LBC Corporate SOCIAL RESPONSIBILITY MANAGEMENT … · LBC Tank Terminals, with its headquarter in Belgium, is an independent operator of midstream and downstream bulk liquid storage

LBC CORPORATE SOCIAL RESPONSIBILITY MANAGEMENT HANDBOOK

LBC CORPORATE SOCIAL RESPONSIBILITY

MANAGEMENT HANDBOOK

CORPORATE SOCIAL RESPONSIBILITY POLICY


MANAGEMENT HANDBOOK

CORPORATE RISK MANAGEMENT POLICY STATEMENT


MANAGEMENT HANDBOOK

CORPORATE RISK MANAGEMENT POLICY STATEMENT


MANAGEMENT HANDBOOK

CONTENTS

1

Introduction ............................................................................................................................................................................... 1

Corporate Risk Register Overview .............................................................................................................................................. 2

Risk Management..................................................................................................................................................................... 10

Management of Change (MOC) ............................................................................................................................................... 19

Permit Application and Compliance ......................................................................................................................................... 22

Management of Contractors .................................................................................................................................................... 24

Recruitment ............................................................................................................................................................................. 31

Onboarding .............................................................................................................................................................................. 38

Efficiency and Innovation reward scheme ............................................................................................................................... 42

Audit Reporting and Compliance ............................................................................................................................................. 45

Incident Reporting and Investigation ....................................................................................................................................... 47

Performance Monitoring and reporting ................................................................................................................................... 58

Emergency Preparedness ......................................................................................................................................................... 62

Variance ................................................................................................................................................................................... 65

Fitness to work ......................................................................................................................................................................... 66

Conservation of Hearing........................................................................................................................................................... 67

Thermal Stress .......................................................................................................................................................................... 69

Vibrations ................................................................................................................................................................................. 70

Fatigue ...................................................................................................................................................................................... 71

Occupational Health Monitoring .............................................................................................................................................. 75

AED ........................................................................................................................................................................................... 76

Permit to Work ......................................................................................................................................................................... 78

Hot Work .................................................................................................................................................................................. 82

Personal Protective Equipment ................................................................................................................................................ 83

Product Transfer ...................................................................................................................................................................... 87

Isolation of Energy Sources ...................................................................................................................................................... 91

Confined Space ......................................................................................................................................................................... 95

High Pressure Water Jetting ..................................................................................................................................................... 99

Pressure Vacuum ................................................................................................................................................................... 104

Hoisting and Lifting ................................................................................................................................................................ 108

Working at height ................................................................................................................................................................... 112

Line Cutting ............................................................................................................................................................................ 117

Hose Management ................................................................................................................................................................. 120

Excavation and Working at Depth .......................................................................................................................................... 123

Vehicles and Driving ............................................................................................................................................................... 126

Electrical work ........................................................................................................................................................................ 128

Responsible Travel, Entertainment and Refreshments .......................................................................................................... 129

Definitions .............................................................................................................................................................................. 142


INTRODUCTION

1

Introduction

The policies defined in this Management System Hand Book are designed to specify minimum requirements

that must be implemented into local procedures at all LBC facilities to ensure a consistent and structured

approach throughout the organization. This is necessary to adequately manage all identified risks and to

facilitate the identification of concealed risks.

A Variance from a Group Policy must be approved in accordance with the Variance Policy.

1. Responsibility and Authority

1.1.1 The CEO is responsible for approving all Group policies and assigning a Policy Owner.

1.1.2 The Group Corporate Social Responsibility (CSR) Director is responsible for reviewing policies for

adequacy, consistency and relevance and for auditing compliance with the policies. The Group CSR

Director is responsible for advising the CEO and Board regarding identified vulnerabilities.

1.1.3 The Policy Owner has accountability for maintaining the policy and ensuring its ongoing relevance

to the organization and for providing training to local Management Teams.

1.1.4 The LBC Terminal Manager/Designated Facility Manager is responsible for ensuring full compliance

in his/her LBC Facility

1.1.5 Variance Approver: The CEO, The Policy Owner and the Group Corporate Social Responsibility (CSR)

Director may collectively approve a variance based upon Risk Assessment from a Group Policy upon

reaching consensus.

2. Compliance

There should be a system in place:

1.1.6 That includes a clear and auditable process to assess the compliance by all employees and

contractors (where applicable) with Group Policies and the procedures relating to Group Policies.

1.1.7 Whereby A training matrix is established to indicate how the local procedure will be trained and

communicated and with what frequency to all affected employees, contractors or visitors (if

relevant)

1.1.8 Whereby the procedures and policies are reviewed as a minimum annually during the Management

Review for relevance and if necessary, documented and traceable adjustments are made by

Competent Persons according to the definition.

1.1.9 Whereby in the event of audit identifying a deficiency or an Incident occurring related to this Policy

and/or the procedures embedding this Policy, a review is conducted and the findings of the Root

Cause Analysis (RCA) are considered and if necessary amendments are made by Competent Persons

to local procedures and/or by the Policy Owner in the case of a Group Policy.

1.1.10 Whereby the Management of Change (MOC) Policy shall be utilized to control all changes to Group

policies.

1.1.11 Whereby a local procedure that deviates from the requirements of a Group Policy can only be

approved via the Variance application process.

1.1.12 Whereby Group Policies and local procedures are stored in the LBC Document Management site.

1.1.13 Whereby documentation is archived in accordance with local legislation except for MOC

documentation and information in the CSR-HSSEQ database which will be stored for 20 years.


GOVERNANCE

Document No. Date First Issue: Date this issue Revision Number Page

GV 02 1 June 2018 1 September 2018 2.0 2

Owner Position & Department Approved by Head of Department

Approved by Group CSR Director

Approved by CEO

Walter Wattenbergh CEO

Corporate Risk Register Overview

Context

LBC Tank Terminals, with its headquarter in Belgium, is an independent operator of midstream and

downstream bulk liquid storage facilities for chemicals, oils and refined petroleum products currently owning

and operating a global network of terminals with a combined storage capacity of 2.0 million m³ (2.1million

m3 including the Seabrook Logistics Joint Venture in Houston, Texas). We have facilities in Europe, Asia and

America serving over 300 customers including all major players

We offer a range of additional value-added services as shown below:

Table of Services

Storage Services Handling Services Waste-water handling Other Services

• Storage and handling of

heated and cooled

products

• Blanketing and purging

• Vapor return and vapor

treatment including

cryogenic, incineration

and vapor abatement

flares

• Filtering

• Blending including in-

tank and in-line

blending

• Automated drumming

and IBC-filling

• Drying and dehydration

• Marpol I, II & III

reception facilities and

forwarding to

destruction or

treatment facilities

• Collection and

forwarding of vessel

residues to destruction

or treatment facilities

• Physiochemical and

biological treatment

• Tank-to-tank transfer

• Direct transfers to and

from ship, barge, truck

or railcar

• Container handling

including heating and

cleaning

• Flexi-bag loading

• Warehousing of

hazardous materials

• Product analysis with

surveyors on site

• Forwarding and

customs services

The weighted average utilization of our facilities was 93.9% with a generated revenue of $186.1million for

the year ended June 30th, 2017.

Overall economically we are performing in line with our expectations. Most of our products are base oils

and chemicals and consequently we are not dependant on the fluctuations of the oil market since we are an

integrated part of our customers ‘supply-chain. This shelters LBC from the effects of a Contango or

Backwardation oil market.

The population of the world is increasing, GDP is growing in most countries, manufacturing and demand for

energy are strengthening and so is the demand for responsible logistics. To meet this demand, we continue

to add tanks and infrastructure at our terminals.


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Our vision is simple, we strive to offer responsible logistic solutions where there is no such thing as a

dangerous product, at least not while in our care.

Together with our highly supportive Shareholders we have confirmed our group strategy, built around three

pillars:

1 Further optimize

2 Build out

3 Expand

Our strategy is founded upon a sound risk management philosophy that involves ensuring a healthy and

responsible balance between taking advantage of opportunities and fostering innovative and

entrepreneurial spirit while managing risks to acceptable levels. In this way we strive to minimize any

negative impacts on society and to secure a sustainable future for LBC, this is evidenced by the fact that

some of our original customers from 1947 are still with us today, a fact that underlines our values:

• Responsibility

• Transparency

• Respect

• Integrity

• Empowerment

We have optimized our base business through the implementation of an ERP system, maintenance and

commercial investments as well as margin improvements. We want to further develop the business by

utilizing the available land banks at hub locations and capitalise on the growing structural imbalances in the

demand and supply of bulk liquid chemical and petroleum products.

Our investors have approved a program to invest $970 million over the coming years. To give a flavour of

our activities:

• In Rotterdam we are expanding our capacity by 179,000m3 and have constructed a new jetty to

accommodate this expansion.

• In the US, we formed a joint venture with Magellan Midstream Partners, allowing LBC to move into

the logistics of crude oil. We are constructing a new ship dock and will add nearly 782,000m3 of

new tanks.


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Corporate Risk Owners

During the execution of such exciting and ambitious growth plans, we do not want to lose sight of our

responsibilities. To this end we have identified Corporate Risk Owners, as shown in the organization chart

below, who work together to identify appropriate Risk Treatments and manage our risks optimally. To

guarantee the independence of the system we have a direct reporting line between our Group Corporate

Social Responsibility Director and our CSR and Audit Committees of the Board. Our risk management process

is subject to regular review and auditing. The résumés of our risk owners are shown in appendix 1.


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Risk Management Process

An overview of the Risk Management process we use within LBC is shown below. We have fashioned our

approach on the guidelines of the ISO 31000:2009 Standard Risk Management – Principles and Guidelines.

Main Risk Areas

Below, several high-level Risk scenarios that we actively manage:

• Human Resource Risk

• Attitude to HSE

• Operational (safety) Leadership

• Occupational illness and accident

• Loss of key personnel

• Talent management

• Knowledge management

• Culture management

• Management of historical labour conditions/costs

• Social conflicts

• Operational Risk

• Contractor Management – attitude to HSE

• Failure of Contractors/sub-contractors

• Product Contamination

• Critical equipment breakdown or utility failure

• Fire/explosion - tank pit, jetty or quay

• Infrastructure issue (internal/external)

• Operational IT/OT interruption

• Major spill in containment


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• Major spill outside containment

• Security breach (including sabotage)

• Managing expansion

• Commercial & Strategic Risk

• Managing customer expectations/satisfaction

• Reliance on major customer

• Predicting activity levels of customers (throughput fees)

• Contract creep

• Market analysis/ change in market forces

• Competitor strategy

• Managing overcapacity

• Reputational damage

• Financial Risk

• Withdrawal of major shareholder support

• Financial fraud (internal/external)

• Cash exposure due to delayed payments

• Cash exposure due to unexpected event

• Bank covenants

• Identification and Management of appropriate insurance portfolio’s

• Managing expansion (costs associated with delays/penalties)

• Customer base and revenue forecast (variation between forecast and actual)

• Economic crisis

• Penalties for under performance (customer contracts)

• Cost of compliance HSE regulations/changes in regulations

• Provision of reserves for unexpected expenses

• IT Risk

• Information/knowledge management and GDPR

• Group wide IT failure

• Facility level IT failure

• Loss of critical server

• Breach of IT/OT security walls/cyber attacks


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• Legal and Compliance Risk

• Loss of licence to operate

• Management of permit lead time and renewal

• Identification and compliance with applicable legislation

• Major breach of regulations

• Legal changes

• Breach of ethical values/regulations

• Liability

• Contracts with customers

• Management of joint ventures/Issues, agreements, terms and conditions

• Communication Risk

• Management of expectations of Stakeholders (internal & external)

• Management of reputation

• Intangible Risk

• Natural disaster

• Terrorist attack

• Pandemic

• Community disputes/war

• Political changes

• Disruption to infrastructure


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Appendix - Overview of Our Risk Owners

Walter Wattenbergh CEO (Commercial Risk & Corporate Risk)

Walter was appointed as Group CEO of LBC Tank Terminals in April 2015 and has an impressive career in the

industry spanning more than 30 years. Prior to joining LBC Walter was with the Stolt-Nielsen Group – the

international transportation and bulk liquid storage business. During his time at Stolt-Nielsen, Walter held a

number of executive roles and was President of Stolthaven BV from 2005 up until joining LBC in 2015.

Niels Van Bladeren CFO (Financial Risk)

Niels is CFO at LBC Tank Terminals since 2015. His experience in finance, controlling and treasury together with

specific competencies in negotiation, leading change, ICT implementation, IFRS, Tax, and integration of

companies contribute to the success of the company.

Niels joined LBC after 18 years in various financial management roles with Koole and NOVA Terminals, Van

Gansewinkel and Unilever. Niels was CFO of Koole and NOVA Terminals for 3 years prior to joining LBC.

Ilse de Loof Group General Counsel (Legal Risk)

Ilse joined LBC in 2011 from Jacobs Engineering. She is a polished and accomplished, group-level general counsel

and corporate secretary, operating at Executive Committee level, with broad and multi-national experience in the

US, Europe and Asia of corporate law, international litigation, employment law and contracting. Ilse is an

individual with experience of working in complex, multi-ownership structures (private equity and pension funds),

structured financing, as well as major global corporations.

John Grimes COO (Operational Risk)

John Grimes originally joined LBC in 1998 and held a variety of functions. In 2016 he was appointed as Business

President Americas. He is a highly-motivated individual who has been skillfully managing our facilities and

expansion plans in the USA over the last years. In 2017 he was promoted to COO.

John has 30+ years of experience in the liquid bulk chemical storage industry and has an impressive knowledge

of construction and maintenance. He is ideally suited to be LBC’s Operational Risk Owner.

Bert Goyvaerts Group HR Director (Human Resources Risk)

Bert is Group HR Director at LBC Tank Terminals since 2015. In this position, he is leading the management of the

human capital of the company in terms of personnel management & development while focusing on strategical

growth.

He has almost 15 years of experience in the Logistics and Bulk shipping industry. Previously Bert worked as HR

Director Northern Europe and HR Director Europe at LBC and as HR Manager at Herfurth group and at Cobelfret.


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Ingrid Haleydt Group IT Director (IT risk)

Ingrid started in 2011 as Group IT Director at LBC Tank Terminals. She is responsible for the implementation of

the company's plans for growth as well as a solid IT plan

Her in-depth knowledge of the industry, business and IT is the result of more than 35 years of experience in

different business management roles in IT in the bulk storage business. Prior to join LBC, Ingrid held multiple IT

roles at Oiltanking including ICT Manager; and she also worked as Regional ICT Director at USG People.

Allison Volbeda-Newell Group CSR Director (Communication Risk)

Allison was appointed Group Corporate Social Responsibility (CSR) Director in 2015 and works together with our

Executive Leadership Team on the visioning, design, development and implementation of the CSR Program.

Allison has a doctorate in physical organic chemistry and over 25 years’ experience working in the mining, terminal

and petrochemical industry. She has a broad operational and commercial experience as well as a strong CSR

background specialized in risk management, communications and occupational HSE.


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Risk Management

1. Purpose and scope

• This Policy is defined to specify the minimum required controls that need to be in place to responsibly treat all Risks at any LBC Facility to prevent any negative impact on society and the environment and maximize positive impact.

• To adopt the Guiding Principles of ISO 31000:2018 to provide a basis for decision-making in order to achieve the company’s objectives based on the management of Risk.

• To provide guidelines for the consistent identification and assessment of Risks.

• To instill a culture of risk management at all levels within the organization such that Risk Assessment is part of all decision making.

• To provide a basis for the planning and allocation of resources (OPEX/CAPEX).

• To provide the basis for the High Level Corporate Risk Register resulting from the consolidation of detailed Facility Risk Registers carried out at each LBC Facility.

• To support business continuity planning and preparedness at Local, Regional and Corporate levels.

• To be legally compliant and improve Governance, Stakeholder confidence and trust and the overall resilience of the organization.

2. Additional Roles and Responsibilities specific to the Policy

• The High-Level Facility Risk Register Owner is the person at each facility assigned with ownership of the

High-Level Facility Risk Register. This person is responsible for ensuring that the High-Level Facility Risk

Register is updated using the system described in Appendix 1 in the light of new information and as a

minimum every year. The Facility High-Level Risk Register is the result of consolidating the highest risks

in each of the Detailed Facility Risk Registers.

3. Definitions specific to this Policy

The main definitions pertaining to this Policy are shown below. Other definitions can be found in the ISO

31000:2018 Standard. Flow diagrams indicating the ISO 31000:2018 process are shown in Appendix 2 to

assist understanding. Other relevant LBC Risk Management Information is contained the Corporate Risk

Management Policy Statement and the Corporate Risk Register Overview.

• Bowtie analysis: is a barrier risk model for Risk Identification and Risk Management.

• Consequences – outcome of an event

• Corporate Risk Management Policy Statement - a statement of intent from the CEO defining the broad

terms of Risk management within the organization.

• Corporate Risk Register Overview - public statement from the CEO advising Stakeholders of Risks that

the organization faces and detailing Corporate Risk Owners.

• Detailed Facility Risk Registers - these are detailed documents containing specific Risks and Risk

Treatments within an LBC Facility that have been identified for local activities and situations and in the

local context.


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• Establishing Context – defining the external and internal parameters to be considered when managing

Risk.

• Governance refers to the mechanisms, relations, and processes by which LBC is controlled and is

directed; involves balancing the many interests of the Stakeholders.

• A Hazard and Operability Study (HAZOP) is a structured and systematic examination of a complex

planned or existing process or operation to identify and evaluate problems that may represent Risks to

personnel or equipment.

• High Level Facility Risk Register – this is a high-level document containing a list of the most significant

risks that an LBC Facility faces and the agreed Risk Treatment and Risk Owners.

This document is established by an escalation process in which all the Detailed Risk Registers within an

LBC Facility are escalated to provide a document containing the highest impact Risks.

• Layers of Protection Analysis (LOPA) is a type of Risk Assessment methodology primarily focusing on

process safety risks.

• Level of Risk – magnitude of risk expressed as a combination of Consequences and Likelihood.

• Likelihood – chance of something happening

• A Process Hazard Analysis (PHA) is a set of organized and systematic assessments of the potential

hazards. A PHA provides information for improving safety and reducing the consequences of unwanted

or unplanned releases of Hazardous Substances. A PHA is directed toward analyzing potential causes

and consequences of fires, explosions, releases of toxic or flammable chemicals and major spills of

hazardous chemicals, and it focuses on equipment, instrumentation, utilities, human actions, and

external factors that might impact the process

• RI&E (Risk Assessment and Evaluation) is a type of Risk Assessment primarily focusing on occupational

health and safety Risks.

• Risk - the effect of uncertainty upon objectives (threat or opportunity)

• Risk Analysis – the process to comprehend the nature of risk and to determine the level of Risk (this

provides the basis for Risk Evaluation and decisions about Risk Treatment).

• Risk Appetite – the amount and type of Risk that an organization is prepared to pursue, retain or take.

• Risk Assessment - overall process of Risk Identification, Risk Analysis, Risk Evaluation and Risk

Treatment.

• Risk Evaluation – process of comparing the results of Risk Analysis with risk criteria to determine

whether the Risk and or its magnitude is acceptable or tolerable (prioritization).

• Risk Identification - the process of finding, recognizing and describing Risks.

• Risk Management - coordinated activities to direct and control an organization with regard to risk (i.e.

identifying appropriate responses to Risk such that exposure is reduced to an optimum level).

• Risk Management Framework - is the organization and process that is established such that the Risks

can be identified, analyzed, evaluated and treated as required by the Corporate Risk Management

Policy.

• Risk Owner - person or entity with the accountability and authority to manage the Risk.

• Risk Register: a document that identifies risks along with their severity and the actions and steps to be

taken to mitigate the Risk.


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• Risk Reporting: - is the process of reporting all key Stakeholders of the contents of the Risk Register(s)

at regular intervals

• Risk Treatment – process to modify the Risk (risk mitigation measure).

• Risk Updates – this is the process of updating the Risk Registers in the light of developments and/or at

pre-defined moments.

• SMART Action – this is an action designed to bring about an improvement. The action is specific,

measurable, attainable, reasonable and timely.

4. Standard Minimum Requirements of the Policy

4.1. There must be a Risk Management framework in place incorporating as a minimum all elements of

the Corporate Risk Management Policy and covering the following eight aspects of risk management:

1. Risk scoping

2. Risk identification;

3. Risk analysis;

4. Risk evaluation

5. Risk treatment

6. Risk reporting

7. Risk updates

8. Risk Management Process Review and auditing

4.2. Detailed Facility Risk Registers - A recognized methodology must be used by the LBC Facility to

conduct the Detailed Facility Risk Assessment(s) and arrive at the individual Detailed Facility Risk

Registers. The LBC Facility is free in the choice of methodology; however, we advise that the

international standard for Risk Assessment techniques (IEC/ISO 31010) be consulted when choosing

Risk Assessment techniques. The shape and form of Detailed Facility Risk Registers may vary per type

of Risk Assessment, risk aspect and level of detail. Examples of Detailed Risk Registers include: Process

Hazard Analysis (PHA), HAZOP, LOPA, Bowtie analysis, RI&E (Risk Assessment and Evaluation) and JSA.

4.3. The High-Level Facility Risk Register is arrived at using the methodology described in Appendix 1.

The responsibility to trigger an update of the High-Level Facility Risk Register rests with the High-Level

Facility Risk Register Owner at each LBC Facility who has been assigned with this task of owing the

Risk Register.

4.4. Risk Scoping (Establishing Context) - the objectives, strategies, scope and parameters of the activities

of the organization, or those parts of the organization where the Risk Management process is being

applied, should be established. When establishing context, the internal and external situations should

be considered. The management of Risk should be undertaken with full consideration of the need to

justify the resources used in carrying out Risk Management. The resources required, responsibilities

and authorities, and the records to be kept should also be specified

4.5. Risk Identification –all known Risks (external & internal) which could affect the achievement of the

objectives should be identified and logged in a Risk Register (together with the analysis, evaluation

and the Risk Treatment). As a minimum, the LBC Facility should consider the following aspects in

their risk management process:

• Human Resource Risk


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• Communication Risk

• Financial Risk

• Legal and Compliance Risk

• Commercial & Strategic Risk

• IT Risk

• Operational Risk

• Intangible

4.6. Risk Analysis –the identified Risks should be evaluated in context to assess the level of Risk. This

should be done by assessing the likelihood that the risk will present itself in combination with the

consequence

4.7. Risk evaluation –based on the Risk Analysis the risks should be evaluated and prioritized based on

pre-determined criteria to assess if the risk and the magnitude are tolerable. The choice of Risk

Treatment should be based on the priority. The organization should define criteria to be used to

evaluate the significance of risk. The criteria should reflect the organization's values, objectives and

resources. Some criteria can be imposed by, or derived from, legal and regulatory requirements and

other requirements to which the organization subscribes. Risk criteria should be consistent with the

organizations Risk Management Policy, be defined at the beginning of any Risk Management process

and be continually reviewed)

4.8. Risk Treatment – appropriate responses to each identified Risk for threats (or Risk exploitation for

opportunities) must be determined and implemented such that the level of Risk exposure is

optimized. Threats with negative impacts must be avoided, transferred or minimized. Any residual

risk must be accepted with suitable levels of contingency. Risk Treatment should be based on the

following hierarchy of control:

• Removal of the hazard

• Isolation of the hazard

• Administrative controls such as rotation of personnel

• Distribution of personal protective equipment

4.9. Agreed Risk Treatment measures must be assigned to a single Risk Owner and appropriate resource

must be made available to ensure that responses are implemented effectively. Risk Treatment

(actions) must be SMART. The possibility for secondary risks arising from agreed Risk Treatment must

be considered.

4.10. The Risks identified in the Detailed Facility Risk Registers must be linked to Emergency Preparedness

Planning which should include Incident prevention actions and Incident management and recovery

actions if there is an Incident

4.11. Risk Reporting - The results of the Risk Assessment process (Scoping, identification, analysis,

evaluation and Risk Treatment) must be recorded in a Risk Register. The Risk Register must contain

the following elements as a minimum:

• Unique reference number

• Date of first risk update

• Brief title of the risk

• Description of the risk


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• Likelihood of occurrence

• Assessment of all types of consequences

• Risk level – determined based on the highest level of consequence

• Risk responses together with current status

• Risk owner

• The Risk Register must contain information on all closed risks to provide an audit trail

4.12. Risk updates – all Risk Registers must be updated in the light of new information and/or progress

and/or Incidents. The updates must contain information regarding the results of Risk responses that

have been implemented, identify new Risks that have presented itself since the last update and check

the validity of existing Risk exposures. In any event, as a minimum all Risk Registers must be reviewed

every year.

4.13. Risk Management Process Review - To ensure that the Risk Management process is effective and

continues to support organizational performance and the achievement of the organizational

objectives, the organization should:

• Establish a Risk Management audit protocol and schedule

• Measure Risk Management performance against indicators, which are periodically reviewed

for appropriateness;

• Periodically measure progress against, and deviation from, the Risk Management process;

• Periodically review whether the Risk Management Framework is still appropriate for the

organization to realize its objectives.

4.14. The organization should establish clear internal communication and reporting mechanisms relating to

Risk Management.

4.15. Risk Management should be implemented by ensuring that the Risk Management process is applied

through a Risk Management plan at all relevant levels and functions of the organization as part of its

practices and processes.

4.16. All aspects of risk management activities should be documented and traceable. There must be an

auditable and regular training of employees and contractors to identify what constitutes a Risk.

4.17. Commitment -Sustained commitment by management as well as strategic planning is necessary to

achieve commitment at all levels. Management must:

• Communicate the Corporate Risk Management Policy Statement

• Define and endorse the Risk Management Policy

• Ensure where necessary that procedures are in place to deliver the minimum requirements

of the Policy;

• A Senior Manager must sign-off on the Risk Registers

• Identify key Stakeholders and develop and implement a plan as to how it will communicate

with Stakeholders

• Ensure that all persons involved in the Risk Management Process are competent in line with

the “Competent Person” definition

• Ensure via the appropriate training and allocation of resources that there is a culture of Risk

Management and that Risk Management forms a part of all decision making such that any

decision making is in alignment with the Corporate Risk Management Policy


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• Determine Risk Management Key Performance Indicators (KPI’s) that align with performance

indicators of the organization

• Align Risk Management objectives with the objectives and strategies of the organization

• Assign accountabilities and responsibilities at appropriate levels within the organization for

managing and monitoring the individual Risks identified and for managing and monitoring

the overall Risk Management process and Risk Management Framework

• Ensure that the necessary resources are allocated to Risk Management

• Ensure that the Risk Management framework for managing risk continues to remain

appropriate

5. References

• ISO 31000:2018 Risk Management –Principles and Guidelines

• IEC/ISO 31010 Risk Management – Risk Assessment Techniques

• Corporate Risk Management Policy Statement

• Corporate Risk Register Overview


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Appendix 1- Methodology for preparing High Level Facility Risk Registers and Corporate Risk Register

Overview.

The basic methodology used in the High-Level Facility Risk Register Spreadsheet for determining the impact

and likelihood of risk and the ultimate Risk Level is shown below.

Determination of Impact

Impact rating scale

Impact categories Minor Limited Significant Major

A - Harm to people

(physicaly/psychol

ogical damage)

Injuries or occupational

health issues requiring

no treatment (one or

more people)

injuries or occupational

health issues requiring

treatment but no

hospitalization and/or

resulting in ≤ 7 days

absence from w ork

and/or 21 days

restricted w ork (one

person)

Injuries or occupational

health issues (1 or more

persons) requiring

hospitalization and/or

more than 7 days

absence from w ork

and/or more than 21

days of restricted w ork.

Or an occupational

health issue resulting in

limited absence from

w ork but prolonged

discomfort (>21 days but

<90 days)

Death of one or several

individuals or an

occupational health

injury or illness resulting

in a permanent life

changing disability

B- Reputational

and/or Community

Not reportable to

regulator

No media attention

No community

involvement

No penalties

Local Media attention

and community

involvement lasting no

more than 1 day

Reportable incidents to

regulator

Isolated claim

Local Media coverage

and/or community

involvement lasting >1

day and < 1 w eek.

Relationship w ith

authorities damaged.

Multiple claims.

Local media or

community involvement

lasting > 1 w eek and/or

national or international

media attention.

Relationship w ith

authorities damaged

such that the licence to

operate or part of the

license to operate is

suspended.

Allegations involving

fraud or coverup of a

legally reportable issue

by more than one

manager.

Criminal law suit and/or

Class Action*.

C- Environmental No impact Limited & local impact /

easily remedied w ithin 1

day

Signif icant local impact

resulting in local

evacuation and/or local

road closure (diversion)

and/or instruction to stay

indoors or remediation

Major impact at regional

and/or national and/or

international level and/or

remediation lasting >5

days

D - Continuity of

LBC operations

and Customer

Service

Agreements

No disruption and/or no

impact on product or

service quality of LBC or

customer.

Disruption to the LBC

operations of ≤8 hours

that has no impact on the

customer or quality of

product.

Disruption of LBC

operations of >8 hours

but <24 hours and/or

the specif ication of the

customers product is

affected but the product

is fully recoverable

and/or the customer

receives a

claim/complaint from their

customer (internal or

external).

Major disruption of LBC

activities >24 hours

and/or specif ication of

customer product is

affected and the

product is not

recoverable and/or the

customer receives

multiple claims or

complaints from their

customers (internal or

external)

E- Financial $0 - $200k > $200k - $500k > $500k - $1 000k > $1 000k

* A Class Action implies legal action by a body operating on behalf of multiple claimants e.g. asbestos compensation groups


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Determination of Liklihood

Final Risk level

Likelihood rating scale

Unlikely Rare Possible Frequent

No history available or

once in > 50 years

Once in 25 years up to

50 years

Once in 5 years up to 25

yearsOnce in < 5 years

Unlikely Rare Possible Frequent

1 2 3 4

Maj

or

4 C B A A

Sign

ific

ant

3 C C B A

Lim

ite

d

2 D D C B

Min

or

1 D D D C

A 4 : immediate action required including possible temporary shut down

B 3 : mitigating measures required including possible Safety stand down

C 2 : ALARP (As Low As Reasonably Practicable) - requires active monitoring

D 1 : No additional action requiredAcceptable Risk

Likelihood

Imp

act

Unacceptable Risk

High Risk

Moderate Risk


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Appendix 2: Risk Management according to ISO 31000:2009


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GV 04 1 November 2015 1 September 2018 2.0 19



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Management of Change (MOC)


This Policy is defined to specify the minimum controls that must be in place to treat Risks resulting from any

Changes. The intent of the Policy is to prevent Incidents occurring that can damage People, Planet or Profit.


Definitions pertaining to this procedure are:

• Change – is an alteration or adjustment to any component, variable or property (except those

permitted within clearly defined responsibilities and boundaries)

• Designated Deputy: a person appointed as a substitute with power to act

• Emergency Change – A Change that must be introduced immediately to restore service due to an

Incident or a Change that needs to be implemented immediately to avoid an Incident. The normal MOC

process cannot be applied because the situation is an emergency and requires immediate action. This

Change must be authorized by the most senior member of the LBC Facility or their Designated Deputy

(NB: this does not mean the most senior person present at the time on the LBC Facility premises)

• MOC Final Approver – the person at the highest level charged with the ultimate sign off of the MOC

procedure thus allowing the implementation of Change to occur

• MOC Proposer – the person submitting the proposal for Change

• MOC Team – the Multidisciplinary Team involved in assessing the proposed Change

• Planned Change – A Change that occurs when deliberate decisions are made in an organization.

• Pre-Start up Safety Review (PSSR): a safety review conducted prior to startup (commissioning) of a

new or modified processing/manufacturing plant or facility to ensure that installations meet the

original design or operating intent, to catch and re-assess any potential hazard due to Changes during

the detailed engineering and construction phase of a project. The PSSR is a final check to ensure:

• that installation meets the original design and operating intent of process plant/facility

• safety, operating, maintenance and emergency procedures are in place and adequate

• appropriate Risk Assessments during engineering phase (e.g. HAZOP) have been carried out and all

action items have been completed

• any site modifications during construction phase have been properly controlled and noted

• training of each employee involved in the operating process is completed

• Replacement-in-kind (RIK) – Any item that satisfies the (design) specification of the item it is replacing

and does not result in a Change. Where no specification exists e.g. for non-physical Changes such as to

procedures, personnel, organizational structures etc. the Reviewer must consider the design and/or

functional requirements of the existing item and decide if the proposal is a RIK or a Change.

• Temporary Change – a Change that is expected to last less than 90 calendar days.

• Unplanned Change – A Change that is a result of unforeseen occurrences.


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3.1. There must be an MOC procedure in place to deal with the following sorts of Change:

• Planned Change or Unplanned Change

• Sudden or gradual

• Internally driven or externally driven

• Permanent Change or Temporary Change

3.2. The starting point of the MOC procedure must include the completion of the Corporate Social

Responsibility “Request for Change (RFC) questionnaire” available in the CSR-HSSEQ database.

3.3. There must be an auditable and regular training of all employees and contractors to identify what

constitutes a Change.

3.4. The MOC procedure must include a system to identify and define the roles and responsibilities.

3.5. The MOC procedure must include the involvement of any persons affected by the Change.

3.6. The MOC procedure must include an approval system whereby all MOC proposals are signed-off by the

MOC Proposer, The MOC Team and the MOC Final Approver.

3.7. The MOC procedure must require that all proposals for Change clearly document and identify:

• The roles and responsibilities

• Title of Change

• The scope of the Change

• The purpose of and motivation for the Change (if it is known, the reason for an external change

influencing the organization may not be known)

• The expected outcome of the Change (pro’s and con’s)

• The duration of the Change

• Dates that MOC meetings are held and a list of attendees

• Minutes of MOC meetings

• The system to be used to test the results of the Change

• The Risk Assessment

• Relevant standards, policies, procedures, P &ID documents (technical, design, HSSEQ etc.) and

regulatory requirements relating to the Change

• Any documentation such as procedures, policies, P &ID’s that need to be amended following the

Change must be identified.

• Further studies to be carried out e.g. hazard studies, financial studies, occupational health and

safety studies, environmental impact studies, production efficiency studies, energy studies etc.

• Experiences based on past Incidents

• If the Change is subject to a trial, the duration and measures for the trial

• The necessary review schedules during the assessment process

• The necessary review schedule (s) to assess the success of the Change once implemented.

3.8. The MOC procedure must include a Pre-Start-Up Safety Review process covering as a minimum the

following elements:


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• A final check to ensure that the Change has been carried out according to the MOC procedure

• A review and sign off by the MOC Proposer to ensure that the original intention of the proposed

Change has been met

• A sign off by all members of the MOC Team relating to all actions defined in the assessment of

the Change to ensure that the implementation phase does not proceed before all actions have

been satisfactorily completed by all involved parties

• A final sign off by the MOC Final Approver

• The timely release of appropriate and relevant information (communication) relating to the

Change to all levels within (and/or outside) the organization

• The establishment of a training protocol to train persons involved or affected by the change

• The proper and timely revision and/or release of updated documentation such as but not

exclusively operational procedures, maintenance procedures, emergency procedures,

organization charts, technical drawings, official company paper and literature and signage.

3.9. The MOC procedure must include a Change evaluation step that ensures:

• No incomplete actions remain

• Change performs as expected

• MOC is closed and documentation filed and retained

4. Standard Minimum Requirements Emergency Change

4.1. There must be a traceable Emergency Change Procedure in place with a contingency procedure to

cover situations in which proposed Changes cannot be subject to the full MOC procedure. Such a

procedure must incorporate as a minimum the approval of the Terminal Manager/Designated Facility

Manager or his Designated Deputy in his absence as the MOC Final Approver. There should be

provisions made for an emergency call out procedure ensuring that the Site Manager or his Designated

Deputy are contactable.

4.2. Such a procedure must include a clear description of what constitutes an Emergency Change.

4.3. There must be a system in place to catch up on the MOC paperwork and Risk Assessment as soon as

reasonably possible following an Emergency Change.

5. Archiving

5.1. There should be a system in place to ensure that all documentation associated with the MOC process is

archived for a period of 20 years.


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GV 05 28 March 2018 1 September 2018 2.0 22



Approved by CEO

John Grimes COO

Permit Application and Compliance


This Policy is defined to specify the minimum requirements that need to be in place to ensure that key

Stakeholders at all LBC Facilities are knowledgeable of the requirements and conditions included in any

regulatory Permit or License to operate. The intent of the Policy is to ensure that Stakeholders and their

direct reports follow current permitting and license conditions, as well as manage and control all Permit

and/or License amendments and/or modifications and/or new Permit/License applications.

This Policy applies to all Permits and Licenses issued by Issuing Authorities.



• Issuing Authority is an entity at a local, regional, or national level that provides oversight governing

safety, environmental, emergency preparedness, or other governmental authority such but not limited

to Port Authority, Coast Guard etc.

• License is defined as a document or certificate authorizing activities or specific functions such as

occupational licenses, or bonded storage licenses. Licenses may also be issued for specific equipment

such as weighbridges, boilers, or scales.

• Permit is defined as a document issued by an Issuing Authority that provides legal authorization to

operate or perform an operation and related activities including the requirements and conditions to

maintain compliance with the Permit. Examples are Permits issued such as Title V, and Environmental

permits.

3. Standard Minimum Requirements Permit Application & Compliance

3.1. The Management of Change (MOC) Policy and local MOC procedure shall be utilized to control all new

Permits and Licenses as well as any modifications to any Permit or License issued by local or

governmental authorities.

3.2. All current Permits and Licenses as well as correspondence shall be stored in the CSR-HSSEQ Database

for each LBC Facility as per local procedure.

3.3. All audits, audit reports and actions arising from audits relating to Permits and Licenses must be

managed in accordance with the Audit Reporting and Compliance Policy

3.4. There must be a local procedure in place that is fully traceable and auditable and includes the following

elements as a minimum:

3.4.1. The requirement that all relevant parties meet to discuss and sign off on the Permit strategy and

required Changes including design specifics, additions, deletions, and modifications before

submitting any application to the governing authority.

3.4.2. The requirement that all relevant parties and their direct reports physically review and sign off

on all Permits and Licenses and their amendments once received by the Issuing Authority.

3.4.3. A training matrix to indicate how Permit and License requirements and conditions will be

communicated to affected employees.


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John Grimes COO

3.4.4. A reference table to indicate all Permits and Licenses issued by governing authorities that are

required to legally operate each specific LBC Facility. This reference table must be reviewed and

where necessary updated annually as part of the Management Review. This reference table

must be uploaded to the LBC Document Management Site.

3.4.5. The reference table must also include a frequency of all required reports that must be submitted

to the Issuing Authority.

3.4.6. The reference table should be reviewed at regular pre-defined in the procedure intervals by an

accredited external independent consultant with specific local knowledge of License and

permitting procedures. The regularity of such reviews must be based on a risk assessed process.

3.5. There must be a system in place to monitor the renewal dates for all Permits and Licenses to operate.

This system should include an “early warning” alert to relevant parties such that applicable applications

are made in a timely manner, considering the necessary internal and external consultation process.

Each Region and LBC Facility should incorporate the use of the Action Manager and the Calendar

function on the LBC Document Management Site for tracking renewal dates.

3.6. The system should ensure that the “early warning” is issued to more than one person to manage Risk.

3.7. There must be a system in place to perform random internal audits at each LBC Facility to ensure the

most current Permit or License is stored on the LBC Document Management Site, conditions of the

Permit or License are being followed, and that training matrix is up to date. The results of such

compliance audits must form part of the annual Management Review, be in accordance with the Group

Audit Reporting and Compliance Policy. and a clear improvement plan must be developed if necessary.

3.8. Contractors and House-Contractor employees that perform work that can affect a condition or

requirement of our Permits or Licenses to Operate at an LBC Facility must receive traceable and

auditable training prior to task assignment. Examples are contract loaders, driver loaders, or tank

cleaning contractors.

3.9. There must be a system in place for archiving both digital and hardcopies of all Permits and Licenses for

a period of 20 years or more if legal requirements dictate.


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Management of Contractors


This Policy is defined to specify the minimum requirements that need to be in place to responsibly mitigate

Risks and manage all contractors working at any LBC Facility to prevent any negative impact on People,

Planet or Profit.



• Blacklisted –A Contractor Company or individual employee of a contractor company when banned

from working at an LBC Facility indefinitely or for a set period because of an indiscretion is said to be

blacklisted.

• Category 1 Contractor: Individuals employed with temporary contracts to work within the organization

including students and vacation workers. For Incident statistics, the worked hours of Category 1

Contractors will be classified as LBC Personnel worked hours.

• Category 2 Contractors: are companies or individuals engaged for either discrete project outside the

operational and/or office area or companies or individuals engaged under contract to carry out specific

tasks or provide specified services within the operational area (including office areas).

• Contractor Manager – this is one designated person at a facility with overall responsibility for ensuring

compliance with the Management of Contractor Policy for all contractors.

• House Contractors: Category 2 Contractors are sometimes referred to as House Contractors if they

have a daily or weekly presence in the facility.

• Preferred Supplier – this is a contractor who has quantitatively been ranked based on their actual

performance and/or expected performance and is considered suitable to work at an LBC Facility.

• Responsible – in the context of this Policy means doing the right/ethical thing to ensure that any

negative impact to People, Planet and Profit are minimized and the positive impacts maximized.

• Service Supplier – a service supplier is a supplier of goods or services that does not fall into the

Category 1, or 2 Contractor definition. Typically, the Service Supplier will deliver goods to the LBC

Facility but will not conduct any on-site work or they will deliver services that do not involve any on-

site work.

3. Standard Minimum Requirements All contractors

3.1. There must be a designated on-site Contractor Manager responsible for ensuring compliance with

this Policy for all contractors. This person may delegate this task to individual employees within the

organization. Delegation of this task must be documented and traceable.

3.2. There must be a documented and traceable audit process in place to monitor the performance of a

contractor who has been engaged to carry out work for LBC against the contractual requirements

(including HSSEQ performance). This audit performance should include feedback to the contractor.

3.3. There must be a system in place to quantitatively rank a contractor’s expected and/or actual

performance and based on this ranking to determine if they are a Preferred Supplier.


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3.4. Each LBC Facility must have a central register detailing the contractors approved to work at the LBC

Facility (Preferred Supplier list). This register should include all documentation (or clear references to

all documentation) relating to the contractor (as defined by this Policy). The list should clearly define

the category of the contractor i.e. 1 or 2 and must be maintained / updated annually.

3.5. There should be a central register held detailing the names of all contractor companies or individual

employees of contractor companies who have been blacklisted from working on LBC Facilities, the

reason for the ban and the duration of time for which the ban has been imposed. This list must be

maintained and updated annually.

3.6. Prior to the commencement of work all contractors must be given a traceable and appropriate to the

LBC Facility orientation (including HSSEQ training and the emergency procedures). A participant or

attendee list must be presented, signed and archived.

3.7. It is not permitted for a Contractor company to sub-contract more than 70% of the labor to another

entity without prior and written permission from LBC

3.8. If more than 70% of the labor will be sub-contracted permission will only be given by LBC upon

receipt of a specific risk mitigation plan addressing this point approved by LBC.

4. Standard Minimum Requirements Category 1 Contractors

4.1. Category 1 Contractors should be treated in all aspects as LBC employees.

5. Standard Minimum Requirements for Category 2 Contractors

5.1. There must be a documented and traceable Contractor Management process that as a minimum

contains the following elements:

• Incorporation of the roles and responsibilities of the contractor in the contract documents

• For Category 2 Contractors a process must be in place for embedding the duties of the Category

2 contractor in a contract.

• Pre-qualification Process – A list of contractors must be available with actual and/or expected

performance. The list must also provide information about if the contractor is considered

suitable enough to be on a Preferred Supplier list. This pre-qualification process should be

based on a quantitative ranking system that results in a weighted score upon which a decision

can be made to select a contractor. This system should include as a minimum the criteria set

out in Appendix 2. NB: the LBC Facility may decide what quantitative methodology they will

apply to determine the importance and/or relevance of items in Appendix 2. However, the

criteria should be “Responsible”.

• Pre-bid meeting – LBC should conduct a pre-bid meeting with contractors to inform them of

the scope and expected deliverables of the project and to discuss potential HSSEQ hazards and

any applicable LBC policies and procedures.

• Bid documents – Contractors’ bid documents must address the expected deliverables as

discussed in the pre-bid meeting and also include a site specific HSSEQ plan that identifies and

addresses all HSSEQ Risks and takes account of all applicable LBC operating procedures.

• Bid Assessment and Selection – Where possible a minimum of three bids must be obtained.

The bid assessment and selection process must include a quantitative weighing system in which


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the cost, technical capabilities and HSSEQ Risk Identification and Risk Treatment plan are

assessed. The HSSEQ plans must receive the same consideration as cost and technical

capabilities. The LBC Facility may decide what quantitative methodology they will apply to

assess and select the bids. However, the criteria should be “Responsible”.

• Contract terms – the contract document must include, a statement of compliance obliging the

contractor to provide adequate supervision (including safety supervision), comply with

applicable regulatory requirements, all applicable LBC HSSEQ policies and procedures and all

other relevant LBC Policies and procedures. The contract should also oblige the contractor to

submit a comprehensive HSSEQ plan and demonstrate adequate insurance coverage for

worker’s compensation and general liability, indemnification agreement. The contract should

include termination clauses or penalties for lack of performance including HSSEQ performance.

The requirements for supervision on the job from the contractor must be defined.

• Contract/contractor approval – there should be a process in place to seek advice from and

involve a LBC Legal representative at the earliest stage of the contractor selection process. All

contracts should be approved by legal prior to signing.

• Pre-job conference – LBC must conduct a pre-job conference with the successful bidder

including a final review of the contract deliverables and to review the HSSEQ expectations

based on the HSSEQ site specific plan including the mechanisms for reporting of near misses,

sustainable safety behavior observations damages and injuries.

• Monitoring and evaluation – LBC must monitor the contractors’ work and carry out formal

documented reviews with them that include all aspects of the HSSEQ plan and the agreed

deliverables and timing of the work being executed. Actions should be agreed and documented

and a formal documented check carried out to assess improvement.

• End of job and feedback – There should be a formal and documented “acceptance of work”

stage and the overall performance (including HSSEQ) of all contractors should be evaluated at

the end of the job to decide if they remain on the Preferred Supplier List or will be blacklisted

(permanently or temporary). This should be shared with the contractor. Records of these

evaluations should be kept and used in future selection processes. The ongoing validity of these

documents should be checked before future bidding begins.

• Temporary Blacklisting – If a contractor is temporarily blacklisted, there should be a clear

written plan in place stating the criteria under which such a blacklisting will be lifted.

5.2. In addition to the Pre-Job conference, there should be a daily pre-work planning meeting and there

must be a permit to work system compliant with the Permit to Work Policy covering as a minimum

the following:

• Set out the work to be done, the specific location of the work to be done, the Risks identified

and the required safe work procedures and measures to reduce Risk.

• Be reviewed every shift and re-issued if a change in the condition of work scope has occurred.

• Be signed by a designated LBC person for the current shift who is the person with

responsibility for the geographical area or task in which the contractors are to work and/or by

a designated competent authority if a specialized field expertise is required e.g. gas

monitoring.


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5.3. The Permit to Work must be discussed by the designated LBC person with the contractor in the field

at the specific Work Location.

5.4. The designated LBC person is responsible for:

• Ensuring where practical that the contractors work area is cordoned off and /or clearly

demarcated,

• Ensuring that the permit to work is available at the Work Location,

• Monitoring the contractors’ work to check compliance with the permit conditions,

• Recording and reporting any HSSEQ Incidents,

• Documenting and acting upon HSSEQ improvement ideas

6. Standard Minimum Requirements Service Suppliers

6.1. Service Suppliers entering the LBC Facility to deliver goods or services should be subject to basic fit

for the purpose safety instructions.

6.2. When obtaining services or goods, where possible a minimum of three bids must be obtained and

the selection of the Service Supplier must involve a quantitative evaluation of all parameters relevant

to the services or goods to be procured such that a responsible and balanced selection of Service

Supplier can be made.

6.3. Where contracts are entered with Service Suppliers, a legal representative must be involved at the

earlier possible point in the process. All contracts should be approved by legal prior to signing. If

approved by legal, preapproved standard contracts may be used.

6.4. LBC must periodically monitor the Service Suppliers performance against the agreed deliverables and

where necessary register a Service Supplier as being permanently or temporary Blacklisted or a

Preferred Supplier.


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Appendix: Pre-Qualification Checklist

NB: where appropriate the contractor company should provide documented evidence in the form of minute

of meetings, inspection reports, Policy documents, organization charts, audit reports, personal and

organization certification documentation etc.

Item

Number

Item for consideration

1. Does the contractor have a valid HSSEQ Policy statement? Valid means less than 3 years old and is

the Policy signed by the person highest in rank? (e.g. CEO/Director/General Manager)

2. Has the contractor provided an overall organization chart relevant to the tender?

3. Is there a professional HSE employee in the company?

4. If not does the organization have access to the a HSE professional?

5. Does the HSE professional report directly to the person highest in rank in the company?

6. If not how is the independent role of the HSE professional protected?

7. Is there a clear and evidenced HSE organization?

8. Does the contractor have an evaluation system in place in which the performance of employees is

evaluated at regular intervals?

9. Does this evaluation system include evaluation of individual HSE performance?

10. Is the highest in rank actively involved in HSE? (evidence of work place inspections and/or minutes

of SHEQ committee meeting should be available)

11. Does the contractor have a Total Quality Management System (TQM) such as ISO 9001?

12. Is there evidence of a Plan, Do, Check, Act (PDCA) cycle for continuous improvement?

13. Is there a formal Health and safety management system such as OHSAS?

14. Is there an environmental management system?

15. Does the Contractor have HSSEQ policies/procedures/work instructions appropriate to the work

that they will carry out at LBC? The contractor should provide a copy of their HSSEQ policies and

these should be evaluated for completeness.

16. Does the contractor carry out an Annual Management Review?

17. Is the Annual Management Review coupled to an improvement program?

18. Does the organization have HSSEQ related KPI’s in place for the group?

19. Does the organization have HSSEQ related KPI’s in place for individual employees?

20. Does the organization have a Contractor Management Policy in place to manage the risks associated

with sub-contracting?

21. Does the Contractor Management Policy of the contractor contain the same elements as the LBC

contractor Management Policy?

22. Can the contractor guarantee that no more than 70% of the job will be sub-contracted?

23. Does the contractor have an up to date (not more than 3 years old) RIE i.e. formal risk inventory and

evaluation document and associated plan of action detailing the risks associated with their

activities?

24. Have employees been trained with regards to the RIE and mitigation measures identified?


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25. Does the contractor have a sustainable safety behavior program?

26. Does the contractor have a LMRA program?

27. Does the contractor have a system in place to carry out task risk analysis?

28. Does the contractor have a system in place to carry out regular and documented work place

inspections?

29. Does the contractor have a formal and regular HSSEQ training program for employees?

30. Does the contractor have a competency/function matrix?

31. Can the contractor provided details (CV’s and certificates) of the competencies of persons to be

engaged for the work?

32. Has the contractor a sanction process?

33. Does this sanction process include sanctioning for HSSEQ demeanors?

34. Does the contractor address the risks associated with language barriers?

35. Does the contractor have a medical surveillance program for her employees?

36. Has the contractor provided a plan to demonstrate how they will be compliant with all LBC

applicable procedures and policies (including HSSEQ)?

37. Has the contractor provided references from other customers?

38. Has the contractor been subject to an audit by a customer in the last 12 months and what was the

result of the audit?

39. Has the contractor provided their HSSEQ performance based on OSHA guidelines for the last five

years for both own employees and sub-contractors?

40. How does the contractor’s safety performance compare with industry standards for their branch?

41. Has the contractor provided their emergency plan?

42. Has the contractor been able to supplier a typical example of a HSSEQ plan and what is the quality?

43. Does the contractor have an Incident classification, recording and investigation process?

44. Is the Incident investigation methodology based on finding root cause?

45. Has the contractor company got the necessary permits/licenses to operate to carry out activities in

the region/country where the work will be executed

46. Is the contractor subject to any investigation by the authorities at this time for any breaches of legal

compliance (including HSSEQ)?

47. What is the inspection regime used by the contractor to guarantee that equipment and appliances

used on the job will be safe and conform legal requirements?

48. How will the equipment and appliances of sub-contractors be monitored and evaluated?

49. Has the contractor provided evidence of adequate insurance coverage for workers compensation

and general liability and indemnification agreement?

50. Has the Contractor fulfilled his Social Security obligations?

51. Has the solvency of the contractor been verified by a “Dun & Bradstreet” report or other equivalent

report? See http://www.dnb.com/

52. Does the contractor show evidence of a CSR Policy?

53. Does the contractor CSR Policy cover the following elements?

▪ Minimum age of labor

http://www.dnb.com/


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▪ Forced labor

▪ Freedom of association and right to collective bargaining

▪ Working hours

▪ Workers holidays

▪ Workers’ wages

▪ Anti-discrimination

▪ Complaints and whistle-blowers procedure

▪ Anti-corruption


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GV 07 1 September 2016 1 September 2018 3 31



Approved by CEO

Bert Goyvaerts Corporate HR Director

Recruitment 1. Purpose and scope

The purpose of this policy is to provide a framework to appoint, recruit and retain employees of the highest

calibre at all levels within the approved FTE budget. This policy is also intended to enable Human Resources

(HR) to track, control and report FTE developments and the quality of the hiring process.

This policy applies to all managers within LBC (Hiring Managers) hiring employees – either temporary (+ 6

months) or permanent – at all levels within the organization and for all hires. It should be applied in all regions

and managed and secured by HR.

2. Responsibility and authority Specific to this Policy

The Corporate HR Director - is responsible to define the minimum requirements of the policy, to regularly

review the policy for relevance and to audit compliance with the policy.

The Local appointed HR Business Partner - is responsible to manage and apply the policy in the local site or

region.

The Hiring Manager - is responsible for adhering to this policy and for following the instructions of the local

appointed HR Business Partner throughout the search process. Where the Hiring Manager is making use of a

team to hire an employee, the Hiring Manager is responsible for ensuring adherence with this policy.

3. Definitions Specific to this Policy


• Assessment: a testing program that the candidate must follow to decide if the candidate is suitable for

the position and obtains the necessary skills.

• External Posting: posting of vacancies on all other canals, open for all candidates.

• Hiring Manager: is the person who is directly responsible for steering the team that the new employee

will join.

• HR Business Partner: is the local HR person responsible for all HR related tasks in the recruitment

process of a new employee.

• Internal Posting: posting of vacancies on various internal LBC canals, open for employees only.

• Recruitment Agency: an agency assigned with searching and screening suitable candidates for the

vacancy and presenting them to the company.

• References: a contact person from a previous employer of the candidate.

• Screening Committee: a committee assembled with a number of LBC staff members to screen

candidates, provide advice and take decisions in the recruitment process.


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4. Standard minimum requirements of the policy

4.1. Pre-recruitment steps

4.1.1. Approval of new hires

The Hiring Manager will provide the local HR department with the Recruitment Approval form

(annex 1). This document needs to be fully completed to be approved by the HR department

before starting the search. All documents require final approval from the Group HR Director and

the CEO in case it is a new, non-budgeted, hire. Local HR will send a copy of the agreed form to

corporate HR.

4.1.2. Job description

Before starting the search, the intended Hiring Manager must produce or update the job

description with the assistance of the local HR Business Partner by using the standard Function

Description format (annex 2). The job description should at least describe the place in the

organization, purpose of the role and key accountabilities. In addition, the profile requirements of

the position should be clearly stated, such as skills, competences, experience, education,

knowledge, desired behavioral traits, etc. The job description needs to be agreed upon by local HR

and the manager of the Hiring Manager. Without an agreed upon job description the search

cannot start.

4.1.3. Remuneration package

An indicative remuneration package needs to be agreed upon between the Hiring Manager and

the local HR Business Partner. Based on the profile information and the local salary benchmark the

local HR Business Partner will be able to indicate base salary and total cash. This package will be

agreed upon via the final Recruitment Approval form (annex 1) and will be reviewed by Group HR

Director and approved by the CEO.

4.1.4. Internal Posting

All vacancies must be visibly posted locally by the local HR Business Partner (e-mail and notice

board) and if applicable regional or global postings should be communicated via e-mail. Internal

Posting is intended to invite interested employees to apply for the position and to invite

employees to share a referral candidate from their own networks. Applicants and referrals need

to be submitted to the appropriate HR Business Partner as indicated in the Internal Posting.

4.1.5. External search

The applicable HR Business Partner, in consultation with the Hiring Manager, will assess and

determine the need to engage a search/recruitment agency and/or to directly advertise the post

externally. The local HR Business Partner will determine the preferred agency and/or preferred

advertisement media with the Hiring Manager. In case of an agency the HR Business Partner will

negotiate rates and conditions. Any contract established with an agency must be reviewed by the


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Group Legal department. At least 3 potential agencies must be contacted, unless there is a specific

contract between LBC and a recruitment company.

4.2. Recruitment Process

4.2.1. Preselecting candidates

All direct applicants, as a result of Internal Posting, referral or direct External Posting must submit

a full resume. Preselection of the resumes with reference to the defined job requirements will be

carried out by the HR Business Partner. Contracted search agencies must present a preselection of

the resumes with reference to the defined job requirements to the HR Business Partner.

4.2.2. Selection

All preselected resumes (long list) will be shared and discussed with the Hiring Manager to define

the top 3 – 5 candidates (short list).

4.2.3. Time-Frame

Once the interview process has begun the HR Business Partner will clearly define the expected

process to the short list candidates and define timelines to manage expectations of the

candidates.

4.2.4. Interviews

The HR Business Partner will make appointments with the preferred (short list) candidates. The

candidates will have an interview with the HR Business Partner and the Hiring Manager (maximum

3 persons per interview).

Before the final selection/decision a candidate will have had at least 2 interviews with a minimum

of 3 LBC staff members. (For blue collars we accept that there is only 1 interview with at least 2

LBC staff members.) If necessary there can be a third-round interview, depending upon the

function. In order to make the process as efficient for LBC and the candidate as possible and to

give the candidate a good impression of LBC 3 rounds is the maximum.

All members of the Screening Committee (at least 3 members, including HR and the Hiring

Manager, will fill out an Interview Evaluation form (annex 3). This form will be used for the final

evaluation and will be filed in the candidates’ record.

4.2.5. Assessment

The HR Business Partner and the Hiring Manager will decide before the startup of the process

whether an assessment will be a part of the selection procedure. An Assessment is required for all

positions from director’s upwards.

The assessment must not be used as pure selection tool. It is a tool to be used as a guideline to

assist in decision making during the final interview.

4.2.6. References


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The HR Business Partner can request reference contacts from the final candidates. (not applicable

for blue collars) These reference(s) must be shared with the Screening Committee in the final

evaluation. References must be treated confidential and must be filed in the candidates’ records.

4.2.7. Evaluation

The HR Business Partner will organize an evaluation session with the Hiring Manager and possible

other participants in the interview process including the members of the Screening Committee.

Evaluation of the short list candidates will take place in reference of the agreed job description

and based on input from resume, assessment (if applicable), interviews and the evaluation forms.

The evaluation discussion is intended to have as an outcome a shared ranking of the candidates

and agreement on the preferred candidate.

In the case of unresolved division of opinion, the Corporate HR Director must be invited to

facilitate the process to resolve the division of opinion.

4.3. Offer

4.3.1. Offer to candidate

The agreed remuneration package in the recruitment approval form will be checked against the

present remuneration of the candidate and the profile and competences of the candidate. Based

on this reassessment (by the HR Business Partner) a package offer will be prepared by the HR

Business Partner in close cooperation with the Hiring Manager. A proposal will be made in writing

to the preferred candidate. Negotiations with the candidate will be conducted by the HR Business

Partner in consultation with the Hiring Manager. After the candidate agrees with the proposal the

HR Business Partner will prepare a contract to be signed by both parties.

4.3.2. Refusal of offer

In the event that the preferred candidate refuses the offer and consensus cannot be reached. The

HR Business Partner and Hiring Manager will assess the suitability of the “runner up” candidate if

there was a runner up. If consensus is reached step 6.3 can be repeated with the runner up. In

the event that there was no “runner up” candidate or the “runner up” is deemed unsuitable the

recruitment process will begin again.

4.4. Communication with applicants

The HR Business Partner (or contracted recruitment agency) will send all unsuccessful applicants

for a position within LBC a thank you letter/e-mail. The HR Business Partner should ensure that

this item is a contractual requirement of the recruitment agency where one is involved.


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Appendix 1

LBC RECRUITMENT FORM (for white collars)

Position title:

Start date: Click here to enter a date.

Supervisor/manager:

Budgeted:

☐ Yes

☐ No

Department/cost center:

Choose an item

Location:

Choose an item.

Employment type:

☐ Employee

☐ Contractor

☐ Temp

Contract type:

☐ Contract of indefinite duration

☐ Contract of definite duration:

And date:Click here to enter a date.

Schedule:

☐ Full-time

☐ Part-time: ………%

Yearly gross salary Employee:

Rate Temp/contractor:

(day rate ☐ or hour rate ☐)

Currency: Choose an item.

Agreed notice period:

Benefits:

☐ Car & fuel card: car level Choose an item.

☐ Pension insurance

☐ Medical insurance

☐ Mobile phone: Choose an item.

☐ Laptop

☐ APA: Choose an item. %

☐ Creditcard

Other benefits:


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APPROVAL

NAME POSITION TITLE DATE

Approval for manager

Click here to enter a

date.

Approval for HR


date.

Final approval

(Regional Business

President or ELT

member)


date.


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Appendix 2

Minimum elements of the function description:

• Function Title

• About LBC

• Purpose of the function:

• Reporting Line:

• Key Interfaces:

• Key Responsibilities / accountabilities

• Knowledge, Experience and Education

• Competencies


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Onboarding


The purpose of this policy is to provide a framework for a common and responsible approach to bring new

employees on board in the LBC Group, to share our values and standards and to develop the necessary skills,

knowledge and behavior for New Joiners to become effective contributors to the organization.

This policy applies to all managers, within LBC, hiring and bringing on-board new employees – either temporary

or permanent – at all levels within the organization. It should be applied in all regions and managed and secured

by HR.

2. Responsibility and authority specific to this policy

• The Corporate HR Director - is responsible to define the minimum requirements of the policy, to

regularly review the policy for relevance and to audit compliance with the policy.

• The local appointed HR Business Partner - is responsible to manage and apply the policy in the local site

or region.

• The manager - is responsible for adhering to this policy and for following the instructions of the local

appointed HR Business Partner throughout the onboarding process.

3. Definitions specific to this policy


• Buddy: collaborator or colleague who is working in the department or in the same team as the New

Joiner. The buddy will accompany and coach the New Joiner during his introduction and predefined

training period.

• HR Business Partner: is the local HR person responsible for all HR related steps in the onboarding of

the new employee.

• Manager: the person who is directly responsible for steering the team that the new recruit will join or

who the new employee reports to. He or she will also determine and plan the evaluation moments

together with the new employee.

• Mentor: The mentor is responsible for the execution of the training, development and the follow up of

the New Joiner.

• New Joiner or new employee: This is a person joining LBC as a new member and is foreseen to stay for

a period longer than 6 months (not a short-term temp).


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4. Minimum requirements and standards of the policy

4.1. Pre-boarding steps

4.1.1. Onboarding form

If the new LBC employee needs an account, the local HR Business Partner will provide an

onboarding request (Annex 1 – Onboarding form) to the IT team via the ticketing tool.

The onboarding form includes the specific needs for communication tools, software and an access

pass/badge to the facility for the New Joiner

4.1.2. Working tools

For a white collar, all working tools will be ordered by the local HR Business Partner via the

onboarding form (Annex 1).

For a blue collar, all working gear and clothes will be ordered by the Manager. HR will provide the

necessary information to the Manager.

4.1.3. Communication

The local HR Business Partner will take the initiative to prepare an announcement to be sent out a

week before the first working day of the New Joiner. HR will create the message in consultation

with the Manager.

4.1.4. Assign a Buddy or Mentor

The local HR partner and the Manager will assign a Buddy and a Mentor for the New Joiner at the

latest the week before the starting date of the new employee.

4.2. Onboarding standards

4.2.1. First day

4.2.1.1. Welcome and tour

The Manager will welcome the New Joiner on the first day and will provide all working tools. On

the first day, the New Joiner will get a tour of the site. In case the Manager is not able to welcome

his new team member, he will assign another person and inform the local HR Business Partner.

4.2.1.2. HSSEQ induction

The first day a New Joiner receives the necessary HSSEQ standard training of the facility.

4.2.1.3. Buddy and Mentor introduction

On the first day, the New Joiner will be introduced to his Buddy and Mentor.

4.2.1.4. Important information about the company

HR will provide a binder/information map with the following corporate information:


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• LBC Mission Statement

• CSR Mission and Values

• Whistle Blower policy

• Corporate Organization Chart

• LBC Sustainable Safety Behavior Program (PEER)

Besides the corporate information local HR needs to provide all necessary information regarding

the local organization and local working rules:

• Local working rules

• Local administrative procedures (holidays, expenses,…)

• Applicable Group policies

4.2.1.5. Function description and position in the organization

On the first day the new employee receives a copy of his function description and information on

his position in the organization.

4.2.2. 6 months training program

The Manager and the Mentor will introduce the 6 months training program to the new employee.

The new employee should be aware of the different milestones and expectations of the program.

A copy of this program should be shared with the local HR department.

4.2.3. PEER

Within the first 3 months of the induction period the new employee should get a complete and up

to date PEER training on the site. The local HSSEQ team will train the new employee, blue and

white collar, in all PEER phases as already implemented in the LBC Facility.

4.2.4. Competition law

HR will assess the positions that need to follow a training on competition law within the first

month of the onboarding. This training is mandatory for all employees at director level, terminal

managers and employees in the sales and marketing departments.

4.2.5. Review sessions

Feedback is very important during the onboarding period. At least 2 times during the onboarding

period of 6 months a new recruit should have a formal review, the first review after 1 month and

the second review between the third month and the end of the onboarding period. The following

items should be assessed during this review:


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• Learning progress: How fast is the newcomer picking up on his tasks?

• Technical skills: What is the status on the necessary technical skills for the job?

• Behavior: Are there any behavioral issues?

• Connection with the company: Does the recruit understand the company values

and mission?

• Attitude and integration in the team: Does the new person fit in the team? How

well is he integrated?

Local HR can provide a tool for this review process. The filled-out form should go to your local HR

department.

4.2.6. Evaluation of the onboarding process with the new employee, Mentor and Manager

As a quality check the local HR Business Partner will have an evaluation of the onboarding process

after 1 month and after 6 months.

4.3. Off boarding

4.3.1. Off boarding form

The off-boarding form is a local checklist provided by the local HR Business Partner to check the

following issues:

• Restitution of all working tools including the access pass/badge.

• Account & OOO (out of office): The local HR Business Partner will inform IT to close

the account of the leaver and will provide IT with a dedicated out of office message.

4.3.2. Exit interview

The local HR Business Partner will have an exit interview with all leavers (except in the case of

termination for cause) of the company. This exit interview will be shared with the local site

responsible and the local HR Business Partner will provide feedback to the Manager of the leaver.

The exit interview will be archived in the personnel file of the leaver.

4.4. Tracking and reporting of the process

Tracking and reporting the process will be the responsibility of the HR Business Partner using an

onboarding checklist.


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Efficiency and Innovation reward scheme


This policy is defined to provide minimum requirements for the Group wide reward scheme designed to

stimulate and reward employees (and/or teams) for suggesting Efficiency and Innovation Ideas that are

aligned with the LBC Group Strategy, Mission, Vision and Values and additionally reward employees (and/or

teams) for ideas that are judged as feasible for successful implementation and are expected to result in a

significant monetary and/or non-monetary benefit.

This policy applies to Efficiency and Innovation Ideas suggested by eligible employees working at LBC and

related to any activity in any part of the LBC organization.



• Efficiency and innovation Idea: a responsible idea that if implemented is expected to result in a

monetary and/or non-monetary improvement of minimum 5% on an annual basis, will contribute to

the Group Strategy and is fully aligned with the Mission, Vision and Values of the organization.

• Group Mission: To create a sustainable and proactive culture in which all risks are identified and

treated responsibly such that the positive impact of our decisions and activities on society is maximized

and any negative impacts minimized.

• Group Strategy: Further Optimize, Build-out, Expand

• Group Values: Responsibility, Transparency, Respect, Integrity, Empowerment

• Group Vision: There is no such thing as a dangerous product at least not when under our care.

• Improvement: is a betterment resulting in but not limited to reduced costs, improved profits, time

savings, reduction of ergonomically repetitive acts, reduced energy and disposable items usage,

increased recycling, health benefit, comfort benefit etc.

• Participation Gift Voucher: this is a nominal reward in the form of a € 10 (or local currency equivalent)

gift voucher that will be awarded to all persons submitting an idea to the [email protected] email

address, with the minimum required information (Minimum Criteria. This voucher will be awarded a

maximum of 3 times per contributing employee in any 12-month period.

• Reward bonus: The Reward Bonus will be given to an employee and/or team who propose an idea that

meets the Minimum Criteria of the policy (section 5.3) and the Additional Criteria (section 6.2). This

reward may be awarded a maximum of one time in any 12-month period to any individual. The Reward

Bonus is € 1.000 net value (or $ 1,000 net value) for an individual who submits an idea or € 2.000 net

value (or $ 2,000 net value) for a team of two who submit an idea (to be divided equally between both

individuals) or € 3.000 net value (or $ 3,000 net value) for a team of 3 or more who propose an idea (to

be divided equally between the team members).

3. Participation Gift Voucher

3.1. All individuals who submit an idea that meets the Minimum Criteria regardless of whether it meets

the Additional Criteria and regardless of whether it is selected as being feasible for implementation

mailto:[email protected]


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will be awarded a Participation Gift Voucher of € 10 (or $10). In the case of an idea being submitted

by multiple parties (team), each individual member of the party will receive this Participation Gift

Voucher.

3.2. The Participation Gift Voucher will be awarded a maximum of 3 times per employee in any 12-month

period.

3.3. The idea must be submitted by e-mail to [email protected] and must contain the following minimum

information to be eligible for the efficiency Participation Gift Voucher:

• Name of idea generator(s)

• Brief description of the idea and its expected benefits (monetary and/or non-monetary)

• Where the idea could be implemented (department, local, global etc.)

4. Reward Bonus

4.1. Any individual or team who submit an idea that meets the minimum criteria and the additional

criteria will be eligible for the Reward Bonus.

4.2. Additional criteria:

• The idea must be expected to result in a monetary and/or non-monetary improvement of at

least 5% on annual basis.

• The idea must contribute to one or more of the three pillars of the Group Strategy and be

aligned with the Group Values, Mission and Vision.

• The idea is selected by the Selection Committee for implementation.

5. Selection Process for the Reward bonus

5.1. The Selection Committee will determine if the idea contributes to the Group Strategy and is in line

with the Group Mission, Vision and Values.

5.2. The Selection Committee will discuss each submitted idea and evaluate it based on merit to

determine if it meets the above Minimum and Additional Criteria and to check if it is likely to result

in a monetary and/or non-monetary Improvement of at least 5%.

5.3. Where necessary the Selection Committee may ask for further information from the person(s)

submitting the idea or other experts to determine the Improvements that are possible.

5.4. The Selection Committee will determine the feasibility of implementing such an idea in the

organization. Their decision is final.

5.5. If an idea is judged by the Selection Committee to meet all the criteria and be feasible to implement,

it will be awarded the Reward Bonus

5.6. An individual may only receive the Reward Bonus once in any 12-month period.

5.7. Where it is difficult to assign a monetary value to the Improvements that an idea is expected to

achieve, such as may be the case with for example, an idea that delivers a comfort or well- being

benefit, the Selection Committee will decide on merit if the Improvements are sufficient to be

worthy of the Reward Bonus. Their decision is final.

5.8. Person(s) receiving a Reward Bonus will be informed in writing by the Selection Committee and their

idea and - after obtainment of their permission thereto - their name(s) will be made public within

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5.9. The Reward Bonus will be paid out with the next due salary.

5.10. The Reward Bonus does not have to be paid back if the Improvement(s) turn out to be less than

anticipated following implementation or if it is subsequently decided not to implement the idea.

6. Exclusions

6.1. Ideas that have already been formally identified or are in progress at the date this policy is released

are not eligible to be submitted. Such entries will also not be eligible for the Participation Gift

Voucher.

6.2. Members of the ELT, Directors and Terminal Managers are excluded from this scheme.

6.3. Contractors are excluded from this Scheme.

6.4. Any employee at Managerial level who is a member of an Operational Excellence Team is excluded

from this scheme.

6.5. Ideas may be submitted either individually or with multiple entry names (team idea).

6.6. In the case of an employee submitting an idea that is not their own, they must also include the name

of the person(s) who made the suggestion. If this is not done the idea will not be eligible for the

Participation Gift Voucher nor the Reward Bonus.


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Audit Reporting and Compliance


The purpose of this policy is to ensure that there is adequate corporate Governance regarding the

scheduling of internal and external audits, the auditing process, the central registration of audit reports and

also to ensure that any proposed improvement actions are responsible and executed in a timely manner.

This policy applies to all internal and external Audits at all LBC Facilities.



• Audit is a systematic, independent and documented process for obtaining audit evidence (records,

statements of fact or other information which are relevant and verifiable) and evaluating it

objectively to determine the extent to which the audit criteria (set of policies, procedures or

requirements) are fulfilled.


3.1. Internal Audits should be planned at the start of the financial year and the dates submitted to the CSR

Team no later than July 15th. The scheduling of internal Audits should be balanced across the whole

financial year and based on a Risk Assessment. If the date of a scheduled internal Audit changes this

should be communicated to the CSR Team immediately.

3.2. All internal Audit reports and the final external Audit reports and all other written communications

received from external auditing body regarding remarks or non-compliances should be placed on the

LBC Document Management Site.

3.3. The scheduling of all external Audits should be submitted to the CSR Team as soon as dates are

known.

3.4. When provisional dates are confirmed this should be communicated immediately to all members of

the CSR Team. The LBC Facility Manager or Designated Facility Manager must arrange for the Audit

dates to be placed in the calendar on the LBC Document Management Site.

3.5. A member of the CSR Team should be invited to the close out meeting of all external Audits (either in

person or virtual via telephone/video conferencing). The CSR Team will decide if it is necessary to

attend.

3.6. When external spot Audits occur that are not scheduled, their occurrence and the provisional

outcome should immediately be communicated in writing to the CSR Team Members.

3.7. All remarks and non-compliances arising from all Audits (internal and external) must be entered into

the Group CSR-HSSEQ database in accordance with the Incident Reporting Policy.

3.8. All actions associated with internal and external Audits must be entered into the Action Manager.

3.9. All actions upon completion must be closed out in the Action Manager.

3.10. Each LBC Facility must endeavor to obtain written confirmation from the external auditing body

confirming that non-compliances have been closed out following completion of the improvement

actions.


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3.11. All written communications with external auditing bodies regarding actual or potential level 3 or 4

non-compliances must firstly be approved by the legal department.


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Incident Reporting and Investigation


This policy is defined to specify the minimum requirement controls that need to be in place for the

reporting, timely communication and investigation of all Incidents at each LBC Facility and that learnings

from Incidents are communicated. The Incident types that fall under the scope of this policy are detailed in

the policy.

All Incidents (including Near Misses and Unsafe Situations) must be reported in the CSR-HSSEQ database.

Local databases are not permitted.



• Action Manager: tool in the CSR-HSSEQ database designed to manage actions from an Incident

investigation process.

• Actual Severity: the actual Severity level of an Incident as determined using the Severity Impact Matrix

• AIFR: All Injury Frequency Rate: number of LTI+RWC+MTC+FAC * 200.000/ worked hours

• Causal Factors: These aspects of the Incident are effectively contributory breaches which in

themselves did not cause harm but made a significant contribution to the Incident. They are also

referred to as “in-direct causes”.

• Crisis Status Incident is a level 3 or 4 Incident that has been escalated in accordance with the Incident

Reporting and Investigation Policy and defined by the Group Crisis Leader and/or Group CSR Director as

being a Crisis and for which the involvement of the Corporate Crisis Team is required.

• Direct cause: These are aspects of the Incident which directly influenced the outcome (damage or

injury) and are also referred to as “immediate causes”. They are the features of an Incident which

immediately contributed to harm or damage being caused.

• Final Reviewer: Competent Person(s) responsible to verify the Incident Investigation process,

investigation reports and close-out of actions. For level 4 Incidents the Group CSR Director is the only

person who may close-out an Incident.

• First Level Reviewer: Competent Person(s) responsible for reviewing Incident entries submitted into

the CSR-HSSEQ database. First Level Reviewers are authorized to appoint an Incident Investigation

Lead and request a Root Cause Analysis. In the case of a level 3 or 4 Incident the Group CSR Director

may assign at his/her discretion assign the Incident Investigation Lead.

• Incident: an unplanned event or chain of events has occurred (i.e. energy was released) that has or

could have, resulted in:

• injury or illness to people

• damage to the environment / reputation / community

• compliance issues

• (temporary) discontinuity of operations and/or customer service agreements

• Financial loss / property damage / unavailability of assets / insurance claim

• Security issues


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• Incident investigation: is a process conducted for Incident prevention which includes the gathering and

analysis of information, drawing of conclusions, including determination of causes and, when

appropriate, making of safety recommendations.

• Incident Investigation Lead: a Competent Person assigned to lead the RCA process.

• Incident Investigation Team: Multidisciplinary Team lead by the Incident Investigation Lead tasked to

investigate the Incident. In the case of a level 3 or 4 Incident the Group CSR Director may assign at

his/her discretion members to the Investigation Team.

• Incident Review Meeting: Meeting with ELT, Group CSR Director and Facility Manager or delegate. The

purpose of the meeting is to review the Incident, the Incident Investigation process, the identified

actions and action follow-up at a local, regional and/or group level.

• Investigation Reviewer: Competent Person(s) responsible for reviewing Incident Investigation reports.

• LOPCFR: Loss of Primary Containment Frequency Rate: number of LOPCs * 200.000/ worked hours

• LTIFR: Lost Time Injury Frequency Rate: number of LTIs * 200.000/ worked hours. NB: Incidents

involving lost time will stop counting at 180 days

• LTISR: Lost Time Injury Severity Rate: number of Lost Time Injury Days * 200.000/ worked hours

• Major Hazard Event: an occurrence such as a major emission, fire, or explosion resulting from

uncontrolled developments, and leading to serious danger to human health or the environment

(whether immediate or delayed) inside or outside the LBC Facility, and involving one or more

Hazardous Substances.

• Near Miss: An Incident that could have caused illness in or injury to people, or property damage,

damage to the environment or reputation, but did not (i.e. energy was released and no actual

Consequence).

• NMFR: Near Miss Frequency rate: number of Near Misses * 200.000/ worked hours

• OSHA Recordable Incidents are work-related injuries, illnesses, and fatalities that must be recorded by

employers according to OSHA (Occupational Safety and Health Administration) standardized

guidelines.

• Potential Severity: the potential Severity Level of an Incident as determined using the Severity Impact

Matrix. The consequences that could have occurred if the circumstances at the time of the Incident

were less favorable.

• Primary Containment: equipment intended to serve as the primary Container or used for processing

or transfer of material. For example: tank, pipe, pumps, flex line, ship, barge, rail car, tank truck, IBC

(packaging) and drum (packaging).

• Root cause: The most basic cause (or causes) that can reasonably be identified that management has

control to fix and, when fixed, will prevent (or significantly reduce the Likelihood of) the problem’s

recurrence.

• Root Cause Analysis (RCA): is a method that allows identification of the Direct Cause, Root Cause(s)

and other Causal Factors of Incidents.

• Secondary Containment: equipment used on an LBC Facility as a second line of defense for preventing,

controlling or mitigating Major Hazard Events. For example: bunds, drip trays, off-gas treatment

systems, interceptors/sumps, expansion vessels, double skinned tanks/vessels, concentric pipes.


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• Severity Impact Matrix: LBC matrix used for determining the Actual Severity and Potential Severity of

Incidents

• Severity Level (or Level): the consequences (actual or potential) of an Incident as identified in the

Severity Impact Matrix.

• TRIFR: Total Recordable Injury Frequency Rate: number of LTI+RWC+MTC * 200.000/ worked hours

Incident types – Health and Safety

• Fatality: This is an OSHA Recordable injury that results in death of the person within 30 working days of

an Incident.

• First Aid Case (FAC): First Aid refers to medical attention that is usually administered immediately after

the injury occurs and at the location where it occurred. It often consists of a one-time, short-term

treatment and requires little technology or training to administer. First aid can include cleaning minor

cuts, scrapes, or scratches; treating a minor burn; applying bandages and dressings; the use of non-

prescription medicine; draining blisters; removing debris from the eyes; massage; and drinking fluids to

relieve heat stress.

• Lost Time Injury (LTI): This is an OSHA Recordable injury or illness that results in an employee missing

more than one full shift of work. Do not count the day of the Incident itself.

• Medical Treatment Case (MTC): This is an OSHA Recordable injury or illness that results in an

employee receiving medical treatment that can only be administered by a medically qualified

professional.

• Minor injury no treatment: This is an injury or illness that requires no form of treatment at all.

• Restricted Work Case (RWC): This is an OSHA Recordable injury or illness that results in an employee

having to carry out restricted duties for more than one day (the day of the Incident should not be

counted). The employee either must perform a different function, is not able to perform all the tasks

associated with their usual job or must work reduced hours.

• Unsafe Situation: Unsafe conditions that could result in an Incident (i.e. an Incident has not occurred:

energy was not released and no actual Consequence).

Incident types – Environment

• External Noise: Any noise exceeding the maximum limit of the noise range causing a nuisance outside

of the LBC Facility to the public

• External Odor: Any spill, release or emission to the environment outside containment causing odor

nuisance outside of the LBC Facility to the public

• External Release to Air: Any spill, release or emission to air outside containment.

• External Release to Ground: Any spill, release or emission to ground outside containment.

• External Release to Water: Any spill, release or emission to water outside containment.

• Loss of Primary Containment: An unplanned or uncontrolled release of any Product from Primary

Containment.

• Category D: <0.1m3, Category C: >0.1m3<1m3, Category B: >1m3<5m3, Category A: > 5m3

• Loss of Secondary Containment: An unplanned or uncontrolled release of any Product from Secondary

Containment:


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• Category D: <0.1m3, Category C: >0.1m3<1m3, Category B: >1m3<5m3, Category A: > 5m3

Incident types- Unintended Product Transfer

• Product cross contamination – different products: Product sent to wrong Container with different

Product resulting in Product cross contamination.

• Product cross contamination – same products: Product sent to wrong Container with similar Product

resulting in Product cross contamination.

• Product transferred to wrong (empty) vessel: Product sent to wrong (empty) Container.

Incident types- Customer complaint

• Communication: Communication with Customer or Carrier causing failures or errors in the quality of

service.

• Customer Shut Down: Any event at LBC Facilities causing a customer to shut down.

• Demurrage: Any event causing a delay in loading or unloading of ships, barges, trucks or railcars which

then would result in extra costs

• Documentation Issue: A wrong paperwork Incident must be recorded if wrong paperwork is sent to

any internal or external customers, including but not limited to Bill of Lading, invoices and reports

• Equipment Issue: Quality issue due to malfunction of equipment

• Inventory Control: Deviations to or differences in inventory control.

• Label Issue: Wrong label used for identifying product. Not compliant with local or regional

classification, labelling and packaging requirements.

• Missed Shipment (or No show): A missed shipment Incident must be recorded if the customer’s

shipment does not meet the shipment date on the scheduled calendar date because of LBC non-

compliance. Late shipments are identified by calendar date, meaning a missed shipment is one that did

not ship on the scheduled calendar date irrespective of the time during that day that it is shipped.

• Product Off-Spec: An out of specification product Incident must be recorded and categorized according

to the priority of selection for Products in our custody, i.e. in our tanks or leaving the LBC Facility.

Inbound product that is sampled and identified as out of spec should not be recorded as an Incident.

Products that are off-spec as a result of Unintended Product Transfer should be recorded under

Unintended Product Transfer.

• Reachability: Customer was unable to connect to Customer Service Department or Customer Service

Department was unavailable.

• Slot / Schedule Issue: Any event or Incident causing obstruction of customer planning

• Third party: Non-LBC employee, Contractor or Visitor

• Third party survey: Intervention or audit performed by 3rd party.

• Wrong quantity: A wrong quantity Incident must be recorded if a wrong quantity is shipped compared

to the customer order and is outside the tolerance. This includes underweight and overweight trucks,

railcars and marine vessels, however only those that depart the LBC Facility. Underweight and

overweight occurrences that are identified through normal procedures such as quality checks or

weighing and are corrected before the shipment leaves should not be recorded. Instead, these

occurrences should be tracked by the customer service department independent from reporting.


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Incident types- Security

• Active Shooter: Suspect (s) activity is immediately causing death and serious bodily injury. The activity

is not contained and there is immediate risk of death or serious injury to potential victims

• Aggression: Hostile or violent behavior or attitudes toward another; readiness to attack or confront

• Bomb Threat: A bomb threat is generally defined as a threat, usually verbal or written, to detonate an

explosive or incendiary device to cause property damage, death, or injuries, whether or not such a

device actually exists.

• Cyber Breach: Unauthorized access to secure intellectual information. A Cyber breach is an Incident in

which sensitive, protected or confidential data has potentially been viewed, stolen or used by an

individual unauthorized to do so. Data breaches may involve personal health information (PHI),

personally identifiable information (PII), trade secrets or intellectual property.

• False Identity: Use of a fake identification to misrepresent in order gain access to the LBC Facility or for

personal gain

• Fraud: Wrongful or criminal deception intended to result in financial or personal gain.

• Kidnapping: To take away (someone) by force usually to keep the person as a prisoner and demand

money for returning the person.

• Piracy: The unauthorized use of another's production, invention, or conception especially in

infringement of a copyright.

• Sabotage: The act of destroying or disabling something deliberately so that it does not work properly.

• Smuggling: Move (goods or people) illegally or without authorization into or out of a country or facility.

• Terrorist attack: Act of terrorism, terrorism, terrorist act. The calculated use of violence (or the threat

of violence) against civilians to attain goals that are political or religious or ideological in nature; this is

done through intimidation or coercion or instilling.

• Theft: An unlawful taking (as by embezzlement or burglary) of property

• Trespasser: A person entering the LBC Facility without permission.

Incident types- Property damage

• Loss or damage: Any event (excluding quality non-conformance) which results in damage to property

and/or Product.

• Category 1: $0 – $100K, Category 2: $100 – $500K, Category 3: $500 – $1000K, Category 4: >

$1000K

Incident types- Compliance

• Major Non-compliance: Breach of the requirements imposed by governmental bodies, regulators,

industry mandates, ISO or branch auditors or internal policies resulting in immediate shutdown of the

LBC Facility or part of the LBC Facility or loss of certification or loss of customer contract.

• Minor Non-compliance: Breach of the requirements imposed by governmental bodies, regulators,

industry mandates, ISO, Branch or Customer Auditors or internal policies but not resulting in

immediate shutdown of part or all of LBC Facility nor loss of certification or termination of customer

contract.


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• Recommendation/ Remark/Observation: No breach of requirements; a best practice example or

proposal for improvement is given by the regulator, ISO, Branch or Customer auditor.

Incident types- Asset Availability

• LBC Facility unavailable for business:

• Major time off: > 5 days, Medium time off: > 1 day < 5 days. Minor time off: < 1 day

3. Standard minimum requirements of the Policy

Incident reporting

3.1. All Incidents classified according to the Severity Impact Matrix in Appendix 1 as level 1 minor, green) or

Level 2 (limited, yellow) must be reported into the Group CSR-HSSEQ database within 3 working days

and approved by the First Level Reviewer within 5 working days.

3.2. All Incidents classified according to the Severity Impact Matrix in Appendix 1 as actual or potential

Level 3 (significant, orange) or Level 4 (major, red) must be reported and approved by the First Level

Reviewer immediately (as soon as reasonably possible) in the Group CSR-HSSEQ database and

separately in accordance with the Escalation Reporting Process Level 3 and 4 Incidents (Appendix 2)

3.3. Local and Regional procedures must be established and training given such that the Incident reporting

requirements detailed in this policy are embedded within the Local and Regional Teams such that the

internal communication of Incidents is timely and effective. The timing must consider the severity of

the Incident and the needs to satisfy the requirements of this policy and any regulatory and customer

reporting requirements.

3.4. Reporting of Insurance Claims: All Incidents that may result in an insurance claim must be reported to

Legal Counsel within 24 hours. Legal Counsel will advise on follow-up.

3.5. Each Facility must enter incident metrics in accordance with the Performance Monitoring and

Reporting Policy.

Incident investigation and follow up 3.6. All Incidents must be investigated as soon as practical.

3.7. A Root Cause Analysis must always be conducted for Incidents classified as Level 3 or 4.

3.8. Level 1 and 2 Incidents typically require a less elaborate Incident Investigation process; however, a

root cause must be defined.

3.9. Management may request an RCA for Incidents classified as Level 1 or 2 or an investigation into a

series of Level 1 or 2 Incidents that appear connected.

3.10. The Incident Investigation Lead assigns a Multidisciplinary Team to conduct the RCA process.

3.11. The Incident Investigation Team:

• Completes the appropriate sections in the CSR-HSSEQ database, including the RCA sections

(‘Incident Investigation’ and ‘Incident Analysis’ - see Guidance note incident investigation

process). These sections guide the Incident Investigation team in their Incident Investigation

process.

http://lbcazpspdshp01/User%20Instructions/Incident%20investigation%20process.docx

http://lbcazpspdshp01/User%20Instructions/Incident%20investigation%20process.docx


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• Will place the watermark “draft” on all Incident reports until they have undergone the final

review

• Obtains legal advice before sharing an investigation report with external parties.

• Documents the findings in an Incident Investigation report. The report must contain as a

minimum the items mentioned in Appendix 3.

• Upload reports, photographs and other documents related to the Incident Investigation to the

CSR-HSSEQ database.

• Upload actions to the Action Manager.

3.12. The Investigation Reviewer:

• Will make a final classification of the Incident based on the outcome of the Incident

Investigation

• Will approve the Incident Investigation report and action plan within 1 month of the Incident.

The CEO and CSR can extend or shorten the deadline.

3.13. The designated manager (e.g. LBC Terminal Manager, Regional Director) will follow up the actions.

3.14. The Final Reviewer will verify the quality of the Incident Investigation process and proper close-out of

actions.

3.15. The local Management Team must decide how to share Incident findings and actions within their LBC

Facility and/or region. For example, via toolbox meetings or a Safety Alert.

3.16. Incidents classified as Level 3 or 4 must be shared within the LBC Facility via a Safety Alert as soon as

practical. In addition, the LBC Facility Manager or Designated Deputy is responsible for drafting an

English language Safety Alert for review and distribution by the Group CSR Director.

3.17. All Incidents with actual severity Level 3 or 4 will be subject to an Incident Review Meeting within 1

month of the Incident. The CEO and/or Group CSR Director can extend or shorten the deadline.

3.18. A decision to also subject Incidents with a Potential Severity Level 3 or 4 to an Incident Review

Meeting is at the discretion of the CEO and/or Group CSR Director.

3.19. When work resumes for the first time following an incident with actual or Potential Severity Level 3 or

4, a Permit to Work should be issued and / or comprehensive JSA should be performed.

4. References

• OSHA Guidelines for classifying and reporting of occupational injuries and diseases.

5. Appendices

Appendix 1: Incident Reporting: Severity Impact Matrix

Appendix 2: Escalation Reporting Process Level 3 and 4 Incidents

Appendix 3: Incident Investigation Report – minimum requirements

Appendix 4: Guidelines Witness Statements


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Appendix 1: Incident Reporting: Severity Impact Matrix


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Appendix 2 Escalation Reporting Process Level 3 and 4 Incidents

Any Incident that has an Actual or Potential Severity Level 3 or 4 must be escalated to Senior Management and

reported immediately as follows:

• Into the CSR-HSSEQ database and immediately submitted by the First Line Reviewer

▪ Reported via the Incident Level 3 & 4 Whatsapp Group by the Designated Regional Responsible

or Designated Responsible for Incidents occurring in the Head Office.

▪ All ELT members

▪ Group CSR Director

▪ Group Senior CSR Manager

▪ Group CSR Manager

▪ Designated Regional Responsible Northern Europe

▪ Designated Regional Responsible USA

▪ Designated Regional Responsible Asia

▪ Group HR Director

▪ Group IT Director

• If the Incident Level 3 & 4 Whatsapp Group does not work or the Incident could be considered as

needing escalation to Crisis Status, the CEO and Group CSR Director must be informed immediately by

telephone.

• The CEO or his delegate is responsible for escalating information about Level 3 and 4 Incidents to The

Board and other Stakeholders.

• The CEO or his delegate and/or the Group CSR Director or his delegate is responsible for declaring a

Level 3 or 4 Incident as having Crisis Status and activating the Corporate Crisis Team if necessary.


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Appendix 3 Incident Investigation Report – minimum requirements

The final Incident report must contain as a minimum the following elements:

• Executive summary with brief description, root cause, direct cause and key causal factors

• Incident number from CSR-HSSEQ database

• Actual and Potential Severity

• Description of what the Actual or Potential Severity is based upon

• Consequences, e.g.:

o Personal injury

o Loss of product

o Material/environmental damage

o Evacuation of persons, closure of public roads

o Impact on operations and supply performance (delay, customer satisfaction…)

o Major non-compliance

o Violation of rules and regulation.

• Investigation lead + investigation team (titles, competencies included)

• Affected part(s) of operation

• Date/time and location of occurrence

• Interviewed persons

• Date and time of interviews

• Description of the Incident as accurate and complete as possible, formulated in a way that it can be

understood by anyone who is not involved: what occurred and the primary effect

• Outcome of the Incident Investigation and RCA section of the CSR-HSSEQ database

• Direct cause, Root Cause and other Causal Factors

• When, where, what happened and who was involved

• Reference to Risk Registers / Risk Assessments and controls (eg. SOPs)

• Environmental conditions such as topography and weather conditions,

• Product involved and estimated quantity of loss of product if appropriate

• Type and material of containment (steel tank, piping, IBC, drum, …), if appropriate

• Type of failure of the means of containment, if appropriate

• Additional non-Incident related factors requiring improvement that are discovered during the

investigation

• Lessons learnt

• Actions (SMART) addressing root causes and direct causes


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Appendix 4 Guidelines Witness Statements

• Explain the purpose of the investigation i.e. to discover Direct Cause, Root Cause and other Causal

Factors to prevent recurrence. Not intended to assign blame.

• Offer the possibility for a supportive person (who stays silent) of their choice to be present during the

interview.

• If possible record interview – ask permission

• Initially request the witness to recount their story in their own words (do not interrupt). They should tell

what they remember of the Incident (not what they have been told since the Incident happened by

others)

• Do not summarize

• When the witness has recounted their version of events, the interviewer may then begin posing

questions of their own

• Questions should be where possible open when trying to gather relevant information (what, why,

where, how, when, etc.)

• Write down what people say using their words

• Obtain signature from witness that statement is correct

• Isolate people from groups of other witnesses

• Do not let others contaminate a witness’ story

• Put people on standby and try not to delay interviews

• Inform interviewees that they may be required to come for an additional interview at a later moment


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Performance Monitoring and reporting


This policy is defined to specify requirements for the reporting of Corporate Social Responsibility Key

Performance Indicators (KPI’s).

This policy applies to all LBC Facilities.



• Key Performance Indicator (KPI) – is a measurable value (metric) that is tracked and analyzed and

deemed as having significant importance to the success of the LBC organization and the achievement

of LBC’s strategic business objectives.

3. Standard minimum requirements of the Policy

3.1. KPI’s must be monitored and analyzed to evaluate the LBC’s Corporate Social Responsibility

performance. The parameters listed in Appendix 1 are identified by LBC Group and her Stakeholders as

being significant.

3.2. There must be a process in place to ensure all KPIs listed in Appendix 1 are monitored and reported as

per the indicated timeline and in accordance with the defined methodology. Note: The timeline in

Appendix 1 pertains to internal and/or external reporting requirements, not to Incident reporting.

Incidents must be reported as per the Incident Reporting and Investigation Policy.

3.3. The process must include provisions for carrying out data checks to ensure data is correct and for

maintaining a documented record of the measurements and calculations of the KPIs.

4. References

• GRI Standards (2016)

5. Appendices

Appendix 1: CSR Key Performance Indicators

https://www.globalreporting.org/Pages/default.aspx


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Appendix 1: CSR Key Performance Indicators

Parameter Unit and Methodology Reporting frequency

and methodology

Occupational Health and Safety

This parameter consists of the following

frequency rates:

▪ LTIFR, TRIFR, AIFR, LTISR, NMFR

Rates for LBC employees and contractors are

reported separately.

There must be a split between Safety Incidents

and Occupational Health Incidents

In accordance with the Incident

Reporting and Investigation Policy

Monthly via CSR-

HSSEQ database

Sustainable Safety Behavior

This parameter consists of the following:

▪ # Near Misses

▪ # PEER reports, Safe and Less Safe

Observations

▪ NMFR

▪ Internal audits (planned vs actual)

▪ #External audits

In accordance with the Incident


Monthly via CSR-

HSSEQ database

Use of energy

(absolute and relative per ton throughput)

This parameter consists of:

o Natural gas consumed

o Electricity, heating, cooling and steam

purchased or self-generated

o Electricity, heating, cooling and steam sold

Note: Total energy consumption outside the LBC

Facility does not have to be reported. Examples

of energy consumption outside of the LBC Facility

include: business travel, employee commuting,

transportation of purchased goods and materials.

Joules or multiples

Use local conversion factors to

convert fuels to Joules. The local

conversion factors applied must

be specified.

Monthly via submittal

process defined by

CSR

CO2 emissions

(absolute and relative per ton throughput)


Kilograms or multiples

The amount of CO2 per purchased

kWh is dependent upon how the

electricity is generated (e.g.


process defined by

CSR


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o Direct CO2 emissions: emissions that result

from combustion of fuels, e.g. in boilers for

steam production

o Indirect CO2 emissions: emissions from the

generation of purchased electricity, heating,

cooling and steam consumed by the LBC

Facility

hydraulic power, solar power,

gas, coal). Use local parameters.

The local conversion factors

applied must be specified.

VOC (Volatile Organic Compounds) emissions


o Total amount of VOC emitted

Kilograms or multiples

Use local methodology. The local

methodology must be specified.


process defined by

CSR

Ground (soil) and Water pollution

This parameter consists of the number and

volume of External Release to Ground and Water

Incidents and the type of Product that was

released.

Number, volume (liter or

multiples) and Product type

Spills to ground and surface

water with Actual Severity Level 3

or 4 as determined using the

Severity Impact Matrix in the

Incident Reporting Policy

Monthly via CSR-

HSSEQ database

Process Safety


o Number of Tier 1 and Tier 2 Process Safety

Events

o Number of LOPC category A Incidents

o Amount and type of Product that was spilled

Number and volume (liter or

multiples)

Tier 1 and 2 Process Safety Events

as defined in API RP 754

LOPC category A Incidents in

accordance with the Incident

Reporting Policy

Monthly via CSR-

HSSEQ database

Business ethics and integrity


o Number of fines from Permit violations

o Monetary value of fines from Permit

violations

o Total number of Incidents of discrimination,

Fraud, corruption and bribery

o Number of External releases to air resulting

in vapor, odor and stench complaints

Number and amount (EUR

thousands)

Legal Counsel and Group CSR

Director to determine if a breach

has occurred in cases that may be

unclear

Quarterly via

submittal process

defined by CSR


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Application of best practices


o Number of external certifications according

to ISO (or equivalent) management system

standards.

o Number of external benchmark studies

o Awards

Number + Qualitative description

Annually within 2

months after calendar

year’s end via

submittal process

defined by CSR

Number of Customer Service Complaints In accordance with the Incident


Monthly via CSR-

HSSEQ database

Number of Unintended Product Transfers In accordance with the Incident


Monthly via CSR-

HSSEQ database

Threats of natural disasters


o Number of LBC Facilities with emergency

response plans that consider natural

disasters and adverse weather conditions

Number

Qualitative description of

emergency preparedness

Annually within 2

months after calendar

year’s end via

submittal process

defined by CSR

Supplier acceptance and continuation

To be defined

To be defined To be defined


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Emergency Preparedness


This Policy applies to all Emergency Action and Preparedness Plans submitted to or required by local or

governmental authorities and regulatory bodies and the requirements of each LBC Facility to have an

escalation process in place in accordance with the Corporate Crisis Plan and the Incident Reporting and

Investigation Policy.

2. Definitions


• Crisis is an inherently abnormal, unstable and complex situation that represents a threat to the

strategic objectives, reputation or existence of an organization.

• Emergency is defined as a serious, unexpected, and dangerous situation requiring immediate action.

Examples of emergencies are fire, explosion, spills, releases, serious injuries, fatalities, inclement

weather including tropical events and flooding, pandemic outbreak, security breach, terrorism, social

riots or unexpected severe reputational damage. An emergency is not necessarily a Crisis.

• Emergency Action and Preparedness Plans are plans written with appropriate actions designed to

prevent Incidents from happening. If Incidents do happen the plans are designed for limiting the impact

of an Incident while in progress and speeding up recovery and return to normal operations. Examples

are Federal Response Plans, Emergency Response Plans, Integrated Contingency Plans, Facility Security

Plans, Process Safety Plans, or any written and approved plan designed to control various Emergency

situations. All Emergency Action and Preparedness Plans are written to cover all risks as identified in

accordance with the Risk Management Policy.

3. Standard Minimum Requirements Permit Application & Compliance

3.1. All Emergency Action and Preparedness Plans as well as correspondence shall be stored in the LBC

Document Management Site for each LBC Facility as per local procedure.

3.2. There must be a local procedure in place that is fully traceable and auditable and includes the

following elements as a minimum:

3.2.1. That Key Personnel meet annually to review accuracy and compliance of Emergency Action

and Preparedness Plans.

3.2.2. That deficiencies found during internal or external Audits and/or training exercises are

managed and corrected timely by local Management Teams.

3.2.3. That Key Personnel and their direct reports physically review and sign off on all Emergency

Action and Preparedness Plans and their amendments.

3.2.4. A training matrix to indicate how plans will be communicated to affected employees.

3.2.5. A training matrix to define the minimum requirements of all individuals with a role in the

Emergency Action and Preparedness Plans

3.2.6. A training matrix to define the nature and frequency of testing of the plan for the differing

identified scenarios


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3.2.7. A reference table to indicate all Emergency Action and Preparedness Plans issued by, or

submitted to, governing authorities that are required to legally operate each specific LBC

Facility. This reference table must be reviewed and where necessary updated annually as

part of the Management Review Process.

3.2.8. The reference table must also include a frequency of all required reports that must be

submitted to the Issuing Authority, if applicable.

3.2.9. The reference table should be reviewed at regular (pre-defined in the procedure) intervals by

an accredited external independent consultant with specific local knowledge of required

Emergency Action and Preparedness Plans.

3.2.10. The local procedure must reference the location and list of all plans that are in place to

mitigate the following Emergency types at a minimum:

• Fire

• Explosion

• Spill scenarios, land or water

• Release inside and outside or property boundary

• Serious injuries

• Fatalities

• Inclement weather such as tropical storms and hurricanes, flooding, windstorm

including tornadoes, extreme hot or cold ambient weather

• Pandemic outbreak

• Security breach

• Terrorism

• Social riots

• Severe reputational damage

3.2.11. There should be an up to date inventory on the LBC Document Management Site of all

products stored on the LBC Facility and the unique storage vessel identification (e.g. tank

number) and the relevant SDS. This should be referenced in local Emergency Action and

Preparedness Plans including the required Emergency response.

3.2.12. The local procedure must include the requirement to escalate an Emergency as soon as

possible in accordance with the Level 3 & 4 Incident reporting requirement in the Incident

and Reporting Policy such that the Corporate Crisis Team can be activated in accordance with

the Corporate Crisis Plan

3.2.13. The local and/or regional procedure must include a process whereby the appointed Regional

Crisis Team Leader (appointed by the Group Crisis Team Leader) in accordance with the

Corporate Crisis Plan defines a single point of contact to communicate with the Corporate

Crisis Team if the Corporate Crisis Plan and Team is activated

3.2.14. A system to monitor the renewal dates for all plans if required to submit to regulatory or

governmental agencies. This system should include an “Early Warning” alert to multiple

Stakeholders such that applicable applications for plan renewals are made in a timely

manner, considering the necessary internal and external consultation process. Each Region

and LBC Facility must incorporate the use of the Action Manager for tracking renewal dates.


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3.2.15. A system to perform random internal audits at each LBC Facility to ensure the most current

Emergency Action and Preparedness Plans are stored in the CSR-HSSEQ Database, conditions

of the Plan are being followed, and that training is up to date. The results of such compliance

audits must form part of the annual Management Review and a clear improvement plan

must be developed if necessary.

3.2.16. A system to ensure that Contractors and House Contractor employees that may be assigned

emergency action or preparedness tasks at an LBC Facility must receive traceable and

auditable training prior to task assignment.

3.2.17. Procedures shall include notification requirements to applicable governmental or regulatory

agencies as required by local legislation.

3.2.18. Procedures shall include a clear organizational structure with pre-determined roles and

responsibilities.

3.2.19. Roles and responsibilities should be defined for the following minimum elements:

• Coordination of the local emergency response teams

• Fire fighting

• First aid and medical

• Rescue

• Facility shutdown (Operational)

• Safety/ Security Officer

• Employee and Next of kin Welfare Coordinator

• Media Spokesperson (in accordance with the Corporate Crisis Plan

• Legal Coordinator (in accordance with Corporate Crisis Plan

• Commercial/Customer Coordinator

• Incident Commander

• Logistics

• Field Operations

3.2.20. Procedures should include post emergency evaluations to measure effectiveness of response

plans or actions taken during an emergency. This evaluation shall be submitted to the Group

CSR Director and Group COO within 60 days of the event.


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GV 14 16 February 2016 1 September 2018 2.0 65



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Variance


This policy is defined to specify the minimum controls that must be in place to have a Variance from a

corporate policy approved. The intent of the policy is to ensure that corporate policies are rigorously

enforced at all LBC Facilities and where this is not possible that the Risks associated with variation from all

or part of a policy are identified and responsibly managed to prevent Incidents occurring that can damage

People, Planet or Profit.


Definitions pertaining to this procedure are

• A Variance is a deviation from all or part of a Corporate Policy


3.1. An application for Variance from a Group LBC Policy must be submitted to the Group CSR Director and

CEO accompanied by complete and relevant documentation including the motivation for applying for a

Variance, a Risk Assessment and risk mitigation plan. This application should be based on the input of a

Multidisciplinary Team.

3.2. The application of a Variance from part or all a Group LBC Policy constitutes a Change and as such the

Management of Change (MOC) policy should be adhered with.

3.3. The Group CSR Director, CEO and Policy Owner will assess the application for Variance and upon

reaching consensus will approve or deny the application. An approved Variance will detail the specific

terms and conditions under which the variance has been granted including review moments and/or the

reasons why it has been denied.

3.4. A log of approved Variances will be maintained on the LBC Document Management Site.


OCCUPATIONAL HEALTH


OH 01 1.0 66



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Fitness to work

To be developed


OCCUPATIONAL HEALTH


OH 02 1 September 2018 1 September 2018 1.0 67



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Conservation of Hearing


This policy is defined to specify requirements that need to be in place to ensure that employees and

contractors will not suffer adverse health effects from noise generated by the business.


2. Definitions specific for this Policy

None

3. Standard Minimum Requirements Risk Assessment

3.1. There must be a Risk Assessment in place covering the noise aspects of all Work Locations,

machinery and/or activities. Note: it is the intention that adequate noise measurements be carried

out to assess risk. The Risk Assessment must also include an assessment of peak noise exposures.

3.2. Where the Risk Assessment indicates the need (based on Occupational Exposure Levels) there must

be a hearing conservation plan in place.

4. Standard Minimum Requirements Hearing Conservation Plan

4.1. The hearing conservation plan must consist of the following aspects:

• The work place noise exposure must be defined and adequately described.

• The persons exposed to hazardous noise must be identified.

• Noise sources that contribute to the exceedance of agreed Occupational Exposure Limits (OEL)

are identified and clearly described.

• Impulse (peak) noise exposures are clearly identified and described.

• Control measures are in place to minimize noise levels and protect persons from adverse

exposure.

• Audiometry programs are in place to monitor the effects of noise on persons exposed. This

program should include trending for specific exposure groups. Employees should be informed of

the results of these tests and any trends that are observed.

• Annual educational programs to adequately inform and instruct all exposed persons.

• Annual evaluation of the hearing conservation plan to assess the effect of such a plan and to

define continuous improvements.

5. Standard Minimum Requirements Occupational Exposure Limits

5.1. Where the possibility exists for a daily exposure of 80 dB(A) (excluding the use of hearing protection)

or peak levels above 112Pa (135 dB(C)):

• Hearing protection must be freely available

• Employees must receive an appropriate training and instruction annually. Such training must

be documented.


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• Employees must be offered the opportunity to have an appropriate periodic hearing test.

5.2. Where the possibility exists for a daily exposure of 85 dB(A) or more (excluding the use of hearing

protection) or peak levels above 140Pa (137 dB(C)) there:

• Must be a plan of action to reduce noise levels conform the Occupational Health Strategy

• Employees are obliged to wear the provided hearing protection

• The areas and/or machines and tools producing this noise must be clearly marked with “hearing

protection compulsory” labels/signs

• Employees must be offered the opportunity for an annual audiometric test.

• By a daily exposure to 87 dB(A) or higher (including the wearing of hearing protection) or peak

levels above 200Pa (140 dB(C), immediate measurements must be taken to reduce the

exposure to under this value.

• Where local legislative requirements are stricter than the above they must be met

6. Standard Minimum Requirements Control Measures

6.1. The hearing conservation plan should be based on the following four step occupational health

strategy hierarchy of control:

• Removal of the hazard

• Isolation of the hazard

• Administrative controls such as rotation of personnel

• Distribution of personal protective equipment

7. Standard Minimum Requirements Personal Protection

7.1. There must be a documented hearing protection device program in which appropriate hearing

protection is selected based on the hazard and in which employees are trained to recognize and

select the appropriate hearing protection based on their exposure to noise.

8. Standard Minimum Requirements Education Program

8.1. There must be an educational program in place that includes an explanation of the following:

• The Risk Assessment and the areas, equipment and tasks where hazardous noise exists

• The plan of action relating to noise reduction

• The signage that will be used to warn about hazardous noise and PPE requirements in the signed

areas

• The correct identification and use of appropriate hearing protection devices

• The sorts of hazardous noise (daily dose and peak noise levels)

• The Audiometry testing program

• The signs and symptoms of hearing loss damage


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Thermal Stress

To be developed


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Vibrations

To be developed


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Fatigue


This policy is defined to specify minimum requirements that need to be in place to ensure that the

organization makes adequate provisions for managing Fatigue and working times such that the Risks

associated with Fatigue are appropriately treated to prevent an Incident from occurring where the Root

Cause can be attributed to Fatigue.




• Extended Shift - no longer than 72 hours per week with no longer than 12 worked hours in any one day

and no more than 6 days in a week. Not necessarily over daytime hours.

• Fatigue - Mental or physical exhaustion that stops a person from being able to function normally. It is

the state of feeling very tired, weary or sleepy resulting from insufficient sleep, prolonged mental or

physical work, or extended periods of stress or anxiety.

• Normal Week with Normal Day Shift - is generally considered to be a work period of no more than

eight consecutive hours during the day, five days a week with at least an eight-hour rest.

• Unusual Extended Shift – is a shift that may be extended for emergency or maintenance repair

situations and does not exceed 16 hours in a shift with a minimum resting period of 11 hours between

each shift.


3.1. There must be a Risk Assessment conducted regarding Fatigue at all LBC Facilities. The Risk

Assessment should take account of the nature and duration of the activities and occupational

exposures that may exacerbate the effects of Fatigue; for example, but not limited to exposure to

vibration, dust, heat, cold, noise, computer work.

3.2. All employees and contractors must have at least one day of rest per week.

3.3. Where possible duties should be planned to fall within a Normal Week with Normal Day Shift.

3.4. Where a Normal Week with Normal Day Shift is not possible, it is permissible to work an Extended

Shift.

3.5. In cases where a Normal Week with Normal Shift or an Extended Shift is not possible and employees

must work an Unusual Extended shift then the working day can be longer than 12 worked hours but no

more than 16 worked hours with a resting period of a minimum 11 hours.

3.6. Unusual Extended Shift work is only permitted as an exception and in such cases emergency

activities, special project periods, unusual non-routine operational activities such as shut downs

3.7. It is not permitted to work more than two consecutive weeks of Extended Shift work without having

a minimum of 2 rest days in between.


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3.8. There must be a system in place to (Risk) assess the previous worked hours of contractors or

temporary employees in the two-week period prior to engaging them to work in an LBC Facility. This

includes traveling and working in different time zone.

3.9. Adequate and timely breaks must be planned into the working day of employees. Breaks do not

count as worked hours.

3.10. Additional break periods and meals should be provided when shifts are extended past normal work

periods i.e. extended shifts

3.11. All travel should be in accordance with the Responsible Travel, Entertainment and Refreshments

Policy In addition:

3.11.1. Travelers on flights in economy (comfort) class taking over 6 hours must take at least an 11

hour’ rest period at a hotel before commencing work. Driving a car immediately following a

flight of 6 hours or more is considered work and is not permitted.

3.11.2. For car journeys for business (other than work-home) lower or equal to 6 hours; the total

work day must not be longer than 12 hours.

3.11.3. For car journeys for business (other than work-home) of 6 hours or more a period of at least

11 hours’ rest must be taken prior to commencing work.

3.12. There must be a process in the Time and Attendance system (T&A) to track and manage working

hours and flag potential compliance issues.

3.13. There must be a process via the supervisors that includes a Fit for Duty observation before

employees are dispatched to their work area.

3.14. There must be a regular awareness training given to all employees and where appropriate

contractors regarding Fatigue, as a minimum such a training should include working hours,

recognition of Fatigue in self and others, possible effects of Fatigue and the management of Fatigue.

The training should also include the management of activities in the private life that could result in

Fatigue related issues in the work place. Appendix 1 contains a Fatigue Fact Sheet that can be used

to make a training.


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Appendix 1 – Fatigue fact sheet

Effects of Fatigue

• General feeling of being unwell

• Memory lapse or reduced ability to recall details

• impaired judgement and concentration

• Over-estimation of performance capabilities

• Decreased reaction time (speed and thought)

• Increased risk-taking behaviour

• Reduced motivation

• Reduced decision making ability

• Reduced ability to do complex planning

• Reduced communication skills

• Reduced productivity or performance

• Reduced attention and vigilance

• Reduced ability to handle stress on the job

• Failure to respond to changes in surroundings or information provided

• Sleepiness, including falling asleep against your will ("micro" sleeps)

• Irritability

• Depression

• Giddiness

• Headaches

• Loss of appetite

• Digestive problems

• Increased susceptibility to illness

All these effects can lead to mistakes, poor Risk Assessment and Incidents – be that personal injuries, asset

damage, customer service errors etc.

Factors contributing to Fatigue

• Long working hours;

• Insufficient break times

• Irregular working times

• Changing time zones

• Long periods spent commuting

• Long periods spent travelling

• Long and extended working periods

• Irregular times of eating and drinking

• Obtaining an inadequate amount of sleep over an extended period


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• Obtaining an insufficient quality of sleep over an extended period

• Shift work and length of shift (shift work is defined as any work conducted outside the normal day shift

cycle e.g. outside the hours of 7am-5pm)

• Workload

• Physical tasks e.g. tasks requiring a person to use force or to exert a force like Lifting manipulating,

striking, throwing, pushing, hammering etc.

• Time of day or night worked (changes from day- to night shift and vice versa)

• Extended exposure to noise, chemicals or heat

• Physical condition of employee

• Medical condition of employee

• Mental condition of employee

• Alcohol

• Drugs (also prescription drugs)

• Nicotine and coffee

• Sleeping disorders such as sleep apnoea

• Any other factors causing disruption to the circadian rhythms (i.e. the physical, mental, and behavioral

changes that follow a daily cycle)

Tips for managing Fatigue

• Report to your employer if you are feeling tired/overworked/unwell

• Go to bed and get up at the same time every day

• Don’t go to bed on an empty or too full stomach

• Exercise regularly.

• Eat at regular intervals and consume a balanced diet of fruits, vegetables, whole grains, healthy fats and

protein.

• Use your bed primarily just for sleeping (e.g., do not watch television, read or do work in bed).

• If you are not sleepy, do not try to go to bed. Get up and read or do something quiet instead.

• Avoid caffeine, tobacco or alcohol - especially before bed time.

• Turn off the telephone ringer and answering machine speaker.

• Make the room as dark and quiet as possible.

• Most people sleep better when the room is cool. Consider using an air conditioner or fan in the summer

months.


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Occupational Health Monitoring

To be developed


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AED 1. Purpose and scope

To ensure that all LBC Facilities are equipped with at least one Automated External Defibrillator (AED) to

allow immediate help to be given to victims suffering from the effects of a heart attack prior to professional

emergency help arriving. Research indicates that victims of a heart attack are twice as likely to survive if an

AED is used to restore the normal heart rhythm in the first few minutes following a heart attack



• AED (Automated External Defibrillator) is a portable device that can be used to restore a regular heart

rhythm by means of delivering an electric shock when someone has experienced a heart attack. Such

equipment can be operated by passers-by with little or no training.

• Designated Employee – an employee trained in basic first aid, resuscitation techniques, recognition of

signs and symptoms and conditions that could result in the need to use an AED and the operation of

the AED. The training must be conducted by a reputable and certified supplier and the Designated

Employee must receive annual refresher training.

• Drop to Shock Time – the time needed to get the AED from its normal storage/display location to the

victim and administer a shock. Shock to drop times should be preferably less than 3 minutes with 5

minutes being the maximum.


3.1. Each LBC Facility must have at least one AED on the premises at all times and at least one Designated

Employee present during working hours.

3.2. A Risk Assessment must be performed to assess the need for an LBC Facility to have more than one

AED on site and the need to have more than one Designated Employee on site during working hours

(e.g. facility size, layout, age profile, Drop to Shock Time etc.).

3.3. Each AED must be clearly visible and signposted and the position of each AED must be determined

based on a Risk Assessment.

3.4. The AED must be fully automated such that it can be operated without any training.

3.5. Although the AED must be fully automated, all LBC employees must be offered the option to take

part in an AED training every 3 years (or more if legal requirements dictate) given by a reputable and

certified supplier. The training must include basic first aid and resuscitation and the recognition of

signs and symptoms of conditions that could result in the need to use an AED.

3.6. The AED may be purchased or rented from a reputable and certified supplier. In both cases a

maintenance contract must be in place to maintain and certify the AED fit for use annually.

3.7. Post-Event Service – the maintenance contract must include provision to have the AED maintained

and certified immediately after use.

3.8. If the AED is removed from the site during maintenance/certification a replacement must be made

immediately available by the service provider – including sites with more than one AED.

3.9. The date of the last certification should be visible on the AED.


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3.10. Person and backups must be assigned at each LBC Facility to regularly inspect the AED’s on site and

ensure that maintenance and training programs are respected. This should be documented and

traceable.

3.11. All new employees and contractors should be informed of the location(s) of the AED on site during

the on-boarding training.


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Permit to Work


This policy is defined to specify the minimum controls that need to be in place regarding Permit to Work at

each LBC Facility. This policy applies to work permitted activities carried out by LBC personnel and

contractors.



• Acceptance– this is a process whereby the Work Permit Holder and Job Executers accept the Permit to

Work since all necessary pre-job controls have been carried out and that these controls have been

verified.

• Central Work Permit Location – this is a location where all Permits to Work for all locations on the

facility are displayed

• High Voltage Electrical Work – is defined by The International Electrotechnical Commission (IEC) as an

electrical voltage of approximately 1000 volts AC and 1500 volts DC.

• Job Executor - is the person(s) who will carry out the job. This may also be the Work Permit Holder.

• Permit to Work – is a formal, written and signed agreement between several parties (normally the

Permit to Work Issuer, Work Permit Holder and Job Executer describing the work to be carried out and

the agreed work method and control measures to be taken to ensure the safe execution of the job. The

Permit to Work is considered as a legally binding agreement.

• Permit to Work Issuer – this person is an authorized and designated person who is responsible for the

area where the work will be executed.

• SDS – Safety Data Sheet.

• Sign-off – this is the process whereby the Permit to Work Issuer, Work Permit Holder and the Job

Executers sign the Permit to Work at the end of each completed shift. This is also the process whereby

the Permit to work Issuer, Work Permit Holder and Job Executers formally hand back the installation

(commissioning) to operations when the job is completed and all parties sign-off the Permit to Work.

• Work Location - this is the location where the activities described in the Permit to Work will be carried

out.

• Work Permit Holder – this is the person who receives the Permit to Work from the Permit to Work

Issuer.


3.1. There must be a process in place to ensure that all employees and/or contractors working on a LBC

Facility receive documented and appropriate training regarding the Permit to Work system.

Appropriate training is determined by Competent Persons.

3.2. There must be a process in place that identifies the activities that need to be managed by a Permit to

Work system.


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3.3. The Permit to Work system must govern all activities that are not routine in nature and are not

governed by a LBC SOP. In any case, the following activities must be covered by the Permit to Work

system:

• Activities carried out on LBC Facilities by contractors

• Confined Space entries

• Hot work activities (flame or non-flame)

• Pressure Vacuum activities

• High Pressure water jetting activities

• High Voltage Electrical Work

• Low and medium voltage works not considered routine and not defined by an SOP

• Non-routine Lift activities

• Inert Entry

• Working at Depth and Excavation activities

• Construction activities

• Activities conducted from Scaffolding or that are considered as working at height from Elevating

Work Platforms

3.4. There should be a system in place that requires a specific and dedicated Permit to Work for the

following activities:

• Confined Space entry and/or Inert Entry

• Pressure Vacuum

• High pressure water jetting

• Hot work

• High Voltage Electrical Work

• Non-routine Lift

• Working at Depth and Excavation

• Line Cutting and line breaking

3.5. There must be a documented and auditable system in place that includes a training matrix to identify

and train individuals (Competent Persons) to issue Permits to Work for activities that they are

deemed competent. This system should prevent a Permit to Work Issuer issuing a permit for an

activity that he is not documented as being trained, authorized and competent to do so.

3.6. There must be a system in place where all Permits to Work are clearly displayed in a Central Work

Permit Location, preferably the Control Room

3.7. There must be a cross-reference system in place to ensure that permits for tasks that may interact,

or conflict are identified and that all individuals are informed about such activities. This must be a

formal procedure to ensure that a consultation takes place at the beginning and end of each shift

between the responsible persons of all designated Work Locations to discuss all Permits to Work that

have been issued and to risk assess any possible additional risks that may be present due to

conflicting activities.

3.8. The Permit to Work system must include controls to ensure that Permits to Work are issued for only

one shift with a maximum duration of 12 hours. The system can include a documented process to


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extend a Permit to Work for a maximum of one more shift if the circumstances are unchanged. The

system must include a documented and formal permit handover for Permits to Work extended by

one shift.

3.9. The Permit to Work system must include a process in which all aspects of the Permit to Work are

discussed with the Permit to Work Issuer, Work Permit Holder and Job Executers at the Work

Location. The system should include a process in which all parties (Work Permit Holder and Job

Executers) accept that the work may start and that all necessary controls have been verified.

3.10. The Permit to Work system must prohibit the use of a Permit to Work being issued for more than one

location i.e. the Permit to Work is location specific and the location should be clearly specified on the

Permit to Work.

3.11. If persons named on the Permit to Work change during the duration of the Permit to Work, a new

Permit to Work must be issued.

3.12. The Permit to Work system should include a Sign-off process when the work is finalized, and the

installation is handed over to operations again.

3.13. The Permit to Work system should include a system to cancel all Permits to Work following a crisis or

site evacuation, following an Incident at the Work Location or a change of team member i.e. a

change of Work Permit Holder or Job Executer

3.14. There should be a system in place to ensure that there is an exchange of information if a Permit to

Work Issuer is replaced by another Permit to Work Issuer such that he/she understands the activities

and associated risks in the area for which they are responsible

3.15. The Permit to Work system should include a process to retain and retrieve all Permits to Work for a

minimum of one year or as required by local legislation if this is longer.

3.16. The Permit to Work system should require that a valid Permit to Work is present at the Work

Location and at a Central Work Permit Location where all other Permits to Work are displayed

3.17. The Permit to Work system must ensure that there is adequate space on the permit to log all gas

measurements necessary as defined by the Risk Assessment.

3.18. The Permit to Work must include the following elements as a minimum:

• Date the work will be carried out and the time and duration

• The exact location and the equipment/process number identification codes

• Description of the work to be carried out (the space allocated on the Permit to Work should be

such that an explanation with sufficient detail can be included) The risks identified for the job in

hand and the Risk Treatments identified (this can be in the form of a JSA).

• The name of the Permit to Work Issuer with an appropriate place to sign for Acceptance of the

Permit to Work confirming all control measures have been carried out. There should also be a

place on the permit for the Permit to Work Issuer to Sign-off when the permit duration has

ended.

• The name of the Permit to Work Holder with an appropriate place to sign for Acceptance of the

Permit to Work. There should also be a place for the Permit to Work Holder to Sign off when the

work has been completed

• The emergency contact details (telephone/radio etc.) of the Permit to Work Issuer and the

Work Permit Holder and any other relevant persons identified by the Risk Assessment.


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• The names of the Job Executers with an appropriate place to sign that the Permit to Work has

been explained and that they have understood and that all necessary control measures have

been carried out. There should also be an appropriate place on the Permit to Work for these

persons to Sign off when the job is completed. NB: when multiple Job Executers exist such as on

large projects the Sign-off can be done on the JSA that is attached to the Permit to Work.

• The tools that will be used and the Sign-off that they have been checked as fit for purpose by a

Competent Person. Contractors must provide evidence of certification for tools brought onto

site

• Materials to be used and the SDS

• Information concerning any applicable SOPs that will be applied or deviated from

• The hazards that have been identified

• The control measures that will be taken to mitigate the identified hazards

• The communication measures in place including how communication will occur with the Control

Room and with Emergency Response Teams

• The language of communication

• The emergency procedures

• The identification and signatures of other parties involved in the work such as man hole guards,

fire prevention personnel and persons carrying out gas tests.

• The results of all tests, such as gas tests, carried out should be recorded on the Permit to Work

along with the time that the tests were taken and any relevant mitigating controls. The Permit

to Work should allow enough space to record any measurements that need to be made during

the execution of the work.

4. Standard Minimum Requirements Training

4.1. Permit to Work Issuers must as a minimum be trained and experienced in the following aspects:

• Plant and equipment layout

• The technical process

• Potential hazards

• The means of mitigating hazards before issuing a Permit to Work

• The specific responsibilities associated with issuing a Permit to Work

• Applicable legal requirements

• All LBC Facility rules associated with the Permit to Work system

• The use of the different forms and/or types of Permits to Work associated with the Permit to

Work system

• Adequate communication skills training

• Shift handover requirements

• Record keeping requirements

• Emergency skills training


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Hot Work

To be developed


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Personal Protective Equipment


This policy is defined to specify the minimum controls that need to be in place regarding PPE at each LBC

Facility.

This policy applies to the correct selection, maintenance and documentation of PPE and the appropriate

training and monitoring of personnel and contractors regarding the use of PPE.



• ANSI: American National Standards Institute

• CE: is a certification mark that indicates conformity with health, safety, and environmental protection

standards for products sold within the European Economic Area

• Clean Shaven Policy is the requirement for individuals to remove facial hair when using certain sorts of

respiratory protective equipment as defined by the Risk Assessment.

• Fit for Work is a medical Risk Assessment that determines the suitability of an individual to wear sorts

of PPE to carry out their activities e.g. breathing air equipment. The necessity for this will be

determined by local regulation and Risk Assessment.

• Fit Test refers to a periodic training for employees to ensure that respiratory protection is correctly

used such that exposures to hazards are reduced. Such a training should involve the use of a Fit Test to

ensure that respiratory protection is firmly sealed around the face such that there is no leakage.

Typically, a Fit Test training will involve exposing employees to a harmless but pungently smelling

substance to determine their effectiveness at correctly using the respiratory protection.

• NFPA: National Fire Protection Association

• NIOSH: National Institute for Occupational Safety and Health

• Personal Protective Equipment (PPE) is defined as for the purposes of this standard as “all equipment

(including clothing affording protection) which is intended to be worn or held by a person at work and

which protects him or her against one or more risks to his or her safety and health. This includes but

not exclusively limited to: clothing, safety shoes, safety helmets, gloves, ear protection, eye protection

(including prescription glasses), respiratory protection equipment, high visibility clothing, safety

footwear, safety harnesses, sun protection products, barrier creams. The hazards addressed by

personal protective equipment include physical, electrical, heat, radiation, chemicals, biohazards, and

airborne particulate matter.


3.1. Any employee on an LBC Facility where operational activities are occurring should as a minimum

wear the following PPE at all times:

• Approved safety helmet

• Clothing conforming to the specified minimum requirements from Appendix 1 sections 1 and 2.

Clothing may be an overall or jacket/trouser combination.


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• Winter or rain wear (depending upon climate this item may not be necessary) if provided

should conform to the LBC specified minimum requirements Appendix 1, section 1, and the

logo placed according to the photographic impression Appendix 1, section 2

• Approved safety shoes

• Approved and appropriate eye protection. NB: The use of sunglasses (even with side-shields) is

only permitted based on Risk Assessment.

• In addition, all persons should carry the following items with them at all times for use when

necessary:

• Appropriate hand protection (gloves)

• Appropriate hearing protection

3.2. Contractors or visitors in operational areas must adhere to the minimum standards. (Note: the LBC

Style requirements of Appendix 1, Section 2 are not required on contractor clothing)

3.3. There must be a documented and auditable PPE Program in place. This program must include a

risk-based assessment of all activities to identify the hazards to which persons working at the LBC

Facility are exposed and identify the correct control measures. The hierarchy of controls is as

follows:

▪ Removal of the hazard at source

▪ Isolation of the hazard

▪ Collective controls

▪ Personal Protective Equipment

3.4. The Risk Assessment must also include medical risk e.g. Fit for Work regarding the use of

respiratory protection devices and Fall Protection devices.

3.5. Only appropriately approved and certified PPE should be sourced and made available on LBC

Facilities (e.g. CE, ANSI, NIOSH, NFPA etc.)

3.6. Where PPE is required it must be provided and be appropriately managed. There must be a

documented and auditable program in place that as a minimum includes the following aspects:

3.6.1. There must be an individual assigned with overall responsibility for the PPE program for

the LBC Facility. There must be an appropriate back-up system in place if this individual is

unavailable.

3.6.2. The selection of PPE must be consistent with local standards and regulations/legislation

and should be based on the Risk Assessment.

3.6.3. The program must include all employees, contractors and visitors to the site.

3.6.4. The program must include new employees.

3.6.5. The program must include the selection criteria, administration, maintenance of PPE,

identification and disposal of PPE no longer appropriate for purpose, correct storage of

PPE, training of individuals in all aspects of PPE selection and use and appropriate

signposting for PPE usage within the LBC Facility. In addition, there must be documented

and designated responsibilities for all these items.

3.6.6. The program must include a system that prevents defective, damaged or otherwise

saturated equipment (e.g. filters) being used.


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3.6.7. The system of selection of appropriate PPE must include a consultation process with the

users and where appropriate a selection of PPE based on comfort and fit must be available

e.g. face shapes vary so it is often impossible for all individuals to use the same face mask.

3.6.8. Regarding the use of respiratory protection masks there must be a Fit Test in place to

ensure that employees are trained and equipped to use the face masks correctly thus

preventing involuntary exposure to hazards caused by incorrectly used PPE.

3.6.9. Where necessary there must be a Clean-Shaven Policy in place for the use of certain sorts

of respiratory protection.

3.6.10. PPE of the appropriate type must be readily available and free of charge to LBC employees

and visitors.

3.6.11. Regarding contractors, the same level of PPE protection must be worn as for employees,

the costs/charges for these items must be contractually defined.

3.6.12. Regarding prescription-based PPE such as safety glasses, orthopedic safety shoes etc.,

there must be a system in place clearly identifying the preferred suppliers and the

frequency and/or circumstances where employees may acquire such items. Note, it is not

appropriate to place side shields on an employee’s normal prescription glasses.

Prescription safety glasses must meet the same requirements as non-prescription safety

glasses and be fabricated by an approved supplier.

3.6.13. The program must include a description of the appropriate PPE in SOPs

3.6.14. The program must include a periodic review (preferably annually) of all PPE in use at the

LBC Facility to assess relevance.

3.6.15. The program must include a trigger to review the necessary PPE for new activities.

3.6.16. Where Incidents occur that are related to the use of PPE (including Near Miss) the PPE

program must be reviewed and amended if necessary.


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Appendix 1: LBC Minimum requirements and LBC Style

Section 1: Minimum Requirements (standards)

LBC has enforced a minimum clothing requirement to ensure minimum protection requirements for all

persons working or visiting in an operational area. The minimum European specifications required for

clothing are listed below. All employees, contractors and visitors in operational areas must adhere to this

minimum standard. Terminals on continents where European standards are not applicable should

determine the local equivalent standard. Guidance can be found at https://www.havep.com/en.

• EN ISO 20471 – High visibility, class 2 or 3

• EN ISO 11612 – Protection against heat and flame (excludes welders and fire fighters)

• EN ISO 13034 – Protection against liquid products

• EN ISO 11611 – Clothing for use in welding and allied processes

• EN ISO 1149 – Anti-static clothing suppressing static charge

• IEC 61482-2 class 1 -Protection against the thermal hazards of an electric arc

Section 2: LBC Style

• The clothing may be in the form of an overall or jacket/trouser combination

• The florescent surface should be yellow in color

• Reflective bands should be a minimum of 50mm wide and positioned as a minimum on the arms, legs,

chest and back

• The LBC logo should be present on the front and back of the jacket/upper body of overalls.

• The name of the employee should be present on the overalls/jacket

• The base color should be chosen from navy/blue or kaki brown

https://www.havep.com/en


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Product Transfer


This policy is defined to specify the minimum controls that need to be in place for the transfer of Products

at each LBC Facility. The intent of this policy is to ensure that an Unintended Product Transfer (including

spills) cannot occur.

This policy applies to the transfer of Products to and from any Container. This includes all Loading and

Unloading and blending activities as well as activities involving the transfer of waste product such as

contaminated waste water and rainwater.



• Bonding is the process by which electrical conductors are joined together such that they have the same

electrical potential thereby preventing charge from building up and current from flowing.

• Container refers to any mobile (portable) or stationary vessel with a capacity greater than 60 liters

(15.84 US gallons) used to contain Products. For example, but not limited to drums, IBC containers, rail

cars, lorries, fixed tanks and marine vessels such as boats and barges.

• Earthing is the term also used to mean grounding. Earthing is the process of providing a low impedance

path to the earth (a physical connection to the earth) to prevent hazardous voltages from appearing on

equipment and systems to ensure that stray electricity does not come into contact with persons or give

rise to a spark.

• GHS: Globally Harmonized System of Classification and Labelling of Chemicals

• Loading and unloading relates to the movements of Products from one Container to another

• Product (or Chemical) - any substance that is handled on LBC Facilities or on a jetty facility used by LBC.

The definition is extended to include waste chemicals and waste water containing chemicals including

rainwater.

• Unintended Product Transfer refers to any movement of Product to a destination that was not the

intended destination regardless of the consequences. For example, mixing of the same or of similar

Products, the mixing of different Products, transfer of a Product to an empty vessel that was not the

intended destination, spillage etc.


3.1. There must be a system in place such that all activities involving the transfer of Products are subject

to a Risk Assessment and whereby all identified risks are treated in a risk mitigation plan. Risks must

include but not be limited to health, safety, environmental, Unintended Product Transfer, customer

dissatisfaction, other commercial risks, logistic and supply chain, facility continuity and community

impact. The Risk Assessment should specifically address all points in the supply chain process

(including secondary transfer sources such as vapor return systems) at which an Unintended Product

Transfer (including spills) could occur. The assessment should also specifically include an element to


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evaluate the risk of an Unintended Product Transfer resulting in a cross-contamination of Products

that could give rise to a violent chemical reaction with the potential for a disaster scenario. The Risk

Assessment should also include potential risks associated with any third-party supplying a transport

service.

3.2. The Risk Assessment should consider robust Risk Treatments as the first option to mitigate risks for

example automated systems, interlocks, barcoding, dedicated systems etc.

3.3. The system must include a documented, auditable and appropriate training program to train all

employees and contractors directly and indirectly involved with the activities governed by this policy

and the identified risks. The training should include a specific training element covering Earthing and

Bonding and the LBC Facility specific mechanisms by which Earthing and Bonding are to be carried

out.

3.4. The system must include the communication of the roles and responsibilities of all employees and

contractors involved in the activities governed by this policy as well as the roles and responsibilities

of external service providers such as transport service providers and independent analytical service

providers.

3.5. There must be a documented and auditable system in place to ensure that timely and appropriate

training is given to all new employees involved directly or indirectly in the activities governed by this

policy.

3.6. There should be a system in place to clearly define and communicate the roles and responsibilities to

any external parties (for example transport service providers, independent analytical organizations)

involved in the activities governed by this policy.

3.7. The system should include clear labeling/identification of all components used in the transfer

process including but not limited to tanks, pipe lines, hoses, flanges, pumps, gauges, valves and earth

lines.

3.8. The system should include the use of Product names and risk signs as defined in the GHS system.

3.9. The system should include the routine controls/checks that are to be carried out to ensure that all

components involved in Product transfer are fit for purpose.

3.10. The system should include as a minimum a periodic review of the effectiveness and relevance of all

SOPs. In any case after an Incident the relevant SOP should be reviewed and where necessary

amended.

3.11. There must be SOPs in place governing all activities in which the transfer of Products has been

identified. Such procedures must include step by step defined actions to mitigate the risks identified

in the Risk Assessment. SOPs must include as a minimum the following items:

• The roles and responsibilities of all parties in the process (contractors, external parties and LBC

personnel) must be clearly defined, trained and communicated.

• The communication methods and processes between all parties involved in all transfers at

every step of the transfer i.e. prior, during and after.

• The steps for receiving and/or identifying a Container or Containers into and out of which the

transfer of Products apply.

• The steps for identifying the Product and the Product quantities to be transferred.


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• The equipment that will be used to track (monitor) and control the appropriate weights and/or

quantities of Products to be transferred.

• The availability and control of the SDS for all Products involved.

• The PPE (including Fall Protection if necessary) to be worn by all parties, including contractors,

involved with the Product transfer.

• In case of waste Products including rainwater, a process for checking the chemical nature of the

Products and defining the correct PPE and other safety measures to be used.

• A cross-check system to double check that the Products being transferred are the correct

Products and are leaving and/or arriving from the correct Containers i.e. a process to prevent

an Unintended Product Transfer.

• Special attention to all points identified in the Risk Assessment that could result in an

Unintended Product Transfer capable of causing a cross-contamination Incident with the

potential for a chemical reaction giving rise to a disaster scenario.

• A “clean Container” step in which the cleanliness of a Container is confirmed and proven or in

which the previous contents of a Container are proven and are checked to be appropriate for

the Products to be transferred.

• Specific steps required to mitigate the inherent risks associated with multiple cargo transfers.

• A step to earth and bond all necessary equipment prior to the start of the transfer and to verify

that the Earthing and Bonding has occurred.

• A step to ensure that the removal of the earth cable is the last step in the process when the

Product has been transferred and all the equipment has been disconnected.

• A clear instruction that it is forbidden to bypass a required Earthing or Bonding system.

• A step to remove keys from the cabin of all road and rail based vehicles during the transfer

process. This step should include a clear instruction of where the driver must be during the

transfer process.

• A step to block the wheels on all road and rail based vehicles (chocks).

• A process of ensuring a visible warning is used when Product transfer is in process involving a

vehicle that could potentially be operated (such as a lorry, truck or train) such as a flag or

barrier in front of the vehicle. Such a warning system must be risk assessed to ensure that it is

clearly visible to all parties (for example minimum flag height).

• An overfill safety process must be identified for each transfer.

• A process to check all valves, outlets, flanges and gauges prior to, during and upon completion

of the transfer of Product. This check must include a check for correct functioning and

connection.

• A process to ensure that all valves, outlets and flanges not involved in the transfer are closed.

• Clear guidelines for safely opening manholes and removing bolts from manholes and flanges.

• A step to ensure that all lines are pressure free before connections are removed

• The process and equipment for vapor recovery if identified by the Risk Assessment as being

necessary and the way an unintended transfer of recovered Product can be avoided.


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• Steps to place suitable containment vessels i.e. “drip pans” under all in- and outlet points

involved in the transfer.

• The process for identifying Product collected in “drip pans” and recycling and/or disposing of

such Products.

• The steps required to identify the correct hoses for the transfer and to carry out pre-, in- and

post-use inspections to identify issues such as failing hoses/leaks.

• Steps to clean hoses after transfer.

• Steps to cap/close all outlet points (hoses, flanges, manholes, drains etc.) to prevent leakage

following transfer. Where the Risk Assessment identifies the need for a flare or filter system

there should be clearly defined steps in the SOP governing the line-up of these.

• There should be a sign-off process in which all parties such as but not limited to Customer

Service, Dispatch, Operations, sign-off for the transfer of chemicals before transfer begins and

after transfer has occurred.


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Isolation of Energy Sources


This policy is defined to specify the minimum requirement controls that need to be in place for Isolation of

Hazardous Energy sources at each LBC Facility.

This policy applies to all sources of Hazardous Energy and Hazardous Substances except for:

• Circumstances where exposure to Hazardous Energy is completely controlled by unplugging the item

from an electric outlet and in situations where the employee (or other) has complete control over the

plug and where electricity is the only source of Hazardous Energy (e.g. but not limited to portable

items such as a vacuum cleaner).

• Circumstances in which a trained and authorized person is performing minor tool changes or other

minor servicing activities that are routine, repetitive, and an integral part of production and that occur

during normal production operations and that have been identified and documented in the Risk

Register and for which there are risk assessed and documented standard operating procedures (SOP)

and work instructions.

• Hot tap operations. These types of operations require a specific Risk Assessment and Risk Treatment

measures that require approval from the highest-ranking member on the LBC Facility or his delegate.


Definitions pertaining to this procedure are

• Energy-isolating device: A mechanical device that physically prevents the transmission or release of

energy. Examples include, manually operated electrical circuit breaker, a disconnect switch, manually

operated switch by which the conductors of a circuit can be disconnected from all

Ungrounded/Unearthed supply conductors (and in addition no pole can be operated independently), a

line valve, a block or similar device used to block or isolate energy. NOTE: push buttons, selector

switches and other control circuit-type devices are not Energy-Isolation Devices.

• Hazardous Energy: for example, but not limited to: electrical, pneumatic, hydraulic, stored (for

example in springs and batteries), potential (by position), heat (for example, hot water, steam),

velocity and radiation.

• Hazardous substances: Gases, vapors, liquids, dusts (solids) with the potential to cause injury or illness

e.g. toxic, corrosive flammable.

• Hot tap: Deliberately piercing the pressure boundary of equipment that is in service or under pressure,

without shutting down or gas freeing the equipment

• Isolation Officer: Competent Person designated to carry out the Isolation procedure. No person may be

designated as an Isolation Officer for an item unless he has been trained, tested and certified in

accordance with local legislation as competent to carry out the specific isolation procedure for that

specific item and thus meets the requirements of the Competent Person definition.


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• Item – is a device (owned or not owned by LBC) that is on LBC premises and requires a Lockout/Tag-out

(LOTO) procedure to isolate all energy sources prior to performing an activity such as servicing or

maintaining.

• Lock box - is a Lockable box containing the key(s) of locks physically applied by Isolation Officers to

hold all energy isolation devices in a safe position and prevent the energizing of machines or

equipment being serviced or maintained.

• Lockout: this is the placement of a Lockout Device on an Energy-Isolating Device that ensures that the

Energy-Isolating Device and the item being controlled cannot be operated until the Lockout Device is

removed.

• Lockout device: A device that uses a positive means such as a lock, either key or combination, to hold

an Energy-Isolation Device in the safe position and prevent the energizing of the item. Included in this

definition are blank flanges and bolted slip blinds that have been identified as such.

• Lockout/Tag-out (LOTO) or (Isolation) refers to the specific practice and procedures to safeguard

employees and others from the unplanned energization or startup of items such as although not

limited to machinery, apparatus, equipment, plant or process during planned and unplanned service

and maintenance activities. Only a designated and trained individual (Isolation Officer) may isolate the

energy source to the equipment or machinery and lock and/or tag the energy isolating device to

prevent the unexpected release of Hazardous Energy.

• Master Lock: A lock or series of locks that are controlled by a master key.

• Personal Lock – a Master Lock issued individually to each Isolation Officer and for the use of only the

designated Isolation Officer to which it was issued.

• Tag-out: This is the placement of a tag-out device (isolation device) on an Energy-Isolation Device to

indicate that the Energy-Isolation Device and the equipment being controlled may not be operated

until the tag-out device is removed.

• Tag-out device: Is a prominent warning device, such as a tag with a means of attachment, which can be

securely fastened to an Energy-Isolation Device in accordance with an established procedure, to

indicate that the Energy-Isolation Device and the item being controlled may not be operated until the

tag-out device is removed. The tag-out device is weather proof

• Ungrounded/unearthed relates to systems/equipment that have not been subject to Earthing.


3.1. There must be a procedure in place to ensure that all employees and contractors working on the

premises and on an LBC owned Item or other Item are informed of the LBC Isolation of Energy

sources policy and that it is applied.

3.2. Lockout Devices are to be used over Tag-out devices.

3.3. Whenever an Item is to be isolated, there must be a person designated as the Isolation Officer who

performs the isolation procedure

3.4. All Lockout/Tag-out Devices used by the Isolation Officer must be clearly identifiable as belonging

only to that specific Isolation Officer.


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3.5. All Items requiring the use of a Isolation procedure for maintenance and service must be identified in

a Risk Register (Energy Isolation Plan) and the point(s) where the Isolation is to be applied must be

clearly identified both in the Risk Register and on the machinery/equipment to be isolated.

3.6. All Items identified in the Risk Register must have a documented procedure for carrying out the

isolation. The procedure must set out how the Item will be made safe and kept safe. For example,

the Risk Register will include; decontamination, venting of stored energy, securing of rotors or fan

blades, chocking of vehicles, and disconnection, blocking or bleeding of equipment, cables, pipes and

vessels to name but a few. The procedure must also show the isolation points for the Lockout/Tag-

out Device and the test procedures to ensure that Isolation has been successfully accomplished and

the process for re-energizing the device. The procedure should include a list of persons identified,

trained, designated and authorized as Isolation Officers for the particular Item.

3.7. Personal Lockout/Tag-out Devices must be applied by each person working on the Item in addition to

the lock applied by the Isolation Officer.

3.8. There must be a system in place to identify activities that occur near adjacent or connected

energized Item(s) that may also require that Item to also be isolated. e.g. where there is a risk of a

body part entering the Danger Zone.

3.9. There must be a procedure defining in what circumstances and under whose authority a

Lockout/Tag-out Device may be removed by a person other than the person applying the device.

This system should require a written approval from the highest-ranking member on the LBC Facility

or his delegate.

3.10. There must be a system in place for defining how communication between different shifts/teams will

take place.

4. Isolation Officer’s Responsibility

4.1. The Isolation Officer is responsible for ensuring that the Item to be worked upon has been made safe

(de-energized, Product free) in accordance with the isolation procedure for that Item.

4.2. The Isolation Officer’s Lockout/Tag-out Device (which is identifiable) must be the first to be applied

and the last to be removed.

4.3. The Isolation Officer’s lock (Lockout Device) must be a master series lock since it will remain on the

Item when handing over to subsequent shifts. Keys to the Isolation Officer’s lock must only be held

by other designated Isolation Officer for that Item. The same principle applies in the case of a tag-

out device.

4.4. In the case where isolation involves only one person on a job to be completed within a single shift

and where it is not appropriate for a master series lock to be utilized, the person must be an Isolation

Officer and he must apply his personal lock and/or identification tag.

4.5. After applying the Isolation of the Item, the Isolation Officer must CLEAR the area of personnel and

carry out the designated trial to ensure isolation has been successful as described in the Isolation

Procedure. NB: in the case of electrical isolation a TEST for voltage must be carried out to ensure the

absence of voltage; this must be completed in accordance with the Group Electrical Policy.

4.6. Where there is a need for work to extend over multiple shifts and involving multiple persons the Risk

Assessment should identify the need for a Project Isolation Procedure. This procedure must meet the


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requirement that all persons working on the project have a Personal Lock and that an Isolation

Officer’s control lock is in place and this control lock cannot be removed without all personal locks

being removed first.

5. Other responsibilities

5.1. Everybody (as well as the Isolation Officer), who has to perform work on an Item must first apply

his/her personal lock and identification tag in accordance with the isolation procedure.

5.2. Personal Locks and personal tags may only be removed by the owner.

5.3. Personal Locks may NEVER be removed by another person except in accordance with the local

‘Emergency Removal of Isolation Device Procedure’.


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Confined Space


This policy is defined to specify the minimum requirement controls that need to be in place for carrying out

Confined Space work at each LBC Facility.

This policy applies to all temporary and permanent Confined Spaces on LBC Facilities. Entry into a Confined

Space Under Inert Atmosphere is not part of the scope of this Policy and it is not permitted for LBC

employees to conduct such activities. If Inert Entry is required this must be conducted by specialist

contractor organizations and be subject to a specific Risk Assessment.



• Confined Space is defined as an enclosed or partially enclosed space that;

• Has been identified as such in a Risk Assessment

• Is not intended or designed primarily as a place of work

• May have restricted entry and/or exit

• May have an atmosphere which contains potentially harmful levels of Contaminants

• May not have a safe level of oxygen for example but not limited to -following a nitrogen purge, as a

result of decaying dead organic matter, chemical reaction etc.

Examples of a Confined Spaces but not limited to are: Storage tanks, process vessels, boilers,

pressure vessels (such as vacuum wagons), tank-like compartments that have only a man-hole for

entry, cellars, attics, open topped spaces such as the space under a weigh bridge, excavation

trenches deeper than 1.2 meters, sewers, shafts, ducts and drains.

• Confined Space Under Inert Atmosphere (Inert Entry) is defined as a Confined Space which has been

purged or put under a blanket of an inert gas such as but not limited to nitrogen or argon. It is not

permitted for LBC personnel to enter a Confined Space Under Inert Atmosphere. This must be

conducted by specialist contractors and a specific Risk Assessment and procedures must to be

developed specifically for Inert Entry.

• Confined Space Watch– this is a specially trained Competent Person whose only task is to remain

outside the Confined Space entrance in communication with the person(s) in the Confined Space and is

charged with raising the alarm in an emergency. This person may have no other tasks when

performing this duty.

• Contaminant is defined as any dust, fume, mist, vapor, gas or other substance in liquid or solid form

that may due to its presence or absence be harmful to health and safety of personnel

• Danger Zone – this refers to an area (typically cordoned off) that is considered hazardous. The Danger

Zone and the safety measurements that apply in the danger zone are determined based on a Risk

Assessment carried out by Competent Persons. A danger zone may be established:


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• around an Excavation site

• around the outside of a Confined Space due to the nature of the atmosphere in the Confined

Space or in which a High-Pressure water jet is being utilized

• around a working at height or Hoisting/Lifting activity

• Entry into a Confined Space is defined either as a person’s whole body, upper body or head entering a

Confined Space. This is not intended to prevent a person placing their hand or arm into a Confined

Space under normal atmosphere while using a testing device or a probe as part of a risk assessed and

clearly defined and authorized procedure.

• Fire Watch – this is a Competent Person to carry out fire prevention and fire repression actions during

hot work or other activities that can give rise to fire and/or explosion. This person is charged with

raising the emergency alarm if a fire occurs during the activities he is watching. This person may have

no other tasks when performing this duty. Such tasks include but are not limited to the correct

selection and use of fire-fighting equipment

• Inert Entry – is defined as either a person’s whole body, upper body or head entering the Confined

Space Under Inert Atmosphere.

• Rescue Team – a group of people who are trained to carry out rescue of a person or persons working

in a Confined Space. As a minimum, the Rescue Team must be comprised of a Standby Person (number

1)- wearing appropriate to the situation PPE and an independent breathing air source to enter the

Confined Space and perform a rescue during an emergency and a second Standby Person (number 2)

with appropriate to the situation PPE and immediate access to an independent breathing air source.

Number 2 will be responsible for coordination and communication during the rescue process. It is

acceptable for the Team Members to rotate roles during any one shift but provision must be made to

ensure that persons wearing independent breathing air equipment receive sufficient rest in

accordance with local regulations. Rescue Team member must be competent to fulfill the tasks

associated with the roles in accordance with the Competent Person definition.


3.1 All Confined Spaces must be identified in a Confined Space Risk Register. A Risk Assessment must be

performed for each Confined Space in both the unpopulated state and the populated state i.e. during

the differing sorts of work activities that could be expected to be carried out in the Confined Space.

The Risk Assessment must specifically consider the amount of time that a person can spend in any

one session in a Confined Space and the total amount of time that can be spent in consecutive

sessions in any one shift. The Risk Assessment must specifically take account of the ambient

temperature and the respiratory protection being used.

3.2 All Confined Spaces on all LBC facilities should be clearly labeled at the Confined Space entrance as

being a Confined Space and requiring a Permit to Work to enter. Temporary Confined Spaces should

also be clearly labeled at the Confined Space entrance.

3.3 Documented and traceable training should be given to all employees and contractors about

recognizing a Confined Space and the associated risks. Such training should be regular and repeated

as a minimum annually.


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3.4 All persons entering a Confined Space or acting as a Rescue Team member, Confined Space Watch

and/or Fire Watch must be Competent Persons.

3.5 Specific training must be given to all members of a Rescue Team detailing the additional Risks

associated with the use of independent breathing apparatus. Each member of the team must be

certified to carry out duties including the appropriate medical certification for the use of

independent breathing air supplies.

3.6 Safe work procedures must be developed for all work activities that are carried out in a Confined

Space.

3.7 Risk assessed rescue procedures must be developed for each Confined Space applicable to the

activity.

3.8 Safe work procedures must be developed for all work activities that are more dangerous when

carried out in a Confined Space than elsewhere, for example, but not limited to hot work (cutting and

welding), chemical cleaning, steam cleaning.

3.9 The Confined Space Watch and/or Fire Watch and/or Standby Person will have no other duties and

must be positioned outside the Confined Space entry point at all times and able to communicate with

the person(s) working in the Confined Space. The distance of the person from the Confined Space

must be determined based on Risk Assessment.

3.10 Equipment foreseen with an audible alarm (such as gas detection equipment) must be located at a

suitable distance such that the Confined Space Watch and the Fire Watch can hear the audible alarm.

3.11 Where the Risk Assessment has identified the need for ventilation this must be covered by a

documented procedure and appropriate training must be given to persons responsible for

implementing ventilation provisions. The air exchange requirements must be determined based on

the Risk Assessment.

3.12 All persons charged with carrying out measurements of contaminants in a Confined Space and/or in

the Danger Zone must be authorized, trained annually and competent to use the chosen

measurement/monitoring device.

3.13 There must be a system in place to ensure that gas measuring devices are maintained in accordance

with manufacturers recommendations, certified as fit for use and calibrated prior to use.

3.14 The number of persons working simultaneously in a Confined Space must be limited to the absolute

safe minimum based on a Risk Assessment.

3.15 Safety provisions (e.g. ventilation, air monitoring, rescue, etc.) should take into account the number

of persons working in the Confined Space

3.16 Continuous gas monitoring must be carried out for all Confined Space work. Probes should be

strategically placed to adequately measure levels. Gas measurements must be documented hourly

on the Permit to Work.

3.17 A Risk Assessment should consider the need for personal monitoring devices.

3.18 Atmospheric conditions must meet the following criteria always during entry:


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Without respiratory protection With independent supplied air

Oxygen (%) 19.5 to 21.5 <Less than 19.5 or greater

than 21.5

Toxics Less than Occupational Exposure

Limit

Greater than Occupational Exposure Limit

Flammables (% of Lower

Explosive Limit)

Less than 10

Less than 10

Temperature (Celcius) Less than 35 oC Less than 35 oC

3.19 Entry into a Confined Space must only be allowed after written approval and Risk Assessment by a

Competent Person in the form of a specific Confined Space Entry Permit to Work. The Permit to Work

must include as a minimum the following aspects:

• A Risk Assessment that identifies all Risks associated with the work but which specifically

addresses the following:

• The required contaminant measurements (e.g. oxygen levels, concentration of

flammable substances) and the identification of the Competent Person who will

conduct these measurements.

• Isolation procedures for contaminants and other energy sources as detailed in the

Isolation of Energy Sources Policy.

• The respiratory protection requirement(s) and/or ventilation.

• The sign-in, sign-out procedure and log for all persons entering the Confined Space.

There should be room for multiple entries to be logged and this log must be kept at

the Confined Space entry location.

• The communication equipment and communication method.

• Confined Space Watch

• Fire Watch if required

• Rescue Team and Rescue procedures, responsibilities and equipment (risk based depending

upon circumstances such as depth, inert atmosphere, restrictions for sending a rescuer and/or

rescue stretcher in etc.).

• Safeguarding of the Confined Space area and Danger Zone during working hours and outside

working hours.

• Identification and cordoning off of the Danger Zone around the Confined Space area and the

special measurements that need to be taken when entering this zone

• Safety specification of equipment permitted in the Confined Space (e.g. safe voltage).

• The completion procedure - to determine that there are no more persons working in the

Confined Space and that the work to be carried out in the Confined Space is finalized, that all

equipment has been removed, the Danger Zone has been made safe and whereby the

Confined Space is returned to a state that it is clear that it is a Confined Space requiring a

permit to work for subsequent activities.


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High Pressure Water Jetting


This policy is defined to specify the minimum requirement controls that need to be in place for conducting

High-Pressure water jetting activities with the use of High Pressure Water Jetting Equipment including the

emergency response procedure for dealing with High-Pressure water jetting injuries.

This policy applies to all LBC Facilities and to all to all High-Pressure water jetting activities be that manual,

fully automatic or semi-automatic systems. The policy also applies to combination High Pressure vacuum

equipment.

This policy must be applied together with the Pressure Vacuum Policy where there is equipment in use that

falls under the scope of the two policies.


• ATEX – Explosive Atmosphere Regulations

• Emergency Stop Button on the High-Pressure Water Jetting System ensures that the High-Pressure

Water Jetting System is immediately depressurized and switches off the whole High-Pressure Water

Jetting System. The remote emergency stop button ensures that the system and the High-Pressure line

are immediately depressurized. Before a High-Pressure Water Jetting System can be switched on again,

it must be reset and it must not be possible after activating the emergency stop button to switch on the

High-Pressure Water Jetting System again with the emergency stop button.

• Emergency Stop Operator is an employee who has the emergency stop button within reach and who

has constant visual contact with the High-Pressure Water Jetter so that he can immediately

depressurize the system using the emergency stop button in the event of a dangerous situation. The

Emergency Stop Operator must hold a valid certificate as High Pressure Water Jetter or High-Pressure

Pump Operator.

• Equipment Operator – this refers to any person using any:

• Pressure Vacuum Truck or Accessories to carry out work; or

• High-Pressure Water Jetting System, High-Pressure Water Jetting Accessories or High-Pressure

Jetting Equipment to carry out work.

• Foot pedal is a foot-operated pedal for pressuring or depressurizing the Jetting Equipment or supply

hose.

• Fully Automatic Cleaning refers to cleaning in which the High-Pressure Jetting Equipment is operated

form a safe distance by a High-Pressure Water Jetter. The High-Pressure Water Jetter must have

complete control over the Jetting Equipment. During pressurization of the High-Pressure Water Jetting

System, the High-Pressure Pump Operator must have a clear view of the working area.

• High pressure is understood to be a working pressure of higher than 250 bar or where the pump power

is higher than 10 kW with a working pressure of higher than 25 bar

• High Pressure Jetting Equipment (or Jetting Equipment) is apparatus equipped with a nozzle (s) with

which the High-Pressure water jet is directed at the surface to be cleaned. For example, but not limited

to: het gun, flexible lance, foot pedal, floor/wall cleaner, lance machine, tank cleaning head.


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• High Pressure Water Jetting Accessories (or Accessories) refers to all equipment needed to be able to

work with the High-Pressure water jetting installation to carry out the High-Pressure water jetting

activity. This includes but is not limited to such items as High Pressure hoses; hose fracture protection

devices and Jetting Equipment.

• High Pressure Water Jetter is responsible for carrying out the High-Pressure water jetting work assigned

to him and he works under the supervision of the High-Pressure Pump Operator at all times.

• High Pressure Water Jetting System is an installation, fixed or mobile, consisting of a power unit, pump

unit, pressure regulation device, pressure gauge, safety devices, hoses and jetting device with which

water can be jetted at High Pressure.

• High Pressure Pump Operator is responsible for the High-Pressure Water Jetting System and for all

actions undertaken. He must be present at the place of work all the time.

• Hose catching mechanism is a device that catches the hose in the event of uncontrolled recoil or

controlled recovery of the hose.

• Hose sleeve is installed over the hose coupling to the jet gun and is resistant to the escaping water jet in

the event of leaks in the hose or coupling.

• Manual cleaning refers to cleaning during which the Jetting Equipment is operated by the High-Pressure

Water Jetter. The High-Pressure Water Jetting System is pressurized by the High-Pressure Water Jetter

by means of a switch on the Jetting Equipment, jet gun or foot pedal. An Emergency Stop Operator must

be present at all times. He must be in constant visual contact with the High-Pressure Water Jetter.

• Semi-automatic cleaning refers to cleaning during which the Jetting Equipment is operated manually by

the High-Pressure Water Jetter. The High-Pressure Water Jetter is sufficiently protected from the High-

Pressure water jet coming out of the equipment. The High-Pressure Water Jetting System is pressurized

by the High-Pressure Water Jetter by means of a switch on the Jetting Equipment. The High-Pressure

Water Jetter must have a clear view of the working area. The Emergency Stop Button is operated by an

Emergency Stop Operator.

• Tank cleaning head is a three-dimensional rotating cleaning head that can be used to clean Confined

Spaces.


3.1. Standard Minimum Requirements Industry standard

3.1.1. LBC has chosen to adopt as a minimum the technical operating and training standards used in

Belgium and The Netherlands based on European legislation and laid down by the Stichting

Industriële Reiniging (SIR also known as The Industrial Cleaning Foundation) for the technical

specification of equipment and Accessories and for the training and certification protocols of

Equipment Operators and other involved personnel. The SIR site can be consulted at www.Sir-

safe.nl. The website, standards and training protocols are available in English, Dutch, German

and French language. Where local legislation prescribes a higher standard, this should be

adopted.

3.2. Standard Minimum Requirements contractors

http://www.sir-safe.nl/



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3.2.1. Only contractors that are SIR approved (www.Sir-safe.nl) or can demonstrate that their

personnel (Equipment Operators) and equipment meets the same or a higher technical and

training standard than prescribed by SIR may be employed on LBC premises.

3.2.2. Where contractors and their equipment are not SIR approved, the contractor must present to

LBC a comprehensive analysis prior to selection and award of the contract demonstrating the

equivalent or higher standard than SIR for operational personnel, equipment and Accessories

employed on the job.

3.3. Standard Minimum Requirements LBC equipment and operators

3.3.1. Where LBC uses own (or hired) equipment, own (or hired) Accessories and own Equipment

Operators to conduct High-Pressure water jetting activities, LBC must ensure that all equipment,

Accessories and Equipment Operators and the Emergency Stop Operator are SIR certified or have

a documented and demonstrable equivalent or higher technical training* standard than SIR.

3.4. Standard Minimum Requirements for Training for Permit to Work Issuers and persons with

Supervision tasks

3.4.1. Permits to Work Issuers related to High Pressure water jetting activities must have a valid and up

to date High Pressure Supervisor Certificate from SIR or must have a training* and certificate that

is demonstrably at the same or a higher level as SIR.

3.4.2. Shift leaders responsible for operational activities and HSSEQ personnel are subject to the same

training and certification criteria as Permit to Work Issuers.

3.5. Standard Minimum Requirements Training All Other Employees

3.5.1. A Risk Assessment should identify employees that should receive as part of their annual training

a demonstrable and adequate training regarding the recognizing the safe execution of High

Pressure water jetting activities and the Risks associated with this work. It is the intention that

these persons will can make an adequate judgment concerning the safe execution of these

activities and that if needed could carry out an intervention. As a minimum, this training should

cover:

• The different roles involved in the pressure jetting activity (from permit issue to job

execution and job completion) including recognizing minimum manning requirements for

equipment and emergency stop devices in conjunction with the type of cleaning activity i.e

automatic, semi-automatic and manual.

• Required PPE depending upon the circumstances (automatic, semi- automatic, manual) and

the use of demarcation signage.

• The requirements for a safe work platform resistant to the reaction forces from the pressure

Jetting Equipment.

• Fundamentals of the “High pressure decision tree” prescribed in the SIR guidelines

• A description of the main sorts of High Pressure or pressure vacuum installations and

Accessories and the main components for manual, semi- automatic and automatic jetting.


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• A description of the required safety protection devices on High Pressure Water Jetting

Systems to prevent inadvertent operations occurring

• A description of other protective devices such as hose protectors and Hose Catchers,

impingement rings, marking rings.

• Minimum requirements for jet guns but not limited to e.g. trigger guard, minimum barrel

length, depressurization status of a jet gun at rest, trigger lock, maximum trigger force, and

the use of a hose sleeve

• Requirements for Foot Pedals

• The fundamentals of a nozzle selection card

• Fundamentals of hose inspections and hose integrity

• ATEX zoning principles in the context of equipment usage

• Static electricity and grounding

• The correct use of emergency stop equipment and the specifics of Incident and medical

intervention

• The use of hot water and/or additives

• Appraisal of the quality and validity of the checklists and logbooks filled in by the Equipment

Operators

• Appraisal of the quality and validity of the Permit to Work and JSA

• Last Minute Risk Assessment training

• Maintaining control over the work area

3.5.2. A process must be in place to identify competency requirements for other roles other than the

ones mentioned above.

3.6. Standard Minimum Requirement Permit to Work and JSA

3.6.1. The following occupational risk hierarchy must be applied when selecting the method of High

Pressure water jetting cleaning:

• Fully automatic (first choice)

• Semi- automatic (second choice)

• Manual cleaning (last choice)

3.6.2. A specific High Pressure Water Jetting Permit to Work must be completed and issued for every

High-Pressure water jetting job. It is not permitted to issue a general Permit to Work for these

activities.

3.6.3. Accessing the tank of a High-Pressure equipment is considered a Confined Space activity and as

such a specific Confined Space Entry Permit to Work must cover this activity.

3.6.4. In addition to the Permit to Work there must be a JSA submitted for each job detailing the

specific Risks for each job, the control measures and work methodology. Note this JSA must

consider the risk of exposure to legionella bacteria and appropriate control measures.

3.7. Emergency response


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3.7.1. Note: High Pressure injuries are different than other injuries and require specific medical

attention. There must be a system of training in place for alerting employees to the characteristics

of a High Pressure wound and the immediate actions that should be taken if they encounter a

situation where a person is involved in an Incident in which a body has been damaged by High

Pressure.

3.7.2. Each LBC Facility must identify hospitals that are equipped to deal with High Pressure injuries and

each LBC Facility must ensure that casualties are dispatched to hospital with the “High Pressure

Medical Treatment Card” to ensure that injuries are treated correctly.

Clarification Note Training and Certification

• *NB: LBC can (if allowable under local legislation) choose to establish their own training and

certification process for Permit to Work Issuers and Equipment Operators conducting pressure

vacuum activities. This training and certification must be based on the SIR guidelines. The

program must include the re-training and re-certification of all certificate holders every three

years. The training and certification process must include an adequate written examination to

acquire valid certification and authorization to issue permits for these activities or in the case

of equipment operators carry out these activities.


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Pressure Vacuum


This policy is defined to specify the minimum requirement controls that need to be in place for conducting

pressure vacuum activities with the use of pressure vacuum equipment including the emergency response

procedure for dealing with vacuum injuries.

The policy applies to all LBC Facilities.







• Pressure Vacuum Accessories (or Accessories) refers to all equipment that is necessary to be able to

work with the pressure vacuum truck and carry out the pressure vacuum activities. For example, but

not limited to ohm-hoses and m-hoses.

• Pressure vacuum Supervisor – refers to the person supervising the pressure vacuum work. Supervisors

must have sufficient knowledge and skills to guarantee safety during the preparation and

implementation of pressure vacuum cleaning work.

• Pressure Vacuum Truck refers to the pressure vacuum truck for liquids as well as the air displacement

truck and suction excavator truck.


3.1. Standard Minimum Requirements Industry standard

3.1.1. LBC has chosen to adopt the technical operating and training standards used in Belgium and

The Netherlands based on European legislation and laid down by the Stichting Industriële

Reiniging (SIR also known as The Industrial Cleaning Foundation) for the technical specification

of equipment and Accessories and for the training and certification protocols of Equipment

Operators and other involved personnel. The SIR site can be consulted at http://www.Sir-

safe.nl. The website, standards and training protocols are available in English, Dutch, German

and French language. Where local legislation prescribes a higher standard, this should be

adopted.

3.2. Standard Minimum Requirements contractors

3.2.1. Only contractors that are SIR approved (www.Sir-safe.nl) or can demonstrate that their

personnel (Equipment Operators) and equipment meets the same or a higher technical and

training standard than prescribed by SIR may be employed on LBC Facilities.




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3.2.2. Where contractors and their equipment are not SIR approved, the contractor must present to

LBC a comprehensive analysis prior to selection and award of the contract demonstrating the

equivalent or higher standard than SIR for operational personnel, equipment and Accessories

employed on the job.

3.3. Standard Minimum Requirements LBC equipment and operators

3.3.1. Where LBC uses own (or hired) equipment, own (or hired) Accessories and own Equipment

Operators to conduct vacuum pressure activities, LBC must ensure that all equipment,

Accessories and Equipment Operators are SIR certified or have a documented and

demonstrable equivalent or higher technical and training* standard than SIR.

3.4. Standard Minimum Requirements for Training for Permit to Work Issuers and persons with

Supervision tasks

3.4.1. All Permit to Work Issuers related to pressure vacuum activities must have a valid and up to

date Pressure Vacuum Supervisor Certificate from SIR or must have a training* and certificate

that is demonstrably at the same or a higher level as SIR.

3.4.2. Shift leaders responsible for operational activities and HSSEQ personnel must receive the same

training and certification as Permit to work Issuers.

3.5. Standard Minimum Requirements Training All Other Operational Employees

3.5.1. All other operational employees – should receive as part of their annual training a

demonstrably and adequate training regarding the recognizing the safe execution of vacuum

pressure activities and the Risks associated with this work. It is the intention that these persons

will can make an adequate judgment concerning the safe execution of these activities and that

if needed could carry out an intervention. As a minimum, this training should cover:

• The different roles involved in the pressure vacuum activity (from permit issue to job

execution and job completion) including recognizing minimum manning requirements for

equipment

• Minimum required PPE

• A description of the different sorts of vacuum pressure trucks or other installations as

covered by the scope and the main equipment components

• Purpose of a return air system and scrubber

• Requirements for apparatus depending upon the ATEX and/or chemicals involved

• Approved hose (Ohms and M-type) and coupling types

• Principles of aeration and deaeration, implosion and explosion and the dangers of

suctioning air

• Sources of ignition e.g. warm engines and hoses and hard objects that could be suctioned

eg. stones, bolts, nuts,

• Reactions with residual substances in a pressure vacuum tank (need for clean tank

certificates)


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• Static electricity and grounding

• Release of Hazardous Substances via the ventilation/blow off devices and the importance

of positioning these devices correctly in relation to other activities or equipment

• Dangers associated with the suctioning power on the socket

• The correct use of emergency stops equipment and the specifics of Incident and medical

intervention

• Appraisal of the quality and validity of the checklists and logbooks filled in by the

Equipment Operators

• Appraisal of the quality and validity of the Permit to Work and JSA

• LMRA training

• Maintaining control over the work area

3.5.2. A process must be in place to identify competency requirements for other roles other than the

ones mentioned above.

3.6. Permit to Work and JSA

3.6.1. A specific Vacuum Pressure Permit to Work must be completed and issued for every vacuum

pressure job. It is not permitted to issue a general Permit to Work for these activities.

3.6.2. Accessing the tank of a pressure vacuum truck or the tank (waste) compartment of a suction

excavator or the filter chamber of a pressure vacuum truck or suction excavator must be

considered as Confined Space activity and as such a Confined Space Permit to Work must cover

this activity.

3.6.3. In addition to the permit to work there must be a JSA submitted for each job detailing the

specific risks for each job and the control measures.

3.7. Emergency response

3.7.1. There must be a system of training in place alerting employees to the immediate actions that

should be taken if they encounter a situation where a person is involved in an Incident in which

a body part is suctioned into a hose or excavator arm.

3.7.2. The emergency response process must include the identification of nearby hospitals /

emergency response centers that are capable of treating injuries from pressure vacuum

operations.

3.7.3. Where combination trucks are in use (High Pressure and vacuum) there must be a system in

place for ensuring that personnel are alerted to the immediate and appropriate actions that

should be taken regarding High Pressure entry wounds (see High Pressure Water Jetting Policy)


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Clarification Note Training and Certification

• *NB: LBC can (if allowable under local legislation) choose to establish their own training and

certification process for Permit to Work Issuers, Equipment Operators and Supervisors of

pressure vacuum activities. This training and certification must be based on the SIR guidelines.

The program must include the re-training and re-certification of all certificate holders every

three years. The training and certification process must include an adequate written

examination to acquire valid certification and authorization to issue permits for these

activities or in the case of equipment operators carry out these activities.


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Hoisting and Lifting


This policy is defined to specify the minimum requirement that need to be in place for all Hoisting and

Lifting activities at each LBC Facility.



• Blind Lift – Lift where the operator cannot see the load for some or all of the Lifting / Hoisting

operation.

• Hoisting is defined as an activity during which the load is suspended and hangs freely e.g. by means of

but not limited to a crane, chain hoist, beam clamp etc.

Lifting is as an activity during which the load is lifted in a controlled and guided manner, normally

spoken from the bottom of the load, e.g. by means of but not limited to a forklift truck, screw jack,

hydraulic jack etc. The term “lifting” is used though out the policy to describe all types of lifting and

hoisting.

• Lift Plan – is a document that defines exactly how Lifting / Hoisting will be carried out. The document

must be based on Risk Assessment.

• Non-routine lift

Non-routine Complex Lift - is characterized by: Lift gross weight >90% of the rated capacity of the Lifting

appliance, use of two or more Lifting appliances, within difficult or restricted areas, over active or

energized equipment, tanks and other critical assets, work in vicinity of overhead electrical power lines,

lowering of a load into a Confined Space, Blind Lift, Lifting of personnel.

Non-routine Simple Lift – is characterized by: Lift gross weight >75% (but less than 90%) of the crane

capacity, loads with known and evaluated weight with a center of gravity below the Lifting point, ample

headroom, unlikely to be affected by changing environmental conditions, not working within live

process, narrow or restricted areas.

• Person in Charge (PIC) – One person must always be designated as the Person in charge of the Lifting

operation in the field. This person has operational control over the lift and is responsible for reviewing

the Lift Plan and ensuring that the work is executed according to the Lift Plan.

• Rigger –this is a Competent Person who must be present in the field to carry out assembly and

disassembly of the load.

• Routine Lift – are characterized by: simple operations with one crane/Lifting appliance, Lifting over

non-sensitive areas and in suitable familiar environmental conditions. Loads of known and evaluated

weight, shape and center of gravity. Basic rigging arrangements. Simple logistics activities with forklift

trucks fall under this category.

• Signal Person –is a person whose task is to act as the interface when the operator of the Lifting

equipment has a restricted view due to any reason. The hand signals to be used by the Signal Person are

to be agreed upon between the Operator of the Equipment and another parties involved in the lift prior

to work beginning.


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• Tag Line - is a line usually made of nylon or some other non-conductive material that is used by a rigger

to help him control a suspended load from swinging and allow him to stand at a safe distance

3. Standard Minimum Requirements Planning

3.1. All Lifting activities must be supported by a Risk Assessment that addresses the associated hazards and

the control measurements to reduce risk. The detail required will be related to the risk and the

complexity of the lift. The risks must be documented in a Risk Register.

3.2. The Lifting Risk Register is a dynamic document and any new Lifting activity must be documented in

the register. The register must be reviewed regularly for actuality.

3.3. A documented Lift Plan (or for Routine Lifts, an SOP) must be established for every Lifting operation

3.4. Approval and input - A Competent Person must be involved in the drafting of all Lift Plans and must

approve all Lift Plans. All parties involved in the Lifting activity for example, the crane operator, Signal

Person and Riggers must have demonstrable input into the Lift Plan and be consulted prior to approval

of the plan.

3.5. Changes- Any change to a plan shall be approved as if it is a new lift plan

3.6. The Lift Plan must include but is not limited to the following:

• The names and roles of the person(s) involved in the drafting of the Lift Plan

• The type, roles, competencies and numbers of personnel required to carry out the lift and how

they will be briefed;

• Communication methods to be used – including agreement on the hand signals;

• One person should be designated as the Person in Charge (PIC)

• The nature and weight of the load and Lifting points; (Where the weight of a load is uncertain,

equipment should be fitted with a load cell with the weight of the load displayed in the visual

range of the operator)

• Equipment required and certification checks;

• Step-by-step instructions;

• Emergency and rescue plans;

• Access and egress for slinging and un-slinging the load;

• The applicable Permit to Work procedures;

• Load integrity check;

• Load charts for generic Lift Plans and for heavy or complex lifts;

• The comprehensive Risk Assessment including but not limited to:

o Restrictions on the lift such as weather, visibility, sea state, etc.;

o Simultaneous, conflicting or nearby operations or work;

o Pick up and set down points and constraints such as space and stacking;

o An assessment of whether tag lines should be used, their hazards and limitations

o The physical position of all persons involved in the lift in relation to avoiding the risk of

“line of fire”

o Barricading plans to prevent access to the lift area/Danger Zone that consider the Risk

associated with crane collapse and boom fall distance etc.


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o Stability of the ground (use of spreader plates, subsidence etc.)

4. Standard Minimum Requirements Maintenance and Inspection

4.1. There should be a register of all Lifting devices and Lifting accessories on LBC sites that are owned or

leased by LBC and operated by LBC personnel and/or Category 1or 2 Contractors. This register should

also contain a list of all components of said Lifting devices and Lifting accessories that are considered

critical.

4.2. There must be a documented system in place for all Lifting devices and accessories (named in the

register) for the inspection, maintenance, repair and approval for use (appropriate certification) of all

Lifting equipment and accessories, including a process that verifies that the equipment is able to

function to its design specifications. All elements of the system must comply with all manufacturer

specifications and regulatory requirements as a minimum. Competent persons must be identified in the

system.

4.3. There must be a clear and unambiguous system in place to ensure that users of Lifting devices and

accessories are only using equipment that is approved and that the inspection status must be clearly

visible. Equipment that is unfit for the purpose (not approved) must be clearly identified and/or

destroyed.

4.4. All Lifting equipment and devices that are not owned by LBC but are brought onto the site must be

approved as fit for the purpose as evidenced by a documented system. The designated LBC Contractor

Manager is responsible for obtaining this information from her suppliers. There should be a visual

inspection of all equipment brought onto site by a contractor by an LBC employee identified as a

Competent Person.

4.5. There must be a designated clean, dry and suitable location to store all Lifting accessories such slings

that are susceptible to the effects of for example weather and chemicals safely.

5. Standard Minimum Requirements Operation

5.1. All lifts must be carried out in accordance with agreed Lifting plans (for Non-Routine Lifts) or SOPs (for

Routine Lifts).

5.2. There should be a documented process that ensures that all critical components as identified in the

register are inspected prior to use every shift by the operator. Where the operator changes, a new

inspection should be carried out.

5.3. Hoisted or lifted loads must never be left unattended.

5.4. It is not permitted to swing a load over people or occupied buildings.

5.5. There should be a warning system (e.g. audible horn) if loads are being passed near people present in

the Danger Zone.

5.6. For Non-Routine Lifts involving cranes, all involved persons will wear reflective vests. Riggers will wear

reflective vests of a different color to the rest.

5.7. For Routine lifts involving cranes there must be a risk assessment to determine the need for reflective

vests.

6. Standard Minimum Requirements Training


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6.1. All personnel involved in the Lifting and Hoisting activities must be competent persons and authorized

to operate Lifting devices and accessories. There must be a risk assessed system in place for

establishing the necessary minimum operation times, frequency of operation and competency testing

of personnel to ensure they maintain their skills and are competent.

6.2. Where contractors are on LBC facilities operating Lifting devices and accessories they must be

demonstrably trained, competent and authorized to operate said devices and accessories.


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Working at height


This policy is defined to specify minimum requirements that need to be in place to ensure that everybody

on an LBC Facility is protected from the risk of falling.

This standard applies to all activities where the risk of falling has been identified by the Risk Assessment and

in any case where elevated work occurs at a height of 1.8 m meters or more.



• Anchor point - is a fixture to which a person anchors an approved line (typically with a hook) to be held

securely and thus reduce the impact of a fall. This point must be certified and approved for the forces

that will be applied in the event of a fall.

• (Mobile) Elevating Work Platform - mechanical device used to provide temporary access for people or

equipment to inaccessible areas, usually at height. Examples include: ‘cherry picker’ and ‘scissor lift’.

• Fall prevention – is a safe Work Platform designed such that the risk of falling has been eliminated e.g.

permanent Work Platform, Scaffold, Elevating Work Platform such as a scissor lift or man lift.

• Fall protection – a fall protection system is a device such as a fall protection harness and lanyard that

must be used when the risk of falling cannot be eliminated by Fall Prevention.

• Harness Suspension Trauma -this is the process whereby a person hanging in a harness can become

extremely unwell or die if not rescued quickly.

• Scaffold is a temporary or movable platform structure for holding workers and materials during the

construction, repair, alteration, or decoration of a fixed structure such as a building, pipe rack, storage

tank, tower, or any other elevated work structure requiring access to the worker. There are two types

of scaffold:

• Supported Scaffold - Work Platform supported by rigid, load-bearing members such as poles,

legs, frames, outriggers, and braces and are typically constructed from ground level to the

height needed to achieve safe work access.

• Suspended Scaffolds – Work Platform suspended by ropes or cables from a secured overhead

support.

• Scaffolding Inspector: A Competent Person in accordance with the LBC definition and in accordance

with local legal requirements.

• Spotter - persons trained to direct vehicle movement on or around site. They should be clearly

distinguishable from other personnel on site.

• Work platform –is any elevated area where work is carried out. Note, the work area above an

excavation site is also a Work Platform in the context of this policy. Note: this definition includes

temporary Work Platforms, such as: Scaffold and (Mobile) Elevating Work Platform.


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3. Standard Minimum Requirements Fall Prevention

3.1. Fall Prevention is preferred over Fall Protection, if this is not possible this should be reflected in the

Risk Assessment with the reasons why Fall Protection has been chosen.

3.2. Permanent safe Work Platforms are preferred above temporary structures such as Scaffolding or

Mobile Elevating Work Platforms such as scissor lifts.

3.3. All work platforms must have complete floors, top rail, mid rail, toe-boards and safe access and

egress must be possible. The floors, guardrails and toe-boards should be securely fixed in place.

3.4. Fixed work platforms must have two emergency escape routes. For temporary Work Platforms, a

Risk Assessment must be performed to prove adequate emergency escape routes are in place.

4. Standard Minimum Requirements Fall Protection

4.1. There must be a clear and unambiguous system in place to ensure that users of Fall Protection are

only using equipment that is approved and that the inspection status must be clearly visible.

Equipment that is unfit for the purpose (not approved) must be clearly identified and/or destroyed.

4.2. Fall Protection must be used in all other cases where Fall Prevention is not possible. This includes

situations in which work is carried out from an Elevating work platform.

4.3. A person is considered to have Fall Protection if they are secured with an approved full body harness,

shock absorbing lanyard (where the potential to fall is greater than 4 meters) or short restraining

lanyard (where the potential to fall is less than 4 meters), self-locking snap hooks (or carabineer type

rings) and the Fall Protection is secured to a secure Anchor Point

4.4. Anchor Points must where possible be situated above the head of the worker, and must ensure that

in the event of a fall the worker will not swing. In cases where this is not possible this must be

included in the Risk Assessment and suitable control measurements put in place. It is not permitted

to have an anchorage point at a height were the person will touch the ground or water in the event

of a fall.

4.5. There must be a system in place to identify all permitted Anchor Points and ensure that they are

tested and approved for the purpose by a competent person.

4.6. There must be a system to ensure that Fall Protection equipment is:

• Tested annually and certified for use,

• Inspected by the user before every use,

• Destroyed following a fall or where inspection reveals evidence of excessive wear or mechanical

malfunction.

4.7. Persons using Fall Protection devices must be demonstrably trained by a Competent Person to use

such devices and to spot defects. They also must be made aware of the risks of Harness Suspension

Trauma.

4.8. There must be a system for preparing and testing emergency rescue procedures for fall victims that

consider Harness Suspension Trauma and other risks. For example, but not exclusively the duration

of suspension, lone workers, height from which person must be rescued, logistic factors.

4.9. Situations in which work must be carried out where there is a possibility for a fall into chemicals or

water, a specific to this risk additional Risk Assessment must be performed and verified by an


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independent party prior to performing the task. This must be another Competent Person not

involved in the task.

4.10. There must be a designated clean, dry and suitable location to store all Fall Protection devices safely.

5. Standard Minimum Requirements Ladders

5.1. There must be a demonstrable annual testing and inspection protocol in place governing the use of

ladders.

5.2. All users of ladders must have a demonstrable periodic training governing the correct use, risks and

inspection of ladders. The frequency and content of the training must be based on a documented

Risk Assessment.

5.3. A person may ascend or descend a mobile ladder without Fall Protection if they are able to use both

hands and legs to do so, face the ladder and use one step at a time and that the use of the ladder in

each circumstance has been risk assessed. In any case, it is forbidden to make use of a ladder that is

more than 7.5 meters high. Ladders must always be tied off or supported below to prevent

movement, the ladder must be on a flat surface and both supports must be firmly on the ground at

all times and situated such that the rungs are horizontal. Persons must maintain three-point contact

when descending and ascending.

5.4. Working on ladders must be avoided if practically possible. Where work must be carried out on a

ladder there must be a special Risk Assessment that considers all aspects of the job including but not

exclusively: effective work time, maximum time allowed on a ladder in any one stretch, scheduled

break/rest times, reach distance, forces the worker must exert to carry out their work.

6. Standard Minimum Requirements Scaffolds and Mobile Elevating Work Platforms

6.1. Employees and contractors charged with working on temporary Work Platforms must receive regular

training to be considered competent according to the definition of Competent Person to carry out

the visual check prior to use and in order to be able to perform work from a temporary Work

Platform.

6.2. Local procedures should include the prohibiting of persons climbing out of temporary Work

Platforms other than via the approved process

6.3. There must be a system in place to ensure the adequate design, construction, certification, of

Elevating Work Platforms and Scaffolds by a Competent Person.

6.4. There must be a system in place to ensure that all Scaffolds and Elevating Work Platforms are visually

checked before each use and before the start of a shift.

6.5. Scaffolds must be inspected daily by a Scaffolding Inspector to evaluate Scaffold compliance and

after any circumstance that might affect the stability or safety of the Scaffold. For work requiring a

Permit to Work, the inspection must be carried out prior to issuance of the Permit to Work. Such

circumstances include:

• Modification

• Period without use

• Exposure to bad weather

• Damage, including impact of traffic or site equipment with the Scaffold


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6.6. There must be a system in place that includes requirements:

• for Scaffold tagging

• for visual check before use. The verification must include Scaffold tag verification as well as a

visual check to ensure the Scaffold has not been modified or damaged

• to use handrails on Scaffold ladders used to access the Scaffold regardless of the angle or

height of the ladder

• to use Scaffold gates to protect workers from accidentally stepping out of the ladder access

opening from the landing platform

• where Fall Protection is required on all Scaffolds when the Scaffold top rail no longer prevents

the worker from falling, example when the worker stands on a step-ladder or box.

• to ensure Scaffold base level is constructed on surfaces that are levelled, capable of bearing

load at 4 times the maximum intended load and otherwise free from erosion potential and

other hazards such as sinking, sliding, swaying or intentional movement of the base legs

• metal securing brackets / clips (plastic is not permitted)

• High visibility identification of parts of scaffold structures that could result in injuries (e.g.

scaffold pipe at head-height)

• ensure people do not ride on a rolling Scaffold of any height.

6.7. There must be a system in place that includes requirements and instructions for suspended

Scaffolds. As a minimum, the system must include:

• Overhead support must meet engineering standards to ensure the supports can bear the

suspended load at 4 times the maximum intended load which includes weight of workers,

materials and Scaffold components

• Scaffold ropes or cables must be rated to accept the weight bearing load at 6 times the

maximum intended load

• Use of Suspended Scaffolds may not be allowed if lightning is present within 12 kms (8 miles)

or in wind speeds exceed 32 km/h (20 miles per hour, or 5 Beaufort)

6.8. There must be a system in place that includes requirements and instructions for Elevating Work

Platforms. As a minimum, the system must include:

• Equipment certification for Elevating Work Platforms must be verified prior to issuing a Permit

to Work

• Mobile Elevating Work Platforms must be operated by Competent Persons.

• All persons in a Mobile Elevating Work Platform must always be secured with certified Fall

Protection equipment.

• Equipment must be protected from contact by any other equipment. The use of barricade

tape around the area is required

• A Spotter must be used when transiting mobile Work Platforms to its destination

• Operators must not drive in any position while the platform is elevated


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7. Standard Minimum Requirements Falling Objects

7.1. Where overhead work is being conducted, the Risk Assessment must include provisions to prevent

falling objects such as but not limited to barricades around the work area to protect persons below,

use of tool boxes, containment for nuts and bolts etc. and securing tool lanyards. In addition, where

activities are carried out at height and there is a risk that a safety helmet may fall from an

individual’s head a chin bands must be worn.


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Line Cutting 1. Purpose and scope

This policy is defined to specify minimum requirements for Line Cutting which is considered a non-routine

operation that requires heightened personal safety, environmental and business continuity Risk

management.

This policy applies to all activities relating to Line Cutting at all LBC Facilities:

• Product process lines, including those confirmed free of hazardous and non-hazardous substances

• Utility and all other Product lines and system (for example, but not limited to: water, steam, natural gas,

steam condensate, nitrogen, and plant air)

This policy does not apply to situations where a ‘hot tap’ procedure will be used for tying into process or

any other follow-up activities after the cutting activities. For ‘hot tap’ work a specific risk assessed local

procedure must be in place established by Competent Persons.


Definitions pertaining to this policy are:






• Line cutting is the intentional physical penetration of the integrity of a Product, utility or other process

line by any means. Examples include but are not limited to mechanical or pneumatic sawing, boring,

welding, High Pressure water jetting.

• Line Cutting Supervisor: an LBC employee officially assigned, authorized and designated to supervise

Line Cutting activities. This person must be competent to fulfill the tasks associated with this role in

accordance with the Competent Person definition.

• Unique Tie Point Identifier: a uniquely numbered weatherproof tag or label applied to the line at the

location of the cut with high visibility weatherproof tape. The tape must be manufactured* with the

text “Line Cut” and be applied around the whole circumference of the line at the cut location. The

unique reference number must always be clearly noted on the permit and job instructions. The

identifier must be written in the agreed common language as well as local language where this differs.

• Unique Tie Point Identifier and Tape Applier: an LBC employee from the operations department

officially assigned, authorized and designated to apply the Unique Tie Point Identifier and tape. This

person must be competent to fulfill the tasks associated with this role in accordance with the

Competent Person definition.

3. Line cutting pre-work

3.1. All Line Cutting activities require a Risk Assessment to be carried out with a Multidisciplinary Team

comprised of competent persons and a Risk Treatment plan must be determined in accordance with


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Risk Management Policy. The Risk Assessment should consider the unique situational and

environmental circumstances of the line to be cut including any other activities that may be

occurring in the vicinity.

3.2. Where possible the planning should be such that there are no other activities near the Line Cutting

activity. When this is not possible, additional Risk Treatment measures must be identified to reduce

any additional Risks that other activities may pose and/or the risks to persons working in the vicinity.

3.3. As per local procedures, all affected lines and equipment must be isolated, emptied, cleaned or

purged in accordance with the local LBC Isolation of Energy (Lock Out/Tag Out) procedures. A gas

test must be performed to ensure the system is free of Hazardous Substances. All test equipment is

required to have valid certification.

3.4. In circumstances where a line cannot be completely cleaned, a Risk Assessment must be carried out

with a Multidisciplinary Team and a Risk Treatment plan must be determined in accordance with Risk

Management Policy.

3.5. The exact location of the cut must be properly identified on the line.

3.6. The Unique Tie Point Identifier and tape may only be applied up to a maximum of 24 hours prior to

the day the line will be cut.

3.7. The Unique Tie Point Identifier number on the weatherproof tag or label must be clearly named on

the Permit to Work.

3.8. In addition to all cut points being clearly marked with a Unique Tie Point Identifier and tape, the cut

points must also be clearly marked on a drawing that will be attached to the Permit to Work. The

Permit to Work and the drawing must be present at the Work Location.

3.9. The Unique Tie Point Identifier and tape must be applied by the Unique Tie Point Identifier and Tape

Applier, in presence with:

• A qualified LBC site safety representative and;

• The person who will carry out the cut – be that an LBC employee or an employee representing a

contractor organization.

3.10. All parties involved in the process described above must sign the Permit to Work, and initial the

drawing.

4. Line cutting

4.1. A Permit to Work must be in place for all Line Cutting activities and present at the Work Location. As

part of the permitting process, a permit will be issued for one line and not multiple lines. Multiple

lines should be treated as separate jobs with separate a Permit to Work to avoid confusion and error.

4.2. The Control Room should be informed immediately before the Line Cutting begins that it will take

place.

4.3. When the Line Cutting has been executed the Control Room should be informed immediately.

4.4. The validity of the permit may not exceed 1 shift.

4.5. The Permit to Work must include a list of all equipment to be used for the cut as well as the planned

cut technique (example, but not limited to cold cutting or hot cutting). The equipment to be used

must have valid certification.


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4.6. Personnel performing the work must receive a traceable and documented instruction with regard to

any specific to the job potential hazards and applicable safety precautions, including emergency

response procedures and PPE requirements. Such training must also include instruction on how to

use spill kits and how to execute any other environmental precautionary measures identified in the

Risk Assessment. The training records must include evidence that the training has been

comprehended by the trainees.

4.7. Prior to each cut, an additional check will be done to ensure the line and location of the cut are

correct and the requirements detailed in the Permit to Work are met, including verification that the

Unique Tie Point Identifiers and tape are visible.

4.8. This additional check will be carried out by:

• The Unique Tie Point Identifier and Tape Applier

• An LBC HSSEQ site representative, and

• The Line Cutting Supervisor, and

• The person who will carry out the cut – be that an LBC employee or an employee from a

contractor organization.

4.9. The person carrying out the Line Cutting must be able to communicate fluently in a common

language with the Line Cutting Supervisor. It is not permissible to make use of a translator.

4.10. All parties involved in the process must Sign-off to confirm that – for each cut – all steps have been

conducted correctly.

4.11. The Line Cutting Supervisor must be present during the cutting activities.

4.12. The work area immediately around, or below the cut location must be barricaded to prevent

unauthorized entry into the work area. This barricaded zone will be monitored by the Fire Watch.

4.13. A Fire Watch must be present within 35 feet (10 meters) at all times during the cutting activities. The

Fire Watch must have all necessary certified fire-fighting equipment at their disposal at the Work

Location.


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Hose Management


This policy is defined to specify minimum requirements that need to be in place to ensure that employees

and contractors use suitable and certified Hoses for the transfer of Product and vapor. This policy also

applies to (fire) water Hoses, Hoses connected to hydraulic pumps and all utility Hoses (e.g. air, nitrogen and

steam).



• Field Check – this is a visual inspection carried out prior to using any Hose -this could be part of the

LMRA

• Hose: removable device for Product transfer in liquid and/or vapor form and/or for the supply of

utilities. Typically, stainless steel corrugated hose with reinforced webbing, or chemi-flex composite

hoses

• Hydrostatic testing is a process whereby Hoses are tested using water under pressure to assess the

structural integrity of the Hose and identify if the Hose is still fit for purpose


3.1. There should be a system in place to ensure that:

3.1.1. All Hoses falling under the remit of this policy are compliant with any applicable requirements

of the Product Transfer Policy

3.1.2. Roles and responsibilities concerning Hose management are clearly defined

3.1.3. Requires a visual Field Check before every use

3.1.4. Includes a training program for all operational employees such that they can be considered

competent according to the definition of Competent Person to carry out a visual inspection of

all Hoses prior to use and determine within the limits of a visual inspection if the Hose is fit for

purpose.

3.1.5. Where there is a risk of friction/vibration induced damage to Hoses; preventative measures

should be in place such as but not limited to the use of rubber mats.

3.1.6. All utility Hoses not in use are capped and product Hoses are flanged using all available bolts.

4. Product and vapor return Hoses

4.1. Hoses are selected and purchased based on the results of a Risk Assessment that considers as a

minimum the required chemical resistance for the Product to be conveyed, allowed maximum flow-

rates, temperature of Product and pressure class.

4.2. Before use every Hose should be foreseen with a unique identification tag which as a minimum

includes type of construction material, diameter, length, pressure class and (inventory) identification

number.


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4.3. All Hoses in stock and use are listed in an inventory overview including the location where the Hose is

in use (e.g. truck loading station 5, jetty/dock) and the Products for which it may be used. Certificates

should be maintained by the LBC Facility for every individual Hose.

4.4. Use of Hoses is limited to the transfer of Product and vapor return on a loading stations or

jetties/docks. It is not permitted to use Hoses in tank pits (e.g. connection between pump and

piping).

4.5. Hose should undergo a Hydrostatic Test with water every 12 months where the following minimum

test criteria must be met:

• Prior to Hydrostatic Testing of the Hose, cleaning of the Hose is mandatory.

• Prior to commencement of testing, Hoses shall be visually examined for integrity and damages.

Hoses found to contain kinks, bulges, flat spots, or damages reinforced webbing must be

removed from service.

• The water used for testing must be at 1.5 times the design pressure of the Hose (e.g. 15 bar test

pressure must be applied for a design pressure of 10 bar).

• A Certified Test Gauge with a 0500 psig range of pressure shall be used to perform the test

(certification documentation of Test Gauge must be provided). The Certified Pressure Gauge

will be used to test/calibrate the hydro-test manifold and pipeline gauges.

o Provide a pressure gauge test manifold (with the Certified Test Gauge installed).

o Calibrated test gauges must be within 5 psig of the Certified Gauge;

o Document the Certified Pressure Gauge number and Calibrated Test Gauge number on

each Hose Test Form.

4.6. Measurement of the total length of the Hose prior to testing and after testing. Total length is

defined as the flange to flange length for a Hose laid out in a straight manner.

4.7. The pressure should be recorded at 15 minutes once reaching the test pressure and must remain

unchanged for a period of 30 minutes

4.8. The whole length of the Hose is checked for abnormalities such as length, torsion, displacements and

leaks. The length of Hose may not exceed 10% growth during the pressure testing.

4.9. The static electrical grounding between the two fitted couplings must be measured.

4.10. Hoses should be foreseen with a tag in case of successful pressure test, valid for a period of 12

months, not to exceed 365 days.

4.11. If a Hose fails the pressure test they must immediately be taken out of service and

collected/transported to an approved waste disposal contractor and the applicable inventory list

should be adapted.

4.12. Hoses should be taken out of service when they have been used for 10 years (maximum).

5. Utilty and hydraulic pump Hoses

5.1. Hose connections are specific to the utility such that it is impossible to connect the wrong hose

5.2. All utility Hoses must be equipped with a Hose Catching Mechanism

5.3. Hoses in use for utility must be color coded, for example:

• Compressed air: blue

• Nitrogen: green


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• Steam: black

• Water: not specified, Hoses should be identified with text: “Fire water” / “water”.

5.4. Utility Hoses should be purchased considering the applicable safety pressure factor based on the

maximum applicable working pressure of the LBC Facility (e.g. maximum pressure compressed air is

6 bar, applicable safety factor for air is 1.5 -> minimum pressure for air Hose is 9 bar).

5.5. The following minimum safety factors must be applied:

• Air / nitrogen / water: 1.5

• Steam: equal PN40

• Hose for hydraulic pumps: 300 bar

5.6. All Hoses in use for air / nitrogen, steam or hydraulic pumps should be inspected visually before use

and tested as a minimum annually. If the Hose passes the test a unique tag should be installed

showing the date of the inspection and the date that the following inspection should be conducted.

5.7. The minimum criteria for inspection are:

• Leakage at thread end

• weep/seep at Hose coupling interface

• Hose cracks

• bulges

• twist of the Hose (kinks) and

• cover blisters.

5.8. Hoses in use for (fire) water should be pressure tested as a minimum every 2 years.


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Excavation and Working at Depth


This policy is defined to specify the minimum requirement that need to be in place for carrying out Excavation

activities or other activities when Working at Depth at any LBC Facility.

This policy applies to all mechanical and manual Excavation activities in which Top Surface Material removal will

occur. In addition, this policy also applies to activities being carried out by personnel working inside an already

excavated or dug out location at a depth deeper than 120cm.



• Digging - refers to the removal of Top Surface Material using manual means such as a spade, pick, hoe

or other manual tool.

• Excavation – refers to the removal of Top Surface Material using any mechanical device. Excavation

and digging shall be used throughout the standard to mean the same thing

• Protective System– a method of protecting persons and/or adjacent structures from a cave-in by for

example excavating the sides (walls) of an Excavation site with an appropriate inclination angle

(sloping) and/or stepping and/or the use of support systems. The system used depends upon the

hydrology, hydrogeology and the geology of the earth as well as the surrounding structures and/or

activities.

• Top Surface Material/Earth – refers to either natural product’s such as but not limited to soil, rock,

clay, sand or man-made products such as but not limited to concrete, asphalt, tarmac.

• Trench – the indent made in the earth by Excavation or Digging activities

• Working at Depth –for the purposes of this standard refers to any activity being carried out by an

employee or contractor inside an excavated area whereby the depth at any part of the Excavation area

is deeper than 120cm. Such areas are classified as Confined Space activities and fall under the Confined

Space Policy.


3.1. There must be a system in place whereby any activity falling under the definitions in this policy may

only be carried out with a dedicated Excavation Permit to Work

3.2. The system must include a “STOP” procedure whereby all activities are halted if an unexpected

structure is encountered during Digging and/or Excavation that has not been identified in the Plot

and/or Probing Procedures. At this point the Permit to Work is rendered null and void and a new

Risk Assessment must be carried out and a new risk mitigating plan of action established and

activities may only proceed under a new Permit to Work.

3.3. The system must include the appropriate training of the Permit to Work Issuer such that he can be

classified as a Competent Person


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3.4. All Excavation and Digging activities must be subject to a Risk Assessment that should include as a

minimum the following aspects:

• The choice of equipment e.g. vacuum in preference to mechanical excavators etc.

• Local and regional hydrology and hydrogeology to ensure that the potential for major water

ingress is understood and prevented

• The geology of the earth to be removed and the risks associated with this geology, for example,

the risk of landslide/collapse of surroundings

• The Protective system to be used describing the nature of sloping and/or stepping and/or any

supporting structures that will be required during the Excavation/Digging process to prevent

the risk of landslide and all risks associated with this. In any case, for all Excavation activities

deeper than 1.20m shoring and/or bracing on the vertical plane must be used. The system

must include a process to ensure that all supporting structures being used are of a suitable

mechanical strength to withstand the expected forces, a plan is made to define the location

where such structures are to be placed and that the person making this assessment is a

Competent Person in accordance with the definition and local legislation.

• Current and expected weather conditions for the duration of the Excavation activities

• Effect of vibration (e.g. caused by vehicle movements and operational activities)

• Logistic provisions including vehicle and pedestrian movements

• The stability of surrounding structures such as buildings, roads, footpaths

• A “Plot Plan” detailing the actual and/or expected locations of all underground structures such

as but not limited to support structures, cables, gas pipes, other Product carrying pipes,

electricity sources, sewer, telephone cables, water pipes, drainage structures, fire water

facilities, sites of archeological and/or indigenous importance

• The plot plan should include an assessment of contaminated earth based on recognized

scientific analytical techniques and the Risk Treatment actions regarding the contamination and

protection of individuals from exposure.

• Barricading of the area to prevent unauthorized and/or accidental entrance to the area. For

open Excavations, such barricades must be a physical barrier rather than tape.

• All Excavation sites must be adequately illuminated at all times. At night, Excavation areas

should be signaled by flashing orange lights that meet the appropriate electrical and explosion

proof requirements.

• The use of ground markings to indicate the location of underground structures and

contaminated earth.

• The tools/equipment to be used for Excavations

• Removal of the excavated material and the location where it will be stored if it will be returned

to the Excavation site and/or any environmental decontamination/ disposal plans

• Emergency egress plans and other emergency procedures for all possible scenario’s must be

defined

• Communication plans for all parties involved in the Excavation activities


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• The identification of the Danger Zone where for example but not limited to vehicle movements

are restricted, persons may not approach due to contaminated material etc.

• Issuance of a new Permit to Work when a new shift/team is taking over the Excavation activities

• Risk assessments must consider Excavation areas that may not actively be excavated for a

period of time and the Risk Treatments that need to be in place to secure the area. The Risk

assessment must include a thorough analysis of the Excavation area and the identification of

additional measures that should be taken following a period of dormancy of an Excavation site

or any other condition (such as bad weather) that could have affected the site.

3.5. Continuous gas measurements are required for all Excavations within operational areas weather

surface material is found to be contaminated or not.

3.6. The system must include the use of high visibility and reflective clothing as defined in the PPE Policy

for all persons involved in the Excavation activities.

3.7. The system should exclude personnel from being inside the Excavation when heavy machinery is

moving or operating (within 150cm of the Trench)

3.8. The system must exclude persons from working inside an Excavation site i.e. Working at Depth

where there is the possibility for water ingress unless actions are taken to prevent gradual and

sudden water accumulation into the Excavation area. For example, but not limited to, water

extraction should be used and berms placed to prevent water flow into the area.

3.9. Any activities whereby a person is carrying out work inside the Excavation area and whereby any

point of the Excavation area is deeper than 120cm must fall under the Confined Space Policy and a

Permit to Work covering Confined Space Entry must also be given to authorize such activities. In any

case for all Excavation and Digging activities where an employee is working inside the

Excavation/Digging area under a Confined Space Permit to Work, gas measurements must be carried

out to determine oxygen levels and levels of other Hazardous Substances. Continuous monitoring

must be employed throughout the Excavation.

3.10. Any activities whereby welding or cutting is being carried out inside the Excavation area must be

covered by a hot Permit to Work and correct respiratory and/or ventilation plans must be in place.

3.11. The system must include a Probing Procedure whereby when the Excavation activity is within 3 m of

the expected location of the various structures identified in the plot plan, the exact location is

determined by safe means e.g. non-conducting probe, sonar, metal detector etc.

3.12. The system must include the use of ground markers to indicate the location of all underground

structures within a 3m radius of the Excavation location.


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Vehicles and Driving


This standard is defined to specify the minimum requirement controls that need to be in place for all activities

involving vehicles and driving at any LBC Facility.

This standard applies to all motorized vehicles with two or more wheels including mobile equipment and

caterpillar transport equipment owned (or hired) and operated by LBC used on site or off-site for business

purposes. The standard also applies to all vehicles used on site by contractors working on LBC Facilities. In the

latter case, the Contractor is responsible for proving compliance with the Vehicles and Driving Policy.



• none


3.1. The use of motorized 2 or 3 wheeled vehicles for work purposes is not permitted.

3.2. All vehicles types and activities with vehicles must be risk assessed by Competent Persons. The Risk

Assessment should as a minimum:

• Involve the operators and maintenance engineers who use the equipment and maintain the

equipment and a qualified health and safety expert.

• Address all aspects of safe operations including the activities to be performed and the context

where the vehicle is used, driver vision, communication options, maintenance requirements,

access and egress for operators and maintainers.

• Address the training needs and frequency of training for the operator of each vehicle.

3.3. There must be a system in place with clear accountabilities for vehicle maintenance.

3.4. Persons accountable for maintenance must be trained and competent in accordance with the


3.5. All vehicles driven for work must be subject to a pre-operation safety check. The nature of this check

will be determined by the Risk Assessment.

3.6. All vehicles must have an approved fitted safety belt for both driver and passengers.

3.7. All vehicles must have a life hammer.

3.8. All vehicles that can exceed the lowest applicable speed limit on the LBC Facilities where they are

usually engaged must be fitted with a speedometer. In the event that this is not possible the vehicle

must be fitted with a speed limiting device that prevents the vehicle exceeding the lowest speed

limit on site.

3.9. It is not permitted to leave a vehicle unattended while the motor is running.

3.10. Each LBC Facility must have a clear logistic plan based on Risk Assessment governing the movements

of all vehicles on site and designated parking locations. The logistic plan must take account of

strategically placed and clearly visible appropriate signage.


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3.11. There must be a system in place to limit the number of vehicles on site. This system should be such

that at any moment it is know what vehicles are present on site.

3.12. Parking locations should be clearly signed and segregated according to vehicle type e.g. lorries

should not be parked in the same spot as personal vehicles or bicycles etc.

3.13. No person is permitted to drive any vehicle unless they have been trained, are competent, tested

and licensed to operate the vehicle. The training must address local legislative requirements, the

hazards identified in the Risk Assessment and the hazards associated with the task the person will

perform when using the vehicle as well as additional hazards that can be expected in the

environment where the person will be operating the vehicle. NB: a state or civil license does not

eliminate the need to carry out the training associated with the Risk Assessment.

3.14. There must be a system in place to ensure that the renewal of licenses and training programs occurs

as identified in the Risk Assessment.

3.15. There must be a system in place to monitor the competencies of individual vehicle operators. This

system must include the non-compliance of operators with site traffic rules.

3.16. There must be a system in place to ensure unattended vehicles can be removed from a specific area

in case of an emergency.

3.17. Vehicles permitted on site must be clearly identified with a label placed inside the vehicle indicating

the date permission was granted and the date of expiry.

3.18. Drivers and passengers must wear their seatbelts at all times.

3.19. No driver will use a mobile telephone or two-way radio when driving in a vehicle.

3.20. It is not permitted to smoke, eat and/or drink in vehicles while driving.

3.21. Speed limits and traffic rules on site must be reviewed regularly and in any case following an

Incident.

3.22. There must be a “reverse parking” rule on site.

3.23. No vehicle will be permitted to tow another vehicle on the premises unless it is engineered to do so

and is subject to a Permit to Work for this activity.

3.24. There must be a system in place to monitor compliance with/and enforce basic rules relating to

vehicles and driving on site

3.25. There must be a system in place to carry out random security controls on vehicles on LBC Facilities.


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OS 15 1.0 128



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Electrical work

To be developed


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OS 16 15 February 2016 1 September 2018 2.0 129



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Responsible Travel, Entertainment and Refreshments



• Allowable Expenses – these are expenses that are considered responsible and justified by LBC and may

be declared.

• Approval Manager – this is the appointed Line Manager who must approve all expenses declared by an

employee and who must also give permission for all travel (up front by e-mail) involving transport

other than by company lease car and/or involving the provision of hotel accommodation.

• Designated Travel Agent – this is the preferred supplier that should be made known at each LBC

Facility in Europe.

• Most Senior LBC Employee – this is the most Senior Local Employee with an LBC credit card present at

an entertainment event who must declare the costs incurred by LBC. If there is no local employee with

an LBC Credit Card present, it is any other LBC employee who has company credit.

• Non- Allowable Expenses – these are expenses that are not considered responsible and justified by

LBC and may not be declared.

• Responsible Entertainment - is fully documented and transparent and in keeping with the Anti-

Corruption Policy and the Code of Ethics and Business Conduct and Whistleblower Policy

• Responsible Travel – this is travel that has been risk assessed and preferably planned in advance to

ensure that harm to people, planet and profit is kept to a minimum.

2. Minimum Requirements

2.1. Other applicable Policies – All travel, entertainment and personal provisions (food and drink) must

also be in line with the LBC Anti-Corruption Policy and the Code of Ethics and Business Conduct and

Whistleblower Policy.

2.2. Personal Safety, health and Security

2.2.1. LBC is a responsible employer and the primary concern above all other concerns is employee

health and safety. All decisions to travel and the mode of travel and the accommodation that

will be used must be made based on an assessment of risks. Employees should include their

personal well-being and business continuity issues in this assessment.

2.2.2. For trips that are more complex e.g. trips to developing countries or where vaccinations and

visas may be applicable help can be obtained from the Designated Travel Agent and/or the

CSR Team and/or Human Resources.

2.2.3. In the attached appendices, there are a number of checklists to help you make the

responsible decision with your Approval Manager.

• Appendix 1: Travelers Pre-Travel Checklist

• Appendix 2: Hotel safety and security

• Appendix 3: Public safety and security


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2.3. Approval for travel

2.3.1. All modes of business travel (with the exception of by company car) and all accommodation

should be approved by your line Manager up front via e-mail. Your request should include

the purpose and justification for such a business trip.

2.4. Travel Insurance

2.4.1. All LBC employees travelling on company business are covered by a company insurance

policy.

2.5. Contact Details

2.5.1. All employees traveling on company business are obliged to leave a copy of their travel

itinerary and contact details with their immediate Line Manager and we recommend that you

do the same with your family.

2.6. Vaccination

2.6.1. To minimize health risks, it is recommended that when traveling to some countries, persons

must be vaccinated and/or must take oral medication prior to visiting a country (and

sometimes for the duration of their visit in a country and beyond). LBC will reimburse costs

for this medication. While LBC cannot force employees to be vaccinated or take preventative

medication we are a responsible employer and expect our employees to take all responsible

preventative measurements to stay healthy.

2.7. Personal Medical kits

2.7.1. Personal Medical Kits for use in developing countries are reimbursable. Such kits include basic

suturing provisions, syringes and bandages.

2.8. Payment of Expenses and cash withdrawals

2.8.1. We trust our employees to act responsibly when spending company funds. Employee

declarations will be reviewed and authorized on merit by the Approval Manager. In cases

where the Approval Manager considers a declaration to be excessive or unnecessary,

supporting information will be required from the employee.

2.8.2. Expenses that are made by or for more than one LBC employee should always be paid by the

Most Senior LBC Employee.

2.8.3. Expenses should be submitted within 30 days of travel on the approved LBC expense form

and accompanied by receipts. Expenses not accompanied by a receipt must be justification

and will be approved at the discretion of the Approval Manager.

2.8.4. Cash withdrawals with the company credit card are not permitted.

2.8.5. Expenses incurred during foreign travel in foreign currency will automatically be converted to

your home currency by the daily market rate. If an employee receives a lower or higher

exchange rate on their personal statement compared to what was reimbursed on the


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expense form then the difference must be corrected by completing an additional expense

form.

2.8.6. Foreign exchange fees (including personal ATM charges) as well as currency variation charges

are reimbursable.

2.8.7. Credit/debit cards should be used when paying expenses in foreign currency to minimize

exchange fees. Employees should purchase currencies at automatic teller machines at

destination airports or at banks where possible. Hotel and airport currency exchange booths

are typically expensive and should be avoided.

2.9. Refreshments (Food and Drink)

2.9.1. Working Hours at your designated place of work

• Working hours must comply with local labor legislation. On occasions when required for

business purposes 11 or more hours are worked during a week day or more than 6

hours in a weekend at your designated place of work, it is permitted to declare

expenses for meals if eaten at the Work Location or if taken as a break away from the

Work Location before returning.

2.9.2. Meals with other LBC Colleagues

• From time to time it may be considered appropriate to have a meal with another LBC

colleague(s) when not traveling. In this situation, the expenses should be declared in

the same manner as entertainment costs. NB: This policy is not intended to address

departmental or team meals that may be necessitated on a yearly basis

2.9.3. Individual Expenses

• Meals are reimbursable, only if for the purposes of work an employee travels 150 km in

one direction further than their normal place of work (as designated in their labor

contract) and the duration and nature of the trip is such that they are unable to return

to their normal place of work or to their home to partake of meals in the way that they

normally would.

• Meals are reimbursable if employees are required to stay overnight away from home

for business purposes.

2.9.4. Taxes and modest tips according to local culture but in any case no greater than 18% associated

with reimbursable meals are reimbursable.

2.10. Room Service

• Room service as an alternative to dining in a restaurant is reimbursable and subject to the same

guidelines as other meals.

2.11. Alcoholic Beverages

• LBC is a responsible employer and does not support the consumption of excessive quantities of

alcohol when traveling on company business and asks its employees to use restraint in line with


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social conventions and legal restrictions. In any case consumption of alcohol is prohibited by

LBC when carrying out operational activities and/or when on or returning to a Terminal.

Consumption should be such that employees maintain possession of adequate faculties to

perform normal activities. Employees must not ‘drink and drive’. Excessive consumption will not

be reimbursed.

2.12. Entertainment and Gifts while traveling

• If while traveling a situation arises that requires entertainment with or gifting to/from a

customer, potential customer, Government Official or other business related person, this

should be done in line with the applicable LBC Anti-Corruption Policy pertaining to gifts,

gratuities, travel and entertainment and also in line with the Code of Ethics and Business

Conduct and Whistleblower Policy.

• Major Entertainment Events while traveling - those entailing more than a meal or equivalent

expense require prior approval by an ELT Member.

2.13. Designated Travel Agent, Mode of Travel and Accommodation

2.13.1. Designated Travel Agency

• Employees should book where possible and where economically responsible all travel via the

travel agent designated by LBC who will assist with all visa requirements and provide

vaccination and currency advice.

• All travel booked via the designated travel agency will be billed directly to LBC.

• The designated travel agency has a 24 hour help number for use in emergencies Employees

should ensure that they have this number with them when they travel.

2.13.2. Air Travel

• LBC will pay carbon off-set fees when travelers reserve a ticket.

• Travelers may choose any airline of choice as long as the airline is a member of the

International Air Transport Association (IATA). https://www.iata.org/Pages/faq.aspx). IATA

works with its airline members and the air transport industry to promote safe, reliable, secure

and economical air travel for the benefit of the world consumers

• Domestic, short haul European Flights and flights outside of Europe lasting less than 6 hours will

be booked flexible economy class.

• Long haul flights lasting more than 6 hours will be booked comfort class with the exception of

the ELT Members who will travel business class. Exceptions to this rule may be approved at the

discretion of the ELT based on a case by case basis and assessment of all circumstances.

• Designated Travel Agents must be instructed to book the least costly non-stop flight if possible

and if appropriate according to the Risk Assessment.

2.13.3. Train

https://www.iata.org/Pages/faq.aspx


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• Train tickets may be booked first class for all travel exceeding 3 hours, otherwise tickets must

be booked second class.

2.13.4. Rental Cars

• Employees may use rental cars when needed for business requirements and these should be

reserved via the Designated Travel Agency.

• In cases where employees must reserve cars themselves they must use only reputable car

rental suppliers.

• Employees are only permitted to hire cars larger than mid-sized if accompanied by four or more

business related travelers.

• Employees should make every effort to coordinate schedules with colleagues to minimize the

number of rental cars in use and emissions to the environment.

• Employees should balance the cost of rental cars with the use of local registered taxis and other

local transport to minimize costs. This should not be at the expense of personal safety which

must always come first.

• Employees should make every attempt to return rental cars with a full tank of fuel and not opt

for the pre-paid tank/fuel option which relies on the rental car being returned with an empty

tank in order for the deal to be economical.

2.13.5. Use of Taxi, Bus, Train, Subway, Shuttle Services

• These modes of transport should be used where appropriate, convenient, efficient and cost

effective but ONLY if it is considered safe to do so. Employees should consider personal safety,

environmental emissions, the costs of parking fees, fuel and employee time when making this

decision.

• Only licensed taxis may be used.

• Expenses for these modes of travel will be reimbursable with a receipt. Modest tips (not more

than 10%) will be reimbursed.

• LBC forbids the use of motorbike taxis by LBC employees traveling on company business.

2.13.6. Accommodation

• Where possible hotel reservations should be made via the Designated Travel Agency and the

reservation guaranteed with a credit card.

• Late arrival should be indicated to the hotel when the booking is made. This is to guarantee

your safety and ensure that your accommodation is still available if you experience delays when

travelling.

• Employees should stay in safe, clean and comfortable standard rooms in 3 or 4 star hotels,

except in emerging countries where 5* accommodation is permitted or in cases where 5*

accommodation is available at a cheaper rate than 3 or 4 star accommodation.

• The cost of accommodation may not exceed 220 euro per night (or equivalent in local currency)

unless approved beforehand by the Approval Manager.


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• LBC encourages employees to participate in the responsible environmental schemes offered by

hotels such as reusable hand towel schemes.

• Charges incurred when an employee fails to cancel a reservation when it could reasonably have

been expected that he would have done so will not be reimbursed.

• Employees may accept luxury and upgraded accommodation when offered at no extra expense

by the hotel chain or when using personal funds or travel points to upgrade. Luxury

accommodation upgrades may not be accepted at the cost of a customer or supplier of any

goods or services.

• In the event that employees are taking part in a seminar or major event where the designated

hotel is more expensive than other acceptable accommodation, they may do so with approval

of the Approval Manager up front.

2.13.7. Cancellations

• Employees are responsible for ensuring reserved hotel accommodation is cancelled as soon as it

is known that it will not be used and for making a note of the hotel employee they have spoken

with or the person at the designated travel agency.

• Employees are responsible for reporting to the Designated Travel Agency as soon as it is known

that any travel transport ticket or part of a ticket that has not been used in order that the

Company can claim any credit or tax refund where appropriate.

2.13.8. Travel Programs and Memberships

• Travelers are permitted to join Frequent Flyer and other loyalty programs at their own expense.

The traveler may use the benefits earned during business travel for either personal travel

upgrades or business travel upgrades.

• It is not permitted to select travel suppliers based on the possibilities to accumulate loyalty

points. Selection will be based on the other criteria named in previous sections of this

document.

2.13.9. Other Allowable Expenses

• Parking fees

• The use of hotel safe boxes

• Additional baggage costs when carrying items of equipment for company use (such as

promotional items for marketing events)

• LBC will reimburse all visa and vaccination costs.

• Supplies needed to accomplish the purpose of the trip e.g. insect repellent. Supplies should be

purchased in advance where possible.

• For trips lasting longer than 5 nights laundry and dry cleaning will be reimbursed. LBC expects

her employees to act reasonably and responsibly.

• Professional fees, dues and taxes which are consistent with the nature of your duties as an

employee of LBC.


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• Soft drinks purchased in supermarkets in order to avoid expensive mini bar options in hotels

• Soft drinks from the mini-bar in the hotel where no alternative is available.

2.13.10. Non-Allowable Expenses

Examples of Non-Allowable Expenses are shown below but not limited to:

• Fines, parking tickets, court costs associated with breaking the local laws e.g. speeding tickets

• Insurances associated with personal travel during a business trip

• Personal trips added to a business trip

• Personal items such as reading materials, tobacco, medicines (other than those needed as a

direct result of business travel), gum, chocolate, bottles of alcohol and the like.

• Baggage fees for recreational items taken on business trips

• Purchase of luggage

• In room or in-flight movies

• Additional fees for amenities such as golf, sauna, tennis etc.

• Expenses incurred by members of your family or friends who may accompany you on your

business trip.

• Valet parking in circumstances where other reasonable options exist that does not put you in

danger.

• Electronic devices

• Clothing or personal hygiene items for luggage that has been delayed by less than two days. NB:

when possible employees should attempt to carry two days provisions in their hand luggage


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Appendix 1: Travelers Pre-Travel Checklist

Item Item for consideration Y/N

1. Has your business travel been approved by your Approval Manager in writing

2. Is there more than one LBC employee traveling with you and could this impact business continuity?

3. Do you feel well enough to travel & are there medical reasons why it may be wise not to travel?

4. Have you considered your personal health, safety and security e.g.? Arriving/departing at unusual

times/ traveling alone, intensity of your visit, is this trip part of a series of consecutive trips?

5. Have you checked Governmental Travel Advice for this country?

6. Have you got the emergency 24 hour help line number with you?

7. Do you know the national emergency telephone number?

8. Have you programed the ICE (In Case of Emergency) number into your mobile?

9. Have you checked up front that the navigator (in hire car) can be programed in your language?

10. Have you left a copy of your travel itinerary and contact details with your Line Manager and a

family member?

11. Do you have the telephone number of the local consulate?

12.

13. Have you got a copy of any relevant insurance policies and numbers with you?

14. Have you looked up the layout/area beforehand to orientate. Google earth is a good tool?

15. Have you got a copy of travel documents with you including passport, hotel, taxi, car hire etc.?

16. Have you got the emergency telephone number to cancel credit cards?

17. Have you got all other business contact details with you such as the person/company you are

visiting?

18. Are visas or other special papers required?

19. Is this a country with an unusual currency and is it recommended to have a small amount of local

currency with you?

20. Do you know where to take a taxi, shuttle or pick up your rental car? Do you know local prices?

21. Are vaccinations or preventative medicines required and how many weeks/days prior to departure

must they be initiated?

22. Is this a developing country? take your own personal medical kit with you

23. Do you know what the climate/weather expectations are and have you got appropriate clothing

and other provisions (such as sun block)?

24. Are you prepared in other respects with regard to climate e.g. do you know what to do in the event

of an earthquake, hurricane, tornado, tsunami etc.?

25. Have you got a basic understanding of the country culture, customers, religious and political

culture and local laws in the country you are visiting?

26. When considering local laws do not forget that in some developed countries the smoking and

alcohol laws could affect you directly?

27. Are you aware of local traffic rules if driving a vehicle?

28. Is it recommended to have a local personal driver?


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29. Consider that in certain countries it is not permitted to be in possession of certain digital

information on laptops and/or telephones or certain literature. Delete any google history that

could be considered illegal.

30. Is this a developing country and/or are there issues with drinking water contamination? If so

do not drink tap water, accept ice cubes or eat salads or other foods that have been washed but

not cooked.

31. Is this a country where insect bites are an issue and if so do you have the appropriate clothing and

or anti-repellents?

32. If you are visiting an LBC Facility have you checked to make sure they have appropriate PPE for

you?

33. Have you packed all medical supplies (either business or personal) in your hand luggage? Have you

got a copy of the prescription for your medicines with you?

34. Check that your medicines are not prohibited in hand luggage and if so obtain a certified doctors

note

35. If you wear glasses have you got a spare?

36. Check the airline website for “healthy” flying tips (fluid intake, deep vein thrombosis etc.)


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Appendix 2: Hotel Safety and Security


1. If possible select hotels with electronic guest locks and not keys

2. If you have a key and lose it request another hotel room

3. If you lose your electronic key always ask for a reset of the system

4. Request that hotel staff do not give out your room number or say your room number in a loud

voice when giving you the key – if they do request another room

5. When registering avoid using title, marital status and gender specific titles

6. Do not leave your credit card on the hotel counter while completing the registration

7. Remain at the reception while your passport is copied. Do not accept a situation where a hotel

would like to return your passport the following day.

8. Upon check-in pick up a hotel business card and put it in your purse/wallet

9. Upon check-in request the emergency number in the hotel

10. If possible request a room with a telephone to dial out

11. Always stay with your luggage – even when using a concierge facility

12. Make use of additional security locks on doors

13. Preference should be given to hotels with own parking facilities

14. If you wish to be accompanied to the parking lot speak to the receptionist

15. Is there a hotel safe that you can make use of

16. Avoid rooms on the ground floor

17. Avoid rooms higher than the sixth floor, some fire departments will be unable to reach you at

these heights

18. Avoid rooms that are in very isolated areas of the hotel

19. When staying in motels reserve a room facing inwards into the inner courtyard and not outwards

on to the parking lot

20. If your room has an adjoining door check that it is locked

21. Do you know how the telephone in your room works

22. Check all closets, bathroom, under the bed, behind the curtains and the balcony

23. When leaving your room make sure the balcony doors and windows are locked

24. Do you know where the emergency exits are situated and have you checked the emergency

evacuation plan?

25. Preference should be given to hotels with a sprinkler and fire alarm system

26. Count the number of doors between your room and the emergency exit then in the event of fire

you can “feel” your way to the exit if visibility is difficult (always crawl on the floor if visibility is

poor due to smoke). Check the door with the back of your hand for heat prior to evacuating

27. Always carry a pocket torch on business

28. If you feel vulnerable leave the hotel room radio on while you are away

29. At night leave a small light on if you are out of the room and this is possible


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30. Ask the maid to make your room up during breakfast. If this is not possible place the “Do not

disturb” sign on the door and call housekeeping at a time that suits you

31. Always pull the door closed behind you to make sure it is locked

32. Do not display your room number in public and do not leave your room key/card on the dining

table during meals

33. Do not tell strangers you are traveling/staying alone

34. Try to avoid boarding an elevator with only one other person

35. If female request that room service be delivered by a female

36. Always meet visitors in reception

37. Do not open the door if you are not expecting visitors. Announce that you are calling reception

and do that immediately

38. Sanitize the hotel remote and telephone – these are the dirtiest items in your room

39. Do not leave valuable items or electronics in the room unattended

40. Be aware that not everybody in the hotel bar is a hotel guest

41. Be aware that some visitors to the hotel bar may be from local escort services

42. Report any unwanted advances to the hotel management


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Appendix 3 General Public Safety and Security

Item Item for consideration Yes No

General

1. Confirm your safe arrival to those that need to know

2. Be aware, blend in and don’t be predictable, don’t look like a tourist

3. When dining/drinking alone do not leave drinks unattended

4. Never tell anybody you are travelling alone

5. Avoid over crowded location and avoid isolated locations

6. Always report unattended packages

7. Always report unwanted attention

8. Try to blend into local surroundings (clothing)

9. Do not wear expensive items of jewelry

10. Do not let others see the contents of your wallet/purse

11. Avoid shoulder bags, opt for more secure fanny bags

12. Done stand openly on the street looking at a tourist map

13. Never use short cuts, alley ways, poorly lit streets

14. Never take a lift from somebody unknown

15. Be on the look-out for pick pockets

16. Trains and metro stations are often places where organized crimes gangs are

active

17. Don’t be afraid to use panic alarms

18. Do not purchase food from street vendors

19. Try and keep your money and bank cards separated at different points on your

body

20. Keep most valuable items in front pockets or in fanny bag

21. Don’t make financial banking transactions in internet cafes and other public Wi-Fi

zones

22. Don’t pet stray animals

23. If you are mugged cooperate with handing items over

24. Make cash withdrawals in daylight hours

25. Avoid discussions about politics or religion and avoid criticizing the countries

leader

In the car

26. Do not get in an unlicensed taxi

27. Speak out if the driver uses his mobile telephone while driving and ask him to stop

– you pay/you say

28. Ask the taxi driver the price before departure

29. Always wear your seatbelt


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Item Item for consideration Yes No

30. Check how the controls/functions work on a hire car before departing the hire

location

31. Do not let the fuel tank get below ¼ full

32. Check the vehicle for defects

33. Keep doors locked in the car when the vehicle is not moving

34. Avoid driving at night in an unknown location

35. Don’t park in an area where you do not feel comfortable

36. Don’t wind the window down to talk to people

37. Do not leave valuables in the car and always place items in the boot

38. Do not stop your car and get out if being flagged down, continue and call for help

form a safe location

39. Do not use the mobile telephone in the car

Airports

40. Keep items that must be x-rayed apart handy (fluids, laptops)

41. Never carry items for somebody else

42. Be aware what the custom rules are for the countries you will visit

43. Dress light and travel light it will be easier at the security controls

44. Don’t make jokes about bombs – security is trained to arrest

45. Despite common advice to do so, avoid tagging luggage with brightly colored

ribbons etc. that would indicate that you are a tourist

46. Use business number and address to label luggage and not home address

47. Do not use a business card as a luggage label

48. Rape alarms and pepper spray are forbidden in many countries and at airport

security

49. Never leave baggage unattended


DEFINITIONS

Definitions

• Acceptance– this is a process whereby the Work Permit Holder and Job Executers accept the Permit to

Work since all necessary pre-job controls have been carried out and that these controls have been

verified.

• Action Manager: tool in the CSR-HSSEQ database designed to manage actions from an Incident

investigation process.

• Actual Severity: the actual Severity level of an Incident as determined using the Severity Impact Matrix

• AED (Automated External Defibrillator) is a portable device that can be used to restore a regular heart

rhythm by means of delivering an electric shock when someone has experienced a heart attack. Such

equipment can be operated by passers-by with little or no training.

• Aggression: Hostile or violent behavior or attitudes toward another; readiness to attack or confront

• AIFR: All Injury Frequency Rate

• Allowable Expenses – these are expenses that are considered responsible and justified by LBC and may

be declared.

• Anchor point - is a fixture to which a person anchors an approved line (typically with a hook) to be held

securely and thus reduce the impact of a fall. This point must be certified and approved for the forces

that will be applied in the event of a fall.

• ANSI: American National Standards Institute

• Approval Manager – this is the appointed Line Manager who must approve all expenses declared by an

employee and who must also give permission for all travel (up front by e-mail) involving transport

other than by company lease car and/or involving the provision of hotel accommodation.

• ATEX – Explosive Atmosphere Regulations

• Audit is a systematic, independent and documented process for obtaining audit evidence (records,

statements of fact or other information which are relevant and verifiable) and evaluating it objectively

to determine the extent to which the audit criteria (set of policies, procedures or requirements) are

fulfilled.

• Assessment: a testing program that the candidate must follow to decide if the candidate is suitable for

the position and obtains the necessary skills.

• Backwardation: The opposite market condition to Contango is known as backwardation

• Blacklisted –A Contractor Company or individual employee of a contractor company when banned

from working at an LBC Facility indefinitely or for a set period because of an indiscretion is said to be

blacklisted.

• Blind Lift – Lift where the operator cannot see the load for some or all of the Lifting / Hoisting

operation.

• Bomb Threat: A bomb threat is generally defined as a threat, usually verbal or written, to detonate an

explosive or incendiary device to cause property damage, death, or injuries, whether or not such a

device actually exists

• Bonding is the process by which electrical conductors are joined together such that they have the same

electrical potential thereby preventing charge from building up and current from flowing.

• Bowtie analysis: is a barrier risk model for Risk Identification and Risk Management.

https://en.wikipedia.org/wiki/Backwardation


DEFINITIONS

• Buddy: collaborator or colleague who is working in the department or in the same team as the New

Joiner. The buddy will accompany and coach the New Joiner during his introduction and predefined

training period.

• CAPEX: Capital Expenditure

• Causal Factors: These aspects of the Incident are effectively contributory breaches which in

themselves did not cause harm but made a significant contribution to the Incident. They are also

referred to as “in-direct causes”.

• Category 1 Contractor: Individuals employed with temporary contracts to work within the organization

including students and vacation workers. For Incident statistics, the worked hours of Category 1

Contractors will be classified as LBC Personnel worked hours.

• Category 2 Contractors: are companies or individuals engaged for either discrete project outside the

operational and/or office area or companies or individuals engaged under contract to carry out specific

tasks or provide specified services within the operational area (including office areas).

• CE: is a certification mark that indicates conformity with health, safety, and environmental protection

standards for products sold within the European Economic Area

• Central Work Permit Location – this is a location where all Permits to Work for all locations on the

facility are displayed

• Change – is an alteration or adjustment to any component, variable or property (except those

permitted within clearly defined responsibilities and boundaries)

• Clean Shaven Policy is the requirement for individuals to remove facial hair when using certain sorts of

respiratory protective equipment as defined by the Risk Assessment.

• Competent Person is a person who has sufficient theoretical knowledge, practical experience and the

required qualities and qualifications for the task in hand and is able to perform the activities within an

occupation of function to the standard expected in the task. Competency requirements and training

records must be documented.

• Confined Space is defined as an enclosed or partially enclosed space that;

• Has been identified as such in a Risk Assessment

• Is not intended or designed primarily as a place of work

• May have restricted entry and/or exit

• May have an atmosphere which contains potentially harmful levels of Contaminants

• May not have a safe level of oxygen for example but not limited to -following a nitrogen purge, as a

result of decaying dead organic matter, chemical reaction etc.

Examples of a Confined Spaces but not limited to are: Storage tanks, process vessels, boilers,

pressure vessels (such as vacuum wagons), tank-like compartments that have only a man-hole for

entry, cellars, attics, open topped spaces such as the space under a weigh bridge, excavation

trenches deeper than 1.2 meters, sewers, shafts, ducts and drains.

• Confined Space Under Inert Atmosphere (Inert Entry) is defined as a Confined Space which has been

purged or put under a blanket of an inert gas such as but not limited to nitrogen or argon. It is not

permitted for LBC personnel to enter a Confined Space Under Inert Atmosphere. This must be

conducted by specialist contractors and a specific Risk Assessment and procedures must to be

developed specifically for Inert Entry.


DEFINITIONS

• Confined Space Watch– this is a specially trained Competent Person whose only task is to remain

outside the Confined Space entrance in communication with the person(s) in the Confined Space and is

charged with raising the alarm in an emergency. This person may have no other tasks when performing

this duty.

• Consequences – outcome of an event

• Container refers to any mobile (portable) or stationary vessel with a capacity greater than 60 liters

(15.84 US gallons) used to contain Products. For example, but not limited to drums, IBC containers, rail

cars, lorries, fixed tanks and marine vessels such as boats and barges.

• Contaminant is defined as any dust, fume, mist, vapor, gas or other substance in liquid or solid form

that may due to its presence or absence be harmful to health and safety of personnel

• Contango: is a situation where the futures price (or forward price) of a commodity is higher than the

anticipated spot price at maturity of the futures contract.

• Contractor Manager – this is one designated person at a facility with overall responsibility for ensuring

compliance with the Management of Contractor Policy for all contractors.

• Corporate Risk Management Policy Statement - a statement of intent from the CEO defining the broad

terms of Risk management within the organization.

• Corporate Risk Register Overview - public statement from the CEO advising Stakeholders of Risks that

the organization faces and detailing Corporate Risk Owners.

• Crisis is an inherently abnormal, unstable and complex situation that represents a threat to the

strategic objectives, reputation or existence of an organization.

• Crisis Status Incident is a level 3 or 4 Incident that has been escalated in accordance with the Incident

Reporting and Investigation Policy and defined by the Group Crisis Leader and/or Group CSR Director as

being a Crisis and for which the involvement of the Corporate Crisis Team is required.

• CSR-HSSEQ database: SharePoint-based database for managing and analyzing HSSEQ data and related

actions, including, but not limited to: Incident reporting and investigation, MOC, PEER reporting,

Critical Safety Rule breaches, Incident frequency rates.

• Customer Complaint - Communication: Communication with Customer or Carrier causing failures or

errors in the quality of service.

• Customer Complaint - Customer Shut Down: Any event at LBC Facilities causing a customer to shut

down.

• Customer Complaint - Demurrage: Any event causing a delay in loading or unloading of ships, barges,

trucks or railcars which then would result in extra costs

• Customer Complaint - Documentation Issue: A wrong paperwork Incident must be recorded if wrong

paperwork is sent to any internal or external customers, including but not limited to Bill of Lading,

invoices and reports

• Customer Complaint - Equipment Issue: Quality issue due to malfunction of equipment

• Customer Complaint - Inventory Control: Deviations to or differences in inventory control.

• Customer Complaint - Label Issue: Wrong label used for identifying product. Not compliant with local

or regional classification, labelling and packaging requirements.

• Customer Complaint - Missed Shipment (or No show): A missed shipment Incident must be recorded if

the customer’s shipment does not meet the shipment date on the scheduled calendar date because of

LBC non-compliance. Late shipments are identified by calendar date, meaning a missed shipment is


DEFINITIONS

one that did not ship on the scheduled calendar date irrespective of the time during that day that it is

shipped.

• Customer Complaint - Product Off-Spec: An out of specification product Incident must be recorded

and categorized according to the priority of selection for Products in our custody, i.e. in our tanks or

leaving the LBC Facility. Inbound product that is sampled and identified as out of spec should not be

recorded as an Incident. Products that are off-spec as a result of Unintended Product Transfer should

be recorded under Unintended Product Transfer.

• Customer Complaint - Reachability: Customer was unable to connect to Customer Service Department

or Customer Service Department was unavailable.

• Customer Complaint - Slot / Schedule Issue: Any event or Incident causing obstruction of customer

planning

• Customer Complaint - Third party: Non-LBC employee, Contractor or Visitor

• Customer Complaint - Third party survey: Intervention or audit performed by 3rd party.

• Customer Complaint - Wrong quantity: A wrong quantity Incident must be recorded if a wrong

quantity is shipped compared to the customer order and is outside the tolerance. This includes

underweight and overweight trucks, railcars and marine vessels, however only those that depart the

LBC Facility. Underweight and overweight occurrences that are identified through normal procedures

such as quality checks or weighing and are corrected before the shipment leaves should not be

recorded. Instead, these occurrences should be tracked by the customer service department

independent from reporting.

• Cyber Breach: Unauthorized access to secure intellectual information. A Cyber breach is an Incident in

which sensitive, protected or confidential data has potentially been viewed, stolen or used by an

individual unauthorized to do so. Data breaches may involve personal health information (PHI),

personally identifiable information (PII), trade secrets or intellectual property.

• Danger Zone – this refers to an area (typically cordoned off) that is considered hazardous. The Danger

Zone and the safety measurements that apply in the danger zone are determined on the basis of a Risk

Assessment carried out by Competent Persons. A danger zone may be established:

• around an Excavation site

• around the outside of a Confined Space due to the nature of the atmosphere in the Confined Space

or in which a High-Pressure water jet is being utilized

• around a working at height or Hoisting/Lifting activity

• Designated Employee – an employee trained in basic first aid, resuscitation techniques, recognition of

signs and symptoms and conditions that could result in the need to use an AED and the operation of

the AED. The training must be conducted by a reputable and certified supplier and the Designated

Employee must receive annual refresher training.

• Detailed Facility Risk Registers - these are detailed documents containing specific Risks and Risk

Treatments within an LBC Facility that have been identified for local activities and situations and in the

local context.

• Designated Deputy: a person appointed as a substitute with power to act

• Designated Travel Agent – this is the preferred supplier that should be made known at each LBC

Facility in Europe


DEFINITIONS

• Digging - refers to the removal of Top Surface Material using manual means such as a spade, pick, hoe

or other manual tool

• Direct cause: These are aspects of the Incident which directly influenced the outcome (damage or

injury) and are also referred to as “immediate causes”. They are the features of an Incident which

immediately contributed to harm or damage being caused.

• Drop to Shock Time – the time needed to get the AED from its normal storage/display location to the

victim and administer a shock. Shock to drop times should be preferably less than 3 minutes with 5

minutes being the maximum.

• Earthing is the term also used to mean grounding. Earthing is the process of providing a low impedance

path to the earth (a physical connection to the earth) to prevent hazardous voltages from appearing on

equipment and systems to ensure that stray electricity does not come into contact with persons or give

rise to a spark.

• Efficiency and innovation Idea: a responsible idea that if implemented is expected to result in a

monetary and/or non-monetary improvement of minimum 5% on an annual basis, will contribute to

the Group Strategy and is fully aligned with the Mission, Vision and Values of the organization.

• (Mobile) Elevating Work Platform - mechanical device used to provide temporary access for people or

equipment to inaccessible areas, usually at height. Examples include: ‘cherry picker’ and ‘scissor lift’.

• Emergency is defined as a serious, unexpected, and dangerous situation requiring immediate action.

Examples of emergencies are fire, explosion, spills, releases, serious injuries, fatalities, inclement

weather including tropical events and flooding, pandemic outbreak, security breach, terrorism, social

riots or unexpected severe reputational damage. An emergency is not necessarily a Crisis.

• Emergency Action and Preparedness Plans are plans written with appropriate actions designed to

prevent Incidents from happening. If Incidents do happen the plans are designed for limiting the impact

of an Incident while in progress and speeding up recovery and return to normal operations. Examples

are Federal Response Plans, Emergency Response Plans, Integrated Contingency Plans, Facility Security

Plans, Process Safety Plans, or any written and approved plan designed to control various Emergency

situations. All Emergency Action and Preparedness Plans are written to cover all risks as identified in

accordance with the Risk Management Policy

• Emergency Change – A Change that must be introduced immediately to restore service due to an

Incident or a Change that needs to be implemented immediately to avoid an Incident. The normal MOC

process cannot be applied because the situation is an emergency and requires immediate action. This

Change must be authorized by the most senior member of the LBC Facility or their Designated Deputy

(NB: this does not mean the most senior person present at the time on the LBC Facility premises)

• Emergency Stop Button on the High-Pressure Water Jetting System ensures that the High-Pressure

Water Jetting System is immediately depressurized and switches off the whole High-Pressure Water

Jetting System. The remote emergency stop button ensures that the system and the High-Pressure line

are immediately depressurized. Before a High-Pressure Water Jetting System can be switched on again,

it must be reset and it must not be possible after activating the emergency stop button to switch on

the High-Pressure Water Jetting System again with the emergency stop button.

• Emergency Stop Operator is an employee who has the emergency stop button within reach and who

has constant visual contact with the High-Pressure Water Jetter so that he can immediately

depressurize the system using the emergency stop button in the event of a dangerous situation. The


DEFINITIONS

Emergency Stop Operator must hold a valid certificate as High Pressure Water Jetter or High-Pressure

Pump Operator.

• Energy-isolating device: A mechanical device that physically prevents the transmission or release of

energy. Examples include, manually operated electrical circuit breaker, a disconnect switch, manually

operated switch by which the conductors of a circuit can be disconnected from all

Ungrounded/Unearthed supply conductors (and in addition no pole can be operated independently), a

line valve, a block or similar device used to block or isolate energy. NOTE: push buttons, selector

switches and other control circuit-type devices are not Energy-Isolation Devices.

• Entry into a Confined Space is defined either as a person’s whole body, upper body or head entering a

Confined Space. This is not intended to prevent a person placing their hand or arm into a Confined

Space under normal atmosphere while using a testing device or a probe as part of a risk assessed and

clearly defined and authorized procedure.





• ERP (Enterprise resource planning) is the integrated management of core business processes, often in

real-time and mediated by software and technology

• Establishing Context – defining the external and internal parameters to be considered when managing

Risk.

• Excavation – refers to the removal of Top Surface Material using any mechanical device. Excavation

and digging shall be used throughout the standard to mean the same thing

• Extended Shift - no longer than 72 hours per week with no longer than 12 worked hours in any one day

and no more than 6 days in a week. Not necessarily over daytime hours.

• External Noise: Any noise exceeding the maximum limit of the noise range causing a nuisance outside

of the LBC Facility to the public

• External Odor: Any spill, release or emission to the environment outside containment causing odor

nuisance outside of the LBC Facility to the public

• External Posting: posting of vacancies on all other canals, open for all candidates.

• External Release to Air: Any spill, release or emission to air outside containment.

• External Release to Ground: Any spill, release or emission to ground outside containment.

• External Release to Water: Any spill, release or emission to water outside containment.

• Fall prevention – is a safe Work Platform designed such that the risk of falling has been eliminated e.g.

permanent Work Platform, Scaffold, Elevating Work Platform such as a scissor lift or man lift.

• Fall protection – a fall protection system is a device such as a fall protection harness and lanyard that

must be used when the risk of falling cannot be eliminated by Fall Prevention

• False Identity: Use of a fake identification to misrepresent in order gain access to the LBC Facility or for

personal gain

• Fatality: This is an OSHA Recordable injury that results in death of the person within 30 working days of

an Incident.


DEFINITIONS

• Fatigue - Mental or physical exhaustion that stops a person from being able to function normally. It is

the state of feeling very tired, weary or sleepy resulting from insufficient sleep, prolonged mental or

physical work, or extended periods of stress or anxiety.

• Field Check – this is a visual inspection carried out prior to using any Hose -this could be part of the

LMRA

• Final Reviewer: Competent Person(s) responsible to verify the Incident Investigation process,

investigation reports and close-out of actions. For level 4 Incidents the Group CSR Director is the only

person who may close-out an Incident.






• First Aid Case (FAC): First Aid refers to medical attention that is usually administered immediately after

the injury occurs and at the location where it occurred. It often consists of a one-time, short-term

treatment and requires little technology or training to administer. First aid can include cleaning minor

cuts, scrapes, or scratches; treating a minor burn; applying bandages and dressings; the use of non-

prescription medicine; draining blisters; removing debris from the eyes; massage; and drinking fluids to

relieve heat stress.

• First Level Reviewer: Competent Person(s) responsible for reviewing Incident entries submitted into

the CSR-HSSEQ database. First Level Reviewers are authorized to appoint an Incident Investigation

Lead and request a Root Cause Analysis. In the case of a level 3 or 4 Incident the Group CSR Director

may assign at his/her discretion assign the Incident Investigation Lead.

• Fit for Work is a medical Risk Assessment that determines the suitability of an individual to wear sorts

of PPE to carry out their activities e.g. breathing air equipment. The necessity for this will be

determined by local regulation and Risk Assessment.

• Fit Test refers to a periodic training for employees to ensure that respiratory protection is correctly

used such that exposures to hazards are reduced. Such a training should involve the use of a Fit Test to

ensure that respiratory protection is firmly sealed around the face such that there is no leakage.

Typically, a Fit Test training will involve exposing employees to a harmless but pungently smelling

substance to determine their effectiveness at correctly using the respiratory protection.

• Foot pedal is a foot-operated pedal for pressuring or depressurizing the Jetting Equipment or supply

hose.

• Fraud: Wrongful or criminal deception intended to result in financial or personal gain.

• Fully Automatic Cleaning refers to cleaning in which the High-Pressure Jetting Equipment is operated

form a safe distance by a High-Pressure Water Jetter. The High-Pressure Water Jetter must have

complete control over the Jetting Equipment. During pressurization of the High-Pressure Water Jetting

System, the High-Pressure Pump Operator must have a clear view of the working area.

• GDP: Gross Domestic Product

• GHS: Globally Harmonized System of Classification and Labelling of Chemicals

• Governance refers to the mechanisms, relations, and processes by which LBC is controlled and is

directed; involves balancing the many interests of the Stakeholders.


DEFINITIONS

• Group Mission: To create a sustainable and proactive culture in which all risks are identified and

treated responsibly such that the positive impact of our decisions and activities on society is maximized

and any negative impacts minimized.

• Group Values: Responsibility, Transparency, Respect, Integrity, Empowerment

• Group Vision: There is no such thing as a dangerous product at least not when under our care.

• Group Strategy: Further Optimize, Build-out, Expand

• Harness Suspension Trauma -this is the process whereby a person hanging in a harness can become

extremely unwell or die if not rescued quickly.

• A Hazard and Operability Study (HAZOP) is a structured and systematic examination of a complex

planned or existing process or operation to identify and evaluate problems that may represent Risks to

personnel or equipment.

• Hazardous Energy: for example, but not limited to: electrical, pneumatic, hydraulic, stored (for

example in springs and batteries), potential (by position), heat (for example, hot water, steam),

velocity and radiation.

• Hazardous Substances: Gases, vapors, liquids, dusts (solids) with the potential to cause injury or illness

e.g. toxic, corrosive flammable.

• High Level Facility Risk Register – this is a high-level document containing a list of the most significant

risks that an LBC Facility faces and the agreed Risk Treatment and Risk Owners.

This document is established by an escalation process in which all the Detailed Risk Registers within an

LBC Facility are escalated to provide a document containing the highest impact Risks.

• High Voltage Electrical Work – is defined by The International Electrotechnical Commission (IEC) as an

electrical voltage of approximately 1000 volts AC and 1500 volts DC.

• High pressure is understood to be a working pressure of higher than 250 bar or where the pump

power is higher than 10 kW with a working pressure of higher than 25 bar

• High Pressure Jetting Equipment (or Jetting Equipment) is apparatus equipped with a nozzle (s) with

which the High-Pressure water jet is directed at the surface to be cleaned. For example, but not limited

to: het gun, flexible lance, foot pedal, floor/wall cleaner, lance machine, tank cleaning head.

• refers to all equipment needed to be able to work with the High-Pressure water jetting installation to

carry out the High-Pressure water jetting activity. This includes but is not limited to such items as High

Pressure hoses; hose fracture protection devices and Jetting Equipment.

• High Pressure Water Jetter is responsible for carrying out the High-Pressure water jetting work

assigned to him and he works under the supervision of the High-Pressure Pump Operator at all times.

• High Pressure Water Jetting Accessories refers to all equipment needed to be able to work with the

High-Pressure water jetting installation to carry out the High-Pressure water jetting activity. This

includes but is not limited to such items as High Pressure hoses; hose fracture protection devices and

Jetting Equipment.

• High Pressure Water Jetting System is an installation, fixed or mobile, consisting of a power unit, pump

unit, pressure regulation device, pressure gauge, safety devices, hoses and jetting device with which

water can be jetted at High Pressure.

• High Pressure Pump Operator is responsible for the High-Pressure Water Jetting System and for all

actions undertaken. He must be present at the place of work all the time.


DEFINITIONS

• Hiring Manager: is the person who is directly responsible for steering the team that the new employee

will join.

• Hoisting is defined as an activity during which the load is suspended and hangs freely e.g. by means of

but not limited to a crane, chain hoist, beam clamp etc.

• Hose: removable device for Product transfer in liquid and/or vapor form and/or for the supply of

utilities. Typically, stainless steel corrugated hose with reinforced webbing, or chemi-flex composite

hoses

• Hose catching mechanism is a device that catches the hose in the event of uncontrolled recoil or

controlled recovery of the hose.

• Hose sleeve is installed over the hose coupling to the jet gun and is resistant to the escaping water jet

in the event of leaks in the hose or coupling.

• Hot tap: Deliberately piercing the pressure boundary of equipment that is in service or under pressure,

without shutting down or gas freeing the equipment

• House Contractors: Category 2 Contractors are sometimes referred to as House Contractors if they

have a daily or weekly presence in the facility.

• HR Business Partner: is the local HR person responsible for all HR related tasks in the recruitment

process of a new employee.

• HSSEQ – Health, Safety, Security, Environmental, Quality

• Hydrostatic testing is a process whereby Hoses are tested using water under pressure to assess the

structural integrity of the Hose and identify if the Hose is still fit for purpose

• Improvement: is a betterment resulting in but not limited to reduced costs, improved profits, time

savings, reduction of ergonomically repetitive acts, reduced energy and disposable items usage,

increased recycling, health benefit, comfort benefit etc.

• Incident: an unplanned event or chain of events has occurred (i.e. energy was released) that has or

could have, resulted in:

• injury or illness to people

• damage to the environment / reputation / community

• compliance issues

• (temporary) discontinuity of operations and/or customer service agreements

• Financial loss / property damage / unavailability of assets / insurance claim

• Security issues

• Incident investigation: is a process conducted for Incident prevention which includes the gathering and

analysis of information, drawing of conclusions, including determination of causes and, when

appropriate, making of safety recommendations.

• Incident Investigation Lead: Competent Person assigned to lead the RCA process.

• Incident Investigation Team: Multidisciplinary Team lead by the Incident Investigation Lead tasked to

investigate the Incident. In the case of a level 3 or 4 Incident the Group CSR Director may assign at

his/her discretion members to the Investigation Team

• Incident Review Meeting: Meeting with CEO, Group CSR Director and Terminal Manager or delegate.

The purpose of the meeting is to review the Incident, the Incident Investigation process, the identified

actions and action follow-up at a local, regional and/or group level.


DEFINITIONS

• Inert Entry – is defined as either a person’s whole body, upper body or head entering the Confined

Space Under Inert Atmosphere.

• Investigation Reviewer: Competent Person(s) responsible for reviewing Incident Investigation reports.

• Internal Posting: posting of vacancies on various internal LBC canals, open for employees only.

• Isolation Officer: Competent Person designated to carry out the Isolation procedure. No person may be

designated as an Isolation Officer for an item unless he has been trained, tested and certified in

accordance with local legislation as competent to carry out the specific isolation procedure for that

specific item and thus meets the requirements of the Competent Person definition.

• Issuing Authority is an entity at a local, regional, or national level that provides oversight governing

safety, environmental, emergency preparedness, or other governmental authority such but not limited

to Port Authority, Coast Guard etc.

• Item – is a device (owned or not owned by LBC) that is on LBC premises and requires a Lockout/Tag-out

(LOTO) procedure to isolate all energy sources prior to performing an activity such as servicing or

maintaining.

• Job Executor - is the person(s) who will carry out the job. This may also be the Work Permit Holder.

• Job Safety Analysis (JSA) – a specific to the job Risk Assessment detailing the risks involved in the

activities, Risk Treatments and work methodology to be employed. The JSA is attached to the Permit to

Work and discussed with all involved parties. The JSA together with the Permit to Work should be

present at the Work Location.

• Key Performance Indicator (KPI) – is a measurable value (metric) that is tracked and analyzed and

deemed as having significant importance to the success of the LBC organization and the achievement

of LBC’s strategic business objectives.

• Kidnapping: To take away (someone) by force usually to keep the person as a prisoner and demand

money for returning the person.

• Layers of Protection Analysis (LOPA) is a type of Risk Assessment methodology primarily focusing on

process safety risks.

• LBC Document Management Site is a SharePoint-based system used to track, manage and store

documents

• LBC Facility – any facility owned or leased by LBC where LBC employees work.

• Level of Risk – magnitude of risk expressed as a combination of Consequences and Likelihood.

• License is defined as a document or certificate authorizing activities or specific functions such as

occupational licenses, or bonded storage licenses. Licenses may also be issued for specific equipment

such as weighbridges, boilers, or scales.

• Lifting is as an activity during which the load is lifted in a controlled and guided manner, normally

spoken from the bottom of the load, e.g. by means of but not limited to a forklift truck, screw jack,

hydraulic jack etc. The term “lifting” is used though out the policy to describe all types of lifting and

hoisting.

• Lift Plan – is a document that defines exactly how Lifting / Hoisting will be carried out. The document

must be based on Risk Assessment.

• Likelihood – chance of something happening


DEFINITIONS

• Line cutting is the intentional physical penetration of the integrity of a Product, utility or other process

line by any means. Examples include but are not limited to mechanical or pneumatic sawing, boring,

welding, High Pressure water jetting.

• Line Cutting Supervisor: an LBC employee officially assigned, authorized and designated to supervise

Line Cutting activities. This person must be competent to fulfill the tasks associated with this role in

accordance with the Competent Person definition.

• Loading and unloading relates to the movements of Products from one Container to another

• Lock box - is a Lockable box containing the key(s) of locks physically applied by Isolation Officers to

hold all energy isolation devices in a safe position and prevent the energizing of machines or

equipment being serviced or maintained.

• Lockout: this is the placement of a Lockout Device on an Energy-Isolating Device that ensures that the

Energy-Isolating Device and the item being controlled cannot be operated until the Lockout Device is

removed.

• Lockout device: A device that uses a positive means such as a lock, either key or combination, to hold

an Energy-Isolation Device in the safe position and prevent the energizing of the item. Included in this

definition are blank flanges and bolted slip blinds that have been identified as such.

• Lockout/Tag-out (LOTO) or (Isolation) refers to the specific practice and procedures to safeguard

employees and others from the unplanned energization or startup of items such as although not

limited to machinery, apparatus, equipment, plant or process during planned and unplanned service

and maintenance activities. Only a designated and trained individual (Isolation Officer) may isolate the

energy source to the equipment or machinery and lock and/or tag the energy isolating device to

prevent the unexpected release of Hazardous Energy.

• LOPCFR: Loss of Primary Containment Frequency Rate

• Loss or damage: Any event (excluding quality non-conformance) which results in damage to property

and/or Product

• Loss of Primary Containment: An unplanned or uncontrolled release of any Product from Primary

Containment.

• Loss of Secondary Containment: An unplanned or uncontrolled release of any Product from Secondary

Containment

• Lost Time Injury (LTI): This is an OSHA Recordable injury or illness that results in an employee missing

more than one full shift of work. Do not count the day of the Incident itself.

• LTIFR: Lost Time Injury Frequency Rate

• LTISR: Lost Time Injury Severity Rate

• Management Review is a formal, structured meeting which involves top management and takes place

at regular intervals throughout the year. The purpose of the meeting is to review and evaluate the

effectiveness of the Management System and to define continuous improvement actions

• Manual cleaning refers to cleaning during which the Jetting Equipment is operated by the High-

Pressure Water Jetter. The High-Pressure Water Jetting System is pressurized by the High-Pressure

Water Jetter by means of a switch on the Jetting Equipment, jet gun or foot pedal. An Emergency Stop

Operator must be present at all times. He must be in constant visual contact with the High-Pressure

Water Jetter.


DEFINITIONS

• Major Hazard Event: an occurrence such as a major emission, fire, or explosion resulting from

uncontrolled developments, and leading to serious danger to human health or the environment

(whether immediate or delayed) inside or outside the LBC Facility, and involving one or more

Hazardous Substances.

• Major Non-compliance: Breach of the requirements imposed by governmental bodies, regulators,

industry mandates, ISO or branch auditors or internal policies resulting in immediate shutdown of the

LBC Facility or part of the LBC Facility or loss of certification or loss of customer contract.

• Manager: the person who is directly responsible for steering the team that the new recruit will join or

who the new employee reports to. He or she will also determine and plan the evaluation moments

together with the new employee.

• Master Lock: A lock or series of locks that are controlled by a master key.

• Medical Treatment Case (MTC): This is an OSHA Recordable injury or illness that results in an

employee receiving medical treatment that can only be administered by a medically qualified

professional.

• Mentor: The mentor is responsible for the execution of the training, development and the follow up of

the New Joiner.

• Minor injury no treatment: This is an injury or illness that requires no form of treatment at all.

• Minor Non-compliance: Breach of the requirements imposed by governmental bodies, regulators,

industry mandates, ISO, Branch or Customer Auditors or internal policies but not resulting in

immediate shutdown of part or all of LBC Facility nor loss of certification or termination of customer

contract.

• MOC – Management of Change

• MOC Final Approver – the person at the highest level charged with the ultimate sign off of the MOC

procedure thus allowing the implementation of Change to occur

• MOC Proposer – the person submitting the proposal for Change

• MOC Team – the Multidisciplinary Team involved in assessing the proposed Change

• Most Senior LBC Employee – this is the most Senior Local Employee with an LBC credit card present at

an entertainment event who must declare the costs incurred by LBC. If there is no local employee with

an LBC Credit Card present, it is any other LBC employee who has company credit.

• Multidisciplinary Team – this is defined as a team composed of Competent Persons with differing and

appropriate skills for the assigned task(s).

• Near Miss: An Incident that could have caused illness in or injury to people, or property damage,

damage to the environment or reputation, but did not (i.e. energy was released and no actual

Consequence).

• New Joiner or new employee: This is a person joining LBC as a new member and is foreseen to stay for

a period longer than 6 months (not a short-term temp).

• NFPA: National Fire Protection Association

• NIOSH: National Institute for Occupational Safety and Health

• NMFR: Near Miss Frequency rate

• Non- Allowable Expenses – these are expenses that are not considered responsible and justified by

LBC and may not be declared.

• Non-routine lift


DEFINITIONS

• Non-routine Complex Lift - is characterized by: Lift gross weight >90% of the rated capacity of the

Lifting appliance, use of two or more Lifting appliances, within difficult or restricted areas, over active

or energized equipment, tanks and other critical assets, work in vicinity of overhead electrical power

lines, lowering of a load into a Confined Space, Blind Lift, Lifting of personnel.

Non-routine Simple Lift – is characterized by: Lift gross weight >75% (but less than 90%) of the crane

capacity, loads with known and evaluated weight with a center of gravity below the Lifting point,

ample headroom, unlikely to be affected by changing environmental conditions, not working within

live process, narrow or restricted areas.

• Normal Week with Normal Day Shift - is generally considered to be a work period of no more than

eight consecutive hours during the day, five days a week with at least an eight-hour rest and does not

include Shift Workers or Contractors.

• Normal Week with Extended Shift - this is no longer than 40 hours with no longer than 12 worked

hours in any one day.

• OPEX – Operational Expenditure

• OSHA Recordable Incidents are work-related injuries, illnesses, and fatalities that must be recorded by

employers according to OSHA (Occupational Safety and Health Administration) standardized

guidelines.

• Participation Gift Voucher: this is a nominal reward in the form of a € 10 (or local currency equivalent)

gift voucher that will be awarded to all persons submitting an idea to the [email protected] email

address, with the minimum required information (Minimum Criteria. This voucher will be awarded a

maximum of 3 times per contributing employee in any 12-month period.

• Permit is defined as a document issued by an Issuing Authority that provides legal authorization to

operate or perform an operation and related activities including the requirements and conditions to

maintain compliance with the Permit. Examples are Permits issued such as Title V, and Environmental

permits.

• Permit to Work – is a formal, written and signed agreement between several parties (normally the

Permit to Work Issuer, Work Permit Holder and Job Executer describing the work to be carried out and

the agreed work method and control measures to be taken to ensure the safe execution of the job. The

Permit to Work is considered as a legally binding agreement.

• Permit to Work Issuer – this person is an authorized and designated person who is responsible for the

area where the work will be executed.

• Person in Charge (PIC) – One person must always be designated as the Person in charge of the Lifting

operation in the field. This person has operational control over the lift and is responsible for reviewing

the Lift Plan and ensuring that the work is executed according to the Lift Plan.

• Personal Lock – a Master Lock issued individually to each Isolation Officer and for the use of only the

designated Isolation Officer to which it was issued.

• Personal Protective Equipment (PPE) is defined as for the purposes of this standard as “all equipment

(including clothing affording protection) which is intended to be worn or held by a person at work and

which protects him or her against one or more risks to his or her safety and health. This includes but

not exclusively limited to: clothing, safety shoes, safety helmets, gloves, ear protection, eye protection

(including prescription glasses), respiratory protection equipment, high visibility clothing, safety

footwear, safety harnesses, sun protection products, barrier creams. The hazards addressed by



DEFINITIONS

personal protective equipment include physical, electrical, heat, radiation, chemicals, biohazards, and

airborne particulate matter.

• Piracy: The unauthorized use of another's production, invention, or conception especially in

infringement of a copyright.

• Planned Change – A Change that occurs when deliberate decisions are made in an organization.

• Policy Owner - has accountability for maintaining the policy and ensuring its ongoing relevance to the

organization and for providing training to local Management Teams.

• Potential Severity: the potential Severity Level of an Incident as determined using the Severity Impact

Matrix. The consequences that could have occurred if the circumstances at the time of the Incident

were less favorable.

• Preferred Supplier – this is a contractor who has quantitatively been ranked based on their actual

performance and/or expected performance and is considered suitable to work at an LBC Facility.

• Pre-Start up Safety Review (PSSR): a safety review conducted prior to startup (commissioning) of a

new or modified processing/manufacturing plant or facility to ensure that installations meet the

original design or operating intent, to catch and re-assess any potential hazard due to Changes during

the detailed engineering and construction phase of a project. The PSSR is a final check to ensure:

• that installation meets the original design and operating intent of process plant/facility

• safety, operating, maintenance and emergency procedures are in place and adequate

• appropriate Risk Assessments during engineering phase (e.g. HAZOP) have been carried out and all

action items have been completed

• any site modifications during construction phase have been properly controlled and noted

• training of each employee involved in the operating process is completed

• Pressure Vacuum Accessories (or Accessories) refers to all equipment that is necessary to be able to

work with the pressure vacuum truck and carry out the pressure vacuum activities. For example, but

not limited to ohm-hoses and m-hoses.

• Pressure vacuum Supervisor – refers to the person supervising the pressure vacuum work. Supervisors

must have sufficient knowledge and skills to guarantee safety during the preparation and

implementation of pressure vacuum cleaning work.

• Pressure Vacuum Truck refers to the pressure vacuum truck for liquids as well as the air displacement

truck and suction excavator truck.

• Primary Containment: equipment intended to serve as the primary Container or used for processing

or transfer of material. For example: tank, pipe, pumps, flex line, ship, barge, rail car, tank truck, IBC

(packaging) and drum (packaging).

• A process hazard analysis (PHA) is a set of organized and systematic assessments of the potential

hazards. A PHA provides information for improving safety and reducing the consequences of unwanted

or unplanned releases of Hazardous Substances. A PHA is directed toward analyzing potential causes

and consequences of fires, explosions, releases of toxic or flammable chemicals and major spills of

hazardous chemicals, and it focuses on equipment, instrumentation, utilities, human actions, and

external factors that might impact the process

• Product (or Chemical) - any substance that is handled on LBC Facilities or on a jetty facility used by LBC.

The definition is extended to include waste chemicals and waste water containing chemicals including

rainwater.


DEFINITIONS

• Product cross contamination – different products: Product sent to wrong Container with different

Product resulting in Product cross contamination.

• Product cross contamination – same products: Product sent to wrong Container with similar Product

resulting in Product cross contamination.

• Product transferred to wrong (empty) vessel: Product sent to wrong (empty) Container.

• Protective System– a method of protecting persons and/or adjacent structures from a cave-in by for

example excavating the sides (walls) of an Excavation site with an appropriate inclination angle

(sloping) and/or stepping and/or the use of support systems. The system used depends upon the

hydrology, hydrogeology and the geology of the earth as well as the surrounding structures and/or

activities.

• Recommendation/ Remark/Observation: No breach of requirements; a best practice example or

proposal for improvement is given by the regulator, ISO, Branch or Customer auditor.

• Recruitment Agency: an agency assigned with searching and screening suitable candidates for the

vacancy and presenting them to the company.

• References: a contact person from a previous employer of the candidate.

• Rescue Team – a group of people who are trained to carry out rescue of a person or persons working in

a Confined Space. As a minimum, the Rescue Team must be comprised of a Standby Person (number

1)- wearing appropriate to the situation PPE and an independent breathing air source to enter the

Confined Space and perform a rescue during an emergency and a second Standby Person (number 2)

with appropriate to the situation PPE and immediate access to an independent breathing air source.

Number 2 will be responsible for coordination and communication during the rescue process. It is

acceptable for the Team Members to rotate roles during any one shift but provision must be made to

ensure that persons wearing independent breathing air equipment receive sufficient rest in accordance

with local regulations. Rescue Team member must be competent to fulfill the tasks associated with the

roles in accordance with the Competent Person definition.

• Responsible means doing the right/ethical thing to ensure that any negative impact to People, Planet

and Profit are minimized and the positive impacts maximized.

• Responsible Entertainment - is fully documented and transparent and in keeping with the Anti-

Corruption Policy and the Code of Ethics and Business Conduct and Whistleblower Policy

• Responsible Travel – this is travel that has been risk assessed and preferably planned in advance to

ensure that harm to people, planet and profit is kept to a minimum.

• Replacement-in-kind (RIK) – Any item that satisfies the (design) specification of the item it is replacing

and does not result in a Change. Where no specification exists e.g. for non-physical Changes such as to

procedures, personnel, organizational structures etc. the Reviewer must consider the design and/or

functional requirements of the existing item and decide if the proposal is a RIK or a Change.

• Restricted Work Case (RWC): This is an OSHA Recordable injury or illness that results in an employee

having to carry out restricted duties for more than one day (the day of the Incident should not be

counted). The employee either must perform a different function, is not able to perform all the tasks

associated with their usual job or must work reduced hours.

• Reward bonus: The Reward Bonus will be given to an employee and/or team who propose an idea that

meets the Minimum Criteria of the policy (section 5.3) and the Additional Criteria (section 6.2). This

reward may be awarded a maximum of one time in any 12-month period to any individual. The Reward


DEFINITIONS

Bonus is € 1.000 net value (or $ 1,000 net value) for an individual who submits an idea or € 2.000 net

value (or $ 2,000 net value) for a team of two who submit an idea (to be divided equally between both

individuals) or € 3.000 net value (or $ 3,000 net value) for a team of 3 or more who propose an idea (to

be divided equally between the team members)

• RI&E (Risk Assessment and Evaluation) is a type of Risk Assessment primarily focusing on occupational

health and safety Risks.

• Rigger –this is a Competent Person who must be present in the field to carry out assembly and

disassembly of the load.

• Risk - the effect of uncertainty upon objectives (threat or opportunity)

• Risk Analysis – the process to comprehend the nature of risk and to determine the level of Risk (this

provides the basis for Risk Evaluation and decisions about Risk Treatment).

• Risk Appetite – the amount and type of Risk that an organization is prepared to pursue, retain or take.

• Risk Assessment - overall process of Risk Identification, Risk Analysis, Risk Evaluation and Risk

Treatment.

• Risk Evaluation – process of comparing the results of Risk Analysis with risk criteria to determine

whether the Risk and or its magnitude is acceptable or tolerable (prioritization).

• Risk Identification - the process of finding, recognizing and describing Risks.

• Risk Management - coordinated activities to direct and control an organization with regard to risk (i.e.

identifying appropriate responses to Risk such that exposure is reduced to an optimum level).

• Risk Management Framework - is the organization and process that is established such that the Risks

can be identified, analyzed, evaluated and treated as required by the Corporate Risk Management

Policy.

• Risk Owner - person or entity with the accountability and authority to manage the Risk.

• Risk Register: a document that identifies risks along with their severity and the actions and steps to be

taken to mitigate the Risk.

• Risk Reporting: - is the process of reporting all key Stakeholders of the contents of the Risk Register(s)

at regular intervals

• Risk Treatment – process to modify the Risk (risk mitigation measure).

• Risk Updates – this is the process of updating the Risk Registers in the light of developments and/or at

pre-defined moments.

• Root cause: The most basic cause (or causes) that can reasonably be identified that management has

control to fix and, when fixed, will prevent (or significantly reduce the Likelihood of) the problem’s

recurrence.

• Root Cause Analysis (RCA): is a method that allows identification of the Direct Cause, Root Cause(s)

and other Causal Factors of Incidents.

• Routine Lift – are characterized by: simple operations with one crane/Lifting appliance, Lifting over

non-sensitive areas and in suitable familiar environmental conditions. Loads of known and evaluated

weight, shape and center of gravity. Basic rigging arrangements. Simple logistics activities with forklift

trucks fall under this category.

• Sabotage: The act of destroying or disabling something deliberately so that it does not work properly.

• Scaffold is a temporary or movable platform structure for holding workers and materials during the

construction, repair, alteration, or decoration of a fixed structure such as a building, pipe rack, storage


DEFINITIONS

tank, tower, or any other elevated work structure requiring access to the worker. There are two types

of scaffold:

• Supported Scaffold - Work Platform supported by rigid, load-bearing members such as poles,

legs, frames, outriggers, and braces and are typically constructed from ground level to the

height needed to achieve safe work access.

• Suspended Scaffolds – Work Platform suspended by ropes or cables from a secured overhead

support.

• Scaffolding Inspector: A Competent Person qualified to determine Scaffold compliance in accordance

with local legislation

• Screening Committee: a committee assembled with a number of LBC staff members to screen

candidates, provide advice and take decisions in the recruitment process.

• SDS – Safety Data Sheet.

• Secondary Containment: equipment used on an LBC Facility as a second line of defense for preventing,

controlling or mitigating Major Hazard Events. For example: bunds, drip trays, off-gas treatment

systems, interceptors/sumps, expansion vessels, double skinned tanks/vessels, concentric pipes.

• Semi-automatic cleaning refers to cleaning during which the Jetting Equipment is operated manually

by the High-Pressure Water Jetter. The High-Pressure Water Jetter is sufficiently protected from the

High-Pressure water jet coming out of the equipment. The High-Pressure Water Jetting System is

pressurized by the High-Pressure Water Jetter by means of a switch on the Jetting Equipment. The

High-Pressure Water Jetter must have a clear view of the working area. The Emergency Stop Button is

operated by an Emergency Stop Operator.

• Service Supplier a service supplier is a supplier of goods or services that does not fall into the Category

1, or 2 Contractor definition. Typically, the Service Supplier will deliver goods to the LBC Facility but will

not conduct any on-site work or they will deliver services that do not involve any on-site work.

• Severity Impact Matrix: LBC matrix used for determining the Actual Severity and Potential Severity of

Incidents

• Severity Level (or Level): the consequences (actual or potential) of an Incident as identified in the

Severity Impact Matrix.

• Sign-off – this is the process whereby the Permit to Work Issuer, Work Permit Holder and the Job

Executers sign the Permit to Work at the end of each completed shift. This is also the process whereby

the Permit to work Issuer, Work Permit Holder and Job Executers formally hand back the installation

(commissioning) to operations when the job is completed and all parties sign-off the Permit to Work.

• Signal Person –is a person whose task is to act as the interface when the operator of the Lifting

equipment has a restricted view due to any reason. The hand signals to be used by the Signal Person

are to be agreed upon between the Operator of the Equipment and another parties involved in the lift

prior to work beginning.

• SMART Action – this is an action designed to bring about an improvement. The action is specific,

measurable, attainable, reasonable and timely.

• Smuggling: Move (goods or people) illegally or without authorization into or out of a country or facility.

• Standard Operating Procedure (SOP) is defined as a step-by-step procedure or work instruction

relating to an operational activity on LBC facilities that can be considered repetitive in routine and

nature. The SOP is determined by Competent Persons.


DEFINITIONS

• Spotter - persons trained to direct vehicle movement on or around site. They should be clearly

distinguishable from other personnel on site.

• Stakeholders – Individual or Group who can affect or be affected by the decisions or activities of our

business and/or the impact of an Incident or crisis.

• Tag Line - is a line usually made of nylon or some other non-conductive material that is used by a rigger

to help him control a suspended load from swinging and allow him to stand at a safe distance

• Tag-out: This is the placement of a tag-out device (isolation device) on an Energy-Isolation Device to

indicate that the Energy-Isolation Device and the equipment being controlled may not be operated

until the tag-out device is removed.

• Tag-out device: Is a prominent warning device, such as a tag with a means of attachment, which can be

securely fastened to an Energy-Isolation Device in accordance with an established procedure, to

indicate that the Energy-Isolation Device and the item being controlled may not be operated until the

tag-out device is removed. The tag-out device is weather proof

• Tank cleaning head is a three-dimensional rotating cleaning head that can be used to clean Confined

Spaces

• Temporary Change – a Change that is expected to last less than 90 calendar days.

• Terrorist attack: Act of terrorism, terrorism, terrorist act. The calculated use of violence (or the threat

of violence) against civilians to attain goals that are political or religious or ideological in nature; this is

done through intimidation or coercion or instilling.

• Theft: An unlawful taking (as by embezzlement or burglary) of property

• Tier 1 Process Safety Event is an LOPC with the greatest consequence as defined by API RP 754.

• Tier 2 Process Safety Event is an LOPC with lesser consequence as defined by API RP 754.

• Top Surface Material/Earth – refers to either natural product’s such as but not limited to soil, rock,

clay, sand or man-made products such as but not limited to concrete, asphalt, tarmac.

• Trench - a narrow underground Excavation that is deeper than it is wide, and is no wider than 15 feet

(4.5 meters).

• Trespasser: A person entering the LBC Facility without permission.

• TRIFR: Total Recordable Injury Frequency Rate

• Ungrounded/unearthed relates to systems/equipment that have not been subject to Earthing.

• Unintended Product Transfer refers to any movement of Product to a destination that was not the

intended destination regardless of the consequences. For example, mixing of the same or of similar

Products, the mixing of different Products, transfer of a Product to an empty vessel that was not the

intended destination, spillage etc.

• Unique Tie Point Identifier: a uniquely numbered weatherproof tag or label applied to the line at the

location of the cut with high visibility weatherproof tape. The tape must be manufactured* with the

text “Line Cut” and be applied around the whole circumference of the line at the cut location. The

unique reference number must always be clearly noted on the permit and job instructions. The

identifier must be written in the agreed common language as well as local language where this differs.

• Unique Tie Point Identifier and Tape Applier: an LBC employee from the operations department

officially assigned, authorized and designated to apply the Unique Tie Point Identifier and tape. This

person must be competent to fulfill the tasks associated with this role in accordance with the



DEFINITIONS

• Unplanned Change – A Change that is a result of unforeseen occurrences.

• Unsafe Situation: Unsafe conditions that could result in an Incident (i.e. an Incident has not occurred:

energy was not released and no actual Consequence).

• Unusual Extended Shift – is a shift that may be extended for emergency or maintenance repair

situations and does not exceed 16 hours in a shift with a minimum resting period of 11 hours between

each shift

• Variance is a deviation from all or part of a Corporate Policy

• Working at Depth –for the purposes of this standard refers to any activity being carried out by an

employee or contractor inside an excavated area whereby the depth at any part of the Excavation area

is deeper than 120cm. Such areas are classified as Confined Space activities and fall under the Confined

Space Policy.

• Work Location - this is the location where the activities described in the Permit to Work will be carried

out.

• Work Permit Holder – this is the person who receives the Permit to Work from the Permit to Work

Issuer.

• Work platform –is any elevated area where work is carried out. Note, the work area above an

excavation site is also a Work Platform in the context of this policy. Note: this definition includes

temporary Work Platforms, such as: Scaffold and (Mobile) Elevating Work Platform.