Section 3.23 Health, Safety and Risk Management

Abbot Point Coal Terminal 0 EIS • Adani

Terminal 0 Environmental Impact Statement


Terminal 0 Environmental Impact Statement 3-675

3.23 Health, Safety and Risk Management

3.23.1 Workplace Health and Safety

Workplace health and safety (WHS) is the highest priority for Adani and the Project. This WHS Framework Plan (the ‘Plan’) outlines the management framework to be adhered to for those involved in the Project and is provided in accordance with the published EIS Guidelines for the Project.

The Project shall comply with all relevant requirements by implementing a WHS system associated with the following Project phases:

Conceptual and Design;

Construction;

Commissioning and Operations; and

Decommissioning.

This plan outlines the framework of how the WHS system will be revised and updated as the Project progresses through its different phases.

3.23.1.1 WHS Objectives

The objectives of this Plan are to:

Outline the WHS management processes that will be applied to the Project;

Define the Adani requirements and processes to guide project staff, contractors and sub-contractors involved in the works;

Define roles and responsibilities for safety critical positions in the Project;

Characterise and summarise the outcomes of the Projects Integrated Risk Analysis (IRA);

Summarise the key requirements of the Emergency Response Procedures;

Define monitoring, audit, communication and reporting procedures;

Define training requirements for project personnel; and

Define the principles of document and record management for the Project.

3.23.1.2 WHS Scope

This plan addresses the management of WHS across all aspects of the Project and acts as an overarching document providing guidance for any additional project WHS plans and procedures developed through the design, construction, commissioning and operations and decommissioning phases. It applies to all workers including Adani, the construction contractor and sub-contractors and is aligned with the obligations of the North Queensland Bulk Ports Corporation (NQBP) Abbot Point’s Health and Safety Policy.

This Project’s WHS Policy, as well as the Adani’s WHS Policy (Appendix C3) makes the following commitments, which have each been addressed in this plan:



Provide a safe working environment, including facilities, plant and equipment;

Encourage a just safety culture which values positive safety behaviours, responsibility, trust, open communication and collaboration to identify and control safety risks;

Encourage management responsibility and accountability for the maintenance of a just safety culture and safety leadership;

Promote a uniform, consistent and integrated approach to health and safety across the business;

Compliance with legislation, regulations and codes of practice relating to health and safety;

Establishing and maintaining safety management systems to manage all health and safety risks associated with operations across the business, including risk specific systems;

Identification, assessment and elimination or effective management of health and safety risks;

Encouraging engagement and collaboration in the development and improvement of safety management systems;

Providing clear, effective and relevant communication in respect of health and safety to all persons associated with operations across the business;

Providing adequate instruction, training, and supervision to enable all employees to perform their duties safely;

Subjecting the safety management system to continuous improvement through review, incident investigation and reporting systems;

Ensuring all equipment, including personal protective equipment (PPE), is available, safe and suitable;

Follow safe work practices, procedures, instructions and rules;

Work in a manner which ensures our health and safety and the health and safety of others;

Encourage other employees to work in a healthy and safe manner;

Participating in training; and

Report or rectify any unsafe conditions or practices that come to our attention.

3.23.1.3 WHS Policy

Adani is the leaseholder for the T1 facility. The Adani WHS Policy makes the following commitments:

“Adani is committed to providing and maintaining the highest health and safety standard of working environment for all workers, visitors and members of the public that are connected with Adani operations.

Our Health and Safety objectives are to ensure that we:

Provide a safe working environment, including facilities, plant and equipment;



Encourage a just safety culture which values positive safety behaviours, responsibility, trust, open communication and collaboration to identify and control safety risks;

Encourage management responsibility and accountability for the maintenance of a just safety culture and safety leadership; and

Promote a uniform, consistent and integrated approach to health and safety across the business.

We have an accountability and responsibility to:

Follow safe work practices, procedures, instructions and rules;

Work in a manner which ensures our health and safety and the health and safety of others;

Encourage other employees to work in a healthy and safe manner;

Participate in training; and

Report or rectify any unsafe conditions or practices that come to our attention.”

3.23.1.4 WHS Legislation, Standards and Codes of Practice

To ensure the WHS works program is consistent with relevant Legislation, Standards and Codes of Practices throughout the Project’s lifecycle, a detailed WHS Integrated Risk Management Plan (IRMP) (3.23.2) will be developed to identify key activities and subsequent legal requirements. The key WHS requirements for each of the Project phases are outlined below.

3.23.1.5 Conceptual and Design Phase

During the conceptual and design phase, the design team has ensured that the Project design effectively considers WHS for the upcoming construction and operations phases. Design shall be based on the relevant legal requirements including the Work Health and Safety Act 2011 (WHS Act), Work Health and Safety Regulations 2011 (WHS Regulations) and the following Codes of Practice as identified as part of the WHS Conceptual Risk Register:

Confined Spaces (2011);

Formwork (2006);

Hazardous Chemicals (2003);

How to Manage Health and Safety Risks (2011);

Managing Noise and Preventing Hearing Loss at Work Code of Practice (2011);

Managing the Work Environment and Facilities Code of Practice (2011);

Mobile Crane Code of Practice (2006);

Plant Code of Practice (2005);

Steel Construction Code of Practice (2004);

Tilt-up and Pre-cast Construction Code of Practice (2003);

Tower Crane Code of Practice (2006); and



Traffic Management for Construction or Maintenance Work Code of Practice (2008).

The following legislation and standards were identified in the Conceptual WHS Risk Register and included in the Emergency Response Plan:

Disaster Management Act 2003;

Ambulance Service Act 1991;

Fire and Rescue Service Act 1990; and

Maritime Safety Queensland Act 2002.

Other leading practice standards identified during the compilation of the Conceptual WHS Risk Register, which shall be considered and adhered to during the design phase, include the following:

AS/NZ 1418:1: 2002 Cranes, Hoists and winches;

AS/NZ 2550.1: 2002 Cranes Hoists and Winches – Safe Use – General Requirements;

AS/NZ 3000 2007 Wiring Rules;

AS/NZ 2299.1: 2007 Occupational Diving; and

AS/NZ 2813.3: 1992 Certification of Occupational Divers – Air Diving – 50 m.

In addition to the legal requirements and leading practice standards, design shall adhere to the requirements of the relevant Adani Health and Safety Management Plan, which address key Work at Heights, Energy Isolation, Fixed and Mobile Plant, Hazardous Substances, Fitness for Work and other key risk areas for Adani. These will be considered by the design team when detailed design commences.

A desktop WHS Design Phase Risk Register shall be completed by the design team during detailed design, with input from Adani WHS professionals. The key focus areas for this risk register include permitting, work at heights, marine operations, infrastructure, contractor and sub-contractor management, rail operations and key considerations for operations, commissioning and decommissioning phases. The WHS Conceptual Risk Register will be used as the template for the WHS Design Phase Risk Register.

3.23.1.6 Construction Phases

Prior to the commencement of construction (for both Phases described in Section 2 Project Details), the contractor shall provide documentation of compliance with the relevant legal requirements, which have been identified as part of the Conceptual WHS Risk Register, including the WHS Act, WHS Regulations and the following Codes of Practice:

Confined Spaces (2011);

First Aid Code of Practice (2004);

Formwork (2006);

Hazardous Chemicals (2003);

How to Manage Health and Safety Risks (2011);

http://www.deir.qld.gov.au/workplace/resources/pdfs/first-aid-cop-2004.pdf



Labelling of Workplace Hazardous Chemicals Code of Practice 2011;

Managing Noise and Preventing Hearing Loss at Work Code of Practice (2011);

Managing the Risk of Falls at Workplaces Code of Practice (2011);

Managing the Work Environment and Facilities Code of Practice (2011);

Manual Tasks Involving the Handling of People Code of Practice (2001);

Mobile Crane Code of Practice (2006);

Occupational Diving Work Code of Practice (2005);

Plant Code of Practice (2005);

Scaffolding Code of Practice (2009);

Steel Construction Code of Practice (2004);

Tilt-up and Pre-cast Construction Code of Practice (2003);

Tower Crane Code of Practice (2006);

Traffic Management for Construction or Maintenance Work Code of Practice (2008) ; and

Work Health and Safety Consultation, Co-operation and Co-ordination (2011).

The contractor shall also provide documentation to ensure compliance with the following leading practice standards identified during the Conceptual WHS Risk Register:

AS/NZ 1418:1: 2002 Cranes, Hoists and winches;

AS/NZ 2550.1: 2002 Cranes Hoists and Winches – Safe Use – General Requirements;

AS/NZ 3000 2007 Wiring Rules;

AS/NZ 2299.1: 2007 Occupational Diving; and

AS/NZ 2813.3: 1992 Certification of Occupational Divers – Air Diving – 50m.

In addition to the legal requirements and leading practice standards, construction shall adhere to the requirements of the relevant Adani Health and Safety Management Plan, which address key WHS risk areas including work at heights, Energy Isolation, Fixed and Mobile Plant, hazardous substances, Fitness for Work and other key risk areas for Adani. These will be issued to the contractor prior to construction commencing.

http://www.deir.qld.gov.au/workplace/resources/pdfs/manual-tasks-people-handling-cop-2001.pdf

http://www.deir.qld.gov.au/workplace/resources/pdfs/whs-consultation-cooperation-coordination-cop-2011.pdf



3.23.1.7 WHS Accountabilities

3.23.1.8 Individual Accountabilities

Table 3-147 below outlines the crucial WHS accountabilities applying to the Project.

Table 3-147 WHS accountabilities applying to the Project

Position Accountabilities Adani Operations Senior Management

Ensure that a WHS Committee is established in accordance with this plan.

HSE Coordinator- Adani Operations

Ensure that technical OHandS work agreed by the WHS Committee is effectively implemented. Ensure that WHS Management Systems being provided by the contractor is evaluated for compliance with legal requirements and applicable Adani Health and Safety Management Plan prior to appointing the contractor. Execute the WHS assurance program for the contractor and its subcontractors, which may consist of audits, periodic reports on WHS performance and periodic participation in WHS forums (including meetings, incident investigations, risk assessments, emergency response scenarios and internal compliance audits).

Director- contractor

Provide for and ensure compliance with contractor WHS management systems, make revisions where required by Adani to meet their system WHS requirements or legal obligations, and implement any directives defined by the WHS Committee.

Operations Staff and Contractors

Staff or contractors are required to understand the risks and control measures associated with the agreed operational controls, which may include procedures, training, risk assessments or change management plans as outlined by the Adani WHS Management Systems.

Contractor Staff and Contractors

Staff or contractors are required to understand the risks and control measures associated with the agreed operational controls, as outlined by the contractor WHS Management Systems.

3.23.1.9 Project WHS Committee

Prior to construction activities commencing and after the detailed design is complete, the Project will establish a WHS Committee to oversee construction activities and to ensure interface points with Adani are effectively managed. These interface points include, but are not limited to the following:

Emergency Response Procedures: The contractor will be likely to require the Adani Emergency Response Team to respond to construction emergency situations, and consequently the Adani Emergency Response Procedures must be understood by the relevant contractor personnel. The Adani Emergency Response Team will also be required to understand and plan for any new or altered potential emergency scenarios arising as a result of construction activities;

Traffic Rules: The contractor will need to conform to the key traffic management plans established by Adani, and such rules must be communicated to and complied with by relevant contractor personnel;

Legal Requirements: Adani may maintain legal requirements which may be consequential to the project construction activities. The contractor will also need to be aware of these conditions and how they will be complied with; and

Incident Investigation: Incidents involving interface points between project construction and Adani activities will need to be investigated jointly in some cases and the contractor will require training in the Abbot Point incident investigation procedures to ensure their competency.



Once the Committee is established, a Charter will be prepared so as the scope and role is defined, some of the key components include the following:

The WHS Committee shall be established and overseen by the Project Director;

The WHS Committee will comprise representatives from the contractor, high risk sub-contractors to the contractor and Adani representatives;

The WHS Committee shall maintain accountability for the implementation of effective WHS systems that facilitate safe working practices for construction related work and operations that interface with construction work; and

Towards the end of the construction phase, the WHS committee will oversee the formal handover program as part of the commissioning process, with the outcome being the formal transfer of management from the contractor to Adani.

3.23.1.10 WHS Management over the Project Lifecycle

3.23.1.11 Construction Management System

During the construction phases, the contractor shall utilise a WHS Management System applying to all activities managed by the contractor and its sub-contractors. This shall comprise well established systems that have been used effectively on large construction projects. These systems, as well as the compliance requirements outlined earlier in construction phases, will form compliance obligations for the EPCM for the duration of the Project.

3.23.1.12 Construction WHS Risk Register

Prior to commencing construction, a team-based risk assessment will be undertaken using the previously developed WHS Risk Registers as the foundation. The development of this Construction WHS Risk Register shall be initiated by the WHS Committee and will involve representatives from Adani and the contractor. The Construction WHS Risk Register addresses the detail of project specific risks likely to be encountered for the project, and how these are controlled by using the hierarchy of controls and by using training, audits, monitoring, communication and the principles of continuous improvement.

3.23.1.13 Training

All employees of Adani, the contractor and other contractors associated with the construction phase shall be provided with an Adani WHS Induction upon commencing work. Staff and contractors associated with the Project shall also receive a project specific WHS Induction provided by the contractor. The completion of these two inductions will be required before workers are permitted to start work.

The contractor shall then implement the WHS Training Program in accordance with the WHS Management System for those workers that require further training. This shall consist of training packages, job-specific training and general awareness sessions delivered during the construction work.



3.23.1.14 Emergency Response

The WHS Conceptual Risk Register completed for the project identified a number of potential emergency scenarios which need to be addressed in further detail prior to the commencement of the construction program. These include the following:

Fires;

Medical emergencies;

Civil disorder and site invasion;

Natural events such as severe weather and storm surges, cyclones, storm damage, flood and earthquakes;

Hazardous substance and dangerous goods incidents;

Structural instability or collapse;

Bomb threats (including phone and written threats, suspicious packages and letter bombs);

Explosion;

Gaseous release;

Collision including between marine vessels, rail vehicles and road vehicles;

Terrorism; and

Public safety issue.

A conceptual Emergency Response Plan has been prepared for the Project, which addresses these Emergencies (see 3.23.3). These procedures will be used as a template for the construction emergency plans that shall be developed by the contractor.

3.23.1.15 Documentation, Records and Reporting

Records and documentation shall be maintained by the contractor in accordance with their WHS Management System, with any records relevant to operations being provided directly to the Adani HSE Coordinator. To ensure that key WHS information is communicated to and reinforced with all workers on the Project, the following actions shall be undertaken:

Incident Injury Boards shall be located at Front gate, and at the entrance to all mess areas with statistics representing Adani injury classification;

Toolbox Meetings will occur daily, which shall provide an opportunity to raise awareness and address key WHS issues faced by workgroups;

A site WHS Meeting shall occur periodically, involving relevant Operations staff, contractors and sub-contractors, to enable awareness and issues faced to be addressed; and

Adani Knowledge Share notices applicable to Project operations and general safety shall be distributed to site leaders each week to be used as safety briefings for each work team. This enables workers to communicate and coordinate with management on the detailed implementation of health and safety procedures and to enable any concerns to be raised with line management.



The Project Director from the contractor will report on health and safety performance to the Adani Management on a weekly basis, and medical treatment injuries and lost-time injuries are reported immediately. As outlined above, a weekly review of high-potential incidents and accidents is undertaken by Adani senior management. Incidents and injuries are included in the monthly management report. Safety performance results are published and distributed throughout the workforce via notice boards and safety briefings.

3.23.1.16 Audit and Monitoring Requirements

Audit and monitoring requirements will form a key component of the WHS assurance program for the contractor and its subcontractors. To bring monitoring and reporting into line with Adani standards, Project-wide reporting standards will be implemented across the project, with illness and injury requirements being separated into standardized classifications for Lost Time Injuries, Restricted Work day Injuries, Medical Treatment Injury and First Aid Injury. These classifications are to apply to externally and internally reported injury statistics for Project construction and operations activities.

WHS audits of all contractor activities shall be undertaken periodically by the Adani HSE Coordinator, based on the compliance requirements of WHS legal requirements, leading practice standards and Adani Health and Safety Management Plan. To ensure ongoing compliance with these requirements and the contractor WHS Management System, daily inspections shall be undertaken by the contractor team leaders and supervisors.

3.23.1.17 Health and Safety Review, Management Meetings and Committees

Meetings and committees shall be established to monitor the WHS program during the construction phase. These forums are intended to facilitate information transfer between and within contractor teams and are identified in Table 3-148 below.

Table 3-148 Key construction-phase WHS meetings

Title Chair Attendees Frequency Purpose

Site WHS Committee

Adani Senior Management

Adani Senior Management, key representatives from Adani, the contractor and its subcontractors

Monthly Oversee construction activities and to ensure interface points with Adani are effectively managed.

Project WHS Meeting

Contractor Project Director

Contractor Area Managers and Adani HSE Coordinator

Weekly Transfer of lessons learnt, corrective/ preventative actions and ensure effective close out of incident actions and investigation, ensure alignment of key WHS issues and track progress of key initiatives

Team Toolbox Meetings

Area Managers

Contractor personnel and subcontractors

Daily Plan work activities and discuss general safety concerns

Contractor and Sub-contractor Safety Meeting

Contractor Representatives from all sub-contractors

Weekly Ensure key WHS initiatives are communicated to all subcontractor workgroups

3.23.1.18 Key Performance Indicators

Adani will monitor key WHS related issues. These issues will be measured using predetermined trigger values known as Key Performance Indicators (KPIs) which will then allow the effectiveness



of the health and safety management system to be determined. These KPIs are presented in Table 3-149.

Table 3-149 Key performance indicators

Key Performance Indicator Target/ Threshold Monitoring Measure

Lost Time Injuries (LTIs) Target: Zero; Threshold: 2

LTI Frequency (per 1 million hours worked)

Medically Treated Injuries (MTI) Target Zero; Threshold: 10

MTI Frequency (per 1 million hours worked)

First Aid Treatments Target: Zero Threshold: 15

First Aid Frequency (per 1 million hours worked)

All Injury Frequency Rate Target: Zero Threshold: 0.56

All Injury Frequency (per 1 million hours worked)

Health Incidents Target: Zero New cases of Occupational Disease (per 10,000 employees)

These KPIs will be revised following the completion of the Construction WHS Risk Register workshops, to ensure any specific priorities generated from this workshop are incorporated. Conformance with Key Performance Indicators will be reported against in Weekly WHS Reports, with corrective and preventative actions being nominated where targets are not being met.

3.23.1.19 Management Review

At a minimum of once per 6 months during the construction program, the WHS Committee will organise a meeting involving the appropriate management and key staff to conduct a review of the contractor WHS Management System to ensure its continuing suitability, adequacy and effectiveness. Reviews shall include assessing opportunities for improvement and the need for changes to the WHS Management System, including the WHS Policy, and Project KPIs.

In undertaking this assessment, regard shall be had to all elements of the contractor WHS Management Systems, including in particular:

Results of internal audits and evaluations of compliance with legal requirements and other requirements to which the organisation subscribes;

The suitability of the WHS Policy;

The number and nature of external complaints and their management;

Any known incidences of legal non-compliance;

Performance against objectives, targets and key performance indicators;

WHS reported statistics relative to industry averages and best practice;

The number and nature of incidents reported;

Follow up actions from previous WHS Management Review Meetings;

A summary of the number and nature of WHS incidents and significant audit findings;

A summary of performance in completing WHS actions;

Changing circumstances, including developments in legal and other requirements related to WHS risks and opportunities;

Emerging risks;

Recommendations for improvement; and



Stakeholder feedback.

The outputs from the WHS Management System Review Meetings shall include any decisions and actions related to possible changes to WHS Policy, objectives and other elements of the WHS Management System, consistent with the commitment to continual improvement.

3.23.1.20 Commissioning and Operational Phases

Following the completion of construction as the project moves into the commissioning and operations phases, an Operations Handover WHS Risk Register will be coordinated by the WHS Committee, which will involve representation from the contractor, Adani and other experts deemed to be necessary for advice on specialist, complex or high risk work and handover areas. This Operations Handover WHS Risk Register will outline a formal handover program as part of the commissioning, with the purpose of organising a safe, organised and formalised transfer of management from the contractor to Adani.

3.23.1.21 Commissioning and Operational Management System

Operational procedures, emergency procedures and pre-start risk assessments shall be developed by the contractor to meet the specific circumstances of the project and to address all high risk tasks. These shall be based upon requirements outlined in the contractor WHS Management System and the compliance requirements provided by Adani.

Key operational controls that involve interface points with the Adani Team shall be developed with input from the Adani Operations Team and the contractor, with sign off of these controls occurring through the WHS Committee.

3.23.1.22 Decommissioning

Prior to the demobilisation by the contractor, a final Decommissioning risk assessment will be conducted with the WHS Committee, which will involve representation from an contractor, Adani and other experts required for advice on specialist, complex or high risk areas. This Risk Register will draw on the content from previously approved risk registers, and will outline a program for incorporating decommissioning arrangements into the broader Abbot Point Port decommissioning and closure procedures.

3.23.1.23 WHS Project Schedule

A WHS Project Schedule has been prepared to ensure that the key work associated with each phase of the project, as outlined in this plan are scheduled in to the broader project schedule. However, operations-phase activities have not been addressed in detail given that the detail is not yet available. This schedule is included as Table 3-150.

3.23.1.24 Conclusion

The WHS risks to Project personnel and the general public are expected to be sufficiently managed following the development and implementation of specific WHS management measures identified in this section.

During the construction phases, the contractor shall utilise a WHS Management System applying to all activities managed by the contractor and its sub-contractors. This shall comprise well established systems that have been used effectively on large construction projects. Prior to commencing construction, a team-based risk assessment will be undertaken using the previously developed WHS Risk Registers as the foundation. All employees of Adani, the contractor and other



contractors associated with the construction phase shall be provided with a Adani WHS Induction upon commencing work. Records and ongoing auditing will be undertaken at regular intervals to ensure that the WHS Management System is adequate and capable of managing all Project related WHS requirements.

3.23.1.25 Commitments

To ensure the safety of Project personnel, the environment and the general public, Adani commit to:

Developing and implementing a Project specific WHS Management System which is compliant with the requirements of all relevant legislation;

Ensure all staff and relevant sub contractors undertake a compulsory induction training course for WHS;

Provide adequate and appropriate PPE for all personnel to ensure their safety;

Undertake ongoing monitoring and auditing of the WHS Management Plan to ensure its adequacy;

Ensure handling and storage procedures for potentially hazardous chemicals are in compliance with relevant legislation and Australian Standards;

Ensure all site equipment undergo maintenance and servicing by a qualified and licensed contractor at scheduled intervals;

Undertake ongoing inspections and implement maintenance programs to ensure structural integrity of infrastructure and equipment; and

Consider potential impacts of climate change on human health risk.



Table 3-150 WHS Project Schedule

Phase Activity Accountability Timing of Implementation

Phase 1: Conceptual and Design Phases

Design team to incorporate requirements of the relevant Adani Health and Safety Management Plan, legal requirements and leading practice standards into a Design Phase WHS Risk Register.

Design Team Prior to detailed design work

Phase 2: Construction Phases

contractor shall provide documentation of compliance with the relevant Australian Standards, legal requirements, the relevant Adani Health and Safety Management Plan identified as part of the Conceptual WHS Risk Register.

Contractor After appointment of the contractor and prior to construction commencing


WHS Committee Assemble the WHS Committee, ensuring representation from Adani and the contractor.


After appointment of the contractor and prior to construction commencing


Construction WHS Risk Register Prior to commencing construction, a team-based risk assessment will be undertaken using the Conceptual WHS Risk Register and the Design WHS Risk Register as the foundation. This WHS Risk Register will be initiated by the WHS Committee.

WHS Committee



Operational controls (1) Operational controls, emergency procedures and key pre-start and plant risk assessments shall be developed by the contractor to meet the specific circumstances of the project and to address all high risk tasks. These shall be based upon requirements outlined in the contractor WHS Management System and the compliance requirements provided by Adani.



Operational Controls (2) Key operational controls that involve an interface with the Adani Team shall be developed with input from the Operations Team and the contractor, and controls will be signed off by the WHS Committee.



Training (1) All employees of Adani and contractors associated with the construction phase shall be provided with a WHS Induction upon commencing work.



Training (2) Staff and contractors associated with the Project shall also receive a project specific WHS Induction provided by the contractor.



Training (3) The contractor shall then implement the WHS Training Program, consisting of training packages, job-specific training and general awareness sessions delivered during the construction work.



Emergency Response The Conceptual Risk Analysis completed for the project identified a number of potential emergency scenarios, which need to be addressed in further detail prior to the construction commencing.






Documentation, Records and Reporting (1) Records and documentation will be maintained by the contractor in accordance with their WHS Management Systems, with any records relevant to operations being provided directly to the Adani HSE Coordinator.



Documentation, Records and Reporting (2) To ensure that key WHS information is communicated to and reinforced with all workers on the Project, the contractor shall prepare Incident Injury Boards, complete Toolbox Meetings, hold a periodic WHS Meeting and prepare Adani Knowledge Share notices.

Contractor Throughout the Construction Program


Documentation, Records and Reporting (3) The Project Director from the contractor will report on WHS performance to Adani Senior Management on a weekly basis.



Audit and Monitoring Requirements Form a key part of the assurance program, which will involve contractor reporting, audits and other forms of evidence to verify compliance with these requirements.



Audit and Monitoring Requirements Adani reporting standards will be implemented across the project, with illness and injury requirements being separated into the following classifications.



Audit and Monitoring Requirements Safety audits of all contractor activities are undertaken by the Adani HSE Coordinator.

Adani HSE Coordinator

Throughout the Construction Program


Audit and Monitoring Requirements Weekly inspections shall be undertaken by the contractor team leaders and supervisors.



Audit and Monitoring Requirements Health and Safety Review and Management Meetings and Committees



Key Performance Indicators Performance Indicators shall be revised following the completion of the Construction WHS Risk Register workshops, to ensure any specific priorities generated from this workshop are incorporated.

WHS Committee

Throughout the Construction Program


Audit and Monitoring Requirements Conformance with Key Performance Indicators will be reported against in Weekly WHS Reports, with corrective and preventative actions being nominated where targets are not met.



Management Review At a minimum of twice per year during the construction program, the WHS Committee will organise a meeting involving the appropriate experts to conduct a review of the WHS Management System to ensure its continuing suitability, adequacy and effectiveness.


Phase 3: Commissioning and Operations Phases

Following the completion of construction as the project moves into the commissioning and operations phases, an Operations Handover WHS Risk Register will be coordinated by the WHS Committee. This Risk Register will outline a formal handover program as part of the commissioning.

WHS Committee

Towards the end of Construction




Phase 4: Decommissioning Phase

Prior to the demobilisation of the contractor, a final Decommissioning risk assessment will be conducted with the WHS Committee, which will involve representation from the contractor, Adani and other experts required for advice on complex or high risk areas.

WHS Committee

Towards the end of Construction



3.23.2 Hazard and Risk

The purpose of this section is to ensure all risks related to the Project will be managed in accordance with this Integrated Risk Management Plan (IRMP). Through implementing a risk management process for the development phases (conceptual through to decommissioning) further definition to the scope can be factored into the Project WHS planning. Key Project WHS Risk Registers to be completed, as identified in the WHS Framework Plan, are summarised in Table 3-151.

Conceptual WHS Risk Register: This is intended to address the key WHS risks throughout the Project lifecycle at a conceptual level. This Risk Register was completed as part of the EIS development, with the findings outlined in Section 3.23.2.6;

Design WHS Risk Register: This will be coordinated by the Design Team prior to detailed design work being completed. Input will be sought from WHS experts as such needs are identified by the Design Team. The intention of this Risk Register is to ensure that Project design addresses all WHS legal requirements and other leading practice standards. It is also critical that the design adequately considers personnel working with and associated with the elements of the Project being designed;

Construction WHS Risk Register: After the appointment of a contractor and prior to the contractor commencing construction work, the WHS Committee will undertake a workshop to develop a Construction WHS Risk Register. This workshop will be coordinated by the WHS Committee, which will be established with participants from Adani, contractor and key sub-contractors. This Construction WHS Risk Register will consider how the construction will be undertaken, with a particular emphasis on Project transition and interface points with Adani managed operations;

Commissioning WHS Risk Register: Prior to commissioning commencing, the WHS Committee will complete a risk workshop which defines the commissioning and Project handover risks. The Commissioning WHS Risk Register is intended to appropriately consider the safe and organised transition of the Project from construction into operations; and

Decommissioning WHS Risk Register: Prior to decommissioning, Adani will develop a Decommissioning WHS Risk Register with key contractors being engaged to complete elements of the decommissioning. The risk register will focus upon WHS risks associated with decommissioning and eventual closure of the port operations. The Decommissioning WHS Risk Register will be developed through a workshop which will be coordinated by the WHS Committee.

3.23.2.1 Scope of the IRMP

This IRMP applies to the management of all potential risks to the Project throughout its lifecycle. It aims to establish the basic method to be employed and key steps to be followed for managing health and safety risks during the Project phases of conceptual and design, construction, commissioning, operations and decommissioning.

3.23.2.2 Objectives

The ultimate Project goal and objective of the IRPM is zero accidents and incidents during the lifecycle of the Project. To achieve this, the key project and ongoing risk registers outlined in this section will ensure that:



All stakeholders are identified and consulted at all points in the Project;

The Conceptual Risk Register is reviewed by all stakeholders and used as the foundation for other Project risk registers; and

The key documents (including management plans, project plans, scope definitions, engineering designs and studies) are identified and incorporated into all future risk workshops.

Table 3-151 WHS risk register schedule


Phase 1: Conceptual and Design Phases

Design team to incorporate requirements of the relevant Adani Health and Safety Management Plan into a Design Phase WHS Risk Register

Design Team Prior to detailed design work


Prior to construction commencement, a team-based risk assessment will be undertaken using the Conceptual WHS Risk Register and the Design WHS Risk Register as the foundation. This WHS Risk Register will be initiated by the WHS Committee.

WHS Committee


Phase 3: Commissioning and Operational Phases

Following the completion of construction as the Project moves into the commissioning and operational phases, the Operations Handover WHS Risk Register will be coordinated by the WHS Committee. This Risk Register will outline a formal handover program as part of the commissioning.

WHS Committee Towards the end of Construction

Phase 4: Decommissioning Phase

Prior to the demobilisation of the contractor, a final decommissioning risk assessment will be conducted with the WHS Committee, which will involve representation from the contractor, Adani and other expert required for advice on complex or high risk areas.

WHS Committee Towards the end of Construction

3.23.2.3 Ongoing Risk Assessment

In addition to the Project Risk Register, Adani will utilise a three tier risk assessment process to support the ongoing risk assessment of tasks. These risk registers will be adopted by the contractor and other contractors throughout the Project lifecycle:

Tier 1- The ‘SLAM Process’ (Stop, Look, Assess and Manage)

All workers will utilise the SLAM process as a base level ‘behavioural risk’ tool for all tasks. Where the SLAM process is considered inadequate in evaluating the hazards and controlling risk, and in the absence of a prescribed way of work (e.g. work procedure, Australian Standards), the risk management process will be escalated to a tier 2 risk assessment process.

Tier 2- Job Hazard Analysis (JHA)

The purpose of the JHA is to formally gather the information associated with the Job Steps; to ascertain what could go wrong; what are the barriers or controls (if any) that are in place; and what is the assessed level of magnitude of the risk associated with the hazards.



Tier 3- Broad Brush Risk Assessments (BBRA)

BBRAs are conducted for high level site HSE risks, including catastrophic hazards. BBRAs are reviewed and updated annually. Note: BBRA follow a different risk assessment matrix and procedure to the first 2 tiered risk assessment processes. Other high level risk assessments may be required for complex work and processes (e.g. hazard and operability study (HAZOP) for a ‘one off’ construction project).

3.23.2.4 General Principles of Risk Assessment

To ensure that significant risks are managed effectively, all risk registers will:

Be an integral part of the decision making process;

Be systematic, structured and timely;

Be based on the best available information;

Take human and environmental factors into consideration;

Be transparent and inclusive; and

Facilitate continual improvement and strive to reduce risks to as low as reasonable practicable.

3.23.2.5 Organisation, Roles and Responsibilities

Table 3-152 below outlines the specific roles and responsibilities for risk assessments and risk management for the Project.

Table 3-152 Description of roles and responsibilities

Title Role Responsibilities

Senior Management

The Adani and contractor Senior Management team is committed to implementing and enforcing risk management processes and procedures.

Defining and endorsing risk management systems; Concur with the risk indicators; Providing sufficient resources for risk

management; Ensuring legal and regulatory compliance.

Managers and Supervisors

All Adani and contractor managers and supervisors are responsible for ensuring that risk management processes defined in this plan are effectively implemented. Each manager has overall accountability for managing risks and opportunities for their respective workplaces.

Ensuring that all risks in their specific areas are identified, assessed and treated;

Ensuring that risk action plans for treating identified risks are implemented;

Ensuring staff have the skills and expertise for risk management activities in their areas of responsibility;

Submitting regular risk reports to senior managers, and keeping them informed about the implementation risk management activities; and

Ensuring the health and safety of employees and other persons at the workplace.

3.23.2.6 Risk Analysis Process

Risk analysis will incorporate consideration of the causes and sources of risk, consequences and the likelihood that those consequences will occur. The Risk Profile, Likelihood (Table 3-153) and Consequence (Table 3-154) charts will be used as the risk analysis and evaluation tool. Applying the Risk Profile (see Table 3-155) will provide an initial view of the significance of the identified risks (initial rating).



Table 3-153 Risk likelihood

Likelihood Rating Interpretation

Almost certain Occurs on average 10 times a year across the operation Likely Occurs on average once a year across the operation Possible Is considered to be a 1 in 10 year event across the operation Unlikely Is considered to be a 1 in 100 year event across the operation Rare Is considered to be a 1 in 1000 year event across the operation

Table 3-154 Risk consequences

Consequence Safety

Disastrous Multiple fatalities Serious Single fatality Significant Injury with permanent disability Minor Injury with lost time Negligible First aid treatment

Table 3-155 Risk assessment profile

Maximum Reasonable Consequence

Negligible Minor Significant Serious Disastrous

Like

lihoo

d

Almost Certain 11 16 20 23 25

Likely 7 12 17 21 24

Possible 4 8 13 18 22

Unlikely 2 5 9 14 19

Rare 1 3 6 10 15

The risk evaluation process will consider the Project priorities and requirements and risk control measures to revise the ‘inherent’ risk ratings to ‘revised’ or ‘residual’ ratings that are agreed by all stakeholders. This will provide an indication of the importance of controls and a guide to the areas where monitoring of controls may be important.

Where possible, a risk control or treatment will be identified and implemented. Control will be assigned to all high level risks. The main objective of risk management will be to deal with risks before they occur, however contingency plans will be developed for major risks in the event they do occur.

3.23.2.7 Risk Treatment Options

The following hierarchy of controls will be incorporated when selecting a risk treatment in all Project and ongoing risk assessment processes:

1. Elimination- removing the risk altogether is the best option. Permanent solutions that are not dependent on compliance will be selected over compliance dependent solutions, and include:

a. Using different equipment

b. Adopting a different method

c. Using a different supplier or contractor



d. Working at a different time

2. Substitution- where the risk cannot be eliminated, an alternative lower risk option will be considered;

3. Application of engineering controls- where the risk cannot be eliminated or substitutes, engineering controls will be considered; and

4. Application of administrative controls- administrative controls will be applied to all identified risks.

3.23.2.8 Reducing or Mitigating Risk

The level of risk will be reduced by addressing the likelihood of the risk occurring and the consequences of the risk occurring, or both.

Methods that will be used to reduce the likelihood and consequence from inherent to residual risk include:

Audit and compliance;

Engineering;

Behavioural change

Inspection and testing;

Administrative controls;

Supervision by appropriately qualified and experienced personnel;

Contingency planning;

Contract administration;

Engineering;

Separation or relocation; and

Disaster recovery plans.

3.23.2.9 WHS Conceptual Risk Register

A WHS Conceptual Risk Register was completed during the conceptual phase of the Project. This Risk Register (see Appendix C2) identifies what are considered the significant risks as well as the control measures required to reduce these risks as well as the control measures required to reduce these risks to as low as reasonable practicable in accordance with the process outlined above.

The Conceptual Risk Register was undertaken on a desktop basis, and given that controls are yet to be implemented, all risks are assessed as inherent risk only. Key findings from the risk register are outlined in the following sections.



3.23.2.10 Design Phase

There are a number of Codes of Practice and Australian Standards that will need to be incorporated into the design, and the key controls focus on ensuring that these requirements are considered in the design. It is also critical that design meet the requirements of Adani Health and Safety Management Plan, which will be considered by the design team as compliance requirements for the design work.

3.23.2.11 Construction

All construction risks concerning infrastructure, vehicle operation, contractor management, rail operations, marine operations and installation were identified as significant. The key controls focus on appointing a qualified contractor, ensuring periodic audits and assessments are undertaken, ensuring training programs are effectively implemented and adhering to key management plans and standards.

A number of Australian Standards, Legislation, Codes of Practice and Adani Health and Safety Management Plan will form compliance obligations for the contractor and the key sub-contractors, which will be audited and assessed throughout the construction phase in accordance with the requirements of the WHS Framework Plan.

3.23.2.12 Commissioning and Operations

The commissioning and operational phases are the transition activities, which involve the transfer of accountabilities from the contractor to Adani. Significant risks identified in the commissioning and operational phase relate primarily to rail unloading, ship loading, operation of machinery, work at heights and confined spaces work. The key controls focus on competency, procedures, audits and inspections and ensuring a robust handover process is organised in accordance with the WHS Commissioning Risk Register.

3.23.2.13 Decommissioning

Decommissioning does not represent a significant risk at this stage at it will be scoped out in closure and decommissioning plans prepared by Adani during the operational phase.

3.23.2.14 Risk Monitoring and Review

Regular reviews of the risk register will be undertaken in accordance with the Project progress, with the next assessment scheduled to occur prior to detailed design. The outcome of risk reviews will result in the generation of Risk Action Plans and revision of the Risk Register.

Risk monitoring will be an agenda item on management meetings. The Risk Register may be used as a review tool. The focus of risk monitoring will be high level risks. The progress and effectiveness of risk treatment actions will be reviewed and adjustments to Risk Action Plans will be made as necessary.

3.23.2.15 Reporting

Managers and Supervisors will report on the current status of risks for which they are responsible. The style and frequency of reporting will be established by Senior Management.



3.23.2.16 Conclusion

The risks assessed for the construction and operation of the Project are considered to be common activities at existing coal terminals and are subject to the same legislative obligations and controls.

There are a number of Codes of Practice and Australian Standards that will need to be incorporated into the design, and the key controls focus on ensuring that these requirements are considered in the design.

All construction risks concerning infrastructure, vehicle operation, contractor management, rail operations, marine operations and installation were identified as significant. The key controls focus on appointing a qualified contractor, ensuring periodic audits and assessments are undertaken, ensuring training programs are effectively implemented and adhering to key management plans and standards.

The commissioning and operational phases are the transition activities, which involve the transfer of accountabilities from the contractor to Adani. Significant risks identified in the commissioning and operational phase relate primarily to rail unloading, ship loading, operation of machinery, work at heights and confined spaces work. The key controls focus on competency, procedures, audits and inspections and ensuring a robust handover process is organised in accordance with the WHS Commissioning Risk Register.

Decommissioning does not represent a significant risk at this stage with this being further scoped out in closure and decommissioning plans which will be prepared by Adani during the operational phase.

Adani will ensure that the risk analysis procedure is implemented where necessary throughout the entire life of the Project. Reporting on near misses, incidents and any other important hazard and risk issues will be undertaken at appropriate intervals.


To minimise the potential hazards and risks to the safety and health of on-site and off-site personnel as a result of Project related activities from construction and operation of the Project, Adani will:

Construct infrastructure under a formal IRMP in accordance with the requirements of all relevant legislation;

Undertake the operations of the coal Terminal under a formal IRMP in accordance with the requirements of all relevant legislation;

Monitor and amend the IRMP on a frequent basis to ensure its applicability and currency is maintained through the life of the Project; and

Frequently liaise with internal and external WHS personnel in regard to the maintenance and improvement of the IRMP.



3.23.3 Emergency Response Plan

The purpose of this WHS Emergency Response Plan (ERP) is to protect the health, safety and welfare of all employees, contractors and visitors.

This document provides guidance, details responsibilities and the key communication processes for effective emergency management on the Project. This document will be supported by the Adani ERP.

3.23.3.1 Scope

This ERP covers critical WHS emergencies associated with the Project, and details the arrangements to control and coordinate an effective emergency response. The WHS Conceptual Risk Register completed for the Project determines that the construction and commissioning phases require processes to manage emergency response, and therefore these two Project phases are considered in the scope of this plan. No emergency situations were identified as part of the conceptual and design phases, and therefore these phases are not considered as part of this plan.

The Project construction and commissioning phases will be under the control of a contractor company who will provide their own ERP. This ERP outlines the key emergency scenarios to be included in the contractor ERP, as well as the key requirements for the contractor to consider in its development.

3.23.3.2 Relevant Legislation

The following legislation and standards are considered relevant in the development of this ERP:

Disaster Management Act QLD 2003;

Ambulance Service Act QLD 1991;

Fire and Rescue Service Act QLD 1990;

Maritime Safety Queensland Act 2002;

Maritime Transport and Offshore Facilities Security Act 2003; and

Maritime Transport and Offshore Facilities Security Regulation 2003.

3.23.3.3 Roles and Responsibilities

Table 3-156 below outlines the specific roles and responsibilities for the WHS ERP.

Table 3-156 WHS ERP roles and responsibilities

Title Roles and Responsibilities


Endorse the contractor ERP; Provide resources to enable this plan to be implemented; and Appoint an Emergency Controller

Contractor Senior Management

Develop the contractor ERP, addressing the process and requirements of the ERP and by consulting with APT Senior Management;

Test the contractor ERP; and Communicate and circulate the ERP, to ensure Project personnel understand the key

requirements.



Title Roles and Responsibilities

Contractor Emergency Controller

The Emergency Controller is responsible for providing a structure and processes that ensure the following: Ensure that this WHS ERP is implemented; and Coordinate response on-site until the arrival of Emergency Services. In addition, the Emergency Controller will: Act as liaison officer with Emergency Services and neighbouring tenants; Assist in ensuring the Company ERP is reviewed annually or whenever there is significant

change that has the potential to affect the currency of the plan; Assist with the development, communications, monitoring and review of the ERP; Ensure an contractor Area Warden or another officer has delegated responsibility for, and

authority as “deputy” or “backup” to the appointed Emergency Controller position in his/her absence;

Control and coordinate as appropriate the activities of individuals/ agencies (other than Emergency Services) at the site in the event of an emergency;

Monitor operations controlled by Emergency Services and maintain liaison; Ensure that the site perimeters are established in accordance with the Company Project

Management Plan and that access to the site is “controlled”; Ensure that individuals/ groups attending on-site emergencies are escorted and briefed

on-site about the location and extent of emergency and other related issues; Designate equipment/ personnel assembly areas, marshalling areas, briefing area,

evacuation assembly area, for use in emergencies; and Contact and alert the Emergency Services and neighbouring tenants that are likely to be

impacted by the event. Contractor Area Wardens

Contractor Area Wardens will be appointed to have responsibility for provided a structure and process to ensure the following: Assist with the development, communication, monitoring and review of the Company

ERP; Act as liaison officer of specific Works Zone to the Emergency Controller when required;

and Be available to act as ‘deputy’ or ‘back-up’ to the appointed Emergency Controller in

his/her absence. Contractor Workplace Health and Safety Manager

Coordinating the development, communication, monitoring and review of the ERP; Ensuring the ERP is reviewed following major incidents and training exercises; Documenting emergency and incident response, conducting investigations, amending

plans and procedures and preparing reports; Ensuring emergency response training is kept current; Ensuring that all emergency response infrastructure and equipment is fit for purpose and

maintained within the appropriate timeframes; and Managing external contracts relating to emergency infrastructure.

Managers and Supervisors

Ensure that all emergency response infrastructure and equipment in the area their under control is fit for purpose and maintained within the appropriate timeframes; and

Ensure that all issues that have contributed, or may contribute, to an emergency situation are addressed effectively and controls implemented.

Project Employees and Contractors

Comply with the requirements of the ERP; Actively participate in emergency response training; Promptly report any incidents or ‘near misses’ that may contribute to an emergency

situation; and Report any deterioration or damage to emergency response infrastructure that may

impact on its effectiveness.

3.23.3.4 Types of Emergencies

Emergency situations that may occur during the Project include:

Fires;

Medical emergencies;



Civil disorder and site invasion;

Natural events such as severe weather and storm surges, cyclones, storm damage, flood and earthquakes;

Hazardous substance and dangerous goods incidents;

Structural instability or collapse;

Bomb threats (including phone and written threats, suspicious packages and letter bombs);

Explosion;

Gaseous release;

Collision including between marine vessels, rail vehicles and road vehicles;

Terrorism; and

Public safety issue.

3.23.3.5 Prevention

Carefully planned and controlled execution of the Project WHS system is paramount in preventing emergency situations from arising, including the following elements:

Ensuring that adequate planning is undertaken, including appropriate risk assessment;

Ensuring that appropriate control measures are implemented and maintained;

Complying with all legislative and industry requirements;

Complying with all applicable internal project system procedures;

Developing and complying with the requirements of a WHS Management Plan; and

Complying with the requirements of this Plan.

3.23.3.6 Risk Assessment

The Conceptual Risk Register completed for the project identifies risks and the required controls to reduce the risks to as low as reasonably practicable. This risk register will be reviewed in consultation with stakeholders during the course of this project in accordance with the Adani WHS Framework Plan, which will ensure that all emergency scenarios are identified as the detailed design and construction program is further defined. Through careful planning of work and through applying the WHS Management System, the project will ensure the likelihood of each emergency situation is minimised.

3.23.3.7 Preparedness

3.23.3.8 Overview

Prior to construction commencing, preparations for potential emergencies will be made by the contractor. The following considerations must be addressed by the contractor:

Developing and implementing procedures and incident and emergency protocols;



Providing adequate and ongoing training for project personnel;

Conducting desktop and field exercises;

Regular auditing of construction activities;

Ongoing and effective communication;

Ongoing liaison with emergency service agencies;

Identifying resources and equipment required for effective emergency response;

Maintaining documentation to ensure that potential incidents or emergencies can be properly managed;

Conducting ongoing compliance checks.

The continued review, as defined in Section 0 (WHS Framework Plan).

3.23.3.9 Training

All Project personnel will receive basic training regarding the prevention, planning, response to and recovery from incident or emergency, which will be incorporated into the Project induction. Specific training regarding safe planning of works to prevent such occurrences includes:

Training in the contents of this plan;

Training in responses required for medical emergencies;

Specific training provided for work performed in the vicinity of in ground service;

Preparation of method statements, detailing key risks and required control measures;

Daily toolbox meetings to discuss specific work related risks and required control measures;

Training in all necessary project quality system requirements;

Training in Incident and Emergency Communication Protocol; and

Security awareness and boundary surveillance training.

3.23.3.10 Resources

Resources and equipment will be located at the Project area to enable prompt response and effective management of incidents or emergencies.

During construction and commissioning phases, such resources and equipment will be made available by the contractor.

3.23.3.11 Adequate Numbers of Trained First Aid Personnel

The number of trained First Aid personnel available on-site will be, as a minimum, as per legislative requirements. In addition, if required and identified during project risk assessment, extra qualified and trained First Aid personnel will be made available on the Project.



3.23.3.12 Fire Fighting Equipment

Fire fighting equipment will include appropriate fire extinguishers located in all workshop areas, amenities, and main offices and on major plant and fuel storage areas.

The fire extinguishers shall be of the appropriate type and positioned at pertinent locations with unrestricted accessibility. This equipment shall be colour coded in accordance with the relevant standards and situated with signage and guides for usage. This equipment should be tested 6 monthly by an appropriately accredited service provider.

Hose outlets, valves and water supply sources are to be compatible with local fire unit equipment, with testing on mains hydrants scheduled annually.

All fire-fighting equipment shall be demarcated to establish clearance areas to enable clear and effective access to the equipment in the event of an emergency.

All emergency response team members (as a minimum) shall be instructed in the use of the fire extinguishing equipment within one month of commencing employment, and thereafter at periods not exceeding 12 months, in accordance with the prescribed requirements by an appropriately accredited provider. The detail of this training is to be recorded.

3.23.3.13 Emergency Exit Lighting

Emergency Exit lighting shall be situated where it is most effective in directing staff to an appropriate exit. All emergency exit lighting is to be in accordance with the relevant Australian Standard and tested annually.

3.23.3.14 First Aid Kits and Rescue Equipment

First Aid and emergency rescue equipment, including chemical showers and eye baths, shall be located within an area of easy accessibility to enable prompt and effective treatment when required. The effectiveness of the First Aid process will be reviewed on a regular basis.

First Aid and rescue equipment shall be checked regularly and re-stocked after use. Mobile transportable First Aid kits and First Aid equipment will be made available on all vehicles.

3.23.3.15 Material Safety Data Sheets

Material Safety Data Sheet (MSDS) files on all chemicals and hazardous substances used on-site will be placed at easily and readily accessible locations and regularly updated.

3.23.3.16 Location of Emergency Command Post

The project office will be the designated Emergency Command Post, from which all emergency activities are to be directed.

General

3.23.3.17 Response

The response stage of this WHS ERP details incident and emergency procedures to be provided by the contractor as part of the construction and commissioning phases. It also provides the protocol for notifying appropriate authorities following the occurrence of an incident or emergency, which will be adhered to by the contractor. The minimum requirements for emergency response



procedures, which will be provided and implemented by the contractor, are also detailed in Section 3.23.3.8 of this plan.

3.23.3.18 Activation of Response Plans

The arrangements detailed in this ERP will be activated by either the Emergency Controller of the relevant contractor Area Warden from the contractor, in consideration of the following:

Safety of personnel, and preventing further injury or damage;

Communicating in accordance with communication protocol;

Type of emergency;

Number of injured persons; and

First aid and emergency resources required.

The contractor Emergency Controller will activate this plan when:

The Emergency Controller has received confirmed reports from any source that an emergency has occurred;

The Emergency Controller has been notified that an emergency in an adjoining area is likely to impact on Company controlled area; or

The Emergency Controller has received advice of an impending emergency.

The Company contractor Area Warden/s will activate this plan when:

The contractor Area Warden has been notified by any Company employee that an emergency has occurred; or

The contractor Area Warden has received advice of an impending emergency.

3.23.3.19 Stages of Activation

Outlined below in Table 3-157 are the various stages of activation of this Emergency Response and Incident Management Plan.

Table 3-157 Stages of activation

Phase Action

Alert Contractor Emergency Controller or contractor Area Warden receives advice of an emergency or incident from either employees, visitors, neighbours, community or through general observation.

Callout Emergency Controller advises emergency services that assistance is required.

Debrief Emergency Controller debriefs contractor Area Wardens and Company emergency response personnel; and

Emergency Controller to investigate and review ERP for its adequacy. 3.23.3.20 Warning

The contractor Area Warden will advise the contractor Emergency Controller (and vice-versa) of any incident or event which apparently has the potential to escalate into an emergency or may



require the support of additional resources (including support from the Adani Emergency Response Team) and in particular any incident involving hazardous or dangerous goods.

Overall responsibility of contacting emergency services, Harbour Control and other functional areas within the site lies with the contractor Emergency Controller. However, the contractor Area Wardens can also contact the emergency services in the case of an emergency and as per directions from the contractor Emergency Controller.

Responsibility of contacting and advising neighbouring communities lies solely with the contractor Emergency Controller.

3.23.3.21 Evacuation

The contractor Emergency Controller (in consultation with the contractor Area Wardens, if required) will determine the need for evacuation. When it is agreed that the evacuation is necessary, the contractor Area Wardens will be in charges of evacuating personnel from their respective area to the designated Assembly area.

Even though the contractor Area Wardens are responsible for evacuation of their respective areas, the contractor Emergency Controller will control and coordinate the overall evacuation process.

In the event of an emergency such as fire, gas leak, flood, earth tremor, civil disturbance or bomb threat occurring, and the following steps shall be taken by contractor Emergency Controller and/or contractor Area Wardens:

1. Danger- Perform a quick assessment;

2. Rescue- If safe to do so;

3. Alarm- Alert all persons in the immediate area;

4. Contain- If safe and trained to do so; and

5. Evacuate.

3.23.3.22 Danger and Rescue

Perform a quick assessment to identify risks. This step covers initial site risk assessment and initial actions only (see Table 3-158);

Assist persons in immediate danger, if safe to do so;

Remove people from immediate danger, if safe to do so; and

Summon the first aid officer if persons are injured.

Table 3-158 Initial danger risk assessment

Assessment Response

Am I in danger? Remove yourself from danger; and Do not do anything that will place you in danger.

Are others in danger? E.g. Workmates, visitors, public

Do what you can to assist or remove other form danger without placing yourself in danger; and

Administer first aid (where necessary). Is the environment affected? Protect the environment where possible; and

Contact the Environment Manager.



3.23.3.23 Alarm

Alert all persons in the immediate area; and

Notify the Emergency Controller and other senior Project Management Staff.

3.23.3.24 Contain

Contain the risk if it is safe to do so and you are trained to do so;

In case of a small fire, assess if safe and contain fire (be aware of dangerous fumes) and use correct fire extinguisher; and

Shut down all flammable equipment. If possible move vehicles and plant out of area.

3.23.3.25 Evacuate

The incident area will be evacuated if appropriate;

The contractor Area Warden must immediately, if there is a dangerous situation like a fire or gas leak, suspicious object, or bomb threat, lead all staff, visitors and contractors to the nearest Assembly area; and

If possible shut down all equipment and move vehicles / plant out of area.

3.23.3.26 Communication Protocol

In the event of an incident or emergency the Emergency Controller will contact the following personnel as appropriate in the circumstance:

Adani Emergency Services;

Relevant Emergency Services;

First aid personnel;

Senior Project Staff;

Harbour Control;

Contact Agencies as appropriate; and

Government agencies as appropriate.

Recovery, Debrief and Corrective Action

3.23.3.27 Recovery

Senior project personnel will form the recovery group to formulate the required actions to enable activity to return to normal as quickly as possible. Sufficient consideration must be given to the recovery actions to be implemented, to ensure that they are effective and suitable.



3.23.3.28 Debrief and Review

Debriefing of the incident will include review by the recovery group and other senior project staff (as deemed necessary by the recovery group). Debriefing of an emergency will include review by the recovery group and representatives from the Port Emergency Committee.

The recovery group will review of the contents of this plan:

Following each moderate incident or emergency;

Where significant changes occur to the scope of construction;

Where WHS Management Systems are significantly altered;

Where significant changes to agreed planned arrangements occur; and

Every six (6) months.

3.23.3.29 Corrective Action

Contractor Area Wardens responsible for specific areas in the project will work in consultation with the contractor HSE Coordinator to manage the development and implementation of corrective action as applicable to incidents which occur in the specific areas of their responsibility.

Managers and Supervisors are directly responsible for ensuring that agreed corrective actions are implemented in a prompt manner and are primarily focussed on preventing a similar event from recurring.

3.23.3.30 Records

All records produced from an investigation into an incident or emergency or relevant to the same will be stored in the document management system.

3.23.3.31 Emergency Response Procedures

Emergency response procedures shall be prepared by the contractor in accordance with the requirements of this Conceptual Emergency Response Plan and aligning to the APPT Emergency Response Plan. In accordance with Adani WHS Framework Plan above, these plans shall be submitted to Adani prior to the commencement of construction work on the project. The requirements for each of the major emergencies identified in the Conceptual Risk Register are presented below in Figure 3-112 to Figure 3-121.



Figure 3-112 General evacuation flowchart

GENERAL EVACUATION FLOWCHART

Evacuation Required

Secure area and plant if safe to do so

Rectify / Fix Problem

Secure area and plant if safe to do so

Remain at Evacuation point for further instruction

Assemble at Evacuation Point for further instructions and

account for all personnel

• Investigate • Report • Review adequacy of ERP

YES NO

Emergency situation identified

Notify closest Supervisor / Area Warden

Ensure all personnel are alerted of the impending Emergency

Contact contractor Emergency Controller, inform / brief and await further instruction.

• Emergency over • All Clear Given • Return to work



Figure 3-113 General medical emergency flowchart

Assess Incident

Notify Supervisor

Render Immediate First Aid if necessary

Major Incident Minor Incident Type of Incident

Contact contractor Emergency Controller/Emergency Services

• Prepare for evacuation • Instructions from Emergency

Controller/Area Warden

Emergency Services to take control once on-site and treat injured people

Supervisor to accompany injured people to hospital

Secure the relevant area

• Investigation • Reporting • Rehabilitation

After assessment return to work

Injured person to First Aid room for further treatment

GENERAL MEDICAL EMERGENCY FLOWCHART



Figure 3-114 Emergency response procedure- first aid

First Aid incident on-site

Injured Worker reports injury to Supervisor and attends First Aid

If employee is trained and it is safe to do so, control the situation/secure area immediately with available and correct equipment. If not, immediately notify Supervisor.

Supervisor notifies First Aid Attendant of injury.

First Aid Attendant provides first aid and records in Register of Injuries

Injured Worker returns to work

Injured Worker informs Supervisor of first aid injury and seeks first aid.

If able to do so, injured worker’s Supervisor to notify First Aider that injured worker is seeking first aid treatment.

First Aid treatment given and details recorded in Register of Injuries. Injured Worker to sign the Register of Injuries.

Injured Worker resumes normal work where it is safe to do so or suitable alternative duties.

EMERGENCY RESPONSE PROCEDURE-FIRST AID

Scope: This emergency response procedure details the procedure to be followed in the event of first aid being required.

Supervisor to advise Zone WHS Coordinator of injury

Supervisor to complete the relevant incident report forms and Incident investigation records as requested by the Health and Safety Coordinator

Supervisor to follow incident reporting guidelines

Ensure all incident report forms required are fully completed.



Figure 3-115 Emergency response procedure- public safety

Unauthorised site access by member of the public

Supervisor to conduct investigation to determine identity of persons and reason for entering work zone.

Staff to advise Supervisor of any unauthorised person(s) on-site.

Supervisor to contact Area Warden if unable to relocate unauthorised persons.

Area Warden to contact Emergency Controller if unable to relocate unauthorised persons.

Emergency Controller to contact Police and have unauthorised person removed from site.

Supervisor to approach any unidentified persons to determine their identity and purpose for being in the work zone and if the access is unintended escort the person(s) off the site and out of danger.

Area Warden with Supervisor to approach unauthorised persons and arrange to escort the person(s) off the site and out of danger.

Emergency Controller to conduct incident investigation/ route cause analysis and develop and implement necessary actions to prevent reoccurrence.

Emergency Controller to brief Police, providing information regarding unauthorised person(s) and details of incident sequence of events.

EMERGENCY RESPONSE PROCEDURE-PUBLIC SAFETY

Scope: This environmental spill response procedure details the procedure to be followed in the event that a member of the public gains unauthorised access or an incident occurs in a work zone. Possible scenarios include:

• Unintended or unauthorised access to Abbot Point project area • Interaction with mobile plant • Incident involving public amenities • Breach of perimeter fence or physical barriers • Motor vehicle/recreational craft incident

Emergency Controller to investigate the circumstances giving rise to the breach of the Abbot Point work zone and inform Senior Management of outcome.

Emergency Controller to complete the relevant incident report forms and records as required.

Emergency Controller to Communicate outcome of incident investigation to Project Director/Zone Managers/OHSandE Manager/Safety Committee and other relevant authorities.

Ensure all incident report forms required are fully completed.



Figure 3-116 Emergency response procedure- land based fire

If safe to do so, Area Warden to ensure fire is controlled using available resources and equipment.

Fire on-site

Notify Supervisor and/or Area Warden

If employee is trained and it is safe to do so, control fire immediately with available and correct equipment. If not, immediately notify Manager / Supervisor

Area Warden to ascertain the extent of fire and notify Emergency Controller

Emergency Controller to decide if evacuation is required and contact emergency services

If required, Emergency Controller to notify neighbours

If ordered to evacuate, all personnel to proceed to the designated assembly point.

Emergency controller to hand control to the attending Emergency Services

Receive ‘All clear’ notification from Emergency Services and inform Area Wardens to return to work

Provide details regarding location and extent / nature of fire if known Manager / Supervisor to investigate to determine the extent and nature of the Emergency

Does the emergency potentially affect other site zones? Use designated emergency radio channel to notify Managers / Supervisors in other relevant zones, and contact Emergency Controller Determine source of fire, restrict access, and contain fire if safe to do so.

Emergency Controller to liaise with Area Warden to determine if an evacuation is required.

Area Warden to notify all staff, contractors and visitors of the evacuation in relevant works zone by making an announcement on the designated emergency radio channel and operating fire alarm if applicable

All personnel to evacuate to designated assembly points. Area Warden to maintain communications with the Emergency Controller to ensure all Employees, Contractors and Visitors are accounted for.

Brief the Emergency Services, providing information regarding unaccounted for Staff, Contractors and Visitors. Employees to act on and relay instructions to Emergency Controller.

EMERGENCY RESPONSE PROCEDURE-LAND BASED FIRE

Scope: This emergency response procedure details the procedure to be followed in the event of fire on-site.

Initiate recovery and reporting

Debrief / review process

Emergency Controller receives ‘All Clear’ from Emergency Services, and relay to Area Wardens

Initiate Recovery, Reporting and Notification processes (as required) according to local procedures and regulations.

Participate in Emergency debriefing exercise (review adequacy of ERP): Site-wide: Emergency Controller, Area Wardens and relevant local Managers / Supervisors Zone-specific: Area Warden, relevant local Managers / Supervisors

If no evacuation, Proceed per Emergency Controllers direction



Figure 3-117 Emergency response procedure- hazardous substances/ dangerous goods incidents/ explosion


Explosion / Hazardous Substances / Dangerous goods incident on-site


If employee is trained and it is safe to do so, control situation immediately with available and correct equipment. If not, immediately notify Manager / Supervisor

Area Warden to ascertain the extent of emergency and notify Emergency Controller






Provide details regarding location and extent / nature of emergency if known Manager / Supervisor to investigate to determine the extent and nature of the Emergency

Does the emergency potentially affect other site zones? Use designated emergency radio channel to notify Managers / Supervisors in other relevant zones, and contact Emergency Controller Restrict access to site of incident if safe to do so.





EMERGENCY RESPONSE PROCEDURE-HAZARDOUS SUBSTANCES / DANGEROUS GOODS INCIDENTS / EXPLOSION

Scope: This emergency response procedure details the procedure to be followed in the event of an explosion or a hazardous substance / dangerous goods incident on-site.









Figure 3-118 Emergency response procedure- natural disaster/ storm


Natural disaster / storm affecting site


If employee is trained and it is safe to do so, control situation immediately with available and correct equipment. If not, immediately notify Manager / Supervisor

Area Warden to ascertain the extent of emergency and notify Emergency Controller






Provide details regarding location and extent / nature of emergency if known Manager / Supervisor to investigate to determine the extent and nature of the Emergency

Does the emergency potentially affect other site zones? Use designated emergency radio channel to notify Managers / Supervisors in other relevant zones, and contact Emergency Controller Restrict access to site of incident if safe to do so.





EMERGENCY RESPONSE PROCEDURE-NATURAL DISASTER / STORM

Scope: This emergency response procedure details the procedure to be followed in the event of a natural disaster / storm affecting area.









Figure 3-119 Emergency response procedure- vehicle collision


Plant / vehicle collision on-site


If employee is trained and it is safe to do so, control situation / secure area immediately with available and correct equipment. If not, immediately notify Manager / Supervisor.

Area Warden to ascertain the extent of incident and notify Emergency Controller






Provide details regarding location and extent / nature of emergency if known. Manager / Supervisor to investigate to determine the extent and nature of the Emergency

Does the emergency potentially affect other site zones? Use designated emergency radio channel to notify Managers Supervisors in other relevant zones, and contact Emergency Controller Restrict access to site of incident if safe to do so.

Emergency Controller to liaise with Area Warden to determine if an evacuation is required

Area Warden to notify all staff, contractors and visitors of the evacuation in relevant works zone by making an announcement on the designated emergency radio channel

If safe to do so, Area Warden to ensure incident is controlled / area secured using available resources and equipment.


EMERGENCY RESPONSE PROCEDURE-VEHICLE COLLISION

Scope: This emergency response procedure details the roles and responsibilities in the event of a plant / vehicle collision on-site.




Initiate Rehabilitation, Reporting and Notification processes (as required) according to local procedures and regulations.

Participate in Emergency debriefing exercise (review adequacy of ERP): Site-wide: Emergency Controller, Area Wardens and relevant local Managers / Supervisors. Zone-specific: Area Warden, relevant local Managers / Supervisors




Figure 3-120 Emergency response procedure- bomb threat


Immediately notify Manager / Supervisor, and fill in Bomb Threat Checklist if contacted directly

Manager / Supervisor to investigate to determine the extent and nature of the Emergency: Approximate number of injuries? Notify first aid attendants Is it an emergency? If yes, contact Emergency Services

Does the emergency potentially affect other site zones? Use phone to notify Managers / Supervisors in relevant zones, or contact Emergency Controller by phone if neighbouring terminals are potentially affected. Radio communications are to be suspended in the event of a bomb threat

Area Warden to notify all Employees, Contractors and Visitors of the evacuation in relevant zone by contacting Area Wardens by phone. Do not operate alarm. Suspend radio communications

Area Warden to allocate designated worker to escort emergency services to area from site entrance (or away from site) Emergency Controller required to inform Site Controller of any Emergency situation.

Emergency Controller receives ‘All Clear’ from Emergency Services, and relay this to Area Wardens and ask personnel to return to work

Initiate Recovery, Reporting and Notification processes (as required) according to local procedures and regulations

EMERGENCY RESPONSE PROCEDURE-BOMB THREAT

Scope: This emergency response procedure details the roles and responsibilities of the Employee in the event of a bomb threat to the site.


Bomb Threat received


Area Warden to notify Emergency Controller

Emergency Controller to notify Emergency Services and evacuate personnel from site

Emergency Controller to notify neighbours

Hand control over to attending emergency Services.

Initiate recovery, investigation and review

Receive ‘All clear’ notification from Emergency Services



Figure 3-121 Emergency Response Procedure- land based structural instability or collapse

Structural instability or collapse on-site


Area Warden to ascertain extent of emergency and notify Emergency Controller

EMERGENCY RESPONSE PROCEDURE-LAND BASED STRUCTURAL INSTABILITY OR COLLAPSE

Scope: This emergency response procedure details the roles and responsibilities of the Employee in the event of a structural instability or collapse of a structure on-site


If employee is trained and it is safe to do so, control situation / secure area immediately with available and correct equipment. If not, immediately notify Manager / Supervisor.






Provide details regarding location and extent / nature of emergency if known. Manager / Supervisor to investigate to determine the extent and nature of the Emergency

Does the emergency potentially affect other site zones? Use designated emergency radio channel to notify Managers Supervisors in other relevant zones, and contact Emergency Controller. Restrict access to site of incident if safe to do so.

Emergency Controller to liaise with Area Warden to determine if an evacuation is required

Area Warden to notify all staff, contractors and visitors of the evacuation in relevant works zone by making an announcement on the designated emergency radio channel

If safe to do so, Area Warden to ensure incident is controlled / area secured using available resources and equipment.

Brief Emergency Services, providing information regarding unaccounted for Staff, Contractors and Visitors. Employees to act on and relay instructions to Emergency Controller.




Initiate Rehabilitation, Reporting and Notification processes (as required) according to local procedures and regulations.





Conclusion

Prior to the construction commencing, Adani will develop and implement and ERP. The purpose of the ERP is to define the processes for emergency response for incidents occurring at the Project site. It will be used as a guide for the contractor Senior Management, contractor Team Members and all site personnel. The ERP will form a critical component of the WHS Management System. Separate JSAs will be developed for the safe day to day operation of the Project.


To minimise the potential hazards and risks associated with emergencies and natural disasters, Adani will:

Ensure that all emergency response procedures part of the ERP are compliant with the requirements of all relevant legislation;

Develop and implement an ERP to address all potential site-based emergencies;

Provide flow-charts for various emergency scenarios for safe response; and

Ensure all site personnel are trained and inducted in the various ERP procedures.

Section 3.23 Health, Safety and Risk Management -...

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