HSE DEPARTMENT 5.20.

2024

Document Title:

HSE ASSURANCE PLAN

Rev.# Date of Description of Revision Prepared Approved

Revision
0 5.20.2010 Initial release

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 HSE DEPARTMENT 5.20.2024

Note:

This document is a controlled copy of the Lubrik Construction Company Ltd Safety Management
System. Any copies made of this document are uncontrolled and are therefore not subject to review and
further approval.

This document will be reviewed on an annual basis, at a minimum, to ensure its continued
appropriateness and effectiveness.

Document Title:

HSE ASSURANCE PLAN

TABLE OF CONTENTS

PURPOSE………………………………………………………………………………………………… 3

OBJECTIVE…………………………………………………………..…………………………………. 3
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 HSE DEPARTMENT 5.20.2024
DOCUMENT AND DATA CONTROL………………………………………………………………… 3

1. GENERIC RISK ASSESSMENT……………………………………………………………….

2. TASK RISK ASSESSMENT……………………………………………………………………

3. SCHEDULED TOOL BOX TALK……………………………………………………………..

4. WORKPLACE SAFETY AUDIT……………………………………………………………..

5. SAFETY REPORT……………………………………………………………………………

6. SAFETY MANAGEMENT SYSTEM REVIEW ……………………………………………

7. SAFETY MEETING…………………………………………………………………………..

8. STEERING COMMITTEE MEETING………………………………………………………

9. HSE GROUP MEETING…………………………………………………………………….

10. SAFETY ALERT……………………………………………………………………………..

11. FIRE DRILL RECORD……………………………………………………………………..

12. FIRE ALARM TEST RECORD……………………………………………………………

13. FOOD HYGIENE INSPECTION………………………………………………………….

14. ACTION TRACKING SYSTEM…………………………………………………………….

15. BEHAVIOURAL OBSERVATION SAFETY PROGRAM………………………………….

16. GOLDEN RULES OF SAFETY……………………………………………………………….

17. “FIVE STAR” SAFETY SYSTEM………………………………………………………………

18. SUMMARY OF ACTIVITIES……………………………………………………………………

FILE MAINTENANCE GUIDANCE

Document Title:

HSE ASSURANCE PLAN

PURPOSE

Purpose of this procedure is to determine procedures for controlling all documents, data and
provide guidance for scheduled and regular activities to be performed, which implement,

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 HSE DEPARTMENT 5.20.2024

proactively monitor and provide a documented basis for objective review the system by which
the health and safety of all company employees is managed.

This plan comprises the system by which the implementation, monitoring and review processes
are managed to meet the requirements of the company’s health and safety policy.

OBJECTIVE

The objective is to provide the means to encourage operational and supporting managers and
supervisors to develop implement and objectively review actions to promote the effective
management of the health and safety of its employees and others potentially at risk as a result of
our actions.

To enable this objective to be realized, all management and supervision will participate in a
program of training, risk assessment, legal compliance, audits and verification of corrective
actions that will proactively generate a positive accident and incident prevention culture capable
of delivering exceptional results and being continuously improved.

DOCUMENT AND DATA CONTROL

1. GENERIC RISK ASSESSMENT (LCC SF 004)

1.1. Generic Risk Assessments for all kinds of activities will be performed for all operations
by the team consisting of supervisors, workers involved in task and safety
representatives prior to start of contract or job.
1.2. Generic Risk Assessment will identify site-specific hazards and actions required to
control the perceived risks to a level that is as low as is reasonably practicable (ALARP).
1.3. Generic Risk Assessments shall be recorded on form RO-TRA SF.
1.4. Generic Risk Assessments’ records shall be held in the Section 1 of Safety File.

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HSE ASSURANCE PLAN

1.5. The Supervisor will carry out a Toolbox Talk for employees on site based on the results
of the Risk Assessment.
1.6. Toolbox Talks shall be recorded on form LCC SF 004.
1.7. Generic Risk Assessments will be reviewed quarterly due to any changes in work
processes.

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2. TASK RISK ASSESSMENT (LCC SF 004)

2.1. Task Risk Assessments will be carried out to assess the risks associated with specialized
tasks or due to any changes to routine operation process.
2.2. The Supervisor shall give a Toolbox Talk to those about to perform the work based on
the results of the Task Risk Assessment.
2.3. Task Risk Assessments shall be recorded on Form LCC SF 004.
2.4. Task toolbox talks shall be recorded on LCC SF 001.
2.5. Task Risk Assessments’ records shall be held in the Section 2 of Safety File for 48
hours. After that hard copies shall be removed but electronical copies shall be kept for
information and learning purposes.

3. SCHEDULED TOOL BOX TALK (LCC SF 001)

3.1. The Supervisor shall give a safety-related toolbox talk every day, before start of each
shift, to those employees in his direct charge.
3.2. The subject matter for toolbox talk may be based on the library of toolbox talks, on
recent Safety Alerts, management guidance, or other relevant health and safety related
topic.
3.3. Additional toolbox talk shall be conducted due to any changes to routine operation
process.
3.4. Toolbox talks shall be recorded on Form LCC SF 001.
3.5. Toolbox talks’ records shall be held in the Section 3 of Safety File.

4. WORKPLACE SAFETY AUDIT (WSA) - (LCC SF 003)

4.1. Workplace Safety Audit (WSA) is used to:

 Identify nonconformities and deviations through making an examination of work

processes and agree necessary measures to improve safe work performance

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HSE ASSURANCE PLAN

 Identify gaps in work processes through talking and discussion with workforce and
determine measures to improve safe work performance.
4.2. Check-list LCC SF 005 is designed to facilitate in audit process.
4.3. WSA shall be carried out by team consisting of Managements’ representative, HSE
technicians, supervisors and/or employee representatives.

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 HSE DEPARTMENT 5.20.2024

4.4. For any deviation discovered during WSA required actions, responsible persons and
target dates shall be determined. Any action which is not sorted out by target date must
be included into Action Tracking System (ATS).
4.5. WSA shall be performed on a monthly basis. The reports shall be copied to and
discussed with the company management and site supervision.
4.6. WSA shall be recorded on Form LCC SF 003.
4.7. WSA records shall be held in the Section 4 of Safety File.

5. SAFETY REPORT (LCC SF 002)

5.1. Any accident, HIPO, near miss, first aid case, and non-conformance occurred or
discovered during work process shall be reported.
5.2. Reports shall be recorded on Form LCC SF 002 Safety Report.
5.3. Report shall clearly define root causes and determine corrective actions to prevent
reoccurrence. Proposed actions shall be done by person who made report. These actions
shall be agreed with area or performing authority and agreed completion date must be
determined.
5.4. Any action which is not sorted out by target date must be included into Action Tracking
System (ATS).
5.5. Safety Reports shall be observed at least monthly by HSE Manager to verify follow up
and close out details.
5.6. Safety Reports shall be kept in the Section 5 of Safety File.

6. SAFETY MANAGEMENT SYSTEM REVIEW (LCC SF 009 )

6.1. Managers must review Safety Management System (SMS) every year to ensure its
continuing suitability, adequacy and effectiveness.
6.2. SMS review is based on information and recommendations collected from HSE audits,
observations, reports and meetings.
6.3. SMS review shall address required actions, responsible persons and target dates.
6.4. SMS review shall be recorded on Form LCC SF 009.

Document Title:

HSE ASSURANCE PLAN

6.5. SMS review shall be kept in the Section 6 of Safety File.

7. SAFETY MEETING (LCC SF 011)

7.1. Safety Meetings with participation of all employees shall be held not less than once per
month. On the meetings shall be discussed safety issues and done recommendations.

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Recommendations shall be included either into agenda of Steering Committee meetings

or Action Tracking System.
7.2. The minutes of meeting shall be recorded on Form LCC SF 011.
7.3. Safety Meeting’s minutes shall be held in the Section 7 of Safety File.

8. STEERING COMMITTEE MEETING (LCC SF 033)

8.1. The Steering Committee meeting shall be convened monthly, chaired by Operations
Manager.
8.2. Recommended committee mix is as follows:
Operations Manager – Chairman
HSE Manager
Fabrication Manager
Member of the Administrative Staff
Supervisor
Employee representative
8.3. Meeting’s agenda shall consist of data and recommendations from Action Tracking
System and Safety Meeting.
8.4. The Chairman may accept any relevant topic for discussion and resolution brought
forward by any committee member.
8.5. Steering Committee Meeting shall be recorded on Form RO SF 033.
8.6. The minutes shall be held in the Section 8 of Safety File and copies shall be issued to all
committee members.

9. HSE GROUP MEETING (LCC SF 032)

9.1. Health, Safety & Environment (HSE) Group Meeting is chaired by the Director and
meets annually. Senior representatives from each department and Safety Manager attend
this meeting. Its purpose is to oversee the established policies and to review
implementation of these policies.
9.2. Those attending the meeting shall be provided with a copy of the meeting minutes.

Document Title:

HSE ASSURANCE PLAN

9.3. HSE Group Meetings shall be recorded on Form RO SF 032.

9.4. HSE Group Meetings’ records shall be held in the Section 11 of Safety File.

10. SAFETY ALERT (LCC SF 018)

10.1 Safety Alerts shall be issued by the HSE department to provide helpful information on the
avoidance of accidents, incidents or any other health and safety related matters of concern.

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10.2. Safety Alerts shall be given the widest possible circulation and shall form a specific part of all
toolbox talks, daily team briefings, Supervisor’s Group meetings and the Safety Committee
meetings.
10.3. Safety Alerts shall be recorded on Form RO SF 018 and held in the Safety File.
[Link] Alerts shall be held in the Section 12 of Safety File.

11. FIRE DRILL RECORD (LCC SF 007)

[Link] Drill must be performed at each operational location each year to test the warning and personnel
evacuation arrangements.
11.3.A record of the drill must be recorded by the HSE Manager on Form LCC SF 007.
[Link] Drill record shall be held in the Section 13 of Safety File.

12. FIRE ALARM TEST RECORD (LCC SF 008)

[Link] alarm shall be tested weekly to ensure its working conditions.

12.3.A record of the test must be recorded by the HSE Representative on Form RO SF 08.
[Link] Alarm record shall be held in the Section 14 of Safety File.

13. FOOD HYGIENE INSPECTION (LCC SF 019)

[Link] hygiene inspection shall be carried out at least once per month to provide assurance or catering
service.
13.3. LCC SF 019 shall be used to record inspections.
13.4.A copy of inspection record shall be held in the Section 15 of Safety File.

14. ACTION TRACKING SYSTEM

14.2. All findings from audits, inspections, safety reports, etc. shall be gathered to the Safety
Department for input into the Action Tracking System. If any action can’t be sorted by
target date pointed in original data it shall be included into Action Tracking System for
further consideration by Steering Committee. The system will record action

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HSE ASSURANCE PLAN

number, description, location, date identified, originator, source, responsible person,
target completion date, status and priority.
14.3. LCC SF 024 shall be used to record actions and held in the Section 16 of Safety File.

15. BEHAVIOURAL OBSERVATION SAFETY SYSTEM (B.O.S.S.)

15.2. BOSS is about the identification and reinforcement of positive behaviors and the
correction of unsafe conditions or unsafe behaviors. The BOSS observation categories are:

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 Communications
 Confined space entry
 Driving Standard
 Emergency Procedures
 Energy Isolation
 Environmental
 External Site Safety talks
 Ground Disturbance
 Health
 Home HSE
 Housekeeping
 Lifting
 Management of Change
 Manual Handling
 Office
 Permit to Work
 PPE
 Positions of People
 Procedures
 Process Safety
 Road Crossing
 Security
 Stair code
 Tools & Equipment
 Travel HSE
 Trip, Slip, Fall Hazards

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HSE ASSURANCE PLAN

 Visitors
 Working at heights

15.3. BOSS cards will be available in all LUBRIK CONSTRUCTION COMPANY LTD sites.
15.4. BOSS cards will be gathered by HSE Department and BOSS cards observations will be
submitted each month for consideration of Steering Committee.

16. GOLDEN RULES OF SAFETY

LUBRIK CONSTRUCTION COMPANY LTD utilizes eight Golden Rules of Safety. In

accordance with these everyone is responsible for their safety and the safety of those around
them.
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Golden Safety Rules are fundamental elements in risk management strategy and will be strictly
enforced to ensure the safety of our people and our communities.

Senior Management is accountable for communicating, training, implementing, and auditing

these rules to assure compliance and performance. These rules are the essential part of induction
training given to every LUBRIK CONSTRUCTION COMPANY LTD employee.

Golden Rules are the mandatory minimum risk control measures that must be applied to the
following work activities before the task commences.

1. Permit to Work
2. Energy Isolation
3. Ground Disturbance
4. Confined Space
5. Working at Heights
6. Lifting Operations
7. Vehicle Safety
8. Management of Change

17. “FIVE STAR” SAFETY SYSTEM

A key element in any Assurance Plan is to establish and maintain a means of monitoring worker
behavior and compliance with HSE requirements. While BOS provide such a means, it is
primarily based on scheduled but periodic audit rather than continual monitoring. In order to
introduce such an element of continual monitoring of behavior and compliance into the HSE
Assurance Plan, the Five Star Safety system was (introduced on the AIOC Sangachal Terminal
Expansion Project on 1st April 2002) utilized by Lubrik Construction Company.

Document Title:

HSE ASSURANCE PLAN

Through the “Five Star” system, the project has created an identification program for positive
safety behavior aligned with a fixed reprimanding program for HSE infringements.

The primary objectives of the “Five Star” system are as follows:

 To encourage individual for safe work performance

 Provide improved safety of the operations
 Provide clear incentive targets for all individuals
 Provide shared responsibility of all site personnel
 Provide a relatively simple scheme to operate and manage.

A comprehensive procedure detailing “Five Star” Safety system implementation and

maintenance has been developed. Key elements of that procedure are as follows:

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 “Five Star” Safety system objectives.

 Who participates in the “Five Star” Safety system?
 “Five Star” Safety system procedure.
 Recommended guidelines for safety offences.
 Recommended guidelines for a reward structure.

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Document Title:

HSE ASSURANCE PLAN

SUMMARY OF ACTIVITIES

Paragraph & Form No. TITLE FREQUENCY

1 (LCC SF 004) Generic Risk Assessment Before job starts

2 (LCC SF 004) Task Risk Assessment Specific tasks &

new/changed task
3 (LCC SF 001) Tool Box Talks Daily
4 (LCC SF 003) Workplace Safety Audit (WSA) Monthly
5 (LCC SF 002) Safety Report As required
6 (LCC SF 009) Safety Management System Review Annually

7 (LCC SF 011) Safety Meeting Monthly

8 (LCC SF 033) Steering Committee Meeting Monthly

9 (LCC SF 032) HSE Group Meeting Annually

10 (LCC SF 018) Safety Alert As required

11 (LCC SF 007) Fire Drill Record Annually

12 (LCC SF 008) Fire Alarm Weekly

13 (LCC SF 019) Food Hygiene Inspection Monthly

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 HSE DEPARTMENT 5.20.2024

HSE ASSURANCE PLAN

FILE MAINTENANCE GUIDANCE

OBJECTIVE

The Safety File contains the evidence and information that helps us to achieve the Objective and
enables us to demonstrate that we and our parent companies regard the safety of our operations
to be a pre-requisite of doing business.

ORGANISATION OF SAFETY FILE

The filing system shall comprise 13 sections, preceded by a copy of the Safety Policy and the
Safety Arrangements (this document). The system may be formed from either a dedicated drawer
in a filing cabinet with hanging folders or several large lever arch files, but either way they must
be in the right order and freely accessible.

LOCATION SAFETY FILES

It is recognized that it may be necessary for Safety Files to be set up at each location or site
where the company is engaged in its normal business activities. Such Safety Files will only be
set up as a result of an analysis of the safety management considerations prior to commencement
of the work.

FILE NOTES

If an element or section does not apply or documents need to be filed elsewhere, it is

recommended that a note is made, signed and dated and placed in the appropriate section of the
safety file. This provides evidence that the system is being properly followed.

OBSOLETE DOCUMENTS

Obsolete documents and data must be promptly removed from all points of issue and points of
use or otherwise assured against unintended use.

ARCHIVAL DOCUMENTS

All documents and data shall be kept in the safety file for current year. In the end of each year all
documents and data must be reviewed for close out details and put to archive. Where electronic
versions of documents and data exist hard copies shall be kept for one year and then removed.
Electronic versions of all documents shall be kept in folder “Archive”.

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 HSE DEPARTMENT 5.20.2024

HSE ASSURANCE PLAN

GUIDE TO SAFETY INPUTS

OVERVIEW

In addition to the measurement tools already discussed (Site Audits, Inspections, BOSS, etc)
there are other categories of Safety Input, which are also actively monitored, measured and
reported.

Near Miss Reports and Safety Training Hours are two Safety Inputs that will also be used. Over
time, it is the intention of the organization to link our safety performance reporting even more
closely to the processes and programs that will continue to drive our actions to proactive
prevention.

The purpose of this section of the document is to describe each safety input, the rules governing
classification including examples, and our reporting and data collection process. We intend to
make this effort as straightforward and easy to use as possible. To that end, we will also make
references to forms and tools.

NEAR MISS

A Near Miss is an undesired and unplanned event that, under slightly different circumstances,
could have resulted in harm to people, damage to assets, environmental harm or unplanned
operational shutdown. The difference between a near miss and a BOSS observation is that an
actual incident has occurred, but no one was hurt and no equipment was damaged. The following
examples illustrate near misses:

 An object drops from height, yet no one is hit.

 A worker stumbles while descending stairs but catches him/herself without injury.
 Reversing out of a parking space a driver narrowly avoids hitting a pedestrian.
 Electrical equipment is tested before maintenance and is found to still be energized.
 A trench is excavated and a power cable or pipeline is contacted that was not known to
be there.
 A Chemical Drum is knocked over yet no spillage occurs.

Given that every near miss has the potential to cause loss, they are sometimes referred to as
“Near Hit” and, imagining the consequences of such events, often provide the motivation for
ensuring that appropriate corrective and preventive actions are implemented.

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HSE ASSURANCE PLAN

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SAFETY TRAINING HOURS

Recording and Measuring Safety Training Hours provides information on the actual hours
delivered against hours planned. This allows the efficiency of training plan execution to be
evaluated and adjusted as appropriate. Current guidance is to capture all formal classroom
training that is carried out. However, some toolbox and safety meetings may count if a specific
HSE subject is covered and is being taught by a competent instructor.

In addition to the formal classroom training that is recorded, an accurate record must also be
obtained as to what is being discussed at toolbox meetings. This should include subject
discussed, how many employees were in attendance and how long the meeting lasted. A Toolbox
talk subject list has been developed and, where appropriate, we should make sure that each
toolbox meeting discusses a specific safety subject and that the person doing so is competent.

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