Alstom Safety Directives and Zero Deviation Policy

(former e-Book Instruction 9.2)

Reference: <EHS-PRO-007> Application date: <09/06/2015>
Version: <00>

Purpose
The purpose of this Procedure is to:
1 Set a framework of application for eleven Alstom Safety Directives focused on highly hazardous
activities and their risk control,
2 Define the principles of application for the Alstom Zero Deviation Policy.

Scope
Whole Alstom activities worldwide

Responsibilities for the execution of this instruction

Accountable for the process: EHS V.P.
Responsible for execution: Line management (Site MD / Project MD / Country MD).
Contributors: EHS Regional Directors, EHS Metiers, EHS Managers, HR.

Signatures

Name Position Date Signature

Electronic
Written by: Florence Betton AT EHS VP <SEE PRISMA>
signature Prisma
AT Human Resources Electronic
Verified by: Mathias Klemptner <SEE PRISMA>
SVP signature Prisma
AT Chief Operating Electronic
Approved by: Thierry Best <SEE PRISMA>
Officer signature Prisma

1/7 TRANSPORT
 Alstom Safety Directives and Zero Deviation Policy
Ref: EHS-PRO-007 Version: 00 Date: 09/06/2015

Contents

1 Applicable documents ............................................................................................................. 3

2 Definitions .............................................................................................................................. 3
3 Key Principles ......................................................................................................................... 4
4 Process ................................................................................................................................... 4
4.1 Alstom Zero Deviation Plan .............................................................................................. 4
4.1.1 Compliance to Requirements .................................................................................. 4
4.1.2 Management of AZDP Directives ............................................................................ 5
4.2 Zero Deviation Policy ....................................................................................................... 5
4.2.1 Stopping the activity .............................................................................................. 5
4.2.2 Unsafe Condition .................................................................................................... 6
4.2.3 Unsafe Behavior ..................................................................................................... 6
5 Attachment 1 – Just and Fair Approach .................................................................................. 6
6 Control Sheet .......................................................................................................................... 7

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 Alstom Safety Directives and Zero Deviation Policy
Ref: EHS-PRO-007 Version: 00 Date: 09/06/2015

1 Applicable documents

The following documents have to be used to execute the process efficiently and are mandatory.
Assessment Check-lists
EHS-FRM-001 ....................... AZDP Self-Assessment Checklist
EHS-FRM-008 ....................... AZDP Directives Compliance Checklists for Formal Assessment
AZDP Directives
EHS-PRO-011 ....................... AZDP Directive - Risk Management for High-Risk-Activities
EHS-PRO-012 ....................... AZDP Directive - Control of Contractors
EHS-PRO-013 ...................... AZDP Directive - Lockout Tagout
EHS-PRO-014 ...................... AZDP Directive - Electrical Safety
EHS-PRO-015 ...................... AZDP Directive - Machine Safety
EHS-PRO-016 ...................... AZDP Directive - Work at height
EHS-PRO-017 ...................... AZDP Directive - Excavation work
EHS-PRO-018 ...................... AZDP Directive - Lifting Operations
EHS-PRO-019 ...................... AZDP Directive - Site Vehicle Movement
EHS-PRO-020 ...................... AZDP Directive - Rail Vehicle Movement
EHS-PRO-021 ...................... AZDP Directive - Work in confined space

2 Definitions

Abbreviation or Term Definition

Environment, Health or Safety requirement applicable through an EHS
EHS Requirement
Procedure, Instruction, Work Method Statement or Standard.
Alstom Zero Deviation Plan: plan focused on the control of High Risk
AZDP
Activities.
AZDP Requirement Requirement identified in the AZDP Directives.
Amongst the AZDP Requirements, some are identified as critical in AZDP
AZDP Critical
Directives and highlighted in bold.
Requirement
They must be applied prior to any other ones
Deviation A departure from a preventive and or protective measure.
One rule defined for each AZDP Directive to summarize the content in a way
Life-Saving Rule that is simple and easy to remind for all. Live-Saving Rules are used to
widely communicate about the AZDP Directives.
Action or omission of worker(s) that is a deviation from the correct and safe
Unsafe behaviour
way of behaving (ex: standing under a suspended load).
Fault with the physical environment, equipment, plant, etc. that is deviation
Unsafe condition
from the correct and safe condition (ex: damaged lifting sling).
UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number
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or any part thereof without prior written authorisation from AlstomTransport
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 Alstom Safety Directives and Zero Deviation Policy
Ref: EHS-PRO-007 Version: 00 Date: 09/06/2015

3 Key Principles

 Most of our Severe Accidents/Incidents and nearly all the fatalities in the past years have
involved a limited number of activities known to be very hazardous. Alstom has strict
requirements regarding the control of those High Risk activities.
 AZDP is the plan focusing on their control. It aims at protecting all our employees and
contractors worldwide from the risks they may face when working for Alstom in a factory,
a workshop, a project and/or a construction site.
 Alstom adopts a Zero Deviation approach regarding High Risk Activities.

4 Process

4.1 Alstom Zero Deviation Plan

The Alstom Zero Deviation Plan consists in:
- 11 AZDP Directives focused each one on one High Risk Activity.
- Each Directive contains 15 to 30 strict requirements.
- Among these requirements a limited number are considered as critical and are shown in
bold. They must be applied with full priority.
- For each AZDP Directive, a “Life-Saving Rule” summarizes the content in a way that is
simple and easy to remind for all.

4.1.1 Compliance to Requirements

All sites/projects are required to be compliant with AZDP requirements.

Self-Assessment
A self-assessment to AZDP Requirements must be led by the local EHS Manager and results
posted on Alstom reporting tool on a quarterly basis as a minimum.

Formal Assessment
A Three Year Audit Plan is defined by Transport EHS in agreement with the Regions to audit
sites/projects based on the following criteria:
- Each unit is audited at least once every 3 years,
- Units with a score lower than 80% are re-audited in the following year,
- Units in which a severe accident related to a High Risk Activity took place are re-audited in
the following year or even earlier.

The audit plan covers at least all Critical AZDP Requirements and can be complemented each
year by some other requirements.

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 Alstom Safety Directives and Zero Deviation Policy
Ref: EHS-PRO-007 Version: 00 Date: 09/06/2015
A centrally managed pool of auditors is built to be able to deliver the audit plan. In most cases,
an audit is delivered by two Alstom people: one from the concerned Region and another one
external to the Region. This system aims at giving an external and different point of view on
the activity audited.

Check-lists have been developed to facilitate self and formal assessments of the compliance to
the AZDP Directives. They are basically a copy/paste of the Group Directives in an Excel
format. AZDP formal assessment checklist is derived from self-assessment checklist and focus
only on audited requirements (Refer to Applicable Documents).

Both assessment and self-assessment are based on field practices as observed by the
assessor(s). Any deviation or non-compliance observed triggers a zero score for the
corresponding requirement (1=compliant; 0=non-compliant).

4.1.2 Management of AZDP Directives

The AZDP Directives are reviewed on a regular basis based on Alstom knowledge of our main
risks and to incorporate any lessons learned from severe or potentially severe accidents that
would have occurred.

4.2 Zero Deviation Policy

When a deviation that could result in a severe accident is observed, it must trigger a
systematic reaction.

Zero Deviation Policy means:

- The concerned activity is stopped immediately,
- Causes of unsafe conditions are analyzed and treated ,
- Causes of unsafe acts are analyzed using a just & fair approach.
Depending on the investigation conclusions, sanctions are applied.
Violations to safety rules are reprimanded.

4.2.1 Stopping the activity

Any person observing a High Risk Deviation (unsafe behavior or unsafe condition) should:
- First, remove immediately from the danger any exposed person and stop the job, where
safe to do so.
- Secondly, inform the relevant supervisor / management about the reason why the job is
stopped.

Any employee must suspend his/her activity when being himself/herself at risk or because of
putting other people in a dangerous situation.

UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number
This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document
or any part thereof without prior written authorisation from AlstomTransport
Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc 5/7
 Alstom Safety Directives and Zero Deviation Policy
Ref: EHS-PRO-007 Version: 00 Date: 09/06/2015
4.2.2 Unsafe Condition

In case of an unsafe condition, activity cannot restart until containment or corrective action
has been taken.

4.2.3 Unsafe Behavior

If case of an unsafe behavior, the cause for this unsafe behavior must be analyzed using the
just and fair approach described in Attachment 1.

If violation is confirmed, it is then the responsibility of the relevant manager to follow-up with
any disciplinary measures (Verbal warning, Written Warning and Exclusion from site or
Stronger/other measures). Disciplinary measures are recorded.

The process of disciplinary measures has to comply with local laws & procedures and can’t be
in any case a type of discrimination.

Local Human Resources is the first “guardian of the rules” and is responsible for putting in
place practically disciplinary measures.
According to local regulations, local Employee Representatives will be informed officially in due
time of the disciplinary measures.

5 Attachment 1 – Just and Fair Approach

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or any part thereof without prior written authorisation from AlstomTransport
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 Alstom Safety Directives and Zero Deviation Policy
Ref: EHS-PRO-007 Version: 00 Date: 09/06/2015

6 Control Sheet

Version Date Content of Modification Author

First issue under Transport reference and form – written from Florence
0 09/06/15
Corporate e-book instruction 9.2 Betton

UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number
This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document
or any part thereof without prior written authorisation from AlstomTransport
Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc 7/7