Exxi 010 00 00 HS PLN 0002 1

Project: ETHYLENE XXI
Number: EXXI-010-00-00-HS-PLN-0002
PLAN Page: 02 / 116 Revision: 01
INDEX
1. SCOPE 8
2. FIELD OF APPLICATION 8
3. CORRELATED DOCUMENTS 8
4. DEFINITIONS AND ACRONYMS 9
5. SITE HSE PLAN 11
5.1. Site caracteristics 11
5.2. Brief Scope of the Project 12
5.3. Work Hours 13
5.4. Language 13
5.5. Site HSE Policy 13
5.6. Line Responsibility 13
5.7. HSE Goals, Indicators and Targets 14
5.7.1. HSE Goal 15
5.7.2. HSE Performance Indicators and Targets 15
5.8. Legal and Other Requirements 17
6. SITE HAZARD IDENTIFICATION AND HSE MANAGEMENT SYSTEM 19
6.1. Site HSE System 19
6.2. Site Hazard Identification (APNR) 19
6.3. Management of Change 19
6.4. Administrative HSE Cycle 20
7. HSE INITIAL EVALUATION AND MONITORING 20
7.1. General 20
7.2. Subcontractors Site HSE Plan(s) 20
7.3. Sub-Contractor Integration 21
8. HSE SITE ORGANIZATION, ROLES AND RESPONSIBILITIES 22
8.1. Generalities 22
8.2. Roles and responsibilities 22
8.2.1. JV Site Management Team 22
8.2.2. Subcontractor 29
8.2.3. All Project Site Employees 32
8.2.4. Suppliers and Vendors 32
8.2.5. Visitors 32
8.3. HSE Organizations 32
8.3.1. HSE Organization for particular situations 33
8.3.2. HSE Committee 33
8.3.3. HSE Steering Committee 33
9. COMMUNICATION, PARTICIPATION AND CONSULTATION 34
9.1. Internal communications HSE meetings 34
9.1.1. Site Kick off meetings 34
9.1.2. Weekly HSE Committee Meetings 36
9.1.3. HSE Steering Committee Meetings 36
9.1.4. PC&C HSE kick off meeting 36
SITE HSE PLAN Page 2 of 116

9.1.5. Pre-commissioning/Construction Coordination Meeting 37

9.1.6. PC awareness meeting 37
9.1.7. Frequency and Reports 37
9.2. External Site Communication 37
9.3. Communication from/to HO HSE Officers 38
9.4. Communication of serious events 38
9.5. Communication of crisis events 38
9.6. Communication in emergencies 39
9.7. Participation and consultation 39
10. RECRUITMENT, ORIENTATION AND TRAINING 40
10.1. All site personnel 40
10.2. Competent persons and Basic HSE and Social Site Staff Qualification 40
10.2.1. Site HSE Staff Qualification 41
10.3. Site Training Scheme 41
10.3.1. Site Personnel and Visitors HSE Orientation Training 43
10.3.2. OWNER Plant HSE orientation training (if any) 43
10.3.3. Human Resources Orientation Training 45
10.3.4. Code of Conduct Training 46
10.3.5. HSE Visitors Orientation Training 47
10.3.6. Supervisors/Foremen Training 47
10.3.7. Workers New-to-job follow up 47
10.4. Site HSE Continuous Training 47
10.4.1. Daily Tool Box Meeting 48
10.4.2. Weekly HSE Talks 48
10.4.3. Awareness HSE Talk 49
10.4.4. Awareness Campaigns 49
10.5. Additional HSE Training 49
10.6. Safety Stand Downs 50
10.7. Specific trainings and other activities of the companies (not related to HSE)50
10.8. Auditors team Refresh Training and Audit Information 50
10.9. Training Register 50
11. MOTIVATION, INCENTIVE AND DISCIPLINE SCHEME 51
11.1. Site HSE Main Board 51
11.2. HSE Publicity 51
11.3. Site Incentive Scheme 51
11.4. Behaviour Based Safety (BBS) Observation Process 52
11.5. Site Discipline Scheme 53
11.5.1. Site Discipline Committee 54
11.5.2. Violation Classification 54
12. SAFETY 55
12.1. Safety Work Assignment (SWA) Process 55
12.1.1. Job Hazard Analysis (JHA) and relevant Method Statement 56
12.1.2. Site Permit to Work (PTW) 57
12.1.3. Daily Task Risk Assessment (DTRA). 59
12.1.3.1. Tool Box Meeting (TBM) 60
12.1.4. Field Execution Control and Follow-Up 60

12.2. Temporary utilities installation and demobilization plan 60

12.3. Personal Protective Equipment 60
12.4. Hazardous Material and Material Safety Data Sheet (MSDS) 61
12.4.1. Dangerous materials handling/storage 62
12.5. Respiratory Hazards and Protection Apparatus 62
12.6. Confined Space 62
12.7. Fall protection 63
12.8. Scaffolds 63
12.9. Lifting Operations 64
12.10. Structures and support erection 64
12.11. Dangerous Area Segregation during Construction 64
12.12. Night work 64
12.13. System/equipment energization 65
12.13.1. Advance Communication of forthcoming PC&C activities 65
12.13.2. Isolation of live systems 65
12.13.3. Identification of live systems 66
12.13.4. Hazardous Area Segregation during PC&C 66
12.14. Lock out/ Tag-out (LOTO) 67
12.14.1. Red Blinds 68
12.15. Management of Battery Limits/Tie-ins 68
12.16. Energized Electrical Substation 69
12.17. Portion of plant in operation within a worksite 69
12.17.1. Pre-start up safety review (PSSR) 70
12.17.2. High Toxic Areas 71
13. OCCUPATIONAL HEALTH AND MEDICAL SERVICES 71
13.1. Medical Examination and Services 71
13.1.1. Medical Services 72
13.1.2. First Aid Facilities 72
13.2. Health training 72
13.2.1. Employees Information and Training 72
13.2.2. First Aiders Qualification and Training 73
13.2.3. Medical Documentation 73
13.3. Sanitation of TCF, Living accommodation, Rest/Break Areas 73
13.3.1. Temporary Construction Facilities (TCF) – Worker Support
Infrastructure 74
13.3.2. Living accommodation (if foreseen) 74
13.3.3. Toilet on Site 74
13.3.4. Rest Areas 75
13.3.5. Eating Areas and Canteens / Kitchens / Food Hygiene 75
13.3.6. Administrative Areas 76
13.4. Alcohol/drugs and smoking 76
13.4.1. Alcohol/drugs 76
13.4.2. Smoking at site 77
13.5. Work Breaks / Lunch Breaks 77
13.6. Hot condition – heat stress 77
13.7. Water Supply 77
13.8. Hearing protection 77

13.9. Site Housekeeping 78

13.9.1. Use of containers/recipients 78
13.9.2. Cable housekeeping 78
13.10. Hygiene industrial condition 78
14. ENVIRONMENT 79
14.1. Environmental Aspects 79
14.1.1. Environmental data reporting 80
14.2. Permits & Approval 80
14.3. Gas, Vapour and Dust Emission and Control 80
14.3.1. Dust Control 80
14.4. Water Use and Waste Water 81
14.5. Waste Management Plan 81
14.5.1. Waste classification, collection, storage, transportation, disposal82
14.5.2. Hazardous Materials and Hazardous Waste 83
14.6. Spill Prevention & Response 84
14.6.1. Spill Prevention 84
14.6.2. Spill Response 84
14.6.2.1. Spill Reporting 85
14.6.2.2. Spill Response Training 85
14.7. Noise 86
14.8. Restricted Materials and Radiation Management 86
14.9. Landscape and surrounding areas 86
14.10. Site Consumption - Minimization of the natural resources 86
14.11. Environmental Data Collection 87
15. EMERGENCY 87
15.1. Possible emergency events 87
15.2. Information and training 88
15.3. Project Emergency Plan 88
15.3.1. Site Emergency Resources 88
15.3.2. Site Emergency Organization and Emergency Team 88
15.3.3. Communication systems 89
15.3.4. Site Alarms 90
15.3.5. Personnel general behaviour and first emergency treatment 90
15.4. Emergency Evacuation 91
15.5. After the emergency / Notifications and Investigations 91
16. INCIDENT TREATMENT, REPORTING AND ANALYSIS 92
16.1. Incident treatment. 92
16.2. Incident Initial Reporting 92
16.3. Incident Analysis, Final Reporting and Follow-up 92
16.4. Incident classification 93
16.5. Incident Communication 94
16.6. First Aid/Near misses Analysis 94
17. SECURITY 95
17.1. Site Security Organization 96
17.2. Personnel admittance and control 97
17.2.1. Visitors 97

17.2.2. Couriers and delivery vehicles 97

17.3. General Gate Control 98
17.4. Material control 98
17.5. Vehicle control 98
17.6. Security Personnel 98
17.7. Security Contracts 99
18. SOCIAL 100
19. TRANSPORT & TRAFFIC 101
19.1. Site Roads and Traffic Rules 101
19.1.1. General Traffic Rules 101
19.1.2. Speed Limits 102
19.1.3. Parking rules 102
19.1.4. Restricted areas 102
19.2. Construction vehicle and hoisting equipment 102
19.3. Equipment and material transportation 103
19.4. Special Transport 103
19.5. Fuelling on Site 104
19.6. Pedestrian 104
19.7. Traffic rules breach 104
19.8. Roads housekeeping 104
19.9. Vehicle accident and emergency 105
20. FIRE PREVENTION AND PROTECTION 106
20.1. Major Site Fire Risks 106
20.2. Fire prevention and fire fighting 106
20.2.1. Cutting and welding 107
20.3. Hydrocarbon areas 107
20.3.1. Hot Works in Hydrocarbon Areas 108
20.4. Fire extinguishers 109
20.5. Other fire extinguisher means 109
20.6. Fire prevention and fighting organization 109
20.6.1. Fire watchers 110
20.7. Fire fighting equipment inspection 110
21. INSPECTION AND AUDIT 111
21.1. Daily Task Risk Assessment (DTRA) 111
21.2. Daily inspection 111
21.3. BBS Observations 112
21.4. Weekly HSE inspection 112
21.5. Machine and equipment inspection 113
21.6. Periodical Health, Environmental and Camp Inspection 113
21.7. Inspection by Authorities 113
21.8. System assurance audits 113
21.9. Audits of PTW 113
22. DOCUMENT, RECORD AND REPORT 113
22.1. Site HSE File 113

22.2. Recommendation Register 114

22.3. Weekly and Monthly HSE Progress Reports 114
22.4. Final HSE Report 114
23. ATTACHMENTS 116

1. SCOPE
Scope of this plan is to define the HSE principles, applicable methods and guidelines to
prevent, identify and control the hazards that may affect the people, facilities and the
environment during the activities of the ETILENO XXI Project, assuring the coverage of
the OWNER requirements, and applicable HSE legal requirements in Mexico.
This Site HSE Plan has as well the scope of ensuring the consolidation by JV Site
Management working teams to promote the culture of safety, health at work and respect
for local cultural and environmental aspects, projecting a positive image to all the
interested parties.
All subcontractors that undertake activities in the Etileno XXI Project, must join and meet
the guidelines set out in this Plan in a mandatory way.
The plan may be reviewed and updated whenever necessary or from one phase to
another one of Site activities, incorporating all changes in legal and contractual
requirements.
During the site execution phase, any change shall be agreed with JV Site Management.
All parties shall be informed of subsequent revisions.
In case site activities are carried out with by JV Site Management, supervision but under
Owner responsibility, such as assistance to Start Up and Performance Test activities,
this procedure shall be utilized as a reference only for the items not covered by the
responsible party HSE documents.
2. FIELD OF APPLICATION
This plan has to be applied by JV Site Management, its Sub-contractors, Suppliers and
Vendors present at Site performing works at any phase of project execution at Site:
Construction and Pre-commissioning.
3. CORRELATED DOCUMENTS
Technip
1000 PR 8010 Site Management and Field Construction Procedure
1000 PA 8001 Construction Subcontract Management Procedure
1000 PA 8019 Construction HSE Procedure and its references
1000 PA 9009 Start-up HSE Procedure
Odebrecht
PI-PR-001 Programa integrado del SSTMA
PI-PR-051 Programa y Control Medico de Salud Ocupacional
ICA Fluor
SSPA10-02 Health, Safety and Environmental Protection Project Model Plan.
SSPA1-111-02 HSE requirements for Subcontractors.
SSPA1-251-01 Conditions of Occupational Health and Examination of new revenue

JV ETILENO XXI Project Documents
EXXI-010-00-00-HS-PLN-0001 Project HSE Plan

EXXI-010-00-00-HS-PLN-0003 Hazard Identification plan
EXXI-010-00-00-HS-PLN-0004 Traffic Plan
EXXI-010-00-00-HS-PLN-0006 Emergency Response Plan
EXXI-010-00-00-HS-PLN-0007 Site HSE Training Plan
EXXI-010-00-00-HS-PLN-0008 Site Environmental Management Plan
EXXI-010-00-00-HS-PLN-0009 Site Medical Plan
EXXI-010-00-00-HS-PLN-0010 Site Safe Scaffold
EXXI-010-00-00-HS-PRO-0207 Site Work Permit
EXXI-010-00-00-HS-PRO-0208 Site BBS Procedure
EXXI-010-00-00-HS-PRO-0200 Temporary Facilities
EXXI-010-00-00-HS-PRO-0201 Drivers Qualification
EXXI-010-00-00-HS-PRO-0202 Safe Excavation and Earthworks
EXXI-010-00-00-HS-PRO-0203 Work at Heights and Fall Protection
EXXI-010-00-00-HS-PRO-0204 Transport of personnel and Use of Machinery
EXXI-010-00-00-HS-PRO-0205 Safe Lifting and Lifting Accessories' Inspection
EXXI-010-00-00-HS-PRO-0206 Confined Spaces
EXXI-010-00-00-HS-PRO-0100 Preliminary Analysis of the Levels of Risk (APNR)
EXXI-010-00-00-HS-PRO-0102 Safe Work Assignment
EXXI-010-00-00-HS-PRO-0103 Incident/Accident Investigation
EXXI-010-00-00-HS-PRO-0104 Site Access Control
EXXI-010-00-00-HS-PRO-0105 HSE Audits
EXXI-010-00-00-HS-PRO-0106 HSE Performance Audits
EXXI-010-00-00-HS-PRO-0107 Treatment of HSE Nonconformities, Corrective and
Preventive Action
EXXI-010-00-00-HS-PRO-0113 HSE Requirements for Subcontractors
EXXI-010-00-00-HS-PRO-0115 Management of Change
Social procedures reference located in the point 18 from this procedure
OTHER REFERENCE DOCUMENTS
IFC General EHS Guidelines (2007)

IDB Environment and Safeguards Compliance Policy
4. DEFINITIONS AND ACRONYMS
 OWNER – BRASKEM IDESA SAPI;

 JV Site Management– Joint Venture (Technip-Italy/Odebrecht/ICA Fluor);
 CONTRACTOR MEMBER – each of Technip–Italy, Odebrecht and ICA Fluor;
 OTHER CONTRACTOR means any contractor, consultant, artist,
tradesperson or other person engaged by Owner to do work in connection with
the Project other than Contractor and Subcontractors.
 Audit. - Systematic, independent and documented process to obtain audit

evidence and evaluating it objectively to determine the extent to which audit
criteria are fulfilled
 Corrective action. - Action to eliminate the cause of a detected non conformity

or other undesirable situation

 Preventive action. - Action to eliminate the cause of a potential nonconformity

or other undesirable potential situation
 Document. - Information and its support
 Disease - Identifiable, adverse physical or mental condition arising from

and/or made worse by a work activity and/or work-related situation
 Risk assessment. - Process of evaluating the risk(s) arising from a hazard(s),

considering the adequacy of any existing controls, and deciding whether or
not the risk(s) is acceptable
 Hazard identification. - Process of recognizing that a hazard exists and

defining its characteristics.
 Incident. - Work-related event(s) that may cause an injury or ill health

(regardless of severity) or fatality
 Workplace. - Any physical location in which activities related to the work are
performed under the control of the organization
 Non conformity. – Non requirement fulfillment
 Interested party. - Person or group, inside or outside the workplace,

concerned with or affected by the HSE performance of an organization
 Hazard. - Source, situation, or act with a potential for harm in terms of human
injury or ill health or a combination of these
 Procedure. - Specified way to carry out an activity or a process
 Record. - Document stating achieved results or providing evidence of

performed activities.
 Risk. - Combination of the likelihood of an occurrence of a hazardous event or

exposure(s) and the severity of injury or ill health that can be caused by the
event or exposure(s)
 Acceptable risk. - Risk that has been reduced to a level that can be tolerated
by the organization considering account its legal obligations and its own HSE
policy.
 Event of Crisis.- Occurrence of an event or series of events not planned with

significant potential to cause impacts on operational continuity and reputation
of the project as a result of the imposition of legal, economic and
environmental responsibilities, or to affect the health and welfare of
employees and workers or the community. These are events that particular
niche of HSE
Lenders: group of Banks that are involved in the Project finance, such as IFC, IDB,
SACE and others.

ANSI American Standard National Institute

CE European Community
EHA Energy Hazardous Analysis
CEO Chief Executive Officer
HIP Hazard (and Environmental Aspect) Identification Plan
HO Head Office
HSE Health, Safety and Environment (SSMA)
ISO International Standard Organization
JHA Job Hazard Analysis
MSDS Material Safety Data Sheet
OSH Occupational Health and Safety
PM Project Manager
PPE Personal Protective Equipment
PTW Permit to Work
BBS Behaviour Based Safety
SA Social Accountability
SWA Safety Work AssIgnment
SM Site Manager
SSMA Safety, Health and Environmental
TBM Tool Box Meeting
DTRA Daily Task Risk Assessment
TCF Temporary Construction Facilities
PC&C Pre-commissioning and Commissioning
5. SITE HSE PLAN
5.1. SITE CARACTERISTICS
The location of the project is to the south-east of Mexico in the petrochemical complex of
”Pajaritos” in Coatzacoalcos Veracruz terminal
The limits of the Coatzacoalcos petrochemical complex are as follows:
 North: Gulf of Mexico
 South: parallel bordered by the town of Nanchital
 East: +/-2 Km of the border Cangrejera plant of Pemex
 West: Rio Coatzacoalcos
The Etileno XXI project during the phase of construction will be divided into 4 areas of
the following forms:
 Ethane Cracker
 HDPE 1 and 2
 LDPE
 OSBL
In each area will be integrated an organization to meet the needs of HSE required

5.2. Brief Scope of the Project
The Project is a “grass roots” realization; all the earthmoving is already done directly by
OWNER. Generally speaking, no relevant excavation job shall be done.
The Project area is totally included inside a biggest fenced OWNER property. Other EPC
contractors are expected to do execution works during the same period inside other
dedicated OWNER areas
The Project includes the execution (construction, pre-commissioning and

commissioning) of the following new Units and Utilities:
Main process units
 No1 Steam Cracker

 No2 HPDE Plants
 No1 LDPE Plant
OSBL Related Facilities:
 SubStation(s) + RIB(s) excluded Main Substation

 Main Interconnecting
 Storage Areas (No 1 Cryogenic Tank + No 4 Mounded Bullets)
 No1 Blow-down & Flare System
 Utilities:
o Steam Generation and Condensate Treatment including Auxiliary Boilers
o Power Generation System including Steam Turbine or Gas Turbine
o Boiled Feed Water system
o Demineralized Water system
o Potable Water system, Sanitary system
o Secondary Waste Water Treatment
o Industrial-Treated Water Treatment
o No1 Cooling Tower
o Plant & Instrument Air systems
o Fire Water system,
o Storm Drainage system
o Fuel Gas and Ethane Feed Metering Station
The categories of work will include:
 Civil works: pilings, concrete, underground works, backfilling;

 Heavy Lifts;
 Working at height;
 Steel structures erection (both concrete and steel)
 Mechanical erection
 Piping and support erection
 Electrical erection
 Instrument erection
 Painting works;

 Insulation works;
 Fire proofing.
 Tie ins execution
 Pre-Commissioning and Commissioning
 Not destructive tests (Rx)
5.3. Work Hours
The execution work shall be done during day hours (with no need of illumination, in
general) according to a schedule pre-agreed with JV Site Management.
During the official day hours the site organization will be fully operating; work outside the
official work hours will not be allowed. (Completion of lengthy works can be allowed
normally, by means of extension and liberation of permissions).
In special circumstances, a specific authorization may be requested - to JV Site Manager

– to execute some specialized jobs outside the normal work-hours period.
Also JV Site Management shall organize itself to guarantee its own services during the
overtime/night work.
5.4. Language
The project language is English for Plans and all other documents regarding HSE.
Multilingual communication shall be foreseen for the basic understanding of major HSE
aspects, rules, regulation and practices. The key roles of each organization at Site, till
discipline supervisors, shall be able to communicate in English language.
The operating procedures that will be used during the execution of the project will be in
English and Spanish language.
5.5. Site HSE Policy
The ETILENO XXI Project HSE Policy Statement is in Attachment 1. It has been shared
and jointly undersigned by OWNER AND JV Site Management, shall be displayed at Site
premises, divulged to all Project stakeholders and considered as a Project value.
5.6. Line Responsibility
The implementation of the whole Health, Safety, Environmental and Security practices,
as described in this and other HSE Site documents, is a Line Responsibility.
Active participation is required of all persons involved throughout the organization,

because HSE is part of the work execution.
Line refers to commitment of Management - Field Representatives, Superintendents /
Supervisor, Foremen - and Workers: the main responsibilities for the HSE of the
workforce lies with management.

The site “line” is deeply involved in day-to-day work planning because it is in the best
position to recognize and manage hazards.
HSE organization should play a supporting role to line management and should work
closely with them on executing HSE Plan(s) all together.
In this context the JV Site Management is the first responsible for the implementation of
this Site HSE Plan, its regular review at sites and eventual revisions needed.
JV Site Management is responsible for execution of the project work to the highest level
of quality and completion on schedule.
JV Site Management shall coordinate the job of its group of workers and its sub-
contractors to avoid at the maximum extent the interferences during task execution.
At no time, HSE performance and considerations will be subordinated to quality, cost or

schedule. Safety is a JV Site Management value.
5.7. HSE Goals, Indicators and Targets
The main HSE objectives are:
HSE Management System Implementation

 Implement and monitor detailed system of HSE management in Etileno XXI
project.
 Decrease the risk of recordable incident (injury) as per OSHA (Occupational Safety
and Health Act)
 Medical Treatment
 Restricted Work Cases
 Lost Work Day Cases
 Fatality
HSE Management
 Have a group multidisciplinary professional to participate actively in the planning,
Implementation, coordination, execution and control of HSE Etileno XXI Project.
 Ensure the proper formation and training of HSE for all personnel.
Audit Reports
 Provide protocols for auditing against which to measure the implementation of the
system of administration of HSE, as well as practices and procedures support.
Legal Requirements
 Identify and comply with the HSE legislation applicable to Project activities and
adapt the HSE Plan to comply with the new requirements and obligations.
Continuous Improvement
 Pursuing continuous improvement using proactive and reactive means through
reviews, analyses of events, inspections and audits.

 Periodical updating of plans and HSE procedures in accordance with the changes
presented in the legal and contractual requirements.
Hazard of HSE
 Identify hazards, assess risk and to establish operational controls necessary to
carry out activities safely and avoid unwanted events.
 Comply with the requirements of use of PPE
 Attention to unwanted events to avoid emergency situations. The emergency
response must be planned, structured, allocation of priorities and mitigation of the
impact before these events.
Technology
 Provide the facilities and equipment to complete the tasks, ensure the necessary
inspection and maintenance, use HSE application of TI by JV Site management..
Communication
 Implement an efficient and effective system of communication for the
administration of HSE System. .
 Proactively create a work environment that is able to establish a mentality and safe
attitude at work.
Revision of the interested parties

 Review when required the HSE site plans with the Owner.
Environment
 To diminish the impact and deterioration on the environment and to the nearby
community.
 Diminishes the generation of hazardous and non-hazardous wastes.
 To optimize the resources / energy consumption.
5.7.1. HSE Goal
JV Site Management, Subcontractors and Suppliers common goals are to achieve,

anytime and anywhere, the following “ZEROES”, as a main task for all involved
personnel:
 ZERO Injuries
 ZERO Occupational Illnesses
 ZERO Releases or spills to the Environment
 ZERO Adverse impact to the Community
 ZERO Process Incidents
5.7.2. HSE Performance Indicators and Targets

Specific HSE Site performance Indicators and Targets have been identified for this
Project and shall be divulged and monitored by JV Site Management. Such indicators
have the scope to follow up the level of implementation and the performances of each
process of the ETILENO XXI HSE Management System. They are divided in Leading
Indicators associated to preventive activities and Lagging Indicators associated to the
negative consequences / events. Among the Leading Indicators the most relevant to
represent how preventive is the HSE System have been selected. The set of indicators,
reported in the following table, is utilised for calculating the “Preventive Index” on the
base of the weight associated to each indicator:
Leading Indicators – Preventive Index (PI)

Indicator Target Value Done Planned Weight
Training
Training Manhours
Manhours
TRAINING 90% T=Done / Planned planned in the Month 20%
performed in the
as per Training Matrix
Month
Each Supervisor,
Number of BBS Manager, HSE shall
BBS=Done /
BBS 90% performed in the perform 2 BBS per 20%
Planned
Month week (8 BBS per
month)
Area HSE Weekly
Meetings + Site HSE
Number of HSE
Weekly Meeting +
HSE HSEM=Done / Meeting
95% HSE Steering 10%
MEETINGS Planned performed in the
Committee Meeting
Month
as per HSE Meeting
schedule
Safety Number of Safety
SOC=Done / To be defined as per
Observation 90% Observation 30%
Planned Statistics' Pyramid
Reports Reports done
Number of HSE
HSE
HSEW=Done / Walkthrough 1 per Week in each
Management 90% 20%
Planned performed in the area
Walkthrough
month.
The Preventive Indicator (PI) can be calculated trough the following formula:
PI = 0.2*T + 0.2*BBS + 0.1*HSEM + 0.3*HSEM + 0.2*HSEW
While the PI target is: PI Target = 0.2*0.9 + 0.2*0.9 + 0.1*0.95 + 0.3*0.9 + 0.2*0.9 =
0.905
Other leading indicators, reported in the following table, need to be monitored in order to follow up
more in detail the implementation of the HSE Management System processes.
Leading Indicators
N° Weekly HSE HSE field survey 1per
field survey week
Management
90% MC=Done/Planned Monthly HSE HSE Steering -
Commitment
Steering Committee 1 per
Committee month
Management Internal audits in One audit each two

90% MC=Done/Planned
Commitment every unit months per unit

Leading Indicators
2 Alert
N° of Alert Notices
Notices/Month
N° of Lessons
Communicati COM= 1 Lesson Learned
80% Learned shared -
on Done/Planned /Month
N° HSE
1 HSE Campaigns / 2
Campaigns
Months
N° of MS issued 1 MS per activity
by JV Site PTW issued as per
Safe Work SWE=
90% Mgment procedure -
Execution Done/Planned
N° of PTW issued 1 JHA per specific
N° of SWA issued activity
6 Internal Drills + 2
N° of Drills
Emergency 90% EM= Done/Planned External Drills per -
executed
year
PTW= N° of PTW
PTW 90% N° of PTW issued -
Done/Planned checked
The Social KPIs are defined in the EXXI-010-00-00-HS-PLN-0001 “HSSE Management
Social
Framework”
The Environmental KPIs are defined in the EXXI-010-00-00-HS-PLN-0001 “HSSE
Environment
Management Framework”
Health Health Campaigns
90% HC= Done/Planned 6 per year 30%
Campaigns executed
Health Drills
Health Drills 90% HC= Done/Planned 4 per year 30%
executed
Health Training
90% HT= Done/Planned As per Training Matrix 40%
Training Performed
Health
90% HI=HC*0.3+HD*0.3+HT*0.4
Indicator
In the following table are reported the Lagging Indicators.
Lagging Indicators
Indicator Formula Target
Lost Time Incidents LTIF= Number of LTI Cases * 1000000
0.5
Frequency (LTIF) / Site Manhours
TRCF=Number of Total Recordable
Total Recordable Cases
Cases * 1000000 / Site Manhours 2
Frequency (TRCF)
5.8. Legal and Other Requirements
This document must be kept updated and current with the legal requirements (federal,
State, municipal and others) that are applicable to the industry of construction in Mexico.
The impact of the changes due to new/updated legal requirements on the Site HSE
System must be evaluated, in order to provide the necessary resources to update the
system.
There is a procedure that allows for the assessment of legal compliance, through the
implementation of the HSE system in their different stages of the construction process.

In case there are legal obligations not fulfilled, or omitted the OWNER shall be
immediately notified.
See also paragraph 8.2.1.11 Law and regulatory compliance expert.
Local Law and Regulations regarding Health, Safety, Environment and Security are
reported in Attachment 4.
IFC performance standards and associated Guidelines (see attachment 50).
OWNER standard documents:
This Plan and HSE procedures has been reviewed in alignment with the Handbook of
quality, safety, health and environment of OWNER and ensures compliance with the
contractual requirements.
JV Site Management and Subcontractors must be fluent with all HSE procedures that
will be used during the execution of the project including those of the contract.
JV Site Management HSE Policy, Management Systems, rules, procedures and

expectations are reported in Attachment 49.

6. SITE HAZARD IDENTIFICATION AND HSE MANAGEMENT SYSTEM
6.1. Site HSE System
Specific project Site HSE Management System is described and applicable throughout
the following main documentation together with HSE contractual requirements:
(EXXI-010-00-00-HS-PLN-0002) Site HSE Plan – this document

(EXXI-010-00-00-HS-PLN-0003) Hazard Identification Plan
(EXXI-010-00-00-HS-PRO-0100) Preliminary Analysis of the Levels of Risk
(APNR)
(EXXI-010-00-00-HS-PLN-0006) Emergency Response Plan
These documents establish a HSE Management system for the Etileno XXI Project,
according to the requirements of OHSAS 18001: 2007, based on the model established
by JV Site Management and establishing operational controls necessary to carry out the
execution of the project activities applying the best safe practices, in compliance with the
legal requirements applicable in Mexico and contractual requirements.
6.2. Site Hazard Identification (APNR)
The hazard analysis is done in two phases: an initial hazard and environmental aspect
identification, as typically reported in the “Preliminary Analysis of the Levels of Risk
(APNR)” EXXI-010-00-00-HS-PRO-0100, and a continuous site Safety Work Assignment
(SWA), as described in the procedure EXXI-010-00-00-HS-PRO-0102.
In this document are collected the information coming from the initial Hazard and
Environmental Aspect Identification. Refer to this document for Site HSE peculiarity,
critical tasks and phases, HSE Hazard identification guide line and general Job Hazard
Analysis.
6.3. Management of Change
Consists in administering any change or alteration (even temporary) to people (changes

in the Organization), technology (machinery and/or equipment), construction, pre-
commissioning and commissioning work processes (design of workspaces, facilities),
legal, contractual requirements and any requirement previously established in the
identification of dangers in order to determine the controls necessary to reduce the
likelihood of an incident, work disease or impact to the environment.
Any change must be a clear definition of the objective of the change, evaluation of risks
and impacts to the environment involved, interaction with other changes or interested
parties, should be documented, releases, approvals, skills of those involved, verification
and monitoring until the conclusion of the change. The process of Management of
Change is described in the Management of Change Procedure EXXI-010-00-00-HS-
PRO-0115. See attachment last page (File included)
Any change must be initiated with a clear definition of the objective of the change,
evaluation of risks and impacts to the environment, to workers and/or to adjacent
communities, interaction with other changes or interested parties. All change processes
should be documented, including releases, approvals, skills of those involved,
verification and monitoring until the conclusion of the change.

All change processes affecting engineering, technology (machinery and/or equipment),

construction, pre-commissioning and commissioning work processes, will be subject to a
critical review by the site HSE manager and the social and community relations staff.
6.4. Administrative HSE Cycle
It provides the support and feedback to establish the coordination of all the HSE aspects
in the project through the flow chart of Administrative HSE cycle that will be implemented
in the project (See Attachment 50).
7. HSE INITIAL EVALUATION AND MONITORING
7.1. General
The work will be executed by JV Site Management according the established procedures
of ETILENO XXI HSE System. A portion of the scope of work will be performed by
assigned Construction Subcontractors.
Each Subcontractor is initially assessed on HSE. In relation to the HSE performance

expected, the assessment may indicate a specific HSE supporting program to be
adopted by the Subcontractor to work at Site.
Any particular and/or additional request coming from the Subcontractor initial evaluation
shall be clearly specified in the contractual agreement.
The Subcontractor will be monitored during the work execution and the final Site HSE
performance evaluation shall be given back to OWNER.
7.2. Subcontractors Site HSE Plan(s)
Each Subcontractor shall prepare its own HSE Plan for the construction, pre-
commissioning and commissioning activities related to its scope of work, coherently with
the rules and procedures established by ETILENO XXI Site HSE Plan.
The Subcontractor’s Site HSE Plan(s) shall be submitted to JV Site Management for
review and acceptance within (30) days from starting activities at site or before
mobilisation to the site.
The Subcontractor’s Site HSE Plan shall, as a minimum, cover the JV Site Management
HSE requirements: local Law and Regulations, and the ETILENO XXI Site HSE Plan and
reference documentations.
It is the responsibility of the involved companies to fully understand and apply at all times
the HSE overall Site Project Requirements.
It is particularly important that the Subcontractor shall highlight to JV Site Management

any known hazard that the Subcontractor is specifically bringing to the job site.
Subcontractor may add HSE Work Practices according to their scope of work or for not
standard operations. Any new HSE Work Practices shall be issued to JV Site
Management, for review, before to be applied.

Deviations from written rules will only be allowed in exceptional circumstances where
alternative HSE measures must be applied. All such deviations will require a hazard
evaluation that shall be submitted to JV Site Management prior to start any activity.
7.3. Sub-Contractor Integration
JV Site Management shall do a specific pre-qualification and selection of its own Sub-
Contractors to ascertain that they are competent and organized to comply with the site
HSE expectations.
The Sub-Contractor shall receive by JV Site Management the HSE requirement in use
for the Project and including HSE performance expected.
Sub-Contractors shall be informed of, and have the opportunity to participate in, the HSE
activities required by the JV Site Management and which the Sub-Contractor is obliged
to instigate pursuant to the contract.
The JV Site Management shall stipulate in any subcontract that the Sub-Contractor shall
take active steps in the field of HSE identical to those required to Subcontractor;
JV Site Management shall regularly check its Sub-Contractor's compliance with HSE
requirements.
JV Site Management shall be responsible for ensuring that all Sub-Contractors and
their personnel understand and operate in accordance with HSE management
systems, performance and Standard in use during the Project at site.
JV Site Management must promote frequent meetings with its Sub-contractors, to

present results of performance of the management system of HSE; the Sub-contractors
with positive performance in HSE will be recognized.
See also paragraph 11.3 Site Incentive Scheme.

8. HSE SITE ORGANIZATION, ROLES AND RESPONSIBILITIES
8.1. Generalities
The site executing activity shall be coordinated and supervised by the JV Site
Management Team under the general direction of OWNER.
Following is reported the general Site HSE organization; the Subcontractor shall detail in
its own HSE Plan the Site HSE organization and responsibilities, specifying interfaces
with the specific JV Site Management organization foreseen.
Therefore, the Sub-Contractors must supply an organizational chart with roles and
responsibilities assigned to the personnel indicated on the chart.
Each Site Organization remains first responsible of the respect of local HSE Law and
regulations. JV Site Management has the ultimate responsibility for his own Sub-
Contractors regarding the respect of the HSE requirements and practices.
This Site HSE Plan does not limit or detract from the responsibilities contained within
current legislation pertaining to workplace health, safety and environment.
Line management, that is those personnel who plan and direct work, is responsible for
providing a place of work that is safe and healthy as much as possible, operating in an
environmentally friendly manner (See, also, Section 5.6).
In case of imminent danger everyone shall immediately ask the suspension of the
activities and/or advise immediately the responsible line supervisor/foreman.
The HSE Team shall cooperate with Social Team in order to manage issues that can
have both social and HSE implications as described by HSE and Social documental
system.
The Social programs and protocols are referenced in the point 18 from this procedure
8.2. Roles and responsibilities
8.2.1. JV Site Management Team
Refer to the site organizational chart
8.2.1.1. Project Director / Manager
The Project Director/Manager represents senior levels of management on the Project; he

is ultimately responsible for all aspects of HSE management and performance on the
Project and is directly accountable for the following activities:
 Implement OWNER/JV Site Management HSE Policy throughout the Project

providing the necessary resources for adequate implementation of HSE
Management system.

 Communicating to involved parties the HSE values of the Project; establish HSE
Objectives, Goals, Indicators e Targets ensuring the HSE performances and
accountability of his organization
 Visibly demonstrate to the organization that personal commitment to HSE is a
number one priority
8.2.1.2. Site Manager
The Site Manager is the first responsible for the general respect of applicable laws,
regulations, procedures and for the implementation of the Site HSE Plan(s) by all the
personnel involved.
 Establish and maintain HSE Awareness by actively demonstrating HSE ownership,

leadership and commitment to JV Site Management personnel and Sub-
Contractor’s organizations, by implementing and obeying all regulations and
promote safe behaviours
 Ensure that an adequate SWA process is operating at site
 Lead and inspire the BBS observation process at site
 Ensure that Emergency Plan is in place, covering the specific role of Emergency
Team Leader
 Ensure that adequate means and correct process are in place regarding: Site
Health Requirement, Medical services, Security Management, Traffic Plan /
Vehicle authorization, Fire fighting equipment
 Be the primary interface with the OWNER-Plant, the JV Site Management and
External Parties for HSE commitment
 Review periodically HSE statistical data, Objectives, Goals, Indicators & Targets,
performances, Site HSE system and matter leading periodical Site Steering
Committee toward performance continuous improvement
 Evaluate and propose the resources needed for HSE implementation and control,
providing also needed PPE
 Participate in Site HSE Selection, Organization and personnel
 Participate at Site Kick off meetings and Coordinate HSE Steering Committee,
maintaining also open communication with Site HSE Manager
 Address HSE in all planning/coordination meeting and site communication,
involving as much as possible the Site HSE Manager in these processes
 Promote and participate at incentive initiatives and respect of discipline scheme,
managing the budget
 Ensure that adequate training sessions will be executed for all personnel involved
in the activities performed as part of JV Site Management scope of the work
 Actively participate in site inspection and audit definition and execution, intervening
to correct unsafe behaviours and conditions, leading by example
 Promote HSE Final Report as part of final construction (site) report
8.2.1.3. Construction Manager
The Construction Manager reports to the Site Manager; he participates and survey for
the implementation of the Site HSE Plan, particularly for the coordination of field
activities, in order to minimize interferences and hazards. He shall:

 Follow up the JV Site Management implementation of the HSE prescriptions as

stated in the contractual documents, starting from the site kick off meeting
 Lead by example, involving his line, the JV Site Management line and the HSE
Staff in an effective team working for the HSE management
 Participate as necessary and following the HSE site activities: weekly HSE talks,
incentive and discipline scheme application, walk around, etc.
 Participate to the implementation of the BBS observation process
 Participate to the implementation of traffic, fire fighting, environmental, security and
health provisions as stated in this document
 Require and participate to the SWA process to determine the necessary
precautions to be implemented
 Follow-up any HSE issue/recommendations made to see that they are
implemented
 Assist in the development of HSE rules, HSE job procedures and the
implementation of HSE program and activities
 Participate in site inspection and audit and actively intervene to correct unsafe
behaviours and conditions. Stop work when there is an imminent danger
 Report to JV Site Management craft supervisor/foreman and/or Site HSE Manager
any spotted unsafe situation
 Make sure that incidents (including near misses) are correctly reported and
participate to ensure that a proper analysis is made
 Participate at Emergency plan application accordingly with the role foreseen
 Participate in HSE performance and periodical review, also during HSE Steering
Committee/HSE Committee
8.2.1.4. Pre-Commissioning/Commissioning Manager
The PC&C Manager actively participates and surveys the implementation of the Site
HSE Plan, being the first responsible for the parts relevant to PC&C phases. In particular
he shall:
 Demonstrate HSE ownership, leadership and commitment to PC&C personnel,

Construction Contractors and their Sub-Subcontractor’s organizations, by
implementing and obeying all regulations, holding awareness meetings and
toolboxes and promoting safe behaviours
 Ensure that adequate SWA process is applied to PC&C activities.
 Ensure adequate system of coordination between PC&C, Construction and Owner
activities is in place
 Ensure that Emergency Plan is consistent with PC&C phase and be an active
member of the Emergency Team
 Lead the PC&C Kick off meetings, arrange for the Handover Kick Off Meeting and
regularly participate to the HSE Steering Committee
 Maintain also with Site HSE Manager open communication with HO HSE
Coordinator
 Address HSE in all planning/coordination meeting, involving as much as possible
the Site HSE Manager in these processes

 Ensure that adequate training sessions will be executed for all personnel to
provide adequate awareness and competence for the safe execution of PC&C
activities.
 Actively participate in site inspection and audit definition and execution, intervening
to correct unsafe behaviours and conditions, leading by example
 Ensure that all accidents/incidents relevant to PC&C activities are investigated and
reported in accordance with the Project Site accident/incident reporting practices;
 Participate in investigating accidents and serious near-miss incidents;
In the last phase of the project, the PC&C Manager may cover also the role of Site
Manager. In those cases, he will cover all the responsibilities of this role as above
described.
.
8.2.1.5. Superintendent and Discipline Supervisors
They participate to the implementation of Site HSE Plan and co-operate with the HSE
Staff in the continuous monitoring that all the HSE regulations in force at site are
implemented; instruct JV Site Management to observe HSE procedure and suspend
works in the event of immediate danger to personnel.
In particular, they shall:
 Actively demonstrate HSE ownership, leadership and awareness to JV Site

Management organization, particularly leading by example toward a constant safe
behaviour, supporting incentive and discipline initiatives;
 directly participate to initial HSE kick off meeting and coordination meetings;
 Assure that they and the personnel in areas of their concern receive the
appropriate HSE information and training that has been designated for the job
execution; particularly they participate at the continuous site HSE training activities
(weekly HSE talks)
 Assure that SWA process is done and implemented in areas of their concern and
that Daily Toolbox Meetings are conducted regularly. Participate also at PTW
process when applicable as requested in site procedure
 Continuously monitor their areas and work to correct any HSE discrepancy from
the SWA process. Participate as requested at weekly walk around and equipment
inspection
 Participate at emergency response procedures accordingly with the role their
assigned and monitoring that areas/staff under their concern are always ready for
suitable response
 Collaborate for HSE activities, as needed (incident investigation, hazard analysis,
BBS observation process, etc.) and at the development of HSE rules and practices
8.2.1.6. Site HSE Manager

The Site HSE Manager is responsible for organizing the HSE activities and resources,
provided by the Project Management, as described by the HSE Plans and deliverables
issued for the Project.
The Site HSE Manager will report directly to the JV Site Project Director.
The Site HSE Manager commitment will support the line management. In particular he
will have the following duties:
 Prepare and issue HSE Site Activities schedule (meeting activity, training activity,
inspection activity, etc.) to all the involved parties of JV Site Management.
 Coordinate site HSE meetings (kick off, weekly, monthly, etc.) and participate at
construction/Pre-commissioning coordination meeting,
 Maintain an open communication with HO HSE Coordinator, Review JV Site
Management and Subcontractors Site HSE Plans and do JV Site Management
and Subcontractors HSE Monitoring and Follow up to be established during kick
off meeting. Review, approve and evaluate assignment of JV Site Management
and Subcontractors HSE Staff
 Address Site HSE Orientation and Training Organization and follow-up, including
weekly HSE talks participation and JV Site Management HSE Refresh Training
 Promote Involvement, Incentive, Discipline scheme application and management
 Monitoring Site Health Requirement implementation, working close to medical
staff, ensuring that needed structure, means and communication are in place and
available
 Maintain a Site MSDS data base, communicating relevant information to all
involved parties at site
 Supervise the PPE continuous definition for JV Site Management;
 Monitoring Security Management evaluating the function and the possible
improvement
 Address Traffic Plan completion and communication, supervising the site vehicle
authorization
 Ensure that SWA process is applied and review the Method Statements and JHAs
 Participate and verify that the BBS observation process is applied and prepare the
relevant statistics
 Participate in developing HSE rules and practices,
 Ensure Environmental practices, monitoring and control
 Act as Fire Marshall, organizing also specific training, drill and inspection
 Address Emergency Plan completion / communication and liaison with the
Plant/Unit and JV Site Management organizations, in order to obtain a whole site
emergency process. Collaborate, in case of emergency, according with its own
role, generally field coordinator
 Participate in Incident analysis as technical / methodological expert.
 Address general Site HSE Inspection and Follow up process and plan (daily
inspection, weekly survey, monthly site/camp, etc.) including any needed
participation
 Organize and manage HSE Document record
 Issue a monthly HSE Report and HSE Final Report

 Collaborate with the Site Manager to establish and maintain a liaison with the
appropriate OWNER representatives, national and local authorities that have HSE
functions
8.2.1.7. PC&C Site HSE Coordinator
Approximately one month prior to start any PC&C field activity, even included PC of
electrical substations, JV Site Management HSE organization shall be integrated with
one PC&C HSE Coordinator to assist and support the Site HSE Manager in the
management of all HSE aspects relevant to the execution of PC&C activities and their
likely overlap with remaining Construction activities or Owner Operation activities.
Fully integrated in the overall JV Site Management HSE Staff, the PC&C HSE
Coordinator directly report to the Site HSE Manager.
The PC&C HSE Coordinator shall be introduced to the PC&C HSE methods and
practices prior to be mobilized at site, otherwise directly at site by the PC&C HO HSE
Coordinator.
The PC&C Site HSE Coordinator shall:

 Address and coordinate the work of the PC&C HSE Specialists
 Promote the coordination between construction and PC&C aiming to minimize
interferences and hazards.
 Promote the coordination between Subcontractor, TPIT and Owner activities aiming
to minimize interferences and hazards.
 Promote preventive communication to all the involved parties on additional hazards
introduced at site by forthcoming PC&C activities and relevant further precautions to
be applied.
 Acting as HSE advisor, ensure competent support to the Site HSE Manager, Start-Up
Manager and Pre-Commissioning & Start-Up staff for the preparation of Pre-
Commissioning & Commissioning HSE documentation such as emergency plan,
specific procedures and Job hazard Analysis.
 Conduct regular site inspection to monitor compliance with PC&C site HSE
requirements and standards, suggesting and promoting eventually needed corrective
actions.
 Take part to all PC&C planning/coordination meeting.
 Whenever delegated by the Site HSE manager, act as JV Site Management HSE
representatives in front of the client.
 Assisting with the identification and administration of any needed additional PC&C
HSE training;
 Participate in investigations of incidents (including near-misses), whenever required;
 Maintain an open channel of communication with Head Office
8.2.1.8. PC&C HSE Specialist
Basing on the total number of people involved and on the project complexity
(requirements, procedures, logistics, subcontractors, magnitude of overlap among
different phases etc.) an adequate number of PC&C HSE Specialists shall be assigned
to support the PC&C HSE Coordinator.

In case of significant overlap between PC&C and Owner activities, further PC&C HSE
Specialists may be foreseen to manage this specific aspect.
The PC&C HSE Specialist shall:

 Participate in the preparation of PC&C HSE documentation such as safety
procedures and Job hazard Analysis.
 Actively participate in the PC&C HSE preventive communication process by assisting
in the preparation of alert notice, awareness campaigns, meetings and toolboxes.
 Maintain updated and periodically share with all site organizations the list of systems
and restricted areas where PTW system is required due to PC&C activities.
 Daily monitor the correct implementation of PTW and LOTO procedures.
 Act as HSE PTW reviewer for activities to be performed on system or inside areas
under PTW for PC&C reasons.
 Daily monitor the correct field implementation of system identification and area
segregation requirements.
 Daily monitor the fully compliance of subcontractors with specific PC&C HSE
requirements, suggesting and promoting eventually needed corrective actions.
 Daily monitor the fully compliance of PC&C subcontractors with site HSE standards,
suggesting and promoting eventually needed corrective actions.
 Deal with subcontractors to solve daily HSE matters.
 Administer PC&C HSE training sessions and maintain the training register
8.2.1.9. Site HSE Supervisors
Presence and number of HSE assistants are defined considering aspect such as: total
number of people, complexity of the project (requirement, procedure, logistic, sub-
Contractors at site, etc.) and phase of the project (Construction, Pre-commissioning and
Commissioning).
Site HSE Supervisors assists the Site HSE Manager with the implementation of the HSE
Plan in the assigned area and coordinate the activity of HSE Officers. For day to day
HSE matters, the Site HSE Supervisors deal directly with JV Site Management and
Subcontractor discipline Supervisors and Foremen to resolve problems, to ensure that
JV Site Management adopts, implements and maintains HSE process in accordance
with this HSE Plan(s) and related documents, and monitor JV Site Management
performance.
The duty of Environmental Supervisor shall be assigned to one of the staff.
Dedicated and sufficient PC&C field HSE Supervisors shall be identified to assist the
PC&C HSE Specialists in the daily supervision of field activities and respect of minimum
HSE requirements.
8.2.1.10. JV Site Management Field HSE Officers
JV Site Management Field HSE Officers shall be added with the ratio of 1 each 50
(FIFTY) workers.

JV Site Management Field HSE Officers ratio shall be increased to 1 each 30 (THIRTY)
workers during the Start Up phase or in any case prior the first process hydrocarbon
introduction.
Prior to start PC&C activities JV Site Management shall appoint a PC&C HSE
Representative to drive and coordinate the JV Site Management PC&C field HSE
Officers and directly deal with the JV Site Management PC&C HSE
Coordinator/Specialists. JV Site Management shall assign dedicated PC&C Field HSE
Officers to cover PC&C activities/personnel with a ratio of 1 each 50 (FIFTY) workers
directly involved in the execution of PC&C activities.
The HSE representative will only be mobilized to site after approval by JV Site
Management.
Additional personnel deemed necessary for the safe execution of work could be
requested for specific work, such as scaffolding, hoisting, crane, etc. by CONTRACTOR
and will only be mobilized to site after approval by JV Site Management.
8.2.1.11. Law & Regulatory Compliance Expert
As part of the Site HSE Organization, the Project Site Manager shall appoint an expert
professional who will be responsible for the management of Mexican law and regulatory
information concerning HSE issues for the Project Site. This professional will:
 Be part of the Project Site HSE Staff and report to the Site HSE Manager..
 Maintain contact with the local HSE authorities in order to be current with new and
revised regulatory legislative procedures concerning the management of HSE
issue at site. He will, also, act as the interface with such authorities in regards to
visits and inspection...
 Maintain the Site HSE project file complete and updated on such matters.
 Provide site notification of changes or new regulations and will be responsible for
developing an implementation plan for them.
8.2.2. Subcontractor
8.2.2.1. Site Representative
The Subcontractor Site Representative/Construction Manager is first responsible for the

participation of its organization in the implementation and the Site HSE Plan(s),
administering and ensuring that commitment to HSE is evident in the workplace.
The Subcontractor Construction Manager (or equivalent) is responsible for HSE matters
within his scope. The Subcontractor Construction Manager shall, in cooperation with the
Contractors employees, HSE Representative and supervisors, develop measures to
prevent incidents and injuries within his area of responsibility. Particularly he shall:

 Ensure needed resource management for effective HSE implementation, providing

needed means and PPE
 Provide HSE Plan / Documents completion/issue
 Participate at Site HSE kick off meeting, Coordination Meetings, HSE Steering
Committee and BBS process implementation
 Organize its own Company HSE Orientation (also for its visitors) Training, and
Weekly HSE Talks
 Collaborate in Involvement, Incentive, Discipline scheme initiatives, leading by
example
 Ensure compliance to the site health prescriptions, providing for its organization
site medical services
 Organize its own Security, Fire fighting, Traffic and Emergency Management,
collaborating to the application of similar processes foreseen for the whole site
 Ensure Method Statement and JHA timely issue, Tool Box Meeting regular
execution to share with the workers the results and for SWA process
completeness and fully application
 Respect PTW process acting as requester, issuer and receiver, according with
specific procedure
 Prepare, communicate and follow specific waste management plan and data
collection, ensuring also any general environmental control requested
 Participate in developing HSE rules and practices
 Provide Fire fighting equipment ensuring training, inspection and drill
 Collaborate in Emergency Management as per role indicated
 Assure Incident detection, treatment, analysis and reporting; in particular: regularly
transmit information regarding First Aid cases
 Ensure inspection and maintenance process in place for its equipment and
structure
 Participate at HSE inspection and walk around, indicating and following corrective
action plan, pushing for the completion within the due time
8.2.2.2. Subcontractor HSE Representatives
The Subcontractor shall appoint an HSE Representative before starting the activities, in
order to be able to prepare in time the needed HSE Documents and Plans.
The HSE Representative shall be present full time at Site when Subcontractor’s
manpower exceeds twenty (20) persons at site. Subcontractor Field HSE Officers shall
be provided with the ratio of 1 each 50 (FIFTY) workers (one HSE supervisor up to 50
workers, when the number of workers exceeds 50 another HSE supervisor shall be
added, and so on).
Subcontractor Field HSE Supervisor ratio shall be increased to 1 each 30 (THIRTY)

workers during the Start Up phase or in any case prior the first process hydrocarbon
introduction.

The HSE representative will only be mobilized to site after approval by JV Site
Management.
Additional personnel deemed necessary for the safe execution of work could be
requested for specific work, such as scaffolding, hoisting, crane, etc. by JV Site
Management and will only be mobilized to site after approval by JV Site Management.
JV Site Management, after a period of trial, reserves the right to request to

Subcontractor the replacement of those HSE personnel that at its opinion don’t perform
up to the project expectation.
The Subcontractor HSE representative is directly involved for implementing the

Subcontractor’s HSE plan on the Project. On this, he works in conjunction with his
Project/Field manager. He is responsible and has the authority for advising and liaising
with the JV Site HSE Manager and Supervisory Staff on all matters relating to HSE in the
workplace and collaborate with the Site JV HSE Manager in planning and implementing
all the HSE activities at site. Particularly he shall, for his organization:
 Participate in Site HSE Plan / Documents completion, Site HSE kick off meeting
and HSE Meetings; Manage HSE Orientation and Training, Weekly HSE Talks
Participation, Involvement, Incentive, Discipline scheme;
 Supervise Site Health Requirement Respect and Main site medical services,
Security and Traffic plan respect; Provide MSDS and related site communication;
Participate in PPE continuous definition;
 Participate in SWA process application, reviewing Method Statement / JHA / PTW
/ presented by his organization and ensuring Tool box meeting execution; Verify
the implementation of the APNR procedure;
 Verify the activity related to the BBS Process; Participate in developing and
application of HSE rules and practices;
 Ensure environmental control and waste management;
 Act as Fire Marshall, doing training, drill and inspection; Collaborate for Emergency
Management completion and application;
 Assure and participate in Incident detecting, treatment, reporting and analysis;
Participate at Site HSE Inspection/walk around and Follow up; Monitor that his
organization is applying an equipment inspection and maintenance program;
manage HSE Document record.
8.2.2.3. Supervisor / Foremen
Responsibility for the health and safety of employees, and environment respect, is an
important part of the supervisory role. All persons in a supervisory role shall:
 fully understand the requirements of the Site HSE Plan;

 Plan and lead site activities always considering HSE aspects; Implement and
enforce Job Hazard Analysis, Foresee and apply/receive all the necessary PTW;
Lead/do Daily Tool Box Meeting to discuss with the workforce the HSE aspects of
the work to be performed and the relevant HSE Work Practices; Promote PPE
availability and use;
 Promote accident prevention awareness and job planning and preparation; Check
all equipment to verify the normal condition to work; Demonstrate commitment to

HSE by monitoring the workplace and correcting any discrepancy; Reporting and
correcting when employees do not comply with workplace safety requirements;
 Require and encourage employees to report hazards and accidents; Investigate
and report accidents and near misses; Participate in HSE inspections.
 Act as BBS Observer and participate to the relevant training/meetings
8.2.3. All Project Site Employees
All personnel have an obligation to work in respect to HSE principles and prescriptions:
not just to work with care and consideration for their own, but also for the heath and
safety of others.
In particular, All Project personnel are expected to:
 Comply with all HSE working practices and procedures that are adopted,
developed, designed or otherwise implemented at the workplace; Use as
instructed all equipment that is issued for personal protection; Use the right
materials and equipment and work safe methods for the job to be done; Be present
at the HSE training and toolbox meetings and to comply with the procedures and
practices described; operate only according to the PTW provisions; fulfil the
inspection duties connected with the APNR; Participate, as required, to the BBS
observation process;
 Be responsible for the correct usage of all the safety equipment, materials and
clothing for the purpose that they have been distributed for; Look after
housekeeping in the work area; Develop personal care and attention for the
environment, own health/safety and the once the others; Take care that all the
waste is placed in the right waste containers and is separated in the appropriate
containers; Report to their immediate Supervisor any potential workplace hazard or
any mishaps, incidents or injuries that may occur during the course of work;
Immediately reports defects, observed at installations and equipment, to his/her
Supervisor; Avoid improvising upon established procedures; Close down
equipment and secure materials at the end of the work. Stop the activities when
there is an imminent danger to personnel, equipment, plant or environment.
8.2.4. Suppliers and Vendors
Suppliers and Vendors will not be allowed at Site unless they have received the
necessary level of HSE training. All vendor specialists shall comply with all Project/Site
HSE rules and HSE Work Practices.
8.2.5. Visitors
All visitors to the Site shall:
 be always accompanied in field and wear the designated PPE;

 Receive the required training by the Site organization prior entering the facility
(hazards, safe and emergency behaviour, own responsibilities, etc.);
8.3. HSE Organizations

8.3.1. HSE Organization for particular situations
If during the project execution will be foreseen different shift and considerable work in
offsite areas, JV Site Management shall ensure a specific HSE support:
a) For two or three shifts, further to usual general support availability (medical,
security services, etc.) also coverage by HSE personnel is an issue: If the
extraordinary shift is limited, then full time HSE is probably not necessary.
Someone on the shift must be given clearly HSE responsibility. If the shift keeps
growing and will be of certain duration plan shall be made to add someone to
provide full time HSE coverage.
b) For significant enough amount of work done at off Site lay down area with
consistent workshops, and/or in remote off Site area, an HSE presence shall be
considered, with the same duty foreseen for the main Site.
8.3.2. HSE Committee
According to the subdivision of the Project, for each operational area (4 foreseen) shall
be set up an HSE Committee.
The following groups:
 JV Site Management and HSE Representatives / Supervisons/ Officers

 Subcontractors Management and Field HSE Representative/Officers
 Representatives of the workers at the workplace (if any)
shall form and act as an HSE Team at Site. The purpose of the HSE Committee is to
increase the capacity of the job Site HSE organization to implement the HSE Plan(s)
(needs and actions which must be implemented, the performance of HSE surveillance,
the analysis of incidents).
In particular, during these meetings shall be reviewed the implementation and results of
the Site BBS system.
The fact of working as a Committee shall not relieve of JV Site Management and its own
Sub-contractors from their respective responsibilities vis-à-vis local laws and contractual
responsibilities.
8.3.3. HSE Steering Committee
Each month the Site Representatives/Managers of the various areas of JV Site

Management and Subcontractors, shall meet as a “Steering Committee” to make an
overall evaluation of the HSE status at site and to take immediate actions, as required.
HSE Representatives/Manager will attend to provide their specialized support and skill.

9. COMMUNICATION, PARTICIPATION AND CONSULTATION
The communication within the Etileno XXI Project will be a tool for dissemination of
knowledge and participation.
The communication will be conducted through electronic means, signs, posters, talks of
orientation for all personnel, visitors (Can include the community visitors) entering the
Site. The communication with all staff, contractors, and visitors will be the key to
strengthening the system of HSE and social on the site and will be designed to increase
the willingness to act safely during the project execution.
 Internal communications in HSE and coordination meetings

 External communication of site
 HSE Office Communications
 Communication from external interested parties
 Communication of serious events
 Communication of crisis events
 Emergency communication
 Participation and consultation
The Social communications with communities are located in the Social programs and
protocols referenced in the point 18 from this procedure
A general Site HSE activity Matrix shall be updated and shared on site – see
Attachment 5.
The project shall ensure that all information will be available and posted in visible places
(bulletins of safe work, HSE & Social posters, emergencies response plan, evacuation
routes, incident communication, security, and Mexican Law (constitutive act of the
Commission on safety and health signs).
9.1. Internal communications HSE meetings
The following meetings with specific HSE topics are usual during the construction period:
 Kick off meeting
 Weekly HSE Committee meetings
 Monthly HSE Steering Committee meeting
 PC&C kick off meeting
 PC&C / Construction Co-ordination meeting
 PC&C Awareness Meeting
 Handover Kick Off Meeting
All regular Site meetings shall start with an HSE topic, issue or observation relevant to
the type of meeting.
9.1.1. Site Kick off meetings

Prior to the start the execution work at site, a local “Kick-off” meeting shall be held,
attended by JV Site Management and Subcontractor’s Site Representative.
The purpose of this meeting is to provide the Subcontractor with all necessary
information in order to put it in condition to access the Site and start the activity in full
compliance with Site HSE rules and local laws.
The HSE agenda of the “Kick-off” meeting includes: Site HSE Plan highlights, delivering
of relevant information, instructions and documents developed and used at Site (i.e.
booklets, procedures, inspection program, Site HSE activity schedule).
Subcontractor shall provide a description of its jobsite organization, HSE nominations,
logistics, etc.
In the meeting report shall be underlined that the Subcontractor has received and knows
the HSE Requirements/HSE Site Plan and other relevant documents as above stated.
Example of meeting topics is in Attachment 6.

9.1.2. Weekly HSE Committee Meetings
Workplace Safety and Health Committee meetings shall be held weekly. These meeting
shall be conducted by the Site HSE Manager (who shall act also as Meeting secretary).
These meetings are to be attended by the JV Site Management and Subcontractors Field
Representatives and relevant Site Superintendent/Supervisor. HSE Staff and
Representatives of workers shall participate to the meetings.
The total number of attendees, names, company and roles of the individuals shall be
recorded with the minutes of meeting that the Site HSE Manager will issue to the Site
Management of each company. See draft in -Attachment 7.
During the weekly meeting, time will be allocated to review HSE items associated with
each Contractor / Subcontractor.
One of the most important scopes is to coordinate the various phases of construction and
the various Contractors Subcontractors activities in order to minimize interferences and
hazards.
Particular attention shall be devoted to the BBS process implementation and to the
positive HSE Indicators statistics.
9.1.3. HSE Steering Committee Meetings
HSE Steering Committee shall be held on a monthly basis on site; however the
frequency of meetings may be increased/decreased, if deemed necessary by JV Site
Manager.
Attendees shall include the JV Site Management, basic Safety and Health Committee
members (HSE Team) present at site (see also previous paragraph 8.3.3): Site
Management, PC&C Management and HSE Representatives of JV Site Management.
The Site HSE Manager will act as Secretary of the Site HSE Steering Committee.
The total attendees, names, Company and roles of the individuals shall be recorded with
the minutes of meeting that the Site HSE Manager will issue to the Site Management of
each Company. See template of the Minutes in Attachment 8.
During the meeting the HSE Steering Committee will review the Site HSE performances
and the leading indicators described to the section 5.7.
9.1.4. PC&C HSE kick off meeting
It shall be held by the PC&C Manager prior starting any PC field activity. JV Site
Management, Construction Management, HSE Management and Construction Sub-
Contractors representatives shall attend the meeting.
The following items shall be discussed: risks and hazards associated with PC&C
phases, coordination procedures with the remaining construction activities, additional
HSE requirements (updated training matrix, new HSE site organization, etc…), specific
awareness campaigns, specific incentive program, revision of emergency plan and

necessary available means, revision of first aid necessary available mean. See also
Attachment 9 for typical guide lines.
Whenever necessary a specific action plan will be originated and included in the relative
minute of meeting. The Site HSE manager will be in charge to follow up the timely
implementation of this action plan.
9.1.5. Pre-commissioning/Construction Coordination Meeting
PC&C and Construction Superintendents shall have occasion to meet each other to co-
ordinate the next day activities. This will serve as communication means between the
two teams in order that work groups are not inadvertently putting other work groups at
risk by competing in the same space. These meetings may be held in the frame of
previous construction meetings with a frequency that may vary according to site activities
progress, but shall not be less than weekly.
9.1.6. PC awareness meeting
Prior to carry out a PC&C activity introducing new significant hazards at site or requiring
to significantly change the site HSE procedures and practices currently implemented
(such as first steam blowing, first nitrogen in, first hydrocarbon in, etc…) a specific
meeting shall be held by the PC&C Manager in order to make all the other organizations
operating at site fully aware. JV Site Management and Subcontractors’ representatives
and superintendents shall attend the meeting. Owner and representatives of any other
organization likely affected by the activity should be invited too.
In the meeting report shall be underlined that all the interested parties have been
informed and understood the additional hazards introduced at site and relevant HSE
Requirements to be applied
9.1.6.1. Handover Kick Off Meeting
A kick off meeting should be held prior to start any system handover to the Owner aiming
to discuss and define HSE procedures and practices that will be implemented in order to
manage the overlap between the forthcoming Start Up activities will be performed by the
Owner and the still remaining construction and PC&C activities.
The meeting should be attended by the JV Site Management, PC&C and HSE
management and Owner representatives.
Agreements taken in the meeting shall be formally communicated to the Subcontractors’
organizations.
9.1.7. Frequency and Reports
The frequency of the above meetings may be modified if specifically agreed on site.
Written reports of all meetings shall be prepared and distributed to the involved parties.
The chairman of each meeting is responsible for preparing the relevant minutes.
9.2. External Site Communication

The Site Manager is the prime responsible for JV Site Management HSE external
communication, including Local Authorities. PC&C Manager may be required to assist or
can be delegated by the site Manager, for HSE external communication relevant to
PC&C activities.
An open preventive communication about foreseen activities that may have external
impact or explanation of unwanted event managed at Site could be useful to a good
relationship.
The Project shall effectively communicate the information related to the hazards of HSE,
emergency situations, and events of crisis that can involve external parties (customers,
suppliers, visitors, subcontractors, surrounding businesses, communities, environmental,
health, labour authorities, civil protection, etc.). Vice versa for the hazards generated by
external interested parties the Project will communicate the relevant information to the
interested parties in order to prevent incidents about the dangers associated with the
activities carried out.
External communication will be managed through a strict collaboration between HSE

team and Social/Communication Team. All HSE issues which could have impact on
external communities will be analysed and communication campaigns will be organized
by HSE and Social team.
Part of external communication is being handled through the CLAM (Local Mutual Aid
Committee), composed by the local companies of industrial area of Coatzacoalcos.
See the “CLAM Emergency Response Plan” Link in the CLAM Web Page: www.clam.com
9.3. Communication from/to HO HSE Officers
JV Site Management and Head Office HSE will maintain a direct communication line with
the Site, throughout the JV Site Management, JV Site PC&C Manager and Site HSE
Manager, being informed about the general execution and HSE implementation. They
shall maintain periodical communication to Sites sharing HSE highlights. Site HSE
Manager shall facilitate these activities giving in details periodical information requested.
See also Chapter “Document, record and Report”.
9.4. Communication of serious events
The lessons learned of the events in the project shall be disseminated in order to
strengthen the preventive and corrective actions arising from the investigation of
incidents.
9.5. Communication of crisis events
Communication in crisis events will be approached considering all the relevant aspects
of the events involving not only HSE aspects but also others such as labour, financial or
social relationships as well as actions under competence and responsibility of other
areas or disciplines of the company.
The Management of Crisis will be performed according a specific procedure of “Crisis
Management”.

9.6. Communication in emergencies
Communication of emergency events is a basic requirement for ensuring the success of

mitigation and control actions implementation. The Project Emergency Response Plan
shall be communicated through dedicated training sessions, advertisement campaigns
and posters/signs showing evacuation routes, assembly points, location maps, medical
information services, emergency exits, fire extinguishers and fire fighting equipment
location, location of devices for control of spills, hazardous material safety data sheets.
Bulletins and lessons learned shall be spread and applied at Site as preventive
measure.
The occurrence of an Emergency situation such as fires, earthquakes, flooding, wind

storms, etc., can present a potential event of crisis (events identified in the Emergency
Response Plan of Etileno XXI Project).
9.7. Participation and consultation
The Etileno XXI project JV Site Management is strongly committed to involve all Project
staff in an active and constant consultation of HSE System performances, including:
 Involvement of those responsible for construction, PC & C in the realization of the

APNR
 Involvement of those responsible for construction, PC & C in the investigation of
incidents
 Involvement in the management of changes.
The participation and consultation process shall involve all interested parties any time
that:
 There are changes in the emergencies of the project.

 There are hazards that may affect the community or vice versa.
 There are changes in the legal requirements applicable to the project.
 EXXI project contain with a MANAGEMENT OF CHANGE PROCEDURE
EXXI-010-00-00-HS-PRO-0115. (File located at the final page)
A Communication shall be established with local Communities in order to inform them

about the Project activities and receive their requests / grievances. The activity of
participation and consultation will be defined in detail in the “Plan de Inversion
Comunitaria”. (EXXI-010-00-00-SR-PRO-0002 )

10. RECRUITMENT, ORIENTATION AND TRAINING
All personnel working at the Project site shall be able to perform their activities according
to legislative, professional and HSE and Social requirements and shall be provided with
IMSS registration. The registration to IMSS is a mandatory prerequisite for accessing to
the Project Construction and Operation areas. However, registration to IMSS will not be
a prerequisite during the selection, recruitment and hiring process, that will be conducted
in a non-discriminatory manner, as per the procedures specified in the Project’s Human
Resources Policy. Incluir acá el numero de referencia del documento en el Sistema>>
See the “Protocolo de Contratacion e Induccion Local” EXXI-010-00-00-SR-PRO-0012
10.1. All site personnel
Each employee, including supervisors and engineers, prior to beginning work at site,
shall have attended the following courses:
 Project Orientation Training.

 Project Site Specific Orientation Training, to include:
 Acquaint the employee with the Work Site, the nature of the job, the hazards
that he may encounter, and the equipment, site rules and safe practices to be
used to minimize accidents – SWA Process).
 Explain actions to take in event of an emergency
 Describe security arrangements
 Review the contents of safety and health plans and procedures, stressing the
sections applicable to the employee and their job.
 Disciplinary policy..
 The obligation to follow and implement the regulation guidelines of safety ,
health and working environment of the Etileno XXI Project that complies with
the Mexican legal requirements.
 The obligation to follow and implement the Security Code provided under the
Transportation Security and Traffic Management Program.
 The obligation to follow and implement the guidelines of the Code of Conduct.
As part of the orientation, each employee will be advised that failure to work safe and
follow safe practices will result in disciplinary actions including expulsion from the site.
Additionally, each craftsman shall have a safety discussion with his craft supervisor after
2-3 weeks of employment when the craftsman has become familiar with the job.
All visitors shall have a specific HSE orientation briefing at site before entering the
working area. Normally they shall be accompanied by a fully inducted site person.
10.2. Competent persons and Basic HSE and Social Site Staff Qualification
Competent person is an individual who by experience and training is knowledgeable of

the work activity and all potential hazards and safe work practices related to the activity.
JV Site Management and Subcontractors shall ensure competent persons, qualified as

requested by the Mexican law, for at least the following roles: scaffolders; riggers;

welders; crane operators; electricians; ionizing apparatuses operators; motor vehicles /

fork lift / truck / excavator drivers.
JV Site Management and Subcontractors shall maintain updated and available a list of
those persons with relevant documentation.
Attendance to specific training may also be required to be qualified for specific roles
(Lock out-Tag out Supervisors, Permit to Work authorised persons).
10.2.1. Site HSE Staff Qualification
Site HSE personnel shall possess the minima HSE qualifications as specified hereafter.
 Site HSE Manager / HSE Representatives: technical diploma, long experience in

industries with at least 5 years of HSE management including field activities,
knowledge of HSE standard, HSE work practices, etc., recognized HSE specific
qualifications and skills, communications and persuasion skills, good spoken and
written English.
 Field HSE Supervisor/Officer/Assistant: technical/national diploma, 5 years’
experience in industries with at least one experience in field HSE activities,
knowledge of HSE standard, HSE work practices, etc., recognized HSE specific
qualifications and skills (i.e. Excavation, Scaffolding-working at heights, Electrical
safety, Rigging, etc.), communications and persuasion skills, English speaking.
 PC&C Field HSE Supervisor: technical diploma, 5 years’ experience in
operation/PC&SU with one experience in field HSE activities, knowledge of HSE
standard, HSE work practices particularly relating to confined spaces entry, gas
testing, respiratory protection, electrical safety, handling of hazardous
materials/chemicals, fire prevention and fire fighting, familiar with Permit to Work
and Lock out–Tag out procedures, communications and persuasion skills, spoken
and written English
 Law & Regulatory Compliance Expert: According to the official Mexican
prescriptions. He shall, also, have communications and persuasion skills, good
spoken and written English and be available full time at site.
10.3. Site Training Scheme
Each organization involved in ETILENO XXI Project activities is responsible for:

 the general information and training of its own personnel and
 the specific training related to the law and to the site project organization and
activities, including necessary certification when needed.
JV Site Management shall ensure that orientation and training sessions are held for all
employees, evaluating HSE and Social training courses and material and spot checking
the execution.
Each organization (JV Site Management and Subcontractors) involved in the execution
of ETILENO XXI Project activities is responsible to make available the necessary
resources for the implementation of the Site Training program for its own employees.
The basic site training scheme foreseen for this Project is:

Type Note
HSE orientation training
General orientation
All site personnel to work on site. By JV Site Management
training
Human Resources
orientation training
Code of Conduct
training
Project HSE All site personnel to work on site – by each organization in
orientation training dedicated area
PC&C integrative All site personnel already present or to work on site – by each
orientation training organization in dedicated area
All personnel directly involved in PC&C activities, Safety personnel
PC&C HSE induction
dedicated to cover PC&C activities, All site supervisors – by each
training
organization in dedicated area
HSE Visitors
All visitors – by each organization in dedicated area
orientation
Specific required Working at height, using mobile platforms etc – by an officially

training (certification) recognized training body
Site Supervisor
After HSE orientation training – by each organization in dedicated
additional HSE
area
training
All management/observing personnel – by JV Site Management in
BBS Training
dedicated area
Continuous HSE field training by supervisor/foremen and workers

Daily Tool Box
for specific tasks on going (SWA Process) – by JV Site
Meeting (DTRA)
Management and Sub-Contractors in field
Continuous HSE field training by/with Supervisor/Foremen and
Weekly Health, Safety
Workers on specific HSE topics (JV Site Management Supervision
and Environmental
participation recommended) – by JV Site Management and Sub-
Talks
Contractors in field
Awareness Periodic awareness campaigns that address HSE and Code of
Campaigns Conduct issues aimed at internal public.
Continuous HSE training for site personnel on specific
tasks/activities: Fire fighting, emergency, first aid, etc.
Sessions held for specific tasks/JHA, i.e. Confined space,
Additional sessions /
Tag/Lock out, energy isolation, chemicals, work at heights, etc.
Specific training / etc.
Sessions held in case of changes of rules on site i.e. pre-
commissioning activities, etc.
Refresh HSE Training and Audit Information
Specific training not Continuous training for site personnel on specific tasks/activities:
related to HSE people management, project management, contract administration,

Type Note
procurement, quality, finance, human resources, etc.
A Specific Training Matrix and schedule shall be developed at site and shall be kept
updated (see Attachment 11)
Training records shall be maintained by HSE and Social organization of JV Site

Management and Subcontractor and make them available when requested.
Training courses shall be developed during the HSE and Social Site Planning so that
they are ready when people start arriving at site. Training material / courses have to be
multilingual, according to the audience.
10.3.1. Site Personnel and Visitors HSE Orientation Training
There are three different sessions of HSE and Social Orientation training:
 OWNER Plant HSE orientation training – is the orientation necessary to have

access to the Plant/ OWNER property;
 Project HSE orientation training - is the orientation necessary to perform the
activities included in the Project scope of work
 Human Resources orientation training;
 Code of Conduct training;
 PC&C HSE induction training– is the induction necessary to perform PC&C
activities included in the Project scope of work
10.3.2. OWNER Plant HSE orientation training (if any)
Project orientation training
The Project Orientation Training is organized by JV Site Management to instruct all the
personnel arriving at site about the major information related to the project, and
delivered by each organisation (JV and Subcontractors) to their respective employees. It
is composed by a Social and HSE Orientation which informs about the HSE Policy,
Targets, HSE rules, and main risks present at Site and a General Induction focused on
social and general information about the ETILENO XXI Project. The duration of the
entire induction is about 8 hours (4 hours for the Social and 4 hours for the HSE).
Each person prior to beginning work at Site shall have attended the Project Orientation
Training (about 8 hours). This training is a pre-requisite to receive a Nominative Label
that attached on the Safety Helmet, allows the person to work on site. See the basic
draft for orientation flowchart in Attachment 12.
A test is required to check comprehension of the training session.
As part of Orientation Training, employees shall be made aware of the importance to

don’t break HSE rules and the risk that unsafe acts could create on site, also to other
workers.
JV Site Management will distribute to everybody on site, after the orientation session, a
basic HSE Booklet to reinforce the Orientation training that will be done on site.

Also, JV Site Management shall communicate HSE work practices and general site rules
at different level of its organization (supervisors, workers, etc.) by specific training
courses and materials.
Typical subject to be discussed during the HSE Orientation Training are reported in
Attachment 13.
The environmental issues to be addressed in the Project’s HSE and Social orientation
training will be those most relevant to the construction site, such as separation and
proper disposal of waste, maintenance of machinery and equipment in reducing
contamination of soil and water, appropriate procedures in several processes and
construction site activities, water savings, etc.
Project HSE Orientation Training shall be updated / modified according to site activities
status, with particular reference to beginning of PC&C activities.
For all construction personnel already present on site before starting of PC&C activities a
new session of updated orientation training shall be done.
The personnel that enters to work at the project Etileno XXI will receive the HSE
orientation, which will be integrated by the following topics (listed, but not limited to)
 Welcome (Company Presentation, Benefits of the HSE Systems)

 Type and Characteristics of the Construction Industry, activities of higher
risks.
 HSE Regulation, HSE policy and
 Control of Accesses and Exits.
 HSE Training.
 Personal Protection Equipment
 Signaling and Barricades.
 High Risk Work Permits and Safety Work Assignment (SWA).
 Emergency Response Procedure
 Evacuation routes
 Muster points.
 Activation of the Emergency preparedness and response plan Specific
emergencies of the project
 Medical Service
 Hygiene reviews in the project.
 Occupational Health Campaigns, Alcohol Tests and use of prohibited
substances.
 Environmental Protection.
 Hazardous Materials (Identification, transportation, handling and storage).
 Safety Materials Data Sheet and hazard communication (HAZ COM).
 Hazardous wastes (classification, handling and disposition).
 Housekeeping
 Consequences of not following the HSE System (Injuries, labor illness, fatality,
wounds, burns, etc).
 Contractual HSE Requirements of the client (if applies)
 Labor Relations (Personnel Department)
PC&C HSE induction training

A more specific PC&C induction training shall be attended by those workers will be
directly involved in the execution of PC&C activities. The attendance to this training shall
be considered as a mandatory pre-requisite.
Safety personnel shall also attend to the PC&C HSE Induction training prior to be
qualified to cover PC&C activities and personnel.
As well all CC supervisor are required to attend this training in order to increase their
awareness on additional hazards introduced at site by forthcoming PC&C activities.
The PC&C HSE induction training shall include the following topics: PC&C hazards and
precautions, noise hazard, rotating equipments hazard, high temperature and pressure
hazard, live system identification and segregation, electrical safety, handling of
hazardous substances, confined space, work at height, fire/explosion hazard, fire
prevention and fire fighting, PTW practice, LOTO practice, environment protection,
emergency.
Contents of the training should be tailored on the specific PC&C activity the worker will
be assigned to (mechanical, electrical, instrument, etc…).
10.3.3. Human Resources Orientation Training
The Human Resources Orientation Training is organized by the JV Site Management to

instruct personnel arriving at site about the working conditions related to the project.
In this course, employees will be informed about the Human Resources policies of the
Main Contractor, including general instructions on general rules of work, rights and
duties of workers, use of ID cards, use of uniform, use of PPE, time clock, working
hours, Social Responsibility practices and other related aspects.
Each person, prior to beginning work at the Site, shall have attended the Human
Resources Orientation Training (about 2 hours long). A test is required to check
comprehension of the training session.
Personnel that joins the Etileno XXI Project will receive the Human Resources
orientation, which will be comprised of, but not limited to, the following topics:
 Welcome (Presentation of the Company’s Human Resources)

 Labor Relations (Personnel Department)
 Human Resources Policies;
 Code of Conduct;
 Social Responsibility Practices;
 Rights and duties of workers;
 Introduction of basic and fundamental psychology concepts of work and
quality of work.
The Main Contractor shall inform its employees and other interested parties of the
company's commitment to combat forced labor and child labor in subcontracted
companies, service providers in the company’ supply chain.

The set of Social Responsibility practices adopted by the Main Contractor should be
disclosed to all employees, aiming at raising awareness, disseminating these practices
and obtaining partners in the fight against any discrimination, combating child labor and
forced labor, bullying, fighting sexual exploitation of children and adolescents, etc.
Ombudsman channels will be available to receive complaints, as defined in the Worker's

Grievance Mechanism and Community Grievance Mechanism.
Workers' rights contained in existing labor laws must be known to all employees. The
Main Contractor shall disclosure information on the benefits to which workers are
entitled, as well as the procedures for proper use of them.
A document containing information about the benefits, rights and duties of workers must
be given to the employee at the signing of the employment contract. This information
should also be addressed in the Project’s HSE and Social orientation training.
10.3.4. Code of Conduct Training
The Main Contractor will establish a Code of Conduct for the construction phase,
stipulating the restrictions of conduct to be observed by all employees hired for the
project. This Code of Conduct is intended to help preserve the environment and health
and hygiene of workers. At the same time, it aims at ensuring the quality of relationships
with communities in the area of influence of the project.
The Code of Conduct Training is organized by the JV Site Management to instruct

personnel arriving at site about general work rules e duties of all workers.
Each person, prior to beginning work at the Site, shall have attended the Code of
Conduct Training (about 2 hours long).
Employees should be counseled about the importance of not breaking the rules of the
Code of Conduct and be aware of the disciplinary actions applicable to infringements of
the rules.
The Code of Conduct of the Main Contractor will present the rules on relationship with
employees, corporate image, information security, information technology, and
relationship with the local community, use of grievance mechanisms as well as
preservation of archaeological, paleontological or historical patrimony, etc.
This Code of Conduct must clearly define the set of rules that the Main Contractor
adopts to guide cases requiring the application of warnings, suspensions or dismissals
for just cause to the employee and/or another form of written or verbal guidance for a
conduct that violates the policies and guidelines of the company. The factors causing a
disciplinary action are those that affect the employment relationship in the functional
aspects of trust, morality, property/financial damage, indiscipline, insubordination and
other related aspects.
A copy of the Code of Conduct shall be delivered to all workers of the company, along
with the employment contract or through a booklet. Records of delivery of the Code of
Conduct and presentation of its content should be properly kept.

Ombudsman and other means of communication will be available for receiving

complaints about violation to the guidelines of the Code of Conduct. The system for
receiving complaints is defined in the Workers’ Grievance Mechanism.
10.3.5. HSE Visitors Orientation Training
All Visitors to the work place shall receive Orientation Training regardless of their
organization, scope of the visit and the length of period at Site. Visitors should be
accompanied at all times while on site always wearing the expected PPE. During the
training shall be underlined the importance to don’t break the HSE rules or Code of
Conduct rules and the risk that unsafe behaviours shall create on site, also to other
workers. The Visitor HSE orientation training shall be updated considering effective site
condition and in any case prior PC&C phase starts.
10.3.6. Supervisors/Foremen Training
Craft supervisors/foremen are the key figures due to their knowledge, power and
proximity to the working people: a particular effort shall be done to train and motivate
these people.
Additional Training session (about 2 hours) shall be executed directly to the craft
supervisors/foremen on specific HSE topics to complete their orientation at the beginning
of activities at site.
Their additional initial training shall include the following topics: Responsibility and
leadership; HSE and the supervisor; Risk concept / Hazard identification and correction;
Pre-task planning / Job Hazard Analysis / HSE Work Practices / Permits / Toolbox talks /
Changing unsafe attitudes / correct unsafe acts.
A specific session is foreseen for Behaviour Based Safety implementation.
Since JV Site Management PC&C Supervisors usually directly participate to the PC&C
field execution, working in close proximity with the subcontractor workforce, they are also
required to attend this training session.
10.3.7. Workers New-to-job follow up
New personnel are the most exposed to accidents. All new workers shall be carefully
coached by their Supervisor/Foremen for 2/3 weeks from their employment at site
(orientation training, etc.) to correct their behaviour and increase their attitude for HSE.
10.4. Site HSE Continuous Training
Orientation is not a “one shot” activity but shall be done throughout the entire period of
site employment. The typical site continuous trainings are:
 Daily Tool Box Meetings – Held by the Operative Line

 Weekly HSE Talks – Held by Operative Line with presence of Staff Supervision

 Awareness HSE Talks – Held by Operative Line with presence of Construction and
PC&C management
 Awareness Campaigns;
 Additional Training Organized by HSE Team on specific subject
10.4.1. Daily Tool Box Meeting
A safety discussion will be organized and implemented by each craft or crew supervisor
every working day.
The meeting shall be held at or near the job site to plan job tasks and discuss matters of
concern to supervisors and crewmembers.
The daily Toolbox HSE meetings shall be directed to all employees of JV Site
Management and Subcontractors with their Supervisors/ Foremen facilitating the
meetings. The Site HSE Manager and other project management may participate as
needed.
This activity is a fundamental step of the Safety Work Assignment (SWA) process – see
Chapter 12.
The subject of the meetings shall be the job/task specific related and contain the
following information:
 Review of the to the job hazard analysis (JHA) of the activities

 Conduct the DTRA.
 The daily work plan
 Work that is being performed near by
 Environmental considerations
 Updates of procedures
For PC&C activities executed under direct JV Site Management Supervision, the TBM
will be held by the JV Site Management supervisor in charge
10.4.2. Weekly HSE Talks
JV Site Management and Subcontractors’ Supervisors shall conduct weekly 20 minute

meetings with the workers to discuss and reinforce HSE practices and to emphasize
hazards of current work. Sub-Contractor Superintendents/Supervisors should participate
and supervise this meeting to collaborate and show their commitment.
Discussion outlines shall be prepared by the Supervisors in collaboration with the HSE
Team, taking into account also the results of the periodic site inspection and meetings.
The meeting shall be held at or near job site to plan job tasks and discuss matters of
concern to supervisors and crewmembers. Regular copy of the topics discussed,
participants, comments, etc. shall be transmitted to JV Site HSE Manager within the day
after the meeting. See Attachment 15.

10.4.3. Awareness HSE Talk
Prior to perform PC&C activities that introduce new significant hazards at site or require
to significantly change the site HSE procedures and practices currently implemented
(such as first steam blowing, first nitrogen in, first hydrocarbon in, etc…) a specific
Awareness HSE talk shall be held with the entire workforce in order to make all the
personnel working at site fully aware of it. JV Site Management Construction and PC&C
Management/ Supervisors shall be present in order to collaborate and show their
commitment.
Awareness HSE Talk may be included in the Weekly HSE talks.
JV Site HSE Manager shall receive by Subcontractor regular copy of the topics
discussed, participants, comments, etc. within the day after the meeting.
Aiming to reinforce the message that critical changes are happening in field, a temporary
stand down of all the site activities right before the execution of the relevant PC&C
activity may be also considered. In this case the awareness HSE talk should be done in
the frame of the stand down.
10.4.4. Awareness Campaigns
The Main Contractor should develop HSE and Social awareness campaigns covering
topics of great relevance to the construction site, including the following ones:
occupational health, combating diseases, separation and proper disposal of waste,
water savings, respect to local population, anti-discrimination, etc.
10.5. Additional HSE Training
JV Site Management and Subcontractors’ employees are, also, required to attend and/or
to do certain additional training session presented by the OWNER Plant and/or
requested by the JV Site Management.
Taking into account different distinct phases of the site work that bring different HSE
issues, following are reported HSE matter to be taken into consideration that might be
subjected to additional continuous training
 Specific working phases (generally mainly for Supervision): reinforce HSE

aspects approaching the peak of work / Overlap between different disciplines,
approaching livening of systems / start-up of other units, etc.
 Train Workers for Specific Qualification / Plan(s) implementation / Tasks:
BBS observation process, Work Permit; Emergency Team member; Confined
Space Entry; Tag Out/Lock Out; Work at heights; Access to restricted areas;
Working with hazardous substances (MSDS, etc.); First aid assistance; Fire
fighting; Gas tester; Escape mask and respiratory protection, Emergency Plan,
Transportation Security and Traffic Management, etc.
JV Site Management will monitor the overall performance and development of training
system throughout the execution of the work.
All personnel shall participate and/or do any additional training, which may be requested
/ provided by JV Site Management.

10.6. Safety Stand Downs
If Project Management determines that the level of HSE awareness has deteriorated
significantly (i.e. increasing unsafe conditions, recognized bad trends of near misses,
disciplinary actions, incidents or other reasons) then specific “Safety Stand Down” will be
done at no cost for the Project to correct the situation: temporary determined stop of
work to resolve specific HSE problems.
A Safety Stand Down may be applied to a specific Area (OSBL, Cracker ISBL, HDPE,
LDPE, Off Site Area) or as well to a specific Subcontractor organization.
The JV Site Manager will coordinate the organization of the Safety Stand Downs for the
entire Project Team, if one is necessary for the entire Project.
However, the JV Site Manager may feel it necessary that a particular Subcontractor (or,
in extreme cases, all) may need to organize a Safety Stand Down for its own particular
organization. In this case, the Subcontractor, at his own cost, must present a plan JV
Site Management for approval and organize its execution on his own.
10.7. Specific trainings and other activities of the companies (not related to HSE)
Other trainings under the management of the Human Resources department will be
offered to all staff of the company, to provide knowledge on behavioral, technical and
practical aspects. Such trainings may address the following issues: people management,
project management, contract administration, procurement, quality, finance, human
resources, etc.
10.8. Auditors team Refresh Training and Audit Information
Auditors team together with the JV Site Manager and HSE Site Manager shall organize
refresh training session, at least for JV Site Management site personnel, after a system
audit. The main purpose of these refresh sessions are: Inform about the audits results &
Reinforce HSE mentality before intensive work phases commencing.
10.9. Training Register
A register recording all personnel who have undergone initial orientation or have
received additional training or re-training shall be maintained by all Site Organizations.
Such register shall allow a regular updating of the site training situation. A summary
situation shall be prepared at least monthly so that the results can be included in the
Monthly HSE Report.

11. MOTIVATION, INCENTIVE AND DISCIPLINE SCHEME
Employee positive motivation and positive field conversation help to develop the right
work habits and conditions. Bottom-up communication shall be facilitated at Site, for
example during the Weekly HSE Talks. Each Organization shall be involved in these
campaigns. Personnel motivation shall be supported with following practices.
11.1. Site HSE Main Board
The main HSE Site Board shall be placed in visible manner at the site entrance and shall
be updated at least monthly. The format is reported in Attachment 16.
11.2. HSE Publicity
Visual aids are an integral part of maintaining and promoting HSE awareness. The
following examples are some of the tools that will be employed:
 Posters (e.g. Labour Inspection Pamphlets and Publications) can be displayed at

many locations throughout the site. Posters are to be displayed in the changing
rooms, field offices, warehouses, bulletin boards and other locations..
 Bulletin boards shall be used to display safety posters, HSE bulletins, information
sharing, lessons learned, etc. Information should be changed between two weeks
/ one month. Boards shall be place in offices, field, TCF, rest/break areas, etc.
The bulletin boards will also contain information such as important telephone
numbers, project organization chart, specific HSE subjects, and specific unsafe
situations.
 Warning signs made of material that will withstand weather conditions are to be
displayed throughout the site wherever physical hazards warrant their use. Special
signs such as "Men Working" or "Falling Material" or use of tape or physical
barriers for exclusion zones will be removed from the area once the work is
completed..
Off the Job Safety shall be part of the communication campaign, publicizing the
hazards of getting to and from the work when long drives are involved and others.
It is the responsibility of JV Site Management to provide and display HSE information

material under the coordination of the Site HSE Manager.
11.3. Site Incentive Scheme
JV Site Management shall develop and implement site incentive plan to promote
positive, proactive HSE behaviours.
Incentive plan will be developed and managed directly by JV Site Management on the
basis of a defined budget and the relevant costs will be shared on site by all the involved
parties.
A specific instruction clarifying the Incentive Scheme shall be issued on site and shared
by all involved parties.
The Incentive Plan shall be based on rewarding the positive, proactive HSE behaviours
and can have the following initiatives:

 Recognition of best HSE performance against area/crew - audit/evaluation

 General project site HSE milestone achievements celebrations.
 On the spot HSE award system
11.4. Behaviour Based Safety (BBS) Observation Process
The Behaviour Based Safety (BBS) Observation Process is built on the HSE philosophy
that encourages and expects each member of line management to participate in the
process to intervene to praise safe behaviour and correct unsafe acts.
Site Supervisors and Management shall implement the system under the coordination of
the Site HSE Manager and the leadership of the Site Manager.
JV Site Management and its subcontractors are part of the system and shall participate
in the implementation of the process..
The BBS Develops a methodology to enable an identification of hazards and risks

behavioral and the consequent actions of prevention using a positive approach
observation and interaction between the team of construction / commissioning, members
and sub-contractors respect to practices and operating positions and behavior during the
execution of activities.

11.5. Site Discipline Scheme
Ignoring violation send a “wrong” message that is all right to violate HSE rules because
they are not so important. A Discipline system shall be implemented to discourage site
HSE rules violation and unnecessary hazardous situations.
Each organization on site shall have a duty and responsibility to detect HSE violations
and unsafe situations and provide measures for correction. Each organization shall
enhance disciplinary “internal” action according to their internal procedures
Whenever OWNER Plant / JV Site Management personnel detects a violation of the

rules and standards, disciplinary actions should be requested and taken by the involved
CONTRACTOR MEMBER / Subcontractor, depending on the nature of the offence.
Verbal/Written warnings may be given depending upon the instance. The measures to
be taken range from a verbal warning up to refusal of admission to the plant site for a
specific period of time or for ever. See Attachment 18 for the ticket-format that can be
applied.
Site HSE Manager shall maintain a record of the written discipline actions required
directly by OWNER Plant/ JV Site Management, with the relevant follow-up. See
Attachment 19.
The involved organization shall provide in writing the guarantee that any corrective
measures requested have been implemented.
The safety, health and working environment Project regulation will be issued as a pocket
guide that will be delivered to each person entering the site during the HSE orientation.
In this document are reported the rules that must be considered as binding according to
the Federal Labour Act with the Federal Security Regulations Hygiene and Environment
of Work and with the applicable HSE Mexican rules , enforceable within the Etileno XXI
Project.
In this booklet are clearly defined the sanctions to be applied for non-compliance to the
HSE system indicated as content:
 Conditions General
 Commission of safety and hygiene
 Prevention and protection against fire
 Health and environment of work
 Use of equipment protection personal
 Rules of safety
 Use of appropriate clothing the protection work
 Environment Protection
 Conduct
 Sanctions for lack of compliance to the rules HSE

11.5.1. Site Discipline Committee
The Site Discipline Committee is composed by the Site Manager, Site HSE Manager,
Area HSE Manager and Human Resources Manager. When a violation is detected and
reported, the component of Site Discipline Committee will meet in order to evaluate the
severity of the violation and establish accordingly one of the following discipline actions:
 Written Reprimand.
 Suspension of the work for a certain number of days, to be established
by the committee, without receiving wages.
 Termination of employment contract
The written reprimand cannot be issued to the same person for more than two times,
after that the person will be suspended.
All sanctions will be made in writing, by sending the non-conformity report by attitude to
the Human Resources department to proceed with the case and record the sanction.
11.5.2. Violation Classification
The following are some basic behaviour of project site personnel that will not be
tolerated and are expected to initiate the appropriate disciplinary process, are broadcast
reports of non-conformity by attitude and nonconformity Real to the HSE system
conformity
Intolerable behaviour: all behaviour violation not classified as “serious intolerable”; i.e.:
 Non-use of prescribed PPE; Unauthorized presence in areas other than the

designated work areas; Horseplay, altercation, gambling, with fellow workers or
supervision; Exceeding specified site speed limit; Disregarding barriers entering
into an area marked as being unsafe; Non-compliance with site HSE requirements,
traffic and camp rules; Non-compliance with HSE work requirements; Not reporting
incidents immediately to supervision, Smoking in areas different from those
allowed
Serious intolerable behaviours: Risky behaviour putting his live or the lives of others
at imminent danger without reason; i.e.:
 i.e. Working without permit when required or violation of permit conditions; Not
complying with fall protection when required; Smoking / free fire in dangerous
areas; Energizing or de-energizing a power source without proper authorization;
Not respect Isolation procedure; Improper use of tools and equipment; Operating
or cause to operate equipment not in condition; Modified scaffolding without
authorization; Remove platform, gratings and railings without authorization or
without barriers / signs in place; Do not fence properly ground / floor gap; Do not
control sparks; Excessive vehicle speed; Unauthorized access into restricted area;
Possession / use of alcoholic beverages or drugs; Environmental voluntary
damage /Insubordination, abuse to others, refusal to follow supervisory instruction
/ harassment / theft / vandalism / falsification of documents / reports / etc.

12. SAFETY
The Project site execution activity for the Project ETILENO XXI shall be done inside on a
“grass roots” area with all the earthmoving works already completed..
The areas involved shall be:
Common areas open to all organization and people operating at OWNER site and plant,
between Plant fence and Project fences;
Areas exclusively assigned to JV Site Management / subcontractors to execute the

construction works.
On the Common areas all the OWNER (JV Site Management) rules are applicable.
In general:
 all activities performed nearby or inside the PC&C areas shall be performed only
after issuing of a proper Permit To Work;
 the activities performed inside the Areas exclusively assigned can be performed
(if foreseen) without a Permit To Work when the areas are properly isolated (by
distance or proper barrier) from the operating components.
The coordination of field activities shall be promoted and regulated with Safe Execution
of Work Process always and additional Work Permit wherever necessary. So, JV Site
Management shall put in place a SWA process always.
12.1. Safety Work Assignment (SWA) Process
Information to gain an initial and quick understanding of hazards associated with Site
work categories are contained in the identification of hazards, evaluation and control of
risks by the HSE Plans of JV Site Management and its subcontractors.
The Hazard Identification, shall be completed with other Site available HSE
documentation (methods statement, Site HSE work practices, procedure, MSDS, etc.)
and with specific field survey to lead to a complete evaluation of the hazards to be
managed.
Site Safety Work Assignment process is composed of the following steps:
 initial evaluation of Hazard Identification Plan(s) and relevant Method Statement;

 Job Hazard Analysis, taking into account specific Health, Safety and
Environmental Hazards;
 Site Permit to Work, when and/or where required;
 communication by Tool Box Meeting to all involved personnel of JHA/PTW and
Safe Work Practices / Methods defined;
 DTRA execution
 Supervision: periodical inspection to maintain conditions defined.
The above mentioned process shall be always applied.

12.1.1. Job Hazard Analysis (JHA) and relevant Method Statement
JV Site Management looking forward the planned works shall identify on time the
activities to be done, for proper and timely JHA execution, identifying health, safety and
environmental hazards and correspondent measures to be applied.
Specific JHA is always required whenever one or more of the following conditions exist:
 All tasks with potential for severe injury / consequence

 New or revised tasks
 When the task is not routine
 When no JHA has ever been conducted for the task
 No HSE Instruction exists specifically for the task
 There are multiple employee or trade/craft exposures
 Tasks under permitting
 Working alone
 Different activities ongoing in the same area or different subcontractors.
JHA and relevant Method Statement shall be reviewed by JV Site Management before
implementation.
Initial generic Job Hazard Analysis for typical Site activities are usually developed by the
organization responsible for the execution of the activity (JV Site Management or
Subcontractor) and issued with their HSE Plans.
Typical generic reference JHAs are attached to the document EXXI-010-00-00-HS-PRO-
0100 Preliminary Analysis of the Levels of Risk (APNR).
Although generic JHA may be available, however, site customization and more specific
JHA is always required at site before to start new or revised or not routine tasks.
Complete and accurate JHA are generally developed by JV Site Management /

Subcontractor Line Supervision and HSE Representatives, with those individuals who
have the most knowledge of the task.
In case the activity has to be performed by Subcontractor, the JV Site Management, Site
Supervisory Personnel and HSE Staff shall receive for review the JHA at least 3 days
before the job starts.
In case the activity has to be performed by JV, the specific JHA shall be prepared by JV
itself, with support of relevant discipline Supervisor and HSE specialists, and approved
three days before the activity starts.
The organization responsible for the execution of the activity (JV Site Management or
Subcontractor) shall approve the specific JHA, ensuring that the correct process of the
JHA and Safety Work Assignment is completely applied, and provide suitable training
and resources for the completion of the JHA.
In case PC&C activities are included in JV scope of work, they will be directly supervised
by the JV Site Supervisors team. In these cases, JHA shall be developed by JV Site
Management Supervisors and PC&C HSE Specialist and approved by the JV Site
Management.

12.1.1.1. How to complete a JHA
JHA shall be conducted including Line Supervision and HSE Representatives. The JHA
is developed with those individuals who have the most knowledge of the task and are
most affected by the task.
The JHA typically addresses the activities associated with a group of workers.
A Job Hazard Analysis is developed in order to:
a. Describe the activity as a sequence of elementary steps;

b. Specify the Health, Safety and Environmental hazards associated with each step,
stage, event or activity;
c. Prescribe control measures that will address the maximum risk that a particular
identified hazard might pose;
d. Submit the JHA for control;
e. Before execution discuss the executive JHA with the employees that are going to
execute the work by a specific Toolbox Meeting or other special session.
The JHA will also identify any Permit to Work that is needed as additional control to the
hazards identified.
12.1.2. Site Permit to Work (PTW)
The PTW procedure shall be applied to the high-risk construction works (even inside
Greenfield areas), defined as follows:
• TCF included site temporary utilities installation and site demobilization (i.e.
disconnection, etc.);
• Confined space (EXXI-010-00-00-HS-PRO-0206);
• Electrical Hazardous Work (i.e. work requiring hazardous energy control/isolation,
those including working near high voltage line/equipment, etc.);
• Hot Works in possible hazardous environment;
• Road Interruption and road systematic closure;
• Crane lift requiring specific study or for example above 50 tons or near live
plant/systems or above 80% of related crane safe working chart (EXXI-010-00-00-
HS-PRO-0205);
• Excavation involving dangerous or unknown underground condition (i.e. possible
presence of live line/pipe/cable, etc.); EXXI-010-00-00-HS-PRO-0202 Safe
Excavation and Earthworks
• Scaffolding requiring specific study and suspended scaffolding(EXXI-010-00-00-
HS-PLN-0010);
• Working at height without proper safety edge condition (i.e. roof work, etc.); EXXI-
010-00-00-HS-PRO-0203 Work at Heights and Fall Protection
• Works involving hazardous material;
• Works in environmental sensitive area or works that could be immediately
dangerous for environmental;
• Radiography (EXXI-010-00-00-HS-PRO-210);
• Night work;
• Any activities to be done on/in/near live plant areas;

• Other non-routine activities creating risk also to those not executing the work or to
area not apparently involved in the work (i.e. pressure testing, abrasive blasting,
chemical welding, pre-commissioning activities such as chemical cleaning,
flushing, blowing, etc.).
12.1.2.1. PTW forms and issuing procedure
For Site Permit to Work in Grass Root Area during Construction, Pre-Commissioning
and Commissioning phases refer to EXXI-010-00-00-HS-PRO-0101 Permission for work
of high risk.
Otherwise, the procedure to be used is the one implemented by the Plant OWNER, if
foreseen. The issuing procedure shall be specifically agreed at site.
12.1.2.2. PTW issuing roles
JV Site Management ensures that the correct process required for a Safe Work
Execution is applied, reviewing (jointly with Plant as applicable) the PTW, as required.
For systems/areas under Pre-commissioning, JV Site Management will also ensure

proper field coordination between Construction and Pre-commissioning activities by
involving the relevant JV Site Management System Owner in the PTW reviewing
process.
For systems/areas under Commissioning and up their handover to the OWNER, the JV
Site Management System Owner, playing the role of Permit Issuer, will ensure that the
system/area where the work has to be done are and will be maintained in the safe
condition that allowed the start of the work.
To respond to these principles the following PTW key roles are basically identified:
 Requester: the executing party, generally JV Site Management or Subcontractor,

who wants to execute the work and shall initiate the PTW, presenting all the
documentation needed (JHA, PTW initial form fill, etc.). The request shall be
submitted not later than the day before to work (unless otherwise specified).
 Reviewer: the concurring party. This additional role will be covered by JV Site
Management/OWNER Plant (the organization in charge of the area) to check that
the system is going to be activated by the executing party as required. For
activities to be performed on systems or inside areas under Precommissioning, the
relevant JV Site Management System Owner will also act as technical reviewer to
improve site coordination.
 Issuer: the operating party, which accepts the work to be done and/or gives the
final prescription/ authorization to work operating party responsible person in the
Grass Root Area (JV Site Management or Subcontractor). For activities to be
performed on systems or inside areas under Commissioning is the relevant JV Site
Management System Owner. The PTW generally will be valid for the duration of
one shift or the period stated and accepted on it.
 Receiver: the executing party - usually the JV Site Management or Subcontractor
Supervisor/Foreman of the crew that shall execute the work and recognized all the
conditions established for a safe execution of the work. The receiver shall be

always present at Site during work execution and shall guarantee the
implementation of the PTW. Working area shall be left in perfect housekeeping
condition after work interruption or completion. Work completion shall be certified
to the issuing authority and JV Site Management.
Construction and PC&C activities, not included in the scope of work of any
subcontractor, may be executed under direct JV Site Management supervision. In this
case, JV Site Management staff may cover, according to different situations, the role of
PTW Requester, Issuer or Receiver. In any case, the role of Issuer and Receiver shall
be never covered by the same person.
All the involved reported persons shall be competent and trained in their duty and role:
trained on the specific Permit to Work Procedure; they shall pass a specific test on site;
their name and signature shall be maintained in a specific register; they shall be easily
identified on site by issuing a specific card/badge, etc. See typical forms in Attachment
10.
NOTE:
During PC&C the JV Site Management System Owner shall be a person in the position
to have constantly the full control on the system, being fully aware on its actual status
and able to identify hazards related to this status; usually this role is covered by the
PC&C Supervisor in charge of the PC&C activities on the system or by the PC&C
management.
Prior starting of PC&C activities on a system or portion of it, the relevant System Owner
shall be named within the JV Site Management PC&C organization.
12.1.2.3. PTW in areas assigned
Request of Permit to Work shall be submitted in time to JV Site Management for review,
not later than the day before (24h) the intended work (unless otherwise specified) and
will be valid for the duration of one shift or the period stated and accepted on the permit.
There shall be no variance of or from the Permit issued and authorized without the
consent of JV Site Management.
All permits, unless otherwise stated, will have a specific Job Hazard Analysis attached
and will be operative after having done specific Tool Box Meeting and relevant –Daily
Task Risk Assessment - DTRA.
12.1.3. Daily Task Risk Assessment (DTRA).
Daily Task Risk Assessment (DTRA) is a systematic process conducted on a day-to-day,

shift-to-shift basis, immediately prior to start a job (and when a job changes) to check
that the Preliminary Analysis of Risk Levels (APNR) is consistent with the risks present
in the field. In case some new risks are detected that are not considered in APNR result,
the activity cannot start and the new risks need to be evaluated through a revision of the
APNR analysis.

The process shall be performed by the foreman with the employees of his crew utilizing
a dedicated check list that is filled in based on the result of the APNR; the document
shall be carried out by the foreman for the entire duration of the shift and updated if
necessary (new risk arising: for instance dust created by wind).
At the end of the shift the DTRA formats will be collected; regularly the JV Site
Management shall analyse the results of these inspection as they are reported to spot
particular problems to be solved beforehand.
See the form inside Attachment 17.
12.1.3.1. Tool Box Meeting (TBM)
The DTRA form (Attachment 17) shall be discussed at the job site by the foreman with
his craft every working day immediately after the DTRA has been performed.
The JV Site Management / Supervisors may participate or facilitate these meetings as

needed.
The subject of the meetings shall be the job/task specific related and contain the
following information:
 Review of the APNR/JHA of the activities

 The daily work plan
 Work that is being performed near by
 Environmental considerations
 Updates of procedures
For PC&C activities executed under direct JV Site Management Supervision, the TBM
will be held by the JV Site Management supervisor in charge.
12.1.4. Field Execution Control and Follow-Up
Line supervision shall conduct periodical site survey during the job execution to evaluate
and immediately correct any discrepancy from the defined JHA/PTW, HSE Work
Practices and working methods.
12.2. Temporary utilities installation and demobilization plan
Plot plan/drawings of temporary utilities installation, such as electrical cable

underground, electrical cable route, power station, water and air supply, etc. shall be
prepared and shared on site to prevent incidents; JV Site Management and
Subcontractors shall collaborate to give and to share such information on site.
12.3. Personal Protective Equipment
Each organization at site is responsible to provide its personnel with any Personal or
Collective Protective Equipment needed to perform the job according with hazard

identification analysis or deemed necessary to control hazards caused by general site

conditions or simultaneous execution of activities, even if not under its direct control.
PPE shall comply with rules and requirements of the Mexican standard. All personnel
present at Site (employees, visitors and vendors) shall wear the foreseen PPE.
This should be considered for the selection of the use of PPE: the selection of suppliers,
to ensure the acquisition under the requirements of the specifications based on the
results of the identification of hazards, evaluation and control of risks (APNR and JHA).
The minimum PPE required for all personnel at Site are: Safety helmet; Safety glasses;
Safety boots (steel sole and ankle protection), Safety gloves, suitable working clothes
and high visibility vest (when necessary).
Clothes shall be type with long sleeves. For easy identification, personnel clothes shall
have a sticker with the Company logo.
Wearing of rings, bracelets, and necklaces is forbidden during working activities. Long
hairs shall be tied back.
During Precommissioning / Commissioning phase use of NOMEX overalls is highly

recommended.
Additional PPE should be requested depending on specific work activities and/or a
specific work area, and should be specified APNR, specific JHA, and/or PTW, MSDS,
etc. such as: Hearing protection; Safety harness; High visibility vest or reflective bands
on coveralls; Coverall; Welding/grinding protection; Respiratory protection; Escape
masks; Portable - Personal gas detectors; Cartridge filter mask, etc. Personnel shall
receive specific training in all the above reported circumstances.
In the areas of work which require the use of PPE other than mandatory specific signs
must be installed.
The use of PPE should be encouraged through programmes of motivation on their use,
care, storage and disposal.
The needs for facilities or collective protection devices shall be identified, on the basis of
the studies of risks and impacts.
It must take precedence for using collective protection devices based on analysis of
engineering in relation with the use of PPE, when conditions of the place of work permit.
12.4. Hazardous Material and Material Safety Data Sheet (MSDS)
Any hazardous material brought to Site shall be accompanied by its MSDS, written
according to ANSI Z 4001:1998 or equivalent recognized standard, i.e. in 16 points.
A copy of the MSDS shall be handed over to the JV Site HSE Manager, which will
forward the information to all involved parties as needed, and always one copy to the
Medical Services. All MSDS shall be maintained in a Site register. See Attachment 34.

The training of all parties involved in the handling, transport, use, storage and disposal of
hazardous waste, must be considered as precaution resulting by the risk analysis
process.
All personnel involved in chemical handling or potentially exposed to hazardous

materials shall be informed in related risk as described in MSDS (See also Sections 14.5
for more details).
12.4.1. Dangerous materials handling/storage
Particular attention shall be given to:
 Material receiving and warehousing (including also the hazards of the internal
vessel/equipment inertization with nitrogen, etc.)
 Material protection during storage and construction (taking particular care also to
non-compatible storage substances that shall not be stored together, etc.)
Materials shall not be stored or used within restricted areas where there is no fire
extinguisher or PPE available as required by the MSDS. The quantity of hazardous
materials stored on site shall be kept to the lowest practicable level.
Specific signals/safety information shall be provided in place where chemicals are

usually load/unload from bulk/tank/track. Personnel shall wear adequate PPE as shown
in MSDS. Load/unload shall be never done alone by the workers, but under specific
supervision.
12.5. Respiratory Hazards and Protection Apparatus
Respiratory hazards at Site shall be identified. If the case, starting from the MSDS, other
information available and specific procedures, following topics shall addressed:
 The specific information/training needed and the evidence of the info/training done
 The minimum HSE requirement to work in such areas, for example the presence of
stand on person, the availability of respiratory equipment next to the place of work,
etc.
In case of possible request to use Respiratory Protection Equipment shall be foreseen:
 Specific additional recorded training including practical drill on how to wear and
use these apparatus. The training/drill shall be done at the start of work on site (or
in the specific role/position) and shall be refreshed at least twice a year.
 Breathing equipment control (pressure, status, etc.) as per manufacturer
instruction
12.6. Confined Space
Confined space entry cases and hazards shall be identified at site, signalled by means
of signs posted at the entrance. A list of all identified Confined Spaces shall be prepared
and kept updated. Specific additional recorded training shall be given to each person
that needs to perform activities inside the Confined Space. The necessary gas test, the

fundamental role of the external man-watching and low voltage equipment and positive
isolation from hazardous energy sources, if any, shall be applied as indicated by the
correspondent risk analysis. Provisions are to be made for emergency evacuation of
injured personnel.
A specific work permit (PTW) is always mandatory.
12.7. Fall protection
Where fall distance exceeds 1.5 meters in Mexico, scaffolds and/or catch platforms shall
be made available.
Safety harnesses with lanyards and shock absorbers attached to lifelines, safety catches
or other substantial objects are mandatory and shall be used.
The personnel working at height shall be properly trained on the correct use of the safety
harnesses.
If the use of scaffolds and/or catch platforms is impractical, safety nets shall be installed.
All people working at height (more than 1.5m) in presence of a fall risk shall be provided
with a full harness system 100% tied off. In most part of cases the implementation of
100% tied off policy implies the use of full harness systems provided with 2 lanyards.
Scaffold shall be managed according the document Site Safe Scaffold EXXI-010-00-00-
HS-PLN-0010. Works at Height shall be managed according Works at Height and Falls
Protection Procedure EXXI-010-00-00-HS-PRO-0203.
Ladders shall not be used as a work-base. Ladders shall be used only as temporary way
to working area, to fasten and detach the rigging equipment and to other similar short
term work. The ladders must be placed on a solid and level base. They must be stable
for the entire working time. The top or foot of the ladders must be fastened with safety
clip or equipped with undrifting gear or used with other similar effected procedure.
12.8. Scaffolds
All scaffolds built at Site shall be stable and safe to use. The Company erecting the
scaffold shall submit to JV a Scaffold Management Plan, before starting the activities.
The Scaffold Management Plan is a document by which the scaffold subcontractor
describes how the scaffolds are managed at Site. It shall include at least the following
topics:
 Scaffold System description (Manufacturer Manual);
 Standard and Engineered Scaffolds;
 Organization and Responsibilities;
 Competence and Certifications;
 Scaffold Erection/Alteration/Dismantling procedure;
 Inspection system (for scaffolds and scaffold material);
 Scaffold Access (Scaffold Tag system);
 HSE control measures and safe practices;

For more detailed information about the requirements and standard to be followed refer
to the document EXXI-010-00-00-HS-PLN-0010 Site Safe Scaffolds.
12.9. Lifting Operations
All equipment brought into site must be in safe operating condition at ALL times.
Cranes and all equipment provided with lifting apparatus shall be provided with a third
party certificate. The certificate shall be maintained through yearly inspection by the third
party.
All lifting accessories (chains, hooks, shackles, slings, etc) shall be maintained in good
condition at all times as well and certified by a third party with validity of one year.
No lifting can be performed with equipment not provided with third party certificate or
with lifting accessories not certified by the third party.
For more detailed information about the lifting operations refer to the Procedure EXXI-
010-00-00-HS-PRO-0205 Safe operation for mobilization of loads and inspection of
lifting accessories.
12.10. Structures and support erection
Every partially constructed or fully constructed supporting structure in a worksite,

including its foundation, shall be able to safely withstand any foreseeable load likely to
be imposed on it during the construction or dismantling of the structure which the
supporting structure supports.
It shall be the duty of JV Site Management to ensure that no wall, chimney or other
structure or part of a structure in the worksite shall be left unsecured or unshored in such
condition that it may fall, collapse or weaken due to wind pressure, vibration or any work
being carried out in the worksite or in the vicinity of the worksite.
12.11. Dangerous Area Segregation during Construction
Hazard related to several Site activities can be indicated through proper area
segregation. Examples of such activities during construction are: area around heavy lift
or below works with possible falling material; sand blasting; radiography; scaffolding
construction and dismantling, excavation, road work, etc. In all these cases rigid barriers
(planks, etc.) shall be preferred to plastic tape, which use is discouraged inside the
Project premises.
For general construction activity the area segregation can be done by red/white barrier
and/or orange plastic net and/or usual warning signs, providing that their integrity will be
periodically checked and those means will be replaced as needed. All people shall
respect area segregation and supervisors shall check that only allowed people enter the
area.
12.12. Night work
All works done during night shift needs to have a specific plan to address the hazards
and the preventive and/or supplementary measures needed, for example: lighting,
emergency, medical and HSE surveillance, supervision, etc.

12.13. System/equipment energization
As getting closer to construction completion, system/equipments will be temporarily or

permanently energized in order to perform PC&C activities. It’s possible to refer to these
systems also as “live” system.
Permanent or temporary energization shall be executed under Permit to Work.
Aiming to promote the field coordination between PC&C and remaining construction
activities, the continuous application of the Safe execution of Work process shall be
integrated with the following additional precautions:
 Advanced communication to other site organizations of forthcoming PC&C
activities.
 Isolation of live systems
 Identification of live system
 Segregation of PC&C hazardous areas
12.13.1. Advance Communication of forthcoming PC&C activities
At least 24hrs prior to temporarily or definitively energize a system or portion of it, an

alert notice shall be sent to all site organizations (JV Site Management, Sub-Contractor,
Owner, etc).
The alert notice shall contain at least: description of the system/portion of system to be
energized, scope of energization, relevant specific hazards, control measures put in
place, eventually site areas to be banned/restricted, eventually additional safety
precautions to be applied, relevant JV Site Management System Owner.
The Site Organization in charge of the activity shall provide JV Site Management with all
needed information to send the alert notice on due time.
The alert notice shall be considered a preliminary requirement for the issuance of any
Permit to Work for system energization.
Each site organization is in charge to ensure that contents of the above communications
are fully cascaded to all their personnel. JV Site Management and Sub-Contratctors shall
include this information in the daily TBM.
An updated list of live systems and an updated map of restricted areas for PC&C
reasons shall be available at site. A weekly resume shall be issued by the JV Site HSE
Manager to all site organizations.
12.13.2. Isolation of live systems
Prior to be temporarily or permanently energized, system/equipments shall be positive

isolated from the rest of the plant still under construction.

Proper method of isolation (isolation points, isolation devices and sequential steps of
isolation) shall be defined by competent personnel belonging to the site organization in
charge of the PC&C activity execution. Defined method of isolation shall be submitted to
JV Site Management relevant System Owner for review and approval at least 3 days
before the energization.
The physical isolation of the system, in accordance with the isolation method approved
by the System Owner, shall be implemented and certified by the site organization in
charge of the PC&C activity execution (usually JV Site Management for PC activities).
This certificate shall be considered a preliminary requirement for the issuance of any
Permit to Work for system energization.
Isolation devices shall be locked and tagged with “DO NOT OPERATE” tag to make
them clearly recognizable in field and avoid unauthorized isolation removal. Isolation
devices can be exclusively removed by the person that installed it.
A list of all isolation points and installed isolation devices (blind list, LOTO register) shall
be maintained updated by the site organizations in charge to physically implement the
isolations and made available to JV Site Management on demand.
12.13.3. Identification of live systems
The site organization in charge of PC&C activities (usually JV Site Management for PC
activities) shall make clearly recognizable in field the systems/equipment under PC&C by
rolling up warning tape and/or posting warning signs on the reachable parts of those
systems (tentatively each 8 m).
When the number of involved systems grows up, segregation of overall areas with rigid
barricades or fence may substitute the one by one system identification. Access to the
segregated area shall be restricted to only authorize personnel.
Specific Permit to Work shall be obtained to perform any kind of activity on live systems
(system under PC&C).
Barricades, tape and warning signs colour shall be differentiate from the ones used
during Construction activities. Generally black&yellow indicates PC&SU, while red&white
indicates Construction. Warning signs shall be able to resist to the weather conditions,
usually plasticized. They shall be fixed and well visible to all workers.
12.13.4. Hazardous Area Segregation during PC&C
The site organization in charge of PC&C activities (usually JV Site Management for PC
activities) is responsible to identify and segregate site hazardous areas due to ongoing
PC&C activities.
Depending on the hazard involved access to the segregated area may be completely
ban or restricted to only authorized personnel.
Access to restricted areas shall be subjected to proper Permit to Work authorization.

Special permits (badges, etc…) may be issued to a limited number of personnel

authorizing to enter inside specific restricted areas just to carry out site visit/survey or
visual inspections.
Area segregation for PC&C reasons shall be done by using black&yellow rigid
barricades, fence, chains or warning tape and warning signs. Warning tapes or chains
can be used only for areas that need to be segregated for a brief period of time such as
air blow-out points or running motors for run-in test.
For high risky areas a human garrison shall be used to have a strict regulation of the
access. If needed a sign in/out log of all authorized people entering/exiting the restricted
area may be maintained
12.14. Lock out/ Tag-out (LOTO)
Nobody is authorized to perform works on circuits or equipments that are or could be

potentially affected by unexpected energization, start up or release of stored energy
capable to cause injury to employees.
LOTO practices shall be applied for de-energizing, isolating and securing all hazardous
energy sources of equipment/circuits before work on it, and to protect from unexpected
energization while working.
Any activity to be performed under LOTO protection shall be previously authorized by a

proper Permit to Work.
Each site organization is fully responsible to assess all the risk connected to the
execution of its own activities, properly identify which could be affected by hazardous
energy releases and, whenever require, ask for LOTO practices implementation.
In case LOTO application is required, the proper method of isolation (isolation points,
isolation devices and sequential steps of isolation) shall be defined by competent
personnel belonging to the site organization in charge of the hazardous energy source.
Defined method of isolation shall be submitted to JV Site Management relevant System
Owner for review and approval at least 3 days in advance.
Competent personnel belonging to the site organization in charge of the hazardous

energy source shall implement the method of isolation approved by the TPIT System
Owner and certify its effectiveness.
JV Site Management will be in charge to define proper method of isolation, implement it

and certify its effectiveness for all the required electrical isolations up to the time the
Electrical Substation will be under its own Care & Custody.
JV Site Management will be in charge to define proper method of isolation, implement it

and certify its effectiveness for all the required mechanical isolations on a system since
the system will be under its own Care & Custody or still not under Commissioning.
The isolation certificate shall be considered a preliminary requirement for the issuance of
any Permit to Work authorizing activities under the energy isolation protection.
Isolation devices shall be locked and tagged with “DO NOT OPERATE” tag to make
them clearly recognizable in field and avoid unauthorized isolation removal. Isolation
devices can be exclusively removed by the person that installed it.

A list of all isolation points and installed isolation devices (blind list, LOTO register) shall
be maintained updated by the site organizations in charge to physically implement the
isolations and made available to JV Site Management on demand.
For the cases not included above the relevant JV Site Management System Owner will
take the responsibility to define and certify all the required electrical or mechanical
isolations and maintain relatives LOTO registers. JV Site Management may be required
to support the Sub-Contractors System Owner in the physical implementation of the
defined isolation methods.
12.14.1. Red Blinds
Isolation Blinds that could lead to major/catastrophic incidents in case they are removed
by unauthorized personnel shall be identified as “critical isolation Blinds” and made
clearly and immediately recognizable in field by having the handle red colour painted
(Red Blinds).
Critical Isolation spades includes but are not limited to:

 Blinds isolating from highly hazardous substances (flammable, toxic substances)
 Blinds installed at the battery limits to isolate from external hazardous energy
sources.
In case the spade is installed with the purpose to isolate from highly hazardous
substances, further to the usual “DO NOT OPERATE” tag, a Red Hazard Tag reporting
the hazard involved and additional precaution required shall be installed on the spade
(g.e. Flammable gas - Gas test required for spade work; Toxic gas – Respiratory
protection required for spade work).
Red Blinds shall be exclusively removed under Permit to Work authorization and control.
12.15. Management of Battery Limits/Tie-ins
The portion of plant where JV Site Management is supposed to work shall be positive
isolated from any possible external source of hazardous energy such as portion of plant
under Owner responsibility; feed streams or electrical power provided by third entities.
Battery limits between the portion of plant under JV Site Management control and
possible external energy sources must be identified and secured in off position since
their first physical erection. Tie-ins shall be considered as Battery Limits.
A specific procedure for the management of battery limits isolating devices shall be
agreed between JV Site Management and the Owner. Minimum contents of this
procedure shall be:
 A system of Lock and Tag shall be enforced. JV Site Management shall be in the
position to lock and tag each battery limit.
 Removal of positive isolation shall be subjected to written JV Site Management
agreement.
 A battery limit register shall be maintained
 Battery limit isolation devices (spades, valves, etc…) shall be red painted to be easily
recognizable

Whenever a portion of the plant (start-up package, system, etc…) is handed over from
JV Site Management to the Owner, the relevant Battery Limits, with the portion of plant
still under JV Site Management responsibility, shall be identified, isolated locked, tagged
and the battery limit register updated.
Management of battery limit shall be kept under direct JV Site Management control and
cannot be delegated to other Sub-Contractor organizations.
12.16. Energized Electrical Substation
Access to totally or partially energized Electrical Substation shall be regulated through

Permit to Work System.
Dedicated patrolling team shall be enforced to ensure the control of the Electrical
Substation accesses.
Only competent electrician can be authorized entering inside the substation unescorted.
All the other employees shall be authorized entering only with the presence and under
the direct control of competent electricians.
Fire retardant clothes shall be worn inside the substation as a minimum precaution.
Conductive objects (jewelleries, clocks, etc…) should not be worn.
The workers in charge of patrolling the Substation shall be trained on what to do in case
of emergency and how to activate/use the available fire fighting systems.
At least one employee knowledgeable and proficient on electrical first-aid fundamentals,

including resuscitation, shall be always present inside the substation.
High voltage rescue kit (telescopic rescue hook, insulating platform, insulating gloves)
shall be available in the substation.
As soon as Motor Control Switches starts to be powered up and field electrical

distribution cables are physically connected to the Motor Control Switches, relevant
electrical consumers, electrical driven equipment and electrical distribution cables shall
be considered power up, regardless the fact the Motor Control Switch has been positive
isolated from them.
Competent and experienced electrician shall be named as Substation Administrator by

the site organization in charge of the Electrical Substation. The Substation Administrator
will be the only person on shift entitled to operate electrical switch gear and
consequently energize or isolate field electrical circuits and consumers. He will be also in
charge to certify electrical positive isolations as per LOTO requirements and maintain
updated the LOTO register.
Written communication of this appointed person shall be made available to JV Site

Management which can approve or reject the appointment.
12.17. Portion of plant in operation within a worksite

Whenever portion of plant are operated under JV Site Management responsibility, even
if as a correlated aspect of on-going PC&C activities (e.g. fuel gas system for furnace
dry-out, operation of dryers/compressors for systems drying), all the necessary
measures shall be implemented to ensure the integrity of the plant equipment and the
safety of the entire site personnel.
System equipment in operation shall be identified or, whenever feasible, physically

segregated from the remaining construction site. Access to the restricted areas shall be
controlled and limited to authorized personnel.
Site organization should be rearranged integrating it with competent shift supervisors,

panel operators and field operators as needed.
A clear written system of communication between different shifts shall be implemented.
Radio communication system between Control Room and field operator shall be
enforced. Construction, PC&SU and HSE management shall be also provided with
radios in order to be able to get quick information in case of emergency. The possibility
to equip subcontractor’s managers with radios should be also evaluated.
By-pass-override of critical control process or safety devices shall be regulated and

subject to written authorization by a competent person belonging to JV Site Management
organization
The following step shall be followed prior to proceed with a by-pass/override of critical
control process or safety devices:
 Identification of correlated process and safety hazards
 Identification of adequate backup protection measures
 Identification of eventually additional safety precautions to be employed during the
override.
A by-pass/override register shall be kept updated at the control room.
12.17.1. Pre-start up safety review (PSSR)
The PSSR shall be performed prior to introduce highly hazardous chemicals (e.g.
flammable liquids and gases, hydrogen sulphide, etc.) in new or significantly modified
facilities aiming to prevent or minimize the consequences of incidents caused by
inadequate, incomplete, unauthorized design, construction, installation, and/or
commissioning.
Scope of the PSSR is confirming that:

 construction and equipment are in accordance with design specifications;
 adequate safety, operating, maintenance and emergency procedures are in place. All
site personnel has been properly instructed on it.
 safety equipment (gas detectors, firefighting, safety showers, breathing apparatus,
etc...) are available and in service
 competent process operator are available and properly trained
 for new facilities, all the recommendations resulted from the Process Hazard Analysis
(Hazop study, etc..) have been resolved and implemented.

 modified facilities meets the requirements contained in the management of change
The PSSR shall include a physical field inspection (walkthrough) aimed to ensure that
general site conditions (housekeeping, facility accessibility, area segregation, safe work
practices implementation) are satisfactory.
Early start-up of single systems/circuits which involves the introduction of substance

possessing toxic, reactive, flammable, or explosive properties, even if to perform
Commissioning activities (g.e. introduction of fuel gas inside the fuel gas system to
perform furnaces dry-out), shall be subjected to a formal (simplified) PSSR review.
12.17.2. High Toxic Areas
Site areas potentially exposed to unexpected releases of high toxic substances shall be
identified and communicated to all site organization and likely affected employees and
physically segregated in field from the rest of site.
For those areas the following shall be implemented:

 All the activities inside those areas are executed under Permit to Work control.
 All personnel entering in those areas is deeply informed and specifically trained on
toxic materials characteristic, preventive and protective measures to be adopted,
emergency procedure;
 Collective protective equipment’s, if any, are in service (g.e. toxic gas detectors and
alarms, water curtains, etc…)
 Suitable personal protective equipments are provided to all personnel (personal gas
detector, escape mask, etc…)
 Stand on person is requested as a prescription in work permit;
 Emergency escape way identified and kept free.
 Rescue team trained and equipped to intervene in case of high toxic substances
released is available
13. OCCUPATIONAL HEALTH AND MEDICAL SERVICES
Each site organization JV Site Management and Sub-Contractors is responsible for the
health of its own employees and the employees of its subcontractors. Nothing contained
in this Site HSE Plan shall relieve any organization of its responsibility.
13.1. Medical Examination and Services
JV Site Management and Subcontractors employees shall be subjected to a pre-job

medical examination, prior to start working at Site, to check that they are fit for the work
they are foreseen to do. The occupational exams shall be performed in accordance to
Mexican regulations and Project HSE procedures. In some cases, for single free-lance
short time job (up to thirty days), a medical certificate attesting the person is fit to work
can be accepted. For all this employees shall be present at Site the tests of occupational
exams according to the function to be performed, including clinical examination,

laboratory tests and additional exams, when required. The subcontractors should
perform occupational exams according to the recommendations of HSE of the project.
If personnel suffering contagious diseases are detected, their entry to Site has to be
prevented until disease is properly treated and no more contagious.
13.1.1. Medical Services
JV Site Management shall provide the necessary site medical services (i.e. main first aid
place, ambulance, arrangement for professional treatment, medical assistance) as well
as the transfer to medical specialist service and evacuation, if necessary.
Information and communication about the nearest Hospital Available will be given on
site.
Written agreements shall be made with the available medical structures. A check must
be done on the preparedness and timetable needed.
13.1.2. First Aid Facilities
The following medical facilities have to be provided by JV Site Management and tailored
on local site conditions:
 Project First Aid facility with certified nurse and paramedics.

 First Aid Boxes (FAB) and stretchers shall be always present related to the number
of employees
 FAB shall be well signalled and located in easy reachable places. Minimum
contents shall be as per Mexican law and integrated, if needed, as suggested by
OWNER Plant. Designated persons shall be in charge as First Aid trained
personnel.
 Communication capability shall be guaranteed with the emergency medical
services at the Plant Site First-aid Clinic and at the Local Hospital Facilities:
agreements or arrangement shall be taken for immediate transport and treatment,
if required
 Workers shall be trained on the quickest way to call the First Aid Room assistance
 All injured personnel must be accompanied to the Local Medical Centre by either
his direct supervision or his delegate. Languages translation problem shall be
evaluated.
13.2. Health training
13.2.1. Employees Information and Training
JV Site Management and its Sub-Contractors personnel shall receive basic construction-
oriented industrial first aid for the emergency treatment of life threatening injury or illness
(arterial bleeding, burns, trauma, stroke, shock, heat stress) and basic first aid principles
and skills (sepsis, fractures, strains, sprains), as well as spreading of the awareness
among the work force and management concerning certain health risks related to the
work itself or to the age of the individual.

The following are some of the information and training that JV Site Management and its
Subcontractors are expected to give to their employees:
 First aid attention, including the management of animal, insect bites;

 “do-s” and “don’t-s” in case of an accident;
 Hygienic conditions and attitudes;
 Proper food handling in the kitchen, mess-room and on the work front;
 Contagious and Occupational Diseases, Heat Stress,
 Climatic Stressors
 Maintenance of “Fit For Work” status
This training can be provided during:
 Orientation training;
 On-going Toolbox Talks;
 Health Campaigns;
 Site Bulletin Boards & Posters;
13.2.2. First Aiders Qualification and Training
Foremen and other line supervision must hold a valid Standard First Aid Certificate.
13.2.3. Medical Documentation
Confidentiality shall be maintained of the information contained in the records of the

worker, as stated by Mexican regulation – Reglamento Federal de Seguridad, Higiene y
Medio Ambiente de Trabajo.
JV Site Management Medical attendant shall record all cases seen or treated by him,
including:
• Date and local of attendant;

• Personal dates (employee´s name, badge number, craft and Company);
• Type of attendant (ambulatory, occupational, emergency, accident/injury/illness);
• Medical evaluation with diagnosis, treatment and further care recommended.
In case of Injury will be done a medical report including all the information; date and time
of injury; nature of injury and whether sent home or elsewhere; treatment provided and
further care recommended; any work restrictions imposed by injury and/or treatments.
Copies of these records shall be attached by JV Site Management to the accident report.
For fatalities, cases requiring hospitalization, or possible lost time injuries, JV Site
Management shall be immediately notified; JV Site Management shall immediately
inform OWNER Plant.
.
13.3. Sanitation of TCF, Living accommodation, Rest/Break Areas

Hygiene and housekeeping is the basis of a healthy environment. Inspection shall

consider such aspect as a first condition to be inspected.
All the temporary buildings and facilities, working, living and storing areas, equipment
and tools must be kept in a hygienic condition.
Decontamination/infectious vectors control in the premises/grounds shall be done as
necessary to prevent breeding of insects or vermin. Form fumigation campaigns were
conducted periodically through an annual programme.
All site organizations shall:
 provide sufficient covered garbage containers at appropriate locations to ensure

adequate storage capacity and to prevent litter from “free” accumulating and
 Collect and dispose of garbage and refuse on a daily basis in a manner
acceptable to JV Site Management.
 For the classification of residues containers will be identified according to the
following colour code:
 Green: organic Residues

 Blue: inorganic Residues
 Coffee: metallic small recyclable Residues
 Red: Dangerous Residues
13.3.1. Temporary Construction Facilities (TCF) – Worker Support Infrastructure
JV Site Management and Subcontractors shall provide the offices, warehouses, lay
down areas, canteens, washrooms, latrines and other facilities, the locations and
availability of which must be in accordance to Mexican regulations and Project HSE
System procedures..
Drawings of the proposed arrangement of these facilities (including all the necessary
services, etc.) shall be handed over to JV Site Management for review and authorization
before any actual installation activity starts.
13.3.2. Living accommodation (if foreseen)
Not foreseen
13.3.3. Toilet on Site
Toilet and hand washing basins at all work locations shall be provided in numbers
commensurate with the number of personnel. There will be at least one toilet and one
wash basin at no more than 120 meters from all work areas. Separate toilets will be
provided at areas serving workers from both genders.
Toilet facilities shall be provided for employees to the ratio of at least one toilet per 20
(twenty) employees. Portable toilets shall be strategically located in shaded areas so as
to provide adequate coverage for all active work areas. Trench toilets are not
acceptable.

Main bathroom facilities will be located by dressing room and bathing areas for use at
beginning and end of work shifts. If urinals are provided in male bathrooms, they will be
distributed at a rate of three (03) linear meters for every 100 workers.
All job site toilets shall be serviced and cleaned on a regular basis, frequently as
necessary according to the amount of use and season providing 2 (two) cleanliness per
day.
13.3.4. Rest Areas
Shaded rest areas will be provided at no more than 150 meters from every work area.
These will be appropriately sized for the workforce they serve and will have sitting space.
Cool drinking water will be available at all rest areas. Supply of cool water will be
planned according the size of the workforce in the vicinity of each rest area and will be
provided on the basis of 700 ml per worker/day. Re-hydrating beverages will be available
during peak summer months.
Rest areas will also serve as rain shelters when weather conditions do not allow for
continuity of some activities.
13.3.5. Eating Areas and Canteens / Kitchens / Food Hygiene
Food cannot be consumed on worksite except in designated areas agreed with JV Site
Management.
Employees shall take breaks and eat lunch in designated areas only. These areas shall
be free from hazardous materials or other possible contaminants. Lunch and break area
shall be removed from active work areas where employees would be exposed to on-
going work while eating lunch or taking break.
Food services shall comply with the Local Legal Requirements for food handling,
following the highest standards of hygiene. Food and beverages offered shall ensure
continuing health and be culturally acceptable to the workforce.
Canteens will have capacity to serve all workers on a sequential shift basis. Self-service
lines will be sized to limit waiting time to less than 10 minutes. Sufficient chairs and
tables will be provided for all. Hand washing basins and soap will be provided near the
self-service lines.
Canteens and kitchens will be cleaned and disinfected daily.
Canteens will be adequately lighted and ventilated and will be kept at temperature
between 20oC and 30oC during serving periods. Water fountains with drinking water will
be available as well as hand washing basins.
Canteens will be designed for acoustic comfort and will meet a 50 dB(A) noise limit
through use of appropriate construction materials and/or architectural layout
adjustments.
Kitchens will comply with international hygiene standards for food preparation, food
storage and cooking. Associated dishwashing / laundry will be sized to meet capacity
requirements.

Kitchens shall be located outside of site construction activity areas, separate from other
premises and unhealthy sources. Kitchen shall be fully furnished to guarantee hygienic
conditions (i.e. lighting; doors; suitable sinks with hot and cold water; refrigerator for food
with thermometer; dedicated room for food storage; cleaning materials; segregated
stored locations for food and chemicals; no smoking areas; fire fighting system, etc.). All
trash, debris and food residue shall be cleaned up at the end of the break, in order to
maintain the area clean and in good housekeeping.
Periodic hygiene assessments or certificate verification shall be conducted to verify

hygiene standard and fitness of kitchen staff.
All personnel working in the canteens and kitchens of the project, without exceptions,
shall be submitted to periodic medical exams to determine their current state of health.
For all this staff personnel the results of relevant laboratory tests, shall be available on
site.
Bacteriological analysis of beverages and food shall be performed on a quarterly basis

by a certified company.
All personnel working in both the kitchen and canteen areas must wear headgear, cloth
apron and mouth cover.
13.3.6. Administrative Areas
Office areas will be designed to meet a 45 dB(A) internal noise limit and will be
adequately lighted and ventilated. Interior temperatures will be kept within the 20oC to
25oC range. Open office halls will observe a maximum density of one worker per 8 m 2.
Office areas will be cleaned at last weekly.
13.4. Alcohol/drugs and smoking
13.4.1. Alcohol/drugs
Each and every worker at Site has a responsibility to work in both physical and mental
condition to perform his/her designated duties. The use, possession, distribution or sale
of impairing drugs or alcohol is strictly prohibited, unless the worker is authorized by a
medical prescription and beforehand he informed Site Management of his health
condition. The violation of such Alcohol / Drug policy is punished through the ETILENO
XXI discipline scheme and according the Mexican applicable law (Art. 47 of Federal Law
of Work – Ley Federal del Trabajo)
In case of doubt due to improper behaviour of an employee, JV Site Management can

request to undergo a test (with the breath analyser &/or urine analysis).
Preventive measures for the consumption of drugs and alcohol will be put in place,
through the execution of specific Training sessions, advertising Campaigns and sharing
of Lessons Learned to all Project personnel.

13.4.2. Smoking at site
Inside the project smoking is prohibited everywhere, except in dedicated smoking areas.
13.5. Work Breaks / Lunch Breaks
All workers will be allowed 30 minutes for lunch / dinner depending on shift. Additionally,
one 10 minute break / rest period will be programmed into each work shift. Additional
breaks may be allowed in the case of physically demanding activities.
13.6. Hot condition – heat stress
Specific breaks will be established during very hard weather conditions for the needed
rest of the workers and instruction given to maintain healthy condition to work.
A permanent program of hydration of the workers shall be implemented at Site, so that,

water containers will be installed in different areas of the project, in order that workers at
all times are hydrated.
13.7. Water Supply
The supply of potable water for human consumption and food preparation must be
guaranteed for the health and well-being of the workers. All personnel shall be provided
with reasonable access to water and rest, sufficient to prevent heat stress.
Adequate supply of cold potable water shall be provided on work sites on shaded rest
areas. Drinking water containers shall be clearly labelled as to the nature of its contents
and the date of filling up, and shall not be used for any other purpose. Common drinking
cup is not allowed and person is not permitted to drink directly from the container or to
tamper it.
All potable water will meet both legal and World Bank standards for potability and will be
random sampled monthly to verify compliance. Sufficient clean glasses for water
consumption will be available. The water containers need to be analysed monthly for
detection of total coliforms and every 6 months for the detection of the maximum
permissible pollutants by heavy metals
Eye washes shall be provided for workers need, (when required).
13.8. Hearing protection
Practicable methods shall be used to reduce hazardous noise levels, but when these
remain excessive, hearing protection shall be worn. Hearing protection is not a substitute
for engineering or administrative controls of hazardous noise sources.
Generally, the following actions can be taken depending on noise level and according
with local law and regulation: Employee education, Distribution and mandatory use of
protective devices and sanitary surveillance.
The JV Site Management is responsible to determine whether the area around

equipment he is using is generating a hazardous level of noise; in this case, the involved
area shall be properly isolated and signalled. It is expected that any involved parties will

provide and maintain available at all times at no cost to the employees, adequate
hearing protection equipment.
13.9. Site Housekeeping
All Site working areas shall be kept always tidy and in good order. Before starting the
activity the foreman with his team shall check the housekeeping status of the workplace,
eliminate all possible tripping/slipping hazards and ensure that all access means are free
and in good condition. At the end of the shift the team work shall remove all scraps,
debris, garbage produced during the activities disposing them in the right waste bins. All
equipment and working tools shall be left in order and in the right place.
Housekeeping campaigns shall be periodically organized at Site in order to increase the
workers’ level of attention and awareness towards housekeeping good practices.
13.9.1. Use of containers/recipients
Each container / recipient shall be suitable for the substance/material it is supposed to

contain and shall be labelled with the name of the substance/material it is designated to
contain.
13.9.2. Cable housekeeping
Cable housekeeping shall be implemented at Site by placing temporary electrical cables

according pre-established routing, and preferably raising them above ground by using
supports and hooks.
13.10. Hygiene industrial condition
The Hygiene condition of the working environment shall be constantly monitored by the
site’s HSE management (as per the procedures in Section 6.2 of this HSE Plan), in order
to reduce the risks for short and long term diseases that could arise due to the exposure
to repeated activities, environmental pollution, poor working environment condition, etc.
Such risks shall be mitigated through the following activities:
Noise Evaluation: evaluation of exposure to high levels of noise, definition of preventive

measures and application of controls and PPE. The noise levels shall be measured
where the risk is present and a Map of the Site where the risk is high shall be produced
and kept updated during the execution of the Project.
Ergonomics: The risk evaluation for repetitive activities and for a wrong posture of the
worker during the job shall be done for each activity and proper measure undertaken to
mitigate this risk.
Respiratory protection: Risk evaluation for chemical and biological agents shall be
performed and individual and collective control measures shall be defined for mitigating
the risk.
Insertion of people with disabilities and reduced mobility / rehabilitation for work:
focuses on integrating people into the workplace without discrimination and recognition
of their special characteristics, forecasts and availability of vacant posts. As necessary,
design of facilities will contemplate accessibility for disabled workers.

Vibrations: Risk of vibrations shall be evaluated for all activities requiring use of
particular machines and mitigation measures established.
Pollutants: The risk evaluation for presence of air pollutants shall be done and
pollutants air monitoring shall be put in place if needed.
Temperature: The temperature of the workplace shall be such that the job can be done
in a comfortable and safe way. The risk for high or low temperatures shall be evaluated
and proper mitigation measures shall be established and implemented.
Lighting Condition: The working environment shall be illuminated with a sufficient level
of light to perform the activities in a safe condition.
Good housekeeping: Practices are essential to a safe workplace. All work fronts and
temporary facilities shall be kept clean and tidy.
14. ENVIRONMENT
Site activities shall be conducted with the minimum impact on the environment and
according with applicable laws, permits, contractual regulation and site rules.
JV Site Management shall enforce and adhere to the Environmental management

requirements and practices executing the works in an environmentally responsible
manner.
Each site organization is responsible of its environmental legal infraction or damages.
During the Job Hazards Analysis execution, all environmental hazards shall be
considered in order to identify suitable corrective measures to be adopted.
All Project Environmental documents must be in compliance with Federal States

Municipal and Lenders’ regulations.
14.1. Environmental Aspects
The Project Group has identified and evaluated the significance of the direct and indirect
environmental aspects relevant to the site during the execution works, through the
following documents:
 EXXI-010-00-00-HS-PRO-0401 Identification of significant environmental aspects.
The analysis has taken into account particularly the local conditions, such as: Law, limits,
requirements, situation in and around the site, etc. and, in general, the severity and
frequency of the aspects related to the local environmental sensibility.
The environmental aspects identified and significant are managed as in this section.

14.1.1. Environmental data reporting
Environmental management data are to be produced and collected monthly by JV Site

Management and Subcontractors as part of the monthly report.
14.2. Permits & Approval
The requirements of all permits and approvals obtained by OWNER are mandatory and
shall be complied with.
An updated inventory of all controlled substances shall be maintained.
14.3. Gas, Vapour and Dust Emission and Control
Practices like vehicle speed restriction, dampening site access roads shall be applied
where necessary. When practicable, low sulphur fuel shall be used for all site diesel
vehicles/engines.
All engines shall be properly maintained to avoid: excessive production of not-

combusted exhausts, excessive fuel consumption, possible lubricant spillage.
14.3.1. Dust Control
Dust emissions should be minimized at all times on site.
 JV Site Management will select equipment designed to minimize uncontrolled dust

emissions
 In case of high winds, activities with significant potential of dust emissions shall be
monitored to avoid excessive spreading of the dust itself
 Emissions of dust that pose an immediate danger or significant nuisance to the site
workforce, general public or surrounding environment shall be limited (i.e.
Insulating material preparation and installation, post weld heat treatment materials,
abrasive blasting, earth-moving, soil preparation, excavation, dust coming from
catalyst loading, etc.)
 Temporary site roads shall be prepared early in the program. Personnel will be
required to enter the site over prepared surfaces and park in designated lots
 Water truck spraying will be used to suppress road dust. Water spraying will be
conducted at a frequency to keep the surfaces moist and prevent the generation of
fugitive dust
 When abrasive blasting operations are required, these operations will be located
so as to minimize noise and dust impact on adjacent work areas (silicate sand use
is forbidden)
 The use of tarpaulin or nylon sheets shall be considered to confine catalyst loading
operation and, consequently, reduce dust impact area.
 During air blowing activities, air releasing point will be barricaded with tarpaulin or
plastic sheets to reduce dust emission impact area.

 JV Site Management shall comply with applicable regulations governing open-

bodied trucks hauling sand, gravel, or soil between on-site and off-site areas.
Loads shall be covered and wheels cleansed where necessary to reduce dusting
and spreading of soil off-site.
14.4. Water Use and Waste Water
Water use minimization and reuse, impact minimization of controlled effluents from the
site to ground, underground or surface waters, are the main objectives.
Sanitary waste water from TCF services area will be collected to authorized treatment
facility or septic tank to be emptied on a regular basis. Under no circumstances shall
unusual waste water be diverted to the sewer systems, drainage ways, settling or
polishing ponds without approval from JV Site Management / OWNER Plant.
The water extracted during excavation (dewatering) shall be disposed of in accordance

with local regulation. Temporary drainage systems shall be used where required in order
to control and capture the runoff.
Specific procedure shall be developed on site for hydro testing, flushing, chemical
cleaning and boiling out of boilers to avoid possible problem to plant sewer system.
During PC&C Phase, liquid waste water streams shall be suitable for biological waste
water treatment otherwise must be disposed as hazardous/not hazardous waste in
compliance with paragraph 14.5.2.
No industrial wastewater shall be discharged to the sanitary wastewater system unless
authorized by OWNER Plant.
14.5. Waste Management Plan
JV Site Management and Sub-Contractors shall define its own Plan for waste
management (type and quantity of disposal, containers, organization, registered waste
transporters and final waste destination).
To dispose its own waste, JV Site Management and Sub-Contractors shall: inform the
local authority, valuate quality (code) and quantity of waste, contract to a licensed
company the transport and final disposal, maintain records of disposed waste, and every
month produce a report of the disposed waste to be submitted to JV Site Management.
All consignment of waste for disposal shall be recorded as per local regulation
requirement (indicating type, volume/weight, destination, other relevant information) prior
to being sent off Site. Records shall be shown upon request.
All wastes shall be properly managed
JV Site Management and Subcontractors at site shall manage and dispose their own
waste according to the applicable Laws and regulations and to the policy and objectives
of the Project.
During the Kick Off Meeting, an inventory estimate of Subcontractor waste production,
appropriated to the scale of the work, shall be submitted to JV Site Management..

JV Site HSE Manager, starting from the inventories of foreseen site wastes, shall verify
local possibility to apply a recycling process. In that case, offices and Site shall be
provided with different containers for recyclable wastes, as for example:
 Office waste: paper, plastic, toner, electronic scrap, etc.

 Site scrap materials and waste: metals, wood, cables, battery, oil and lubricants,
plastic and paper.
Site cleanliness shall be maintained at all times and trash removed in a timely manner. If
the site is not maintained in a clean condition, JV Site Management has the right, but not
the obligation, to clean up the working area and back-charge the costs to the responsible
organization in accordance with the contract.
14.5.1. Waste classification, collection, storage, transportation, disposal
Wastes shall be collected and classified, at least, as: Hazardous, Non-hazardous/ Inert
and Municipal wastes:
 Municipal / Urban Waste (Food residual, office waste etc. that should be kept
sealed and transported to disposal frequently)
 Non-hazardous / Inert Waste of special managing (material resulting from
excavation – to verify, depending on the area - concrete scraps from demolition,
glass, timber cuts, metal scraps, etc.)
 Hazardous Waste (hazardous chemicals, batteries, exhausted oils, lubricants,
contaminated soil, etc.) shall be disposed in specific areas
Wastes shall be first classified according with Mexican’s Law before to be either
disposed or recycled. All involved parties shall utilize licensed waste transporters and
disposal or treatment facilities authorized by Mexican law. JV Site Management shall
supervise the correct application of this process at site.
A map of the authorized areas to deposit different kind of wastes and scraps at Site shall
be issued as soon as possible by Site HSE Manager. Construction debris, scraps, waste
and demolition materials shall be collected and moved on a regular basis to designated
areas provided by themselves with suitable containers.
Temporary storage of wastes shall be within dedicated storage areas, selected,

designated and managed to prevent the accumulation that could create health and/or
fire hazards for workers or members of the public, or a nuisance to nearby community.
All wastes shall be collected and stored in suitable containers to ensure that ground
contamination is avoided. Containers shall be labelled, stored, segregated based on
compatibility and routinely inspected for damage or leaks.
14.5.1.1. General Solid Waste Management and Recycling On Site
Municipal waste, non-hazardous industrial waste and inert waste shall be segregated at
all times; open burning of waste is prohibited.

An adequate number of containers shall be strategically placed throughout the

construction areas and temporary facilities by each part involved in job site activities.
Light non-hazardous solid waste, paper, polybags or light packing material which may be
moved or fly easily by wind, shall be not disposed of untidily in skips or in uncovered
bins.
14.5.1.2. Inert surplus material re-use
Re-use of excavated materials shall be maximized, for example backfilling where

practicable.
Any surplus or contaminated material shall be communicated to JV Site Management
and shall be dumped as authorised by local law and regulations.
14.5.2. Hazardous Materials and Hazardous Waste
Hazardous materials have the characteristics of

Explosive, flammable, spontaneously combustible, dangerous when wet,
oxidizing, organic peroxides, poisonous (acute), infectious substances,
corrosives, liberation of toxic gases in contact with air or water, toxic (delayed or
chronic), Eco toxic, secondary hazard and radioactive.
Hazardous material shall be inventoried and controlled.
For Site hazardous wastes, involved parties shall refer to local instruction for different
disposal methods. Storage areas shall be carefully selected. Hazardous waste shall be
managed and stored in compliance with the provisions of the next paragraph.
Batteries, packages, abrasives, oils, etc. shall be returned for recycling to specialized
company or vendors; if not possible, they shall be disposed as hazardous waste. MSDS
shall be consulted whenever possible.
14.5.2.1. Ground Contamination Prevention and Hazardous Material Management
Hazardous material introduction at site shall be previously communicated to JV Site

Management. Hazardous materials also include hazardous wastes.
Hazardous material containers shall be designed and constructed of suitable materials to

contain it without leakage/spillage.
The containers shall be bonded and placed on substantial pads; the area shall have a
containment system to avoid the spread of spilling/leaking materials.
The storage areas shall be fenced off to prevent entry of unauthorized persons or
vehicles. Incompatible materials shall not be placed in common containment areas or in
the same containers.
Hazardous materials storage area shall not be connected to a sewer or drainage system.
All the involved parties shall ensure that washing down of equipment does not cause soil
contamination. A typical action to be managed is the washing of concrete pouring
machine, which shall be managed properly in a dedicated area.

As well for abrasive blasting, hydro testing, flushing, chemical cleaning, etc. measures
shall be established to avoid ground and underground disturbance.
14.6. Spill Prevention & Response
14.6.1. Spill Prevention
The following procedures shall be carried out to reduce the possibility of a spill that may
be harmful to the environment or to the health and safety of the staff and made part of a
plan:
 The stationary diesel storage and dispensing area will have a double liner under the
tank containment area around it and shall be large enough to contain the 110% of
the volume of the content(s) of the biggest tank(s).
 A checklist and record of inspection for tanks, secondary containment, and

containment materials (i.e., pads, boom, silt curtain) will be kept as a part of the
monthly inspection.
 One or more covered drains must be installed on collection basins used as a

secondary containment. Drains must be provided with means to eventually empty
the containment into an authorized tank for transport to disposal or authorized
drainage system.
 All equipment shall be inspected for leaks and repaired as required prior to entering
on the Project site. Periodic inspections will be scheduled for equipment once on
site.
 The use of underground fuel or chemical tanks is forbidden.
 The use of stationary fuel tanks on the Project site shall be minimized and only then
with JV Site Management / OWNER Plant’s permission. All station stationary fuel
tanks shall be equipped with secondary containment.
 Tidy tanks, gasoline cans and solvents shall be stored in leak proof secondary
containment.
 Absorbent pads or other methods of containment shall be used as required for oil
changes and servicing to prevent spills.
 JV Site Management and Subcontractors shall maintain an appropriate stocked

emergency spill kit on site.
14.6.2. Spill Response
In case of chemical product, the following actions will be taken (note: the magnitude of
the discharge/spill will determine the extent of the actions that have to be taken):
 Any spillage occurring from vehicles will be collected for appropriate off-site
disposal.

 Only attempt containment and clean-up operations of accidentally discharged

petroleum products/wastes when it can be performed safely.
 If spilled material is flammable, eliminate sources of ignition near spill area.
 When it can be performed safely, stop source of spill and contain spilled material
using absorbent pads/booms or a berm within as small of an area as possible. The
spill should not be washed away.
 Barricade off or isolate the spill area with "Red Danger Do Not Enter" tape.
 Screen/cover stockpiles of contaminated matter to prevent dispersion of it; the

stockpile area shall be lined to protect groundwater.
 Contaminated soils and clean-up materials from such spills must be handled
properly, stored in a suitable container that is then labelled and stored in the
appropriate location for subsequent final disposal.
 Focus on the Emergency Response Plan
Management steps:
 Notify the JV Site HSE Manager or Site Manager immediately.
 The JV Site HSE Manager/ Site Manager will coordinate to secure the area and
establish perimeter control at a safe distance from the spill.
 Spills will not be considered “closed” until an JV Site Management / OWNER Plant
representative approves the clean-up.
14.6.2.1. Spill Reporting
Any spill shall be documented and reported.

Basic information shall include: date, time, location, type and quantity of spilled material,
description and cause of incident, action taken, name of person reporting the incident
and recommended/actions for ensuring the incident doesn’t reoccur.
It should be noted that if the incident had the potential to pollute the environment,
although has not yet done so, then this will still be recorded to allow potential serious
incident to be identified at an early stage and the appropriate corrective action
implemented.
14.6.2.2. Spill Response Training
 Staff shall be trained in the maintenance and use of spill response materials.
JV Site Management / Subcontractor is responsible for providing all materials,

equipment and services for providing the suitable response to a spill caused to the
activities. All spills related to the Project must be reported immediately to JV Site
Management.

External reporting to the Mexican Environment regulatory body will be only conducted by
the JV Site Management / OWNER Plant in the event of a spill.
External reportable spills must be assessed after clean up by a third party consultant to
determine closure. This will be done at cost of the organization responsible for the spill.
14.7. Noise
Traffic flow of the Site vehicles inside and/or out of the Site shall be limited if noise will
reach significant level. Other measures to minimize the noise could be: selection of low
noise emissions machinery; effective maintenance of machinery; use of acoustic
dampening / attenuation; activities scheduling, etc.
Operation that could create high noise, (example: abrasive blasting, etc.), but mainly
during Pre-Commissioning / Commissioning, shall be communicated in advance and
planned in such manner, day and hours, to minimize disturb in and off the site.
There are some short lengths activities, peculiar of such phase that can increase the
existing noise level in the surrounding area, as: Air and Steam blowing / Rupture Disk /
PSV opening / Flaring / boil out boilers, etc. To minimize the noise level, following
measures shall be considered if applicable:
 Temporary silencers shall fit during steam blowing activities, if necessary to

achieve specified noise limits; Noisy activities to be conducted at specific hours to
minimize affected workers and / or public disturbance; Proper instruction to be
given to the workers; if an unacceptable and not predictable noisy emission
occurs, it shall be eliminated or at least minimised as soon as possible.
14.8. Restricted Materials and Radiation Management
At Site are forbidden use of: any asbestos products; any chlorofluorocarbons (CFC) and
halon or other substances defined in the Montreal Protocol (and subsequent
amendments) which could deplete stratospheric ozone.
JV Site Management shall be informed in advance and authorize the introduction of

radioactive materials at Site. Such authorization shall be given only after review of the
resources (mainly competent/ specialised persons/ equipment) and safe work practices
for storage and use.
No disposal of radioactive material is foreseen: all radioactive material shall be removed

from Site by the Company that brought them in, according to the applicable Laws.
14.9. Landscape and surrounding areas
The impact relevant to the Project scope of work is negligible.
14.10. Site Consumption - Minimization of the natural resources

All the site organization and personnel shall minimise the use of fuels, water and energy,
as well as the production of waste.
The data regarding the site consumption of energy/fuel/water/lubricants/soil and other

consumable will be recorded by JV Site Management in the HSE Indicators of
performance procedure EXXI-010-00-00-HS-PRO-0108 .
14.11. Environmental Data Collection
A basic environmental data collection according with the Attachment 32 shall be

maintained and transmitted on monthly basis to JV Site HSE Manager.
As well Site HSE Manager shall insert the site environmental data collection as part of
the Monthly HSE Report
15. EMERGENCY
This chapter reports the main guidelines; the document Site Emergency Plan shall
develop all the details.
Each Site Organization is responsible for the health and safety of its employees and for
the protection of the environment, and nothing related to site emergency management
shall relieve them from their own responsibility.
15.1. Possible emergency events
The construction of the project will take place inside of the limits of the premise that still
is not in operation.
Every emergency in the nearby Units the phase of construction has the potential to
involve the Project premises.
Also, emergencies arising inside the Project premises can easily involve the nearby
Units.
So, it is of paramount importance to coordinate the emergency response activity of the

Project with the Plant organization (as expressed within the Emergency Response
Plan EXXI-010-00-00-HS-PLN-0004).
The emergency events to be considered during the phase of Construction and PC&C
are:
From the Plant/nearby Units (emergencies with importing potential):

Fire / explosion, Gas and vapours release, Spill of hydrocarbon, Chemicals and other
dangerous substance release,
From the Project execution site (emergencies with exporting potential):

Injury, Environmental incident, Spill of hydrocarbon, Chemicals and other dangerous
substance release, Collapse of structure, rescue at height, rescue in confined space,
etc., Vehicle incident, Fire / explosion, Gas and vapours release or other large industrial
less probable incident that could also affect the site, sabotage, attack, etc.

During commissioning phase the following events shall be also considered: Fire /
explosion, Gas and vapours release, Spill of hydrocarbon, Chemicals and other
dangerous substance release,
From the Environment

Extreme weather conditions (hurricanes)
15.2. Information and training
All execution personnel and visitors entering the site shall receive basic information
regarding the Site Emergency management.
Personnel that have specific roles in the Site Emergency Management shall receive
additional specific training on their role. Continuous information, refresh training and drill
program regarding the Emergency Management shall be developed and implemented
on site by the JV Site HSE Manager.
Periodic drills will be conducted in coordination with the OWNER Plant for Emergency in
project construction areas and in the Plant.
At least one complete site evacuation emergency drill shall be undertaken prior the first
introduction of hazardous substances in the process.
The drills that must be addressed for fulfilment of the Mexican legislation will be
established and the periodicity include emergency drill and drills for contingencies (this
can be desktop when conditions do not permit)
The objective of the drills is to check the effectiveness of the plan. It must be analysed
after the execution and the emergency or contingency plan must be revised.
For activities carried out by (third) service providers these must have its response plan
emergency and contingency and shall be evaluated periodically.
15.3. Project Emergency Plan
15.3.1. Site Emergency Resources
OWNER Plant shall supply both general management and the services of the Plant
Emergency Response Team (Fire Brigade, High Angle Rescue, medical help)
JV Site Management and Subcontractors shall organize their own team so to be ready to
manage local “small” emergencies and to cooperate with the Plant Emergency
Response Team
All the emergency resources are to be defined and available as soon as the site activity
starts.
15.3.2. Site Emergency Organization and Emergency Team
The whole Site organization shall adopt a specific structure in case of emergency. The
typical structure to be adopted is described in this section.

The following is the JV Site Emergency Team and its functions:
 Site Manager (Emergency Team Leader)

 Construction Manager (Alternate Emergency Team Leader – Duty Engineer)
 Site HSE Manager (Site survey and Fire Marshall)
 Office Manager/Security Officer (Personnel & Media Response)
 Other designated at the moment by the Team Leader (Log report)
In collaboration to and with::
 Field Representative (Coordination of field means/resources)

 Supervisors/HSE Staff (Field control and collaboration)
 Medical Services & Fire fighting team (if needed)
 Rescue team for construction emergency scenarios: i.e. rescue at height, in
confined space, etc.
Since his arrival at site the PC&C Manager shall be part of the Site Emergency Team.
From the beginning of Commissioning activities the PC&C Manager will act as
Emergency Team Leader in case of Site Manager absence or whenever delegated by
the Site Manager to cover this position.
Further to the above, OWNER Plant Emergency Response leader shall be always timely
informed on the emergency developments.
JV Site Management shall be ready with means and resources to collaborate at site to
correct construction emergency situation, when requested and when practicable. The
gatehouse shall maintain clear the gate(s) where emergency vehicles and equipment’s
could pass during the emergency..
The implementation of a system of mutual assistance among the companies in the

region that includes at least the knowledge of hazards of the neighbour and related
response shall be implemented.
15.3.3. Communication systems
Communication system, radio and telephone, shall be clear, adequate and available in
case of emergency. The emergency numbers shall be known and widely spread..
All the emergency basic information shall be easily available at Site, for example by
booklets, leaflets, posters, prepared, distributed and/or posted appropriately in Site and
its premises. See example in Attachment 33.
All parties involved in the Emergency response like Protección Civil, STPS, IMSS,
Centros de Salud, Cruz Roja, Federal Police, etc. shall be duly informed about the
Emergency procedure and always reachable through the established means of
communication. All contact information and emergency signals shall be communicated to
the entire Site.

Use of personal mobile phones is allowed only in the offices / administrative areas. It is
prohibited in the construction areas during working activity and when driving a vehicle.
15.3.4. Site Alarms
A general site alarm will be given by a siren and/or local area air horns.
Prior starting of commissioning activities the emergency alarm and communication

system shall be revised to ensure it is adequate for the new emergency scenarios and
site organization and it is consistent with the fire & gas detection and alarm systems
currently in service.
The preferred means of reporting emergencies, such as manual pull box alarms, public
address systems, radio or telephones shall be identified and communicated to the entire
workforce.
15.3.5. Personnel general behaviour and first emergency treatment
The Emergency Procedure can be activated by the alarm due to any situation that is not
ordinary and can create real or possible danger or in case of real emergency on going
(i.e. fire, injury, incident, etc.).
In all these cases anyone shall:
 GIVE THE ALARM and report the danger immediately to the appropriate
Supervisor or to JV Site Management personnel or to OWNER-Plant personnel or
dialling the Emergency Number xxx:
SAY: WHO YOU ARE – WHERE YOU ARE – WHAT’S GOING ON –
IF THERE IS ANY PERSON INVOLVED IN THE INCIDENT
 Intervene immediately, within proper limits and if it is safe to do so, with local
equipment (i.e. extinguisher, etc.)
 Go to help people or start to treat the emergency situation only if in safe condition,
protected and trained to do that, otherwise wait for the other resources that are
coming
 Do not move injured personnel unless to leave them would create more problem
 Stop safely the work, make work area safe and switch off all equipment, all the
vehicles in use and put out all the free flames
 Maintain all the roads open and clear in order not to inhibit the access of the fire
brigades and other means of help
 Avoid the use of vehicles in presence of hydrocarbon emission
 Vacate the area. Do not run but move quickly. Stay at the assembly point and wait
for further instructions
 In general fire-fighting equipment shall be used only by authorized and/or trained
personnel of the site
 In the event of a major incident, i.e. gas leak or fire, check the direction of the wind.
Then move in the opposite direction of the wind to the nearest assembly point

 Use radio and telephone devices only in relation to the report of the incident and in
a concise way
 Re-enter or remain in the usual working places, remaining in availability, with the
exception of a different role being assigned
 Start to prepare the evacuation of the buildings near to where the incident
happened
In case a limited number of personnel are required to remain to operate critical plant
operations before their evacuation becomes absolutely necessary, they shall be
precisely and univocally identified. Detail procedures to be taken in case of emergency
by those employees shall be developed.
15.4. Emergency Evacuation
Some incidents/events may require the evacuation that should be partial or total of a
work area or the project Site.
Assembly points are established at Site. A count of the attendants shall be given by
each supervisor and if someone is missed the Emergency Team Leader shall be
informed immediately
Prior starting of Commissioning activities the emergency evacuation exit, routes and
assembly points shall be reviewed to be consistent with new emergency scenarios.
In case of possible toxic/flammable gas releases aspects such as wind direction, location
of most hazardous sources of leak and main source of ignition shall be considered.
15.5. After the emergency / Notifications and Investigations
Emergencies situations shall be immediately notified to JV Site Management/ OWNER

Plant Emergency Response Leader and investigated. After emergency make sure that
safety equipment/material utilized are returned ready to use. A post-emergency analysis
and report shall be done according to next paragraph.

16. INCIDENT TREATMENT, REPORTING AND ANALYSIS
All unwanted events (incident – injuries, equipment/vehicle/property/environmental

damages, etc., incident – near misses) shall be reported to supervision and Site
management immediately upon detection for due investigation.
16.1. Incident treatment.
In the event of an incident resulting in injury or damage to property or facilities, the scene
shall be barricaded and preserved and nothing moved or removed until such time as the
investigation team has completed its review of the area(s).
Upon the occurrence of an incident the person witnessing the event shall:
 In case of injury, protect the victim and provide immediately for specialized help
(phone the First Aid facility)
 Remove any immediate source of hazard, to avoid immediate recurrence of the
event
 Recommend other workers to free the access to the spot and signal the position to
the source of help (ambulance with nurse)
 Inform his foreman of the event and protect the conditions of the incident spot
Personnel shall refrain from rendering aid except for those deemed necessary to avoid
the worsening of the injured person’s condition..
No one should attempt to move injured individual unless the individual is in imminent
danger.
ALL injured personnel shall be accompanied by either their direct supervisor or his
delegate to the Project First-aid Clinic or outside Medical Facilities (Hospitals).
16.2. Incident Initial Reporting
Any unwanted event shall be immediately reported verbally to JV Site management.
The report in writing for incident, near miss or injury shall be sent to JV Site Management
within 24 hours;
16.3. Incident Analysis, Final Reporting and Follow-up
Any incident/accident that needs to be statistically classified, or that is considered

serious enough to be investigated, upon JV Site Management request, shall be analysed
by an Investigation Team comprised of the following and/or other persons appointed by
the Site Manager:
 Coordinator: JV Site HSE Manager –HSE Representatives

 Chairman: Responsible/Line Supervision
 Member(s): Construction Manager/Supervisors and other personnel familiar with
practices involved and who can contribute to its analysis and make

recommendations for action to prevent recurrence. May include JV Site

Management Representatives.
The incident investigation shall identify: the incident scenarios (where, when, who, why,
etc.); the immediate and root causes of the incident and, related to the root cause, the
actions to be applied to prevent incident recurrences.
In the event of major injuries and fatalities a hearing with the witnesses and direct
involved personnel shall be held to determine the cause and subsequent actions.
Accident reports shall be registered and distributed to project management and as per
Mexican law.
Results of investigation and recommendations for preventive/corrective actions shall be

submitted in writing to JV Site Manager within 5 working days of the incident.
After completion of the incident report a Lesson Learned bulletin shall be distributed on
site. See Attachment 35.
The JV Site HSE Manager will be in charge of tracking the recommendations to closure
that were made during the investigation. Line management of all organizations will be
responsible for the implementation of the recommendations and corrective actions.
JV Site HSE Manager shall make summary reports of all incidents maintaining a short
database: classification; date; company involved; brief description; risk level (high,
medium, low); main causes; main actions taken including communication done; status as
per draft in Attachment 36.
16.4. Incident classification
Site organizations shall use OWNER/ JV Site Management terms and/or

accident/incident definitions as per international standard. Data and information shall be
according to OWNER/ JV Site Management procedure.
The analysis and investigation of Incidents, near miss and majors will be carried out at
Site through the procedure EXXI-010-00-00-HS-PRO-0103 Report of investigation of
Incidents and Near Miss in the following cases:
 Incidents that for their magnitude are listed in the OSHA standard (Medical
Treatment, Restricted Work, Lost Workday and Fatality)
 Major incidents related to leaks, explosions, hazardous or non-hazardous spills

and fires (even if they have not generated injuries to the workers).
 Near miss, those events where an injury could occur to the workers or the
facilities.
The corrective action plan established for the prevention and recurrence of the incidents
will be disseminated to the project team through the safety talks that will take place on a
daily basis before the beginning of the activity and through the safety committee
meetings.

16.5. Incident Communication
Major incident and any LTI shall be immediately communicated by JV Site Management
to OWNER HSE Corporate. Final report shall be forwarded also to OWNER HSE
Corporate.
Minor events happened and analysed at Site shall be highlighted in monthly HSE reports
by the Site HSE Manager, for information and HSE statistical data.
JV Site HSE Manager will take the measures necessary to guarantee the sharing at Site
and at the OWNER/JV Site Management HSE Corporate organizations the lessons
learned from incidents that might occur, reporting and sharing briefly: Classification and
event summary; Event treatment; Immediate and root causes; Lessons learned / Actions
done.
Lessons learned leaflet are usually shown at Site notice board and shall be discussed
with the workforce during Tool Box meeting and/or Safety Talks.
16.6. First Aid/Near misses Analysis
First aid / Near miss analysis shall be done by the JV Site HSE Manager at least
monthly. Trends of homogeneous first aid cases (eyes problems, legs problems, etc.),
shall be communicated to Site management, for example during the Steering committee,
in order to resolve the basic causes. Highlights and data shall be reported in the HO
periodic HSE Reports too.

17. SECURITY
OWNER Plant/JV Site Management fix the general security rules to access to, and
egress from the site and the preventive measure to avoid unwanted events.
It is forbidden to go to areas not part of the scope of work.
Photos and videos are prohibited and, in case, have to be authorised by the OWNER
Plant through JV Site Management.
JV Site Management shall provide additional security as necessary to protect its own
facilities and workforce within the Project’s areas.
A procedure shall be prepared for the control of access and exit to the Site and will be
implemented by a company of Security specialists and supervised by the JV Site HSE
manager during the Construction Pre- Commissioning and Commissioning phase.
The EPC Contractor will provide security training to all employees. All employees will be
trained in, and will be familiar with, the contractor's security procedures. At a minimum,
training will cover overall security objectives, individual employee security
responsibilities, specific security procedures; and the organization's security structure.
Management will be responsible for establishing and communicating the security goals.
Construction supervisors will be responsible for being knowledgeable of the security

issues and concerns of their area, and employees. They will also be responsible for
providing information on system operations including daily work processes, activities,
and identifying potential security vulnerabilities. The construction supervisors select,
prioritize, develop, and implement strategies and procedures to meet established
security goals, measure and monitor the effectiveness of the security strategies and
procedures and to review and when necessary, adjust the strategies and procedures. If
deficiencies or other vulnerabilities are discovered in the security process, appropriate
corrective action or adjustments will be made.
The EPC Contractor will provide adequate security measures to ensure the safety of
employees, equipment, facilities and the general public, according to the Security
Management Plan (Protocolo de Gestion de Fuerzas de Seguridad y Derechos
Humanos – EXXI-010-00-00-SR-PRO-013) The EPC Contractor will provide a work
environment that is reasonably free of hazards and threats of violence which may cause
damage to property or harm to people. Employees will be responsible for adhering and
conforming to all security-related work activities and procedures.
All employees have a responsibility to themselves and to the Company, to observe and
report any suspicious or unusual activity that threatens safety or security. Employees
will be trained to use common sense and good judgment when assessing threat
potential of any suspicious activity. Employees will report any observed suspicious
activity to their immediate supervisor. A complete listing of emergency telephone
numbers will be provided to all construction supervisors. The list will include the numbers
for local police.
The EPC Contractor will maintain frequent communications with local communities on
safety and security activities and will record and investigate any human rights allegations
received.

All allegations of human rights abuses by private security shall be recorded and
investigated. Both the OWNER and the EPC Contractor will use the complaints lodged in
the grievance mechanism by the local community to assist in tracking, assessing, and
managing the performance of security personnel.
The EPC Contractor will establish a partnership and professional working relationship
with local law enforcement officials and other public safety and security agencies. Local
law enforcement officials and other public safety and security agencies will be
periodically invited on-site to discuss and evaluate potential security risks, vulnerabilities,
and to assist in the development or enhancement of the security program.
All suspicious activities or apparent criminal acts affecting the safety or security of the
EPC Contractor or the OWNER’s interests will be reported immediately to the proper law
enforcement agencies and appropriate company official. In addition, a detailed written
report will be made of any security-related incident.
17.1. Site Security Organization
a) Plant Security
The security of the OWNER Plant area is assured by an external fence with guarded
gates manned by OWNER Plant security personnel.
All personnel/vehicle/material coming to Project site shall enter only through gate(s)
controlled by OWNER-Plant and only after obtaining OWNER-Plant authorization.
OWNER-Plant authorization can be assured only though timely information through JV

Site Management.
b) JV Site Management Project Security
All Project areas are fenced and guarded; JV Site Management / Subcontractor shall
provide its own fences according to its needs.
All permanent personnel/vehicle coming to Project site shall obtain a permanent ID

“badge”/ pass issued by OWNER-Plant through JV Site Management.
Personnel ID badge readers gates shall be installed at the fenced execution areas to
allow the access.
All perimeter fences will be subject to a schedule of regular inspection of the fence and
associated gate(s). Broken fences, walls, and other barriers will be repaired immediately.
Construction Supervisors will be responsible for implementing and enforcing the regular
schedule of inspection which includes, but is not limited to the following:
 A daily routine of securing all gates and related locks.

 A periodic perimeter fencing inspection.
 Monitoring and sealing entrances which go under the perimeter such as culverts
Any unusual or suspicious damage to fences or gates will be reported to the construction
supervisor immediately. Fence lines will be kept free of debris or other objects (such as
trees, pallets, or skids) that could be used to allow entry over the fence. Storage of any

ladders or long objects will be kept away from fencing/barrier to prevent scaling a fence
or entering a building.
Construction areas, equipment storage area and parking lots will be well lighted and
exterior security lighting will be directed downward and away from buildings to prevent
glare and to ensure the grounds are visible. Exterior security lighting will be inspected at
a rate of not less than once per month.
17.2. Personnel admittance and control
Site employees shall be issued with ID badges that must be displayed at all times and
hold together with the identity documents. The card allows the employee to enter the site
under control during the normal working time.
Personnel ID badge readers at gates shall be installed at the fenced work areas to allow
access.
Personnel/visitors shall enter and leave the job-sites only through the controlled gate(s)
and route(s) provided with sufficient number of checks controls.
The badge status register shall be maintained by administration personnel of any Site
Organization and status changes must be submitted to JV Site Management /Security
whenever a new employee begins work or is terminated..
Any Organization is responsible to communicate in writing to the CONTRACTOR, the

intention to cancel the ID Pass of a worker, and within 24 hours after the last working
day of the worker, the badge shall be given back to the JV Site Management who shall
provide to transfer it to OWNER-Plant.
Visits shall be pre-arranged and authorized, Security staff being formally advised in time,
better days before: person’s name, passport number, visa, job title, person to visit, etc...
All personnel and visitors must have site safety orientation training prior to being allowed
access in field. Each organization, presenting the list of those that have received the
training, will obtain a mandatory Project Sticker (See Attachment 23).
17.2.1. Visitors
Visitors shall be issued with a Visitor Gate Pass and must be met and accompanied
during their visit by a person holder of a valid ID site card. Visitors must be collected
from the gatehouse and returned there at the conclusion of their visit by their deputy.
JV Site Management must inform the superintendents of any visitors at least 24 hours
before. All visitors are to attend site HSE Visitors Orientation Training prior to being
collected by their host.
17.2.2. Couriers and delivery vehicles
The procedures allow couriers and delivery vehicles to enter the site without orientation
or a host under specified conditions. They are required to complete identification details
at the Gatehouse and to respect the basic HSE rules (PPE, speed limit, authorized
route, etc.).

17.3. General Gate Control
Security personnel shall ensure that dangerous material and individuals don't get on to
the site and that project material and equipment does not leave the site without
authorization.
Security personnel could control/inspect every person and vehicle trying to pass in or out
of the site gate. The control/inspection level depends also on local general conditions.
17.4. Material control
Material entering/leaving the job-Site shall be accompanied with Material Transport

Documentation and Pass. Materials will be checked also by the Security. Unauthorized
material, equipment or documentation shall be referred immediately to JV Site
Management.
Deliveries, material and equipment incoming for JV Site Management shall be

authorized by JV Site Management and directed to warehouse or storage areas.
Collection/removal of material from those areas shall be subjected to approval by a
Material Pass signed by the “Involved Line Manager”.
17.5. Vehicle control
Vehicle passes shall be issued only for those necessary to work: JV Site Management
vehicles; working vehicles and Service cars. Only guarded gate and indicated route shall
be used driving/making deliveries into/out Site. Any vehicle entering the industrial
premises shall have a tag clearly indicating the Company name.
Vehicle shall be inspected on their initial entry and shall be re-inspected on regular
basis: illegal, uninsured or unsafe vehicles will not be allowed at Site. All drivers must be
in possession of the correct type of driving license for the vehicle being driven according
with the local law (See Attachment 24).
17.6. Security Personnel
All Security Personnel, regardless of whether directly employed by the EPC Contractor
or hired through specialized private security firms, will be required to comply with the
Security Management Plan (Protocolo de Gestion de Fuerzas de Seguridad y Derechos
Humanos – EXXI-010-00-00-SR-PRO-013) and the following guidelines:
 Observe the project’s Code of Conduct applicable to EPC Contractor employees.

 Act respectfully with respect to both local community members and employees;
 Exercise restraint and caution consistent with the UN Code of Conduct for Law
Enforcement Officials.
 Private security shall not be armed and will rely on the national police or other
specialized public security in cases that require enforcement capabilities that
surpass its capacity.
 Private security shall only act preventively and shall not engage in activities
under the responsibility of national police or other public enforcement agencies.

 Private security shall have written procedures regarding appropriate conduct and
rules of engagement.
 Private security shall treat as confidential all information obtained as a result of its
position as security provider, except when legally required to disclose it.
17.7. Security Contracts
Specialized security companies retained to provide security services for the project, will
be required to comply with the Security Management Plan (Protocolo de Gestion de
Fuerzas de Seguridad y Derechos Humanos – EXXI-010-00-00-SR-PRO-013) and the
following guidelines:
 All norms and procedures applicable to the contract shall be guided by the
principles of proportionality, applicable law, good international practices rules of
conduct, training and equipping of personnel;
 The security company shall commit to make reasonable inquiries to check that
those employed to provide security are not implicated in past abuses, crimes,
irregular behavior, etc. and shall be required to demonstrate that no individuals
implicated in past misconduct and/or human rights abuses are employed.
 Training of the security workforce on the use of force and appropriate conduct
toward workers and the local community will be an explicit contractual
requirement;
 Use of force will not be allowed unless for preventive and defensive purposes and
always in proportion to the nature and extent of the threat.
The EPC Contractor will consult and monitor private security providers to ensure
compliance with the principles outlined herein.

18.SOCIAL
 Focus on define the Social Responsibility system scope

 Establish the programs to improve the stakeholder life quality and bases to establish
community sustainable projects.
 Describe the relation between HSE and Social responsibilities.
 Communicate the social policy
Reference: EXXI-010-00-00-QA-PLN-0001 “Social Responsibility Plan” and EXXI-010-00-00-HS-

PLN-0001 HSSE Management Framework

19. TRANSPORT & TRAFFIC
Each organization is responsible for transportation of its personnel and material. Drivers
shall be in possessed of regular locally recognized licence. Awareness shall be foreseen
on the importance of Safe Driving. Traffic rules to avoid unwanted events shall be
defined. Mopeds (“scooters”)/ bikes are not permitted.
Vehicles entering the Site shall have valid documentation (circulation, inspection and
assurance) and shall be in safe conditions to operate; all vehicles and fuel driven
construction equipment shall be equipped with a fire extinguisher. Construction
equipment shall have beeper for reversing maneuver. Service cars should be provided
with car first aid kit and car extinguisher.
All Project vehicles, both JV Site Management as well as Subcontractors, shall display
conspicuously, on both sides of the vehicle/machinery, the Company’s logo.
19.1. Site Roads and Traffic Rules
Temporary roads and parking area with necessary barricades, bridges, signs, etc. shall
be provided at site. Traffic map shall be developed as soon as possible and distributed
Road sign shall be provided at all intersections of the different roads. Flagman should be
appointed in case of intensive traffic, located at different intersection and educated to do
it.
All drivers are to obey the posted speed limits, driving and parking rules. Roads shall not
be used as storage and/or work areas.
Total interruption of a road is allowed only under specific permit by JV Site Management
/ OWNER Plant. Road closure shall be planned in advance depending on its duration
and impact on site activities.
Any road shall not be made impassable or hazardous without JV Site Management /
OWNER Plant's prior approval that will be based on availability of alternative roads for
emergency vehicles.
JV Site Management and Subcontractors shall maintain the roads within their work area
and, in addition, shall repair any damage to roads resulting from their activities that are
outside of their work area. Roads that are cut shall be repaired and guaranteed for one
year by the responsible party.
19.1.1. General Traffic Rules
Site circulation is subject to rules of National Traffic legislation and more restrictive site
rules.
The drivers are prohibited from using hand-held cell phones while operating the vehicle.
Reversing manoeuvre shall be avoided if possible; in any case the appropriate beeper
shall be kept in operation during such phase. Flagman shall be used during reversing of
trucks and construction vehicles/equipment.
Wearing of safety belts is mandatory while travelling.

Use of trucks as transportation for personnel is not permitted, unless adequate

provisions are made and the vehicle is adapted for that purpose. In any case, the
number of personnel shall not cause overcrowding. Vehicles may not block or hinder
roads. -
Riding on crane, winch trucks, tractors, etc. is permitted only when adequate safety
provisions, such as seats, platforms, rails, etc., are provided for passengers.
19.1.2. Speed Limits
Maximum speed on the public road is 60 km/h and in special cases lower as indicated by
specific signs. Maximum speed limit on the Site internal Main Road is 30 km/h.
Maximum speed limit on the Construction work-site roads is 10 Km/h. The maximum
speed for cranes is generally 10 Km/hr.
However all drivers have to take in consideration local situation, additional road signs,
etc. as to guarantee maximum safety for pedestrian and other vehicles. Special caution
is required at the periods of crew changing.
19.1.3. Parking rules
Parking for personnel will be available, if necessary, and possible at designated

locations. The personnel shall use only approved parking location. No vehicle shall be
parked elsewhere, except authorized vehicles being used directly in site activities.
Heavy equipment (hoisting cranes, big trucks, bulldozers, etc.) must be parked, at the
end of the day, at own maintenance workshop, unless will be pointed out another
parking place.
On site, keys shall be left in the ignition of parked cars and it is forbidden to park:
 in front of water tanks, water guns, fire prevention equipment or other safety
equipment (like emergency and eye showers, respiration devices) - within a radius
of 10 m from any fire hydrant, extinguisher, hose reel or other emergency
equipment - in traffic roads, in front of stair cases, exits, entrance roads to safety
equipment; under power lines or pipe racks or in designated "No Parking" areas;.
All vehicles shall be parked on the reverse, so to facilitate a direct emergency drive.
19.1.4. Restricted areas
No vehicles will be allowed in work areas that are adjacent to or in live plant areas
without a specific permit from JV Site Management / OWNER Plant. Smoking inside
vehicle is not permitted.
19.2. Construction vehicle and hoisting equipment
All equipment brought into site must be in safe operating condition. Construction
vehicles/equipment shall be equipped with beeper for backward operation and driving.
Running motorized equipment (trucks, dozers, cranes, etc.), shall not be left unattended.

Hoisting cranes and other hoisting equipment are to be in possession of a valid

inspection certificate and report of operation, both to be handed over before entering.
Construction equipment operators shall be competent for the equipment operation and
provided with certification issued by a third party body recognized by Mexican
Government and by the Client.
An “Equipment and Operators Documents and Certificates Matrix”, indicating the

mandatory certifications and documents needed for each kind of construction equipment
and its correspondent operator shall be issued for the Project.
All Equipment and operators shall mandatorily be in possess of the certificates and
documents described by the “Equipment and Operators Documents and Certificates
Matrix” for entering the Site.
The equipment’s that will be find at Site not provided with said documents will be
immediately stopped and sent out the Site.
Each construction vehicle operator shall inspect his equipment on a daily basis before
starting the operation.
For cranes, winch trucks and similar equipment having booms or extended loads in
excess of 10 meters in front or to the rear of the equipment, a "boom walker" shall be
provided in addition to the crane operator to assist in clearing traffic and obstructions.
The hoisting crane driver will lower or tie down the boom of the crane at a convenient
and safe place, after finishing the works. In case this is impossible, the boom may
remain in the upright position, only after JV Site Management / OWNER Plant approval.
19.3. Equipment and material transportation
Transport of equipment/materials should be undertaken considering the following points:
 Utilize vehicles designed for the purpose: select the most appropriate vehicle and
trailer for the task to assist in reducing the number of trips
 Drivers should be briefed on the special provisions applicable to the load and their
understanding of those provisions checked before movement
 Segregate equipment/materials from the vehicle occupants and further segregate
potentially reactive chemicals/materials that cannot be brought into contact by
accident
 Do not overload vehicles. Positioning heavy or dense loads so as not to overload
or damage any part of the vehicle or to affect its stability during journeys
 Fix material and equipment before movement, utilizing pallets, chains, ropes, nets,
etc. All vehicle shall have adequate locking/security at the frame, particularly to
transport hazardous/heavy material. Loads shall not be suspended from a cable
allowing free swinging beyond the sides of a truck or crane. Material that
overhangs the truck sides or ends (generally more than 1 meter) shall be marked
according to local law. Equipment, i.e. welding machines, pumps, etc. shall not be
transported while running.
 Dragging or skidding material and objects along plant roads is prohibited
19.4. Special Transport

Prior to moving over-sized loads, a specific authorization of the proposed routing shall be
obtained; such authorization shall specify any precautions or restrictions to be observed.
It is prohibited to allow heavily loaded equipment of unusual length, width, or height or

with caterpillar chains to be moved over any plant road or bridge without specific JV Site
Management / OWNER Plant prior approval. No piece of equipment shall be driven over
any of JV Site Management / OWNER Plant's scale platforms unless CONTRACTOR/
OWNER Plant approval.
19.5. Fuelling on Site
The refuelling operations inside/nearby (10 mt radius) operating components/circuits shall

be limited only to the equipment/machinery not easily moveable (for instance: big cranes).
This operation can be done only after issuing and receiving a dedicated permit to work of
high risk.
Containers/portable pumps used for transporting or transferring hydrocarbons shall be

designed for the purpose. Truck transporting fuels shall be equipped with sufficient
number of fire extinguishers easily available.
Fuel tanks on motorized equipment shall not be filled while the engine is running or while
welding or other hot work is being done nearby. Welding or any spark or flame generation
must be stopped within a radius of 10 meters during any re-fuelling operations. Smoking
shall not be allowed. A man watching with extinguisher ready shall assist the fuelling
operations.
Fuel storage tanks, filler hoses and dispensing vehicles or containers must be properly
grounded and be equipped with fire extinguishers.
Storage tanks must be identified with the Company's name, content of liquid and no
smoking signs. Refuelling facilities are required with quick closing shut-off valve dead man
type on the dispensing end of fuel hoses and safety vents.
Refuelling facilities/means shall not be located in live plant area and not closer than 10
meters from inhabited buildings or other existing facilities. Fuelling is not allowed in live
plant area.
19.6. Pedestrian
Pedestrians on site shall: walk on the road board (better left); Follow dedicated
pedestrian walkways if indicated; Avoid staying unnecessarily on the roads; Act in a
defensive manner.
Must be defined and marked all pedestrian walkways
19.7. Traffic rules breach
In case of breach, a relative letter shall be sent to the person or the firm involved. In case
of relapse, the sign and/or the badge can be withdrawn for a variable period. In case of
act particularly serious breach, a prohibition of access to the site can be decided.
19.8. Roads housekeeping

The job site is to be maintained orderly during the execution of works. The access road
shall not be used for storage of materials and equipment. The access road shall not be
used for loading/unloading operations; these operations shall, also, be limited in any
other roads.
The access road shall not be obstructed by broken down vehicles or equipment.
It is the responsibility of JV Site Management / Subcontractor to remove all materials or
substances falling from its vehicles that make the road unsafe or inaccessible.
Used and dismantled equipment, materials, waste, etc. must be cleared up and stocked
daily in such a way that they will not hurt anybody nearby (sticking out of metal objects
on body height, nails sticking out of planks, obstacles to stumble over, slippery
products).
19.9. Vehicle accident and emergency
Any accident/incident shall be reported to JV Site Management. Bad trends of traffic

incident shall be treated with suitable corrective actions (retraining, traffic plan review,
etc.).
In general, in case of emergency,

 maintain the roads open and clear for the access of emergency vehicles
 avoid use of vehicles in presence of hydrocarbon emission and in case of
evacuation
 stop immediately the vehicle out of the road; if you leave the vehicle, shut-down
the engine and leave the car open with the key inserted

20. FIRE PREVENTION AND PROTECTION
The construction activity will be done inside a “grass roots” area. So, generally speaking,
the fire risks are limited.
Fire prevention and protection is mandatory to all the involved parties.
During the Site HSE planning, to JV Site Management and Subcontractors shall set up
specific fire hazard identification, clarifying methods, practices, means, organization,
training and inspection foreseen at site to manage fire hazard.
Open flame is always forbidden.
Refer to the applicable Document EXXI-010-00-00-HS-PLN-0004 Emergency Response

Plan
The study according to the NOM-002-STPS-2010 established in the applicable

regulations to determine the risk of high or ordinary fire in the project during the phase of
construction and PC & C should be performed.
20.1. Major Site Fire Risks
The major “typical” fire risks during the construction job activities at Site are, but not
limited to: bad housekeeping; uncontrolled storage; storage and use of flammable
material (warehouse, temporary storage place, flammable liquid, gas cylinder, wooden,
etc.); electrical system; offices and amount of paper, etc.; hot works or other controlled
or uncontrolled source of ignition (fire, sparks, hot parts, cigarettes, engine, electrical
devices, etc.); uncontrolled fire, not identified and not approached immediately, etc.
The major fire hazard during the PC&C phase is clearly represented by the introduction
of hydrocarbons and other flammable and explosive substances in the plant. Also the
presence of newly livened electrical systems and their testing create further possibility of
ignitions and fires.
20.2. Fire prevention and fire fighting
For fire prevention and fire fighting, the major practices to consider and set-up at site
are, but not limited to:
 All the activities performed near/inside operating Unit (areas agreed with OWNER
Plant/Unit) shall be done only after the issue and implementation of the
prescriptions reported on the Permit to Work;
 Dedicated persons (fire watchers) shall be utilized to verify the proper
management of this safety aspect on the spot;
 Lay out of temporary facilities shall consider emergency exit, alarms, smoke
detectors, protection and fire fighting equipment, particularly where important
documents/spare parts or high fire risk combustible material are stored (archive,
warehouse, etc.);
 Fire lanes inside of all buildings/workshops or congested areas shall be maintained
and kept clear for safe egress;

 Dangerous goods shall be stored in dedicated areas agreed with JV Site

management. Fuels, combustible/dangerous materials shall be managed as per
MSDS;
 Use only approved safety containers for handling and storage of flammable
liquids/fuels. Refuelling safe practices shall be followed at all time.
 Stored oxygen cylinders must be separated from gas cylinders by either a fire
retardant partition at least 2 meters high or by a minimum distance at least of 6
meters away. Flammable gas cylinders shall be equipped with flashback arrestors;
 Ignition source shall be minimised, for example by: smoking restriction, hot work
safe practices, fire arresting net/devices, electrical standard application, etc.
Burning of scrap materials is forbidden at Site;
 Workers performing hot works must be instructed on how to minimize fire risk
(clear area around or underneath from flammable materials, gas test if needed,
containment of sparks and control of other hot parts, use of fire blankest/screen,
availability/use of extinguisher, etc.). Combustibles materials might be present
nearby/underneath while the work is being performed shall be adequately
protected;
 Regular inspections on fire prevention and fire fighting system shall be made to
ensure safe standard. A clear access to all fire protection equipment shall be
maintained
 To prevent ignition hazards, electrical wiring and equipment shall be installed in
accordance with recognized international code for construction site
20.2.1. Cutting and welding
 Provided portable or permanently mounted extinguishers shall be available within

15 meters of a workforce involving welding, burning or the use of an open flame
 Each welder shall use welding blankets in order to contain weld splatter. Practical
welding screens are to be used to protect personnel from ultra-violet rays (flash
burns).
 Fire blankets to be used to retain sparks, slag or hot pieces of metal to prevent
contact with a flammable substance, electrical circuits, machinery, equipment or
people
 For elimination of possible fire in confined spaces, as a result of gas escaping
through leaking or improperly closed torch valves, the gas supply to the torch shall
be shut off.
Whenever the torch is not in use or if the torch can be left unattended for a
substantial time, the torch and hose shall be removed from the confined space.
Open ended fuel gas and oxygen hoses shall be immediately removed from
enclosed spaces when they are disconnected from the torch.
20.3. Hydrocarbon areas
Areas where hydrocarbons are or may be present in concentration that could lead to fire
or explosion if a source of ignition is introduced shall be identified and communicated to
JV Site Management and Sub-contractors.
The followings shall be implemented inside hydrocarbon areas:

 All the activities executed under Safe Permit to Work control.

 All personnel deeply informed on flammable/explosive hazard, preventive and
protective measures to be adopted, basic fire-fighting, emergency procedure;
 Fire and gas detectors and alarm system in service, if any
 Firefighting systems and equipment’s available and in service.
 Smoking as well as carrying matches and lighters is strictly forbidden.
 Use of mobile phones forbidden.
 Keep the area free from unnecessary flammable/combustible materials such as
paper, wood, gas cylinders, etc….
 Internal combustion engines equipped with spark arrestor on the exhaust pipe.
Vehicle entry permit required.
 Portable electrical tools and temporary electrical panels of approved explosion proof
design.
 Pneumatic driven rather than electrical driven equipment, whenever possible (air
mover vs. air blower, pneumatic vs. electrical driven torque machine, etc…)
 Use non-sparking spanners and hammers when operating in presence of
hydrocarbons or performing activities that could likely caused hydrocarbons leaks
(g.e. tightening or releasing live pipes bolts)
 Emergency escape way identified and kept free.
 Firefighting team trained and equipped to intervene in case of flammable/explosive
substances released or fires/explosions is available
20.3.1. Hot Works in Hydrocarbon Areas
As a principle hot works in hydrocarbon areas, such as process areas, should be

avoided.
Prior to introduce hydrocarbons or other flammable/explosive substances in the plant,

construction hot works activities should be completed.
In case hot works needs to be performed in a hydrocarbon area a previous analysis shall
be performed to determine if:
 alternates to carrying out hot work activities exist (g.e. cold cutting)
 the hot work can be moved away to a safe area.
 fire hazards can be removed or moved fire away from the hot work
If hot work in fire hazardous area is indeed required, as a minimum the following
requirements shall be applied:
 hot works performed under PTW control
 preliminary and repeated gas test monitoring to confirm the working area is free of
flammable/explosive substances and no minor/major leaks are on-going.
 Combustible materials removed from the working area (11 meters around) or
protected with fire blanket or by continuous wetting.
 Hot work equipments in satisfactory operating conditions and in good repair.
 Working area well ventilated to maintain a non-flammable work environment.

 Holes, cracks, sewer manholes, drain funnel in the working area (11 meters)
deeply flushed/purged or covered/sealed.
 Hot work confined with a welding box constructed of fire resistant materials to
contain sparks and isolate any nearby fire hazard from the hot work operation.
 Fire fighting systems available and in service. As a minimum fire extinguisher in
place.
 Properly trained and equipped fire watcher in place
20.4. Fire extinguishers
Fire extinguisher not less than 6 Kg. ABC shall be the minimum general construction site
standard. Carbon tetrachloride extinguishers are prohibited.
Extinguishers shall be located where they are easily available in case of fire. Location of
permanently mounted extinguishers shall be marked and free access maintained.
Permanent ABC extinguishers are required at least at the following locations:
 In buildings as per NOM-002-STPS-2010, in any case at least near a door, and

additional extinguishers mounted to have one within 30 meters of any point inside
the building
 Was placed at least one fire extinguisher for each 200 square meters of surface
area to the high fire risk and at least one fire extinguisher for each 300 square
meters of surface area for the regular fire risk.
 At least one on all vehicles and equipment including ton trucks, cranes, hoes,
welding machines and other internal combustion engines, particularly those utilized
for refuelling
 At sources of ignition such as welding, cutting, burning or use of open flames,
located no further than 15 mt
 At fuel or combustible material storage areas, extinguishers shall be located within
15 meters of any point on the perimeter of the stored material.
 A CO2 extinguisher shall be mounted at each large electrical installation such as a
substation, transformer, generator, or motor control centre
 Throughout the work areas for emergency service
20.5. Other fire extinguisher means
JV Site Management / OWNER Plant, in case of fire or other emergency not properly
manageable by the Project site organization, will ask the intervention of the local Fire
Brigade.
20.6. Fire prevention and fighting organization
Details for key roles activation in case of emergency are reported in the Emergency
Response Plan EXXI-010-00-00-HS-PLN-0004. JV Site Management Fire Marshal is the
Site HSE Manager or one of his staff, duly nominated, if he’s absent from the site.

JV Site Management shall appoint its own Site Fire Marshal, with adequate training and
experience in fire prevention and fire fighting, to coordinate the overall fire prevention
and fighting organization, including the training of Fire-watchers at the jobsite.
All employees shall receive basic fire extinguisher training during new hire orientation.
Basic practices shall be refreshed periodically. Training on this matter shall be recorded.
20.6.1. Fire watchers
Fire watchers are requested when performing hot works at Site in sensitive areas.
The Fire watchers shall receive specific training, shall be equipped and shall wear vest
for easy identification; all the fire watchers are part of the fire Spotting and Containment
field team.
Fire watch knowledge shall include: understanding and being able to recognize fire
hazards; being trained in incipient fire fighting; being familiar with facilities for sounding
an alarm; being able to communicate effectively with the workforce.
Their exclusive duty is to watch for fires, prevent fires, put fires out, and give the alarm.
Each fire-watcher will be responsible for a maximum area that shall be evaluated at Site
depending on the intensity of hot activities and characteristic of the overall areas to
cover.
Fire watcher shall maintain a watch at least 1/2 hour after completion of the hot work to
ensure the area is free of fires or smouldering materials.
JV Site Management personnel will conduct only incipient fire fighting. Personnel who
have had specific training on how to fight incipient stage fires can only perform this
activity.
20.7. Fire fighting equipment inspection
Fire prevention/fire fighting equipment shall be periodically inspected to ensure they are
in a good working order and repaired/replaced if missing or faulty. The inspection shall
be planned and recorded by each organization managing their means. Records shall be
available upon request.
Extinguishers shall be inspected to ensure that they have not been actuated or
tampered, and to detect any visible damage.
Inspection tags shall be placed on them, indicating the last inspection date. Each
extinguisher shall have a durable tag, securely attached to show the maintenance test
and recharge date and the responsible that performed the services.
A discharged fire extinguisher shall be removed from service immediately and replaced.
The following equipment shall be also inspected on regular basis and a log be kept of
each inspection
 Chemical and Fire suit - Check to see if adequate gear is available, readily
accessible, and in good condition in case of an emergency.
 Scott Air-Packs/Fresh Air Supply Systems - Inspect the hoses, masks, and seals
for wear; verify equipment is protected from the elements; verify that the air
supply bottle is full and the expiration date has not expired.

 Eyewash Stations/Safety Showers - Verify that any alarms installed on the

safety equipment are working, test operability, and water flush each station.
 Safety signals – Verify for any deterioration and proper visibility
The control/test plan is described below.
Equipment Type of check Frequency*

Fire Water pumps Test Weekly
Foam system – storage Visual Weekly
Fire Truck Test Daily
Safety Box (hoses, key) Visual Weekly
Portable Extinguisher Visual M
Fire Hydrants Visual Weekly
Water monitors Visual Weekly
Water monitors Test Monthly
Foam monitors Visual Weekly
Foam monitors Test Monthly
Steam hose reels Visual Weekly
Steam hose reels Test Monthly
Fire blanket Visual Weekly
Sprinklers Test Twice a year
Water fixed system Test Twice a year
Gas and fire detectors Test Twice a year
Respiratory equipment Visual Monthly
Fire Suit Visual Monthly
Chemical Suit Visual Monthly
Safety signals Visual Monthly
Emergency shower Test Weekly
* at least
During Commissioning phase both operative and emergency personnel shall execute
these controls, in order to obtain high level of familiarization of safety equipment
available.
21. INSPECTION AND AUDIT
Each organization working at site shall have its own Inspection Plan. Some site survey
should be done together on site.. JV Site HSE Manager shall issue a site overall
inspection plan for common activities (see a typical in Attachment 39-43 with applicable
inspections forms).
21.1. Daily Task Risk Assessment (DTRA)
JV Site Management shall have its own procedure for the DTRA implementation.
Observations shall be done regularly (normally weekly), properly registered, updated all
day long – as required – and properly analysed to spot recurrent problems.
21.2. Daily inspection

The Site HSE Staff, both JV Site Management and Subcontractors, shall do daily
inspections of the work areas and work procedures implementation. In addition, it is
expected that all Field Representatives, Construction/ Pre-Commissioning Managers
and Supervisors also will perform a daily inspection of the work areas. Problems should
be immediately solved or handled by the observing parties.
Anyone observing work being performed in an unsafe manner which could lead to an
injury or accident, shall suspend the work, pending correction of the problem by field
supervision, and shall immediately advise the pertinent Area Superintendent or
Construction/Pre-Commissioning Manager and the JV Site HSE Manager.
The following are items that the inspectors shall check involving the workers (discussing
and asking open questions): Work Permits and Safe working methods; Personnel safety
equipment; Lifting activities; Excavation; Temporary Support for pipes; Tools and
Electrical Equipment; Gas cylinders and Fire-fighting; Working at height, scaffolding
suspended platform; Waste management and other environmental aspects; Order,
tidiness, housekeeping, healthy conditions, etc.
The daily inspections are recorded as per Attachment 39.
21.3. BBS Observations
BBS observations are to be done by the “BBS Observers” as foreseen by the procedure
EXXI-010-00-00-HS-PRO-0111 Behaviour Based Safety Site, as applicable.
All the observations done, both positive and negative, shall be properly recorded and the
results summed up to be analysed at the relevant site HSE meetings.
21.4. Weekly HSE inspection
In general, collective HSE field inspections will be held on a weekly basis on site;
however the frequency can be increased, if deemed necessary by JV Site Management.
Participants shall include JV Site Manager, Construction/PC&C Manager, Site HSE

Manager and the involved Field Representatives, Area Managers and Safety
Supervisors/Officers and Sub-contractors.
The items to check are the same of the daily inspections. Checklist/inspection guide
shall be used to provide homogeneous data.
This kind of activities is considered very important to demonstrate the site management
commitment; therefore, constant participation of the management is mandatory.
A briefing shall be held after the inspection to record all the observation and action taken
or to be taken.
JV Site HSE Manager shall issue the inspections report to Site Management, including:
Area, time, positive and negative findings, corrective action done or to be done,
responsible, targeted time, list and signs of participants.
The files of all the inspection recorded it is a document valid as a Site Observation and
Recommendation Register.

21.5. Machine and equipment inspection
The JV Site Management and Subcontractors shall provide and operate their equipment
in compliance with the specific manufacture instruction and the mandatory inspection
and maintenance requirements. Machine and equipment shall be verified daily by the
user and before each use. Moreover also a site specific frequent inspection programme
shall be established for the equipment and the machine utilised to work (i.e. colour code
system).
21.6. Periodical Health, Environmental and Camp Inspection
No camp installation/management is foreseen.

.
21.7. Inspection by Authorities
JV Site Manager, supported by JV Site HSE Manager, shall assist inspection made by
the Authorities. OWNER shall be informed by JV Site Management of relevant inspection
and notifications..
21.8. System assurance audits
External HSE site audits shall be performed by OWNER during the Construction Phase
to check the HSE System implementation.
The Site Manager is responsible for implementation of Site actions and for the
communication to the HSE Auditor of the follow up of the actions done, till the completion
of all improvements agreed.
21.9. Audits of PTW
They form work permit random audits included periodic workplace in order to identify if
they were considered or taken into account the operational controls to mitigate the risks
of the activity that those involved are aware the dangers linked to the identification of
danger, risk control, evaluation and assignment of secure tasks
22. DOCUMENT, RECORD AND REPORT
The main HSE documents of JV Site Management and Subcontractors organizations

shall be orderly filed in the HSE offices by Control of documents in the project.
22.1. Site HSE File
At least the following documentation shall be kept as an HSE Files by HSE Staff and be
available for JV Site Management review and/or retention at any time:
JV Site Management, Sub-contractor Site HSE Plan and their attachments; Law, rules,
etc.; Standards in use (ISO, ANSI, etc.); Organisation chart, including list and roles of
HSE staff; Competence assurance; Personnel Certification records including medical
examination; Discipline actions record; Awareness program record; HSE communication,
notices, leaflet; Training program and records including specific session training
(confined space, tag/lock out, etc.); Report of HSE meetings; Monthly/Weekly reports;

Monitoring record (air, noise, etc. test results); HSE Correspondence; Risk assessment;
Job Hazard Analysis / PTW; Operative procedure and safe work practice; MSDS of
hazardous materials in use at site; Lifting plan, scaffold design, etc.; Instruction for
machinery, instruments, etc.; Check of the instrument, vehicle, machinery, etc.;
Inspection and audit results (description, observation, corrective actions, etc.); HSE
statistics, such as: days lost, total recordable injuries, lost time injuries, environmental
damage, accident, incident, near miss, safety index, etc.; Environmental statistics, such
as kind and quantity of wastes managed, etc.; First aid records; Accident and incident
reports, including Investigation results, Corrective action and follow-up in place;
Files for audit findings and incidents, non-compliances should be kept for 5 years
minimum.
The documentation shall be kept up to date, with the date of issue and revision, easy to
found and when needed communicate to whom it may concern.
The certificates are to be properly numbered and signed. The forms to be used shall be
agreed with JV Site Management / OWNER. As a reference, a set of forms is attached to
this Plan.
22.2. Recommendation Register
All Site observations and deviations (by site inspection or by site surveillance activity)
are recorded in a Register, under direct responsibility of the JV Site HSE Manager.
The JV Site HSE Manager stresses each involved party to the resolution of the
recommendations.
The Register contains all information necessary for the tracking of the activity.
22.3. Weekly and Monthly HSE Progress Reports
JV Site Management and Subcontractors will issue weekly and monthly HS&E reports.
 Weekly HS&E reports shall be prepared by noon each Monday, covering the
preceding week's work (Monday to Sunday).
 Monthly HS&E reports shall be prepared within the first 5 days of each month
according to Project calendar requests, covering the preceding month's work.
22.4. Final HSE Report
The JV Site HSE Manager shall prepare a HSE Final Report as part of the Construction
Final Report under the responsibility of the Site Manager.
The list of topics dealt in the Final Construction Report shall include:
 List of documents and procedure utilized and developed on site (including copies);
Incentive scheme applied during the project (including results and copies);
Numbers and type of JHA prepared (including copies); Number of Lesson Learned
issued and their type (including copies); List and type of HSE training held,
including number of participants where possible; Hours spent for HSE courses and
training ; All the HSE statistical data (LTI rate, Frequency Rate, man-hours,
manpower, etc.) monthly and cumulative; Type of recorded Project HSE meetings,

including hours spent; Survey recorded and unsafe or hazardous conditions;

Number of internal inspections and audits performed; Report from management
inspections with HSE Action/Issue Tracking; Communication with the authorities or
external organizations concerning HSE; Environmental management dates/results:
waste management, etc.; Disciplinary action issued; Sanitary protocol evidence
(pre-employment, periodical exams; Audits and follow-up; List of Incident/Accident/
Near miss/ Medical treatment analysis, action taken; Any achievement and award;
Database system of Certification, Training, Equipment, Inspections, etc.; Any
significant events occurred during the project period regarding HSE; Final
evaluation of HSE Staff (Low, Medium, High performance);
The list of topics can be expanded as needed.

23. ATTACHMENTS
1. ETILENO XXI PROJECT HSE POLICY;
2. GENERAL SITE DRAWING;
3. SITE HSE ORGANIZATION CHART;
4. LIST OF APPLICABLE HSE LAWS AND REGULATION;
5. SITE HSE ACTIVITY MATRIX – DRAFT;
6. KICK OFF SUBCONTRACTORS’ HSE REQUIREMENTS – DRAFT;
7. WEEKLY HSE MEETING REPORT – DRAFT;
8. MONTHLY STEERING COMMITTEE MEETING REPORT – DRAFT;
9. GUIDELINE TO MANAGE CONSTRUCTION & START-UP OVERLAP - DRAFT;
10. COMPETENT PERSONS LIST;
11. BASIC TRAINING MATRIX;
12. GENERAL INDUCTION TRAINING FLOWCHART – DRAFT;
13. HSE ORIENTATION TOPICS AND RECORDS – DRAFT;
14. LEAFLET FOR VISITORS – DRAFT
15. WEEKLY HSE REFRESH TRAINING / TOOLBOX MEETING – DRAFT;
16. SITE ENTRANCE HSE BOARD – DRAFT;
17. PRELIMINARY ANALYSIS RISK LEVEL;
18. INCENTIVE AND DISCILPINE TICKETS – DRAFT;
19. DISCIPLINE REGISTER – DRAFT;
20. PRE-EMPLOYMENT MEDICAL EXAMINATION BASIC PROTOCOL;
21. MEDICAL REPORT – DRAFT;
22. MEDICAL RECORDS – DRAFT;
23. PROJECT STICKERS AND BADGE FACSIMILE;
24. VEHICLES INSPECTION CHECKLIST – DRAFT;
25. TYPICAL JHA FORMAT – DRAFT;
26. TYPICAL PTW FORMAT – DRAFT;
27. SITE STRUCTURE WORKING PLATFORM TYPICAL TAGS;
28. TYPICAL TAG-OUT AND SCAFFOLDING TAGS;
29. ENERGIZED SYSTEM COMMUNICATION;
30. SEVERE WEATHER CONDITION – SITE CONTROL CHECKLIST;
31. MSDS RECORDS – DRAFT;
32. ENVIRONMENTAL DATA REPORTING;
33. EMERGENCY LEAFLET EXAMPLE;
34. INCIDENT REPORT FORM;
35. HSE LESSONS LEARNED SHARING INFORMATION;
36. INCIDENTS LOGBOOK DRAFT;
37. GENERAL HSE INSPECTION PROGRAM DRAFT;
38. BEHAVIOR BASED SAFETY OBSERVATION FORM;
39. HSE DAILY AND CRITICAL INSPECTION GUIDELINE;
40. WEEKLY ENVIRONMENTAL INSPECTION – DRAFT;
41. DAILY HSE INSPECTION REPORT – DRAFT;
42. WEEKLY HSE WALK AROUND REPORT – DRAFT;
43. SITE HSE INSPECTION (LONG VERSION) – DRAFT;
44. EQUIPMENT INSPECTION SCHEDULE AND LOG;
45. SUBCONTRACTOR PERFORMANCE MONITORING REVIEW;
46. GENERAL SITE HSE / SUBCONTRACTOR / AUDIT REPORT – DRAFT;
47. MONTHLY HSE REPORT – DRAFT;
48. MANAGEMENT OF CHANGE – DRAFT;
49. ADMINISTRATIVE HSE CYCLE
50. FOLLOWING THREE ATTACHMENTS.

Exxi 010 00 00 HS PLN 0002 1

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Project: ETHYLENE XXI

SITE HSE PLAN Page 2 of 116

9.1.5. Pre-commissioning/Construction Coordination Meeting 37

SITE HSE PLAN Page 3 of 116

12.2. Temporary utilities installation and demobilization plan 60

SITE HSE PLAN Page 4 of 116

13.9. Site Housekeeping 78

SITE HSE PLAN Page 5 of 116

17.2.2. Couriers and delivery vehicles 97

SITE HSE PLAN Page 6 of 116

22.2. Recommendation Register 114

SITE HSE PLAN Page 7 of 116

SITE HSE PLAN Page 8 of 116

JV ETILENO XXI Project Documents

EXXI-010-00-00-HS-PLN-0001 Project HSE Plan

OTHER REFERENCE DOCUMENTS

IFC General EHS Guidelines (2007)

4. DEFINITIONS AND ACRONYMS

 OWNER – BRASKEM IDESA SAPI;

 Audit. - Systematic, independent and documented process to obtain audit

 Corrective action. - Action to eliminate the cause of a detected non conformity

SITE HSE PLAN Page 9 of 116

 Preventive action. - Action to eliminate the cause of a potential nonconformity

 Document. - Information and its support

 Disease - Identifiable, adverse physical or mental condition arising from

 Risk assessment. - Process of evaluating the risk(s) arising from a hazard(s),

 Hazard identification. - Process of recognizing that a hazard exists and

 Incident. - Work-related event(s) that may cause an injury or ill health

 Non conformity. – Non requirement fulfillment

 Interested party. - Person or group, inside or outside the workplace,

 Procedure. - Specified way to carry out an activity or a process

 Record. - Document stating achieved results or providing evidence of

 Risk. - Combination of the likelihood of an occurrence of a hazardous event or

 Event of Crisis.- Occurrence of an event or series of events not planned with

SITE HSE PLAN Page 10 of 116

ANSI American Standard National Institute

5. SITE HSE PLAN

5.1. SITE CARACTERISTICS

The limits of the Coatzacoalcos petrochemical complex are as follows:

 North: Gulf of Mexico

 South: parallel bordered by the town of Nanchital

 East: +/-2 Km of the border Cangrejera plant of Pemex

 West: Rio Coatzacoalcos

SITE HSE PLAN Page 11 of 116

5.2. Brief Scope of the Project

The Project includes the execution (construction, pre-commissioning and

Main process units

 No1 Steam Cracker

OSBL Related Facilities:

 SubStation(s) + RIB(s) excluded Main Substation

The categories of work will include:

 Civil works: pilings, concrete, underground works, backfilling;

SITE HSE PLAN Page 12 of 116

5.3. Work Hours

In special circumstances, a specific authorization may be requested - to JV Site Manager

5.5. Site HSE Policy

5.6. Line Responsibility

Active participation is required of all persons involved throughout the organization,

SITE HSE PLAN Page 13 of 116

At no time, HSE performance and considerations will be subordinated to quality, cost or

5.7. HSE Goals, Indicators and Targets

The main HSE objectives are:

HSE Management System Implementation

PI = 0.2T + 0.2BBS + 0.1HSEM + 0.3HSEM + 0.2*HSEW