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EHS MANAGEMENT SYSTEM <G01_xxXXxxxx>

GUIDELINES Version <1.0>


Confidentiality: <CF / IP / PB /
SC>
CHEMICAL MANAGEMENT Status:
<draft/released/expired>

Site Chemical Management

Table of Contents:

1. Objective........................................................................................................................................................ 2
2. Scope of Application........................................................................................................................................ 2
2.1. Scope....................................................................................................................................................................2
2.2. Responsibilities......................................................................................................................................................2
3. Reference Documents..................................................................................................................................... 2
4. Terminology, Definitions, Abbreviations........................................................................................................... 2
5. procedure...................................................................................................................................................... 3
5.1. Before Bringing Chemicals on Site..........................................................................................................................3
5.1.1. Chemicals provided by Project....................................................................................................................3
5.1.2. Chemicals chosen by Site............................................................................................................................3
5.1.3. Chemicals brought on site by subcontractors............................................................................................3
5.1.4. Risk assessments.........................................................................................................................................3
5.2. Chemical Safety Data and Inventory.......................................................................................................................4
5.3. Delivery.................................................................................................................................................................5
5.3.1. Bulk Deliveries.............................................................................................................................................5
5.3.2. Other Deliveries..........................................................................................................................................5
5.4. Storage.................................................................................................................................................................5
5.4.1. Bund Drainage.............................................................................................................................................6
5.4.2. Storage Combinations.................................................................................................................................6
5.4.3. Temporary Storage......................................................................................................................................7
5.5. Refuelling Activities...............................................................................................................................................8
5.6. General Chemical Handling....................................................................................................................................8
5.6.1. Exposure limits............................................................................................................................................8
5.6.2. Control measures........................................................................................................................................8
5.6.3. People management...................................................................................................................................8
5.7. PCB (Polychlorinated Biphenyls)............................................................................................................................9
5.8. CMR......................................................................................................................................................................9
5.8.1. Management of CMR Substances...............................................................................................................9
5.8.2. Follow-up and Minimization plan.............................................................................................................10

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5.9. Emergency control of spillages.............................................................................................................................10


5.9.1. Identification of Substances and mitigation measures.............................................................................10
5.9.2. Clean-up Protocol......................................................................................................................................10
5.9.3. Reporting...................................................................................................................................................11
6. Attachments................................................................................................................................................. 11

The blue colour used in this document indicates any revision changes from the previous or replaced
version.

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OBJECTIVE

To provide guidance on the management of storage and handling of chemicals at site.

SCOPE OF APPLICATION

Scope

JULIUS BERGER NIGERIA PLC Project Sites.

This guideline describes the minimum standard to be applied on all projects, however where any part of this
guideline conflicts with or is of a lower standard than local regulations, then the corresponding section of the
local regulation will apply.

Responsibilities

The JULIUS BERGER NIGERIA PLC Project EHS Manager shall ensure that this document is included in the
Project Management File, distributed accordingly and fully understood by the JULIUS BERGER NIGERIA PLC
Site EHS Manager/Representative.

The JULIUS BERGER NIGERIA PLC Site EHS Manager/Representative shall ensure that:
This document is brought to the attention of the appropriate JULIUS BERGER NIGERIA PLC Site Management,
JULIUS BERGER NIGERIA PLC Partners and Subcontractors.
Where local requirements are not met by this guideline, the guideline is amended to suit or other suitable
provisions are made.

Management of JULIUS BERGER NIGERIA PLC and its Partners will ensure that the workers, over whom they
have direct control, comply with this guideline and that subcontractors are managed accordingly.

All Site Supervisory Personnel shall monitor compliance and report any breach of any guideline to the
appropriate manager.

REFERENCE DOCUMENTS
XXX-EHS-TEMP-013 Site Specific Emergency Procedure
XXX-EHS-TEMP-014 Site Chemical-Hazardous Substance Inventory
XXX-EHS-TEMP-016 Chemical-Hazardous Substance Site Access Request Form
XXX-EHS-TEMP-017 Chemical-Hazardous Substance Assessment Form
XXX-EHS-GL-028 Management of Waste

TERMINOLOGY, DEFINITIONS, ABBREVIATIONS

CMR Carcinogenic, Mutagenic substances and substances that are toxic for
reproduction

Health Surveillance The means of medically determining through monitoring of a person or group of
persons exposure to any biological, chemical or physical risk above a defined
acceptance factor

MSDS Material Safety Data Sheet - a document relating to a chemical providing full
toxicology and safety information, it is provided by manufacturer of the chemical
to an international standard.
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GPI General Planned Inspection

PPE Personal Protective Equipment

PROCEDURE

Before Bringing Chemicals on Site

Chemicals provided by Project

The Project EHS Manager shall provide to the Site EHS Manager/Representative a list of the hazardous
substances that will be delivered by the Project to the site. All MSDS will be communicated with this list, in
the relevant language.

The Project EHS Manager will ensure that, when reasonably practicable and for each technical need, the less
dangerous chemical is provided to the site.

Chemicals chosen by Site

When chemicals are chosen and bought by site, the Site EHS Manager/Representative shall be part of the
decision process and shall provide guidance to choose the less dangerous chemical available for the purpose.

Chemicals brought on site by subcontractors

Access of any new chemical on site is subjected to a formal approval by the Site EHS
Manager/Representative.

The concerned subcontractor shall provide to the Site EHS Manager/Representative all necessary
information, by using NX-EHS-TEMP-016 Chemical-Hazardous Substance Site Access Request Form and XXX-
EHS-TEMP-017 Chemical-Hazardous Substance Assessment Form and providing MSDS of the concerned
chemical.

For chemicals that are classified as toxic or CMR, the Site Access Request Form shall be accompanied by a
memo demonstrating that the use of a less dangerous material is not economically and technically feasible.

Risk assessments

Prior to delivery and handling of a hazardous material, a suitable risk assessment must be performed and
submitted to the JULIUS BERGER NIGERIA PLC Site EHS Manager/Representative, ensuring that appropriate
controls have been identified and that they may be implemented prior to the arrival of the material.

Risk Assessments for hazardous materials should concern delivery, storage, transport on site and handling
issues. They should take into consideration quantities, ways of exposure, length and frequency of exposure,
efficiency of existing protection means (e.g. general ventilation of a room) and people exposed. Whenever
required, the risk assessment shall be supported by quantitative measurements of exposure.

As soon as JULIUS BERGER NIGERIA PLC is concerned (e.g. chemical used by JULIUS BERGER NIGERIA PLC or
delivered to a subcontractor by JULIUS BERGER NIGERIA PLC), the site EHS Manager/Representative shall
participate to the risk assessment process.

The XXX-EHS-TEMP-017 Chemical-Hazardous Substance Assessment Form may be used for this process.
Details of the risk assessment shall be recorded and communicated to relevant personnel.

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Chemical Safety Data and Inventory

A MSDS must be available for all chemical products on site. For any hazardous material, a Material Safety
Data Sheet (MSDS) must be provided, no matter how the substance is supplied - in bulk or in packages, no
later than at the time of delivery. There is no requirement for the provision of a Safety Data Sheet with
repeated orders but suppliers have a duty to ensure that recipients are in possession of the latest version.
Obligatory headings for Safety Data Sheets, are as follows:
Identification of the substance/preparation and company
Composition/information on ingredients
Hazards identification
First-aid measures
Fire-fighting measures
Accidental release measures
Handling and storage
Exposure controls/personal protection
Physical and chemical properties
Stability and reactivity
Toxicological information
Ecological information
Disposal considerations
Transport information
Regulatory information
Other information

All MSDS shall be retained in a format suitable to allow easy retrieval by any interested parties. A copy of the
MSDS or some other suitable information shall be provided to the medical centre, if in place.

A register must be maintained by the Site EHS Manager/Representative. It must consist of three sections:
Section 1: This section of the register deals with CMR materials. This section will provide access to risk
assessments available for their use. In addition, action plans will exist to minimize such
substances, preference being given to their replacement by a less harmful substance. Once
this is done, the new substance will be placed into Section 3 of the register and the CMR
transferred to Section 2, cross-referencing the replacement substance.
Section 2: This section will contain the listing of banned substances. These substances are banned by
virtue of local legislation or by virtue of having been replaced by a less harmful substance and
procedures must be in place to ensure that JULIUS BERGER NIGERIA PLC or subcontractors
will not bring them on site.
Section 3: Register of all chemical substances used on site excluding CMR’s.

This could be done by using the XXX-EHS-TEMP-014 Site Chemical-Hazardous Substance Inventory.

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Delivery

A responsible and competent person, who has satisfied JULIUS BERGER NIGERIA PLC Site EHS
Manager/Representative regarding to the risks associated with the substance and the requisite control
measures, must supervise any delivery.

All containers must be clearly labelled as to their content. Information to be included on the label is as
follows:
Name, address and telephone number of the supplier
Name of the substance
Indication(s) of the dangers and the corresponding symbol(s)
Risk Phrases (R-phrases)
Safety Phrases (S-phrases)
EEC number, where applicable

Bulk Deliveries

Prior to the delivery, a method statement shall be established between JULIUS BERGER NIGERIA PLC and the
company in charge of the delivery, in order to define all necessary equipment and assign each delivery task to
according person. The responsible person shall ensure that all necessary control measures have been
implemented (or can be implemented), including the provision and use of appropriate personal protective
equipment (PPE) and delimitation of hazardous area.

Before commencement of delivery, the responsible person shall ensure that the receiving vessel has sufficient
capacity to receive the quantity of substance being delivered; this shall be verified by a supplementary
physical check (e.g. use of a dip stick) and that any bund drain valves are locked in the closed position. For
highly flammable materials, a grounding strap must be connected between the tanker and the ground via a
suitable metal structure.

Delivery may then commence - the tanker driver must remain with the vehicle until transfer is complete.
Before delivery hoses are disconnected the responsible person shall ensure that a suitable container is
available to accept any potential drainage from the hoses and all necessary precautions are taken, where
applicable.

The responsible person shall then ensure that the grounding strap is disconnected (where applicable), the
flange blanking plate is refitted to the receiving vessel intake and that all intake valves are securely closed.

Other Deliveries

Deliveries that include substances in drums or other non-internally bunded containers shall be transferred
directly to a bunded storage area as defined in the following section.

Storage

All chemicals must be stored and used in approved containers. These containers must be labelled with the
contents and hazards according to section 5.3.

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All storage areas must be provided with suitable safety signs, including hazards warning and relevant
obligation and/or prohibition (e.g. prohibition of smoking or naked flames for storages of flammable liquids).
All fuels, paints or other chemicals must be stored within a bunded area suitably positioned, or other steps
taken, such as the provision of drum trays with integral bunds, so as to minimize any risk of damage by
impact (so far as reasonably practicable) the walls and base of which must be impermeable to the substance
stored and water. If there is one storage container in a bund, the bund must be able to hold 110% of its
volume. If there are more than one container in a bund, the bund must be able to hold whichever of the
following is greater:
25% of the total volume of containers
110% of the largest containers volume

Bunded areas shall be examined on a regular basis (at least weekly for oil storage facilities) for any leakage of
liquid from the storage vessel, associated pump and pipelines and any spills or releases cleared up
immediately. Where reasonably practicable, bunds shall be protected against rainwater and if not, inspected
during or after periods of heavy rainfall to ensure that they do not overflow. Rainwater removed from
bunded areas has to be considered as hazardous waste, unless proved as safe (see 5.4.1). All internal areas
shall be maintained in a clean state, free from general litter and debris.

Oil Storage installations, the valves, filters, sight gauge, vent pipe or other equipment ancillary to the
container must be within the bunded area (other than a fill pipe or draw off pipe or, if the oil has a flashpoint
of less than 32°C, a pump). A notice should be displayed stating that valves be kept locked when not in use
and that trigger guns and hoses be stored within the bund or suitable secure cabinet, which is locked shut
when not in use. The storage container (whether tanks, bulk containers, mobile bowsers or drums) should
not be constructed or situated outside a building within 50 meters of any well or borehole or 10 meters of
any inland freshwaters and coastal waters or drains that leaking oil could enter. Where this is not practical,
measures for preventing any spillages entering drains must be agreed and implemented.

Toxic or highly toxic substances must be stored in a locked container or a place that allows restricted access.

Bund Drainage

Under normal operating conditions all bund drain valves must be locked in the closed position. Valves may
only be opened to allow drainage of rainwater when there is no obvious sign of contamination - particular
care must be taken when the stored substance is water-soluble.

If contamination is suspected a sample must be taken for analysis and the results approved by a competent
person before the bund is drained. On completion of drainage, the drain valves must be locked in the closed
position.

Any water found to be contaminated shall be disposed of in accordance with Waste Management procedure.

Storage Combinations

Incompatible chemicals must be stored so that they do not come into physical contact with one another (e.g.
flammables and oxidizers, acids and caustics).
Acids must be segregated from alkalis for storage;
Acids must be segregated from organics for storage;
Alkalis must be segregated from organics for storage.
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In addition, the following shall be considered:

LEGEND:

+ : Can generally be

+ - - + - stored together

-: Cannot be stored

- + - o - together

O: Can be stored together

- - + + - only if specific
measures are taken
(see MSDS)

+ o + + -
- - - - +
Chemical storage requirements and information can be found on each material’s MSDS.

Temporary Storage

When it is necessary to have temporary fuel or chemical storage facility the most appropriate method of
containment shall be applied as following.

Prepared Bund

A bund should be built on the ground (as far as practicable), using materials that will ensure that the walls
and base are impermeable to the substances stored and water. The height of the bund calculated to hold at
least 110% of the container contents. It is recommended that the minimum height of the walls be 150mm.
The bund should then be lined with polythene and the container placed on top of pallets to give the
necessary height to facilitate gravity feed for discharge. The area immediately adjacent to the bund, where
filling will take place, should be covered with polythene and held in place by a quantity of inert material such
as sand. Inspection of the bund and adjacent ground should be carried out at regular intervals and cleaned as
necessary.

Secondary Bunding

For small containers the following types of bunding may be employed:


Skips
Double skin vessels
Oil Drums and Plant being used in work areas must have drip trays capable of holding 25% of the
container/s storage capacity under connections and fuel tanks. The ground beneath these trays should
be periodically inspected for spillage
Store all chemicals in an area where spills can be contained. This should be within an impermeable
bund. A bund is a secondary containment area that holds liquid

Chemical storage in certain quantities may trigger other regulatory requirements (e.g. US Spill Prevention
Counter-Controls (SPCC), Process Safety Management (PSM), and UK Control of Major Accident Hazards
(COMAH)). The quantity and storage limitations shall be taken into account during the chemical inventory
process.

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Refuelling Activities

Where practical, refuelling of mobile plant should be conducted in a designated area, preferably on an
impermeable surface, away from drains or watercourses. The operation should not be left unattended or
valves jammed open. Diesel pumps and similar equipment shall be placed on drip trays to collect minor
spillages and should be checked regularly and any accumulated oil removed for disposal.

General Chemical Handling

Health and safety issues are a primary concern when addressing chemical handling issues. Chemical handling
concerns should be addressed in each Job Risk Assessment developed at the site in order to reduce risks
associated with chemical handling. Substitution with other substances/packages/process, which present less,
or no risk, has always to be considered.

Exposure limits

The site must know workplace exposure limits for all chemicals handled on site or produced by site
plants/environment.

Whenever there is a doubt regarding exposure above limits, a monitoring of the exposure shall be performed
on a frequency and method defined by the risk assessment (e.g. only once, periodically, continuously) and
local regulations.

Control measures

The control measures to prevent or limit exposure to hazardous substances/mixtures have to be defined in
the risk assessments. They can consist in:
Technical measures such as total or partial enclosure, general or local exhaust ventilation, suitable PPE,
emergency means (see 5.8),
Organizational measures such as reducing number of persons exposed, permit-to-work process, handling or
storage instructions, training, adequate supervision, health restriction.

People management

All persons who may be exposed to chemicals, above any legal exposure limit or acceptable exposure
standards must be:
Provided with adequate information, including risk assessments, education and training, which must include:
Understanding of safe systems of control
Knowledge of the use and maintenance of protective equipment and its limitations
Awareness of potential risks, emergency measures (e.g. emergency actions to take in the event of a
spill, location of eyewash or safety shower stations and exits) and general precautions that may be
required to be taken
Placed upon a register of potentially exposed persons for health surveillance purposes. This
information must be linked to occupational hygiene initiatives and include input from the medical
staff on site where available.
Provided with personal protective equipment (PPE) appropriate to the risk, which must be
maintained

A health surveillance process shall be in place whenever an occupational health disease may be
contracted by people or required by local regulation.

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PCB (Polychlorinated Biphenyls)

Where PCBs has been discovered on site all measures shall be taken to avoid contact with it. If you suspect
that a substance is PCBs then, whilst observing local legislation the following action should be taken:
Ensure proper provision of containment facilities to face potential spill
Vacate and cordon of the area
Request inspection and tests by a specialist organisation

Where is has been determined by a specialist organisation that PCBs are present on site then this must be
appropriately dealt with.

Where the decision is taken to remove the PCBs from site then this must be done by a specialist and
authorised contractor, and disposed through a qualified and approved contractor, according to local
legislation.

CMR

Each site will have to establish a list of CMR or criteria selected by the local regulation. For information, the
European regulation identifies the CMR substances with these sentences that can be found on the original
packing of the substances or in the section 15 of the MSDS:
R45: can provoke cancer
R49: can provoke cancer by inhalation
R46: can provoke genetic impairment
R60: can tamper fecundity
R61: risks during pregnancy can have dangerous effects on the child.
R62: possible risk of impaired fertility
R63: possible risk of harm to the unborn child
R68: possible risk of irreversible effects
R40 limited evidence of carcinogenic effect

Management of CMR Substances

Whenever possible, CMR products shall be forbidden at site. However, the use of substances presenting CMR
characteristics may remain necessary for certain activities. Prior to any product delivery, the associated MSDS
shall be collected and checked to review its characteristics and if the substance falls under the CMR
classification. Inventory of CMR substances, if any, shall be then established with details of quantity and
toxicity and shall be reviewed at least on a monthly basis. CMR products shall be stored in accordance with
the content of Storage.

Any activity / work areas where the use of CMR products is required shall be clearly identified. Exposure risks
to CMR products shall be reviewed and included in the EHS risk assessment of concerned site activities. List of
potentially exposed employees shall be therefore established. The concerned employees shall be informed
about the potential risk associated to the presence of CMR products in their work area / activity. Employees
who are in charge of either the delivery or use of the CMR substances shall be trained according to MSDS
recommendations and risk assessment results. All required PPEs and associated precautions shall be
therefore provided.

In addition, specific and stringent control measures can be required by the local regulations, such as medical
surveillance for exposed workers, monitoring of exposure time and levels, etc. Therefore a minimization plan
shall be implemented.

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Follow-up and Minimization plan

CMR products at site shall be eliminated whenever possible. In case CMR products cannot be eradicated from
the site, a minimization plan shall be implemented to ensure minimization of:
Quantities stored at site
Time exposure of employees
Number of employees potentially exposed to CMR products at site

Metrics shall be established to monitor on a monthly basis the implementation of the minimization plan.

Emergency control of spillages

Identification of Substances and mitigation measures

The mitigation measures of the risk assessment shall include conditions of use regarding spillage risks, storage
requirements and provision of emergency response means (e.g. absorbents, excavating tools or equipment).
GPI schedule shall ensure that these requirements are fully met at all times.

All uncontrolled spillages or releases must be reported to the JULIUS BERGER NIGERIA PLC Site EHS
Manager/Representative. It is his responsibility to evaluate the spillage or release and determine the required
response.

Clean-up Protocol

Process specific emergency spill kits (acid, alkali, solvent, toxic etc.) and appropriate personal protective
equipment should be readily available with supporting procedures. These spill kits should be maintained on a
regular basis to ensure that they are always available and fit for purpose.

Where permeable soils may be polluted,

Not Hazardous

Where the spillage is not a harmful substance to human health or for the environment, a general clean-up
operation is initiated with the source of the spillage/release being identified and stopped. In order to avoid
any impact to environment, protecting the watercourse or surface water drain from being polluted should be
taken into account.

Waste issued for the cleaning operation should be then collected and disposed of accordingly.

Hazardous

Where the spillage/release concerns a hazardous material, with direct and severe impact to human health or
to the environment, the following procedure is followed:
Clear the area of all non-essential personnel, assess the extent of the hazardous area and demarcate the
area,
Raise the alarm,
Obtain/distribute suitable protective clothing (if required) to those dealing with the spillage (reference
must be made to the appropriate Material Safety Data Sheet),
Implement measures to limit the extent of the pollution and prevent spread of the material to other
areas. This may involve the use of temporary diking, sand bags, dry sand, oil booms, absorbent pads,
excavating tools or plants;
Wherever possible the material should be rendered safe by treating with appropriate chemicals
If spillage is flammable, prevent all possible ignition sources,

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Take appropriate action to locate the spillage source and stop it if possible;
Use an emergency portable pump to transfer the spillage to sound storage receptacle;
Where the spillage/release has entered a drain, the outfall of the drain is identified and containment of
the spillage/release is continued in accordance with this procedure;
In the event of a major spillage entering a watercourse, the Local Authority or Environmental Protection
body may be contacted for assistance;
All contaminated materials (e.g. absorbents, PPE, soils) are stored in waste disposal area for recycling or
disposal in accordance with current waste regulations.
Once the material has been treated, the cleared up area should be washed with large volumes of water
that has to be dispatched to relevant treatment plant according to pollution (internal if available, or
external).

Reporting

All spillages have to be reported to the Site EHS Manager/Representative.

All spillages shall be investigated and reported in line with NX-EHS-WI-0013 “EHS Event Management and
Reporting” and any requirements identified in the Specific EHS Plan.

ATTACHMENTS

None.

Identification Storage Recovery Protection Discard


NA NA NA NA NA

NA NA NA NA NA

Review History

Review Date Items Description of Items Reviewed Responsible


00 - Initial Issue

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