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HSE Plan (Health, Safety and Environment)

HSE Plan

Health, Safety and Environment

Revision Nr.: 1Revision Date: xxxDocument : HSE PlanPage 2 of 19

Table of Content

1.Introductionpage 3
2.HSE Objectivespage 4
3.EFG Scandinavia contractor managementpage 5
4.Overview of environmental managementpage 5
5.Environmental aspectspage 7
6.Measurespage 8
7.Risk Assessmentpage 9-10
8.Emergency scenariospage 11
9.Emergency Preparedness and Responsepage 12
10.Commitment to the Code of Conductpage 13-14
11.Contact Detailspage 15

Annex 1:   Copy of EN ISO 9001:2015, EN ISO

14001:2015 and EN ISO 45008:2018 certificate

page 16

Annex 2:   Company Policy                                                  page 17-18

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1.       Introduction

The EMS-FEHN-Group’s (EFG) HSE Plan is developed and implemented in the intention to minimize the  risks of accidents and  incidents to  people,  equipment, material and the environment. EFG Scandinavia, as part of EFG, underlies these set out regulations and undertakes it’s utmost to grant the best services with highly experienced and skilled personnel and subcontractors.

Contractors and suppliers are the key to our business performance, and the capabilities and competencies to perform transportation on our behalf are assessed continuously. By monitoring subcontractors’ performance, it can be ensured that our image of safety and environmental friendly processes are aligned with these contractors and provided to – and beyond – the customer’s satisfaction.

Generally, all applicable laws, provisions and regulations – national and international

– are to be followed during the whole service process. Additionally, the environmental support as well as safe handling of cargo is mandatory for service providers carrying out transports on our behalf.

EFG  provides  all  required  resources  for  supporting  the  occupational  health  and safety, not only for employees of EFG Scandinavia, but all people involved in the whole transport chain. The prevention of damage to any person is the highest obligation to all contracted partners.

EFG Scandinavia will act in an ethical and socially responsible manner and within the laws, customs and traditions of the countries operating in. Our ambition is to avoid negative environmental impact, enhance positive effects and contribute to the sustainable development.

Daily behavior of each and everyone of the persons involved in the supply chain is crucial for creating a solid reputation for our overall progress. By consistently implementing and living the obligations set out above, we are laying, together with our contractual partners, the foundation for our successful future.

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2. HSE Objectives

Health                                            Safety                                      Environment

Psychial and physical health of all involved persons within the transport process

Occupational health for all employees

Health care / protection

Health awareness

Training and education of personal

Accident / incident prevention

Safety working environment

(infrastructure)

Personal protective equipment

Safety awareness Risk assessment Internal / external audits

(control measures)

Cargo stowage, securing and handling

Training and education of personal

Pollution prevention

Possible compliance with all relevant

rules and regulations

Possible reduction of emission

Environmental awareness

Training and education of personal

Plan                                                                                       Do

Continuously Improvement

Act                                                                                     Check

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3. contractor management:

 transport architects

Qualitymanagement

Environmental management

Occupational health and safety management

• customer satisfaction

•  good service

• sustainability

• environmental awareness

• OH&S for everyone in the supply-chain

Contractor mmanagement

(supplier selection, – evaluation,

– development, – controlling)

Producer /

initiator /

truck

Common carrier

Seller / Receiver

customer

Seagoing vessel

train

Cranes

Service provider

transport architects

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Overview of environmental management (on-site / projects):

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4. Environmental aspects

Our environmental objectives are essential to improve the sustainability and enhance the  effect  on  the  environment.  Our  environmental  aspects  differentiated  into significant  as  well  as  direct/indirect  environmental  aspects  and  the  resulting objectives are defined  in our environmental  program  (“analysis of environmental aspects”). Our major goals are the continuous improvement of the environment within the complete supply chain and the decrease of our consumption rates.

Environmental aspects:

Consumptions

Paper

Toner

Emergency management (preparedness and response) Handling of media and press

Water

Heating

Fire protection

Pollution

Energy

Old equipment disposal

Waste seperation (according to legal requirements)

Toner

Batteries

Environmental aspects

Crane operations

Old equipment

Chemicals

Reduction of emissions (NOx / noise)

Printer, copier (toner)

Reduction of emissions (CO² / NOx)

Subcontractors

Transport of dangerous substances / dangerous goods / damages during the transport

Company  cars, business  travels

Significant environmental aspects:

Reduction of emissions (CO² / NOx)

Subcontractors

Crane operations

Company cars, business travels

Reduction of emissions (NOx / noise)

Old equipment disposal

Significant environmental aspects

Printer, copier (toner)

Toner

Batteries Old equipment Chemicals

coactive

Waste seperation (according to legal requirements)

Emergency management (preparedness and response)

Handling of media and press

Fire protection

Pollution

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5. Measures

Together with the employees of EFG Scandinavia a company policy has been developed and principles defined, to steadily improve the provided service to our customers. The employees are familiar with these principles and incorporate same into their daily work. Additionally, to this EFG Scandinavia is certified according to EN ISO  9001:2015,  EN  ISO  14001:2015  and  ISO  45001:2018  by  Lloyd’s  Register Quality Assurance (LRQA) providing an independent proof and sign of high quality, environmental and occupational health and safety works in the company.

All works of EFG Scandinavia are carried out according the “PDCA”-Cycle (Plan – Do

– Check – Act). With this the services and works carried out are permanently monitored and evaluated in respect to fulfillment of the customer’s obligations, contractual agreements and possible improvements for future transportations. Required resources – regardless if personal, financial or infrastructural – are provided by the management to improve the processes of the company and its subcontractors.

A company policy is established within EFG Scandinavia, defining the principles for keeping responsible handling and compliance with occupational health and safety as well  as  environmental protection  regulations.  These  principles  are  to  be  applied throughout the whole supply chain.

To find the  most suitable and  trusting  subcontractor for the  customer, we have developed a system of selecting the subcontractors based on different factors, e.g. present certifications, experience and also references. Furthermore, each project is monitored by the employees and any discrepancies are analyzed in respect to the root cause and the respective actions taken for correction. Additionally, preventive measures are taken into consideration and control measures are set in place.

The selection and evaluation of the subcontractors is permanently updated and every project is part of the general evaluation of all supporting and contracted companies. Additionally, the environmental support as well as safe handling of projects is mandatory for service providers carrying out services on our behalf.

As the main service of EMS-FEHN-Group is providing transport services in any ways, a group-based “risk assessment” has been developed. Depending on the means of transportation, this risk assessment has taken into account the most common risks and defined counteractions for preventing any injuries, damages and delays.

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6.       Risk Assessment

One  of  our  objectives  is  to  assess  all  identified  risks  to  our  personnel,  the environment  and  the  equipment.  On  basis  of  our  risk  assessment  we  have  to establish  appropriate  safeguards  and  procedures  to  minimize  the  risks  and  to recheck   if   appropriate   measures   /   actions   are   defined   to   prevent   the harm/risk/hazard:

•     a hazard is anything that may cause harm, such as chemicals, electricity, working from ladders, an open drawer etc.

•     the risk is the chance, high or low, that somebody could be harmed by these and other hazards, together with an indication of how serious the harm could be

5 steps to create a risk assessment:

•    identifying what can harm (hazard/risk)

•    identifying who might be harmed and how

•     evaluating the risks and deciding on the appropriate controls, taking into account the controls you already have in place

•    recording your risk assessment

•    reviewing and updating your assessment

 Effect / Severity
insignificant   General: no effect on our  service provision   Occupational health and safety: slight injuries or illness, no permanent damage caused to health   Environment: no environmental effect, no measures / actions necessary   1slight   General: restricted effect on our  service provision   Occupational health and safety: medium-heavy injuries or illness, no permanent damage caused to health   Environment: insignificant effect, no permanent effect, moderate actions / measures necessary   2critical   General: serious effect on our  service provision, definition of measures/ actions   Occupational health and safety: heavy injuries or illness, slight permanent damage caused to health   Environment: moderate, significant effect, definition of actions/measures   3kathastrophic   General: sigificant effect on our  service provision, immediate actions/measures   Occupational health and safety: heavy injuries or illness, heavy permanent damage caused to health, dead, disaster   Environment: immediate actions/ measures, significant effect, permanent damages to environment 4
Probability  very low (hardly imaginable; insignificant danger, preventable) 1    1    2    3    4
  low (imaginable; visibly and suppressible) 2    2  4   4    6    8
  medium (possible; visible and terminable by continuous control) 3    3    6    9    12
  high  (high  danger, in case measures fail – damage unavoidable) 4    4    8    12    16
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Subject to the results the company’ management takes the following steps: The

measures are defined, using “E-STOP” method:

E = total elimination

S = substitution

T = technical measures

O = organizational measures

P = personal protection means.

Taking into account the services provided by us, complete elimination and/or replacement  is  not  always  possible.  Usually  measures  are  defined  applying  the “TOP” method.

Following steps will be commenced by the management addicted to the evaluation:

Risk evaluation
1-2No measures needed / no need for actions
3-4Precaution is recommended / Appropriate measures if needed / observation of situation
6Measures needed / additional need for actions (hazards) / checking feasibility – measures realizable? / in case of risk acceptance – measures are not necessary
8-16Immediate actions necessary / immediate stop of operation (if necessary)
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7.       Emergency Scenarios

The specific emergency scenarios as well as the relevant measures / actions to react on same are recorded in the list of emergency scenarios as well as in the risk assessments. They are reviewed and, where necessary, updated, in particular after emergencies (including training in respect of the emergency situation) and at least once per year during the annual management review.

These emergency scenarios can cause the following consequences:

➢  Accidents, incident to workers (office and on-site)

➢  Pollution (caused by accident, water used for extinction)

➢  Negative image in the public press / media

➢  Lack of confidence in the legislator / authorities

➢  Consequences of the choice of subcontractors

➢  Loss of confidence (also among employees)

Definition of suitable ways to react in case of emergency situations

Evacuation routes and assembly stations

Risk and opportunity management

Internal and external communication

Training of emloyees for emergency response and emergency prevention

Possibilities with interested parties to support each other

Emergency preparedness and responce

(analysis of environmental aspects)

Improvement of emergency prevention and emergency response referring to accidents, impacts, evaluation

Evaluation of defined corrective measures for emergencies

Constant verification of relevant measures

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8. Emergency Preparedness and Response

Emergency preparedness and response

(ongoing inspections and practices in respect of emergency response)

Plan practice Define practice targets / objectives

(Ability to respond)

Inform management, neighbours and visitors

Execute and observe practice (reached planned ability to respond?)

Deviate measures, evaluate emergency preparedness (efficiency rating)

Document results

(reporting)

Emergency planning and reaction have to be adjusted afterwards (especially after cases of emergency).

We are a part of the supply chain and as a service provider we are the first point of contact for our interested parties, especially for our customers, in the event of accidents and / or emergencies. We may get notice of environmental and/or occupational  health  and  safety  incidents  and  emergencies  that  we  directly  or indirectly affect.

The relevant communication and information chain needs to be followed to respond to an emergency as quickly and appropriately as possible. The same applies to the ability to take measures and prevent and / or mitigate negative effects, in particular a negative impact on the occupational health and safety and on the environment.

The employees are briefed prior to proceeding to the work on possible emergency situations to prevent it and respond (response measures) and about the emergency chain and relevant contact persons.

Appropriate resources for training, further education and emergency / response measures training as well as resources in case of accident and incident to expand knowledge, acquire new knowledge and have adequately trained personnel available in emergency situations are granted.

The specific emergency scenarios as well as the relevant measures / actions to react on  same  are recorded  in the  risk  assessments.  They are  reviewed  and,  where necessary, updated regularly and in particular after emergencies (including training in respect of the emergency situation).

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9. Commitment to the Code of Conduct

As all members of the EMS-Fehn-Group, EFG Scandinavia set out certain obligations to its employees and subcontractors regarding general behavior. These principles combined are to be seen as the “Code of Conduct”.

a.   Antitrust

Competition can only develop freely when it is fair. EFG is committed to integrity and fairness when competing other in the market. Conduct that undermines competition is not  tolerated.  EFG  will  compete  in  an  ethically  justifiable  manner  within  the framework of the antitrust and competition rules in the market.

Antitrust  laws  prohibit agreements  or  actions  that might  eliminate  or  discourage competition, bring about a monopoly, abuse a dominant market position, artificially maintain prices, or otherwise illegally hamper or distort commerce.

It is therefore explicitly prohibited, e.g. to make agreements dividing up markets, regions or customers, to make agreements not to compete, to discuss processes related to participation in tenders, or to exchange information about prices, market shares or other market conditions with competitors, customers and business partners in violation of the applicable law.

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b.  Corruption

Corruptions undermine economic development and free competition. It ruins reputations and exposes both companies and individuals to risk EFG is against all forms of corruption does not occur in any parts of the company’s business activities.

The prohibition of corruption applies both to EFG Scandinavia as a company and to all persons acting on our behalf. In case of violations, it might lead to serious consequences both for the individuals involved as well as for EFG Scandinavia.

Gifts however – of material or immaterial value and nature – may be offered or accepted if the value is negligible or reasonable for the provided circumstances. In doubt the superior or management is to be consulted prior acceptance or offering.

c.   Rasicm

EFG does not tolerate any kind of racist behavior in any way against any people, regardless their nationality, religion, culture or others. Violating against this will lead to drastically steps taken by EFG against the indicted person(s) and / or company(s).

d. Anti-bribery and anti-corruption (Bribery Act 2010)

Our organization will follow all applicable (national and international) laws and regulations as well as the bribery act 2010 (or latest edition).

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10. Contact Details

EMS-Fehn-Group Scandinavia AS

Kokstadflaten 35

5257 Kokstad

Norway

Tel.: +47 55 55 80 80

Email: [email protected]

Person in Charge: Mr. Tom-Roar Solhaug (Managing Director)

Quality Management EMS-Fehn-Group

Hafenstr. 15

26789 Leer

Germany

Persons in Charge:

Mr. Jens Feuerhake (QHSE-Manager) Mrs. Dana Heibült (QHSE department) Office: +49 (0) 491 45 45 810

Mail:  [email protected]

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Annex 1: Copy of actual EN ISO 9001:2015, EN ISO 14001:2015 and EN ISO

45001:2018 certificate

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Annex 2: Company Policy

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Created by: QM department EMS-FEHN-Group                                   Accepted by: Tom-Roar Solhaug

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EMS-Fehn-Group Scandinavia AS

Kokstadflaten 35

5257 Kokstad

Norway

Created by: xxx                                   Accepted by: Txxx

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