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PROTOCOL OF HSE REVIEW FOR NEW PROJECTS Page 1 of 6 Developed by: FH Reviewed By: SSJR Approved By: RAF Revision No: 00 Date Approved: 3 May 2013 Revision due: 3 May 2016 Department: HSE Unit / Section: Safety Area: XXX PROTOCOL OF HSE REVIEW FOR NEW PROJECTS Prepared by: ______________________ (FH) Safety Engineer Reviewed by: ______________________ (SSJR) HSE Advisor Approved by: ______________________ (RAF) Corp.HSE Manager Date of Approval: ______________________ Change Record: Sr. No. Date Rev No. Page No. Section Change Description 1

Protocol of HSE Review for New Projects Level 1

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ENGRO POLYMER & CHEMICALS LIMITED

PROTOCOL OF HSE REVIEW FOR NEW PROJECTSPage 1 of 4Developed by: FH

Reviewed By: SSJRApproved By: RAFRevision No: 00Date Approved: 3 May 2013

Revision due: 3 May 2016

Department: HSEUnit / Section: SafetyArea: XXX

PROTOCOL OF HSE REVIEW FOR NEW PROJECTSPrepared by:

______________________

(FH)

Safety Engineer

Reviewed by:

______________________

(SSJR)

HSE AdvisorApproved by:

______________________

(RAF)

Corp.HSE Manager

Date of Approval:

______________________

Change Record:

Sr. No.DateRev No.PageNo.SectionChange Description

Distribution:As per distribution list given in Document and Data Controller Page of Site HSE Manual.1.PhilosophySome of the HSE aspects are getting missed in Due Diligence & New Projects. Engros endeavor to become world class would require that HSE aspects are given as much importance as other aspects when embarking on new projects or acquisitions.

2.Responsibility:CCHSE to steward the compliance of HSE review protocol & update EXCOM.

3.Sequence of HSE reviewNew Project:1 Concept Stage2 DBM Stage

3 AR stage

4 Contract Award5 Construction Safety3.1CONCEPT STAGE:Review of inherent HSE issues with the Materials & Products (Ref EPA listing for toxic chemicals) which are involved in any new project, identify regulatory requirements, Conduct Facility Siting, Conduct Environmental Study (EIA or IEE) and Conduct Qualitative Consequence analysis3.2DBM STAGE:Ensure Inherent HSE is built into the design by HSE checklist, Inherent safety issues & Human Factors analysis (DuPont standards), Pre-Authorization PHA, HSE organization requirement and Assessment of Environmental Impact Report3.3AR STAGE:Ensure HSE items have been incorporated into the project cost covering PHA Recommendations and IEE/EIA Requirements. 3.4CONTRACT AWARD:Company ensures to fulfill following HSE requirements at the time of contract award; Pre-qualification of contractor to have due weightage of safety records, Competency in HSE field and all HSE requirements & accountabilities are specified in the bid document.3.5CONSTRUCTION SAFETY:Company to ensure to develop construction safety program including Allocate HSE Resources, Develop HSE Procedures / Manual (covering Safety, environment & Occupational health), Formation of Contractor HSE Organization, Adequate Training on behavioral safety, Interim Review @ 30 %, 60% & 90% of project completion.Pre-Commissioning

Company to ensure PSSR of all systems, Emergency Preparedness Protocol / Squad, HSE training of Operations Team (Skill Certification /board reviews), Butt Listing, Work Permit Protocols, Pre start up safety review, Installation of firefighting equipment are completed.CommissioningCompany to ensure to conduct HSE Audits (Pre startup HSE reviews)

Post CommissioningCompany to ensure Base Line PHA and Review of all HSE systems are completed.4.0DUE DILIGENCE:Company to ensure following precautions for Safety , Environment and OHIH of Inherent safety features assessment, Safety systems gap analysis, Record of process safety incidents, Status of NEQS compliance, Review of lenders requirements (if any), Preliminary environmental assessment of site, Environmental statutory gaps identification, Identification of CDM Projects, Any legal proceedings going on Environment, Number of notices/penalties due to environmental excursion, No environmental legacy, Materials hazards assessment, IH hazards protection gap analysis and Health assessment of manpower are taken in HSE review of any new projects,

Company to ensure resource adequacy and competency assessment, Cost of upgrade to ECPL / Regulatory /lender Standard, Equipment & Personnel upgrade, Estimate of the magnitude of potential significant liability, exposure and risk, HSE cost impact, Time line to meet regulatory requirements, Put in place HSE organization, Upgrade HSE systems to ECPL Standards and Full implementation of PSRM & PSM. 5.0HSE RESOURCE REQUIREMENT:HSE resource is mandatory on part time basis for new Project on Concept Stage, Feasibility Stage, AR Stage, Contract Award Stage, Bid Package and on full time basis on DBM Stage, Construction Stage, Commissioning Stage, Due Diligence & Post Acquisition. 6.0HSE REVIEW ATTACHEMENT:1. Indicative values for treated sanitary sewage discharges

2. WHO ambient air quality guidelines3. Small combustion facilities Emissions guidelines

4. Noise limits for various working environments

5. Noise level guidelines6. Minimum limits for workplace illumination intensity

7. Acceptable effective dose limits for workplace radiological hazards

8. General EHS Guidelines

9. Industrial sector guidelines

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