TITLE: ENVIRONMENT, HEALTH & SAFETY PLAN Safety is the responsibility of everyone and more especially, top management

2015

Themba Zungu INKWALI FABRICATION & MAINTENANCE (PTY) LTD

Revision Number 03 Date 08 January 2014

Reference Number IFM – SHE – ISP-001

Document Title Inkwali SHE Plan

EH & S PLAN

ENVIRONMENTAL, HEALTH & SAFETY PLAN

This document was approved by:

__________________________ DATE:___________________

THEMBA ZUNGU (MD)

PREPARED BY: Mr M. NIKANE REVIEWED BY: T. ZUNGU

TABLE OF CONTENTS

1. Objective

2. Scope

3. EH & S Records

4. Non-Conformance Management

5. Auditing

6. References

7. EH & S - Scope of work

OBJECTIVE

The objective of this document is to define requirements needed to achieve proper implementation of Environmental, Health and Safety practice.

1. SCOPE

To ensure that the management has identified risks and has preventive measures in place as far as Environmental, Health and Safety standards and regulations are concerned.

2. EH & S RECORDS

The applicable EH & S company forms shall be used for communicating, reporting, investigation and recording of information related to Environmental, Health and Safety within the company and its operations. The company’s EH & S forms may not be limited to the use of client’s project specific EH & S documents which will be labelled as Project Specific whenever used.

3. NON- CONFORMANCE MANAGEMENT

Preventive and corrective action on failure or negligence of systems and procedures should be dealt through non-conformance management. Recording of non-conformance, root cause analysis and corrective action will be implemented by Management and will ensure continual improvement.

4. AUDITING

The objective of the Audit is to review systematically all parts of the EH & S system within the company and throughout its operations. The management shall implement an Auditing system on the Environmental, Health & Safety. The Audit schedule and reports shall be recorded and evidence of them made available at anytime to the client. Findings or recommendations results from such audit will be expressed in terms of corrective actions to be taken together with completion dates.

5. REFERENCES

6.1 Inkwali Environmental, Health & Safety Rules and Regulation; 6.2 Project Specific Environmental, Health & Safety Scope of Work; 6.3 Occupational Health Safety Act, 85 of 1993; 6.4 Compensation for Occupational Injuries and Diseases Act, 130 of 1993; and 6.5 National Environmental Management Act, 107 of 1998.

6. EH & S - SCOPE OF WORK

7.1 MODEL INDEX

7.1.1 EH & S Policy

7.1.2 Responsibilities and Authority

7.1.3 Applicable documents

7.1.4 Organisational Chart

7.1.5 Organisational business activities

7.1.6 Induction and training

7.1.7 EH & S Promotion and Awareness

7.1.8 EH & S meeting (incl. Toolbox talk)

7.1.9 Risk Assessment and Critical Tasks

7.1.10 Inspections and check list

7.1.11 Incidents and Accidents Reporting

7.1.12 EH & S Record, Reports & Regulations

7.1.13 Safety Practice Rules and Regulations

7.1.14 Emergencies and Alarms

7.1.15 Hazardous Materials & substances

7.1.16 Safety Representatives

7.1.17 Personal Protective Clothing

7.1.18 First Aid / medical Arrangement

7.1.19 Fire prevention and Fire Fighting

7.1.20 Transport and Access

7.1.21 Safe Work Procedure when Working in Confined spaces

7.1.22 Safe Work Procedure when Working at Heights

7.1.23 Safe Work Procedure when using a Grinder

7.1.24 Safe Work Procedure when using Welding Machine

7.1.25 Safe Work Procedure when using a Ladder

7.1.26 Housekeeping

7.1.27 Security Arrangement

7.1.28 Standard Forms

7.1 ENVIRONMENTAL HELATH & SAFETY POLICY

7.2 RESPONSIBILITY AND AUTHORITY

Company Directors

Responsibilities

Inkwali Fabrication and Maintenance (PTY) LTD Managing Director

Carries all the responsibility for Safety and Health of employees and Environment control both at

the company premises and on client sites where the company carries its activities including that

of its sub-contractors.

Ensures awareness training to all employees and taking proper care of the customer's property.

Ensures provision of personal protective equipment (PPE) to all the employees.

Delegates responsibilities to his subordinates through appointments and clear understanding of

responsibility, authority and communication.

Site Supervisor / Workshop Foreman

Responsibilities

The Site Supervisor / Safety Representative reports to the Managing Director on all issues related to the

safety, health and environmental pertaining to the company and its sub-contractors and he is

responsible for;

Ensuring that all company and sub-contractor operations are carried out in a safe and

environmentally controlled manner.

Ensures the safety plan is kept-up to date and reflects all site activities.

Reviews and approves sub-contractor safety, environmental and loss prevention programs.

Ensures that all company, government and client regulations are properly addressed and carried

out.

Arranges induction program stressing safety and environmental issues for all personnel on site

and organises regular safety meetings attended by company, sub-contractor representatives

and/or client.

Regularly inspects all company and sub-contractor activities and operations to ensure that these

are carried out in a safe and environmentally controlled manner.

Sees to it that all employees have proper understanding of environmental, Safety and Health

regulations and standards and also comply with the requirements.

Supervises all operations aspects of field construction within his designated area and to his level

of competency which include but not limited to the following:-

Ensures that employees are informed about risk in respect of tasks carried by individuals or

teams.

Ensure the working area is safe before resuming work and at the end of the activities.

Carry out daily safety task identification (DSTI).

Carry out proper planning of the works to minimize risk and identify hazards.

Communicates Safety, Health and Environmental awareness at all times to his team.

Identify risks and hazards for all activities before they commence any task.

Report all incidents and accidents that occur on site and assist the Safety Officer during

incidents/accidents investigations.

Motivate employees in promoting safe working environment and practices.

7.3 APPLICABLE DOCUMENTS

This document has been drawn in line with the local and international standards pertaining to Safety, Health

and Environment. The referenced standards used in this document are but not limited to the following:-

ISO 14001: Environmental Standard

OHSAS 18001: Safety and Health Standard

Machinery Act

Mine and Mineral Act

Inkwali Fabrication & Maintenance (Pty) Ltd COMPLIANCE WITH OCCUPATIONAL HEALTH & SAFETY ACT OF 1993

HEALTH AND SAFETY REPRESENTATIVE (OHS – APPOINTEE)

In terms of Section 17 (1) of the Health & Safety Act of 1993, Themba Zungu, who is ultimately responsible for

Health & Safety in all Inkwali Fabrication & Maintenance activities (Pty) Ltd hereby designate Mr.

Mzikayise Nikane as a Health and Safety Representative in respect of all work done for and on behalf of Inkwali Fabrication & Maintenance (Pty) Ltd at Western Platinum Refinery.

FUNCTIONS OF OHS –APPOINTEE “HEALTH & SAFETY REPRESENTATIVE”

To ensure the safety of Personnel and Persons at and in the vicinity where work is being performed. Submit inspection checklist to the Managing Director once a month.

Meeting to be held quarterly in February, May, August and November annually.

Managing Director Accepted By:

T. Zungu Name: ……………………….

Signature …………………………………. Signature……………………..

Date …………………………………… Date ……………………...

7.4 ORGANIZATIONAL CHART

Inkwali Fabrication & Maintenance EH&S Organogram Rev. 3

THEMBA ZUNGU

MANAGING DIRECTOR

C

T. GOVERE

BOILERMAKER

K. NTULI

CODED WELDER

E. MBIZA

DRIVER

H. DUBE

CODED WELDER

MZIKAYISE NIKANE WORKSHOP FOREMAN/ HSE REPRESENTATIVE

C

S. NYEMBE

BOILERMAKER

N. MAGWAZA

WELDER

X. NXUMALO

CODED WELDER

N. NKOSI

CODED WELDER

S. MAAKE

CLEANER

7.5 ORGANISATIONAL BUSINESS ACTIVITIES

Inkwali undertakes the operations of structural steel, plate work and piping fabrication and erection

including mechanical installations as well as plant maintenance.

These activities are carried at the company premises (workshop) and on customer site.

7.6 INDUCTION AND TRAINING

7.6.1 Inkwali carries its own induction training on newly recruited employees to familiarise them with the

company operations, policies, health & safety as well as ethics codes, refer to Doc. IFM/SHE-STI 001

Rev. 1.

7.6.2 Every year all employees will undergo induction training as a refresher course to ensure that they

adhere to the company policies, safe work procedures as well as client’s safety requirements.

7.6.3 All staff that work at PMR Plant will be inducted according to Lonmin’s site specific induction training.

7.6.4 The company also ensures that employees receive training in operating equipments and machinery

and further more ensures awareness training as far as HIV/AIDS is concern ( see Inkwali HIV/AIDS

pledge)

7.7 EH & S PROMOTION AND AWARENESS

Inkwali Fabrication and Maintenance (PTY) Ltd invests in skill development through promotion and

awareness training as required in different disciplines where the company operates.

Part of the awareness training given is the employee HIV / AIDS awareness and employee support

programs that the company set up either internal or through third party institutions.

7.8 EH&S MEETING AND TOOLBOX TALK

7.8.1 EH & S MEETINGS

Inkwali has EH&S committee that has representatives from the employees and management. The main

purpose of these EH&S meetings is to improve the EH&S communication, participation and involvement to

identify key problematic areas and to ensure continual improvement on our Safety and Health procedures.

TOOLBOX TALK

Projects are our core business and most construction fatalities and accidents happen on projects due to the

time frame and pressure set on companies to complete projects on time. Inkwali affirms the need to place

more value on human lives and health before production and has adopted the use of toolbox talk prior to

any daily activities either at Inkwali premises or client’s construction site.

Reminding employees of the importance of going home alive every day and to ensure better understanding

of all safety measures that they need to practise in order to safeguard themselves and their colleague’s

safety. Our goal is to make safety their way of life not only at the work place but at home as well. During

toolbox talk sessions a safety topic is discussed and all present are required to sign an attendance register.

The toolbox talks which run for a period of thirty (20) minutes are presented by Site Supervisor before the

start of each daily activity. Different hazards and risks related to not only the work they do but also the

surrounding area where they work are discussed including safety procedures and controls to be used to

eliminate or reduce safety risks. Environmental risks and hazards are also discussed at these meetings.

Refer to Inkwali Toolbox Talk Form-Doc: IFM-EHS-TBT 001

7.9 RISK ASSESMENT AND CRITICAL TASK

Every job activity comes with health and safety risks. This necessitate the need to identify all risks and

hazards associated with each work activity. This is accomplished by first listing all the risks and hazards

related to each activity, their impact (i.e. low, medium or high), root causes and implementation of controls

to either avoid their impact or total elimination of such risks. Inkwali risk mitigation procedures starts with

implementation of risk controls and thereafter use of PPE in that order. The company has developed

baseline risk assessment which associated with all the activities that Inkwali performs such as welding,

grinding, etc.

Inkwali employs the Work Breakdown Structure (WBS) approach as part of job planning, whereby the Site

Supervisor is able to plan what needs to be done, how is going to be done, what tools are needed to

do the work, what could go wrong and what shall be done if things go wrong.

Once the WBS is completed each activity is evaluated on the basis of its risk profile. The risk matrix is

developed and controls are applied to eliminate or reduce risks. Refer to Inkwali Risk Assessment form-

Doc: IFM-EHS-RISK 001

7.10 INSPECTIONS AND CHECKLISTS

Inkwali Fabrication and Maintenance developed check lists and inspection sheets for the works as per

statutory regulations and acts to ensure proper maintenance of equipments and tools to prevent injuries

and stop accidents before they happen.

These checklists and inspections are done at predetermined intervals and have responsible persons

assigned to perform inspections. This ensures that the inspections are done by suitably qualified personnel.

Inkwali maintains compliance certification, e.g., load tests certificates, tags, etc., including calibration

certificates of certain equipment.

Such equipments include but not limited to:

Lifting Equipments:

-Shackles, slings and lifting cables

-Electrical Tools

-Power tools

-Electrical cables

-Fire Equipment

-Fire Extinguishers

-Cutting Torch and Accessories

Refer to Inkwali inspection and checklist file for applicable checklists and inspection forms.

7.11 INCIDENTS AND ACCIDENTS REPORTING

All incidents and accidents shall be reported immediately to the supervisor. The evidence will not be

removed until the Site Supervisor and / or PMR representative has recorded all necessary information

either being oral or photographic. An incident or accident report is compiled in the acceptable format for

submission to PMR Management and updating of company safety records.

7.12 EH&S RECORDS, REPORTS AND REGULATIONS

Inkwali Fabrication and Maintenance control their documentations, reports and records as required by the

ISO 9001: 2008 Quality standard system on control of records and documentation. This is done through the

organization’s document control procedure on Control of Documents and Records.

Documents are approved for adequacy prior to use.

Reviewed and updated as necessary and re-approved

Ensuring that changes and the current revisions status of documents are identified

Ensuring that documents remain legible and readily identified

Define the controls needed to identification, storage, protection, retrieval, retention, and disposition

of records

7.13 SAFETY PRACTICE RULES AND REGULATIONS

Inkwali Fabrication and Maintenance abide by construction regulations 8. (1) 0f the Occupational Health

Safety Act, 85 of 1993 as well as client’s site specific safety requirements. The company has written and

adequately communicated safe work procedures which ensures safety in all our operations. Refer to

Inkwali Site Safety File under Safe Work Procedures.

7.14 EMERGENCIES AND ALARMS

Employees have been trained on emergency procedures and action required when the situation arise that

may endanger health, life, environment and facilities. Education includes awareness with regards to

different alarm signals, their meaning as well as identification of assembly points throughout the PMR plant

in the case of emergency.

There will be availability of the following at the offices and notice boards on sites:

Emergency telephone number(s)

Course of action to be taken

Alarms

Evacuation and assembly

Reporting emergency situation

7.15 HAZARDOUS MATERIAL AND SUBSTANCES

All hazardous material and substances are kept in an identifiable and locked storage with the MSDS

sheets. This materials storage will also have safety sign placards to make people aware of the danger

associated with the materials and substances.

Disposal of hazardous material and substance will also be done in such a way that all hazardous waste and

substances is not mixed with general waste and the disposal bins are legibly identifiable in line with PMR

procedures.

7.16 SITE SAFETY REPRESENTATIVE

Inkwali Workshop Foreman also carries Site Safety responsibility as per construction regulations 8. (1) of

the Occupational Health Safety Act, 85 of 1993 requirements.

7.17 PERSONAL PROTECTIVE EQUIPMENT

The company ensures that every employee has the correct P.P.E for the job that he/she undertakes. The

Site Supervisor regularly checks the condition of the PPE on all employees and issue new one for

individuals that need their PPE replaced. Each PPE issue is recorded on employee’s PPE issue register.

Employees are also trained on proper use and care of PPE in their possession. Care, use and handling of

PPE includes training employees about hygiene matters which are very important in preventing

communicable diseases such as TB.

7.18 FIRST AID/MEDICAL ARRANGEMENTS

The company ensures the availability of a qualified First Aider and employees ate trained on procedures to

follow in the case of an injury in line with PMR requirements. First Aid Box location is clearly marked and

identifiable. The contents of the first aid box are a responsibility of PMR personnel who ensures that

minimum medical equipment and tools are always available.

7.19 FIRE PREVENTION AND FIRE FIGHTING

Inkwali employees are trained on fire prevention and fire fighting. PMR through safety topics issues which

are communicated to Inkwali employees also assist in raising awareness with regards to fire prevention and

fighting. The telephone numbers for Fire Department are also displayed on notice boards and employees

are kept aware of their location in case of emergency.

7.20 TRANSPORT AND ACCESS

The use of company transport by unauthorised personnel is treated under the company HR policies and

those individuals who might be found transgressing these policies will be charged according to the

company HR procedures.

The company will identify access to sites, confined space and other accesses including emergency exit and

will communicate these to all employees.

7.21 SAFE WORK PROCEDURE WHEN WORKING IN CONFINED SPACES

Inkwali has an established procedure on working in confined spaces which provides for risk assessment

and has been written in line with the applicable standards and regulations for working in confined spaces.

This procedure has details all risk control measures that are required when working in confined spaces and

was communicated to all employees on site who were subsequently made to sign the attendance register.

Refer to Inkwali SWP - working in confined space procedure- IFM-SHE-CS-001

7.22 SAFE WORK PROCEDURE WHEN WORKING AT HEIGHTS

Inkwali has a procedure on working at heights which provides for risk assessment as well as

implementation of risk controls measures that need to be followed as well as correct PPE to be used in

such instances. In particular, this procedure makes reference to Inkwali’s fall protection plan document

which provides for all safety requirements and controls to be used when working at heights. Refer to

Inkwali SWP - working at heights procedure-Doc: IFM-SHE-WAH-001

7.23 SAFE WORK PROCEDURE WHEN USING A GRINDER

Grinders can be very dangerous if not used properly mainly due to the speed at which the grinding disc

spins. Therefore extra care should be exercised at all times when using grinders. As such, only trained and

competent employees are allowed to use grinders. Moreover, Inkwali has a documented procedure that

needs to be followed which was also communicated to all employees who are trained to use grinders. Refer

to Inkwali SWP - using a grinder procedure – Doc: IFM-SHE-GR-001

7.24 SAFE WORK PROCEDURE WHEN USING WELDING MACHINE

Most of the tasks that Inkwali personnel do at PMR is welding of pipe and steel structures. The company

has a detailed safe work procedure that must be followed when using a welding machine. Welding safe

work procedure was communicated to all the employees who are trained to perform welding tasks. Refer to

Inkwali SWP - using a welding machine procedure – Doc: IFM-SHE-WM-001.

7.25 SAFE WORK PROCEDURE WHEN USING A LADDER

Inkwali regularly performs tasks at elevated platforms which in some instances require the use of ladders

for access to the work site. Inkwali follows provisions stipulated in the company’s fall protection plan for all

work done at elevated platforms. All Inkwali employees are trained on the company’s safe work procedure

when using ladders. Please refer to Inkwali SWP – Using a ladder – Doc: IFM-SHE-LD-001.

7.26 HOUSEKEEPING

Clean working area eliminates hazards and increase productivity. As part of the Inkwali EH&S awareness

the company ensures employees keep working areas and environment clean at all times. Walkways and /

or passages are kept clear at all times to allow easy movement and trip hazards are removed as far as

possible.

7.27 SECURITY ARRANGEMENTS

PMR plant is a high security zone due to the products being handled in the plant. Inkwali employees are

made aware of the security requirements as directed by PMR and provides its employees with all the tools

necessary to ensure compliance to security requirements. Employees are encouraged to report any

damage or theft they witness to PMR security personnel immediately.

7.28 STANDARD FORMS

Refer to Inkwali EH&S standard form file.