Indorama Eleme - FSA206265 - 16-20.07.12 - V1.0.pdf

8/20/2019 Indorama Eleme - FSA206265 - 16-20.07.12 - V1.0.pdf

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PRIVATE AND CONFIDENTIALFIVE STAR OH & S AUDIT

Indorama Eleme Petrochemical Limited

East West Express Way

P.M.B. 5151Port Harcourt

Rivers State

Nigeria

AUDIT BY: Bob WallaceDATE OF AUDIT: 16 – 20 July 2012REFERENCE NUMBER: FSA/206265

Version 1.0


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British Safety Council Five Star Health and Safety Audit Report

© British Safety Council 2011 1


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This audit was arranged by Mr U K Chatterjee and conducted on behalf of the British SafetyCouncil by Bob Wallace.

The auditor would like to take the opportunity to thank all management and staff for theirassistance, contribution and hospitality during the audit process.

The audit was conducted using the following process of objective evidence gathering:

The audit was conducted by reviewing key areas of the organisation’s health and safety

documentation and systems in relation to the requirements of the British Safety Council’s Five Star

Audit and was followed by an inspection of the site(s) and associated buildings.

The inspection process is used to determine the effectiveness of the implementation of the

organisation’s health and safety arrangements.

This subsequent report has been prepared to identify the strengths and areas for improvement

within the organisation's health and safety management systems and also to provide

recommendations, together with action planning, for consideration.

The audit process is intended to ensure all appropriate aspects of occupational health and safety

have been considered within an organisation’s safety management system(s) and how effectively

such arrangements are being implemented.

It is emphasised that the audit report will only comment on the conditions observed and

impressions formulated during the audit visit.


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DISCLAIMER

Every effort has been made to ensure that all statements and information offered in this report are

given in good faith and are related to matters seen during the audit together with informationsupplied by the organisation. The auditor assumes that the aforementioned information suppliedand representations made by the organisation during the audit, on which the report is based, wascurrent, valid, accurate and complete. The organisation must notify the British Safety Council ofany factual inaccuracies in the report or misinterpretation of information provided by theorganisation as reflected in the report.

The items commented on in this report are limited to areas reviewed during the audit process, andshould not be taken as identifying all areas of possible unsafe conditions and/or contravention ofstatutory requirements. Due to the dynamic nature of ongoing activity, the report may cease to beentirely accurate immediately after being provided to the organisation.

All relevant information contained in this report may need to be disclosed to the organisation’s

insurers. The contents of the report alone may not be sufficient for their requirements and furtherinformation may therefore be required by insurers. British Safety Council accept no responsibility tothe organisation or their (potential) insurers as a result of inaccuracies in the report arising forwhatever reason if the report is disclosed for the purposes of obtaining insurance.

BACKGROUND

Eleme Petrochemical Company Limited (EPCL) is jointly owned by the Indorama Group andNigerian National Petroleum Corporation, with Indorama holding 80% of the company andmanaging the day to day operation and future investment.

This year the company has made shares available to employees, who now own around 7.5% of thecompany.

The company employ expatriate Indian management, with the supervisors and employees beingdrawn from the local population. The total number of employees, including catering andadministration support staff is around 1100.

The company is growing annually through investment, with a new plant being commissioned in2012 and another planned later this year.

SCOPE

The scope of this audit has been agreed between Indorama Eleme and the British Safety Counciland includes the occupational health and safety management systems of the Port HarcourtPolymer site only, together with all premises and workplace activities under the direct control andmanagement of the organisation with the exception of the new plant and a small construction site.

It should be noted that the findings and subsequent recommendations made within this audit reportare applicable to the aforementioned areas and activities only.


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AUDIT SCORING

The five sections of the audit are divided into fifty seven (57) elements which attract a maximumnumerical value of 5000 points. Wherever an element of the audit is not applicable to theorganisation, it is withdrawn from the audit. The Maximum Accredited Audit Figure (MAAF) is themaximum total score available when non applicable questions have been removed and the Actual

Accredited Audit Figure (AAAF) is the score achieved against all applicable questions.

The Verification process in Section 6 allows the auditor to record:

Specific areas inspected

Personnel interviewed

Documentation reviewed

GRADING SYSTEM

The audit was conducted using the British Safety Council’s numerical safety grading system.The breakdown of the scoring, together with recommendations where the score falls below theMaximum Accredited Audit Figure (MAAF) is set out later in the report.

The audit grading is as follows:

MARKS % STAR RATING

92 – 100 : Excellent

85 – 91.9 : Very Good

75 – 84.9 : Good

60 – 74.9 : Satisfactory

50 – 59.9 : Basic

The Five Star Audit process focuses on five sections shown in table 1 below:

GRADING SYSTEM TABLE 1: THE FIVE AUDIT SECTIONS

SECTION AUDIT CRITERIAMAXIMUM

ACCREDITED AUDITFIGURE

1. Safety Organisation 1910 Points

2.Management ControlSystems

1570 Points

3. Emergency Control Systems 860 Points

4. Accident / Incident / NearMiss / Ill Health Reporting

System

250 Points

5. Workplace Implementation 410 Points

TOTAL:5000 POINTS


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ACTION PLANNING

The recommendations against the marked requirements of the Five Star Audit have beenpresented in tabulated colour coded format as per the key below:

GRADING SYSTEM TABLE 1: THE FIVE AUDIT SECTIONS

COLOUR CODE PRIORITY DEFINITION

HIGH:Differential over40% in this area

Recommendations tobe implemented as apriority 1 action

MEDIUM:Differential of 1 – 40% in this area

Recommendations tobe implemented as apriority 2 action

LOW:Full marks awarded

Monitor existingarrangements in thisarea to demonstratecontinuousimprovement

NOT APPLICABLE The requirements ofthis section are notapplicable to thisaudit

The red coded differential indicates where significant marks (over 40%) have been lost in respectof the five star audit scoring regime that has been developed to benchmark against current bestpractice technique in safety management. Wherever this has been identified by the auditor arecommendation has been provided that, if followed and implemented, would assist theorganisation in working toward best practice standards.

The amber coded differential indicates where marks have been lost (1-40%) in respect of the fivestar audit scoring regime that has been developed to benchmark against current best practicetechnique in safety management. Wherever this has been identified by the auditor arecommendation has been provided that, if followed and implemented, would assist theorganisation in working toward best practice standards.

The green coded area indicates wherever full marks have been awarded in respect of the five staraudit scoring regime that has been developed to benchmark against current best practicetechnique in safety management. The organisation must monitor these elements in order tomaintain best practice and demonstrate continuous improvement. The sectional tables are alsodesigned to allow the organisation to plan for implementation of the recommendations bypopulating the relevant columns as appropriate.

If any elements of the audit are not applicable to the audited organisation then this will be left blankwithin the relevant table and indicated as N/A.

As with any time bound audit, observations and recommendations made are applicable to thescope and depth of information reviewed during this audit, and as representative sampling has

been undertaken the recommendations only apply to the observations noted during this process.


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EXECUTIVE SUMMARY

The primary aim of this audit was to provide an external, independent assessment of theoccupational health and safety management arrangements developed by the client and theeffectiveness of their implementation.

This should provide a benchmark for the organisation so that an action plan(s) can be developed tofurther improve and develop these safety management systems.

The organisation has done exceptionally well to achieve this five star grading, which should beviewed as a realistic measure of where the organisation is at present so that a programme ofmonitoring and improvement can be implemented in the near future.

KEY AREAS MAY BE SUMMARISED AS FOLLOWS:

STRENGTHS:

A committed management team

Very high levels of maintenance within plant locations

Very good contractor management within plant locations

High levels of investment in plant, equipment and personnel

Excellent fire safety management across the plant areas

High standards of housekeeping

Well managed inspections department

Occupational health and employee family medical provision

Corporate social responsibility to local population

Change management to process plant

Forklift truck management

AREAS OF IMPROVEMENT:

Contractor management away from plant locations (civil, cleaning and transport)

Employee transport and contractor maintained vehicle management

Isolation procedures

Senior management recording of inspections

Management objectives


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FIVE STAR AUDIT RESULT

MAXIMUM ACCREDITED AUDITFIGURE (MAAF) : 5000

FIVE STARGRADING

Actual Accredited Audit Figure(AAAF): 4613

Percentage Achieved : 92.27%


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TABLE 2: ELEMENTS, MAAF AND AAAF FOR ALL 5 SECTIONS

SECTION 1 : SAFETY ORGANISATION(TOTAL MARKS 1910)

MAAF AAAF

1.1 Safety Policy 200 184

1.2Competent OH&S assistance and managementreporting

100 88

1.3 Management objectives and planning 180 157

1.4 Legal/regulatory compliance 40 40

1.5 Insurance 20 20

1.6Employee consultation, communication andinvolvement

100 93

1.7 Safety meetings 40 34

1.8 First aid facilities and training 90 90

1.9 Documentation and information control 70 70

1.10 Training 130 120

1.11 Occupational health programme 200 190

1.12 Safety inspections 100 88

1.13 Safety audits 100 94

1.14 Procurement 50 48

1.15 Management of change 100 92

1.16 Appointment and control of contractors 140 112

1.17 Risk management and safe working practices 250 221

TOTAL 1910 1741


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SECTION 2 : MANAGEMENT & CONTROL SYSTEMS(TOTAL MARKS 1570)

MAAF AAAF

2.1 Work equipment (including hand tools) 120 110

2.2 Permit to work systems 110 90

2.3 Safe isolation procedures and equipment controls 100 80

2.4 Access equipment 80 62

2.5 Working at height 100 83

2.6 Lifting equipment and operations 80 80

2.7 Pressure systems and portable gas containers 80 78

2.8 Mobile work equipment 90 88

2.9 Hazardous substance control 180 178

2.10 Radiation sources 80 80

2.11 Non ionising radiation 30 27

2.12 Portable electrical equipment 50 45

2.13 Electrical installations and protection systems 100 100

2.14 PPE assessment and controls 80 74

2.15 Respiratory protection 40 35

2.16 Management of noise 70 70

2.17 Vibration 60 55

2.18 Manual handling and Ergonomics 60 60

2.19 Workplace assessment and DSE 60 54

TOTAL 1570 1449


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SECTION 3 : EMERGENCY CONTROL SYSTEMS(TOTAL MARKS 860)

MAAF AAAF

3.1 Competency and co ordination 80 78

3.2 Fire risk assessment 120 120

3.3 Alarm systems 80 72

3.4 Fire fighting equipment 80 80

3.5 Emergency / escape route lighting 70 68

3.6 Evacuation, drill and instruction 80 80

3.7 Fire risk management and inspections 80 75

3.8 Fire escape routes and exits 120 112

3.9 Security 50 50

3.10 Emergency planning 100 100

TOTAL 860 835

SECTION 4 : ACCIDENT/INCIDENT/NEAR MISS/ILLHEALTH REPORTING(TOTAL MARKS 250)

MAAF AAAF

4.1 Reporting systems 20 15

4.2 Investigation procedures 130 121

4.3 Accident statistics and performance measurement 30 25

4.4 Recognising and managing potential loss areas 70 46

TOTAL 250 207

SECTION 5 : WORKPLACE IMPLEMENTATION(TOTAL MARKS 410)

MAAF AAAF

5.1 Buildings, floors, passageways and stairs 90 90

5.2 Ventilation, heating and lighting 30 30

5.3 Welfare and hygiene 50 42

5.4 Safety signs and notices 50 50

5.5 Traffic management 90 73

5.6 Stacking and storage 50 50

5.7 General housekeeping and waste management 50 46

TOTAL 410 381

TOTAL MAAF 5000 4613


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SECTION 1- SAFETY ORGANISATION

PERCENTAGE MARKS FOR SECTION 91.17%

1.1 SAFETY POLICY

The company has now integrated its management systems (IMS) following successful OHSAS 18001and ISO 9001 and 14001 audits in 2012.

The health, safety, environmental and quality policy statement of intent (SOI) is signed by the managingdirector (MD), Manish Mundra dated April 2011.

All management and many supervisory personnel have access to the company Intranet and the IMS isheld centrally.

The auditor requested several management appointments to demonstrate their knowledge of the IMSand each knew exactly where to access the relevant information.

Employees and contractors access the policies via notice boards, through induction, training andbriefings held on various occasions.

1.2 COMPETENT OH & S ASSISTANCE AND MANAGEMENT REPORTING

The company Head of Safety (HOS), Mr Pandey, reports directly to the Technical Director (TD) who isthe senior person on site and takes a direct role regarding safety management.

The HOS and Fire Chief are the two main safety professionals on the site and they take the lead whendetermining procedures and safety controls. Both have suitable Indian qualifications and significantindustry experience, as do the majority of management appointments, all of whom are degree qualifiedin their various fields.

The TD has placed additional pressures on all management through directives and E-mails and alsoregular management meetings to promote safety.

The auditor observed the monthly reports from January, March, April and June 2012 and each was verydetailed and comprehensive, allowing all management to understand the company performance andprogression.

The HOS presents to the Heads of Function /Department who attend the central safety committeemeetings and the auditor observed the presentations and minutes from 2011 and 2012. Policies andperformance is reviewed at these meetings also.

The management are appraised against the objectives set annually and the KPI’s allocated by the TD.The Head of HR confirmed all management have safety integrated into their annual appraisals and theauditor observed those from Olefins and Poly Propylene Plants.

The HOS, TD and senior management review the IMS and performance monthly and the policies andprocedures are supposedly reviewed annually, which makes the fact that the SOI has not been updatedin 2012.

The auditor was informed that each plant Head of Function (HOF) and Head of Department (HOD) arerequired to undertake regular inspections of their locations. The auditor observed many significant


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improvements across all locations which could not have been made without senior managementcommitment, but unfortunately these inspections are not recorded and so cannot be adequately verified.

1.3 SAFETY MANAGEMENT OBJECTIVES, PLANNING AND REVIEW

The auditor observed the company objectives which were set in December 2011 for 2012. Theseincluded the achievement of the British Safety Council 5 star rating, zero lost time injuries andaccreditation to OHSAS 18001 and ISO 9001/14001, along with near miss promotion, audits andvarious others numbering 25 in total.

The individual plants also have set targets and objectives to compliment the company objectives. Theauditor observed and reviewed those for Power Plant and Utility (PPU) and Offsite.

Although the objectives were laudable, they could not be considered SMART as there were no setfigur es to demonstrate attainment and some were simply “ongoing” (on the job training and briefings).

The various monthly meetings (central safety committee, HOD/HOF, safety ambassadors) all monitor

compliance with objectives and the internal audit process also assesses compliance.

The TD is the senior person with safety responsibility, but the auditor was informed by local employeesduring interviews that the HOF/HOD also promotes safety.

The auditor observed good evidence of suitable resources being made available, through newequipment, proposed purchases, training and interaction with contractors at meetings.

1.4 LEGAL/REGULATORY COMPLIANCE

The company are required to comply with Nigerian laws, the Factories Act and Mineral Oil (Safety)Regulations principally.

They also maintain compliance with the accredited management systems through inspections, auditsand HOS/Fire Chief’s interaction and training sessions.

The objectives for PPU included training for employees regarding the IMS and procedures, which is alsodesigned to promote compliance.

The auditor was informed that there are currently no investigations or pending prosecutions by theregulatory authorities.

1.5 INSURANCE

The company has the insurance required by Nigerian law and their brokers attend site annually toconduct liaison and inspection.

1.6 EMPLOYEE CONSULTATION, COMMUNICATION AND INVOLVEMENT

The auditor observed several means employed to facilitate employee consultation.

Each plant has a safety ambassador, who is the principle interface between management and staff andthese ambassadors are trained and in regular contact with the HOS.

Many plants conduct safety briefings prior to critical tasks (Polypropylene Plant – Offsite – Poly EthylenePlant) and the auditor observed briefing details and lists of Eleme and contractor employees that had

attended. Unfortunately this is not a standard routine across the site and in each plant.

All activities (less daily inspections and basic housekeeping tasks) within plant areas require a permitissued by the management within the control rooms and this is an opportunity to discuss the risks


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associated with the task. The auditor observed many permits during the audit and all were completedcorrectly (see 2.2).

The HOS has introduced contractor meetings and the auditor observed evidence where individualplants have also brought in briefings and consultation prior to activities (see 1.16).

The auditor was informed by the Head of HR, that a new online employee suggestion scheme waslaunched in July 2012, but has yet to receive anything so far. The auditor did observe suggestion boxesin locations, but was shown no evidence of their use.

The HOS issues a significant number of alerts, notices, reports and safety information; the auditorobserved examples of these documents on notice boards across the site.

Employee feedback regarding the interaction and culture within Indorama Eleme was positive with theexception of PPE, which is dealt with in section 2.

The company issue a quarterly magazine, which includes details regarding company improvements andperformance, along with corporate social responsibility but does not include any information regarding

health and safety.

An employee engagement survey was conducted in May 2012 and the auditor observed an E-maildated May 2012 from the managing director, referencing the survey before he sent the results toIndonesia Group Head Quarters.

1.7 SAFETY MEETINGS

The management and HOS attend the Central Safety Committee meetings and the auditor observed theminutes from September 2011 and February and June 2012. These minutes had actions allocated withtime frames where appropriate and focussed on the recommendations following the Five Star Audit of2011.

Safety ambassadors attend a meeting with the HOS which is supposed to be quarterly, but sometimesis allowed to slip. The auditor observed the minutes from April 2012.

Each department and plant holds a monthly meeting, which should be attended by HOD/HOF and othersenior plant management.

The auditor observed the minutes from 2012 for Poly Propylene and Poly Ethylene Plants. In both,there was poor compliance with HOF/HOD attendance and the minutes from each plant are differentaccording to what they determine should be discussed.

The auditor would question the quality and value of some safety committee meetings, as the agenda isconsistent and does not allow flexibility according to the site and plant performance. That for Poly

Propylene had exactly the same information repeated month after month. There is insufficient detailwithin much of the plant minutes and a lack of specific actions to promote improvements in the cultureand safety management process.

1.8 FIRST AID FACILITIES AND TRAINING

There are a number of first aid trained personnel across all plants and departments and these attendedtraining with the doctor on various occasions in 2012.

This training is detailed and includes off site safety, health and the use of the defibrillator.

The auditor was informed that the recommendations from last year’s audit have been acted upon with

annual training being run for first aid personnel.

The auditor was informed that all injuries are treated by the medical centre and first aid injuries havereduced in 2012.


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First aid equipment was observed as easily available in all locations and the equipment is checkedmonthly and replenished as and when required by medical centre staff. The auditor observed thedocuments showing equipment inspections from Olefins and Polyethylene Plants dated 2012.

The medical centre has three doctors and there is 24 hour access, with the auditor being informed that

all live within ten minutes of the site should an out of hours emergency occur.

The auditor was informed the medical centre ambulance would be dispatched to the plant or locationshould a serious incident occur.

1.9 DOCUMENTATION AND INFORMATION CONTROL

The Intranet is the control document and all policies and procedures are held on this medium andavailable for all staff with IT access.

Each plant and department holds a plethora of files and documents applicable to the various equipmentand activities. The auditor requested details of information being presented as evidence and on almost

every occasion the documentation was readily available.

1.10 TRAINING

Training is managed by plants, the safety and fire departments and management training by HR.

During the auditor’s interview with the Head of HR, it was explained that during each employee’sappraisal, they themselves identify the training they believe is required and who should facilitate thistraining. EPCL – TC – 4.201 is the current training needs analysis (TNA) document utilised.

The document is reviewed by the line manager following the employee completing their sections andthey then recommend the learning strategy.

The auditor was informed of a new video that has been produced and all personnel entering the plantwill be required to view this film.

All induction training is planned and managed by HR, with the HOS presenting and plant staff thenconducting specific technical training. The auditor observed the records from three sessions ofinduction training dated March, April and June 2012.

The HOS manages the refresher training programmes, which he undertakes by E-mailing plantmanagement to release personnel and this is then reported during the HOD/HOF and HOS meetingswhich are attended by the TD. The auditor observed many attendance sheets from 2012, which arelisted in section 6 of this report.

The auditor was informed the managing director also requested training to enhance his managementcompetence. The evidence of his attendance within an E-mail from Stanford University in the USA,dated July 2011 was observed by the auditor.

The auditor observed the presentation which is given by the Head of HR regarding the newly introducedMentoring Scheme which is designed to enhance the abilities of local employees. Another presentation,entitled IEXCELL (Indorama Excellence), dated May 2012 was observed by the auditor and the modularprogramme is designed to promote positive behaviours across all disciplines.

As already identified, the company has striven to enhance and improve contractor competence throughseminars (May and June 2012), plant training sessions (Offsite and Poly Propylene Plant) duringbriefings prior to activities and assessments of welding proficiency (Inspection Department – recordsfrom 2011 and 2012 observed).

The auditor observed a document entitled “Initiatives in Employee’s Training and Development” whichshows the number of and attendance at various training programmes in 2012. Health, safety,environmental and fire training has attained 816 man hours. It also demonstrates the planned trainingfor July to December 2012.


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The completed courses and numbers attending each was also observed fro 2012, which covered allaspects of training including many safety related courses.

1.11 OCCUPATIONAL HEALTH PROGRAMME

The auditor was informed by the company doctor, that all employees are medically assessed beforebeing allowed to start work.

This assessment covers a wide range of functions, including blood and urine. Plant operators alsoreceive annual medicals which replicate the original assessments to identify any changes. Theseannual assessments now include a questionnaire regarding vibration exposure (prior to employmentand current hand and finger conditions). The auditor observed examples from a forklift truck operatordated March 2012 and an engineer dated June 2012.

The auditor was informed that HIV blood checks are offered on a voluntary basis.

The medical centre promotes health for both employees and families, with dependants having the rightto access medical treatment on site for those living close enough or through an insurance policyallowing access at the family’s local hospital. Heart and cholesterol health is promoted also.

This insurance scheme is currently under review and another provider is being sourced as the currentprovider is not meeting the expected standard of service (see 1.14).

Airborne monitoring is conducted by fixed detectors and the results are reported within each monthlyreport produced by the HOS.

The doctor informed the auditor that alcohol breathalyser equipment has been procured and somerandom testing has been conducted but there have been no positive results have occurred.

A whole range of inoculations are offered, again to both staff and family. There is an active anti-malarialprogramme for long term employees and expatriate Indian staff. There is walk-in clinic availability for allstaff, where any health issues can be addressed.

All drivers and contract forklift operators have their eyesight tested annually and records from 2012were observed.

The auditor did not observe any evidence that management training to assist their identification ofoccupational health issues was continuing.

The auditor was informed that doctors manage all return to work following illness or injury; upon receiptof the employee’s doctors or hospital report, the ability of the employee to return to work is assessed atan interview with the doctor.

Assistance and if required, treatment can be offered on site with the retained physiotherapist oralterations made to the work patterns or location.

The auditor could not be shown any evidence as there have been no lost time injuries or illnessesrequiring management in 2012.

The quarterly magazine has details of a free eye clinic conducted for local populations in March 2012.

1.12 SAFETY INSPECTIONS

The auditor observed that plants operate a two stage inspection programme, consisting of visual

inspections (look, listen and feel) by plant operators and planned preventive maintenance programmesmanaged by plant engineers. Some plants have routine condition monitoring (vibration analysis)programmes also.


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The auditor observed the various records from these inspections within plant log books (Poly Propylene,Effluent Treatment and Poly Ethylene Plants) and maintenance records also from these plants datedJune and July 2012.

The HOS and Fire Chief undertake routine inspections of the plants, but these only record concerns and

do not follow a planned checklist. The auditor observed those for the HOS for Ollefins, Poly Propyleneand Offsite dated May and June 2012.

The safety ambassadors are required to regularly walk their locations and the auditor observed theinspection reports collated by the PPU ambassador for 2012.

During the inspection of the Effluent Treatment Plant, the auditor was informed that the Supervisor alsoundertakes a daily walk of the plant and reports only concerns and issues. The operators checklist isconducted monthly and the auditor observed a selection from 2012, which are then forwarded to thesafety ambassador.

I t was dur ing this inspect ion th at a near miss o ccurred wh en the Supervisor accompanied the

audi tor and the grated f loor ing over a tank w as insecure and he almost fel l through .

As already identified, HOF and HOD are expected to undertake inspections of their own departments,but these are not recorded.

The plant locations are well covered regarding the inspection process and conditions reflect the effortsof those conducting them. Away from plant areas though, the inspection process is less effective.

Other engineering inspections are reported in section 2 of this report.

1.13 SAFETY AUDITS

The company operate an internal safety management system audit process, which is based upon the

British Safety Council Five Star Audit and scores departments.

The auditor observed the reports from all plant, workshop and warehouse locations dated May and June2012.

The HOS conducts compliance audits for the permit systems and these results are recorded in themonthly reports and HOD/HOF presentations from 2012.

Bureau Veritas conducted the combined audit in May 2012.

As will be identified in element 1.16 and section 2, the value of these audits is high when auditing theplant locations, but less effective away from the plant.

1.14 PROCUREMENT

The auditor observed good evidence that safety is considered when new equipment is procured, withthe HOS monthly report showing discussion and assessment regarding the “Cherry Pickers” beingpurchased for engineering and security departments.

Changes to the plant or process, including introduction of new equipment requires the authorisation of anumber of management appointments, including the health, safety and environmental function (HSEF)manager (see 1.15).

The auditor interviewed the HOF Commercial and he explained and the auditor observed the processregarding the procurement of the bullet proof coach to transport ex-patriot personnel to and from the

airport in enhanced safety. The auditor observed several E-mail chains between the HOF Security whovisited Dubai to inspect the originally proposed vehicle and the preferred supplier dated June 2012.

The auditor also observed another E-mail chain dated June and July 2012 between the HOFCommercial and various medical insurance providers regarding the proposed change of supplier.


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The auditor observed no significant concerns regarding Indorama Eleme equipment identified throughthe site.

1.15 MANAGEMENT OF CHANGE

The company have a specific management of change procedure – HSEF 2-317 revision 2 datedNovember 2011, which is managed by Technical Services Department.

This procedure requires all management appointments, including HSEF to authorise the proposedamendments to the process within plant locations. The company has made an average of 60-70changes to the processes across the site since they took control in 2006.

Each process is managed through to completion and signed off following pre-start and post projectreviews, including pre-start safety reviews. The auditor selected some projects at random and observedtheir records – Conversion of the PRF Sphere 31TK2B NGL. This project was planned in February andMarch 2011 and pressure test reports produced following the work in March 2012 and a pre-start upsafety review was undertaken immediately after also in March 2012. This review also identified a

training need for staff.

The auditor observed an E-mail sent to all management by the TD, dated April 2012 informing them thatthe HOS would be reporting directly to him from then on.

Temporary change management within the plant areas is managed by the permit system and thisrequires a risk assessment if one does not already exist. Several permits and critical task safetybriefings were observed confirming this procedure – Poly Propylene Plant dated May 2012 and PolyEthylene Plant dated June 2012.

1.16 APPOINTMENT AND CONTROL OF CONTRACTORS

This is an element where the company manages their contractors both very well and very poorly.

The company has Contractor Selection and Management procedures and Annual ContractsManagement procedure – EPCL COM/PUR 26301 dated October 2011; an approved contractor list anda suppliers list of equipment including a quality rating of the materials is also held on the Intranet.

The selection procedures cover many aspects of the requirements, but do not include any pre-selectioncriteria regarding competence and safety performance.

Commercial manage the process and with the exception of current contractors, who are subject toevaluation by the user department before any contracts are renewed; there is no involvement of theend user or safety department until after the contractor has been selected. The assessment completedby user departments prior to renewal of contracts was observed by the auditor and the process is

scored, but not all had a requirement for assessment regarding safety compliance. Some followingwork in the Admin and PP Bagging locations dated April 2012 were scored.

The auditor was informed by Commercial management, that it is the responsibility of the userdepartment to ensure the contractor works safely. The auditor did observe a contract issued to GiosNigeria Ltd in July 2012, which included instructions that the first payment would only be made followinginduction and safety training by the safety department.

The auditor did observe evidence that a contractor bringing a mobile crane to site had his competenceand the inspection dates of the crane confirmed. Mech Construction – Ekens Amaobi certificate ofcompetence and Nitram Industrial Crane certificate, both from April 2012.

Due to the issues and concerns raised during the audit of 2011, there have been many improvements

regarding the quality of and management of contractors attending the plant and process areas,including the workshops.


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The HOS has facilitated seminars and meetings with regular contractors to promote their safetyawareness and improve competence and understanding of the Indorama Eleme standards andexpectations. The auditor observed the records from these meetings dated May and June 2012.

All equipment brought to site by contractors working in the plant, process locations and workshops is

now subject to inspection (electrical hand tools, welding competence, harnesses and lifting equipment).

Most plant management conduct pre-activity briefings where the risks and safety controls are discussed(PP Plant – PE Plant – Offsite) and contractor induction includes a high level of safety instructionincluding fire safety and emergency procedures. The auditor observed records dating back toDecember 2011 for safety induction.

It is the plant and process locations and workshops where the management of contractors is good.However, contractors employed away from the higher risk locations are not well managed.

During the audit, each day the auditor observed and identified concerns associated with contractorsworking unsafely. This included:

Cleaning contractors working with highly flammable paint thinners within the main office which hadbeen issued by their management to assist them in cleaning flooring under the stair well. This is areasonably confined area and they were being exposed to toxic and narcotic fumes, also introducingan explosive hazard into an occupied building.

A gardening contractor not wearing hearing or eye protection when operating a strimmer. Painting anddecorating contractors working on unauthorised scaffold, without the knowledge of the departmentmanagement.

Transport contractors using vehicles with unsafe tyres to transport Indorama Eleme employees to andfrom work.

Contract vehicles operating on site with unsafe tyres.

Construction workers working on improvised access equipment made of planks of wood, working onexposed edges where a fall from height risk existed and with poor quality welfare facilities. When theauditor checked for induction records, not all personnel were accounted for in this company(Marblehead).

All of these contracts are issued and managed by Civils Department and it is they that now need toapply the same standards as the rest of the company.

1.17 RISK ASSESSMENT AND SAFE WORKING PROCEDURES

The company has a quantitative risk assessment (RA) procedure and each department and plant holdtheir own file of assessments. The auditor observed the files from Offsite, which were all dated June2011.

Pre-activity safety toolbox talks were held by the management prior to permits being issued and thesecovered;

Scaffold erection from January 2012 - Insulation activity dated February 2012 and a Spray Paintingactivity dated June 2012.

During the inspection of the tanks in this location, the employees confirmed the presence of snakes inthe longer grass and they would be expected to access some valves occasionally during maintenanceactivities, which had no concrete access routes. None of the RAs for Offsite identified snakes as ahazard.

The RA for access to the overhead crane at PPU was observed which identified scaffolding would beerected for maintenance activities. When questioned further, the auditor was informed that personnel

gaining access for very short duration activities would actually wear a harness and lanyard.The plant locations have the permit system to identify and manage risk, but many also have CriticalTask working procedures, which include step by step procedures. The auditor observed that from PPPlant dated May 2012 to replace a cam clutch and this included photographs for future referral.


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Files from other locations were observed, most of which were adequate and concentrated upon genericphrases such as “work carefully”, “wear suitable PPE” or “obtain permit”.

If the company could improve its RA process to include more detail and produce detailed written safeworking procedures, these could then form the basis of future toolbox talks and briefings prior to

hazardous activities.

The auditor observed the recent behavioural safety initiatives and was informed that seniormanagement are expected to undertake one observation per month.

The auditor feels this is too low and management commitment should be demonstrated by increasingthe requirement.


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RECOMMENDATIONS TABLE – SECTION 1

SECTION 1 SAFETY ORGANISATION RECOMMENDATION PRIORITYPERSON

RESPONSIBLE

COMPLETION

DATE

1.1 SAFETY POLICY AND PROCEDURES Introduce a requirement for the SOI to be

updated annually

1.2 COMPETENT OH & S ASSISTANCE AND

MANAGEMENT REPORTING Non plant management require further

training to enable them to manage the

concerns identified within this report

Their annual appraisal process should

reflect their specific objectives as detailed in

element 1.3 below

1.3 SAFETY MANAGEMENT OBJECTIVES, PLANNING

AND REVIEW Management targets should be specific to

their department, consistent with the

company objectives and designed to

compliment these objectives

Targets should be SMART and be specific

to actions. E.g. – Ensure all risk

assessments are reviewed annually –

attend safety meetings quarterly

1.4 LEGAL / REGULATORY COMPLIANCE

1.5 INSURANCE

1.6 EMPLOYEE CONSULTATION, COMMUNICATION

AND INVOLVEMENT Ensure all departments follow the best

practice of critical task briefings for all

personnel prior to the activity and other

consultation procedures (including

contractors)

1.7 SAFETY MEETINGS All departments should follow the same

procedure regarding set agendas


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and other issues identified during audits etc,

to formulate checklists for all locations /

departments / activities / equipment etc

Conduct regular training for all personnel

required to inspect the workplace

1.13 SAFETY AUDITS Ensure all locations are audited in detail

annually

Introduce a quarterly audit programme for

higher risk activities and management

procedures (permits, confined spaces,

isolation etc)

1.14 PROCUREMENT Introduce a formal authorisation procedure

for all new equipment prior to purchase

1.15 MANAGEMENT OF CHANGE Ensure the management of change away

from plant and workshop locations is

applied as stringently

1.16 APPOINTMENT AND CONTROL OF CONTRACTORS Introduce a requirement for the competence

of contractor personnel to be verified before

they are selected

Introduce the requirement for all contractor

induction to be recorded on excel

spreadsheets for ease of compliance audit

Consider requiring all inducted contractors

to wear a badge / sticker on helmets to

make identification and verification easier

Apply the same determination to the

management of non plant / workshop /

process location contractors as those

employed in these locations


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Consider requiring unannounced inspection

and monitoring of Civils contractors

1.17 RISK ASSESSMENT AND SAFE WORKING

PROCEDURES Make safety control information specific and

remove generic phrases – e.g. wear

suitable PPE, this should be specific (wear

eye protection – acid proof overalls etc)

Produce detailed safe working procedures

for all higher hazard activities. Their

briefing and explanation should then be a

requirement prior to the permit being issued

The behavioural safety observation

requirements should be increased for senior

management – four per month would not be

unreasonable

Lower level management should be

expected to conduct daily observations of

activities

All departments should be following the

same procedures regarding pre-activity and

permit issuing safety briefings


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SECTION 2 - MANAGEMENT CONTROL SYSTEMS


2.1 WORK EQUIPMENT

The company have workshops attached to each plant and a centralised workshop.

The auditor visited and inspected the main workshop, PP – PE and Olefins workshops and observedtremendous improvements from 2011.

All electrical hand tools are now inspected by the main workshop personnel and this includes allcontractor tools. The auditor observed records held in the central workshop, with four books holdingthe registers of equipment and dates inspected.

During inspections of containers which are utilised by contractors to store equipment, the auditoridentified that all equipment was tagged.

There were some chain saws held by Indorama Eleme engineers that were operated by a triggermechanism and this stops the equipment when released. There were some concerns for the auditorregarding the PPE used. Kevlar thigh and shin guards should be within the legs of the trousers as aminimum to protect the operator.

Machinery within all workshops were observed as being suitably protected, although there was apedestal drill in PE workshop without a “mushroom” type emergency stop fitted, had no guard fittedand the engineer admitted he wore cloth gloves when operating the drill.

All of the above now needs to be addressed and all drills across the site reviewed for compliance andall engineers informed to stop wearing cloth gloves when operating rotating machinery.

Inspection and Instrumentation departments are responsible for ensuring specific equipment iscalibrated and the auditor observed several records from 2011 and 2012.

Unfortunately this very good system does not extend to contractors working for Civils departments asthe auditor observed construction equipment with very poor quality guarding and electricalconnections.

2.2 PERMIT TO WORK SYSTEMS

All maintenance activities within the plant require the control room management to issue a permit toauthorise the task. The auditor observed the records within each plant inspected and in all situationsthey were found to be issued according to the procedures.

The HOS undertakes permit audits and the auditor observed records from December 2011 andJanuary, February, April and May 2012.

All personnel understand the systems, which include contractor activities and personnel and theauditor observed records of training held by the HOS and within plants (PP – PE – PPU) dated 2012.

The only concern identified by the auditor is that authorising personnel do not always confirm all safetycontrols are in place before the permit is issued and one observed at PPU, was issued at 0815 andwhen the auditor attempted to view the activity, it had yet to begin at 1030. This is an efficiency issue

primarily for the plant management, but also identifies some failings of management to adequatelymonitor strict compliance with risk control measures.


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2.3 SAFE ISOLATION PROCEDURES AND EQUIPMENT CONTROLS

The company has improved the system since 2011, with the procedures now requiring all disciplinesworking on equipment to have their supervisor place a padlock onto the lock-out.

All isolations are recorded on permits and log books and the plants hold equipment within theirworkshops.

The auditor interviewed several engineers from the plants visited and observed several permits andtasks which were compliant with this procedure.

During the visit to PPU, an activity was being conducted by a small group of electricians and thepermit (11298) had been issued at 0815. This activity involved isolation of a lighting circuit.

The auditor then discussed the isolation procedures and was informed the new procedures only applyto higher voltage and electrical motors / equipment. This activity required the electricians to simplyopen the panel, open the circuit breaker, place a tag and close the panel, which is then left insecure.

Although improvement shave been made and the auditor would congratulate the company on theirefforts, there is still a lack of understanding regarding best practice.

All personnel undertaking a task which requires equipment and energy isolation are to have a padlockfitted to the lock-out. This is to include lower voltage activities too.

The main department with interlocked equipment is the Bagging Plant, where robotic equipment isemployed. The auditor observed the records for the six monthly inspections conducted by supervisorsfrom 2012.

The auditor was informed by several electrical engineers that all high voltage switching, racking in andout is conducted under a permit and when the equipment is isolated.

2.4 ACCESS EQUIPMENT

The workshops hold an asset register of all access equipment, which is inspected annually. Theauditor observed the colour coding to denote this year’s inspection and serial numbers painted on allequipment.

All scaffolding is issued from central workshops to plant engineers and the procedures require allscaffolds to be erected by trained personnel, to be inspected by a competent person and green tagattached if fit for use, with red tags when unfit for use.

The auditor observed scaffolding in all plant locations visited and none appeared unsafe, all hadcorrect tags fitted and none were observed being used with red tags fitted.

Once again though, this high standard of management did not apply to Civils contractors, with theauditor identifying a small, low scaffold outside the medical centre without edge protection and safetytag. The access equipment used by construction contractors was a very poor standard.

2.5 WORKING AT HEIGHT

The majority of working at height is conducted from scaffolding and this has been covered in element2.4 above.

The auditor raised concerns in 2011 regarding the access platforms on the overhead cranes in severallocations across the site and there are still some concerns.

As identified in element 1.17, for some activities when undertaking basic inspection and maintenanceon these cranes, the auditor was informed a harness and lanyard would be employed.

This must then be included in the various risk assessments for these activities.


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The auditor observed harnesses and lanyards within a storage container in the PE Plant and adiscussion was held between the auditor and HOS regarding working at height.

The auditor was offered no evidence of inspection procedures for harnesses and lanyards used withinplant areas.

The lanyards attached to these harnesses were fall arrest and some activities would be only 3-4metres above ground / platform level and so offer no protection when working at these heights due tothe extension of the lanyard when it opens under fall conditions and the height of the individual.

The Fire Department hold ropes and harnesses for rescue purposes and the auditor observed therecords showing the quarterly inspections undertaken by fire personnel from 2012.

The auditor did observe training records for working at height and the improved presentation followingthe discussions identified above.

There is a hydraulic ladder which was inspected by Lunar Services in February 2012, but wascondemned and is out of use currently awaiting spares. The training record from May 2011 was

observed, which included the RA and safe working practices and included details of how to lowershould the electrical supply fail.

The auditor observed the evidence that departments are to obtain “Cherry Pickers” later in 2012 andwas informed that the suppliers would conduct the training.

When staff were questioned regarding rescue procedures, all confirmed that the Fire Departmentwould be called and during the interview with the Fire Chief and officers, this was confirmed. Trainingfor fire staff to conduct rescues from various locations around the site is conducted weekly.

It was confirmed to the auditor that the company does not hold a vertical rescue stretcher to safelylower an unconscious casualty.

2.6 LIFTING EQUIPMENT AND OPERATIONS

The auditor observed some very good management procedures regarding lifting equipment and again,there have been tremendous improvements since 2011.

All lifting equipment is now colour coded to identify inspection compliance, including contractors andall inspections are managed by the Inspections Department.

In all locations visited, the auditor observed no lifting equipment in poor condition and not colouredyellow.

The department has now harmonised its inspection schedule with that of the government inspectors,

so all equipment is now to be inspected in January and July annually.

The certificates for these inspections are copied and sent to individual departments. The mastercopies from April 2012 were observed, conducted by Lunar Services. Inspections hold masterspreadsheets for each department and these were observed by the auditor.

The test loads used by the company when undertaking crane inspections, were also observed asbeing colour coded yellow and were also calibrated in April 2012.

Training is conducted internally by the safety department and records from June 1012 were observed.

All forklift trucks (FLT’s) are included in the inspection programme and the auditor observed all withinthe Bagging Plant as colour coded yellow and stencilled June 2012.

The passenger lifts in the accommodation were inspected by Lunar Services in September 2011 andMarch 2012.


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2.7 PRESURE SYSTEMS AND PORTABLE GAS CONTAINERS

Portable gas container management has been improved since 2011 and the auditor observed all assecure, stored correctly and only a very small number had poor quality hose connections. All torcheswere observed as having flashback arrestors fitted.

As identified in element 1.16, all welders are assessed by Inspections personnel to determine thequality of their welding and gas cutting competence.

The auditor observed training records regarding MIG welding and safety in gas cutting conducted bythe HOS dated July 2012.

The company has a large number of pressure vessels and the auditor observed the spreadsheets forequipment held along with the required inspections conducted by Lunar Services in January 2012 forall pressure valves, with Indorama Eleme conducting boiler inspections also in January 2012.

The auditor observed the certificates of competence for the Lunar Services inspector (Kenneth Umeh).

The spheres in the tank fields require inspection every five years and the auditor observed the recordsfrom March 2008.

2.8 MOBILE WORK EQUIPMENT

The Bagging Plant hold the FLTs and all were observed as being far better maintained than 2011.

The contractors maintain the equipment through a rolling programme of inspections and the auditorobserved the records from 2012 dated May to July.

All FLT’s now have suitable mirrors and fire extinguishers fitted and the battery charging area hasbeen transformed from the poorly maintained and hazardous area it was in 2011.

The auditor observed the medical records from 2012, for operators in Bagging during the interviewwith the doctor.

Training records from 2011 were observed, but the auditor did not observe a specific training scheduleto ensure all operators are refreshed at the three to five year point.

2.9 HAZARDOUS SUBSTANCE CONTROL

Some of the chemicals used and produced during the processes are extremely hazardous to theemployees and environment.

The HOS conducts airborne monitoring for Benzene, Toluene and VOCs and reports the results withineach months report to management.

Each plant holds assessments for the chemicals they employ, along with training records for thespecialist PPE (if required).

Several chemical hazards were identified and the auditor requested evidence that the material safetydata sheets were available and complied with. These are referenced within verification.

One of the most hazardous locations is the Effluent Treatment Plant, where concentrated sulphuricacid is delivered. The RA was observed – EPCL PPUO RA 0012 dated April 2012.

Employees were interviewed and the emergency procedures were explained adequately to the

auditor, along with a demonstration of wearing the acid proof PPE and respirator. It transpired therewas only a single respirator although two employees are within the delivery area should a spill occur.They also explained the emergency procedures to follow should an individual be contaminated bysulphuric acid and they did so correctly.


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The emergency shower was checked and operated correctly and this is included in the deliverychecklist which is completed beforehand. The auditor observed the folder which held these checklistsand selected several at random for 2012, all of which were correctly completed. The auditor confirmedwith the doctor the availability of skin salve should skin contamination occur.

The plant locations have their chemicals contained within the process and exposure would be as aresult of leaks or spillages, where spillage control procedures would be enacted.

Employees from PE Plant explained the procedures to the auditor correctly and the spillage controlequipment, along with the plentiful supplies of water to dilute spillages was observed.

The PPU Plant is the only location where Legionella could occur and the water droplets are dosed withchlorine and biocides. The auditor observed the records for the daily analysis of total organic contentand weekly bacteriological content measurements from 2012.

As already identified, the cleaning contractors within the main administration building brought highlyflammable, toxic and narcotic paint thinners in to clean the floors. When interviewed, none of thecleaning ladies realised the risks they were placing themselves and others to.

It was also very concerning that this incident was only discovered when the auditor and HOS entereda separate part of the building and the auditor was concerned about the smell which was clearlyevident and permeating throughout the building.

2.10 RADIATION SOURCES

There are some radioactive sources on site, but all were observed as being low level risk as they areinstrumentation equipment held within the process.

The Nuclear License for Silo Probes and Low Pressure Separator Gauge was observed from theNigerian Authorities dated December 2010.

The HOS conducts monthly inspections and takes readings to assess exposure to employees and theresults recorded in the monthly reports to management.

Felix Okoson attended the Radiation Protection Officer course in August 2008 with the NigerianNuclear Regulation Authority.

2.11 NON IONISING RADIATION

The only sources of non ionising radiation are welding activities and occasional microwave oven use.

The auditor observed that welding is controlled using screens and long sleeved overalls, with suitable

eye protection and gloves.

There is no method employed to detect leakage from microwaves.

2.12 PORTABLE ELECTRICAL EQUIPMENT

The company has improved the management and inspection of portable equipment since 2011,through the proactive programme identified in element 2.1.

Whereas in 2011 the auditor identified many poorly maintained items and unsafe connections tosockets, this year’s audit identified none.


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2.13 ELECTRICAL INSTALLATIONS AND PROTECTIONS SYSTEMS

The auditor interviewed several engineers from the workshop regarding electrical maintenance andobserved the Indorama Computer Maintenance System (ICMS) which is the software employed toplan schedules inspections and maintenance activities.

The auditor observed the physical records held on the main workshop computer and verified the hardcopies during plant inspections.

Fixed wiring inspections are conducted annually with tests undertaken on the main panels in the MCCrooms.

Lighting circuit inspections are also conducted annually as are the residual current devices (ELCBs)and earthing pits.

The records from 2011 and 2012 were observed for PP – PE – Olefins plants.

High voltage engineers undertake annual inspections and oil tests and the oil sampling records from

January 2012 were observed.

Non plant locations receive annual visual inspections only, where sockets and outlets are checked, butthe ELCB’s tested. Records of the visual inspections from September and October 2011 wereobserved, as were the ELCB tests from May 2012.

All electrical testing equipment was calibrated by Lunar Services and records observed from July2012.

The auditor observed that all lighting within plant and offsite locations where flammable hydrocarbonsand volatile organic compounds are present is intrinsically safe.

2.14 PPE ASSESSMENT AND CONTROLS

Plant management are responsible for the management and issue of protective clothing and thecompany endeavours to source supplies from within Nigeria where possible.

The auditor observed that all personnel wore the correct PPE for the activities they were undertakingand the company holds supplies of specialist equipment for use where acids, flammable liquids orgasses are present.

During visits to plant areas, the auditor requested evidence that staff have access to eye protectionand in all cases it was not on their person but in their welfare area lockers. This was a concernidentified during the audit of 2011 and should have been addressed.

The locally produced PPE is of a lower standard than would be expected, with the employees and ex-pats both complaining about the quality of footwear and overalls supplied.

During discussions with the electrical engineers, it transpired they have no access to internationalstandard flash suits should they be required to rack in or out under emergency conditions.

2.15 RESPIRATORY PROTECTION (RPE)

During the inspections of the Effluent Treatment and Olefins Plants, employees were requested to donthe respirators held for emergency spillage protection. Although they donned the RPE effectively, theauditor observed the items were hung by the straps, which is incorrect as it can stretch them andreduce the sealing potential.

Training records were observed dated February 2012; where 37 employees attended, but the HOSadmitted he does not conduct full face fit testing using fragrant odours, simply a negative pressuretest.


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Canister shelf life is not shown and so the age of canisters and when to change them cannot beaccurately managed.

The auditor observed many different employees and contractors wearing simpler RPE, primarilyagainst visible dusts, but in almost all situations they were not fitted correctly and so offered no

protection.

The Fire Department undertake self contained breathing apparatus (SCBA) training for their own staffand plant staff every six months, with the records from May and July 2012. The Fire Department alsoconducts quarterly inspections of the SCBA and the auditor observed the records from 2011 and2012.

2.16 MANAGEMENT OF NOISE

The auditor observed the HOS monthly reports where he records for management the noise levels hemeasures in specific locations. Although some locations have a high level, the auditor was informedthat as employees only spend short periods of time conducting basic maintenance activities and wear

hearing protection, they have been assessed as low risk.

The annual medical inspections include hearing and the auditor was informed that some of the noisierequipment is shut down during maintenance activities.

The auditor did not experience any excessive noise levels and only wore hearing defence once duringthe plant visits die to leaking pneumatic energy.

2.17 VIBRATION

The auditor was informed that only engineers experience exposure to vibration through the use ofhand tools. The company has not conducted full assessments, but as referenced in element 1.11, is

now conducting questionnaire research during annual medical assessments.

During discussions with engineers and the HOS, the actual exposure times would appear limited.

2.18 MANUAL HANDLING AND ERGONOMICS

As identified during the audit of 2011, the main manual handing (MH) activities are conducted by locallabourers during the loading of large goods vehicles at the Bagging Plant.

The auditor could not observe this activity during this audit, so cannot determine if improvements havebeen made.

Indorama Eleme personnel conduct relatively few regular MH activities, with engineers being thosethat would be required to manually manoeuvre equipment during maintenance activities.

The auditor observed hoists and lifting equipment within each plant and workshop.

FLT’s operate within Bagging and occasionally in other locations.

The auditor observed no tasks that would require significant ergonomic assessments, with theexception of computer workstations which is covered in element 2.19 below.

The HOS has conducted some FLT and ergonomic training for the Bagging Plant and Logisticpersonnel, but as the location was within a plant conference room, it would be difficult to determine theeffectiveness.


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2.19 WORKPLACE ASSESSMENT INCLUDING DSE

This is still an element that requires some further effort from the company.

Although some computer workstations were observed with suitable chairs and screens, both of which

were adjustable, many were not.

Many workstations had simple and basic chairs, low or poor quality desks, screens with direct sunlightor glare and laptops being employed without separate keyboards.


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© British Safety Council 2011


SECTION 2 MANAGEMENT CONTROL SYSTEMS RECOMMENDATION PRIORITYPERSON

RESPONSIBLE

COMPLETION

DATE

2.1 WORK EQUIPMENT Conduct a review of all plant workshop

equipment to determine the required guarding

and emergency stops are fitted

Amend all RAs to ensure cloth gloves are not

worn when operating machinery with rotating

parts

Ensure Civils contractors are subject to the

same level of equipment inspection

2.2 PERMIT TO WORK SYSTEMS All higher risk activities should require

authorisation by management that are

competent in the management of the hazards

associated with the task

Higher risk activities should only be authorised

following physical confirmation that all control

measures are in place

2.3 SAFE ISOLATION PROCEDURES AND EQUIPMENT

CONTROLS Amend the procedures to ensure all activities

requiring energy isolation are locked out

It can only be acceptable if all personnel working

on isolated equipment have padlock fitted to the

lock-out

Multiple point isolation, requiring a large number

of keys should be managed using a “key box”

system

2.4 ACCESS EQUIPMENT Ensure all contractor activities managed by

Civils are subject to the same level of

management and scrutiny as those operating in

plant locations

2.5 WORKING AT HEIGHT Review all activities to determine the correct


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harness and lanyard controls are employed

All departments should be inspecting harnesses

and lanyards quarterly as a minimum

Review the access platforms fitted to overhead

cranes and where not required, remove them.

Where a fall from height risk exists, provide

railings / barriers for those accessed regularly

Procure a vertical rescue stretcher to be held by

the Fire Department

Apply the same standards to managing Civils

contractors as those operating in plant locations

2.6 LIFTING EQUIPMENT AND OPERATIONS

2.7 PRESURE SYSTEMS AND PORTABLE GAS

CONTAINERS Continue the drive to improve hose connections

2.8 MOBILE WORK EQUIPMENT Introduce a re-training schedule which ensures

all FLT operators are re-assessed every three-

five years and following any incident

2.9 HAZARDOUS SUBSTANCE CONTROL Undertake a full review of all contractors

operating away from plants, but including all

cleaning contractors, to determine the

substances and materials being employed

2.10 RADIATION SOURCES

2.11 NON IONISING RADIATION Consider conducting leak tests on microwave

ovens

2.12 PORTABLE ELECTRICAL EQUIPMENT Apply the same standards to managing Civils

contractors as those operating in plant locations

2.13 ELECTRICAL INSTALLATIONS AND PROTECTIONS

SYSTEMS

2.14 PPE ASSESSMENT AND CONTROLS Review the safety boots and overalls issued to

plant staff to determine if better quality can be


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obtained

All plant staff should carry their eye protection at

all times so they can immediately wear to

protect them should there be a need

Procure international standard arc flash

protection suits in numbers sufficient to cover all

plant and workshop locations

Procure trousers with inbuilt Kevlar protection

for use when operating the chainsaws

Apply the same standards to managing Civilscontractors as those operating in plant locations

2.15 RESPIRATORY PROTECTION Introduce annual refresher training programmes

for all personnel expected to wear respirators

Introduce a method to readily identify when

canisters are due for change

All personnel expected to wear RPE should be

subject to formal face fit testing to include odour

detection which determines if equipment is fitted

correctly

2.16 MANAGEMENT OF NOISE

2.17 VIBRATION Undertake full reviews of all personnel operating

vibrating equipment, to determine trigger times

and average monthly exposure

Consider using the UK HSE vibration calculator

that can be downloaded from their website

2.18 MANUAL HANDLING AND ERGONOMICS

2.19 WORKPLACE ASSESSMENT INCLUDING DSE Review all workstations to determine the

ergonomic concerns and train staff to

understand how to correctly set up their

workstation


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Issue correctly adjustable chairs and screens to

IT users

Issue separate keyboards for use with laptops


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SECTION 3 - EMERGENCY CONTROL SYSTEMS


3.1 COMPETENCE & CO ORDINATION

This is a very positive section for the company, as they fully understand the tremendous risks to theirbusiness from fire and explosion and also security breaches by terrorists.

The Fire Chief is very experienced and has spent many years working in petro-chemical industries.He has a Fire Officer, eighteen firemen and three training and maintenance staff covering three shifts.

The auditor was informed that local firemen attend training with the Nigerian Fire and Rescue Servicefor six months, and then continue their training with Indorama. As there have been no new firemen

employed in recent years, this could not be verified.

The Head of Security is a retired Colonel from the Indian Army and he liaises very closely with thelocal authorities, military and government.

All staff are trained annually to ensure they understand the onsite emergency plan, with the auditorobserving the records from various sessions in 2012. Selected plant staff are designated asEmergency Marshals and it is these that assist in the evacuation procedures.

3.2 FIRE RISK ASSESSMENT

Plant management conduct their own fire risk assessments (FRA) and review them annually, with the

auditor observing those from the plants inspected dated 2012.

The potential for fire is a significant risk to the plants and there is ongoing fire safety managementthrough the permit system, which includes hot work permits. Training for plant staff regarding safetyduring hot work was conducted by the HOS in 2012.

The Fire Department conduct the building FRAs and the auditor observed those from June 2012covering the accommodation and administration.

Fire prevention training is conducted for all staff annually, with records from April and May 2012 beingobserved.

3.3 ALARM SYSTEMS

The company have various systems across the site including manually operated call points, which inthe plant areas isolate systems to reduce the potential for fire spread.

Call points are recorded on a register and the auditor observed evidence of random testing by the FireDepartment between January and July 2012. When interviewed, the Fire Chief could not confirm thatall had been tested within the past year.

Atlantic Bluewater conducts the annual system inspections and the auditor observed the records forthe gas detectors dated October 2011 and April 2012.

The alarm systems cover the whole site and when interviewed, all personnel confirmed the alarms are

very loud and easily heard.


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British Safety Council Combined Five Star Audit Report


3.4 FIRE FIGHTING EQUIPMENT

There is a number of different fire fighting systems in operation and the auditor observed portableextinguishers in all locations which were within their inspection dates.

All extinguishers are inspected each two months, as are the sprinkler systems and the auditorobserved the records from 2012 covering Olefins, PPU, PP and Offsite.

There are deluge systems in the tank farms and these are inspected annually and flushed throughevery two months, with the auditor observing all records from 2012.

Hydrants are tested every two months and fire tenders quarterly, with records of both from 2012observed.

Fire training is conducted for the fire staff daily and plant staff regularly and this includes live firefighting techniques. The auditor observed several records from 2011 and 2012.

3.5 EMERGENCY ESCAPE LIGHTING

Plant electricians conduct the inspections for emergency lighting annually and the records from theseis referenced in element 2.13.

All plant locations are external and the auditor visited several locations during the night shift andvisibility was very good.

Administration buildings all had good visibility from windows and the auditor was informed thatpersonnel do not work there by night.

The accommodation block was observed with suitable emergency lighting.

The auditor observed no records for inspection and testing for non plant locations.

Illumination surveys were conducted by the HOS dated July 2011, with no significant issues identified.

3.6 EVACUATION, DRILL AND INSTRUCTION

The auditor was informed that evacuation drills are conducted annually for each plant and the auditorobserved the records from PP Plant dated March and Olefins dated May 2012. Each drill was detailedwith a full report showing positive and negative aspects, with very minor recommendations made.

A full site evacuation was conducted in December 2011, which included a full dress drill wearingSCBA and aluminium suits for all fire teams. The report from this drill was observed and there were

no major concerns identified.

3.7 FIRE MANAGEMENT INSPECTIONS

The auditor was informed that plant inspections are the responsibility of plant staff and managementand these are not a formal process, but any issues would be entered into the plant log books and plantengineers would be required to rectify any faults.

The HOS, when undertaking his random plant inspections would also be expected to report anyconcerns directly to plant management.

The auditor observed various “what went wrong” displays on plant notice boards, which included

several fire incidents from petro-chemical sites across the world.

The company has also identified a concern with long flange bolts, which expand when exposed to fireand if holding flammable liquids, this promotes and increases the fire severity. The company has nowbegun covering these flanges with fire protection to reduce this risk.


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3.8 FIRE ESCAPE ROUTES AND EXITS

All locations (less MMD) were observed as having suitable escape routes which were well maintained.

Plant locations being external, have various routes to escape from fire or potential hazards.

When the auditor was inspecting the MMD warehouse, the side fire doors were locked and padlockedwhich was highlighted with management and by the time the audit was completed, these had beenreleased. This was an example of non plant locations being subject to lower levels of safetymanagement and is an area the company must improve upon.

The audit of 2011 raised the concerns that within administration and accommodation buildings, thereare insufficient fire doors to prevent the spread of fire, smoke and heat. There are doors protectingfinal escape routes on stairs only.

This has not been addressed and should be given a higher priority.

3.9 SECURITY

This is a very positive aspect of the audit and the company, under the management of the new HOSecurity is making improvements across all areas.

Security is a mixture of private, military, state security and police personnel.

All vehicles entering the site are checked by security personnel, which include a full contents checkand basic vehicle conditions. Any non essential personnel are removed from the vehicle whilst on site.

The site is covered by armed security patrols, posts, CCTV which is monitored at all times, dog patrolsand non essential vehicles are banned from plant locations.

All ex-pat movements are protected by armed vehicle escorts and all convoys are GPS tracked, withthe auditor observing the location of a convoy whilst interviewing the HO Security.

The auditor was shown the plans regarding additional security equipment being procured, whichincludes biometric entry (introduced in 2012) and X-ray scanners for all pedestrians (to be late 2012).

3.10 EMERGENCY PLANNING

The auditor observed the Onsite Emergency Plans, all revision three dated April 2012.

These plans cover all aspects of potential emergencies, including environmental – fire – chemicalspillage – medical and maintenance.

The last full site emergency drill was conducted in December 2011, with the next planned forDecember 2012.


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SECTION 3 EMERGENCY CONTROL SYSTEMS RECOMMENDATION PRIORITYPERSON

RESPONSIBLE

COMPLETION

DATE

3.1 COMPETENCE & CO ORDINATION See 3.7

3.2 FIRE RISK ASSESSMENT

3.3 ALARM SYSTEMS Introduce a programme to ensure all manual call

points are tested six monthly at least

3.4 FIRE FIGHTING EQUIPMENT

3.5 EMERGENCY ESCAPE LIGHTING All locations should be subject to formally

recorded emergency escape lighting tests

Discharge tests should be conducted in all

locations six monthly

3.6 EVACUATION, DRILL AND INSTRUCTION

3.7 FIRE MANAGEMENT INSPECTIONS Introduce formal fire risk management

inspections in non plant locations

3.8 FIRE ESCAPE ROUTES AND EXITS Install fire protection doors in administration and

accommodation buildings at specific locations to

prevent the spread of fire

The HOS should ensure the situation within

MMD never happens again, through regularinspection

3.9 SECURITY

3.10 EMERGENCY PLANNING


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SECTION 4 – ACCIDENT/INCIDENT/NEAR MISS/ILL HEALTHREPORTING


4.1 REPORTING SYSTEMS

The company has a good incident reporting system, with all first aid cases being reported andrecorded before being passed to the HOS.

The company has promoted near miss reporting for 2012 and the auditor observed the HOS monthlyreports, which record the figures and the auditor observed there has been an increase, but for a site ofthis size, there should be more reported.

4.2 INVESTIGATION PROCEDURES

The auditor obse

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