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

PRIVATE AND CONFIDENTIAL
FIVE STAR OH & S AUDIT

Indorama Eleme Petrochemical Limited
East West Express Way
P.M.B. 5151
Port Harcourt
Rivers State
Nigeria
AUDIT BY: Bob Wallace

DATE OF AUDIT: 16 20 July 2012
REFERENCE NUMBER: FSA/206265
Version 1.0
British Safety Council Five Star Health and Safety Audit Report
British Safety Council 2011
This audit was arranged by Mr U K Chatterjee and conducted on behalf of the British Safety
Council by Bob Wallace.
The auditor would like to take the opportunity to thank all management and staff for their
assistance, 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 organisations health and safety
documentation and systems in relation to the requirements of the British Safety Councils 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
organisations 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 organisations 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.
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 information
supplied by the organisation. The auditor assumes that the aforementioned information supplied
and representations made by the organisation during the audit, on which the report is based, was
current, valid, accurate and complete. The organisation must notify the British Safety Council of
any factual inaccuracies in the report or misinterpretation of information provided by the
organisation as reflected in the report.
The items commented on in this report are limited to areas reviewed during the audit process, and
should not be taken as identifying all areas of possible unsafe conditions and/or contravention of
statutory requirements. Due to the dynamic nature of ongoing activity, the report may cease to be
entirely accurate immediately after being provided to the organisation.
All relevant information contained in this report may need to be disclosed to the organisations
insurers. The contents of the report alone may not be sufficient for their requirements and further
information may therefore be required by insurers. British Safety Council accept no responsibility to
the organisation or their (potential) insurers as a result of inaccuracies in the report arising for
whatever 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 and
Nigerian National Petroleum Corporation, with Indorama holding 80% of the company and
managing 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 the
company.
The company employ expatriate Indian management, with the supervisors and employees being
drawn from the local population. The total number of employees, including catering and
administration support staff is around 1100.
The company is growing annually through investment, with a new plant being commissioned in
2012 and another planned later this year.
SCOPE
The scope of this audit has been agreed between Indorama Eleme and the British Safety Council
and includes the occupational health and safety management systems of the Port Harcourt
Polymer site only, together with all premises and workplace activities under the direct control and
management 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 report
are applicable to the aforementioned areas and activities only.
AUDIT SCORING
The five sections of the audit are divided into fifty seven (57) elements which attract a maximum
numerical value of 5000 points. Wherever an element of the audit is not applicable to the
organisation, it is withdrawn from the audit. The Maximum Accredited Audit Figure (MAAF) is the
maximum 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 Councils numerical safety grading system.
The breakdown of the scoring, together with recommendations where the score falls below the
Maximum 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 CRITERIA
MAXIMUM
ACCREDITED AUDIT
FIGURE
1.
Safety Organisation
1910 Points
2.
Management Control
Systems
1570 Points
3.
Emergency Control Systems
860 Points
4.
Accident / Incident / Near

Miss / Ill Health Reporting
System
250 Points
5.
Workplace Implementation
410 Points
TOTAL:5000 POINTS
ACTION PLANNING
The recommendations against the marked requirements of the Five Star Audit have been
presented in tabulated colour coded format as per the key below:
GRADING SYSTEM TABLE 1: THE FIVE AUDIT SECTIONS
COLOUR CODE
PRIORITY
DEFINITION
HIGH:
Differential over
40% in this area
Recommendations to
be implemented as a
priority 1 action
MEDIUM:
Differential of 1
40% in this area
Recommendations to
be implemented as a
priority 2 action
LOW:
Full marks awarded
Monitor existing
arrangements in this
area to demonstrate
continuous
improvement
NOT APPLICABLE
The requirements of
this section are not
applicable to this
audit
The red coded differential indicates where significant marks (over 40%) have been lost in respect
of the five star audit scoring regime that has been developed to benchmark against current best
practice technique in safety management. Wherever this has been identified by the auditor a
recommendation has been provided that, if followed and implemented, would assist the
organisation in working toward best practice standards.
The amber coded differential indicates where marks have been lost (1-40%) in respect of the five
star audit scoring regime that has been developed to benchmark against current best practice
technique in safety management. Wherever this has been identified by the auditor a
recommendation has been provided that, if followed and implemented, would assist the
organisation in working toward best practice standards.
The green coded area indicates wherever full marks have been awarded in respect of the five star
audit scoring regime that has been developed to benchmark against current best practice
technique in safety management. The organisation must monitor these elements in order to
maintain best practice and demonstrate continuous improvement. The sectional tables are also
designed to allow the organisation to plan for implementation of the recommendations by
populating the relevant columns as appropriate.
If any elements of the audit are not applicable to the audited organisation then this will be left blank
within the relevant table and indicated as N/A.
As with any time bound audit, observations and recommendations made are applicable to the
scope 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.
EXECUTIVE SUMMARY
The primary aim of this audit was to provide an external, independent assessment of the
occupational health and safety management arrangements developed by the client and the
effectiveness of their implementation.
This should provide a benchmark for the organisation so that an action plan(s) can be developed to
further improve and develop these safety management systems.
The organisation has done exceptionally well to achieve this five star grading, which should be
viewed as a realistic measure of where the organisation is at present so that a programme of
monitoring 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
FIVE STAR AUDIT RESULT
MAXIMUM ACCREDITED AUDIT

FIGURE (MAAF) : 5000
FIVE STAR
GRADING
Actual Accredited Audit Figure

(AAAF): 4613
Percentage Achieved : 92.27%
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
1.2
Competent OH&S assistance and management

reporting
100
88
1.3
Management objectives and planning
180
157
1.4
Legal/regulatory compliance
40
40
1.5
Insurance
20
20
1.6
Employee consultation, communication and

involvement
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
1910
1741
TOTAL
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
1570
1449
TOTAL
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
MAAF
AAAF
SECTION 4 : ACCIDENT/INCIDENT/NEAR MISS/ILL

HEALTH REPORTING
(TOTAL MARKS 250)
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
MAAF
AAAF
SECTION 5 : WORKPLACE IMPLEMENTATION

(TOTAL MARKS 410)
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 18001
and ISO 9001 and 14001 audits in 2012.
The health, safety, environmental and quality policy statement of intent (SOI) is signed by the managing
director (MD), Manish Mundra dated April 2011.
All management and many supervisory personnel have access to the company Intranet and the IMS is
held centrally.
The auditor requested several management appointments to demonstrate their knowledge of the IMS
and each knew exactly where to access the relevant information.
Employees and contractors access the policies via notice boards, through induction, training and
briefings 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 is
the 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 when
determining procedures and safety controls. Both have suitable Indian qualifications and significant
industry experience, as do the majority of management appointments, all of whom are degree qualified
in their various fields.
The TD has placed additional pressures on all management through directives and E-mails and also
regular management meetings to promote safety.
The auditor observed the monthly reports from January, March, April and June 2012 and each was very
detailed and comprehensive, allowing all management to understand the company performance and
progression.
The HOS presents to the Heads of Function /Department who attend the central safety committee
meetings and the auditor observed the presentations and minutes from 2011 and 2012. Policies and
performance is reviewed at these meetings also.
The management are appraised against the objectives set annually and the KPIs allocated by the TD.
The Head of HR confirmed all management have safety integrated into their annual appraisals and the
auditor observed those from Olefins and Poly Propylene Plants.
The HOS, TD and senior management review the IMS and performance monthly and the policies and
procedures are supposedly reviewed annually, which makes the fact that the SOI has not been updated
in 2012.
The auditor was informed that each plant Head of Function (HOF) and Head of Department (HOD) are
required 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 management
commitment, 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. These
included the achievement of the British Safety Council 5 star rating, zero lost time injuries and
accreditation to OHSAS 18001 and ISO 9001/14001, along with near miss promotion, audits and
various others numbering 25 in total.
The individual plants also have set targets and objectives to compliment the company objectives. The
auditor 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 set
figures 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 employees
during interviews that the HOF/HOD also promotes safety.
The auditor observed good evidence of suitable resources being made available, through new
equipment, 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, audits
and HOS/Fire Chiefs interaction and training sessions.
The objectives for PPU included training for employees regarding the IMS and procedures, which is also
designed to promote compliance.
The auditor was informed that there are currently no investigations or pending prosecutions by the
regulatory authorities.
1.5
INSURANCE
The company has the insurance required by Nigerian law and their brokers attend site annually to
conduct 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 and
these ambassadors are trained and in regular contact with the HOS.
Many plants conduct safety briefings prior to critical tasks (Polypropylene Plant Offsite Poly Ethylene
Plant) 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 permit
issued 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 completed
correctly (see 2.2).
The HOS has introduced contractor meetings and the auditor observed evidence where individual
plants 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 was
launched in July 2012, but has yet to receive anything so far. The auditor did observe suggestion boxes
in locations, but was shown no evidence of their use.
The HOS issues a significant number of alerts, notices, reports and safety information; the auditor
observed examples of these documents on notice boards across the site.
Employee feedback regarding the interaction and culture within Indorama Eleme was positive with the
exception of PPE, which is dealt with in section 2.
The company issue a quarterly magazine, which includes details regarding company improvements and
performance, 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-mail
dated May 2012 from the managing director, referencing the survey before he sent the results to
Indonesia Group Head Quarters.
1.7
SAFETY MEETINGS
The management and HOS attend the Central Safety Committee meetings and the auditor observed the
minutes from September 2011 and February and June 2012. These minutes had actions allocated with
time frames where appropriate and focussed on the recommendations following the Five Star Audit of
2011.
Safety ambassadors attend a meeting with the HOS which is supposed to be quarterly, but sometimes
is 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 other
senior 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 different
according to what they determine should be discussed.
The auditor would question the quality and value of some safety committee meetings, as the agenda is
consistent 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 detail
within much of the plant minutes and a lack of specific actions to promote improvements in the culture
and 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 attended
training 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 years 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 have
reduced in 2012.
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First aid equipment was observed as easily available in all locations and the equipment is checked
monthly and replenished as and when required by medical centre staff. The auditor observed the
documents 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 location
should 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 and
available for all staff with IT access.
Each plant and department holds a plethora of files and documents applicable to the various equipment
and 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 auditors interview with the Head of HR, it was explained that during each employees
appraisal, they themselves identify the training they believe is required and who should facilitate this
training. 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 and
they then recommend the learning strategy.
The auditor was informed of a new video that has been produced and all personnel entering the plant
will be required to view this film.
All induction training is planned and managed by HR, with the HOS presenting and plant staff then
conducting specific technical training. The auditor observed the records from three sessions of
induction training dated March, April and June 2012.
The HOS manages the refresher training programmes, which he undertakes by E-mailing plant
management to release personnel and this is then reported during the HOD/HOF and HOS meetings
which are attended by the TD. The auditor observed many attendance sheets from 2012, which are
listed in section 6 of this report.
The auditor was informed the managing director also requested training to enhance his management
competence. 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 introduced
Mentoring 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 modular
programme is designed to promote positive behaviours across all disciplines.
As already identified, the company has striven to enhance and improve contractor competence through
seminars (May and June 2012), plant training sessions (Offsite and Poly Propylene Plant) during
briefings prior to activities and assessments of welding proficiency (Inspection Department records
from 2011 and 2012 observed).
The auditor observed a document entitled Initiatives in Employees Training and Development which
shows 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 training
for July to December 2012.
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The completed courses and numbers attending each was also observed fro 2012, which covered all
aspects 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 before
being allowed to start work.
This assessment covers a wide range of functions, including blood and urine. Plant operators also
receive annual medicals which replicate the original assessments to identify any changes. These
annual assessments now include a questionnaire regarding vibration exposure (prior to employment
and current hand and finger conditions). The auditor observed examples from a forklift truck operator
dated 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 right
to access medical treatment on site for those living close enough or through an insurance policy
allowing access at the familys local hospital. Heart and cholesterol health is promoted also.
This insurance scheme is currently under review and another provider is being sourced as the current
provider 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 monthly
report produced by the HOS.
The doctor informed the auditor that alcohol breathalyser equipment has been procured and some
random 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-malarial
programme for long term employees and expatriate Indian staff. There is walk-in clinic availability for all
staff, where any health issues can be addressed.
All drivers and contract forklift operators have their eyesight tested annually and records from 2012
were observed.
The auditor did not observe any evidence that management training to assist their identification of
occupational health issues was continuing.
The auditor was informed that doctors manage all return to work following illness or injury; upon receipt
of the employees doctors or hospital report, the ability of the employee to return to work is assessed at
an interview with the doctor.
Assistance and if required, treatment can be offered on site with the retained physiotherapist or
alterations made to the work patterns or location.
The auditor could not be shown any evidence as there have been no lost time injuries or illnesses
requiring 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 programmes
managed by plant engineers. Some plants have routine condition monitoring (vibration analysis)
programmes also.
15
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 dated
June 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 Propylene
and Offsite dated May and June 2012.
The safety ambassadors are required to regularly walk their locations and the auditor observed the
inspection reports collated by the PPU ambassador for 2012.
During the inspection of the Effluent Treatment Plant, the auditor was informed that the Supervisor also
undertakes a daily walk of the plant and reports only concerns and issues. The operators checklist is
conducted monthly and the auditor observed a selection from 2012, which are then forwarded to the
safety ambassador.
It was during this inspection that a near miss occurred when the Supervisor accompanied the
auditor and the grated flooring over a tank was insecure and he almost fell 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 efforts
of 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 June
2012.
The HOS conducts compliance audits for the permit systems and these results are recorded in the
monthly 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 the
plant 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, with
the HOS monthly report showing discussion and assessment regarding the Cherry Pickers being
purchased for engineering and security departments.
Changes to the plant or process, including introduction of new equipment requires the authorisation of a
number 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 process
regarding 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 who
visited 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 HOF
Commercial 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 through
the site.
1.15 MANAGEMENT OF CHANGE

The company have a specific management of change procedure HSEF 2-317 revision 2 dated
November 2011, which is managed by Technical Services Department.
This procedure requires all management appointments, including HSEF to authorise the proposed
amendments to the process within plant locations. The company has made an average of 60-70
changes 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 project
reviews, including pre-start safety reviews. The auditor selected some projects at random and observed
their records Conversion of the PRF Sphere 31TK2B NGL. This project was planned in February and
March 2011 and pressure test reports produced following the work in March 2012 and a pre-start up
safety 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 that
the HOS would be reporting directly to him from then on.
Temporary change management within the plant areas is managed by the permit system and this
requires a risk assessment if one does not already exist. Several permits and critical task safety
briefings were observed confirming this procedure Poly Propylene Plant dated May 2012 and Poly
Ethylene 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 Contracts
Management procedure EPCL COM/PUR 26301 dated October 2011; an approved contractor list and
a 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-selection
criteria regarding competence and safety performance.
Commercial manage the process and with the exception of current contractors, who are subject to
evaluation by the user department before any contracts are renewed; there is no involvement of the
end user or safety department until after the contractor has been selected. The assessment completed
by 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 following
work 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 user
department to ensure the contractor works safely. The auditor did observe a contract issued to Gios
Nigeria Ltd in July 2012, which included instructions that the first payment would only be made following
induction and safety training by the safety department.
The auditor did observe evidence that a contractor bringing a mobile crane to site had his competence
and the inspection dates of the crane confirmed. Mech Construction Ekens Amaobi certificate of
competence 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.
17
The HOS has facilitated seminars and meetings with regular contractors to promote their safety
awareness and improve competence and understanding of the Indorama Eleme standards and
expectations. 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 instruction
including fire safety and emergency procedures. The auditor observed records dating back to
December 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 contractors
working unsafely. This included:
Cleaning contractors working with highly flammable paint thinners within the main office which had
been issued by their management to assist them in cleaning flooring under the stair well. This is a
reasonably confined area and they were being exposed to toxic and narcotic fumes, also introducing
an explosive hazard into an occupied building.
A gardening contractor not wearing hearing or eye protection when operating a strimmer. Painting and
decorating contractors working on unauthorised scaffold, without the knowledge of the department
management.
Transport contractors using vehicles with unsafe tyres to transport Indorama Eleme employees to and
from work.
Contract vehicles operating on site with unsafe tyres.
Construction workers working on improvised access equipment made of planks of wood, working on
exposed edges where a fall from height risk existed and with poor quality welfare facilities. When the
auditor 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 to
apply 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 hold
their own file of assessments. The auditor observed the files from Offsite, which were all dated June
2011.
Pre-activity safety toolbox talks were held by the management prior to permits being issued and these
covered;
Scaffold erection from January 2012 - Insulation activity dated February 2012 and a Spray Painting
activity dated June 2012.
During the inspection of the tanks in this location, the employees confirmed the presence of snakes in
the longer grass and they would be expected to access some valves occasionally during maintenance
activities, which had no concrete access routes. None of the RAs for Offsite identified snakes as a
hazard.
The RA for access to the overhead crane at PPU was observed which identified scaffolding would be
erected 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 Critical
Task working procedures, which include step by step procedures. The auditor observed that from PP
Plant dated May 2012 to replace a cam clutch and this included photographs for future referral.
18
Files from other locations were observed, most of which were adequate and concentrated upon generic
phrases 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 safe
working 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 senior
management are expected to undertake one observation per month.
The auditor feels this is too low and management commitment should be demonstrated by increasing
the requirement.
19
RECOMMENDATIONS TABLE SECTION 1

SECTION 1 SAFETY ORGANISATION
RECOMMENDATION
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
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
1.3
SAFETY MANAGEMENT OBJECTIVES, PLANNING

AND REVIEW
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
PRIORITY
PERSON
RESPONSIBLE
COMPLETION
DATE
20
1.8
FIRST AID FACILITIES AND TRAINING
1.9
DOCUMENTATION AND INFORMATION CONTROL
1.10
TRAINING
Introduce the requirement to discuss risk

assessments for hazardous activities in
detail review investigations into accidents
and near misses from across the site
training needs and compliance with
programmes inspection reports planned
changes or large scale maintenance
activities for example
Management should attend all meetings,

which can be rotated through HOD/HOF
Each plant should manage its own training

needs analysis process regarding safety
Each plant should formulate its own

programme of attendance at HOS training
sessions. This programme should ensure
all staff attend annual training according to
their needs
The HOS should produce a safety training

programme, which is produced quarterly.
This plan should follow the TNAs conducted
by department management
1.11
OCCUPATIONAL HEALTH PROGRAMME
Conduct training for management to

increase their awareness of potential
occupational health symptoms
1.12
SAFETY INSPECTIONS
HOF and HOD inspections are to be

formally recorded (SMART target)
Use the concerns raised within this report
21
and other issues identified during audits etc,

to formulate checklists for all locations /
departments / activities / equipment etc
1.13
SAFETY AUDITS
Conduct regular training for all personnel

required to inspect the workplace
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
22
1.17
RISK ASSESSMENT AND SAFE WORKING

PROCEDURES
Consider requiring unannounced inspection

and monitoring of Civils contractors
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
23
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 observed
tremendous improvements from 2011.
All electrical hand tools are now inspected by the main workshop personnel and this includes all
contractor tools. The auditor observed records held in the central workshop, with four books holding
the registers of equipment and dates inspected.
During inspections of containers which are utilised by contractors to store equipment, the auditor
identified that all equipment was tagged.
There were some chain saws held by Indorama Eleme engineers that were operated by a trigger
mechanism and this stops the equipment when released. There were some concerns for the auditor
regarding the PPE used. Kevlar thigh and shin guards should be within the legs of the trousers as a
minimum to protect the operator.
Machinery within all workshops were observed as being suitably protected, although there was a
pedestal drill in PE workshop without a mushroom type emergency stop fitted, had no guard fitted
and 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 and
all engineers informed to stop wearing cloth gloves when operating rotating machinery.
Inspection and Instrumentation departments are responsible for ensuring specific equipment is
calibrated and the auditor observed several records from 2011 and 2012.
Unfortunately this very good system does not extend to contractors working for Civils departments as
the auditor observed construction equipment with very poor quality guarding and electrical
connections.
2.2 PERMIT TO WORK SYSTEMS

All maintenance activities within the plant require the control room management to issue a permit to
authorise the task. The auditor observed the records within each plant inspected and in all situations
they were found to be issued according to the procedures.
The HOS undertakes permit audits and the auditor observed records from December 2011 and
January, February, April and May 2012.
All personnel understand the systems, which include contractor activities and personnel and the
auditor 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 safety
controls are in place before the permit is issued and one observed at PPU, was issued at 0815 and
when 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 adequately
monitor strict compliance with risk control measures.
24
2.3 SAFE ISOLATION PROCEDURES AND EQUIPMENT CONTROLS

The company has improved the system since 2011, with the procedures now requiring all disciplines
working 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 their
workshops.
The auditor interviewed several engineers from the plants visited and observed several permits and
tasks which were compliant with this procedure.
During the visit to PPU, an activity was being conducted by a small group of electricians and the
permit (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 apply
to higher voltage and electrical motors / equipment. This activity required the electricians to simply
open 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 their
efforts, 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 padlock
fitted 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 is
employed. The auditor observed the records for the six monthly inspections conducted by supervisors
from 2012.
The auditor was informed by several electrical engineers that all high voltage switching, racking in and
out 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. The
auditor observed the colour coding to denote this years inspection and serial numbers painted on all
equipment.
All scaffolding is issued from central workshops to plant engineers and the procedures require all
scaffolds to be erected by trained personnel, to be inspected by a competent person and green tag
attached 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 had
correct 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 the
auditor identifying a small, low scaffold outside the medical centre without edge protection and safety
tag. 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 element
2.4 above.
The auditor raised concerns in 2011 regarding the access platforms on the overhead cranes in several
locations across the site and there are still some concerns.
As identified in element 1.17, for some activities when undertaking basic inspection and maintenance
on 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.
25
The auditor observed harnesses and lanyards within a storage container in the PE Plant and a
discussion 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 within
plant areas.
The lanyards attached to these harnesses were fall arrest and some activities would be only 3-4
metres above ground / platform level and so offer no protection when working at these heights due to
the 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 the
records showing the quarterly inspections undertaken by fire personnel from 2012.
The auditor did observe training records for working at height and the improved presentation following
the discussions identified above.
There is a hydraulic ladder which was inspected by Lunar Services in February 2012, but was
condemned 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 lower
should the electrical supply fail.
The auditor observed the evidence that departments are to obtain Cherry Pickers later in 2012 and
was informed that the suppliers would conduct the training.
When staff were questioned regarding rescue procedures, all confirmed that the Fire Department
would be called and during the interview with the Fire Chief and officers, this was confirmed. Training
for 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 safely
lower 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 and
all inspections are managed by the Inspections Department.
In all locations visited, the auditor observed no lifting equipment in poor condition and not coloured
yellow.
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 master
copies from April 2012 were observed, conducted by Lunar Services. Inspections hold master
spreadsheets for each department and these were observed by the auditor.
The test loads used by the company when undertaking crane inspections, were also observed as
being 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 (FLTs) are included in the inspection programme and the auditor observed all within
the Bagging Plant as colour coded yellow and stencilled June 2012.
The passenger lifts in the accommodation were inspected by Lunar Services in September 2011 and
March 2012.
26
2.7 PRESURE SYSTEMS AND PORTABLE GAS CONTAINERS

Portable gas container management has been improved since 2011 and the auditor observed all as
secure, stored correctly and only a very small number had poor quality hose connections. All torches
were observed as having flashback arrestors fitted.
As identified in element 1.16, all welders are assessed by Inspections personnel to determine the
quality of their welding and gas cutting competence.
The auditor observed training records regarding MIG welding and safety in gas cutting conducted by
the HOS dated July 2012.
The company has a large number of pressure vessels and the auditor observed the spreadsheets for
equipment held along with the required inspections conducted by Lunar Services in January 2012 for
all 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 records
from 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 auditor
observed the records from 2012 dated May to July.
All FLTs now have suitable mirrors and fire extinguishers fitted and the battery charging area has
been 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 interview
with the doctor.
Training records from 2011 were observed, but the auditor did not observe a specific training schedule
to 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 the
employees and environment.
The HOS conducts airborne monitoring for Benzene, Toluene and VOCs and reports the results within
each months report to management.
Each plant holds assessments for the chemicals they employ, along with training records for the
specialist PPE (if required).
Several chemical hazards were identified and the auditor requested evidence that the material safety
data sheets were available and complied with. These are referenced within verification.
One of the most hazardous locations is the Effluent Treatment Plant, where concentrated sulphuric
acid 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 there
was 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 by
sulphuric acid and they did so correctly.
27
The emergency shower was checked and operated correctly and this is included in the delivery
checklist which is completed beforehand. The auditor observed the folder which held these checklists
and selected several at random for 2012, all of which were correctly completed. The auditor confirmed
with 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 a
result 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 control
equipment, 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 with
chlorine and biocides. The auditor observed the records for the daily analysis of total organic content
and weekly bacteriological content measurements from 2012.
As already identified, the cleaning contractors within the main administration building brought highly
flammable, toxic and narcotic paint thinners in to clean the floors. When interviewed, none of the
cleaning 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 entered
a separate part of the building and the auditor was concerned about the smell which was clearly
evident 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 are
instrumentation equipment held within the process.
The Nuclear License for Silo Probes and Low Pressure Separator Gauge was observed from the
Nigerian Authorities dated December 2010.
The HOS conducts monthly inspections and takes readings to assess exposure to employees and the
results recorded in the monthly reports to management.
Felix Okoson attended the Radiation Protection Officer course in August 2008 with the Nigerian
Nuclear 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 to
sockets, this years audit identified none.
28
2.13 ELECTRICAL INSTALLATIONS AND PROTECTIONS SYSTEMS

The auditor interviewed several engineers from the workshop regarding electrical maintenance and
observed the Indorama Computer Maintenance System (ICMS) which is the software employed to
plan schedules inspections and maintenance activities.
The auditor observed the physical records held on the main workshop computer and verified the hard
copies during plant inspections.
Fixed wiring inspections are conducted annually with tests undertaken on the main panels in the MCC
rooms.
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, but
the ELCBs tested. Records of the visual inspections from September and October 2011 were
observed, as were the ELCB tests from May 2012.
All electrical testing equipment was calibrated by Lunar Services and records observed from July
2012.
The auditor observed that all lighting within plant and offsite locations where flammable hydrocarbons
and 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 the
company endeavours to source supplies from within Nigeria where possible.
The auditor observed that all personnel wore the correct PPE for the activities they were undertaking
and the company holds supplies of specialist equipment for use where acids, flammable liquids or
gasses are present.
During visits to plant areas, the auditor requested evidence that staff have access to eye protection
and in all cases it was not on their person but in their welfare area lockers. This was a concern
identified 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 expats both complaining about the quality of footwear and overalls supplied.
During discussions with the electrical engineers, it transpired they have no access to international
standard 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 don
the respirators held for emergency spillage protection. Although they donned the RPE effectively, the
auditor observed the items were hung by the straps, which is incorrect as it can stretch them and
reduce the sealing potential.
Training records were observed dated February 2012; where 37 employees attended, but the HOS
admitted he does not conduct full face fit testing using fragrant odours, simply a negative pressure
test.
29
Canister shelf life is not shown and so the age of canisters and when to change them cannot be
accurately managed.
The auditor observed many different employees and contractors wearing simpler RPE, primarily
against 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 staff
and plant staff every six months, with the records from May and July 2012. The Fire Department also
conducts quarterly inspections of the SCBA and the auditor observed the records from 2011 and
2012.
2.16 MANAGEMENT OF NOISE

The auditor observed the HOS monthly reports where he records for management the noise levels he
measures in specific locations. Although some locations have a high level, the auditor was informed
that 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 noisier
equipment is shut down during maintenance activities.
The auditor did not experience any excessive noise levels and only wore hearing defence once during
the plant visits die to leaking pneumatic energy.
2.17 VIBRATION
The auditor was informed that only engineers experience exposure to vibration through the use of
hand 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 local
labourers 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 have
been made.
Indorama Eleme personnel conduct relatively few regular MH activities, with engineers being those
that would be required to manually manoeuvre equipment during maintenance activities.
The auditor observed hoists and lifting equipment within each plant and workshop.
FLTs operate within Bagging and occasionally in other locations.
The auditor observed no tasks that would require significant ergonomic assessments, with the
exception 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 Logistic
personnel, but as the location was within a plant conference room, it would be difficult to determine the
effectiveness.
30
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 sunlight
or glare and laptops being employed without separate keyboards.
31

SECTION 2 MANAGEMENT CONTROL SYSTEMS
2.1
2.2
2.3
WORK EQUIPMENT
PERMIT TO WORK SYSTEMS
SAFE ISOLATION PROCEDURES AND EQUIPMENT

CONTROLS
RECOMMENDATION
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
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
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
PRIORITY
PERSON
RESPONSIBLE
COMPLETION
DATE
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 threefive 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

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
obtained
2.15
RESPIRATORY PROTECTION
2.16
MANAGEMENT OF NOISE
2.17
VIBRATION
2.18
MANUAL HANDLING AND ERGONOMICS
2.19
WORKPLACE ASSESSMENT INCLUDING DSE
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

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
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
Review all workstations to determine the

ergonomic concerns and train staff to
understand how to correctly set up their
workstation
Issue correctly adjustable chairs and screens to

IT users
Issue separate keyboards for use with laptops
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 their
business 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 Service
for 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 the
local authorities, military and government.
All staff are trained annually to ensure they understand the onsite emergency plan, with the auditor
observing the records from various sessions in 2012. Selected plant staff are designated as
Emergency 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 management
through the permit system, which includes hot work permits. Training for plant staff regarding safety
during hot work was conducted by the HOS in 2012.
The Fire Department conduct the building FRAs and the auditor observed those from June 2012
covering the accommodation and administration.
Fire prevention training is conducted for all staff annually, with records from April and May 2012 being
observed.
3.3 ALARM SYSTEMS

The company have various systems across the site including manually operated call points, which in
the 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 Fire
Department between January and July 2012. When interviewed, the Fire Chief could not confirm that
all had been tested within the past year.
Atlantic Bluewater conducts the annual system inspections and the auditor observed the records for
the 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.
36
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 portable
extinguishers in all locations which were within their inspection dates.
All extinguishers are inspected each two months, as are the sprinkler systems and the auditor
observed 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 through
every 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 2012
observed.
Fire training is conducted for the fire staff daily and plant staff regularly and this includes live fire
fighting 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 these
is referenced in element 2.13.
All plant locations are external and the auditor visited several locations during the night shift and
visibility was very good.
Administration buildings all had good visibility from windows and the auditor was informed that
personnel 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 auditor
observed the records from PP Plant dated March and Olefins dated May 2012. Each drill was detailed
with 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 wearing
SCBA 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 management
and these are not a formal process, but any issues would be entered into the plant log books and plant
engineers would be required to rectify any faults.
The HOS, when undertaking his random plant inspections would also be expected to report any
concerns 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 fire
and if holding flammable liquids, this promotes and increases the fire severity. The company has now
begun covering these flanges with fire protection to reduce this risk.
37
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 padlocked
which was highlighted with management and by the time the audit was completed, these had been
released. This was an example of non plant locations being subject to lower levels of safety
management and is an area the company must improve upon.
The audit of 2011 raised the concerns that within administration and accommodation buildings, there
are insufficient fire doors to prevent the spread of fire, smoke and heat. There are doors protecting
final 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 HO
Security 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 check
and 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 patrols
and non essential vehicles are banned from plant locations.
All ex-pat movements are protected by armed vehicle escorts and all convoys are GPS tracked, with
the auditor observing the location of a convoy whilst interviewing the HO Security.
The auditor was shown the plans regarding additional security equipment being procured, which
includes 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 chemical
spillage medical and maintenance.
The last full site emergency drill was conducted in December 2011, with the next planned for
December 2012.
38

SECTION 3 EMERGENCY CONTROL SYSTEMS
3.1
COMPETENCE & CO ORDINATION
3.2
FIRE RISK ASSESSMENT
3.3
ALARM SYSTEMS
3.4
FIRE FIGHTING EQUIPMENT
3.5
EMERGENCY ESCAPE LIGHTING
RECOMMENDATION
See 3.7
Introduce a programme to ensure all manual call

points are tested six monthly at least
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 regular
inspection
3.9
SECURITY
3.10
EMERGENCY PLANNING
PRIORITY
PERSON
RESPONSIBLE
COMPLETION
DATE
39
SECTION 4 ACCIDENT/INCIDENT/NEAR MISS/ILL HEALTH

REPORTING
4.1 REPORTING SYSTEMS

The company has a good incident reporting system, with all first aid cases being reported and
recorded before being passed to the HOS.
The company has promoted near miss reporting for 2012 and the auditor observed the HOS monthly
reports, which record the figures and the auditor observed there has been an increase, but for a site of
this size, there should be more reported.
4.2 INVESTIGATION PROCEDURES

The auditor observed the investigations of several incidents, including near misses and low
significance first aid injuries.
The most significant lost time injuries were reviewed in detail.
August 2011 an employee was showered with hot water following an escape of pressurised steam
during a maintenance activity. The investigation, which was conducted by the HOS, identified that the
permit procedures had not been complied with. The report is dated September 2011, but the
recommendations have yet to be closed out.
May 2012 a canteen employee was scalded when a pressure cooker lid was forced off. The
investigation by the HOS was effective as it identified the root cause, which was the procurement of a
cheap alternative pressure cooker. The auditor also identified there was a concern that the cooker
was over-filled, but this was not addressed.
The near misses identified during the review of the plant safety committee meetings, were also
reviewed and their quality was poor as the root causes were not identified.
That from PP Plant, dated April 2012 was due to an employee climbing onto the plant to access a
valve during a breakdown as he could not locate the access steps. The auditor observed nothing
regarding step provision or previous incidents.
That from PE Plant dated March 2012, was due to a maintenance engineers failing, but the toolbox
talk identified as a recommendation was subsequently given to Technical personnel.
The auditor observed no evidence that management are taking their role seriously by taking a direct
role during the investigation process.
4.3 ACCIDENT/INCIDENT STATISTICS AND MEASURES OF PERFORMANCE

The HOS includes details of all incidents within the monthly report to management, including the
advertisement of issues at safety committee meetings and notice boards.
He also includes details of incidents within the presentations he gives to the various management
meetings (see element 1.2).
The safety ambassadors are the principle liaison between the HOS and plant management.
The costs associated with the pressure cooker incident were included in the investigation and
presentations given to management. These costs did not include the HOS and doctors time.
40
4.4 RECOGNISING AND MANAGING POTENTIAL LOSS AREAS

The HOS informed the auditor that he does record details to identify trends.
He produces a report called Incident Recall, which lists the incidents per month and this is made
available to management to share with their staff. Unfortunately, the auditor observed no evidence
that this is included in safety committee meetings.
The behavioural safety initiative was only launched in June 2012, so has yet to produce enough
evidence of its effect and impact.
41

SECTION 4 ACCIDENT/INCIDENT/NEAR MISS/ILL
HEALTH REPORTING
4.1
4.2
4.3
4.4
REPORTING SYSTEMS
INVESTIGATION PROCEDURES
ACCIDENT/INCIDENT STATISTICS AND MEASURES

OF PERFORMANCE
RECOGNISING AND MANAGING POTENTIAL LOSS

AREAS
RECOMMENDATION
Continue to promote near miss reporting across

all locations.
Use the incidents identified by the auditor as

examples of near misses to enhance
management awareness
Management should be required to lead

investigations under the direction of the HOS
Recommendations must be designed to address

the root causes and be closed out within a
suitable time frame
Promote the advertisement of performance and

incidents in all welfare locations, toilets and
workshops
All incidents should be discussed in detail at

safety committee meetings across the site
Ensure the correct personnel are briefed

following incidents
Compile all incidents by type, location and time

to identify trends
Increase the behavioural safety requirements as

identified in element 1.17
PRIORITY
PERSON
RESPONSIBLE
COMPLETION
DATE
42
SECTION 5 WORKPLACE IMPLEMENTATION

5.1 BUILDINGS, FLOORS, PASSAGEWAYS AND STAIRS

All plant, workshop and warehouse locations were observed as being very well maintained
and in good condition.
Departments are inspected daily and details of faults entered into the log books.
The administration building was also observed as being well maintained, with evidence of
regular cleaning in all locations.
The auditor was informed by the HOS that there are no asbestos containing materials in the
site or buildings.
5.2 VENTILATION, HEATING AND LIGHTING

All locations observed were well ventilated, with air conditioning in all offices and control
rooms.
As identified in element 3.5, illumination surveys were conducted in 2011.
5.3 WELFARE AND HYGIENE

The facilities observed within the main site were all suitable and well maintained.
However, the welfare facilities for contractors working for Civils were below that of a 5 star
organisation.
5.4 SAFETY SIGNS AND NOTICES

All locations have good quality signage, information, notices and all pipe work is clearly
identified with the contents and flow direction.
5.5 TRAFFIC MANAGEMENT INTERNAL AND EXTERNAL
There have been some good improvement s made since the audit of 2011, regarding the
manoeuvring of FLTs within the Bagging and MMD locations.
Clearer routes, better quality maintenance and improved facilities on the FLTs themselves
have enhanced the safety management of internal traffic.
This cannot be confirmed regarding transportation in and around the site, including vehicles
employed to transport employees to and from their homes.
The auditor observed and inspected some busses at random and identified five of the seven
inspected had poor quality tyres with little of in some cases, no tread. As Nigeria is subject to
frequent and heavy rain falls, this should be unacceptable to Indorama Eleme management.
43
When the auditor interviewed the Transport Department personnel, they informed the auditor
that it was down to the drivers to inspect their vehicle and report any faults. This is not a
formal process which employs check sheets to be completed weekly.
There is an ad hoc method for Indorama Eleme management to conduct inspections and the
auditor observed details of an inspection conducted in April 2012. There was no evidence that
the concerns had been passed to the contractors to address and no follow up was conducted
to ensure compliance.
The Indorama Eleme owned vehicles are subject to annual MOT and service and
maintenance programmes, which the auditor observed for the two vehicles identified (AE 704
BND AG 976 ABU).
The auditor also observed Toyota pick-up trucks being driven by company personnel and
contractors, which had bald front tyres.
Unfortunately, the company could offer no such evidence that contractors also maintain their
vehicles effectively.
5.6 STACKING AND STORAGE SYSTEMS

In all locations, including the Bagging Plant and MMD, the stacking and storage facilities were
very good and well maintained.
All containers, including those employed by contractors, were observed as having secure
shelving and storage facilities.
5.7 GENERAL HOUSE KEEPING AND WASTE MANGEMENT

The company is accredited to ISO 14001 by Bureau Veritias.
The auditor observed good quality waste management and as much recycling as can be
expected in Nigeria.
Again, this did not extend to the construction and Civils contractors.
44

SECTION 5 WORKPLACE IMPLEMENTATION
5.1
BUILDINGS, FLOORS, PASSAGEWAYS AND STAIRS
5.2
VENTILATION, HEATING AND LIGHTING
5.3
WELFARE AND HYGIENE
5.4
SAFETY SIGNS AND NOTICES
5.5
TRAFFIC MANAGEMENT INTERNAL AND

EXTERNAL
5.6
STACKING AND STORAGE SYSTEMS
5.7
GENERAL HOUSE KEEPING AND WASTE

MANGEMENT
RECOMMENDATION

Introduce a requirement for all drivers to conduct

a written weekly vehicle inspection
Indorama Eleme transport management are to

monitor compliance and receive these reports as
evidence
Conduct random vehicle inspections and

impound all vehicles found un-roadworthy and
only release to contractors / engineers for repair
Introduce a requirement for contractors to report

details of all MOT, service and maintenance
details and rectification of faults resulting in
vehicle impounding
Give safety ambassadors and the HOS the

power to impound any vehicle found to be
unroadworthy

PRIORITY
PERSON
RESPONSIBLE
COMPLETION
DATE
45
SECTION 6 - VERIFICATION
VERIFICATION OF THIS AUDIT WAS CONDUCTED USING THE FOLLOWING PROCESSES:
a) Interviews with key personnel and employees
b) Tours and inspections of workplace(s)
c) Identification and review of relevant documentation
INTERVIEWS
Interviews, both formal and informal, were held with a wide range of personnel during the audit
process including those listed below:
Department
General Management
Name & designation

Mr. BK Shrivastava - Technical Director
1) Okechuku Echie - Marblehead Project Manager.
2)
Rogers Netgum - Marblehead Site Engineer
3)
Martins wankasi - Marblehead site Engineer
4)
Nsikan E. Ekwere Marblehead Site Engineer
5)
Patience Dimkpa Admin Marblehead
6)
Hardeep Singh Chauhan Indorama Manager
7)
Elechi Obianko-Elechi Indorama
8)
Maxwell Famous Okewu Indorama
9)
Ugochukwu Onyeije Labour Marblehead
10) David Osauhwu Mason Marblehead

11) Ikwiki Gbara Labour Marblehead
12) Anele Promise Mason Marblehead
13) Praise Akpan Mason Marblehead
14) Jumbo Micheal Labour Marblehead
15) Okubo Emmanuel Mason Marblehead
16) Esowunne Chibuike - Labour Marblehead
17) Kalu Micheal Labour Marblehead
18) Paul Onyedikachi Mason Marblehead
19) Peter Onekin Mason Marblehead
Electrical
Mr. A K Bharucha - Head of department

1) Mr. Yogesh Tamore
2) Mr. Egere Tetenwi
3) Mr. Hezekiah Oluka PPUO Electrical
PPOU
1) Adebisi Lukuman - Senior engineer

Kailash Chawahan - Dupty Manager
2)
46
PP Plant
1) Anthony Kemi - Senior staff

Senior Engineer
CES Electrical
workshop
1) Mr. Ansari. Mohammed Senior Engineer CES Electrical
2) Dinesh Kumar -
2) Mr. Nwankwo Nduka (Junior Staff - CES Electrical)

3) Mr. Solomon (Junior Staff CES Electrical)
Mechanical
Mr. C P Limaye- Head of Department

1) Nwakaji Ekka , (Engineer)
2) Harrison Onyema (Engineer)
3) Uwuigbe Vincent Edanwe. (Technician)
4) Amadi Saloka (Technician)
5) Eze Charmi (Technician)
1) Ede ThankGod Ordi Technician (second shift )
2) Friday Kartey Technician (Night Shift)
3) Mr.Peter (Perujk Multi Link Resourcescontractor)
4) Mr. Nwechi Beloved Engineer (field visit)
1) Mr. Blessing Jaja (Engineer)
Olefins Mechanical
1) 2) Mr. Osaro Aji (Technician) regarding LOTO & PM job

PPUO Mechanical
1) Jadumani Hansdah, Engineer

2) Agba Benson Mba, Engineer
Olefins Operation
Off site tank farm
Mr.Stoica Ichim Head of Olefins

1)
Mr.D.Mital DGM
2)
Mr.A.Basu AGM
3)
Mr.N.Mukherjee Manager
4)
Mr.A.Mishra Engineer
5)
Mr.I.Awobite Safety Ambassador
6)
Mr. Eze Luke Shift Engineer
7)
Mr.Jaka Jude Panel Operator( Emergency Crew team member)
Mr. Sunil Dave Head of department

1)
Mr.Odediran Adebambo Operator
2)
Mr.Toro Engineer
3)
Mr.David Ukpong- Senior Engineer
Inspection
1)
2)
Akash Verma - HOD Inspection

Maxwell Okwara - Inspection Engineer
PP Operation
1)
Mr. Ashok Mohapatra
2)
Mr. Dinesh Bhakat
HOS
3)
4)
Mr. Felix Okeke

Mr. Eli Paschal
Safety Ambassador
Shift In-charge
HOD
47
PE operation
1) Mr. AB Rao- Head of the Function

2) Mr. AV Rao- Head of department
3) Mr. Chima- Safety Ambasador.
4) Nilanjan Dutta.
5) Mr. Borate- Shift Incharge.
ETP
Mr. Rakesh Singh - HOD

Mr. Young earnie - Senior Engineer
Mr. Nicolas- Engineer
Mr. Charles- Engineer
Power Plant
Mr. Rama Rao - HOD

Mr. T douglas Safety Ambasador.
Mr. GoGo hart
Safety
Mr. K PPandey- Head Safety

Mr. Felix Okusun- Safety Engineer
Fire
MMD
Mr. HSSircar - Fire Chief

Mr. Yusuf Suleiman
Junior fire officer
Mr. Ben son West
Senior fire officer
Mr. Raja Singh
HOD
Mr. A Tosin- Safety Ambassador

Commercial
Mr. Praveen Jain- HOF commercial

Mr. Harish Sharma- Section head
Security
Transport
Mr. Ranbir seth
Head
Mr. Gaurav Trivedi
Officer
Mr. Mano Thapa
Officer
Mr. Pradeep Ekka
Head
Mr. Emmanual
Officer
Mrs Grace
Contractor
HR
Mr Rajesh Kaushik
HOF
Weigh bridge
Mr. JG Pichai
Head
Mr. Innocent
Officer
48
WORKPLACE INSPECTION
The tour of the premises included:
Main Workshop
Poly Propylene Plant
Olefins Plant
Poly Ethylene Plant
Power Plant
MMD
Bagging Plant
Offsite
Effluent Treatment Plant
Administration Block
Weigh Bridge
Security
DOCUMENTATION REVIEWED
A range of documentation, including those listed below, was reviewed and authenticated during
the audit process as referenced within main body of report and:
Weekly Fire Drill Schedule

Safety Performance Action Plan 2011-12 presentation
Safety Performance Graph Presentation
MSDS Epoxy Thinner / Apextide 100 / Apextheme HS / Apexguard 460 + 64
What went wrong issues 1-38
Weekly safety information bulletins 1-9
Training attendance sheets from 2012 - HOS delivery including scaffolding / excavations /
guarding / hazard communications chemical handling and isolation
Near miss reports x 11
HOS Inspection reports 2011 12
Central safety meetings February, May and June 2012
49
THE BRITISH SAFETY COUNCIL IS ONE

OF THE WORLDS LEADING INDEPENDENT
HEALTH AND SAFETY ORGANISATIONS
TELEPHONE: +44 (0)20 8741 1231
EMAIL: CUSTOMER.SERVICE@BRITSAFE.ORG
WWW.BRITSAFE.ORG
British Safety Council (Company Limited by Guarantee). Registered
in England and Wales No. 4618713 at 70 Chancellors Road, London,
W6 9RS. Registered Charity No. 1097271 and OSCR No. SC037998
V:02/11
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PRIVATE AND CONFIDENTIAL

FIVE STAR OH & S AUDIT

AUDIT BY: Bob Wallace

British Safety Council 2011

British Safety Council 2011

British Safety Council 2011

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

Specific areas inspected

GRADING SYSTEM TABLE 1: THE FIVE AUDIT SECTIONS

Emergency Control Systems

Accident / Incident / Near

British Safety Council 2011

British Safety Council 2011

KEY AREAS MAY BE SUMMARISED AS FOLLOWS:

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

Employee transport and contractor maintained vehicle management

Senior management recording of inspections

British Safety Council 2011

FIVE STAR AUDIT RESULT

MAXIMUM ACCREDITED AUDIT

Actual Accredited Audit Figure

Percentage Achieved : 92.27%

British Safety Council 2011

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

SECTION 1 : SAFETY ORGANISATION

Competent OH&S assistance and management

Management objectives and planning

Employee consultation, communication and

First aid facilities and training

Documentation and information control

Occupational health programme

Appointment and control of contractors

Risk management and safe working practices

British Safety Council 2011

SECTION 2 : MANAGEMENT & CONTROL SYSTEMS

Work equipment (including hand tools)

Permit to work systems

Safe isolation procedures and equipment controls

Lifting equipment and operations

Pressure systems and portable gas containers

Mobile work equipment

Hazardous substance control

Non ionising radiation

Portable electrical equipment

Electrical installations and protection systems

PPE assessment and controls

Manual handling and Ergonomics

Workplace assessment and DSE

British Safety Council 2011

SECTION 3 : EMERGENCY CONTROL SYSTEMS

Competency and co ordination

Fire risk assessment