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March, 2003, TA

This document contains information that is confidential and proprietary to Holcim and is solely for the use of Holcim. No part of it may be circulated,
quoted, or reproduced for distribution outside Holcim without prior written approval from Holcim Corporate Occupational Health and Safety Project
Co-ordination Office. © 2002
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Table of Contents

OH&S POLICY 7

OH&S PERFORMANCE TARGETS 7

1. INTRODUCTION 8

2. PYRAMID ELEMENTS 9
2.1 A structural model for the Holcim OH&S Pyramid. 10
2.2 Why apply the Pyramid? 11

3. ROLES, RESPONSIBILITIES AND ACCOUNTABILITIES 12


3.1 Summary of Intent 12
3.2 General Comment 12
3.3 Details 13
3.4 Auditor Evidence 14

4. HAZARDOUS WORK ACTIVITIES 15


4.1 Summary of Intent 15
4.2 General Comments 15
4.3 Detailed Discussion 16
4.4 Additional Issues 22
4.5 Auditor Evidence 23

5. HAZARD IDENTIFICATION AND RISK ASSESSMENT 24


5.1 Summary of Intent 24
5.2 General Comments 24
5.3 Details 25
5.4 General Risk Controls 27
5.5 Auditor Evidence 27

6. PLANNED INSPECTIONS 28
6.1 Summary of Intent 28
6.2 General Comments 28
6.3 Discussion of topics 29
6.4 Auditor Evidence 32

7. LEGAL OBLIGATIONS 33
7.1 Summary of Intent 33
7.2 General Comments 33
7.3 Details 33
7.4 Auditor Evidence 34

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8. MANAGEMENT COMMITMENT AND PLANNING 35


8.1 Summary of Intent 35
8.2 General Comments 35
8.3 Issues to be addressed 37
8.4 Emergency Planning 38
8.5 Management Review 40
8.6 Auditor Evidence 40

9. INDUCTION AND TRAINING 42


9.1 Summary of Intent 42
9.2 Induction 42
9.3 Training 43
9.4 Training Review 44
9.5 Auditor Evidence 44

10. INCIDENT INVESTIGATION AND CORRECTIVE ACTION 45


10.1 Summary of Intent 45
10.2 General Comments 45
10.3 Incident Investigation Process 46
10.4 Corrective Action System 49
10.5 Auditor Evidence 50

11. INDUSTRIAL HYGIENE AND MONITORING 51


11.1 Summary of Intent 51
11.2 General Comments 51
11.3 Workplace Monitoring 51
11.4 Health Monitoring 52
11.5 Auditor Evidence 52

12. EMPLOYEE COMMUNICATION AND INVOLVEMENT 53


12.1 Summary of Intent 53
12.2 General Comments 53
12.3 Details 54
12.4 Auditor Evidence 55

13. INFORMATION AND REPORTING 56


13.1 Summary of Intent 56
13.2 Details 56
13.3 OH&S Manual 57
13.4 Records 58
13.5 Design Information 58

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13.6 Reporting 59
13.7 Auditor Evidence 59

14. SAFE WORKING PROCEDURES 60


14.1 Summary of Intent 60
14.2 Task Analysis 60
14.3 Auditor Evidence 61

15. INSPECTION AND TESTING 62


15.1 Summary of Intent 62
15.2 General Comments 62
15.3 Inspection Topics 62
15.4 Critical Parts and Equipment 64
15.5 Auditor Evidence 65

16. DESIGN SAFETY 66


16.1 Summary of Intent 66
16.2 General Comments 66
16.3 Details 67
16.4 Auditor Evidence 68

17. AUDIT AND SYSTEM IMPROVEMENT 69


17.1 Summary of Intent 69
17.2 General Comments – Internal Audit 69
17.3 General Comments – External Audit 69
17.4 Auditor Evidence 70

18. OCCUPATIONAL REHABILITATION 71


18.1 Summary of Intent 71
18.2 Rehabilitation 71
18.3 Auditor Evidence 71

19. PROCUREMENT 72
19.1 Summary of Intent 72
19.2 General Comments 72
19.3 Details 72
19.4 Auditor Evidence 73

20. MANAGEMENT OF CHANGES 75


20.1 Summary of Intent 75
20.2 General Comments 75
20.3 Details 76

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20.4 Auditor Evidence 76

21. HEALTH AND WELLNESS ISSUES 77


21.1 Summary of Intent 77
21.2 Employee Assistance Program 77
21.3 Other Issues 77
21.4 Auditor Evidence 77

APPENDICES
A1 Risk Management Methodology 74
A2 Management of Changes Form 89
A3 Example Emergency Plan 92
A4 OH&S Definitions 102

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OH&S Policy:

We provide healthy and safe workplaces by striving for zero risk to our
employees, contractors and visitors.

We apply OH&S standards and guidelines, provide the necessary


resources and training, and measure performance.

OH&S Performance Targets:

Zero deaths or injuries causing permanent disablement annually

A Lost Time Injury Frequency Rate of <five achieved annually

A Lost Time Injury Severity Rate of <60 achieved annually

We strive for continual improvement in the actual results we achieve, with a


long-term goal of zero harm to people

… and a green OH&S pyramid in all Group companies by end 2005.

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1. INTRODUCTION
U

The Holcim Executive Committee (Exco) has clearly stated as a goal that the Group companies
achieve “accepted good practice” with respect to Occupational Health and Safety (OH&S)
performance.

To achieve this goal a Holcim OH&S Pyramid has been established. The purpose of this
Pyramid, its elements (blocks) and associated documentation, is to indicate the key
requirements within each of these elements for establishing “accepted good practice” in OH&S
Management System performance.

Because of historical circumstances, companies in different countries have developed


approaches to OH&S management in different manners. It is important that any Group wide
OH&S Management System establishes clear guidelines regarding what must be achieved, so
that as a minimum requirement can be reached. However, at the same time, it is important that
the approach is not prescriptive, requiring companies to unnecessarily revise existing practices
and existing work and effort, i.e. the approach should be to indicate what must be achieved by
each Group company, but still leave the details of how they achieve it to them individually.

The purpose of this Handbook ç is to clearly establish the minimum level for the outcomes that
P P

must be achieved for a site to achieve “accepted good practice” in OH&S management. This
document is structured in a manner so that for each of the elements within the Pyramid
The goals that must be achieved are identified,
Some guidance is given regarding key implementation issues,
The evidence that an auditor would expect to find is identified.

Nevertheless, it is still left to the individual companies to determine what methodologies,


systems, etc. they will choose to adopt in order to achieve these goals. The effect of this
approach is to minimise any rework effort for sites, but also to provide the basis for a direct
comparison between the level of performance and achievement at different sites.

AKNOWLEDGEMENT: Dr. W.G. Danaher of Risk Management Intercontinental (Brisbane, Australia) prepared the first version
of this Handbook. A multi-functional Working Group representing a cross-section of Holcim business units worldwide, led by
Ted Anderson, did subsequent versions.

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THE HOLCIM OH&S PYRAMID

Health &
Legend
Wellness
Issues Implementation
isPlanned
planned

Occupational Management
Procurement
Rehabilitation of Changes Implementation
hasBegun
started

Audit and
Safe Working Inspection Design Fully
System
Procedures & Testing Safety implemented
Improvement

Incident Industrial Employee


Induction Information
Investigation & Hygiene & Communication
& Training & Reporting
Corrective Action Monitoring & Involvement

Roles Hazard
Management
Responsibilities Hazardous Work Identification Planned Legal
Commitment
and Activities and Risk Inspections Obligations
& Planning
Accountabilities Assessment

2. PYRAMID ELEMENTS

The elements within the Pyramid are:

People Related:
Roles, Responsibilities and Accountabilities, Hazardous Work Activities
Hazard Identification and Risk Assessment, Induction and Training
Incident Investigation and Corrective Action, Safe Working Procedures,
Occupational Rehabilitation

Process Related:
Industrial Hygiene and Monitoring, Planned Inspections
Audit and System Improvement, Inspection and Testing
Management of Changes, Design Safety, Procurement

Management Related:
Management Commitment and Planning, Legal Obligations
Employee Communication and Involvement, Information and Reporting

A Link to CSR:
Health and Wellness Issues

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2.1 A structural Model for the Holcim OH&S Pyramid

Health &
Wellness
Issues

MANAGEMENT

Information
& Reporting

PROCESS
Occupational
Procurement
PEOPLE

Rehabilitation

Legal Employee
Obligations Communication
& Involvement
Safe Working
Design
Procedures
Safety
Management
Commitment
& Planning
Induction Incident
Inspection Management
& Training Investigation &
& Testing of Changes
Corrective
Action

Roles Hazardous Hazard Industrial Planned Audit and


Responsibilities Work Identification Hygiene & Inspections System
and Activities and Risk Monitoring Improvement
Accountabilities Assessment

The initial assessment of any Group company OH&S management system against the pyramid will
identify where the areas with the most improvement possibility exist. Addressing these can then be
prioritized on the basis of a risk assessment to decide which have the biggest potential threat to
control/opportunity to realize. In general terms, lower blocks in the three subdivisions should be
addressed at the same time and are likely to need to be dealt with before those higher up.

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2.2 Why apply the Pyramid?

The overall objective of implementing all of the blocks within the Holcim OH&S Pyramid is to provide an
OH&S Management System that is capable of delivering healthy and safe workplaces. This is
measured against the Targets for OH&S performance and, when all the blocks of the Pyramid are fully
implemented, this will be evidence of the application of OH&S standards and guidelines, provision of
the necessary resources and training, and measurement of performance. Individual Group companies
will grade their accomplishment in relation to each Pyramid block according to the scale. This grading
will be verified:

Initially in a verification process; and


In ongoing reviews from time to time; that are
Done by persons from outside that company.1 TP PT

Any company that cares about it's people and the management of health and safety in all its forms will
likely not only become an employer of choice, but also enhance it's reputation with it's stakeholders.
Hence, Group companies must be able to demonstrate that their activities are being conducted in such
a way as to provide healthy and safe workplaces while striving for zero risk to employees, contractors
and visitors.

1
TP PT eg. The Holcim Group OH&S Co-ordinator - Other Group company OH&S Co-ordinator - Other 3rd party - Or a
team made up from these people.

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3. ROLES, RESPONSIBILITIES AND ACCOUNTABILITIES


U

3.1 Summary of Intent

Each Group company must ensure that appropriate organizational structures are put in place to
manage OH&S, and there is an appropriate allocation of responsibility and accountability to all
personnel within the organization to ensure successful functioning of the OH&S Management
System.

Group companies must maintain, as a basic principle, that their activities will be conducted in
such a way as to provide healthy and safe workplaces, and to strive for all operations to expose
employees, contractors and visitors only to levels of risk that are as low as reasonably
achievable.

Management commitment is an integral part of establishing an OH&S Management System.


One way in which management commitment can be demonstrated is through appropriate
organizational structures, and allocation of responsibility and accountability to key personnel
within the organization.

This element of the Pyramid addresses such matters, and addresses also the importance of
including annual review of OH&S management performance as part of each employees
performance review; eg. including it in employee Dialogue or the equivalent local Personal
Performance Management Program.

3.2 General Comment

Effective OH&S management occurs if persons at all levels within an organization are seen to
be responsible for relevant aspects of OH&S management. Therefore, it is expected that:
There will be an OH&S responsibility and accountability system for personnel
at all levels in the organization, eg. job/position descriptions or task statements
The system will specify OH&S responsibilities and accountabilities for all
personnel commensurate with their level within the organization
Selection procedures will successfully match personnel to jobs
Personnel will have been clearly informed of their OH&S responsibilities
A mechanism will exist within the organization for reviewing an individual’s
performances with respect to OH&S management.
Management must ensure that responsibility and accountability for OH&S matters is seen to be
an intrinsic part of each person’s job, irrespective of their level in the organization. Therefore, it
is expected that performance requirements, or targets, for OH&S performance will be specified
for all personnel.

It is considered critical that these targets are established as both “positive” and “negative”
targets, eg. targets for injury reduction (negative), and positive targets whereby persons are
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required to actively undertake OH&S initiatives, (development of safe operating procedures,


doing site audits, involvement in hazard identification and risk assessment, etc).

It is further expected that performance with respect to OH&S will be included as part of an
annual performance review system. This system should involve annual setting of targets
pertaining to OH&S for individuals, and the subsequent review of achievement with respect to
those targets.

3.3 Details

Responsibility and Accountability System

Modern OH&S legislation is written such that obligations or duties of care are placed upon all
persons at a workplace. The system establishing OH&S responsibility and accountability; eg.
position descriptions, for all these persons should reflect the fact that everybody has some
responsibility for OH&S.

It is important that all personnel at all levels have defined responsibilities and accountabilities
for OH&S. Items that should be addressed include:
Legislative requirements;
Reporting requirements; and
Levels of authority.
Note: OH&S is not the responsibility of the OH&S Department or the OH&S coordinator. The
role of the OH&S Department or the OH&S coordinator/Officer is to provide guidance and
advice about OH&S matters. The discharge of OH&S responsibilities and the undertaking of
actions necessary to ensure OH&S at a workplace is the responsibility of all persons delegated
through the management structure at that workplace.

Performance Appraisal

Management should also evaluate the effectiveness of the performance of persons with
specific allocated responsibilities for OH&S. This evaluation of performance should be no
different to the evaluation that occurs with respect to performance in all other aspects of any
person’s responsibilities.

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Performance can be evaluated in the following manners:


Formal performance appraisal.
At management meetings.
By means of written reports.
Informal checks.
Personal communications.
Formal audits.
Incident frequency and cost analysis.
Random sampling.
Analysis of property damage.
It is only through making individuals responsible and accountable for OH&S management in
their areas of responsibility that long-term improvement of performance will occur. Note that it
is also important that management, in assigning responsibility and accountability, provides the
necessary resources and training to enable these responsibilities to be discharged.

3.4 Auditor Evidence

The following information will be sought as part of an audit.


Documented organizational structure.
Documented evidence of a safety responsibility and accountability system in
place; eg. position descriptions
Evidence that OH&S responsibilities and accountabilities are defined for all.
Evidence of a performance monitoring or review system operating.
Evidence of setting of “positive” and “negative” OH&S goals
Evidence within the performance monitoring/review system that OH&S
performance is clearly addressed and measured.

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4. HAZARDOUS WORK ACTIVITIES


U

4.1 Summary of Intent

This element has been included as one of the building blocks of the Pyramid because the
activities addressed by this element are those where there is potentially the greatest risk for
fatality or permanent disablement. The content of this element indicates the types of issues
that should be addressed, and the structures and systems that should be in place to ensure
that work permit systems are implemented and functioning effectively.

As a matter of priority, any organization serious about managing OH&S must address
the control of those areas or work practices in which there is potential risk for a fatality
or permanent disablement to occur. Work permit systems are the way to achieve this
control.

Hence the aim of this element is to ensure that the organisation has in place the systems
necessary
To identify areas requiring work permits,
To identify particular activities to which those permits must apply,
To identify the authorized personnel responsible for issuing of the permits, and
To ensure that those personnel have the appropriate competencies

4.2 General Comments

The basic purpose of a work permit system is to ensure that a higher level of checking and
control is applied to particular work activities and work practices. A work permit system aims to
provide an independent check and assessment of particular work activities to ensure that
suitable risk controls are in place.

The requirement for issuing work permits may require an assessment of risk, and therefore this
element links to “Hazard Identification and Risk Assessment”.

For Holcim sites, it is expected that a system of work permits will be in place for the following
activities:
Confined space entry
Management of ignition sources; eg. welding, cutting, brazing, etc
Excavation and digging
High voltage work
Other high-risk work activities include, but are not be limited to:
Lockout and isolation
Working at heights
Working with hazardous materials, including radiation sources

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Use of explosives
Kiln light up
Traffic and road OH&S
These activities will not require a work permit system, but will have Standard Work Procedures
(and Practices) that ensure that a higher level of checking and control is applied to them.

These lists above should not be considered exhaustive, and individual sites may have further
specific requirements that they include as well.

4.3 Detailed Discussion

Confined Space Entry

A confined space may be defined as an enclosed or partially enclosed space which

a) Is at atmospheric pressure during occupancy, and

b) Is not intended or designed primarily as a place of work, and

c) Is liable at any time to


Have an atmosphere which contains potentially harmful levels of toxic
substances/contaminants
Have an oxygen deficiency or an excess; or
Cause a person to be engulfed/buried by a material; and
d) Could have restricted means of entry and exit.

If one or more such space is found at the site, a confined space entry/work procedure must be
in place. As a minimum, the following would be expected.
A “Safe working in confined spaces procedure” be developed and implemented
at the site. It is expected that this procedure would be based upon the
requirements of internationally or nationally recognized standards.
The confined space procedure will require risk assessment to be undertaken
prior to confined space entry
The confined space procedure will require a list of persons inside the confined
space to be maintained outside the confined space
The site will undertake a survey of its activities and operations, and identify the
confined spaces present at the site. These confined spaces should be
summarized in a register and the confined spaces should be marked with
suitable signage.
The site should also undertake a survey to identify restricted spaces, i.e. those
spaces which are not automatically classified as confined spaces, but which
could become confined spaces if activities are undertaken within the space
which affects the quality of the atmosphere therein, eg. welding. A register of
restricted spaces should also be prepared.
Specific personnel should be authorized by site management to be responsible
for issuing confined space work permits. These personnel should be trained

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regarding the confined space entry system and their responsibility for issuing
confined space permits. Training and refresher training should be provided.
Personnel who are required to work within confined spaces should be trained
regarding the requirements of the permit system, and their responsibilities as
workers within a confined space. The training should include how particular
hazards identified with the tasks to be performed within the confined space
have been controlled. Training and refresher training should be provided.
A rescue capability should be in place to ensure that personnel who may be
trapped in a confined space can be rescued. Training should be provided to all
personnel who are or may be required to effect rescues within confined spaces.
This training should include use of breathing apparatus where this control is
determined necessary by the Risk Assessment process. Suitable rescue
equipment should be available. Training and refresher training should be
provided.
Control of Ignition Sources

The site should develop and implement a permit system to control ignition sources based upon
relevant international standards and practices. (Such a permit is often called a “Hot Work”
permit). This system must also take account of the requirements of the Alternative Fuels &
Raw Materials (AFR) Health & Safety Manual.2 As a minimum, the following should be in
TP PT

place:
A written Control of Ignition Sources permit system and associated forms. This
system should identify those circumstances where gas testing is required as
part of permit issue.
The site should identify and document those circumstances/locations where
Control of Ignition Sources permits will be required; eg. Flammables,
combustibles, coal, coal dust, oil, gas and all other fuels.
Specific personnel should be authorized by site management to be responsible
for issuing Control of Ignition Sources permits. These personnel should be
trained regarding the Control of Ignition Sources permit system, and their
responsibility to issue Control of Ignition Sources permits. Training and
refresher training should be provided.
Personnel who are required to work under Control of Ignition Sources permits
should be trained regarding the requirements of the permit system, and their
responsibilities as workers. Training and refresher training should be provided
All personnel who are required to do 'Hot Work'; eg. welding, cutting, brazing,
etc must be competent and possess an appropriate qualification.
Suitable fire fighting equipment must be available onsite; eg. fire barriers, fire
screens (non-combustible), fire extinguishers, hose reels, foam, water, etc
A systematic program must be in place for testing fire fighting equipment
Personnel must be trained and retrained in the use of fire fighting equipment

2
TP PT For more details on this, check on ENVIRONET on HolSpace or HGRS/CIE/ETPS albert.tien@holcim.com

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Excavation and Digging

Undertaking Excavation

Each site should develop and establish a permit system to control excavation and digging.
Unauthorized excavation and digging may damage underground services and place personnel
at risk through contact with buried electrical cables, gas lines, fuel lines, etc. As a minimum, the
following should be in place:
The site should develop and implement an excavation and digging permit
system.
Specific personnel should be authorized by site management to be responsible
for issuing excavation permits. These personnel should be trained regarding
the excavation permit system and their responsibility for issuing permits.
Training and refresher training should be provided.
Reference to site plans prior to undertaking excavation will be required as part
of the permit issue system
There must always be alternative access provided for persons who have to
cross the excavated area.
Entering Excavations

In addition to the excavation permit system discussed above, the site must also implement a
system for protecting persons entering excavations where there is potential for collapse of
walls.

Ideally this will involve a separate entry permit or equivalent system. It is essential that a
competent person inspects an excavation prior to persons entering that excavation. If
necessary, risk controls must be put in place to prevent the walls of the excavation collapsing.
In keeping with good risk management practice, attempts must be made to design the walls of
excavations in such a manner so that the potential for collapse is minimized (eg. angled walls
rather than vertical walls). Persons required to enter excavations must be trained with regard
to the content of this aspect of the Management System.

High Voltage Work

The definition of high voltage is as given by the local electrical authority but will always include
sub-station and/or plant distribution voltages. A permit system must be in place to manage
associated risks. As a minimum the following is required:
A formal written high voltage work permit system be established and
implemented.
Specific personnel should be authorized by site management to be responsible
for issuing high voltage work permits. These personnel should be trained
regarding the permit system and their responsibility for issuing high voltage
work permits. Training and refresher training should be provided.

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Personnel who are required to work under high voltage permits should be
trained and retrained regarding the requirements of the permit system and their
responsibilities as workers
Personnel operating on high voltage electrical equipment must be suitably
licensed with respect to local or international regulations. Such licenses must
be kept current and an inspection system to ensure that they are must be in
place.
Suitable OH&S equipment must be provided and maintained, and personnel
trained and retrained in its use
Lockout and Isolation

Personnel may suffer severe injuries if equipment is energized at the time that work is being
undertaken on, or in the vicinity of, the equipment. Therefore, formalized isolation and lockout
procedures are required. As a minimum, the site must ensure:
That a documented lockout and isolation procedure is developed for the site.
(This procedure may also include requirements for tagging of equipment.)
Unless totally impracticable, lockout and isolation points for key items of
equipment must be identified and documented. If necessary, retro-fitting must
occur
Specific personnel are to be authorized by site management to be responsible
for issuing lockout / isolation permits. These personnel should be trained
regarding the operation of the permit system and their responsibility for issuing
work permits. Training and refresher training should be provided.
It should be noted that the accepted international good practice requirement is that there has to be the
ability to physically lock out and isolate equipment, not simply to rely on protection of any worker by
means of an advisory tagging procedure.

Working at Heights

Work at heights greater than 1.8 meters

While not a formal requirement under a work permit system, it is now internationally considered
good practice that any persons working at a height where they could fall 1.8 meters or more
wear fall arrest equipment. Note that this specifically refers only to those situations where
persons are not protected by handrails, scaffolding, etc.

Therefore the site must ensure that there is a system in place to provide protection for those
persons who may fall a distance of >1.8 meters. This will require those personnel to be
provided with protection or suitable fall arrest equipment. Where fall arrest equipment is
provided, the persons using the fall arrest equipment must be trained and retrained in its use.
In addition, the fall arrest equipment must be subject to inspection by a competent person on a
regular basis, and whenever a fall arrest system is used, there must be a system in place to
retrieve a person who has fallen in less than 5 mins.

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Where it is decided to provide other forms of protection, eg. scaffolding, then the person
erecting or providing that form of protection must be competent. Records of the necessary
competency should be available.

Hazardous Material Handling (incl. radioactive Sources)

Hazardous materials may be used in a variety of applications at the site. As such, there is the
potential for exposure of personnel to the material, should appropriate controls not be in place
or fail. This system must also take account of the requirements of the AFR Health & Safety
Manual.3 Therefore, the following is needed:
TP PT

Each site to identify applicable local legislation and standards, and ensure that
there is a mechanism in place for remaining up-to-date with respect to changes
to that legislation.
Specific personnel should be authorized by site management to supervise
hazardous material handling. This includes a qualified person who is named
as taking overall responsibility for this (It is noted that this is not seen to be a
separate job, but simply a formal responsibility that may be applied to a suitably
skilled person at the site). These personnel should be trained regarding the
permit system, and their responsibility for issuing work permits. Training and
refresher training should be provided.
Personnel who are required to work with hazardous materials should be trained
and retrained regarding their responsibilities as workers in the safe handling of
hazardous materials.
Suitable emergency response systems must be in place to deal with an
emergency incident involving a hazardous material.

Mineral Fiber Materials

A particular group of hazardous substances are mineral fiber materials (MFM's). This includes
materials containing asbestos as well as those consisting of synthetic mineral fibers.

Synthetic mineral fibers (SMF's) are manufactured materials and include glass fiber and wool,
mineral wool (eg. rockwool, slagwool, kaowool) and ceramic fibers. SMF's can irritate the skin,
eyes, nose and throat, and cause itching, sneezing and coughing. The International Agency for
Research on Cancer (IARC) classifies ceramic fibers, glasswool and rockwool as possible
human carcinogens. Asbestos is a natural mineral fiber, which was used extensively in building
work and insulation during the 1950s, ’60s and early ’70s. It is now only used rarely4 in some TP PT

few applications such as friction materials like brake linings and gaskets. Asbestos is
hazardous because its dust contains tiny fibers that can be breathed in and lodge in lung
tissue. These have been found to cause diseases including asbestosis and mesothelioma, a
cancer that is usually fatal. Such diseases can take from 10 to more than 30 years to develop
after exposure to the fibers has ceased.

3
TP PT For more details on this, check on ENVIRONET on HolSpace or HGRS/CIE/ETPS albert.tien@holcim.com
4
TP PT IMPORTANT NOTE: The use of asbestos has been banned in Holcim Group.

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Those who may be at risk from exposure to MFM's include asbestos removalists, demolition and
construction workers, operators of plant and equipment, trades people, laborers, office workers and
householders when they live in, work in or work on buildings, plant or equipment containing any MFM's.

The general requirements for managing hazardous materials given above apply and, in addition, to
manage any special risks from MFM's, each Group company OH&S coordinator must:

Have a mineral fiber materials survey conducted in all workplaces;


Report the results to the local Chief Executive Officer;
Check for any potential exposures based on the results;
Do a risk assessment on any exposures identified; and
Act accordingly; ie: use the Hierarchy of Controls.5 P P

NOTE: Compliance with this guideline must be checked using the Assessment Audit
Protocol
For more information/advice, please contact HGRS: CHRM/CSR-OH&S

More information on MFM's as well as information on good practices in managing them can be found on
SafetyNet https://web.holcim.com/safetynet/
HTU UTH

Special Notes on Asbestos Cement Roof and Wall Sheeting

In most circumstances, asbestos-cement (AC) materials are best left undisturbed. Removal of
AC materials does not need to be undertaken unless it is suspected that they may be releasing
asbestos fibers into the air because of poor condition. Unnecessary removal may pose a
greater health risk than simply leaving these products in situ - so long as the products are
undisturbed and are likely to remain undisturbed.

Where for aesthetic or other reasons, asbestos-cement products are to be removed, the risks
to health caused by their removal should be minimized. Appendix 1 of the Good Practice
Guideline "Management of Mineral Fiber Materials" outlines the steps that should be taken to
minimize risks during removal and can be found on SafetyNet
https://web.holcim.com/safetynet/
HTU UTH

Piping, guttering/other associated roofing components and wall sheeting/other associated wall
components that are manufactured from asbestos-cement should be dealt with in the same
way as AC sheeting.

IMPORTANT: Where AC sheeting is damaged/not in good condition eg. badly weathered


or hail storm damage, the AC sheet can be easily crumbled and release
asbestos fibers. Fibers can also be released if breakage occurs during

5
TP PT See Appendix A1

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dismantling and removal. So, the removal of aged or damaged AC sheets


can present particular risks to health and shall be left to a licensed asbestos
removalist.

Explosives

Explosives are used extensively in mining and quarrying operations. Therefore, as a minimum,
the following are required:
Each site to identify applicable local legislation and standards, and ensure that
there is a mechanism in place for remaining up-to-date with respect to changes
to that legislation.
Site management must ensure that position descriptions reflect responsibilities
for the storage, handling and management of explosives.
Documented site procedures must be in place for
• Receival of explosives,
• Storage of explosives,
• Design and operation of magazines,
• Management of magazine inventory,
• Loading of explosives into drill holes,
• Shot firing, including use of licensed personnel
• Dealing with misfires noted at time of explosion,
• Dealing with misfires identified during mining activities, and
• Dealing with emergencies involving explosives.

Personnel must be trained regarding procedures involved in storage and


handling of explosives. Refresher training must also be provided.
Suitable emergency response systems must be in place to deal with an
emergency incident involving explosives.

4.4 Additional Issues

In addition to the formal work permit systems documented above, it is necessary for the site to
develop formal OH&S Management Systems/ procedures for dealing with the following
activities.

Kiln Light Up / Coal Mill & Coal Dryer Start-Up

Documented Safe Working Procedures (SWPs) must be in place for dealing with risks
associated with kiln light up as well as coal mill and coal dryer start-up. These SWPs will be
developed based upon hazard identification and risk assessment of all kiln start activities. All
personnel involved in kiln start-up must be trained and retrained regarding the content of the
procedures and a record of this training maintained.

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Traffic and Road Safety

Traffic and road OH&S will be maintained by means of a documented set of traffic rules for a
particular site. These traffic rules will be developed on the basis of hazard identification, risk
assessment and the local traffic regulations.

The content of the traffic rules will be communicated to all site personnel and must be
specifically addressed in the induction training/processes for all new site personnel,
subcontractors and/or 3rd party/contractor personnel.

4.5 Auditor Evidence

Specific requirements in relation to work permit systems have been noted in section 4.3 above.
These effectively establish audit requirements, and an auditor would expect to sight evidence
that all of these issues have been implemented.

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5. HAZARD IDENTIFICATION AND RISK ASSESSMENT


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5.1 Summary of Intent

Hazard identification and risk assessment are key building blocks of modern OH&S
Management Systems. From a legal point of view, OH&S legislation often specifies that
organizations must undertake risk assessments on the tasks and conditions existing in their
workplaces.

From a practical point of view, hazard identification and risk assessment provides the
opportunity to be proactive and to identify situations in the workplace that could cause injury or
illness, and deal with those situations before their consequences occur.

This guideline provides a lengthy discussion of hazard identification and risk assessment, and
also a simple methodology that can be used to perform this activity.

5.2 General Comments

Modern OH&S management legislation frequently spells out the need for a risk-based
approach to managing OH&S in the workplace. This approach requires that hazards are
identified, risks are analyzed and evaluated, and strategies put in place for effectively managing
and monitoring those risks.

A comprehensive approach to OH&S Risk Management must be implemented within the


organization to ensure that OH&S management goals are achieved, including:
Hazard reports and process hazard analysis
Definition of risk
Risk analysis and assessment
Risk calculation matrix
Specific risk controls in OH&S
Monitoring and evaluation the effectiveness of controls
It is expected that there will be a formal system in place for hazard identification and the
subsequent managing of the risks associated with those hazards.

A detailed discussion of Risk Assessment is included in the Appendix One at the end of this
document.

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Examples of hazards or circumstances for which risk assessment is expected to be required include,
but are not limited to:

• Noise • Radiation
• Vibration • Biological hazards
• Dust / silica • Mobile plant and equipment
• Hazardous substances • Fixed plant and equipment
• Manual handling • High pressure
• Ergonomics • High temperature
• Human factors • Working at heights
• Electrical • Falling objects
• Communicable diseases • Excavations
• Crane operations • Hand tools
• Coal dust • Plant rescue requirements
• Hazardous substances • Introduction of new equipment
• Confined spaces • Changes to procedures
(NOTE: See the blocks
Design Safety, Purchasing, and
Management of Changes

5.3 Details

Hazard Studies

A number of different approaches are available for the management of OH&S at any site. One
area, which must be addressed, is identification and management of hazards intrinsically
associated with the process. Therefore, a formal Process Hazard Analysis (PHA) should be
undertaken and documented and recommendations made for control of risk.

Types of techniques that may be applicable to such an analysis include:


Risk assessment
HAZOP/HAZAN
“What if?” analysis
Failure mode and effect analysis
Fault tree analysis
Event tree analysis
It is expected that:
A multi- functional/disciplinary team will undertake any PHA done and that a
formal report will be issued;
The PHA should be subject to regular review; and
Hazard studies / risk assessments are undertaken on all operational and
maintenance activities.

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Key issues to be considered by those who own and operate plants include:
• Risk management • Repair
• Design and construction • Modification
• Positioning of plant in the workplace • Cleaning
• Operation • Disengaged and stored plant
• Damaged plant • Transporting plant
• Dismantled/stored plant • Lighting
• Plant with moving parts • Ventilation – mists, fumes and dusts
• Powered mobile plant • Wear corrosion and damage
• Electrical plant and plant exposed to • Information provision
electrical hazards • Instructing workers
• Industrial lift trucks • Training workers
• Industrial robots • Supervising workers
• Air conditioning units • Safe work practices
• Auditing • Competency
• Inspection • Consultation
• Servicing • Records
• Maintenance

Operating Procedures

Written operating procedures, which specify key information for operations personnel, should
be provided at the site. These assist personnel to manage OH&S by setting clear standards for
operational practices. Operating procedures should provide plain instructions for safe
operation of the facility and be consistent with the hazard identification and process OH&S
information available.

Operating procedures should address the following:


Initial start up
Normal operation
Normal shutdown
Start up following a shutdown or turnaround
Emergency operations, including emergency shutdown
Any temporary operations
Operating procedures should also provide information on operating limits and where a deviation
from normal operations could have OH&S consequences, the following should be provided:
Consequences of the deviation
Steps required to correct or avoid the deviation
A reference to OH&S systems and their function.
Operating procedures should also address the following:
Properties of, and hazards presented by, materials used in the process
Special precautions required to prevent exposure to materials
Control measures to be undertaken if physical contact or airborne exposure
occurs
Any special or unique hazards.
Operations procedures provide a description of operation of the plant and facility at a particular
time. Over time, plant modifications will occur and operator understanding of key plant issues
will also change. Therefore, operating procedures may need to be modified and updated to

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reflect these changes. Thus a system must be in place for ongoing review of the effectiveness
of operations procedures and modifying and updating operations procedures, as required.

5.4 General Risk Controls

In addition to any outcomes from specific risk assessments, the following general controls
should be in place
Drug and alcohol policy
Fitness for duty protocol - both physical and literacy/language.
Provision of first aid facilities
Provision of general worker amenities (sufficient toilets, showers/washing
facilities, eating areas, heating/cooling, hot/cold potable water, lighting, etc) as
well as maintenance of them

5.5 Auditor Evidence

The Audit will seek evidence of:


Hazard identification
Risk assessment
Implementation of risk controls
Review of effectiveness of risk controls
Any audit will also normally assess mechanisms in place for reviewing,
updating and improving operating procedures.

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6. PLANNED INSPECTIONS

6.1 Summary of Intent

Simple planned inspections can be undertaken even in the absence of fully implemented OH&S
Management Systems. These inspections are useful to quickly identify deficiencies and
hazards in the workplace.

The inspections discussed in this section are those that can easily be undertaken by any
worker, eg. housekeeping, presence/absence of machinery guarding, etc. In section 15 of this
Handbook, those inspections requiring a high level of expertise are considered, eg. pressure
vessels/relief valves.

Undertaking regular inspections of key areas or aspects of a workplace is an important part of


effective OH&S management. Planned inspections allow a regular checking of key features of
the workplace, and ensure that appropriate risk controls are in place. Planned inspections may
be carried out even if the more comprehensive aspects of an OH&S Management System are
not in place.

When deficiencies and hazards have been identified, a properly operating corrective action
system ensures that they are eliminated or controlled. This block provides guidance on the
types of planned inspections that should be undertaken.

6.2 General Comments

Planned inspections may be applied to a range of different areas and activities within the
workplace. These include the various topics listed in the table below. Each site should
determine those topics for which planned inspections are required. This may require Planned
Inspections in addition to those listed below.
Guards Ladders
Access Hygiene and sanitation
Storage practices Refuse storage
Refuse disposal Hand tools
Gas cylinder storage Mobile plant and equipment
Personal protective equipment OH&S equipment
Color coding Labeling of critical equipment
Signage Chemical storage (Including flammables and
corrosives)
Material OH&S Data Sheets Stairs
Handrails Eyewash Stations and Safety Showers
Workplace Amenities Certification & Licenses
Housekeeping Training is current/up to date (according to
Training Master Plan)
Breathing apparatus Lifting equipment

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6.3 Discussion of Topics

In the sections below, each of the inspection topics is briefly discussed in order to indicate their
role and purpose. The list is not expected to be comprehensive and each site should add local
requirements.

Guards

Providing guards, where required, is an important way of protecting employees from injury.
The requirement for guarding is likely to be determined by local legislation and applicable
Standards or Codes. A register of items of equipment requiring guarding should be developed,
including specific details relating to guards and, if appropriate, numbering of guards. The
person undertaking the inspection is then able to identify whether the guard is in place and in
good condition and, if necessary, make recommendations for further action.

Ladders

Ladders, stairs, and walkways are generally addressed either directly by legislation or by
appropriate Standards and Codes. Details of all portable ladders should be recorded including
their location. It is recommended also that each ladder be numbered for easy reference.

Access Inspection

This inspection is aimed at checking and making recommendations regarding access in various
areas within the workplace. Access is essentially a housekeeping item. However, many
incidents occur in workplaces because there is inadequate access. Where key problem areas
are known these should be included on the inspection form to ensure that when an inspection
for quality of access is undertaken those particular areas will be inspected.

Hygiene and Sanitation Inspection

This inspection aims to address hygiene and sanitation issues within the workplace. Therefore,
the types of issues to be addressed by the inspection include cleanliness of wash-up and
shower areas, toilets, restrooms, and lunchrooms. Each relevant area should be listed and
when the inspection is undertaken problems and recommended actions should be identified. If
the workplace has a specified first aid area or first aid room, this should also be inspected.

Storage Practices Inspection

The purpose of this inspection is to ensure those areas where materials are stored are
inspected and checked for good storage practices. Issues, which may be addressed by this
inspection, include storage of materials in work areas and also warehouses. The inspection
should also address the suitability and adequacy of stacking practices.

Refuse Storage and Disposal Inspection

This inspection relates to good housekeeping practices by focusing on storage and subsequent
disposal of refuse. The inspection can be used to check that materials are placed appropriately

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into bins and that bins are emptied at regular intervals. Therefore, the location of the key waste
storage and waste bin areas should be identified. It is noted that in some circumstances
different types of bins will be required for different types of materials eg. paper, glass,
chemicals etc. Where different types of bins are used, each should be separately identified.

Hand Tool Inspection

Many accidents occur in workplaces because persons use faulty tools and equipment. The
purpose of this survey is to inspect all key hand tools and ensure that they are fit for use.
Generally, the responsibility for completing the inspection will fall to the person who has
responsibility for the day-to-day use of the hand tool, or sometimes their supervisor to check
the adequacy of the inspections being undertaken.

Gas Cylinder Inspection

The purpose of this inspection is to identify the different types of gas cylinders present at a
worksite and their storage locations. The inspection enables identification of cylinders that
have been present in a particular location for an extended period of time and those that are in
need of maintenance attention and action.

Mobile Plant and Equipment Inspection

Because of the energies involved there is potential for serious incidents associated with mobile
plant and equipment to occur. Therefore, this inspection requires that all items of mobile plant
and equipment are identified and their usual location specified. The inspection then requires
that each item of equipment is inspected for suitability for continued operation and any
problems and associated recommendations are noted. These inspections may include daily
pre-start checks and regular maintenance inspections.

Personal Protective Equipment Inspection

As noted in a later section, personal protective equipment is one key strategy for protecting
employees from OH&S risks. However, PPE will be effective only if it is appropriately
maintained. This inspection enables an inventory of PPE to be developed, the various
locations to be identified and particular problems and recommended actions to be specified.
Generally each employee should have responsibility for his or her own protective equipment.

Safety Equipment Inspection

As well as personal protective equipment and fire fighting equipment there may be other
specified items of OH&S equipment present at a workplace. The purpose of this inspection is
to create an inventory of such equipment and its location and also to specify testing
requirements and confirm that tests have been undertaken. Depending upon the nature of the
equipment there may be applicable Standards or Codes specifying test intervals.

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Color Coding and Labeling Inspection

One effective way of highlighting hazards in the workplace is to use color coding or labeling.
For example, pipes containing different types of materials are painted with different colors in
order to alert employees regarding their different contents. This particular inspection enables
each item of plant or equipment to be specified in a register / form, including its location and the
appropriate color requirement to be identified. Use of the inspection register then confirms the
suitability of color-coding and can be used to identify the need for repainting etc. The
requirements for color-coding, the use of specific colors and the interpretation of that use are
usually contained in particular Standards, Codes or legislation.

Labeling of Critical Equipment Inspection

In any workplace, it is likely that there will be key items of equipment that are critical to the
continuity of work practices or critical to the performance of certain OH&S actions or functions.
An example is an emergency alarm or emergency shutdown button. This inspection requires
the location of critical items of equipment to be specified, any appropriate labeling requirements
also to be specified and problems associated with the labeling of the equipment to be identified
as the result of an inspection.

General Signage Inspection

In any workplace, there will be a range of requirements for signage. These may be formal
requirements relating, for example, to hazardous substances placarding and/or signs or there
may be decisions made at a particular site regarding the erection of particular warning signs,
eg. requirement to wear safety helmets, glasses, boots etc. Once decisions regarding signage
have been made, it is essential that the signage is erected and maintained. The purpose of this
inspection is to specify signage requirements at different areas in the workplace. Adherence to
these requirements can then be assessed by use of an inspection.

Stairs

Stairs should be inspected to ensure that there are no deficiencies. This should include a
consideration of treads and handrails.

Handrails

Handrails should be inspected for structural integrity and repairs effected where required. The
requirements for handrails should be addressed in accordance with the relevant standards.

Chemicals and MSDS Inspection

Management of chemicals in the workplace requires an inventory of all chemicals and their
location to be developed. In addition, there is a requirement that Material Safety Data Sheets
are obtained for all chemicals classified as 'hazardous'. The purpose of this inspection is to
generate an inventory of chemicals that are present at a workplace, their storage locations and
determine whether a Material Safety Data Sheet is currently available. The Register should
also provide scope for assessment of the adequacy of storage and the need for formal risk

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analysis. Management of hazardous substances in a workplace is a major issue and generally,


there will be specific legislation and supporting Codes and Standards that must be addressed.

Eyewash Stations and Safety Showers

A register of eyewash stations and safety showers should be developed and these should be
tested on a weekly basis. Where deficiencies in water flow are identified, corrective action
should be carried out immediately.

Workplace Amenities

Workplace amenities refer to those amenities provided to workers in a workplace. They consist
of items such as toilet facilities, changing/showering/locker room blocks, kitchen areas, eating
areas, drinking water and heating or cooling devices. An inspection program to monitor the
quality in all areas of amenities should be in place.

6.4 Auditor Evidence

An audit will check


That a systematic inspection program is in place
That outcomes of inspection are actioned by means of corrective action
requests
That linkages exist to both MAC & SAP

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7. LEGAL OBLIGATIONS
U

7.1 Summary of Intent

It is essential that each site satisfies legal obligations and complies with relevant legislation. It
is expected that if all the other elements in the Pyramid are fully addressed, then legal
compliance should in most cases be in place, since there is a commonality within OH&S
Management Systems and OH&S legislation.

Nonetheless, this element provides the opportunity for confirmation that all compliance
objectives have been met, and also requires that each Group company has in place a
mechanism for identifying changes to legislation, and ensuring that the impact of those
changes is assessed and implemented at each site.

7.2 General Comments

This element requires that each site establishes and maintains a procedure to identify and have
access to current legal and other requirements that are applicable to the site.

Compliance with relevant legislation and/or regulations must be fully achieved. This block
requires that Group companies have in place a mechanism for:
Identifying all legal obligations
Confirming that these legal obligations have been addressed
Ensuring that the companies are aware of any changes that may be made by
governments or regulators with regard to their responsibilities.
This block recognizes that there are sometimes external agencies such as SUVA in
Switzerland or OSHA in the USA that can impose regulation on Group companies.

7.3 Details

Some of the issues that need to be considered include:


How the site accesses and identifies relevant legal and associated
requirements, e.g, legislation, Standards, Codes.
How the site addresses/complies with these legal and other requirements.
How the site monitors changes to legal and other requirements.
How the site communicates relevant information on legal and other
requirements to people working there.

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local regulatory/legal requirements

It is noted that the regulatory requirements applicable to a site’s activities, products or services
may exist in several forms. Examples include:
Those specific to a particular activity eg. site operating permits.
Those applicable to the site’s products or services.
Particular authorizations, licenses and permits.
In implementing a OH&S Management System, it is important to maintain a listing of current
applicable Legislation. Note that different regulatory authorities, eg. Federal, State and Local,
may administer different aspects of Legislation.

A master copy of the Legislation and all applicable Standards and Codes should be retained.

7.4 Auditor Evidence

An audit will seek evidence of:


Identification of legal obligations
System for maintaining knowledge of legal requirements
System for communicating changes to site personnel
Compliance audits

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local regulatory/legal requirements Planning

8. MANAGEMENT COMMITMENT AND PLANNING


U

8.1 Summary of Intent

To be effective, an OH&S Management System requires the participation and support of all
sections of an organization. Gaining this commitment requires senior management to
demonstrate a corporate commitment through leadership and allocation of resources.

Management commitment and planning must manifest itself within policies and targets adopted
by Group companies.
Integration of OH&S issues into planning and budgeting processes
Establishing and resourcing functional plans
Reviewing the results achieved by their OH&S Management System
In particular, OH&S related insurances (especially Accident Insurance /
Workers Compensation) must be sufficient and well managed
The planning for action to be taken in the event of an emergency OH&S
situation.
Hence the existence and application of OH&S policies, budgets, standards, targets, annual
plans, special programs, emergency and contingency plans, is addressed in this block.

8.2 General Comments

This element is considered to be a key element within the Holcim OH&S Management System.
Effective attention will not be given to the management of OH&S and implementation of OH&S
management initiatives unless there is demonstrated by management a demand for, and
commitment to, achieving good OH&S management.

The types of issues to be addressed as part of management commitment include:


Development of an OH&S Policy.
Distribution of the OH&S Policy and other site critical information in the
necessary language(s).
Specification of an organizational structure suitable for managing OH&S

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One recommended Structure for OH&S:

CEO & GC
Executive
Overall management control of OH&S
Committee
in the Group company (GC)

GC Exco Member Particular responsibility for OH&S in the GC

GC OH&S Co-ordinates the OH&S approach in the GC


Co-coordinator

GC and/or
Promotes OH&S in the GC
Business Unit
OH&S Committee

Person Provides OH&S expertise


responsible for Informs
OH&S in a
Business Unit

This model is recommended for effective and efficient OH&S structure and staffing, however
local legal requirements may mean there is a variation in a Group company.

Other issues to be considered as part of management commitment include:


Each operating site with 80 or more FTE employees should have a person
responsible for the function of providing OH&S support. A risk assessment is
required to decide how sites with less than 80 employees are to be provided
with OH&S functional support, and how much time should be allocated to
perform the function at a site.
Specification of responsibilities of all persons within the organization, with
respect to management of OH&S.
Structures for communication of OH&S information within the organization.
Structures for consultation within the workplace.
Commitment of sufficient financial resources towards the achievement of
OH&S management goals.
Review of OH&S management performance.
The need to be able to respond to emergency situations is also a fundamental part of any
OH&S Management System. Emergency planning is closely allied to hazard identification and
risk assessment, because it is through the hazard identification that it is possible to identify
where emergency plans are needed (See 8.4).

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8.3 Issues to be addressed

OH&S Policy

Company management, in consultation with workers, must develop an OH&S policy. This
Policy should embody the requirements of local legislation as well as the key aspects of the
Holcim OH&S Policy. The policy should be signed by the Chief Executive or Company
Manager, as appropriate, and be reviewed on an annual basis. This policy:
Should be a formal document
Be dated and signed by the current Chief Executive or Company Manager
Must clearly state OH&S objectives
Must declare management’s commitment and determination for achievement of
OH&S objectives
Must broadly define responsibilities for all parties at the workplace
Must be clearly understandable and
Be available to/provided for employees at all levels of the organization
Holcim OH&S Targets

Each site will develop an OH&S Plan with the objective of achieving Holcim’s corporate OH&S
performance targets:
Zero accidents causing death or permanent disablement annually
Achieving a LTIFR of <5 annually
Achieving a LTISR of <60 annually
Communication of OH&S Policy and Targets

It is important that an OH&S Policy once formulated, and the performance Targets, are
communicated effectively within the workplace. This can be done in a several ways:
Issuing written copies to employees.
Issuing written copies to visitors.
Including it in induction training.
Including it in procedure manuals.
Including it in OH&S promotions.
Including it in contract documents.
Displaying it on notice boards.
Discussing it at group meetings.
Discussing it at OH&S meetings.
Discussing it at other formal and informal meetings

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Evaluation of OH&S Policy and its Communication

Management must also evaluate the effectiveness of the OH&S Policy and its communication.
Ways of doing this include:
Checking that it is fully understood by all employees.
Ensuring, where appropriate, that it is translated into other languages.
Ensuring that it accommodates the needs of persons with specific disabilities.
Checking notice boards.
Participation in OH&S meetings.
Participation in training sessions.
Formal and informal discussions.
Resources

It is the responsibility of management to ensure that suitable resources are provided for the
OH&S program. This could include some or all of:
Appointment of a person to the Group company OH&S coordinator function
Appointment of site OH&S officer
Training of OH&S officer
Training of OH&S Committee personnel
Other OH&S specific training
Identification of key competencies required
Provision of budget for OH&S initiatives
Development of a plan to achieve OH&S objectives
Linkage of the OH&S plan to the budgeting process
OH&S Plan

Managing OH&S should be a matter of ongoing and continuous improvement in OH&S


performance. Therefore, an OH&S Plan should be developed and reviewed on an annual
basis.

The OH&S Plan should address the following:


Input from site personnel (via the OH&S Committee or local equivalent)
Focus on key hazards and risks
Linkage to requirements of legislation
Linkage to incidents that have previously occurred.

8.4 Emergency Planning

An effective risk management program aims at preventing the occurrence of incidents likely to
pose a significant threat to individuals or operations. Nevertheless, it is possible that such
incidents, including natural disasters, may occur and therefore an effective Emergency Plan
needs to be in place - See Appendix 3 for an example.

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General Comments

As a minimum, the following is required:


A documented threat analysis to identify the scenarios for which emergency
planning is required. (Note: This should flow in part from application of hazard
identification and risk assessment practices.) The threat analysis should
consider both on and off site impacts, as appropriate
Appointment of a coordinator for the emergency plan to ensure that the plan
remains current.
Development of more detailed emergency response plans for each of the main
scenarios identified in the threat analysis.
Nomination of responsibilities and duties for personnel to implement those
plans.
Liaison with external authorities.
Provision of suitable emergency response equipment.
Training and retraining of personnel in emergency response procedures.
A maintenance program for emergency response equipment.
Undertaking of drills to test aspects of the emergency plan.
Evaluation of those drills as a means of improving the quality of the emergency
response plan.
Annual review of the plan
Risk Management Basis

A consideration of emergency planning and the development of suitable emergency plans


should flow from the risk management process. When hazard identification and risk analysis is
undertaken it is possible at the same time to identify those sets of circumstances that may lead
to emergency situations. The strategy to be adopted in developing an emergency plan is:
Identify the different types of emergency scenarios that could occur, eg. fire,
explosion, natural events, bomb threat, terrorism, etc.
Identify the types of consequences that are likely to emerge from such
incidents and also identify the emergency response measures that will be
needed to minimize the impact of those consequences.
Emergency planning follows naturally from risk management. Risk
management aims to identify risks and control them so that undesired
situations do not occur. Emergency planning and emergency response plans
attempt to minimize the consequences of those undesired situations when they
do occur.

Content

A well-constructed emergency plan should contain the following:


A list of scenarios that could occur and their likely consequences.

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Actions, involving specified personnel, which are required to deal with different
emergencies (an emergency plan may have several pages containing identified
scenarios and specific responses).
A list of contact phone numbers for emergency services, doctors, staff,
contractors etc. to be called in out of hours, suppliers of emergency equipment,
Government officials etc.
A list of emergency response equipment on-site and its storage location.
Identification of an emergency control room or point if that is appropriate.
A collection of relevant information that may be needed in an emergency, eg.
drawings, registers of chemical storage, etc.
Testing Emergency Plans

To be effective an emergency plan must be tested on a regular basis. Testing of emergency


plans should be documented and after each test, the results should be reviewed in order to
identify the types of improvements that can be made to the emergency response strategy.

Workplace circumstances may change and render the contents of an emergency plan
ineffective. Therefore, regular reviews are needed to ensure that changes are incorporated into
the plan and that the plan is reviewed at regular intervals.

Document Control

It is critical that at the time of any emergency, the Emergency Plan in place is current and is
therefore able to be effective in dealing with the emergency. Therefore, an Emergency Plan
should be a controlled document and those personnel participating in the plan or in need of an
understanding of the plan, should be part of a formal distribution list for the Plan.

8.5 Management Review

There must be a senior management review within each Group company of the OH&S program
on an annual basis. Although it is expected that OH&S performance and the OH&S program
will be reviewed at several levels, including the OH&S Committee, senior management must do
so, in recognition of their overall responsibility for OH&S management. They should:
Formally review the success of the program on an annual basis
In particular, a check must be made that OH&S-related insurances are
sufficient and well managed
Document that review, and
Formulate an OH&S plan for the forthcoming year.

8.6 Auditor Evidence

The following will be considered:


Existence of OH&S Policy.
Date and signature on OH&S Policy.
Evidence of OH&S Policy throughout the work site.

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Inclusion of OH&S Policy in site induction material.


Evidence of review and updating of the OH&S Plan.
Evidence of a review of sufficiency as well as the efficiency and effectiveness
of all OH&S-related insurances
A process should be in place to ensure that ongoing audits and reviews of the
OH&S Management System are undertaken.
Policy targets and communication of them
OH&S planning
Resourcing and budgets
The existence of an emergency plan based upon a realistic scenario / threat
analysis. (The content of the plan will be reviewed).
Emergency planning
Testing emergency and contingency plans
Evidence that the emergency plan is a controlled document and is reviewed
and updated regularly to reflect changes in circumstances
Occurrence of drills to demonstrate the effectiveness of the Emergency Plan
Action plan based upon outcome of drills
Overall management review and system improvement

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9. INDUCTION AND TRAINING


U

9.1 Summary of Intent

The basis for any program aimed at the prevention of risk exposures or accidents is to cultivate
a culture of OH&S awareness, and to provide each person with the skills and knowledge
necessary to ensure that they work in a safe and healthy way.

This block establishes the need for all workers at Group company workplaces to receive a
systematic set of courses containing a series of guidance, instruction, schooling and
assessment that is given:
When any employee or subcontractor or self employed person first starts to
work in one of our workplaces or changes to a new job, or any other visitor
comes to any of our workplaces (induction)
To meet and identify the need to improve the skill or knowledge of an employee
(training).
Plant managers are responsible to ensure that site personnel receive the
necessary OH&S training.

9.2 Induction

OH&S induction training for new employees is an important aspect of a site OH&S
Management System. Every new employee or a current employee working at a site or in an
area for the first time should undergo induction training.

The content of the induction training will depend on the circumstances, the type of work the
person is undertaking and the hazards to which they are likely to be exposed.

The elements that are common to most OH&S induction programs are:
OH&S Policy and objectives for the site
Main site hazards.
Specific site OH&S rules.
Location of first aid and medical facilities.
Location of fire fighting facilities.
Details regarding emergency plan.
Information regarding OH&S Representatives.
Information regarding OH&S Committee.
Other general OH&S information.
Where possible it is desirable to provide to new staff a booklet or brochure summarizing the key
OH&S issues relating to the site. Induction will also include a test to ensure the person's
understanding.

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They should also receive a more detailed OH&S induction from their supervisor, manager, or
team leader on the job that relates specifically to the hazards that they are likely to encounter in
their area of work. Receipt of induction training should be recorded and it is important that
persons who have received induction training are able to undertake refresher training later.

It is also important for a site to review the content of its OH&S induction training from time to
time because as development occurs and processes change, the types of hazard that may
exist in a particular area of the workplace may also change.

9.3 Training

Training is complementary to the notion of including OH&S responsibilities in position


descriptions. Often many of the incidents that occur result from inadequate training.

The types of issues that need to be considered in identifying training needs are:
Occupation types.
OH&S issues.
Tasks within occupations.
Critical tasks within occupations.
Literacy and language
The following issues should be addressed:
Training requirements of particular occupations.
Specific tasks within occupations requiring training.
Critical tasks within occupations requiring training.
Selection of the trainer.
Attendance records.
Documentation of training.
The types of training which may need to be undertaken may include:
Training of new employees.
Training of promoted employees.
Training of transferred employees.
Induction training.
Training in emergency procedures (including practical sessions).
First aid training.
Training on new or remodeled equipment.
Training in hazard identification, risk assessment and risk control.
Training in specific tasks.
General supervisor/manager training.
Specific training for OH&S coordinators, Representatives and Committees.
Specific training relating to new or revised Standards or Legislation.
Training relating to revised or different work methods
Refresher training as required

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9.4 Training Review

It is important also that management tests and evaluates the effectiveness of the induction and
training program. This can be done in a number of ways:
Reviewing of course content.
Informal discussions with attendees.
Formal testing for proficiency.
Reviewing accident/incident records to determine whether involved persons
were appropriately trained.
Reviewing the competency of trainers.
Conducting task observations.
Conducting random inspections particularly after training has been given on a
particular topic.
It is important that training is seen to be an on-going process. All skills need to be revised by
means of refresher training. Refresher training is particularly important and should be
constructed in a way that challenges the person who is undergoing the training to either
demonstrate their current level of knowledge or to acknowledge the need for the refresher
training and to update their knowledge.

9.5 Auditor Evidence

The following information will be sought as part of an audit:


Initial training for new employees or person new in a job
Consideration of differing levels of ability and literacy of attendees.
Provision of training by appropriate competent personnel.
Use of suitable training facilities.
Maintaining training records.
Evaluation of training sessions to ensure comprehension and retention.
Regular review of training program.

An audit will also review the induction program for:

New employees
Contractors
Visitors

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10. INCIDENT INVESTIGATION AND CORRECTIVE ACTION


U

10.1 Summary of Intent

In any organization incidents will continue to occur, and it is important to learn from them. A
proper incident investigation system will permit identification of the root cause, contributory
factors and system deficiencies in each particular case. It will also permit control of these
causes to help prevent any similar incidents recurring.

An additional requirement for reporting and sharing of critical information between Group
companies is established in this block.

It is fundamental to any improvement methodology that a corrective action system is in place in


order to distil lessons learned from any mistakes or hazards found, and then correct identified
deficiencies, and realize any identified opportunities for improvement.

In order for a site to


“Learn from its mistakes”,
Correct identified deficiencies, and
Identify opportunities for improvement,
It is fundamental that a corrective action system is in place. Note that companies with existing
ISO9000 or ISO14000 systems should have this block substantially in place.

10.2 General Comments

Incidents are unwanted occurrences for any organization. An incident may not necessarily
result in damage or injury, but may be a “near hit”.

However, the occurrence of an incident provides the opportunity for identifying root cause,
contributory factors and system deficiencies and making changes to Management Systems and
work practices to prevent such an incident occurring again. Other elements of the OH&S
Management System, eg. hazard identification and risk assessment, attempt to take a
proactive approach to OH&S management and identify those circumstances that could lead to
incident or injury. Incident investigation, however, takes a predominantly reactive approach
and attempts to learn lessons from incidents that have occurred.

This particular element is included as one of the basic elements of the Holcim OH&S
Management System, because it is considered that any site, irrespective of the overall OH&S
Management Systems that are in place, should be capable of investigating incidents and
putting remedial measures in place.

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It is also important that a robust incident investigation system is in place, so that relevant
statistical data can be accumulated to provide a better indication to a site of their OH&S
management performance. Formal incident investigation procedures should be in place for
investigating process-related incidents such as high temperature excursions, overfilling of bins,
silos etc.

Further, formal procedures should be in place to investigate incidents such as injuries, near
hits/misses, damage, substandard conditions, substandard practices, defects in plant and
equipment, hazards, illness, disease and any other matters of interest.

Investigation procedures should seek to determine the immediate and root cause, contributory
factors and system deficiencies, and develops remedial actions for preventing the same or
similar events occurring in the future. Managers and supervisors should be trained and
retrained in incident investigation procedures.

10.3 Incident Investigation Process

Overview

There are four broad goals associated with incident investigation:


To prevent the same incident occurring again
To learn from “near hit” incidents and so prevent incidents occurring
To review management and work practices and prevent similar incidents
occurring in the future elsewhere in the Holcim group of companies
To develop statistical data.
The first three sub-elements are particularly important. Many organizations are successful in
investigating incidents and putting controls in place to prevent the same incident occurring
again. However, they may fail to take a broader view and to develop controls that can prevent
similar occurrences elsewhere within the organization in the future.

It is important, therefore, that any OH&S Management System is developed in such a way that
incident investigation is seen to be a contributor to the overall improvement of the OH&S
Management System and not simply a matter of reacting to a specific set of circumstances.

The purpose of incident investigation is to determine why a particular incident occurred and to
set in place measures that will prevent that same incident or incident occurring again.
Therefore a typical outcome from an incident investigation is a set of short-term (quick fix)
measures that will prevent the same incident occurring immediately again. Additionally, there
should be a series of longer-term measures, which will make fundamental changes to the
OH&S Management System and therefore prevent the same or similar incident occurring again.

It must be strongly stressed that the primary purpose of incident investigation is to identify
causes and not to attribute blame to individuals who may have been involved in a particular
incident.

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Incident Reporting

Documented procedures should be in place for reporting


Injuries
Note: An important part of this is SafetyAlert, the Critical Incident Reporting
System that has been established. All Fatal and Permanently Disabling
Injuries must be reported on this as soon as they occur.
Illnesses
Property damage
“Near hits/misses”, eg. person nearly struck by a falling object
Hazards
Defects
Undertaking Incident Investigation

Each site should develop and implement specific procedures or strategies for undertaking
incident investigation. However, any good incident investigation procedure should address the
following issues:

1) Identification of what happened

It is important that incident investigation identifies in a factual manner “what happened”. This
phase of incident investigation is not involved in determining causes or remedial action but is
merely concerned with obtaining information.

A good incident investigation report should list briefly:

The nature of the incident.


When it happened (date, time, shift).
Who was involved.
Who was a witness.
The type of equipment that was involved.
The nature of the injury.
The nature of the damage to the equipment.
A brief statement of the circumstances of the incident
After this is completed it is important to review it to ensure that it is purely factual information
and does not include cause analysis or recommendations.

2) Sequence of Events leading to Accident/Incident

After factual data has been obtained it is then necessary to identify the sequence of events
leading up to the incident. This might involve identifying the sequence of three or four events
that occurred immediately before the occurrence of the incident.

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3) Determining Root Cause, contributory Factors and System Deficiencies

The key to effective accident investigation is to keep asking the question "Why?" For each of
the events preceding the incident it is possible to ask and continue to ask why that particular
event or the event that led to it happened. Continually asking “Why?” will lead to a series of
basic causes for the incident. At the end of this stage of incident investigation, it should be
possible to identify a series of causes and factors regarding why a particular incident
happened.

4) Developing remedial Measures

Incident investigation will normally generate two types of remedial actions:


1) Short term fixes; and 2) Longer term solutions.

A “short-term fix” is something that can be put in place almost immediately and will prevent that
same incident from occurring again in the immediate future. The purpose of a longer-term
solution is to put in place measures that will effectively prevent the same incident occurring but
will also prevent similar incidents occurring in other areas of the workplace.

5) Communication with Persons involved

After an incident investigation has been undertaken and documented, it is important that the
results of the investigation are reviewed by the person or persons originally involved in the
incident. Incident investigation reports typically have an attached circulation list such that the
involved persons, the OH&S officer and also management, can review them. This must be
specified in the procedure.

6) Follow-up and Review

Many organizations fail to learn from mistakes by not adequately implementing


recommendations from incident investigation. Results of incident investigations should be
audited to confirm suitability and success in implementation of recommendations. Procedures
should be in place to review the outcome of incident investigation and confirm that
recommendations have been implemented. Group companies should also be aware that
sharing the results of investigations with other Holcim companies could help prevent a similar
incident occurring in another company. This sharing is done via SAFETY and/or the OH&S
coordinators' Community of Practice.

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7) Training

Personnel involved in incident investigation should be provided with training, including training
in analysis of root cause, contributory factors and system deficiencies.

8) Statistical Analysis of Data

Review and analysis of data may reveal useful trends. Trends may be identified for:
Injuries
Property damage
“Near hits/misses” eg. person nearly struck by a falling object
Hazards
Illness
Compensation claims

10.4 Corrective Action System

General
While incident investigation provides the opportunity for an organization to learn about
deficiencies within its OH&S Management System and implement initiatives to prevent the
same and similar incidents occurring in the future. Whereas incident investigation is a specific
response to a particular occurrence leading to an injury or illness, establishing corrective action
requests can be proactive and part of a broader approach to identify deficiencies and potential
for improvement, even if undesired consequences have not yet occurred.

Note: It is expected that sites with existing ISO9000 or ISO14000 systems operating will have
this element substantially in place.

Details

As a minimum, the following requirements must be in place:-


A mechanism for identifying the need for corrective actions.
A mechanism for recording the requirement for a corrective action. (Typically
this will be a corrective action request form.)
A mechanism for tracking corrective action requests, including a specific
number for each corrective action.
A mechanism for assigning responsibility for implementation of corrective
actions.
A system for assigning responsibility for reviewing the effectiveness of
corrective actions.
A “sign off” and record system to ensure that corrective actions are completed,
and details appropriately recorded.

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10.5 Auditor Evidence

An audit will seek evidence of


Hazard reporting
Incident reporting (including Critical Incident reporting)
Incident investigation procedure
Incident investigation activities, including training
Development and communication of corrective actions
Implementation of corrective actions
Review of corrective actions
Statistical analysis of data

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11. INDUSTRIAL HYGIENE AND MONITORING


U

11.1 Summary of Intent

Industrial hygiene is the anticipation, recognition, evaluation and control of those environmental
factors (sometimes called stressors) arising in or from the workplace that may cause sickness
or impaired health amongst employees, visitors, contractors or the general public. (These
various environmental factors or stressors are usually classified as chemical, physical,
biological or ergonomic.)

All workplaces should have a program to identify and measure the extent of environmental
factors in the workplace as well as the exposure of employees, visitors, contractors or the
general public.

If it is indicated by the results of a risk assessment, employees should be involved in a medical


monitoring program to identify if there has been any negative impact on them. This monitoring
may need to be ongoing or continuous to ensure that exposures are controlled to levels that is
as low as reasonable achievable.

11.2 General Comments

An industrial hygiene and monitoring program will:


Identify and measure employee environmental exposures
Undertake risk assessments
Undertake monitoring
Develop action plans
Maintain records
Special consideration should be given to the introduction and/or use of a new waste (AFR)
before it is to be utilized at the plant. This must also take account of the requirements of the
AFR Quality Manual and the AFR Health & OH&S Manual.6 TP PT

11.3 Workplace Monitoring

Issues that may be addressed as part of such monitoring include:


• Toxic/hazardous material exposures • Temperature
• Atmospheric contamination • Flammable gases
• Noise • Fire
• Air quality • Radiation
• Ventilation • Ergonomics
• Vibration • Lighting/Illumination

6
TP PT For more details on this, check on ENVIRONET on HolSpace, or in HGRS/CIE/ETPS albert.tien@holcim.com

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Each site should undertake hazard identification and determine the whether or not monitoring is
needed. If it is, the type of monitoring that is required must then be decided. It is important to
note that consideration should also be given to any environmental exposures being caused to
neighbors or other emission points in the area around the site.

11.4 Health Monitoring

There is a requirement for undertaking employee health monitoring when employees are
exposed to particular types of risks. This may be specified by local legislation or found through
risk assessments.

Depending upon the nature of work circumstances, employees may be exposed to hazards
requiring ongoing health monitoring. Hazards requiring health-monitoring programs may
include exposures to:
Noise
Dust containing crystalline silica
Asbestos
Lead, other heavy metals or other specified chemicals
Excessive stress resulting from the activities in the workplace
A health surveillance program may be undertaken when a risk assessment determines the level
of risk of exposure requires surveillance or there is a legislative requirement to have a program.

Any such program should established with suitable medical input. Results should be
communicated to workers and records of the length and type of exposure to each material
maintained on a secure long-term basis. Local legislation should be checked but as a guide,
keeping records of monitoring for at least 30 years should be considered. Health surveillance
results should also form the basis for improving strategies for minimizing worker exposure to
risks.

11.5 Auditor Evidence

An audit will seek evidence of the existence and implementation of the items listed above. An
audit will also review evidence of record keeping.

Based upon a site inspection, a comment may also be made on the adequacy of monitoring
undertaken.

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12. EMPLOYEE COMMUNICATION AND INVOLVEMENT

12.1 Summary of Intent

Modern OH&S Management Systems call for consultation through mechanisms such as OH&S
Committees. Consultation is important because it directly involves those persons performing
tasks in the workplace and it is these people who often have the best understanding of the
nature of the hazards involved in the work. Consultation should also involve discussing the
incidents (and near hit/miss incidents) that have occurred, and the solutions that can be put in
place for controlling such incidents.

Therefore, an open consultation process will ensure that such issues are raised, and will also
provide the opportunity for comment and feedback on the effectiveness of OH&S management
strategies.

OH&S is an integral part of the process of stakeholder involvement in the whole Corporate
Social Responsibility (CSR) program at a Group company, and this block includes recognition
of that requirement.

12.2 General Comments

Consultation in the workplace can occur in a number of ways. The most common method is
through an OH&S Committee. The requirements for the formation of an OH&S Committee and
the composition of the OH&S Committee are often specified by local legislation.

In some workplaces, it may be more practicable to have several OH&S Committees/OH&S


groups. For example, each shift or work area such as operations and maintenance may have
its own local OH&S group whose aim is to deal with their OH&S issues at the local level.

As a recommended minimum, an OH&S Committee should contain both workforce and


management representatives (majority workforce representatives) and meet at least four times
per annum. Minutes of meetings must be kept and communicated to both management and
the workforce.

Consultation must also address the problems associated with different languages at a given
site.

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12.3 Details

OH&S Committee

The key factor to be considered when forming an OH&S Committee is to ensure that an
appropriate balance is maintained between representation of all interest groups and areas in
the workplace, and the overall size of the OH&S Committee.

To be effective OH&S Committee members must have received basic training in understanding
the applicable legislation and its impacts, and basic training in OH&S Management practices.

As a minimum, training in the following areas is recommended:


Overview of applicable legislation.
Hazard identification and risk assessment.
Accident investigation.
Undertaking reviews, inspections and audits
There are a number of other issues that need to be considered in order to have a well
functioning OH&S Committee. These include:
Making workers aware of the name/s of their OH&S representatives.
Planning for OH&S Committee meetings.
Preparation of meeting agenda.
Ensuring OH&S Committee meetings are kept to a reasonable length, eg.
about one and half-hours.
Ensuring that all members of the OH&S Committee are allocated tasks and
given time to follow up those tasks outside normal committee time.
OH&S Communication

The presence of communication systems will ensure that persons at all levels within the
organization receive appropriate OH&S information.

Publications

One important aspect of establishing communication systems is to identify critical OH&S


publications and determine the distribution list for them. The implementation stage requires
that key OH&S publications are identified and that a register of those publications is produced.
Similarly the distribution for each publication must be identified and a corresponding register
produced. Having both of these document registers is evidence that key OH&S publications
are distributed to the appropriate personnel in a timely manner.

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Training

Good communication is not simply a matter of distributing documents to appropriate personnel.


To be effective Managers and Supervisors must also initiate communication on a personal
basis. Therefore, it is important that Managers and Supervisors have appropriate
communication skills. An assessment should be made of communication skills currently
possessed by Managers and Supervisors and, where appropriate, additional training is
provided.

OH&S Promotion

One of the most important functions of the OH&S Committee will be to engage in OH&S
promotion. There are a large number of ways that this outcome can be achieved and these
should be the focus of OH&S Committee considerations.

The OH&S Committee should consider the type of material that is currently available in the
organization and identify also sources of external promotional material, eg. ability to hire
videos, purchase other forms of OH&S awareness material, organize and run poster
campaigns, etc.

It is not the purpose in this document to prescribe any particular approach to OH&S promotion.
The topic of OH&S promotion is important because it raises the awareness of all persons at a
workplace regarding the importance of OH&S. The Committee needs to be aware of the type
of internal resources that are currently available, and those that are available for use from
outside the organization.

Language

It is recognized that at a number of Holcim sites different languages may be spoken.


Therefore, it is important that appropriate OH&S information is conveyed to all personnel. This
may require preparation of key information, such as policy and procedures, in multiple
languages. The site should demonstrate that it has reviewed this issue and produced
information in the appropriate manner and language.

Review of Consultative Arrangements

As with any process it is important that consultative arrangements are reviewed on an annual
basis. The OH&S Committee in consultation with the site management should, on an annual
basis, review its effectiveness, consider new initiatives, and consider also the need to change
the membership of the OH&S Committee.

12.4 Auditor Evidence

Evidence expected to be available in an audit is noted in section 12.3 above.

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13. INFORMATION AND REPORTING


U

13.1 Summary of Intent

If the other blocks of the pyramid are to operate effectively, it is essential that the OH&S
handbook and/or any other source or reference documents are readily available, properly
controlled and updated to reflect any changes and improvements made. Hence a document
Management System is essential.

Those companies with existing ISO9000 and/or ISO14000 systems should have this
substantially in place.

Reporting of OH&S performance results is fundamental, and this block describes the reports
needed internally within the Group company, internally to Holcim group level, and externally as
appropriate.

13.2 Details

General

Many sites may already have document Management Systems based upon the ISO9000 or
ISO14000 series of Standards. If this is the case, then the systems will be able to be used. A
document Management System is required:
To ensure that documents are able to be located.
To ensure that key information relevant to the ongoing management of OH&S
within the organization can be controlled.
To ensure that appropriate OH&S information is identified, collected, filed,
maintained and controlled.
To ensure that appropriate records can be retrieved.
To ensure that critical records are retained for an appropriate period of time.
To ensure that documents undergo periodic review and, as appropriate, are
revised and approved by authorized persons.
To ensure that current versions of relevant documents are readily available at
those locations where processes, which are essential to the effective
functioning of the OH&S Management System, are undertaken.
To ensure that obsolete documents are removed and suitably archived for
further reference.
As a minimum, document control procedures should apply to all procedures and documents
that will be subject to review, and other critical documents that may be identified by the
management team or OH&S coordinator.

It is essential that each new document be subject to document control.

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Document Management

The intent of this section of the OH&S Management System is to ensure that persons have
access to correct and up-to-date documents and that changes to documentation are only made
with the approval of authorized persons.

In order to effectively manage OH&S it is important that key documents are identified and
controlled at all stages. Therefore, it is expected that there will be procedures to:
Identifying OH&S critical documentation
Ensuring documents critical to OH&S carry an identification of their status,
authorization, date of issue and date of modification
The intended distribution of a document is specified on the document
OH&S documentation is effectively and systematically stored
Obsolete documents are promptly removed from use
A system exists for making and approving changes to documentation
A system exists for communicating changes in documentation to those people
on whom the document impacts.

13.3 OH&S Manual

It is often considered to be effective to summarize the key documents from the OH&S
Management System into an OH&S Manual. This should show how key aspects of the OH&S
Management System would be addressed.

A Group company OH&S Manual is likely to include information on:


Policy and Targets
Document control
Recording, reporting and planning
Organizational structures, roles and responsibilities
Task identification, analysis and performance management
Consultation and communication strategies
Design and planning
Risk management (Hazard identification, risk assessment, risk control
measures)
Emergency plans
Training
Permit systems and permits
Inspection, monitoring and testing
Incident investigation and reporting
Audit, inspection and review
Purchasing
Employee health & wellness
It may also be desirable to have a section in the OH&S Manual describing how the company
addresses the requirements of each block in the Pyramid.

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13.4 Records

Procedures should be in place for identifying, collecting, filing, maintaining and controlling
OH&S records.

Records are required to demonstrate the standard of OH&S management achieved and the
effectiveness of the OH&S Management System.

Records may include:


Minutes of OH&S Committee meetings
Incident investigation reports
Maintenance records
Air sampling records

13.5 Design Information

Adequate OH&S information is an essential prerequisite to effective hazard identification and


risk management. Systems must be in place to ensure that information is current and
available.

Suitable process design information should be available to permit operational personnel to


safely manage the plant and associated equipment.

Appropriate process design information should be available to operations and maintenance


personnel. This information may include:
A process flow diagram
Piping and instrument diagrams
Details of the process chemistry
Details of inventories
Details of upper and lower operational limits
OH&S related consequences of deviations from normal operation
Properties of materials used in the process
Detailed equipment drawings and diagrams.
Mechanical and electrical design information should be available to assist operations and
maintenance personnel, and may include the following:
Materials of construction
Piping and instrument diagrams
Electrical area classification drawings
Electrical diagrams
Design and basis of OH&S systems
Design of ventilation systems
Description of shutdown and interlock systems
Lighting/illumination system

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The mechanical design should be consistent with the requirement of local Codes and
Standards and reference should be made to these Codes and Standards. If design is not
consistent with Standards, then the differences should be documented.

13.6 Reporting

In addition to document control and the provision and recording of information, it is essential
that reporting of OH&S information occurs. The expectation is that all incidents will be recorded
in an incident register at each site. Based upon this information, the following reports must be
made.
SafetyAlert It is mandatory that a report be done on any accident causing
death or permanent disability. This can be done via HolSpace:
https://web.holcim.com/sustdev/polstrat/csr_intro.htm
HTU UTH

NOTE: This report can also be applied for any serious accident, near hit or
other incident the Group company feels should be reported.
Every Group company must report their performance with respect to achieving
the Targets annually. This is to be done by the OH&S coordinator completing
the Annual Safety Statistics Report and submitting it to the responsible HGRS
person.
Regular reporting within the Group company will be done via a report that is
currently being developed as part of the Holcim Information Platform (HIP)
project.

13.7 Auditor Evidence

The audit will confirm that a document control process is in place and that
Critical documents have been identified
Critical documents are controlled
The document control process is functioning
The Audit will review the adequacy of mechanical / electrical design information
as listed above. Mechanisms for the review and updating of mechanical design
information will also be addressed.
The Audit will review the adequacy of process design information as listed
above. Mechanisms for the review and updating of process design information
will also be addressed.
The Audit will review whether reports are made on time as well as looking at
their adequacy and accuracy.

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14. SAFE WORKING PROCEDURES

14.1 Summary of Intent

Safe Working Procedures

Although hazard identification and risk assessment encourages personnel to identify hazards in
all aspects of work activities, including work tasks, this element within the OH&S Management
System stresses the importance of detailed task analysis.

Hazards are introduced into the workplace because of the work tasks or activities that must be
undertaken to produce products and services. Therefore, it is important that key tasks are
analyzed in detail, that hazards are clearly identified and understood, that risk assessment
occurs, and that safe working practices are developed to ensure that personnel are protected in
undertaking these activities.

Worker Behavior Modification

This aspect builds upon task analysis and hazard identification and risk assessment, and
further stresses the importance of managing workers in undertaking tasks, and provides an
obligation for supervisors to undertake task observation and provide comment and feedback
regarding performance. One example of Worker Behavior Modification is job observation. This
is not aimed at introducing a form of policing in the workplace, but emphasizes that it is the
responsibility of supervisors to observe and manage their workers, and to provide suitable
feedback to those workers regarding their performance.

14.2 Task Analysis

Introduction

The OH&S risks experienced by an organization are related to the particular activities that
occur within an organization. For example, the types of risks present in a mining environment
are different to those present in an office environment. Therefore, it is important to be able to
analyze tasks undertaken in order to identify hazards and effectively manage risks.

General Comments

The topic of task analysis is closely related to hazard identification and risk assessment, and is
also related to Worker Behavior Modification - Refer to Appendix One where risk assessment
and task analysis are discussed in greater detail.

Hazard identification and risk assessment provides a general methodology for identifying and
managing OH&S issues. Task analysis is specifically focused on work tasks or work activities,

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whereas hazard identification is generally concerned with the physical layout and design of the
workplace as well as specific tasks.

The objective of task analysis is


To analyze in detail particular tasks,
To identify the hazards and risk involved at each stage of those tasks, and then
To ensure that suitable controls are put in place or proper task redesign occurs.
Details

Work procedures or work instructions should be available for work activities that are not
addressed by standard operating procedures. Standard operating procedures will deal with
particular OH&S risks associated with plant operation. However, there are many other
activities, which will not be addressed by operating procedures, and appropriate work practices
should be documented for these.

It is essential that documented procedures are established where the absence of such
procedures could adversely affect OH&S

Procedures should:
Conform with appropriate legislation and/or standards
Be prepared using risk management techniques
Be readily available
Be understandable by employees, i.e. targeted at the correct level of
complexity and language
Be monitored, reviewed and updated as necessary

14.3 Auditor Evidence

An audit will seek evidence of standard work practices generated by task analysis / risk
assessment. Other issues will include:
Records of task analysis
Training of personnel in task analysis and risk assessment
Communication of results of task analysis
Mechanism for review of task analysis outputs
Evidence of a structured behavior modification program

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15. INSPECTION AND TESTING


U

15.1 Summary of Intent

Where audits look at OH&S system performance, development and improvement, this pyramid
block deals with sophisticated inspection and testing techniques that are required to ensure the
ongoing reliability and OH&S of plant and equipment.

The inspections discussed in this section are different to those discussed in Section 6.
Employees with only low levels of training typically undertake the inspections discussed in
Section 6. The inspections discussed herein generally require employees with better
qualification and/or training to use sophisticated testing techniques.

Note that companies with existing maintenance cement systems (MAC) should have this block
substantially in place.

15.2 General Comments

This element requires that regular inspections and tests of critical plant and equipment be
undertaken. A good program should be based upon:
Identification of OH&S-critical plant and equipment
Identification of key OH&S functions, eg. trips, alarms
Development and documentation of maintenance work procedures and
practices
Training of maintenance employees in the application of the procedures
Quality control procedures to ensure that maintenance materials and spare
equipment meet design requirements
Procedures to ensure that maintenance employees and contractors are
qualified to undertake repairs
Procedures to ensure that changes in technology and facilities are
appropriately reviewed.
Recommended intervals between the inspection and testing of equipment for OH&S issues
should be specified.

15.3 Inspection Topics

Inspections may be applied to a range of different areas and activities within the workplace.
These include the various topics listed in the table below.

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Each site should determine those topics for which inspections are required. This may require
inspections in addition to those listed below.

Buildings and Roofs Lighting/Illumination


Electrical Portable Electrical Equipment
Earth Leakage Circuit Breakers Lifting Gear
Pressure vessels Fire fighting equipment
Emergency Stop Systems Security & Fencing
Indoor Air Quality Lightening Protection
Overhead Cranes/Gantries Fixed Lifting Points

Brief descriptions of topics that may receive routine inspections are listed below.

Buildings and Roofs

Regular inspection of buildings and roofs should be undertaken. The types of issues that may
need to be considered are:
Structural integrity of building
Quality of access and egress (exits)
Quality of roof to prevent water entry
Structural integrity of roof and OH&S associated with persons moving across
roofs
Tie-down of roof and potential to lose roofing material in bad weather
conditions.
Lighting
Lighting should be inspected on a regular basis to identify deficiencies or changes in lighting
levels. A baseline survey should be undertaken to record light intensities at strategic locations,
and these should be compared with the requirements of relevant standards. Ongoing
monitoring should review changes in light intensity.
Electrical
Electrical equipment should be inspected and tested by a qualified electrical tradesperson. A
register of electrical equipment should be developed and the testing program undertaken in
accordance with the relevant local standards.

Portable Electrical Equipment Inspection


There is a requirement that items of portable electrical equipment are inspected on a regular
basis. The frequency of inspection depends on the nature of the equipment and its usage. An
inventory of items of portable electrical equipment (and their location) should be developed.
The register should also provide an indication of test interval and confirmation that testing has
been undertaken.

Earth Leakage Circuit Breaker / Residual Current Device Inspection

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This inspection serves a similar purpose as that regarding portable electrical equipment. Each
earth leakage circuit breaker (or residual current device) should be identified, including location
and test intervals specified. The inspection can then be used to confirm that the appropriate
testing has been undertaken. Generally, legislation or applicable Standards and Codes will
specify testing requirements.

Lifting Gear
Items of lifting gear should be identified and recorded in a Register, including their usual
location. In addition, where appropriate, a Safe Working Load (SWL) should be marked. The
SWLs applicable should be marked on shelving where lifting gear is stored. Regular testing of
lifting gear is required. Qualified personnel should inspect lifting gear and make
recommendations for repair or replacement as appropriate.

Pressure Vessels
The requirement for testing of pressure vessels and associated pipe work and valves is
generally covered directly by legislation or through appropriate pressure vessel Codes. A
register of pressure vessels should be developed, including specification of the type of
equipment, location, design pressure limits and required testing interval.

Fire Fighting Equipment Inspection


The purpose of this inspection is to ensure that all items of fire fighting equipment present at a
workplace are identified and documented. Items will include fire extinguishers, fire blankets,
fire hoses, fire pumps and other supporting items of fire fighting equipment. The location of
each item should be specified and the required test interval also included on the inspection
form. The required test interval for different items of fire fighting equipment is generally
specified by the appropriate Standard or Code. The inspection form enables the due date for
the testing to be identified and confirmation that the test has actually been done can also be
included on the form.

Emergency Stop Systems


Emergency stop systems associated with plant and equipment should be identified and
documented. A structured program for proof testing the effectiveness of these should be
implemented, with results recorded.

Other Inspections
Other areas of consideration for inspection may include:
Corrosion monitoring
Structural integrity checks (especially tall structures)
Condition monitoring of bearings and drives
Monitoring of natural hazards
Areas agreed with local authorities and/or insurance companies

15.4 Critical Parts and Equipment

Procedures should be in place to ensure that critical parts and equipment are tracked during
the fabrication stage, and that appropriate checks and inspection procedures are established
and implemented to ensure that the installation of equipment is consistent with both the design
and the manufacturer’s specifications.

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15.5 Auditor Evidence

An audit will seek evidence supporting the requirements noted above.

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16. DESIGN SAFETY


U

16.1 Summary of Intent

There are many ways of controlling risk in the workplace. However, the most effective way of is
to ensure that, where practicable, hazards are eliminated at the design stage, or where this is
not practicable, the mechanism for control of those hazards, is incorporated intrinsically into the
design. This element of the OH&S Management Pyramid requires the establishment of
processes to ensure that all new designs are reviewed and hazards identified prior to
construction of the plant or implementation of the particular change. This element also requires
that designs be based upon internationally recognized standards, and that a design should also
take into account human factors as well as the practicalities of engineering design.

This also cover the requirements of "due diligence" in identifying the necessary safety
equipment, documented procedures and training to be included in new projects, mergers and
acquisitions, etc.

16.2 General Comments

OH&S Management must start at the initial design and planning phase and be an integral part
of all phases of a project or activity; ie. planning, design, procurement, construction, operation,
maintenance, modification, decommissioning and rehabilitation.

This particular element requires that consideration of OH&S issues be included in the design
phase for plant, equipment and operations. Furthermore, a design should reflect consideration
of the hierarchy of risk controls (see Appendix One), and formal design review should be
conducted at appropriate stages in the development a design.

It is important also that there is a clear linkage between the design and the documentation
generated by the design process.

The following techniques may be applicable:


Broad-brush review
Design review
Design standards
HAZOP/HAZAN study
“As built” study
Commissioning risk assessment
Updating of drawings

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16.3 Details

Design Process

Consideration of OH&S issues must be included in the design phase for plant, equipment and
operations. The most effective way of managing OH&S is to ensure that risk control features
are incorporated into the design of system, plant or equipment. Therefore, it is important that:
Design responsibility is clearly defined
Designers are suitably qualified and competent
Designers are trained in risk management principles and practices
Adequate resources are provided in relation to design
Design is based upon relevant Standards
Design seeks to address relevant issues within legislation.
Risk management activities are included in the design process (at an early
stage in the process)
Design Issues

Plant is a general term used to define a range of equipment and machinery used in the
workplace. Typically there are many phases of plant life and hazards may exist in any phase.
Phases include:
Design
Manufacture
Storage
Transportation
Installation
Commissioning
Use
Cleaning
Setting and adjustment
Inspection
Maintenance, servicing and repair
Modification and refurbishment
Decommissioning
Dismantling and demolition.

Key issues to consider in designing plant include:-


Legislation, standards, codes and guidelines that may be applicable
Intended use and reasonably foreseeable misuse
The nature of persons who will use the plant
Designing to facilitate safe use
Environmental conditions
Erection and installation
Maintenance

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Provision of information
Provision of guarding
Identification of energy sources
Static electricity
Fire and explosion
Noise
Vibration
Radiation
Lighting and illumination
Release of substances
Testing of plant and operational stability
Control devices and operating controls

Hierarchy of Risk Controls

Design should reflect a consideration of the hierarchy of risk controls. OH&S risks can be
managed in a number of ways. Effective design should consider each of the elements of the
hierarchy and, where practicable, and incorporate the most important. The hierarchy is:
Elimination
Substitution
Separation/isolation/engineering
Administration
Personal protective equipment.

16.4 Auditor Evidence

The audit will seek evidence of:


Hazard identification
Occurrence of design reviews
Documentation of design risk studies
Evidence of attempts to eliminate the need for PPE
Consideration of OH&S in design reviews
Completion of recommendations
It is important that there is a clear linkage between the design and the
documentation generated by the design process.

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17. AUDIT AND SYSTEM IMPROVEMENT

17.1 Summary of Intent

A system of internal audits is essential to monitor and review the performance of those
elements that have been implemented, and ensure the ongoing functioning and improvement of
an OH&S Management System. Internal audits do not have to be extensive site wide audits,
but may be internal reviews conducted within a particular department or work group aimed at
reviewing the implementation and performance of the OH&S Management System in a specific
area. For example, in relation to high-risk work activities, it is recommended that internal audit
reviews of the performance of the work permit system be undertaken on a regular basis.

Similarly, internal audits should be undertaken in relation to the effectiveness of incident


investigation, risk assessment etc. Outputs from internal audits can then be linked to the
corrective action system to ensure that improvements are locked into place.

Although internal audits provide feedback regarding the effectiveness of OH&S management
performance, it is important that an external audit by an independent party be undertaken to
provide a full and objective review of the performance of the OH&S Management System.

External audit also provides feedback to senior management to assist them in their ongoing
system improvement and development.

17.2 General Comments – Internal Audit

An internal audit program should be developed with aim of reviewing key aspects of the OH&S
Management System. An audit program should be prepared with a risk-based audit frequency.
Auditors should be trained by means of a recognized internal auditor’s course. Audit
recommendations should be followed-up through the corrective action request system.

17.3 General Comments – External Audit

Internal audit provides ongoing feedback regarding the effectiveness of OH&S management
performance. External audit by an independent party should be undertaken to provide a full
review of the performance of the OH&S Management System. The external audit will provide
feedback to senior management assisting them in the process of planning the ongoing
development and improvement of the OH&S management program.

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A suitably qualified auditor should undertake an external audit, and the audit results reported to
site management. This person or persons (in a team) could be drawn from HGRS or other
Holcim companies and do not have to necessarily be from a 3rd party (external) organization.
P P

Any recommendations from the external audit should be part of the site’s OH&S Plan.

17.4 Auditor Evidence

An audit will seek evidence of:


Internal audit program
Trained internal auditors
Linkage to Corrective Action System
Review of all audit recommendations
Reports, reviews and system improvement

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18. OCCUPATIONAL REHABILITATION


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18.1 Summary of Intent

Corporate social responsibility (CSR) addresses how a Group company manages its societal
obligations and expectations. One key issue from an OH&S viewpoint is occupational
rehabilitation. Implementation of this block requires close cooperation between all relevant
stakeholders.

18.2 Rehabilitation

Although the primary aim of any OH&S Management System is to prevent the occurrence of
incidents and injury, it is important in those situations where an injury or illness has occurred,
that assistance is provided to an employee to return them to meaningful work as soon as
possible. Therefore an effective employee rehabilitation scheme should be in place to return
employees to productive work as soon as possible after a lost time injury or after contracting
work related disease.

The rehabilitation scheme should be in place consistent with the requirements of any local
Workers’ Compensation/Insurance Legislation.

Key issues to consider in a structured rehabilitation program are:


Appointment of a person responsible for coordinating rehabilitation
Preliminary liaison with company doctors and local doctors about the feasibility
of light duties programs
Structured procedure to identify injured persons and ensure that an early
indication and understanding of the nature of their illness or injury is identified
to the rehabilitation coordinator
Identification of potential light duties available in consultation with the injured
person and the doctor
Implementation of a formal light duties program for an injured person
Ongoing monitoring of the progress of an injured person
Criteria and processes for deciding when a person is able to fully resume
duties.

18.3 Auditor Evidence

An audit will seek evidence of:


An occupational rehabilitation program
A properly trained coordinator
Records showing the program is working

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19. PROCUREMENT
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19.1 Summary of Intent

Just as design safety is an important way of ensuring that hazards are not brought
unnecessarily into the workplace, so management of procurement activities is also a way of
preventing new hazards from entering the workplace. Taken together, these two elements are a
combined approach to ensure that emerging OH&S issues are identified and controlled.

This OH&S pyramid block sets guidelines for ensuring that the procurement process for any
new plant and equipment, goods or contractor services, is subject to a review process in which
hazards are identified, risks are assessed, and appropriate control measures planned and
taken prior to introduction.

19.2 General Comments

It is important that procedures are in place to ensure that the OH&S requirements of procured
materials and equipment are specified and met. To ensure OH&S issues are included in the
process that defines how suitable equipment and services are obtained, the appropriate OH&S
coordinator shall be consulted during the specification process. Further, the OH&S coordinator
shall be asked to assist by providing OH&S input during the making of procurement decisions,
if necessary.

19.3 Details

Procurement and Suppliers

The most effective way of dealing with any OH&S problem is to eliminate or minimize the
problem. One pro-active way of doing this is to ensure that controls are placed upon the
procurement of items of plant, equipment, and substances. The types of issues that can be
addressed by an effective procurement policy are:
Ensuring that only OH&S equipment that meets criteria set by the Group
company is procured, eg. hard hats, safety glasses, boots, respiratory
protection, gloves, fire-resistant clothing, etc to ANSI or OSHA standards.
Ensuring that when items of plant and equipment are procured, OH&S and
particularly ergonomic considerations are taken into account prior to placing an
order, and when the goods are received on site that appropriate documentation
relating to any OH&S aspects is obtained; etc
An effective procurement system will also ensure that:
All the additional information needed to undertake maintenance work in a safe
way is obtained

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Material Safety Data Sheets are obtained before the procurement or receipt of
a chemical (risk assessments can be undertaken before the chemical is used)
Persons involved in procurement are always made aware of the OH&S issues
that need to be taken into account in the procurement process
People in procurement and stores should be included on OH&S training schedules relating to
hazard awareness. Prior to purchasing, an evaluation should be carried out to ensure that
materials and equipment to be procured meet:
Legislative requirements
Relevant Standards and Codes
Hazardous chemicals requirements
Any other OH&S performance criteria or specifications.

Procurement documents must clearly describe the goods and specify OH&S needs. A system
should also be in place for verifying that the goods supplied meet them.

Contractors

Contractors are best controlled in terms of OH&S performance through the selection process.
The process of selecting a suitable contractor should involve consideration of that contractor’s
past OH&S performance and whether they can show evidence of having an effective OH&S
Management System operating.
Control of contractors is important for various reasons.
The company may have a duty of care to contractors who are working for it.
Where it exists, part of this duty of care involves informing the contractor of the
types of hazards to which they are likely to be exposed and having systems of
supervision and control that ensure that the OH&S of the contractor’s
personnel are protected.
It is also important to control contractors by preventing them undertaking tasks
or working in areas where it is considered that it is unacceptable for them to
work. There may be, for example, high-risk areas in a plant where very specific
training is required in order to work there. Part of the control placed on a
contractor would be non-entry to certain areas without having received specific
induction training.
So despite the contractual arrangements that may exist, OH&S for contractors should be
addressed in the same way as that for an employee.

19.4 Auditor Evidence

An audit is expected to address the details noted in section 18.3, including:


Procedures to ensure that OH&S requirements of procured materials and
equipment are met.
Evidence of consideration of OH&S requirements in the procurement of
materials and equipment.

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A selection process for contractors based in part upon their ability to meet
clearly defined OH&S requirements.
Evidence of consideration of OH&S requirements in the procurement of
services.

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20. MANAGEMENT OF CHANGES


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20.1 Summary of Intent

Management of changes builds upon the elements of Design OH&S and Hazard Identification
and Risk Assessment. The inclusion of this element is recognition of the fact that
circumstances in the workplace will change over time, and that changes may introduce new
hazards or alter the effectiveness of existing OH&S Management Systems and controls.

Therefore, a risk-based Management of Changes procedure is required to identify hazards


associated with proposed changes and ensure that those hazards are effectively controlled
prior to the implementation of the change.

This block establishes a risk-based procedure to check for actual or proposed changes,
examine the hazards associated with them, and ensure:-
Changes are documented and recorded as required in the Information &
Reporting Pyramid block
Hazards are effectively controlled prior to the implementation of any changes
as required in the Design Safety element

20.2 General Comments

An organization and its facilities may be subject to continual change to increase efficiency,
improve operability and safety and accommodate innovation and improvement. These
changes may introduce new hazards or alter existing risks. Therefore, appropriate systems
should be in place to manage changes.

The purpose of this element is to ensure that when a change is made to an organization's
activities, products or services, the associated changes to OH&S aspects and impacts are
identified at, or preferably before, the time at which the change is made. All of these factors are
considered within the context of determining whether the change requires a change in OH&S
objectives and targets and an overall change in the OH&S Management Program.

The Management of Changes procedure addresses both physical change and also changes in
policies, standards, and work instructions. It is a critical procedure because it is through the
Management of Changes procedure that a site will develop amended policies and standards
and determine their impact on operations. This is a key aspect in the implementation of the
OH&S Management System and provides the bridge between the global policies and standards
and the specific instructions that provide guidance to workers at lower levels.

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20.3 Details

Many OH&S problems emerge because changes (to technology, plant, equipment or systems)
are made which destroy or diminish the integrity of plant and equipment or existing OH&S
systems. Therefore, it is necessary that:
Changes are identified
Changes are analyzed and assessed for OH&S implications
Suitable risk controls are implemented
Changes are communicated to affected personnel
Changes are made to associated documentation
Changes are authorized
A sample Management of Changes form is included in Appendix Two.

20.4 Auditor Evidence

An Audit will seek evidence of:


A management of changes procedure
Implementation of that procedure
Completion of all aspects of the procedure
Identification of changes
Documenting changes
Use of a management of changes form

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21. HEALTH AND WELLNESS ISSUES


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21.1 Summary of Intent

Effective management of OH&S is not confined solely to the workplace and workplace
activities. Many issues may impact on the ability of a worker to perform tasks and functions in
a safe and efficient manner. This element of the pyramid addresses broader health and
wellness issues, some of which are directly related to workplace activities and others may be
related to business activities outside one’s normal work.

This block is a key element within the corporate social responsibility program, and recognizes
Holcim’s commitment to addressing issues beyond the bounds of a particular work site.

21.2 Employee Assistance Program

Each Group company should have in place an Employee Assistance Program, consistent with
the requirements of local customs and legislation. Such a program could be developed in
consultation with the OH&S Committee and external experts (doctors etc) and be aimed at
addressing issues such as substance abuse, stress, post-trauma counseling, etc

21.3 Other Issues

As a minimum, each site should demonstrate that risks associated with the following have been
assessed for their workforce:
Precautions for overseas travelers (eg. vaccinations)
Management of endemic diseases (eg. malaria, cholera, etc)
Stress management and counseling
Drug and alcohol awareness (substance abuse)
Communicable diseases (eg. HIV/AIDS)
Quality of life (eg. balancing time at work to time for recreation/with family)
Other general health and lifestyle issues (eg. stop smoking, diet, fitness, etc)
Where the risk assessment finds a level of risk where action is necessary, appropriate systems
for managing the risk(s) should be introduced into the workplace.

21.4 Auditor Evidence

An Audit will seek evidence that other issues decided as relevant to the employees in the
Group company are being dealt with appropriately.

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APPENDIX ONE: RISK MANAGEMENT METHODOLOGY

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Introduction
The first phase of the risk management process is hazard identification.

The purpose of hazard identification is to construct a comprehensive list of hazards associated


with any particular asset, item of plant, work practice, work area etc. The fact that many
hazards may exist is not necessarily an indication that there are significant levels of risk
because the hazards may be well controlled.

Therefore, it is always important to maintain a clear distinction between the process of


identifying hazards, and subsequently analyzing the risk associated with them.

Definition of Hazard

A hazard is typically defined as "anything that has the potential for harm or a potentially
damaging energy source".

The key word in the definition of hazard is the word potential. By defining a hazard as a
potential for harm, one is not stating that the harm will actually occur. Therefore, the notion of
hazard is a notion of possible harm and possible future consequences. In hazard identification,
one is attempting, through a range of techniques, to identify what could happen and the types
of energies present in a workplace that could cause injury, illness, or property damage.

Sources of Hazards

As noted above, hazards can be identified as different types of damaging energies. Examples
of damaging energies include:
Thermal
Electrical
Chemical
Radiation
Biological
Vibration
Noise
Gravity
Kinetic
Mechanical
Potential

In general terms, hazards can be associated with three categories.


People
The workplace layout and general work environment.
Work practices

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1. People

There are potentially damaging energies associated with people. These are damaging
energies associated with physical/muscular exertion, activities such as:

Lifting
Striking an object
Being struck by another object
Pushing/pulling/restraining
Repetitive strain
Postural strain

Some risks may arise because of mismatches between people, the tasks that they must
perform, and the equipment that they must use. Care must be taken when assessing people
as new employees may be at greater risk performing a task than older employees with years of
experience behind them. On the other hand younger employees may be more agile and
physically fitter than older employees.

2. Workplace Layout and General Environment

Many different hazards exist in the design and layout of the workplace, and the general work
environment. Examples of damaging energies include:
Thermal
Machinery: mobile, fixed
Chemical
Electrical
Noise
The hazards associated with this category are those that arise from the type of plant and
equipment that are in use, the general design and layout of the workplace and the broader work
environment in which the workplace is located. Usually these types of hazards are the easiest
to identify, and often (unfortunately) hazard identification does not proceed beyond this stage.

3. Work Practices

Many hazards arise through work practices, and many workers are exposed to hazards as that.
For example, a chemical hazard may be present in the form of chemicals stored in drums.
However the way that workers are exposed to the chemical will depend upon the work
practices that are adopted. Particular work practices may also affect the nature of the hazard;
eg., a chemical normally in liquid form may be sprayed in an airborne state where it can be
easily inhaled.

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Identification of hazards in work processes is probably the most difficult part of hazard
identification, and therefore such hazards are often overlooked. Because work practices may
change on a daily basis, the nature of hazards and worker exposures to those hazards may
also change. Safe work practices are one way of addressing such hazards. For new or
unusual tasks, hazard identification and risk assessment should be undertaken before the
commencement of the task. The process management approach will assist to clarify work
practices and associated OH&S issues.

Techniques for Hazard Identification

Summary

A range of techniques exists to assist in hazard identification. They include:

Job Safety Analysis


Review of incident data
Consultation with workers
Brainstorming
Use of checklists
Observation
Flowcharting
Experts
Each of these techniques is discussed in more detail below

Job Safety Analysis

Job Safety Analysis reports promote safe work practices and safe systems of work.
They help sites ensure employees’ safety and health by documenting work procedures
for each task that each employee has to carry out and listing the associated hazards,
risks and control measures. They provide employees with information and instruction
required under safety & health laws and act as a sort of standardized work procedure.

Review of Historical Data

Reviewing historical data is an effective way of identifying those hazards that have
caused injuries or property damage in the past and the Pareto Chart is very effective in
presenting historical data in a way that emphasizes the key problem areas.

Because the hazards displayed in a Pareto Chart have been involved in past incidents,
it can reasonably be expected that controls for those risks would have been developed
and implemented in relation to those hazards as related to those incidents. However,
reviewing historical data will not enable a focus to be made on the type of hazards that
may be present in other circumstances where controls may not exist.

Consultation with Workers

Consultation with workers permits those persons who are exposed to the hazards on a
daily basis, and who have to deal with those hazards, to provide relevant information.
It is always workers who know ‘what really happens’, rather than what is dictated by a

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particular policy or procedure. Workers also may be aware of incidents that have
occurred in the past that have not been formally documented or reported.

Brainstorming

Brainstorming is a technique that is used to tap the creative thinking of a group of


people. Consultation with workers may occur via brainstorming, but it may also involve
other people; eg. OH&S experts, managers, etc

Use of Checklists

Checklists can be used in hazard identification to focus attention on particular hazards


and collect relevant data. It is often convenient to construct checklists based upon the
results of previous hazard identification activities or upon a review of historical data.
The main advantage of checklists is that they are easy to use and are good at focusing
attention on particular issues. Their major disadvantage is that by focusing on some
particular hazards, other significant hazards may be ignored.

Observation

Direct observation is also an effective technique for identifying hazards. Observation


may be undertaken in conjunction with the use of a checklist or other suitable recording
device, eg. video camera. Observation may be used for studying work practices and
identifying hazards associated with workplace layout/design and environment,
ergonomics and patterns of flow, etc.

Flowcharting

It has already been noted that it is essential that hazard identification addresses
hazards associated with work practices. Although this can be partly achieved through
observation, flowcharting is a systematic technique that can be used to break a work
practice into its component parts and allow identification of hazards at each step of a
work practice. Using a flowchart in this manner can provide the basis for
HAZOP/HAZAN studies as well as the subsequent development of safe work practices
for each of the steps.

Selection of Hazard Identification Techniques

As noted above a range of techniques are available for undertaking hazard analysis.
For example, if the focus is on work practices then techniques such as observation and
flowcharting should be used. If, however, the aim is to identify hazards associated with
workplace layout, then observation, checklists, and consultation may be more effective.
Relevant historical data should be reviewed on all occasions.

It is essential in the longer term that all types of hazard (different damaging energies)
and all sources are addressed (people, practices, layout, and environment). In
addition, the human factor (people are fallible) should also be addressed by having a
system to make sure that the person with the right abilities, skills and training required
for the position is actually filling it (this is a normal function of Human Resources).

Definition of Risk
Risk is the chance of something happening that will have an impact on objectives or
targets. It is measured in terms of likelihood and consequence and may arise from an
event, an action or from a lack of action.

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Likelihood is used as a qualitative description of statistical probability and frequency - it


is often given in % terms. Significance is the outcome of an event or situation,
expressed qualitatively or quantitatively. This could be negative (ie. a loss or
worsening in situation); or positive (ie. a gain or improvement)

The key issue to address in managing OH&S is the management of risk. There will
inevitably be many hazards with the potential to cause an impact on objectives existing
in a workplace. The key issue to consider is what is the level of risk is actually posed
by these hazards. A good OH&S Management System normally attempts to eliminate
some hazards and minimize the risk associated with others.

Risk Analysis and Assessment


Simple Risk Assessment
In some situations, risk assessment is simple. For example, the problem and solution
may be obvious and the solution may be easily found and implemented, eg. identifying
and removing a trip hazard.

Complex Risk Assessment


In other situations, undertaking risk assessment may be extremely complex, and may
require various scientific measurements to be made. Generally, where the nature of
the risk is such that the impact develops over a period of time, eg. exposure to
chemicals, radiation, noise, then a more complex assessment is required. Such
assessments are generally topic-specific and are not addressed in detail in this
Handbook.

Risk Calculation Matrix


One simple but extremely useful methodology for risk analysis is based upon a five by
five matrix.

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Consequence can be rated from a ranking of 1 (considered minor) to 5 (catastrophic),


as shown in the table below.

Consequence

RANKING DESCRIPTION OF CLASSIFICATION


1 Illness, injury requiring first-aid or no treatment
2 Medical (doctor) treatment
3 Single serious (hospitalization) injury
4 Single death or major permanent disablement
5 Multiple deaths

Likelihood ranks from A (considered certain) to E (improbable) with a range of values in


between as shown below. IMPORTANT: Typically the likelihood scale is logarithmic
with each succeeding level being a factor of ten times more or less likely than the
adjacent level.

Likelihood

RANKING DESCRIPTION OF CLASSIFICATION


A Expected many times per year
B Expected about once per year
C Expected between once every year and once every 10 years
D Expected between once every 10 years and once every 100 years
(possibly once or twice in the life of a site/plant)
E Expected between once every 100 years and once every 1000
years (not expected to occur in the life of a site/plant)

Once a risk has been assessed according to the classification descriptions above, a 5
X 5 risk analysis matrix is then possible in which consequence and likelihood are
combined to give a measure or ranking of risk. Risks are ranked from low (possibly
acceptable) to extreme. The purpose of this risk analysis matrix is to provide a
prioritization of risks and therefore the basis for developing risk management plans and
allocating valuable risk management resources.

Consequence 1 2 3 4 5
Likelihood
A H H E E E
B M H H E E
C L M H E E
D L L M H E
E L L M H H

E = Extreme risk - immediate top management action required.


H = High risk - senior management attention required quickly
M = Moderate risk - management responsibility must be specified
L = Low risk - manage by routine procedures; eg. Work Instructions/SWPs

So, to simply assess a level of risk, the process is:

1. Identify a hazard or incident scenario

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2. Identify existing risk controls


3. Identify the consequences and likelihood for a given scenario (this may be done by
assuming the existing controls to be in place, or by calculating the risk in the
absence of controls).
4. Assign Likelihood and Consequence rankings from the tables above.
5. Combine them in the matrix to give a measure of risk.
6. Implementing the appropriate actions based upon the risk ranking

Risk Control in OH&S

Introduction

Hazard identification is the process to identify potential sources of harm or sources of


potentially damaging energy. The fact that a hazard may exist in the workplace does
not necessarily mean that it will cause harm to a person or to property. It may be that
the risk associated with that hazard is adequately controlled by some existing risk
control mechanism.

Therefore in undertaking risk assessment it was noted that it is important to determine


and identify existing risk controls before trying to determine the consequences and
likelihood relating to a particular hazard. When this is done, and consequences and
likelihood are combined, a measure of risk is obtained and this may be compared
against criteria to determine whether the risk is or is not acceptable.
If it is considered that the risk is acceptable, then, no additional action will be required
other than on-going monitoring and review to ensure that the level of risk remains
acceptable.

If however risk analysis and risk assessment indicates that the level of risk is
unacceptably high, then action needs to be taken. With regard to OH&S risks, this is
referred to as risk control. The purpose of risk control is to modify either consequences
or likelihood (or preferably both), such that the level of risk is reduced to an acceptable
or tolerable level. In this section, general strategies that can be used to control risk are
discussed.

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Risk Control Strategies

It is considered that there is a hierarchy of risk control options. By calling them a


hierarchy, it indicates that there are a number of risk control options but that some are
better or more preferable than others. The hierarchy of controls is:

ELIMINATION

SUBSTITUTION

ENGINEERING

ADMINISTRATIVE

PERSONAL PROTECTIVE EQUIPMENT

Note that any control measure adopted must achieve the following criteria:
Adequately control exposure to the risk;
Not create another hazard; and
allow workers to do their work without undue discomfort or distress.

Each of the "hierarchy of risk controls" is now discussed in more detail below.

Elimination

The best way to control a hazard in the workplace is to eliminate it, i.e. if the hazard is
eliminated then all the risk associated with that hazard is also eliminated and there are
no further problems relating to the control of that particular hazard. Elimination of a
hazard involves some form of redesign of a workplace or a process. In many situations
this may be quite simple and may not necessarily involve a lot of time or expense.

Hazard elimination is the most preferable risk control option because it


comprehensively changes the nature of the workplace and protects workers by
ensuring that the hazard is no longer present. It does not require or rely upon the use
of mechanical equipment, the use of procedures, the use of PPE or the
cooperation/knowledge of particular persons.

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Substitution

Although hazard elimination is desirable often it is not possible to eliminate a hazard.


In fact, although some hazards may be able to be eliminated, the vast majority will
continue to be present at the workplace. The fact that work is being undertaken, that
equipment is being used, that chemicals are being used, that persons are involved in
various types of manual activity, means that there will be a whole range of hazards
present. Ultimately the only way to eliminate such hazards would be to discontinue the
particular work activity.

Once a workplace is established a large number of hazards will also be introduced and
the vast majority of those hazards will persist for the lifetime of the workplace. The
strategy of substitution requires substituting something that is less hazardous for
something that is more hazardous.

For example, replacing a noisy piece of equipment with a new item of equipment that is
less noisy is an example of substitution. There is a noise hazard present in both
circumstances. However, with less noisy equipment the hazard is significantly reduced
because substitution has occurred.

Another example of substitution is to use a chemical in a pellet form rather than in a


powder form. Solids that are present as powders may become airborne and so may be
inhaled by persons. On the other hand, a chemical that is present in a pellet form will
less easily become airborne, and therefore the level of risk in that situation will be
lower. Substitution therefore is a highly desirable risk control strategy.

Elimination and to a lesser extent substitution are the preferred risk control strategies.
The main reason why they are preferred is that they make a fundamental change to the
nature of the workplace. As noted above, elimination comprehensively removes a
hazard from the workplace. Substitution on the other hand reduces the degree or
severity of a hazard. Both of these strategies are independent of other aspects of the
workplace, i.e. they do not require the continuous functioning of particular items of
plant, they do not require people to understand and use procedures and they do not
require the use of particular items of PPE.
When considering risk control it is important that the possibility of elimination or
substitution is seriously considered as the first step. In many situations, these may not
be possible or realistic risk control strategies. However it is necessary that they are
considered and, if possible, actions taken in this regard.

Elimination and substitution are often not the quickest-to-implement control options that
can be chosen. It is recognized that sometimes it may take a considerable period to
apply either of these risk control strategies. To eliminate a hazard, for example, may
require the redesign of a workplace and changing of work processes. In many
situations, this may require significant capital expenditure that will need to go through
various approval stages. In addition, associated design work will also need to be
undertaken. However, Elimination and substitution should always be considered and if
possible implemented.

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Engineering Controls

The next control in the hierarchy of control options is engineering controls. Types of
Engineering controls are varied and examples are:

Ventilation systems
Separation of workers and hazards
Isolation

Fundamentally, an engineering control is one that changes or affects the way a hazard
and the worker may come into contact. Therefore, an engineering control places a
barrier between a worker and the hazard. The worker is unable to come in contact with
the energy source that constitutes the hazard.

It should be noted that an engineering control does not make any fundamental change
to the nature of the hazard. For example, use of a ventilation system in an area where
hazardous fumes are present is an example of an engineering control. The hazard in
this situation is a chemical hazard associated with the chemical composition of the
particular dust or fume. Installation of a ventilation system will protect workers by
removing the fumes from the work area and venting them into some other safe
location. However, the ventilation system does not prevent the fumes from being
generated and therefore the nature of the hazard is unaltered. What is altered is how
the hazard and the worker can come into contact. If an engineering control fails or
ceases to be present then a worker will be exposed to the original hazard or energy
source.

Another example of an engineering control is a guard that prevents a worker coming


into contact with moving mechanical equipment. A guard is very effective while it is in
place. However on many occasions guards are removed during maintenance work and
are not reinstalled. If this does occur, then the hazard associated with the mechanical
equipment is uncontrolled and the worker is exposed to a higher level of risk.

Therefore, although engineering controls are very effective in the areas in which they
are applied, engineering controls also require on-going monitoring, observation and in
some situations maintenance to ensure that control remains in place and continues to
perform its desired function.

Administrative Controls

The fourth type of control in the hierarchy of risk controls is administrative controls.
Administrative controls refer to those ways in which risks are controlled by procedures
or particular rules and regulations. Regulatory authorities, eg. Acts of Parliament and
associated Regulations, may define administrative controls. Administrative controls
may also be present in particular Standards and Codes that may be applied in a given
industry. For example, a Standard for Safe Working in a Confined Space is an
administrative control because it defines a series of requirements that must be in place
before a person can work in a confined space.

Many administrative controls are generated at a particular worksite in response to the


risks associated with a certain type of hazard. Therefore, the requirement to follow
certain safe working practices when doing a job is a particular form of an administrative
control. A well-developed administrative control will be effective in the control of risk.
However for an administrative control to be effective it is necessary that the persons to
whom the particular administrative control applies are aware of the control, understand
the need for the control and have the skill, knowledge and experience to make control
work.
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There are numerous instances where administrative controls have existed but for
various reasons persons do not follow the requirements of a particular administrative
control and as a result suffer an injury. Administrative controls therefore require the
cooperation and involvement of workers at a worksite and this introduces a range of
additional issues. Aspects relating to human factors in risk assessment are discussed
in a following section.

Role of Task Analysis

The risk assessment process involves identifying hazards, assessing risk and if the risk
is unacceptably high putting in place risk control strategies. Often the major focus of
hazard identification is the physical layout and design of the workplace, i.e. hazards are
identified in terms of storage of chemicals or other forms of equipment, access, and
other states of affairs that exist in the workplace.

One of the major sources of hazards in a workplace, however, is within work practices;
i.e. workers are exposed to hazards because of the types of jobs that they do and the
way they do those jobs. Therefore task analysis is an essential aspect of any OH&S
Management System and incorporates the previously discussed aspects of risk
assessment. The outputs of task analysis are safe working practices.

Strategy: The key strategy involved in task analysis is to document particular work
tasks. Until a work task is formally documented, it is difficult to identify the types of
hazards to which a worker is exposed and the nature of the risk associated with those
hazards.

Documentation must be developed in consultation with the involved workers. It is


important in documenting work practices and work tasks that workers are comfortable
to discuss the actual practices that they use and adopt rather than those that might be
specified in any existing procedure or be assumed by management to be undertaken.
The quality of task analysis and the development of subsequent safe working
procedures will depend upon the accuracy with which a particular task is documented.

Risk Assessment: After a task has been documented, it is possible to undertake a risk
assessment of the risks associated with the task. This is done by reviewing the task
and asking at each stage of the task what are the hazards associated with that task or
what are the sort of incidents that could occur leading either to personal injury or
property damage.

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Based on these identified hazards or incident scenarios it is then possible to estimate


consequences and likelihood and determine risk. Once risk is determined it is then
possible to decide whether the risk is unacceptably high and, if that is the case, risk
controls must be applied.

Task analysis as with any other risk assessment strategy provides the opportunity of
using a range of different risk control solutions. Initially in task analysis one should
attempt to determine whether or not fundamental changes can be made to the design
of the workplace that significantly lowers the level of risk. If this is not the case then
risk needs to be controlled through the task itself and therefore it is necessary to
amend the task such that the risk is reduced to a low level. This may involve changing
how a particular task is performed in terms of the steps that are involved in it or the
type of equipment that might be required.

After the risk controls have been added to the task and the new task has been
documented the risk assessment process should be repeated again to confirm that the
risk has been reduced to an acceptably low level. On this basis, it is then possible to
confirm that the modified task meets all the requirements of risk minimization and the
new task is generally referred to as a safe working procedure.

Personal Protective Equipment

The last risk control strategy is the use of personal protective equipment (PPE). This is
a way of controlling risk by selecting a particular type of equipment that will provide a
barrier between the hazard and the worker. For example, the purpose of a hard hat is
to provide a barrier between a falling object and a worker's head at the exterior of the
hat. Therefore, PPE does not in any way alter the nature of the hazards that exist at a
workplace.

PPE can be a very effective means of risk control providing hazard identification, risk
analysis, and risk assessments have been undertaken in a comprehensive manner.
PPE will only be effective if the nature of the risk is clearly understood and the correct
type of PPE is identified. This may not always be a simple matter; eg. in handling
solvents there are many different types of solvents and typically, one would use gloves
to provide protection to the hands. However different solvents interact with different
glove materials in a range of ways, and a pair of gloves that may provide excellent
protection against one type of solvent may provide very poor protection against
another.
For PPE to continue to be effective in controlling a hazard, it is essential that the
equipment is properly maintained, or in a situation where maintenance is not
appropriate, that it is replaced when it no longer is able to do the job. In many
circumstances, this may require an extensive program of monitoring the quality and the
performance of PPE.

To be effective, PPE also requires the cooperation of the person who is required to
wear it. Therefore if PPE is chosen as a risk control option it is essential that the
persons who are required to wear the equipment are given appropriate training.

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This training should include:


1. An understanding of the nature of the hazard and the degree of risk
2. The reason why PPE is required
3. How to use the equipment properly
4. Maintaining the equipment
Understanding and recognizing when the equipment needs to be replaced.
Use of PPE is the least desirable of all risk control options. As noted above, PPE
merely provides a barrier to the hazard at the worker and therefore is a last line of
defense.

Selection of Risk Control Options

The discussion above has indicated that there is a hierarchy of risk control options that
can be used for the control of risk. The type of control that will be used in any set of
circumstances will depend upon the nature of the hazard, the nature of the workplace
and the availability and suitability of different types of controls; eg. in one situation
redesign of the workplace to eliminate a hazard may be possible and in another
situation, it may only be possible to have PPE provided. In undertaking risk
assessments it must always be recognized that the whole hierarchy of risk controls are
available and all must be considered.

In many situations, PPE is chosen as a risk control option because it is the simplest
and most convenient risk control to use. For example, it may merely be a matter of
going to the warehouse and obtaining a respirator, a pair of gloves, a pair of goggles
etc. PPE is often a very good temporary risk control, i.e. it can be instituted quickly and
will be effective in the short term.

However even if PPE is chosen in the short term, a comprehensive risk assessment
will consider other possible risk controls and decide whether it may be preferable to
introduce a different risk control in the future. For example, in a work area where fume
was present, provision of respirators might be a suitable short-term risk control. It may
be decided that a more effective risk control would be to install a ventilation system to
ensure that the fume is removed from the work area and so eliminating the need for
use of a respirator.

PPE may also appear to be a cheap risk control option. This may not necessarily be
the case! Use of PPE to control the risk will require on-going purchases of the
protective equipment and it may be that some larger expenditure on an item that
makes a more fundamental change to the nature of the workplace will be a more
effective means of risk control.

Verification of Effectiveness of Risk Control Measure(s)

The risk assessment process discussed above has involved identification of hazards,
analysis of consequences and likelihood, generation or measurement of a level of risk,
evaluation of the level of risk and then decisions regarding the need for risk control. It
is essential however if risk assessment is to be effective that risk controls are
evaluated.

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Once a risk control has been identified, the risk analysis and risk assessment process
needs to be undertaken again to confirm that that control is adequate. For example, a
risk control may affect consequences, it may affect likelihood, or it may affect both.
Therefore, it is necessary to undertake an analysis and assessment again considering
the situation where risk control is in place and determine the level of risk.

The level of risk remaining after a risk control has been put in place is called residual
risk.

The purpose in choosing a risk control is to ensure that the level of residual risk is as
low as is practicable and/or acceptable.

It may be that when a particular risk control is postulated and the assessment is
undertaken again the analysis may show that the risk is still unacceptably high. In such
a situation, it would be necessary to develop either a new risk control strategy or add
another level of risk control to that already suggested. Once this is done, the analysis
and assessment process should be repeated again to demonstrate and ensure that the
level of risk is acceptably low.

It is often this aspect of verification of the suitability of risk control that is omitted from
the process of risk management. It cannot be stressed highly enough that it is
necessary that each time a risk is identified as requiring risk control, that it is ensured
that the control is evaluated to determine whether it will adequately control the risk.

Role of Monitoring

It is necessary to confirm that a particular risk control is achieving the desired level of
risk reduction after being put in place, ie: Ongoing monitoring of risks and associated
risk controls needs to be undertaken. For example, a risk might be identified, analyzed,
assessed, and found to be unacceptably high. A risk control is then chosen, verified,
and put into place. It would be expected that some months after the control has been
put into place, a review of the adequacy and effectiveness of that control should be
made. This is to ensure that it is achieving its role in the workplace as expected by
those who undertook the risk assessment.

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APPENDIX TWO: MANAGEMENT OF CHANGES FORM

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7
MANAGEMENT OF CHANGES ASSESSMENT FORM

Plant: Title: Reg. No:

Underline those factors that have been changed by the proposal

Process Conditions Engineering hardware and design


temperature line diagram
pressure wiring diagram
flow plant layout
level design pressure
composition design temperature
toxicity materials of construction
flash point loads on, or strength of
reaction conditions foundations, structures, vessels
bellows/supports/bellows
Operating Methods temporary or permanent
start-up bellows/supports/bellows
routine operation valves, slip-plates
shutdown restriction plates, filters
preparation for maintenance instrumentation and control systems
abnormal operation trip and alarms
emergency operation static electricity
layout and position of controls and instruments lightning protection
radioactivity
Engineering Methods rate of conversation
trip and alarm testing rate of erosion
maintenance procedures isolation for maintenance
inspection mechanical-electrical
portable equipment fire protection of cables
control logic handrail
ladders
OH&S Equipment platforms
fire-fighting and detection systems walkways
means of escape tripping hazards
OH&S equipment for personnel access for
operation, maintenance vehicles, plant, fire fighting
Environmental Conditions underground/overhead:
liquid effluent services
solid effluent equipment
gaseous effluent
noise

7
Contact the Group OH&S coordinator at Holcim (US) for more detail on this form.

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Within the categories listed below does the Yes What problems are created effecting Signed
proposal: or plant or personnel OH&S? and
no Recommend action? dated
Relief and Blow Down
(1) Introduce or alter any potential causes of
over/under pressuring the system or part of it?
(2) Introduce or alter any potential causes of higher or
lower temperature in the system or part of it ?
(3) Introduce a risk of creating a vacuum in the system
or part of it?
(4) In any way affect equipment already installed for
the pressure of preventing or minimizing over or under
pressure

Area Classification
(5) Introduce or alter the location of potential leak of
flammable materials?
(6) Alter the chemical composition or the physical
properties of the process material?
(7)Introduce new or alter existing electrical equipment?

OH&S Equipment
(8) Require the provision of additional OH&S
equipment?
(9) Affect existing OH&S equipment?

Operation and Design


(10) Introduce new or alter existing hardware?
(11) Require consideration of the relevant Codes of
Practice and Specification ?
(12) Affect the process or equipment upstream or
downstream of the change ?
(13)Affect safe access for personnel and equipment,
safe places of work and safe layout?
(14) Require revision of equipment inspection
frequencies?
(15) Affect any existing trip or alarm system or require
additional trip or alarm protection?
(16)Affect the reaction stability or controllability of the
process?
(17) Affect existing operation or maintenance
procedures or require new procedures?
(18) Alter the composition of, or means of disposal or
effluent?
(19) Alter noise levels?

OH&S assessor ....................... Date ........

Checked by ................................. Plant Manager Checked by ................................. Engineer

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APPENDIX THREE: EXAMPLE EMERGENCY PLAN

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Example:

Emergency Management and Local Disaster Recovery Plan

For …

All Group Company Business Units and/or Sites

This document must be kept next to the


reception telephone or the central
communication control point.

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Emergency Procedures and Disaster Recovery Plan

A siren sounding continuously means to make your way quickly and calmly to
the evacuation area.

Site Information - Plant/Site Name: _______________________________________

Location/Address: _____________________________________

Notification:
Person Phone
Emergency Co-coordinator _________________________________________
Plant/Site Manager _________________________________________
Business Unit Manager _________________________________________
Fire Warden _________________________________________
First Aid _________________________________________

Plant Communication Position Call Number/Sign


Telephone/s _________________________________________
_________________________________________
_________________________________________
CB _________________________________________
Two-way radio/s _________________________________________
Other _________________________________________

Evacuation Assembly Areas

1. _______________________________________________________________________

2. _______________________________________________________________________

3. _______________________________________________________________________

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Notification Procedures

Should one of the persons listed not be on site - notification is to be to the next level.

1. Plant should notify whichever of the following they are first able to contact -

a) Emergency Co-coordinator.

b) Plant/Site Manager.

c) Area Supervisor.

2. It is the responsibility of Managers, Supervisors, Emergency Co-coordinator to:

a) Ensure the safety of all on site.

b) Co-ordinate response.

c) Notify emergency services (If this has not already been done).

3. It is the responsibility of all personnel on site to comply with all emergency plan requirements.

4. Managers and Site Supervisors must notify external organizations as required.

5. The Business Unit Manager should contact The Divisional General Manager.

NOTE: Only the Business Unit Manager or equivalent can talk to/liaise with media.

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Emergency Communication Requirements

Fill in names & phone numbers/relevant details - The flow of information is as shown:

Emergency Coordinator

Internal Requirements Emergency Services Site Manager/Supervisor

Activate Phone ???

Siren Police Site OH&S Officer

First Aid Fire Brigade

Gov’t Health & Safety Dept.


Ambulance
Extinguishers

Other Emergency Gov’t Environment Dept.


Water Truck
Services
Etc

Gov’t Mines Dept.

Business Unit Mgr.

Division/Departmental General Mgr.


Managing Director

Corporate Crisis Management Team

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An Emergency Response Procedure

1. Assess The emergency and its extent:


eg. What, Where, How many, How badly, Is the danger passed?

. 2. Alert Get help from appropriate Emergency Services:


The local and site numbers are beside the office phone.
External: Dial Number ????

3. Assist / Evacuate Your personal safety must be assured.


U U

If all danger has passed, secure the accident scene and render assistance as necessary. If any
danger exists, make your way immediately to the evacuation area.

General Emergency Procedures


U U

If you detect an emergency situation, NEVER place yourself in danger - Don’t panic!

Notify site management immediately.

Note as many details as you possibly can.


They will be necessary when calling emergency services, and also in the investigation that
must follow any accident or incident whether it is injury producing or not.

Call for emergency services.


Even when a situation looks minor it can escalate into a major emergency very quickly.

Make yourself aware of the emergency procedures and evacuation area at any site where you
work or visit; eg. Know that a siren sounding continuously means to make your way quickly and
calmly to the evacuation point.

Never leave the accident scene or evacuation area without letting someone know. Lives have
been lost trying to save someone who was safe but had not been accounted for.

Act calmly and don’t panic.

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Evacuation Procedures

1. The need for evacuation will be indicated by:


a) A siren sounding continuously.
b) Verbal Orders.
c) Both.

2. (Excepting for Flood, Storm or Cyclone/Hurricane threat) Leave immediately by the nearest exit
- Do not stop to collect personal belongings.

3. Go straight to your head count area and report to the Emergency Coordinator.

4. Do not leave your evacuation area until told by the Emergency Coordinator.
If safe, a designated person should:

a) For fire
i) Shut down machinery and all ENERGY sources.
ii) Close all windows.
iii) Close all doors behind them.

b) For bomb threat


i) Shut down machinery and all ENERGY sources.
ii) Open all windows.
iii) Open all doors.

c) For storm or cyclone threat


i) Shut down machinery and all except emergency ENERGY sources.
ii) Slightly open windows on the side of building opposite to the direction of the
coming storm.
iii) Close all doors.
iv) Do not use the telephone during the storm.
v) Stay indoors and away from windows.

d) For flood
i) Shut down machinery and all except emergency ENERGY sources.
ii) Close all windows and doors.
iii) Sandbag entrances as appropriate
iv) If possible, move computers and other electrical equipment to the highest area
inside the buildings.
v) Stay indoors.

e) For earthquake, tsunami, volcanic eruption or other natural disaster


i) Shut down machinery and all except emergency ENERGY sources.
ii) Close and seal all windows.
iii) Close and seal all doors.

EVACUATION AREAS are site specific and you must know where these are for any site that you are
on.

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ACCIDENTS AND INJURIES

1. Quickly assess the scene, noting the type of accident, possible hazards, and the number of
injured people and the nature of the injuries.
2. Check for any danger at the scene and try to anticipate further possible danger.
3. If there are any dangers - control them eg. turn off all electricity, control petrol spillage, and
secure unstable elements. traffic control.
DO NOT PLACE YOURSELF OR OTHERS IN DANGER.
4. Administer First Aid if qualified - Remain with the victim and arrange for immediate transport to
medical assistance ie. Ambulance.
5. Where the accident involves live electrical contact, do not touch any victim.
Turn off the power at its source if possible.
If not, use an unpainted wooden pole to break electrical contact or remove live wires.

Do not move the victim unless there is immediate danger to them!


If there are any hazards that you cannot control and you must move a victim, then as gently as possible
drag them by holding the clothing, the ankles or under the armpits - If possible stabilize the neck/spine
during all movement.

SOME BASIC PROCEDURES THAT CAN BE USED IN EMERGENCIES:

Death or Serious Injury on Site

1. (See Accidents and Injuries above) Assess the situation.


2. Stabilize/control any dangers as required but under no circumstances place any other person in
danger.
3. Alert site management immediately and advise emergency services providing all the available
details.
4. Provide whatever assistance possible for the victim.
5. Notify main plant entry gate and have a person standing by there to take Emergency Services
to the scene.

Fire on Company Property

1. Alert all persons in the area and initiate evacuation.


2. Identify area effected.
3. Notify emergency services giving all details.
4. Turn off your equipment and any other energy sources.
5. Use fire extinguishers or hose reels ONLY IF IT IS SAFE TO DO SO.
6. Contain fire ONLY IF SAFE TO DO SO. eg. close doors and windows.
7. Secure the emergency scene and prevent entry.
8. Walk by the most direct route to your Evacuation area and report to your emergency
controller/warden
9. DO NOT LEAVE THE EVACUATION AREA UNTIL YOU ARE ADVISED TO DO SO.

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Fire on Neighboring or nearby Public Land - If you are told a fire is approaching your site

1. Secure equipment and buildings


2. Ensure all flammables are sealed, and where possible moved to a safer area.
3. Report to your Emergency Controller/warden at your assembly area
4. Await further instruction.
5. DO NOT LEAVE THE SECURE AREA

Explosion

1. Determine nature of emergency.


2. Identify area effected and determine if danger still exists e.g. gas leak.
3. Notify emergency service - Do not attempt repairs unless qualified to do so.
4. Remove to safety/assist any injured persons ONLY IF SAFE TO DO SO (Refer Accidents and
Injuries).
5. Secure the area ONLY IF SAFE TO DO SO.
6. Move to evacuation area and report to your emergency controller.
7. DO NOT LEAVE THE EVACUATION AREA.

Severe Rain/Wind/Hail/Electrical Storm

1. Notify all personnel on site.


2. Secure all loose materials/objects that could become missiles in wind gusts.
3. Shelter all personnel and mobile plant under cover and do not use telephones during lightning
activity.
4. Shutdown or electrically isolate operations, plant, machinery or energy sources as appropriate.
5. Stay indoors and Notify the Business Unit/Site Manager.

Information System Failure

1. Notify Group company and local Information Technology Manager.


2. All sales details are to be entered by hand onto the sales dockets retaining, the numbering
sequence of dockets in order from the last computer generated docket.
3. When system is ‘up’, details must be entered into the system ensuring that the computer
generated number matches the hand written docket. Customers are to be notified should the
computer-generated number may vary from that written on their delivery docket.

Environmental Contamination or Spill

1. Notify the Site and/or Group Environmental Manager or Supervisor.


2. Ensure all personnel are notified and instructed to remain clear of the area.
3. DO NOT attempt to recover or contain dangerous or hazardous goods unless qualified to do so.
4. Notify emergency services and the Environment Department in the case of dangerous or
hazardous goods.
5. Refer to and follow spill containment and clean up procedures for all other spills.

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Misfire During Blasting

1. Notify the Quarry/Mine Manager.


2. Ensure all personnel are notified and instructed to remain clear of the area
3. DO NOT enter the area until the Quarry/Mine Manager advises that it is safe to do so.

Mobile Plant/Machine Rollover or Accident

1. Power down and discontinue use of the machine.


2. Notify the manager immediately.
3. Clear the area until the machine is stabilized.
(See Accidents and Injuries above).

Damage to Overhead Wires

1. Discontinue work in that area.


2. Notify the manager and the power provider.
3. If necessary, evacuate to the assembly area.
(See Accidents and Injuries above - Don’t be the next victim).

Communication System Failure

1. A mobile phone should be available at each site where no other communication exists to
ensure continued ability to communicate.
2. Notify the service provider.
3. Advise Business Unit/Site Manager.

Civil Disorder

1. Alert Site and Business Unit/Head Office Management


2. Notify police and request urgent assistance.
3. Assist in action to restrict contact between demonstrators & occupants.
(Close and lock gates, doors, shutters, security barriers/screens and windows).
4. Assist in action to:
a) Restrict access.
b) Confine disturbance.
c) Secure respective work areas.
d) Withdraw employees to a safe area.
e) Shut down processes where necessary.
5. Protect all valuables, sensitive documents, computer discs or other materials by locking them
away in a safe or in secure cabinets - Shutdown computers and network access.
6. If safe and possible to do without the knowledge of the persons concerned, take photographs of
people attempting to obtain access to the site and protect the camera and/or video and films.
7. Don’t panic and under no circumstances offer any forcible resistance

Recovery Plans

1. The Business Unit Manager , Site Manager / Supervisor and others as required shall determine
the action to be taken based on individual requirements.
2. All requests for information by external bodies, including the media, shall be referred to the
Business Unit/Site Manager. Note however that many Government Personnel (e.g. Police and
Environmental or Occupational Health & Safety Inspectors) have very wide powers to require
the provision of information and/or actions to be taken during any emergency situations. Hence
all individual employees should always co-operate fully with such authorized personnel
3. The Corporate Crisis Management Team will be involved only at the request of the Chief
Executive Officer/Managing Director or the Divisional General Manager.

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APPENDIX FOUR: OH&S DEFINITIONS

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Definitions related to the OH&S Policy

HOLCIM OH&S POLICY


We provide healthy and safe workplaces by striving for zero risk to our employees, contractors and
visitors.

We apply OH&S standards and guidelines, provide the necessary resources and training and measure
performance.

OH&S means Occupational Health and Safety


We place the highest value on being a responsible and caring employer. There are many reasons
why we want to prevent accidents death or harm at work. They include:
a safe and healthy workforce will be most likely to achieve other Group performance targets
our moral responsibility to ensure our colleagues return home without being hurt at work,
discharging any legal duties on individuals and the organization; as well as
minimizing our costs for death, accidents and/or disease, illness and injury; and
avoiding the potential for penalties relating to non-compliance with our legal obligations.
Hence, people are healthy and safe when their death or harm at work is prevented.

Occupational
Occupational means involving a workplace, workplace activities or operational plant/equipment
known to potentially represent higher risk.

Examples(of operational plant/equipment known to potentially represent higher risk): Cranes and
lifting equipment, pressure vessels, cooling towers for air conditioning open to the environment, etc

Health
Health means the absence of disease, illness, death or permanent disablement and can be
physical or mental in nature.

Example of a physical illness caused by a workplace:


Asthma caused by inhaling spray paint mist in a workplace

Example of a physical illness caused by a workplace activity:


Carbon monoxide poisoning caused by a liquefied petroleum gas powered forklift being used inside
an enclosed area that is poorly or non-ventilated

Example of a physical illness caused by known high-risk plant:


Legionnaire's disease (a pneumonia) due to inhaling Legionella bacteria from a contaminated
cooling tower

Example of an illness that is mental in nature:


Stress … which can be due to a variety of factors and can contribute to physical illness such as
heart disease

Safety
Safety means the absence of risks that may cause injury, illness, death or permanent disablement
and can be physical or mental in nature.

Example of a physical injury caused by a risk in a workplace:


Cuts and abrasions caused by obstacles that cause tripping and falling at work

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Example of a physical injury caused by a workplace activity:


A lime burn due to exposure to fresh mortar or concrete.

Example of a physical injury caused by known high-risk plant:


A crush injury caused by a crane load slipping

Example of an injury that is mental in nature:


Mental stress caused by a long period of working hours that exceed recommendations.

Workplace
A workplace is any place where work is, is to be, or is likely to be done by any Holcim employee or
any other person acting under the direction of Holcim management.

Examples:
A cement manufacturing plant, an aggregates quarry or a plant making pre-mixed concrete;
A room that has been rented for presenting the annual financial results of the organization;
A vehicle supplied by an employer for use by an employee for the performance of work.
A project office located in a client's site, but under Holcim's control.

Providing healthy and safe Workplaces


Providing healthy and safe workplaces involves the anticipation, recognition, analysis, evaluation
and control of those hazards or factors that may cause disease, illness, injury or impaired health
and well-being amongst persons at the workplace or those who are directly impacted by the
workplace.

Striving for zero Risk to our Employees, Contractors and Visitors. By carrying out the process
of Hazard Identification & Risk Assessment and Risk Control on an ongoing basis, we are striving
for zero risk to our employees, contractors and visitors.

Risk
Risk is the chance of something happening that will have an impact on objectives or targets. It is
measured in terms of likelihood and consequence and may arise from an event, an action or from a
lack of action.

Likelihood
Likelihood is used as a qualitative description of statistical probability and frequency - It is often
given in % terms.

Consequence
Consequence is the outcome of an event or situation, expressed qualitatively or quantitatively. This
could be negative (ie. a loss or worsening in situation); or positive (ie. a gain or improvement).

Monitor Performance
To monitor performance is to check, supervise, observe critically, or record the progress of an
activity, action or system on a regular basis in order to identify change. Each Group company will
monitor its performance against the requirements of the Holcim OH&S Targets.

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Definitions related to the Holcim OH&S Targets

HOLCIM OH&S TARGETS


Zero accidents causing Death and Zero accidents causing Permanent Disability annually
A Lost Time Injury Frequency Rate of < 5 Achieved Annually
A Lost Time Injury Severity Rate of < 60 Achieved Annually

Death
Loss of human life as a result of a work related accident.

Permanent Disability
Permanent Disability occurs when person is no longer able to have gainful employment with Holcim
or any other employer as a result of a work-related accident.

Lost Time Injury Frequency Rate Number of Lost Time Injuries (LTI’s) x 1,000,000
Total Number of Hours Worked

Lost Time Injury Severity Rate Number of Work Days Lost from LTI's x 1,000,000
Total Number of Hours Worked

A Lost Time Injury (LTI) is a work-related injury after which the injured person cannot
work for at least one full shift or full working day anytime after the shift or day on which
the accident causing the injury occurred.
Injuries causing Death or Permanent Disability are not counted as LTI's and so are not
in the Frequency or Severity Rates.

APPLICATION OF TARGETS

All Targets will be applied for all our own employees in all segments and business units
The Death/Permanent Disablement Rate Target will be applied for all sub-contractors, third parties
(contractors) and others where Holcim caused the accident
The Lost Time Injury Frequency Rate Target will be applied for all sub-contractors

While there are no specific Targets defined, records will be kept of the:
Total number of Accidents; and
The number of Lost Time Accidents
Involving all sub-contractors, third parties (contractors) and others where it is shown that Holcim
caused the accident

Hours Worked
Hours Worked includes the actual hours worked by the non-exempt hourly personnel, as well as
those for salaried exempt personnel.
Hours worked shall not be counted for vacations, holidays, sick leave, and any other off-duty time.
For salaried personnel, the hours shall be calculated by using a given value of 8 hours per day
times the number of days worked (as per HARP).

Number of Work Days Lost


Number of Work Days Lost is the number of work days (consecutive or not) after, but not including
the day injury occurred, during which the person would have worked but could not do so; ie. could
not perform the major duties of the work during all or any part of the workday or shift. The counting
of workdays lost ceases when the person returns to productive work.

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Sub Contractors
Sub contractors are persons who are engaged in work for Holcim and meet all three of the following
criteria:
Holcim directly controls the number of hours worked;
Holcim directly supervises the daily work activity; and
The subcontract personnel fulfill the functions normally performed by Holcim employees
with Holcim expertise or know-how.
(NOTE: This is the HARP definition)

Occupational Disease
An occupational disease is defined as a condition produced in the work environment over a period
longer than one workday or shift; ie. usually such a disease is due to repetitive factors over a period
of time. It may result from systemic infection, repeated stress or strain, chronic exposure to toxins,
poisons or other ongoing aspects of the work environment.

Occupational Injury: This is any injury such as a cut, fracture, sprain, amputation, or other harm
T T

resulting from a work-related event or a single instantaneous exposure in the work environment.

Occupational Illness
T

Occupational illness is any abnormal condition or disorder, other than one resulting from an
occupational injury, caused by exposure to factors associated with employment. It includes acute
illnesses or syndromes and immediate reactions which may be caused by a harmful exposure due
to inhalation, absorption, ingestion or direct contact.

In order to report on their performance against the Targets, it will be necessary for all Group
companies to collect the following data:

Total number of Injuries causing Death


Total number of Injuries causing Permanent Disability
Total number of Lost Time Injuries
For all own employees and subcontractors, as well as 3rd parties (contractors) and any
others where it is shown that Holcim caused the accident
Total amount of time worked
Total FTE personnel
For all own employees and subcontractors separately
Total working hours lost in Lost Time Accidents
For all own employees only

NOTES:
Cement plants already collect and report this data in the Annual Technical Report (ATR) each year.
This requirement is now being extended to all parts of the Group, and will be done via HIP.

External reporting (outside Holcim) of both the Lost Time Injury Frequency Rate and the Lost Time
Injury Severity Rate will be done on a 24 month rolling average basis.

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Holcim Group Support Ltd Phone +41 58 858 54 51


Im Schachen Fax +41 58 858 54 52
CH-5113 Holderbank/Switzerland ohs-hgrs@holcim.com
www.holcim.com

11/2002

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