safety performance in the personnel evaluation/appraisal process;
• Assuring that adequate resources are available to incorporate safety into their operations;
• Monitoring and ensuring those supervisors within their responsible area are performing their duties in
accordance with this safety management system.

Supervisors
Supervisors report to the operations management.
• Setting an example for employees to follow by incorporating safe work practices in all aspects of their
activities and following all El Eman Construction Est. (ELEMAN) and client safety policies and procedures;
• Enforcing all El Eman Construction Est. (ELEMAN) and client safety rules, policies or procedures in a
consistent manner;
• Assuring that safety devices and PPE are available and properly utilized;
• Promptly addressing safety concerns and issues brought to their attention by employees;
• Assuring that injuries/illnesses are treated promptly and management being notified immediately;
• Assisting in investigating all incidents and near misses;
• Assuring that no unsafe condition exists in their area of responsibility;
• Assuring that employees are properly oriented and trained for hazards and equipment at their location;
• Performing safety orientations and documenting the orientation before allowing any employee to begin
work at their location.

All Employees
Working safely is a condition of employment. Each employee has personal responsibility and accountability for
safety on the job. All employees are responsible for:

• Following all El Eman Construction Est. (ELEMAN) and client safety policies and procedures and to perform
assigned work duties in a safe manner;
• Stopping work immediately if they consider conditions or work methods to be unsafe and notifying their
supervisor of the problem;
• Immediately reporting any injury, suspected injury, job related illness, spill or damage to any property to
their immediate supervisor. If their immediate supervisor is not available the employee is then to
immediately notify the project manager.

PROCEDURE

4.2.2 Documentation and Communication

Responsibilities are defined and documented within the Responsibilities section of each HSEMS procedure. The
responsibilities are clearly communicated to employees through various means such as job descriptions, meetings,
site specific HSE plans, training, HSEMS Manual, etc. HSEMS responsibilities are reviewed and revised through
inspections, assessments, and management reviews.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 29 of 64

4.3 Training, Awareness and Competency (Refer to Procedure No. - ELEMAN/HSE/PR/GE/04 &
05)

OBJECTIVES
• To ensure the competence of personnel to carry out their designated function.
• A competent employee means adequately qualified suitably trained and with sufficient experience to
safely perform work without supervision or with only a minimal degree of supervision.

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager

Identifies updates and monitors training for employees.

Site Manager and Supervisors

• Shall ensure all employees assigned to their project complete training identified in the training matrix.
• Shall ensure that any work that may endanger an employee must be completed by an employee who is
competent to do the work.
• Shall ensure all employees assigned to their project are trained in procedures until they are competent.
• Shall ensure all employees have sufficient experience to safely perform work without supervision or with
only a minimal degree of supervision.

Employees
Attend and follow requirements of safety and health management training.

PROCEDURE

4.3.1 HSE Competency Assurance Process

Competence is a combination of knowledge, understanding and skill, and the appropriate level of competence
cannot be acquired simply by attending a training session. The understanding and skill are acquired by experience.
For individuals managing HSE hazards and risks experience and training are essential. The following components
are to be considered for each worksite’s delivery team for competency assurance:

Experience Level of Knowledge Capability to Perform

Upon hire with El Eman Construction Est. (ELEMAN) every employee will participate in the Competency Assurance
Process. This process begins with the selection of personnel and enters a continuous improvement loop that will
stay with the employee during his career with El Eman Construction Est. (ELEMAN). At El Eman Construction Est.
(ELEMAN) our view of competency assurance involves the continuous assessment of training and development
needs against a person’s responsibilities, abilities and critical activities. Not only will employees gather evidence of
competence, they will also participate in an annual appraisal to assess their performance, behaviors and personal
development. This process enables the continuous improvement loop that feeds back into training and
development activities that ensure competency assurance is an ongoing career cycle process.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 30 of 64

1. Job Description Identified → Candidate Selection and Hiring Process (Reference and Background Check,
Drug Screen, Physical Assessment) → Person Assessed and Hired for Open Position

2. Experience, Qualifications Assessed for Initial Training ↔ Initial Induction Training Completion

3. Further Training Required? If no → Ready for Work → On the Job Training → Competency Continually
Assessed

4. Annual Performance Appraisal → Ready to Promote? → Employee Promoted → Further Training

Required?

Additional competency regarding health and safety is demonstrated during inspections employees are interviewed
for knowledge to determine competency to work safely and be knowledgeable of their responsibilities within the
El Eman Construction Est. (ELEMAN) Safety and Health Management System.

For individual directly managing risk the specific requirements will be matrixes with training for areas such as
legislative requirements, client HSE requirements and recognized certification and licensing.

4.3.2 Identification of Training and Competency Needs

Training is identified in our training matrix which specifies safety and health training needs by job title. Our training
matrix is updated based on changing risks.

4.3.3 Training Records

All training records are maintained on site either by the El Eman Construction Est. (ELEMAN) Safety Manager or
senior representative of management or their designee.

4.3.4 Delivery of Induction, Transfer & Refresher Training

Employees receive initial induction training. No work by any employee is allowed to begin until the orientation is
completed.

Training requirements are tracked by the El Eman Construction Est. (ELEMAN) Safety Manager and formal training
sessions are conducted either on or off site by the Safety Manager or competent/qualified instructor for the
required subject matter.

4.3.5 Training Documentation

All training must be documented with: date; employee name, employee signature; instructor name; instructor
signature and title of course.

Each new employee shall receive an orientation prior to beginning any work.

4.3.6 Supervisor Safety Management Training

Supervisors and managers receive annual, documented safety management system training.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 31 of 64

4.3.7 El Eman Construction Est. (ELEMAN) Training Matrix

Additional training for identified hazards must

Management
FREQUENCY
be completed prior to employee exposure based

LOCATION
upon a hazard assessment. Sample shown.

Admin

Craft
Bloodborne Pathogens All A PRN X X
Confined Spaces All I X X
Defensive Driver Awareness | Driving Safety All I X X X
Electrical Safety - Unqualified All I X X
Emergency Response Plan All I X X X
Fall Protection All I X X
Fire Extinguishers All A X X X
First Aid/CPR PRN 2 PRN PRN PRN
H2S All I X X
Hand and Power Tools All I X X
HAZCOM All I X X X
Hearing Conservation All A X X X
Isolation of Energy | LOTO All I X X
JHA All I X X X
Ladder Safety All I X X
Personal Protective Equipment All I X X
Rigging Awareness All I X X
Scaffolding All I X X
Site Specific HSE Plan All I X X X
Supervisor Safety Training All PRN PRN X PRN
PRN = As Required Frequency: I = Initial A = Annual 2 = 2 Years 3 = 3 years

4.3.8 Short Service Employee Program

The purpose of the Short Service Employee (SSE) Management program is to prevent work related injuries and
illnesses to new hires and temporary workers. The Supervisors and co-workers must be able to readily identify
Short Service Employee participants. El Eman Construction Est. (ELEMAN) will assign experienced employees to
oversee the daily activities of those assigned to the SSE program. Refer to the El Eman Construction Est. (ELEMAN)
Short Service Employee Procedure.

Short Service Employee – An employee or sub-contractor employee with less than six months experience in the
same job or with his/her present employer.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 32 of 64

• Supervisors will assure that all new, transferred and temporary employees have been through El Eman
Construction Est. (ELEMAN) Safety Orientation and have a complete knowledge of the expectations for
their job function.
• Short Service Employee participants will wear orange hard hats or another approved method of
identification. The El Eman Construction Est. (ELEMAN) shall comply with client designated hardhat color
for SSE.
• Mentors will set the proper safety example for any Short Service Employee assigned them.
• Mentors will be assigned one short service employee. Exception: in shop environments, a maximum of 3
Short Service Employee, participants may be assigned per mentor.
• Short Service employees on client locations shall make up no more than 50% of a crew.

4.4 Consultation and Communication

OBJECTIVES
To encourage participation in good safety and health practices and support for our policy and objectives by
consulting and communicating with all employees.

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager

• Establishes procedure to ensure that pertinent safety and health information is communicated to and
from employees and other interested parties
• Ensures employees are involved in the development and review of procedures to manage risks

Site Manager and Supervisors

• Encourages all employees to participate in safety matters and provide input into the safety process
• Immediately forwards any question, concern or suggestion any employee has regarding safety and health

Employees
• Provide input into the safety process and participate in all levels of safety they choose to

PROCEDURE
Methods used to involve employees in hazard identification, risk assessment and risk control and to encourage
employee involvement in the safety and health process include:

4.4.1 Open Door Policy

It is preferred that the immediate supervisor and/or project management be consulted for resolution of the
concern; however, El Eman Construction Est. (ELEMAN) maintains a strong open door policy to report problems or
concerns to any level of management without fear of reprisal of any employee.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 33 of 64

4.4.2 Behavior Based Safety Program (BBS)

• Employees may report any suggestions, unsafe act, unsafe condition or recognition, even anonymously,
via the El Eman Construction Est. (ELEMAN) BBS Safety Observation Form). The name of the employee
being observed is never used. The form is to be immediately forwarded to the El Eman Construction Est.
(ELEMAN) Safety Manager. Refer to the El Eman Construction Est. (ELEMAN) Behavior Based Safety (BBS)
Procedure.
• Employees may use other observation forms if another safety observation program is present.
Observations by fellow employees are to be performed in a positive, non-judgmental manner and the
observing employee must give permission prior to the observation.
• No disciplinary action may result from safety observations by fellow employees. Supervisors will always
allow time for safety observations to be made based on operational scheduling. Supervisors do not
conduct observations.

4.4.3 Incident Notice Form

This communicates lessons learned from incidents, is posted on employee bulletin boards and shall be discussed in
weekly safety meetings.

4.4.4 Weekly Safety Meetings

Employees are required to attend safety meetings and the meetings shall be documented. Management is to
attend all safety meetings if present on site.

4.5 Document and Data Control

OBJECTIVES
To document and maintain up-to-date sufficient documentation to ensure that our health and safety management
system is adequately understood and effectively and efficiently operated.

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager (Preparation and Custodian Duties)
• Responsible for validating and approving all documents and revisions to existing documents
• Responsible for assuring documents included in an HSEMS are in the proper format
• Ensures documents can be located, current versions are available, and obsolete documents are removed
and determine the routing path for review of a controlled document
• Updates El Eman Construction Est. (ELEMAN) HSEMS Document Control List

PROCEDURE
The authority initiates document development. The authority seeks input from appropriate personnel to create
the document. The draft document is submitted to the appropriate individuals for review.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 34 of 64

4.5.1 Document Format

HSEMS documents shall be consistent in format and include a document number, issue date, authority, preparer
and revision history.

4.5.2 Reviewing
Reviews of controlled documents are performed annually. Revisions to controlled documents are performed on an
as needed basis.

4.5.3 Control
The El Eman Construction Est. (ELEMAN) Safety Manager prepares a Document Control List. The list defines the
document retention period and other requirements.

4.5.4 Document Distribution

This manual is maintained on the El Eman Construction Est. (ELEMAN) server and is available to the following
personnel:

El Eman Construction Est. (ELEMAN) President Operational Management

Human Resources
Site Managers Safety Department Clients upon request

Only PDF versions of this manual are available to non-authorized persons. The master documents are maintained
under a secure access configuration. No controlled copies will be issued. Only PDF documents will be distributed
with a self expiring footer showing as uncontrolled after 24 hours from time of printing.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 35 of 64

HSEMS DOCUMENT CONTROL LIST

Retention
Off
Document Title On Site Driver Method Authority Date Last
Site
HSEM MANAGEMENT SYSTEM
HSEM Management System As Updated 5 Years Policy Electronic President 02/02/2011

HSEM MANAGEMENT SYSTEM FORMS

Worksite Hazard Assessment Form As Updated 5 Years Policy Electronic President 02/02/2011

Job Safety Analysis (JSA) As Updated 5 Years Policy Electronic President 02/02/2011

Field Level Risk Assessment (FLRA) As Updated 5 Years Policy Electronic President 02/02/2011

Safety Observation Form As Updated 5 Years Policy Electronic President 02/02/2011

Incident Notice Form As Updated 5 Years Policy Electronic President 02/02/2011

Field Incident Report Form As Updated 5 Years Policy Electronic President 02/02/2011

PROGRAMS
Assured Equipment Grounding As Updated 5 Years Policy Electronic President 02/02/2011

Blood borne Pathogens As Updated 5 Years Policy Electronic President 02/02/2011

Disciplinary Program As Updated 5 Years Policy Electronic President 02/02/2011

Confined Spaces As Updated 5 Years Policy Electronic President 02/02/2011

Electrical Safety As Updated 5 Years Policy Electronic President 02/02/2011

Fall Protection As Updated 5 Years Policy Electronic President 02/02/2011

Fire Safety As Updated 5 Years Policy Electronic President 02/02/2011

Fire Safety - Extinguishers As Updated 5 Years Policy Electronic President 02/02/2011

First Aid Program As Updated 5 Years Policy Electronic President 02/02/2011

Hand & Power Tools As Updated 5 Years Policy Electronic President 02/02/2011

HAZCOM As Updated 5 Years Policy Electronic President 02/02/2011

H2S As Updated 5 Years Policy Electronic President 02/02/2011

Ladder Safety Program As Updated 5 Years Policy Electronic President 02/02/2011

Managing Hazardous Energy As Updated 5 Years Policy Electronic President 02/02/2011

Noise/Hearing Conservation As Updated 5 Years Policy Electronic President 02/02/2011

PPE Program As Updated 5 Years Policy Electronic President 02/02/2011

PSM As Updated 5 Years Policy Electronic President 02/02/2011

Rigging As Updated 5 Years Policy Electronic President 02/02/2011

Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 36 of 64

4.6 Operational Control

OBJECTIVES
To establish and maintain arrangements to ensure effective measures are used to control risk, to follow our safety
and health policy, meet objectives and conform to legal and other requirements.

Refer to specific El Eman Construction Est. (ELEMAN) safety program document external to this document.

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager

Responsible for development of operational controls and reviewing to confirm the appropriate legal and other
requirement are identified in the operational controls.

Site Manager and Supervisors

• Responsible for the implementation of operational controls at the operational level of the HSEMS
• Identifies the roles and responsibilities of operations personnel

Employees
• Follow all safety and health procedures
• Provide suggestions and other input to improve procedures

PROCEDURE

4.6.1 Compliance with Legal and Other Requirements

The Manager, with assistance from the El Eman Construction Est. (ELEMAN) Safety Manager, leads the
development, documentation, and maintenance of applicable operational controls. Operational controls are
developed for safety and health requirements identified in the Safety and Health Compliance Matrix.

4.6.2 Identified Hazards and Risks

Operations and activities associated with hazards and identified risks are addressed within the HSEMS through the
worksite hazard assessment.

4.6.3 Management of Change (MOC) (Refer to Company Procedure # ELEMAN/HSE/PR/GE/08)

The Manager identifies facility and operational changes for review. The El Eman Construction Est. (ELEMAN) Safety
Manager determines whether the changes have a potential impact the operational controls and, if so, updates the
operational controls in conjunction with the Manager. Modifications and revisions to operational controls are
communicated to relevant personnel via the site specific HSE plan. Refer to the El Eman Construction Est.
(ELEMAN) Management of Change Procedure.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 37 of 64

4.6.4 Purchase of Goods and Services

• Only approved suppliers are used when purchasing personal protective equipment to ensure the
equipment meets regulatory requirements.
• No hazardous chemical may be purchased without proper MSDS documentation.

4.6.5 Systems to Control Access or Exiting Customer's Premises

• All vehicles will be properly insured and equipped with all client vehicle required safety equipment.
• All staff will have proper client required training and identification prior to entering a client location.
• All staff will log in and log out per client requirements.
• No material will be brought onto or leave client property without permission from the client in
accordance with their requirements.

4.6.6 Background Checks Prior to Issuing Identification Cards

• All individuals shall provide proof of identity prior to being issued a badge or access to company or client
property. The proof must be issued by a governmental agency and have a photo (driver’s license,
passport, etc.).
• All visitors shall log in and out of our or client facilities.
• Further background investigation may be required based on the sensitivity of the employee’s position.

4.6.7 Company Employee Identification System

• All employees shall be issued an ISNetworld identification badge with photo included. Temporary badges
can be downloaded from ISNetworld prior to the final badge arriving. Employees are required to carry at
least the ISNetworld badge in addition to any client or El Eman Construction Est. (ELEMAN) issued
identification badge.

4.6.8 Hazardous Materials

• No controlled products or materials will be allowed to be used unless there is a valid Material Safety Data
Sheet available on-site and there is a supplier or workplace label on the container for any controlled
product that is produced, manufactured or used at any work site.
• El Eman Construction Est. (ELEMAN) will ensure the MSDS is obtained from the supplier when receiving a
controlled product on each job site.
• El Eman Construction Est. (ELEMAN) will ensure that MSDS are filed at the work site where they will be
readily accessible to employees. MSDS must be updated every three years.
• El Eman Construction Est. (ELEMAN) will ensure that MSDS are available and posted near the work site
where controlled products are used.
• Managers will ensure that employees are notified if a controlled product is to be used in an open area or
where fumes may migrate.
• A Controlled Product Inventory List and Material Safety Data Sheets shall be kept at a main location and
will be made available to employees for review.
• Any work site generated waste classified as hazardous shall be stored and handled safely and properly
using a combination of any and all means of identification and instruction of employees on the safe
handling of the hazardous waste.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 38 of 64

4.6.9 Control of Hazardous Materials for Client Locations

• No hazardous material will be brought onto client property unless all client approval processes have been
met. This may involve a needs analysis review and MSDS submittal and approval. All client procedures
must be followed.

4.6.10 Reporting of Hazardous Conditions, Security Incidents or Injuries

• All employees have a responsibility for reporting hazardous work conditions or acts that are encountered
on the job site.
• Employees shall not perform any work they feel is unsafe. Each employee is required to immediately
report any unsafe condition or act to their immediate supervisor. Any employee may report hazardous
work conditions without fear of reprisal.
• Employees shall immediately report any injury, near miss and incidence of fire, property damage, theft or
other security related matter and environmental non-conformance or, before reporting for work, and any
non-work injuries or prescriptions that could affect their ability to safely perform their normal job.
• Failure to report incidents, hazardous work conditions or near misses shall result in disciplinary action.
• Additional methods for reporting hazardous conditions include: Weekly safety meetings; El Eman
Construction Est. (ELEMAN) BBS Safety Observation Form to the El Eman Construction Est. (ELEMAN)
Safety Manager/ Supervisor or JHSC
• Direct communications with any member of El Eman Construction Est. (ELEMAN) supervision or
management;
• Client hazard reporting methods.

4.6.11 Fire Fighting - Incipient Policy

Employees shall only use fire extinguishers if trained. No employee will risk their own or others personal safety in
attempting to put out a fire in its initial (incipient) stage. Employees will evacuate and use the appropriate alarm
and allow qualified individuals attempt to extinguish the fire.

4.6.12 Disciplinary System

Management is committed to the safety excellence of its employees by providing an injury and incident free
workplace. All employees are to abide by the regulations, safety rules and the use of safe work practices and
procedures. Refer to the El Eman Construction Est. (ELEMAN) Disciplinary Action Procedure.

Safety violations will be handled in an objective but firm manner. The enforcement progression follows the steps
outlined below with documentation at each stage:

• Verbal Warning
• Written Warning
• Dismissal
Violation of any of the below rules will not be tolerated on the job and are additional grounds for immediate
discipline up to and including dismissal:

• Consuming or being in possession of alcohol or illegal drugs on company premises, or on any company
job-site, is prohibited.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 39 of 64

• No weapons or firearms of any type are allowed on the worksite.

• Fighting, horseplay, practical jokes or otherwise interfering with other workers is prohibited.
• Theft, vandalism or any other abuse or misuse of company property is prohibited.
• All unsafe acts and conditions, including “near miss” incidents, are to be reported to appropriate
supervision promptly.
• Hard hats, safety boots and safety glasses are to be worn at all times on all job-sites.
• All work shall be carried out in accordance with appropriate safe work practices and your supervisor’s
direction.
• Only those tools that are in good repair, with all guards and safety devices in place, shall be used.
• Attempted or actual physical force to cause injury, threatening statements or other actions to cause an
employee to feel they are at risk of injury.

4.6.13 Impairment
El Eman Construction Est. (ELEMAN) has a ZERO tolerance and prohibits any employee from possessing or being
under the influence from alcohol, drugs and other substances at any El Eman Construction Est. (ELEMAN) work
location. Refer to the El Eman Construction Est. (ELEMAN) Drug and Alcohol Policy Statement.

4.6.14 General Safety Standards and Guidelines

The below applies to all El Eman Construction Est. (ELEMAN) worksites. Additional work practices are contained in
the site specific HSE plans based on local operating requirements as well as specific El Eman Construction Est.
(ELEMAN) safety programs associated with this safety and health management system.

Training
• All work that may endanger an employee must be completed by an employee who is or is working under
the supervision of an employee who is competent to do the work. All employees must be trained until
they are competent.

Housekeeping
• El Eman Construction Est. (ELEMAN) is responsible for making sure that the work site, and in particular
entry and exit routes at a work site, are free of waste, materials and equipment.
• Obstructed entry and exit routes can pose a serious hazard to workers having to leave a work site quickly,
as might be required during an emergency and shall be kept clear at all times.
• Obstructions may reduce visibility at a work site and may also present a tripping hazard and shall be
removed as observed.

Lighting
• El Eman Construction Est. (ELEMAN) is responsible for ensuring adequate lighting is available for tasks
requiring the ability to distinguish detail, such as an electrician working on live circuits at a panel board or
a sewing machine operator stitching a product.
• El Eman Construction Est. (ELEMAN) is responsible for protecting light sources above a working or walking
surface against damage.
• Emergency lighting must be available if employees are in danger if the normal lighting system fails.
Natural daytime lighting cannot be relied upon as a dependable source of emergency lighting.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 40 of 64

• El Eman Construction Est. (ELEMAN) is responsible for ensuring that an emergency lighting system
provides sufficient light to allow workers to safely leave the work site, start any necessary emergency
shutdown procedures or restore normal lighting.

Pallets and Storage Racks

• All goods, materials and equipment at work sites must be stacked, stored, and secured in such a way that
they do not flow, move, roll or collapse. Employees responsible for stacking, storing, or securing goods,
materials, and equipment must be trained in the safe methods for doing so.
• Stacks, shelving and other fixtures for holding or storing materials shall be laid out and designed so that
there is sufficient access for safe loading and unloading.
• Storage areas shall be specifically designated and be clearly marked. Aisles should be wide enough for the
type of storage, and be kept free of obstacles and waste materials.
• Suitable racks will be provided for materials capable of rolling such as steel tubes, bars and piping. Large
diameter tubes or pipes can be stored on their sides as drums might be stored.
• Wedges, chocks, stakes or other means shall be used to restrain the bottom tier of round objects that are
stacked or tiered and that could cause the stack to collapse by rolling or moving.
• Racks, shelving, fixtures, etc. shall be regularly inspected for damage and other defects that might cause
loss of strength or result in injury or damage.
• Employees must report to their employer any damage to storage racks as soon as is practical.

Restraining Hoses and Piping

• In those cases where failure or disconnection could cause movement that endangers employees, the
hoses or piping and their connections must be restrained.
• Methods of restraint include wiring together hose connections, clamping or bracketing pipe sections, and
securing restraint cables at the ends of hoses or pipe that function as loading spouts.

Securing Equipment and materials

• Bags, containers, bundles, etc. stored in tiers must be stacked, blocked, interlocked and limited in height
to prevent sliding or collapse.
• Loads must be secured by tie-downs, bulkheads, or blocking. Rolling equipment, when parked, shall have
wheels chocked to prevent unintentional movement.

Vehicle Traffic Control

• Employees on foot and exposed to the hazards of moving vehicles are required to wear highly visible
apparel that is clearly distinguishable.

Apparel
• Apparel should be kept clean and worn as intended – done up properly around the body with no loose or
dangling parts, there is to be no wearing of jewelry while working on site to ensure no entanglement and
no other clothing or equipment shall obscure high visibility clothing.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 41 of 64

4.6.15 Facility Equipment and Working Conditions

• Damaged and faulty equipment reporting procedures must be in place.
• No El Eman Construction Est. (ELEMAN) employee is allowed service vehicle tires or wheel assemblies.
This work shall only be performed by a qualified contractor.
• No equipment shall be operated unless the employee has received proper training by the supervisor.
• Tools and equipment damaged during use must be replaced or repaired only by a qualified person or
company.
• Floors, platforms, ramps, stairs and all walking surfaces for employees must be maintained in a state of
safe repair and kept free of slipping and tripping hazards. If such areas are taken out of service El Eman
Construction Est. (ELEMAN) will take reasonable means for preventing entry or use.
• El Eman Construction Est. (ELEMAN) shall ensure that worksite traffic is controlled to protect our
employees. This will be accomplished through engineering controls or administrative controls either by El
Eman Construction Est. (ELEMAN) or via our customers if they maintain control of the traffic on the
worksite. Each worksite must have a designated safe way of entering and exiting.
• El Eman Construction Est. (ELEMAN) will ensure that housekeeping issues such as keeping the work site
clean and free from materials or equipment that could cause employees to slip or trip.
• El Eman Construction Est. (ELEMAN) will ensure all equipment is maintained, safe to perform adequate
strength for its purpose and free from obvious defects. As with our statement that if it isn’t safe doesn’t
do it – this also applies to equipment; if it isn’t safe don’t use it.
• Any equipment being found to be defective or in need of repair shall be tagged out, isolated from service
by being turned into an employee’s direct supervisor and not used until repaired by a qualified repair
person.

4.6.16 Lone Workers Policy

Each worksite shall develop a Working Alone Plan and must provide effective radio, telephone, cellular phone or
other electronic communication between an employee who works alone and persons capable of assisting the
worked in an emergency or if the employee is injured or ill.

Each worksite's Working Alone Plan shall address having an established contact person. A person must be
designated to establish contact with the employee at predetermined intervals and the results must be recorded by
the person.

If electronic communication is not practicable or readily available at the worksite, El Eman Construction Est.
(ELEMAN) must ensure that a representative of El Eman Construction Est. (ELEMAN) or another competent
employee visits the employee, or the employee contacts El Eman Construction Est. (ELEMAN) or another
competent employee.

These visits or contacts shall be at intervals of time appropriate to the nature of the hazards associated with the
employee's work. As a minimum contact shall occur no less than every four hours.

The hazard assessment and Working Alone Plan at each El Eman Construction Est. (ELEMAN) worksite must be
reviewed on an annual basis or when work processes or arrangements which could affect an employee's well-
being are introduced or changed.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 42 of 64

4.6.17 Lifting and Handling Loads

• No employee will manually lift, lower, push, pull, carry, handle or transports a load that could injure them.
All employees shall receive ergonomic training addressed in the MSD procedure in this safety
management system.
• El Eman Construction Est. (ELEMAN) has a responsibility to provide, where reasonably practicable,
appropriate equipment for lifting, lowering, pushing, pulling, carrying, handling or transporting heavy or
awkward loads.
• Within each worksite’s site specific safety plan is a hazard assessment that all employees receive.
Included within that document that all employees receive and are tested on is an area addressing how to
handle heavy and awkward loads to minimize manual handling by the employee. Examples include: not
lifting over a set amount, being required to ask for help, being required to utilize mechanical means for
lifting and transport, etc.
• Material and equipment must be placed, stacked or stored in a stable and secure manner. Stacked
material or containers must be stabilized as necessary by interlocking, strapping or other effective means
of restraint to protect the safety of employees.
• An area in which material may be dropped, dumped or spilled must be guarded to prevent inadvertent
entry by employees, or protected by adequate covers and guarding.

4.6.18 Fatigue Management

Refer to the El Eman Construction Est. (ELEMAN) Fatigue Management Procedure. The guiding principles of fatigue
management shall be incorporated into the normal management functions of the business and include the
following:
• Employees must be in a fit state to undertake work
• Employees must be fit to complete work
• Employees must take minimum periods of rest to safely perform their work

The following work hour limitations and will control job rotation schedules to control fatigue, allow for sufficient
sleep and to increase mental fitness. If local legislated requirements are higher they shall be followed.
1. Every Employee shall have necessary work breaks in order to avoid fatigue. These scheduled breaks will
apply to both driving and on site hours. The following shall be a minimum (or reflect local legislated
requirements):
• 15 Minutes each 2.5 hours
• 30 Minutes after 5 Hours
• 30 Minutes after 10 Hours

2. No Workers shall work more than:

• 12 hours per day
• 24 Days Continuous

3. Unfamiliar or irregular work should be avoided.

Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 43 of 64

El Eman Construction Est. (ELEMAN) will provide equipment such as anti-fatigue mats for standing, lift assist
devices for repetitive lifting and other ergonomic devices as deemed appropriate, chairs for workers to sit
periodically and will provide periodic rest breaks for personnel. El Eman Construction Est. (ELEMAN) will also
periodically evaluate and improve work tasks to control fatigue.

4.6.19 Safe Journey Management (SJM) Policy

Each journey exceeding 10 miles outside of base operational areas, shall be planned, executed, monitored,
controlled and reviewed in a manner that the purpose of the journey is accomplished without any incident. A
written request and report shall be completed and the site manager make a monthly report to the Safety Manager
for SJM trips completed. This journey management plan must be performed in such a way as to:
• To minimize risks and incidents during transport or travel operations
• To reduce non-planned events inherent in transportation
• To increase the effectiveness of suitable emergency response planning
Potential journeys involving driving and/or road transport should be screened and assessed relative to hazards,
risks and costs with the following type of questions:
• Is the journey really necessary or will phone calls, e-mail, or video-conferences, etc. achieve acceptable
results?
• Must you drive, or is suitable public/commercial transportation available?
• Can the business requirement for a potential journey be delayed and possibly combined with a later trip?
• Can the journey be combined with other people to share a vehicle?
• Is a fit-for-purpose vehicle for the expected route and conditions available (for example, a four-wheel
drive vehicle, etc.)?

4.6.20 Driving Safety

Operators of El Eman Construction Est. (ELEMAN) or client on or off road vehicles shall be qualified by possession
of a valid, current driver’s license for the type of vehicle being driven.

No passengers shall be on trucks used to deliver goods.

Drivers shall have 3 years of driving experience on the vehicle he/she is licensed to drive & regularly drives.

Passenger compartments are to be free from loose objects that might endanger passengers in the event of an
incident. Any vehicle with non-segregated storage shall be equipped with a cargo net or equivalent to separate
the storage area.

Vehicles (light vehicles, heavy vehicles and trailers) may not be modified without the endorsement of the
manufacturer.

Signs, stickers or labels are to be fitted in such a manner that they do not obstruct the driver's vision or impede the
driver's use of any controls.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 44 of 64

El Eman Construction Est. (ELEMAN) requires drivers and all passengers to wear seat belts anytime the vehicle is in
motion. All El Eman Construction Est. (ELEMAN) vehicles capable of more than 10 mph/15 kph shall have seat
belts installed and they shall be used.

Employees driving vehicles are required to:

• Obey all local and provincial driving laws or regulations as well as requirements of clients;
• Immediately report any citation, warning, vehicle damage or near miss associated with company or client
vehicle operation to the supervisor;
• Immediately report any restriction or change to their driving privileges to the supervisor.
• Seat belts shall always be worn by all occupants during the operation of any vehicle; only seats fitted with
three-point inertia-reel type seatbelts be used. All vehicles capable of more than 10 mph/15 kph shall
have seat belts installed.
• Defensive drivers continually assess conditions and hazards and remain prepared for any challenge that
may approach them;
• When speaking with a passenger, always keep your eyes on the road;
• Both hands on the wheel;
• Our policy prohibits backing whenever practicable. Where backing is required, drivers, when parking,
should make every effort to park the vehicle in a manner that allows the first move when leaving the
parking space to be forward. The vehicle must either have a reversing alarm, or the driver shall use a
spotter or walk around the truck/trailer prior to backing;
• No use of cell phones, radios or other electronic devices while driving any vehicle - vehicle must be safely
parked prior to using a mobile phone or 2-way radio;
• Slow down around construction, large vehicles, wildlife, fog, rain, snow, or anything else that adds a
hazard to your driving;
• Drive for conditions, not just the speed limit;
• Alcohol or illegal drugs are not allowed to be in a company, client or leased vehicle at any time and all
vehicles are subject to random inspections.

Drivers are to be prepared before leaving:

• Perform 360 walk around – report new damage;
• Check windshield for cracks that could interfere with vision;
• Inspect for vehicle damage and immediately report any damage to the supervisor if not previously
observed;
• Make sure dirt or snow is removed from lights on all sides of the vehicle;
• Brush or clean off snow or ice on all windows to ensure complete vision;
• Check fuel level to be certain the destination can be reached;
• Check to ensure the license plates and inspection tag on vehicle are current;
• Ensure that there is a first aid kit and inspected fire extinguisher in the company vehicle;
• Ensure driver is rested and alert for driving;
• Secure all loads;
• Employees are not to perform repairs or maintenance other than routine fluid additions unless qualified.
• Assess the risk of a journey before driving and plan their driving route based on a journey risk assessment.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 45 of 64

4.6.21 Vehicle Requirements

• All company vehicles shall be outfitted with an adjustable steering column.
• All company vehicles shall be outfitted with an independently adjustable driver's seat (at a minimum,
moveable forward and rearward).
• All company vehicles will be outfitted with a functional air conditioning/heating system that is able to
maintain an in-cab temperature range of 5*C/41*F to 30*C/86*F under all local climatic and driving
conditions and the air conditioning unit will use a non ozone-depleting refrigerant.
• All drivers of light vehicles shall carry a high visibility jacket for use in case of emergency stops.
• All instrumentation will be in the local unit of measurement (e.g. speedometer, fuel gauge).
• All light duty vehicles (including buses) are to be equipped with an adjustable left, right and central rear
view mirrors
• All light duty vehicles carry a minimum of one collapsible hazard warning triangle.
• All light equipment vehicles shall be outfitted with two red high-intensity lights located as high, as far
apart, and as far back as practical, wired to the headlight switch, but also with an override switch, if
permitted by local regulations.
• All light vehicles registered after July 1, 2006 will be equipped with Anti-Lock Braking Systems (ABS).
• All light vehicles shall be equipped with a securely stowed first aid kit.
• All seats are to be fitted with headrests. Where practical all company vehicles will be outfitted with a
radio, cassette or cd player (or equivalent) to help reduce driver fatigue.
• All vehicle door locking systems will be equipped with an override in order that occupants can open the
doors after the vehicle has been locked externally.
• All vehicles are to be equipped with a multipurpose fire extinguisher with a capacity of at least 0.9 kg/2 lb.
The fire extinguisher shall be securely mounted on a bracket and located so that it is easily accessible in
an emergency without becoming a hazard in case of an incident.
• All vehicles shall have a mobile phone, 2-way radio, or other such communication device that allows
communication with emergency response personnel or El Eman Construction Est. (ELEMAN) managers.
• All vehicles will be outfitted with an adjustable steering column and the vehicle steering wheel will be
located on the left hand side of the vehicle.
• Any vehicle with non-segregated storage shall be equipped with a cargo net or equivalent to separate the
storage area.
• Driver shall ensure that passenger compartments are free from loose objects that might endanger
passengers in the event of an incident.
• Drivers are prohibited from backing whenever practicable.
• Drivers must have a reversing alarm, use a spotter or walk around the truck/trailer prior to backing.
• Drivers shall have 3 years of driving experience on the vehicle he/she is licensed to drive & regularly
drives. All vehicles will be equipped with a mobile phone, 2-way radio, or other such communication
device that allows communication with emergency response personnel or company managers.
• No passengers are allowed on trucks used to deliver goods.
• No vehicle less than 1000 kg is to be used on public roads. All company vehicles (light, heavy and trailers)
shall be suitable for operation in local climate conditions
• Only seats fitted with three-pointed inertia-reel type seatbelts shall be used.
• Rollover protection will be installed in any vehicle to address high risk environments. The rollover
protection engineered will conform to recognized regulatory standard and industry preferred practices.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 46 of 64

• Tire type and pattern is to be recommended by the vehicle or tire manufacturer for use on the vehicle in
the area of operation.
• Tires are to be radial with a minimum tread depth of 1.6mm [1/16 inch], 2.0mm across 75% of the tire
width and tread-pattern visible across 100% of the tire.
• Tires, including spares if full size, are to be of same type, profile and tread pattern, except when the
vehicle or tire manufacturer recommends a different type for certain axles.
• Vehicles (light vehicles, heavy vehicles and trailers) may not be modified without the endorsement of the
manufacturer.
• Vehicles are to be fitted with a spare wheel and changing equipment to safely change a wheel, or a
suitable alternative.
• Vehicles longer than 6 meters/20 feet or with restricted rear view (i.e. pickup trucks that are fully loaded)
are to be fitted with an audible reversing alarm.
• Vehicles must be safety parked prior to using a mobile phone or 2-way radio.
• Vehicles shall be outfitted with an independently adjustable driver's seat (at a minimum, moveable
forward and rearward).
• Where backing is required, drivers, when parking, should make every effort to park the vehicle in a
manner that allows the first move when leaving the parking space to be forward.

4.6.22 PPE
• The use and care of personal protective equipment is the responsibility of the employee. El Eman
Construction Est. (ELEMAN) provides basic safety equipment such as safety glasses; gloves and other as-
required PPE.
• PPE must be inspected by the employee for defects prior to each use. Where defective or damaged PPE is
found during inspection, it is disposed of. PPE must be kept clean and in good repair at all times. The El
Eman Construction Est. (ELEMAN) PPE Procedure and SSHP detail the PPE Matrix as well as the selection,
use, care and training for PPE.
• El Eman Construction Est. (ELEMAN) may require that other companies with employees to work on our
site. They shall have a comprehensive health and safety program and comply with El Eman Construction
Est. (ELEMAN) safety and environmental policies.
• We allow no other company’s employee to be on El Eman Construction Est. (ELEMAN) jobs until
documentation is provided demonstrating the employees meets all required training based on the
worksite hazard assessment.

4.6.23 Preventative Maintenance Program for Tools and Equipment

All tools, equipment and vehicles must be properly maintained so that workers are not endangered. Preventive
maintenance is the systematic care and protection of tools, equipment, machines and vehicles in order to keep
them in a safe, usable condition limit downtime and extend productivity. Maintenance tasks themselves are
potentially hazardous and can result in injury. This maintenance program must be prepared at a site level and:
• Be well organized and scheduled
• Controls hazards
• Defines operational procedures, and
• Trains key personnel
General requirements for equipment maintenance include:
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 47 of 64

• Obtaining a copy of the maintenance schedule recommended by the manufacturer.

• Ensuring that maintenance is performed as required.
• Ensuring that the person(s) performing the maintenance are competent (e.g. licensed mechanic).
• Retaining records of maintenance/service conducted.
• Specifying who is responsible for overseeing equipment maintenance and where the records are kept.
• Set up a system for removal and tagging of damaged or defective tools and equipment.

Tools and Equipment Maintenance Program

• Only properly trained workers are to use tools, equipment and vehicles.
• Inspect all tools, equipment and vehicles before using.
• For vehicles, inspection will consist of doing a circle check.
• If applicable, maintenance schedules for all tools, equipment and vehicles are to be respected.
• Each jobsite supervisor is to conduct a bi-weekly inspection of all tools, equipment and vehicles on the
site. This inspection is recorded bi-weekly using an inspection checklist based on the type of equipment
and vehicles at that site.
• If at any time a worker judges that a tool, equipment or vehicle is unsafe for use, they are to properly tag
the item and inform the supervisor immediately.
• Tools, equipment or vehicles that are tagged unsafe shall be either repaired or replaced - El Eman
Construction Est. (ELEMAN) management shall be informed.
REMINDERS: Always use Hand and Power Tools Safely
• Select the right tool for the job.
• Keep tools in good condition.
• Use tools the correct way.
• Keep tools in a safe place.

Maintenance Personnel Qualifications - All individuals who perform maintenance work on company tools shall
have the appropriate skills, accreditation and/or certification. This certification applies both to company
employees and to contracted maintenance services.

Mobile Equipment Maintenance Program - Maintenance Personnel Qualifications - All individuals who perform
maintenance work on company mobile equipment will have the appropriate skills, accreditation and/or
certification. This certification applies both to company employees and to contracted maintenance services.

Operator Qualifications and Training - All individuals who operate mobile equipment, cranes, vehicles etc. will have
the appropriate skills, accreditation and/or certification. This applies to both company employees and contracted
equipment services. The approval process includes the following:
• Possession of a valid driver's license appropriate to the type of equipment
• Successful completion of a practical operating exam administered by competent and authorized
personnel
• Vision test to meet the appropriate standard - Vision tests must be conducted by competent and
authorized personnel
• Hearing test with or without a hearing aid must be adequate for the specific operation. Hearing tests will
be conducted by competent and authorized medical personnel.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 48 of 64

• No history of epilepsy or of a disabling heart condition or any other physical disability or impairment.
• The operator shall be trained in the following:
o Their responsibilities to operate the equipment in a safe manner
o Familiarity and comprehension of safety requirements for the piece of mobile equipment which
they intend to operate
o Manufacturer’s operating and maintenance procedures;
o Hand signals and/or other requirements set by El Eman Construction Est. (ELEMAN).

Records - The maintenance program must contain a recording system. Part of this system should be made up of
inventories and schedules. In addition, the recording system should document what maintenance work was done,
when, and by whom.

Monitoring - The monitoring functions in a maintenance program fall into two areas. First, the staff responsible for
operating and/or maintaining equipment must monitor that equipment to ensure that appropriate checks and
maintenance are done. Secondly, management must monitor the entire program to ensure that it is functioning in
accordance with company policy.

Scheduled Inspections and Maintenance - All mobile equipment is to be inspected and maintained according to the
following Equipment Inspection Schedule as a minimum. Records of all inspections and maintenance are
completed and maintained for review and approval.
Maintenance of equipment, release of lubrication fluids, etc., is performed only in approved areas. Spills and leaks
from equipment are cleaned up promptly.

EQUIPMENT INSPECTION SCHEDULE

TYPE OF EQUIPMENT TYPE OF INSPECTION SCHEDULE
Complete inspection and certification Before put to work and annually
Critical items, controls, overall
Daily
functioning
Cranes - Crawler, Truck, Hydraulic,
Safety device, hooks, cables, electrical Monthly
etc.
Complete inspection Every 3 months
Repair When failure occurs
Preventative maintenance Manufacturer's recommendation
Heavy Equipment Complete inspection Before put to work
Dozers, Backhoes Complete inspection Every 3 months
Repair When failure occurs
Compactors, Trucks Preventative maintenance Manufacturer's recommendation
Operator's checklist Daily
Miscellaneous Complete inspection Before put to work
Complete inspection Every 3 months
Compressors, Welding Machines,
Repair When failure occurs
Generators
Preventative maintenance Manufacturer's recommendation
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 49 of 64

Slings, Shackles, Chokers, Lifting Deformation, cracks, corrosion, etc. Daily or before each use
Devices Regular inspections of all devices Every 3 months

Pre-Operation Checks
• Walk around checks on all pieces of mobile equipment are necessary to ensure the unit is safe to operate
both from the personnel standpoint and for the equipment; that is, all fluids must be at the correct level
and all components must be intact.
• Check for personnel in the cab area and around the equipment. Before the operator commences the pre-
start checks, the operator should check the cab area for other operators and others who may be working
around the equipment.
• Visual check - The operator should walk completely around the equipment looking underneath the
equipment, in the engine compartment, and in the cab.
• Brake Lines - Visually check the brake lines for leaks. Check for moisture on the brake line. Report any
leaks to maintenance for repair as soon as possible. DO NOT operate equipment with brake leaks.
• Steering Assembly - Check the tie rod ends, pins and keepers, drag links, ball joints, steering rams and
hoses; Check that all the joints are tight; Report any faulty conditions to your supervisor. Note: Never
operate a truck with faulty steering.

4.7 Emergency Preparedness

OBJECTIVES

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager

• Develop, review and implement contingency response plans and procedures
• Ensure employees are aware of contingency plans through training
• Monitor effectiveness of contingency plans

Site Manager and Supervisors

• Responsible for ensuring necessary assets are made available for all contingency procedures
• The implementation of the contingency procedures or plans for their facility.

Employees
• Follow all contingency procedures or plans
• Through the Joint Health and Safety Committee reviewing and revising as required the emergency
response plans.

4.7.1 Preparedness Requirements

Each El Eman Construction Est. (ELEMAN) worksite shall have contingency plans that identify the potential for
incidents and emergency situations. Refer to the El Eman Construction Est. (ELEMAN) Emergency Response
Program.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 50 of 64

These shall include, as a minimum:

• Plans for responding to an emergency that may require a need for rescue or evacuation is found.
• Plans to address thermal exposure of heat and cold
• Plans to address workplace violence
• Plans to address working alone
• Plans to address severe weather
• Plans to address medical emergencies
• Plans to address any other known or potential emergency
Each facility shall conduct an annual routine emergency evacuation drill.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 51 of 64

5.0 CHECKING & CORRECTIVE ACTIONS

OBJECTIVES
• To identify key performance indicators (KPIs) for safety and health performance
• To have effective procedures for reporting and evaluating/investigating incidents and non-conformance
to requirements
• To establish and maintain procedures for the identification and maintenance of safety and health records
• To allow our company to review our own conformity to the El Eman Construction Est. (ELEMAN) Health,
Safety & Environmental Management System by conducting inspections

RESPONSIBILITIES
All responsibilities are identified with each of the HSEMS Checking and Corrective Actions procedures.

Through effective checking and corrective actions El Eman Construction Est. (ELEMAN) benefits by:

• Measuring success and areas for improvement within the safety and health processes
• Learning from problems and making sure we follow our own procedures
• Maintaining clear and consistent documentation

5.1 Key Performance Indicator Measuring and Monitoring

OBJECTIVES
To identify key performance indicators for safety and health performance.

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager

Reports to senior management monthly measured results of identified objectives and annual safety programs
goals.

PROCEDURE

5.1.1 Health and Safety Key Performance Indicators (KPI)

KPIs are used to determine what changes need to be made, to review individual project management success
towards compliance and to track progress towards published goals and objectives. KPI results are supplied to El
Eman Construction Est. (ELEMAN) management on a monthly basis. Safety and health KPIs are tracked for each
project manager’s responsible area and include:

• Injuries
• Days Away From Work Cases
• Restricted Work Cases; Recordable Medical Cases
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 52 of 64

• Total Recordable Injuries/Illness and Incident Rate

• First Aid Cases
• Hours Worked
• Vehicle incidents and property damage or loss
• Reportable spills
• Workers compensation data

5.1.2 Monitoring
Monitoring is conducted to confirm and check compliance with safety and health requirements and to ensure the
use and effectiveness of operational controls. Activities include:
• Annual Management Review
• Monthly Key Performance Reports
• As needed facility inspections
• Employee observations
• Incident investigations

5.2 Incidents, Reporting, Non-Conformance and Corrective Actions (Refer to Procedure No. -
ELEMAN/HSE/PR/GE/12)

OBJECTIVES
To have effective procedures for reporting and evaluating/investigating incidents and non-conformances in order
to prevent further occurrences.

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager

Ensures investigations are conducted and assists in identifying corrective actions.

Site Manager and Supervisors

• Investigates (or assists in) incident investigations
• Corrects non-conformances
• Accompanies injured employees to the medical provider for initial treatment.
• All Incident investigations will be reviewed by senior management

Employees
Immediately report any injury, job related illness, spill or damage to any property to their immediate supervisor. If
their immediate supervisor is not available the employee is then to immediately notify the project manager.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 53 of 64

PROCEDURE

5.2.1 Reporting Policy

This policy shall be communicated so all employees understand our position. The following must be reported to
the employee's supervisor immediately. If that person is not available then the El Eman Construction Est.
(ELEMAN) Safety Manager shall be immediately notified for:

• Near miss incidents with the potential to harm people, the environment or assets
• Work related injuries or illnesses; Property damage including vehicle incidents
• Hazardous chemical spillage, loss of containment and contamination
• Non-conformance to safety or environmental rules, policies or standards
• Fires, explosions, motor vehicle crashes, etc.
• Security concerns such as theft, suspicious activity, etc.
The supervisor makes the necessary notifications and begin the incident investigation process.

In the case of a major injury or incident the scene of the event should be closed off and kept "as is" at the time of
the incident. This is vital for effective incident investigation.

An authorized individual shall accompany injured employees to the medical provider for initial treatment.

5.2.2 Investigations of Incidents & Non-conformances

Investigation is an important part of an effective safety program in that it determines the root cause and corrective
actions necessary to prevent similar incidents or non-conformances.

Incident investigation occurs as soon as possible, while the facts are still fresh within the minds of those involved
(i.e. witnesses). Take the opportunity to talk to all of those involved before they become unavailable or memory
fades. An incident investigation must be thorough and concerned only with cause and prevention and must be
separate from administrative disciplinary action.

5.2.3 Incident Reporting Matrix

The Incident Reporting Matrix identifies, based on type of incident, who within corporate management shall be
verbally notified and when. It also specifies which type of report from the field shall be completed based on the
type of incident.

INCIDENT NOTIFICATION MATRIX

TYPE OF INCIDENT WHO TO NOTIFY VERBALLY WHEN INCIDENT REPORT FORM
Minor First Aid Safety Manager 24 hrs Yes
Clinic or Doctor Visit Safety Manager ASAP Yes
Hospitalization/Fatality President then Safety Manager ASAP Yes
Reportable Spill Safety Manager ASAP Yes
More than $500 Safety Manager ASAP Yes
Non-conformance Safety Manager 24 hrs Verbally Initially
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 54 of 64

5.2.4 Incident Review Team and Incident Investigation Report

When deemed necessary, the El Eman Construction Est. (ELEMAN) Safety Manager forms an Incident Review Team
that participates in the determination of a final root cause investigative incident report. The team consists of
representatives of management or other designees as assigned by the El Eman Construction Est. (ELEMAN) Safety
Manager.

The team will utilize an Root Cause Analysis (RCA) model of incident investigation. The final incident investigation
report consists of findings with critical factors, evidence, corrective actions, responsible parties, and timelines for
corrective action completion.

Results of incident investigations are communicated to employees via the Incident Notice form.

5.2.5 Field Incident Report Form

The supervisor completes the El Eman Construction Est. (ELEMAN) Field Incident Report and takes the below steps
when beginning an incident investigation.
• Provide emergency assistance, as needed and qualified for
• Secure the area as quickly as possible to retain area in the same condition at the time of the incident
• Notify management by phone according to the Incident Notification Matrix
• Identify potential witnesses
• Use investigation tools, as needed (camera, drawings, video, etc.)
• Tag out for evidence any equipment that was involved
• Interview witnesses (including the effected employee) and obtain written, signed statements and fax to
the El Eman Construction Est. (ELEMAN) Safety Manager
• Prepare El Eman Construction Est. (ELEMAN) Field Incident Report, sign the form, fax it to the El Eman
Construction Est. (ELEMAN) Safety Manager
• Implement any immediate corrective actions needed;

5.2.6 Incident Notice Form

In order to communicate incident information and lessons learned from incidents the El Eman Construction Est.
(ELEMAN) Safety Manager shall send the Incident Notice to all work sites. The form shall be posted on employee
bulletin boards and shall be discussed in weekly safety meetings until all employees at the job site have been
informed of the incident.

5.2.7 Corrective Actions

Site Managers are held accountable for closing corrective actions. Corrective actions for safety improvement input
are posted at each site and tracked by the El Eman Construction Est. (ELEMAN) Safety Manager to ensure timely
follow up and completion.

Corrective actions are also used as needed for revisions to site specific safety plans and the El Eman Construction
Est. (ELEMAN) Safety and Health Management System.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 55 of 64

All incident investigations will be brought to closure.

5.2.8 Accompanying Employees to Medical Treatment

Whenever possible an authorized individual shall accompany any injured employees to the medical provider for
initial treatment. This is to ensure the medial provider has all required information regarding the administration of
workers compensation, availability of return to work job functions available and to ensure the employee receives
the best possible medical attention.

5.2.9 Incident Classifications

Damage – Damage to personal, business or client owned property occurred.

Environmental – Damage to the environment or animal interaction occurred.

Injury – An injury to staff, contractor or client staff occurred.

Near Miss – An incident occurred that had the potential of becoming an higher level incident of actual injury,
damage, etc.

Non-conformance – A incident occurred because a safety, environmental or quality rule, policy or procedure was
not followed.

5.2.10 Injury Classifications

Injuries shall be classified per the following:

First Aid – Dressing on a minor cut, removal of a splinter, typically treatment for household type injuries.

Lost Work Day Case (LWDC) – An injury that results in an employee being unfit to perform any work on any day
after the occurrence of an occupational injury.

Number of Lost or Restricted Work Days – The number of days, other than the day of occupational injury and the
day of return, missed from scheduled work due to being unfit for work or medically restricted to the point that the
essential functions of a position cannot be worked.

Occupational Injury – An injury which results from a work related activity.

Occupational Illness – Any abnormal condition or disorder caused by exposure to environmental factors while
performing work that resulted in medical treatment by a physician for a skin disorder, respiratory condition,
poisoning, hearing loss or other disease (frostbite, heatstroke, sunstroke, welding flash, diseases caused by
parasites, etc.). Do not include minor treatments (first aid) for illnesses.

Recordable Medical Case (RMC) – An occupational injury more severe than first aid that requires advanced
treatment (such as fractures, more than one stitch, prescription medication of more than one dose,
unconsciousness, removal of foreign body embedded in eye (not flushing), admission to a hospital for more than
observation purposes) and yet results in no lost work time beyond the day of injury.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 56 of 64

Restricted Work Day Case (RWDC) – An occupational injury which results in a person being unfit for essential
functions of the regular job on any day after the injury but where there is no time lost beyond the day of injury. An
example would include an injured associate is kept at work but not performing within the essential functions of
their regular job.

Work or Work Related Activity – All incidents that occur in work related activities during work hours, field visits,
etc. are reportable and are to be included if the occupational injury or illness is more serious than requiring simple
first aid. Incidents occurring during off hours and incidents while in transit to or from locations that are not
considered an employee’s primary work are not reportable.

The following are examples of incidents that will not be considered as recordable:

• The injury or illness involves signs or symptoms that surface at work but result solely from a non-work-
related event or exposure that occurs outside the work environment.
• The injury or illness results solely from voluntary participation in a wellness program or in flu shot,
exercise class, racquetball, or baseball.
• The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for
personal consumption (whether bought on the employer's premises or brought in). The injury or illness is
solely the result of an employee doing personal tasks (unrelated to their employment) at the
establishment outside of the employee's assigned working hours.
• The illness is the common cold or flu (Note: contagious diseases such as tuberculosis, brucellosis, hepatitis
A, or plague are considered work-related if the employee is infected at work).

5.2.11 Return to Work - Light/Restricted Duty Procedure

Objectives
It is the goal of El Eman Construction Est. (ELEMAN) to return employees to meaningful, productive temporary
employment following injury or illness until their health care provider releases them to full duty.

The return to work program provides opportunities for any employee who sustains a compensable injury during
the course and scope of employment to safely return to work. If the employee is not capable of returning to full
duty, the return to work program provides opportunities for the employee to perform a temporary assignment,
either modified or alternative duty as defined below.

Definitions
Lost Time - Time spent away from work beyond the day of injury at the direction of the treating health care
provider as a result of a compensable injury sustained in the course and scope of employment. The term does not
include time worked in a temporary assignment.

Full Duty - Performance of all duties and tasks of the position for which the employee is employed. Full duty entails
performing all essential and non-essential functions of the employee's regular job.

Temporary Assignment - Performance of a temporary job assignment intended to return an injured employee to
work at less than his or her full duties when a serious injury or serious medical condition prevents the employee
from working full duty. Temporary assignments are limited to six months at the same pay, beyond six months; the
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 57 of 64

program will be reviewed in assistance of El Eman Construction Est. (ELEMAN) management to determine the next
best course of action. Temporary assignments are modified duty and alternative duty.

Modified Duty - Modified duty allows the employee to return to employment in his/her regular job and perform all
of the essential functions of the position and those nonessential duties and tasks that are within the capabilities of
the employee, given the restrictions imposed by the treating health care provider. Modified duty is a temporary
arrangement until the injured employee can resume full duty. If during the course of the modified duty
assignment or after six (6) months, whichever is sooner, it is determined that the employee has permanent
restrictions, the program will be reviewed in assistance of El Eman Construction Est. (ELEMAN) management to
determine the next best course of action.

Alternative Duty - Alternative duty allows the employee to temporarily perform the essential functions of a job and
other nonessential duties and tasks, within the restrictions prescribed by the treating health care provider, other
than the position for which the individual is employed (regular full-time position). Such alternative duty may be
physically located in the same employing department or in a hosting department. Alternative duty is a temporary
arrangement until the injured employee can resume full activities of his/her regular job or until an alternate duty
position is no longer needed.

Hosting Department – This is the department that has a temporary assignment position available but not
necessarily the employee's department.

Employing Department - Department that the employee is permanently assigned to for his/her full duty regular
job.

Prohibited Actions
This return to work program shall not be applied to any situation or circumstance in a manner that retaliates or
discriminates on the basis of race, color, sex, age, national origin, religion, or disability.

Authorization for Leave and Lost Time

An employee who must miss work due to an injury or illness must be certified by a health care provider to be off
work. It is the employee's responsibility to obtain such documentation from the health care provider and to return
it to the supervisor within one working day upon receipt. Employees will be reimbursed for any costs in obtaining
written documentation from a health care provider with a valid receipt of payment.

If the health care provider states that the employee cannot perform any temporary assignments/ modified duties,
El Eman Construction Est. (ELEMAN) may challenge the decision depending on the injury and request independent
medical information. Some El Eman Construction Est. (ELEMAN) sites have a local health care provider that
employees may be requested to visit; employees can decline without any reprisal.

Return to Work Coordination

The El Eman Construction Est. (ELEMAN) Safety Manager will assist Site Managers/ supervisors with return to work
activities/ plans for individuals who have sustained a compensable injury or illness during the course and scope of
employment.

Temporary Assignment/ Modified Work Procedures

Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 58 of 64

An employee who is absent due to an injury or illness is required to submit written verification of the injury or
illness from a qualified health care provider. Such verification must be submitted to the supervisor within one
working day upon receipt of the documentation and in compliance the appropriate local Workers Compensation
Act and El Eman Construction Est. (ELEMAN) policy.

A copy of the employee's regular job description must be supplied to the health care provider.

If the employee is unable to perform the essential functions of his/her regular job, a temporary Modified Work
Plan is developed by the HSE Manager in consultation with operations management. The Modified Work Plan
must be completed in writing and accepted or declined by employee. The accepted or declined plan must be
forwarded to the Safety Manager which will forward a copy to the local effective Worker’s Compensation
administrator.

The employee must obtain the appropriate forms from their supervisor or the Safety Manager to be completed by
his/her health care provider at each visit or every rotation, whichever is sooner, for assessment of the employee's
ability to perform the functions of the temporary assignment/ Modified Work position offered and accepted.

An employee who chooses not to continue a temporary assignment/ modified job must notify the
employing/hosting department and/ or Safety Manager immediately in writing. An employee who fails to accept a
local workers compensation administrator’s approved temporary assignment/ modified work job and abandons
his/her job may be subject to disciplinary action including termination.

The period of temporary assignment is limited to a maximum period of six (6) months from the beginning date of
the temporary assignment, or the duration of the medical condition, whichever ends first. The employee shall
perform the duties of the temporary assignment for the term of the assignment or until the employee is able to
return to full duty, whichever is sooner. The employing department is expected to provide temporary
assignment/modified work jobs.

Employee Reporting Responsibilities

An employee who is a candidate or participant in a modified or alternative duty temporary job assignment under
the Return to Work program is responsible for reporting to Workers Compensation carrier any employment or
income earned while performing modified or alternative duty if required by the Workers Compensation carrier.

An employee participating in the Return to Work program must provide his/her supervisor with medical
documentation accounting for all absences due to the injury/illness within one day of any absence from work, or
face disciplinary action, up to and including termination.

Non-Retaliation
Retaliation against an individual for in good faith filing a request or making a claim under this or related policies,
for instituting or causing to be instituted any proceeding under local regulatory guidelines or federal anti-
discrimination or anti-retaliation laws, for testifying in an investigation or proceeding, or for otherwise opposing
discriminatory or retaliatory actions or practices will not be tolerated. Retaliation by any El Eman Construction Est.
(ELEMAN) employee is a violation of this policy. Individuals who believe they are the victim of discrimination or
retaliation and those who suspect discrimination or retaliation should report the matter to their immediate
supervisor, the head of their department or the Human Resources Department.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 59 of 64

Nothing in this procedure should be interpreted as requiring an individual to report suspected acts of
discrimination or retaliation to the individual he or she believes is engaging in discriminatory or retaliatory
conduct.

5.3 Records and Records Management

OBJECTIVES
• To ensure key records are properly filed and readily accessible
• To ensure regulatory records are retained for the applicable regulatory requirement periods
• To ensure key records are removed from files and destroyed when the applicable retention period is
reached

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager

Identifies safety and health records; identifies record storage location and retention requirements and identifies
records to be destroyed.

PROCEDURE

5.3.1 Access to Medical Records

Safety and health records will be identified by the El Eman Construction Est. (ELEMAN) Safety Manager and are
maintained based on legal, regulatory and business requirements.

The Safety Manager will maintain applicable medical and exposure records for all employees. All requests to access
medical and exposure records and analysis based on those records must be submitted to using the forms provided
for that purpose.

The Safety Manager will assure access of each employee and/or their designated representative, to all exposure
and medical records concerning the employee's work conditions or workplace within 15 working days from the day
request is made. If the records cannot be provided within 15 working days, the employee or designated
representative requesting the record shall be informed with the reason(s) for the delay and the earliest date when
the record(s) can be made available.

Except for a recognized collective bargaining agent, any designated representative must have the employee's
written permission for access to exposure records and analyses. It is necessary however, for the union
representative to specify the occupational need for access to records absent the employees consent. Union
representatives must have the employee's written permission to access medical records.

Employees or their representatives will be provided with one copy of the records at no cost or free use of a
copying machine. There will also be no charge for the first request for information by a recognized collective
bargaining agent, even if the employee has previously received a copy of the same record. Additional copies will
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 60 of 64

be provided at a cost of five cents per copy. Each copy provided will be stamped with the word COPY. At no time
will original records and/or x-rays be loaned out to enable the requesting party to make a copy.

The authorized physician, nurse or other responsible health care personnel maintaining employee’s medical
records may delete the identity of anyone who has provided confidential information concerning the employee's
health status but cannot withhold the information itself.

When an analysis of medical records identifies the employee, a physician may remove direct or indirect personal
identification. If this cannot be done, the personally identifiable portions need not be provided to the person
seeking such information.

Employees and their designated representatives will be permitted upon request access to past and present
exposure data to toxic substances or harmful physical agents.

Copies of exposure records of other employees with past or present job duties or working conditions like or similar
to those of the employee will also be provided upon request.

Any employee or designated representative is also permitted access to any record of exposure information which
pertains to a new workplace or condition(s) to which the employee is being assigned or transferred.

5.3.2 Records Filing and Accessibility

Safety and health records shall be legible, identifiable and traceable to the activity, product or service involved.
The records shall be stored in identified secured locations and maintained in such a way that they are readily
retrievable and protected against damage, deterioration or loss.

5.3.3 Key Records Retention

The El Eman Construction Est. (ELEMAN) Safety Manager reviews records files annually to determine which records
are to be destroyed, considering safety and health records that have met their retention period.

KEY RECORDS RETENTION SCHEDULE

RECORD STORAGE
RECORD NAME RETENTION
LOCATION
Incident Investigation Documentation 10 years Site/Safety Manager Office
Safety Inspection Checklist 5 years Site/Safety Manager Office
Management Of Change Records 5 years Site/Safety Manager Office
Corrective Actions Tracking Log 5 years Site/Safety Manager Office
Training Records 5 years Site/Safety Manager Office
Physical Exam & Medical Records 30 years Human Resources & Storage
Incident Notices 5 years Site/Safety Manager Office
Safety Observation Forms 2 years Site/Safety Manager Office
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 61 of 64

Hazardous Chemicals Inventory List 5 years Site/Safety Manager Office

Site Specific HSE Plans 5 years Site/Safety Manager Office
Weekly Safety Meeting Form 2 years Site/Safety Manager Office
Management Review Meeting Minutes 5 years Site/Safety Manager Office

5.4 Inspections

OBJECTIVE
To provide a method to review and verify compliance with the El Eman Construction Est. (ELEMAN) HSEMS.

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager

• Ensures inspections are conducted
• Develops the inspection schedule and scope
• Communicates inspection findings
• Verifies non-compliance and non-conformance areas are corrected
• Tracks inspection findings and communicates progress toward closure of findings

Site Manager and Supervisors

• Develops and implements corrective and preventive action for deficiencies
• Tracks inspection findings until the responsible party has corrected the deficiencies
• Conducts monthly site safety inspection

PROCEDURE

5.4.1 Formal Annual Inspection

The El Eman Construction Est. (ELEMAN) Safety Manager or his designee conducts formal inspections (scheduled
or unannounced) no less than once per year per location.

5.4.2 Routine Site Inspection

Every quarter the senior staff member at each job conducts a site safety inspection using the El Eman Construction
Est. (ELEMAN) Safety Inspection Checklist. The completed inspection checklist is sent to the El Eman Construction
Est. (ELEMAN) Safety Manager with a copy to the appropriate project manager.

5.4.3 Conducting Inspection

The inspector completes the El Eman Construction Est. (ELEMAN) Safety Inspection Checklist form for each
inspection by interviewing people, reviewing records and touring the site.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 62 of 64

An inspection closeout meeting is held between the inspector and appropriate site personnel to review
information and identify areas of non-conformance.

Findings are communicated to the appropriate project manager and El Eman Construction Est. (ELEMAN) Safety
Manager by sending a copy of the checklist to these positions.

5.4.4 Corrective and Preventive Actions

Non-conformances are corrected and are the primary responsibility of the appropriate project manager and will be
monitored by the El Eman Construction Est. (ELEMAN) Safety Manager.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 63 of 64

6.0 MANAGEMENT REVIEW

OBJECTIVES
• To ensure continuing suitability, adequacy and effectiveness of the HSEMS
• To address needs for changes to our policy, objectives and other elements of the HSEMS
• To identify opportunities for continual improvement

RESPONSIBILITIES

El Eman Construction Est. (ELEMAN) Safety Manager

• Reviews safety and health compliance status and HSEMS effectiveness with top management
• Updates the HSEMS where appropriate based on decisions made in the Management Review
• Implements changes identified in the management review process and resource assessment

PROCEDURE

6.1.1 Safety Management System Review

The El Eman Construction Est. (ELEMAN) HSEM Management System is reviewed at least annually by the El Eman
Construction Est. (ELEMAN) Safety Manager to evaluate its success in meeting the goal and objectives for safety
within El Eman Construction Est. (ELEMAN).

The El Eman Construction Est. (ELEMAN) Safety Manager maintains a record of the review. Results of the annual
review are incorporated into changes to the El Eman Construction Est. (ELEMAN) HSEM Management System
manual, site specific HSE plans or appropriate safety procedures.

6.1.2 Management Meetings

On a schedule, determined by the El Eman Construction Est. (ELEMAN) President, senior El Eman Construction Est.
(ELEMAN) management must meet at least annually and address the following subjects:

• Review of Performance (Objectives & Safety Programs)

• Corrective Actions and Inspection Review
• Safety and Health Management Resources Adequacy
• Operational Controls
• Roles and Responsibilities
• Review of Safety and Health Policy
Meeting results are documented through meeting agendas and minutes that include an executive summary and a
summary of post review action items.
Doc No: ELEMAN/ HSE/PR/GE/O1

EL EMAN HSEMS Initial Issue Date

Revision Date:
Revision No.
HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM Next Revision Date:
Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 64 of 64

SPECIFIC SAFETY PROGRAMS

REVISION STATUS

Date of Current
Ref. No. Description/ Details of Amendment
Amendment Rev. No.

13.02.2018 ----- Newly Legislated 0