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EHS PROCEDURE
Section ENVIRONMENTAL HEALTH AND SAFETY
Doc No. PR-01-EHS-015 Subject EHS Violation
Revision No. 1 Effectivity Date: September 27,2021 Page 1 of 6

1. Objective
To ensure uniformity in the implementation of sanctions issued to sub-contracting companies
for unsafe acts committed within MDC projects sites by their workers.

2. Scope
All Non- MDC personnel regardless of rank, level and status of employment present inside
MDC facilities and project sites including MDC provided barracks, staff house for use of Non-
MDC personnel whether on-site or off-site at the time of the commission of offense.

Infractions by MDC employees shall be governed by the requirements in prevailing MDC Code
of Discipline.

3. Definition
3.1. Final Written Warning - A written notice served to the sub-contracting company informing
them that an unsafe act had been committed or a repeat thereof by their personnel as
prerogative of the company. This serves as warning that a repeat of the unsafe act may
result to temporary or permanent barring of the vendor personnel.

3.2. Temporary Barred – The offending sub-contract worker is prohibited from entry in any
MDC premises by reason of an unsafe act committed and that the sub contract worker is
being processed for disciplinary action by his/her company.

3.3. Permanent Barring – The act of banning or prohibiting entry in any MDC premises of a
sub-contract worker by reason of an unsafe act that is considered gross or grave or is a
repeat/habitual offender.

The prohibited acts committed by the non MDC Personnel and the administration of
disciplinary action by their respective subcontractors, shall be without prejudice to the filing
of a criminal or civil case in the regular courts, as the case may be and without prejudice to
fines imposable as required by other procedures, processes and/or involved/affected parties.

4. Procedure Details

4.1. OPERATING POLICY

This procedure provides lists of unsafe acts prohibited within MDC premises. MDC in its
prerogative may perform acts which in its discretion is proper to preserve a safe working
environment to its employee and sub-contract workers. Depending on the nature and
severity of the unsafe act, MDC may bar the sub-contract worker temporarily or
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EHS PROCEDURE
Section ENVIRONMENTAL HEALTH AND SAFETY
Doc No. PR-01-EHS-015 Subject EHS Violation
Revision No. 1 Effectivity Date: September 27,2021 Page 2 of 6

permanently. Further, MDC may impose fines and other penalties to the sub-contracting
company should the unsafe act committed by its workers result in damage to MDC owned
properties.

Ignorance of the existing approved policies, procedures, rules and regulations and other
information disseminated through various forms of communication shall excuse no one
from compliance therewith.

4.2. PROCEDURES FOR EHS VIOLATIONS

ITEM
ACTIVITY RESPONSIBILITY
NO.
Upon discovery and validation of reported unsafe acts and
violation of procedures, rules and regulation, a Notice of EHS
EHS Personnel
1 Violation (FR-01-EHS-039) shall be prepared and forwarded to
Project Document Controller/ PHR
Notice of Violation Memo (FR-01-EHS-040) addressed to
Subcontractors PM / PIC shall be prepared describing the
2 MDC PHR
unsafe act and the corresponding action of the company for
signature of MDC PIC/PM
Issue the signed Notice of Violation Memo to Subcontractor
3 PM/ PIC and forward copy to Subcontractor head office/ MDC PHR
Principal
Enforce specified sanction to the subcontractor and provide Subcontractor PM/
4
proof of action. PIC
Consolidate EHS violation and submit report to MDC Head
5 Office ER/ LR on a monthly basis for reference and appropriate EHS Personnel
action

4.3. LIST OF EHS VIOLATION

A. MINOR EHS VIOLATION

Sanction;

1st Offense : Formal Written Warning

2nd Offense : 3 days barred in all MDC Projects
3rd Offense : 10 days barred in all MDC Projects
4th Offense : Permanently Barred in all MDC Projects

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EHS PROCEDURE
Section ENVIRONMENTAL HEALTH AND SAFETY
Doc No. PR-01-EHS-015 Subject EHS Violation
Revision No. 1 Effectivity Date: September 27,2021 Page 3 of 6

GOLDEN RULES
No. Particular
Affected
1 Working without EHS Orientation, Induction. 2
Failure to deploy First Aider with valid I.D./ Certification from
2 2
Philippine Red Cross (PRC).
Failure to provide Fire Protection and Control (Fire Extinguisher,
3 Smoke Detector, Illuminated EXIT signage, etc.) (to specify, temfacil/ 4
warehouse/ office).
Failure to attend Toolbox Meeting while inside the project site
4 4
without valid reason.
Riding on heavy equipment/vehicle not designed/designated to
5 4
transport personnel.
Failure to provide adequate and required Construction Safety
6 4
Signage.
7 Rendering more than 24 hrs duty. 2
Failure to avoid / limit unnecessary noise and/or dust, illumination
8 within the construction site. (Non-conformance to noise/dust 4
controls required before operation starts).
Failure to act / respond to issued Safety Observation Report (SOR)
9 4
within agreed time.
10 Failure to participate in the emergency drill. 4
11 Horse playing inside the project site. 4
Deliberately not attending scheduled EHS related meeting, trainings
12 8
and orientation without a valid reason.

B. LESS SERIOUS EHS VIOLATION

Sanction;

1st Offense : 3 days barred in all MDC Projects

2nd Offense : 10 days barred in all MDC Projects
3rd Offense : Permanently barred in all MDC Projects

GOLDEN RULES
No. Particular
Affected
1 Allow workers to work without EHS Orientation, Induction. 2
Allow workers to work on critical activities without valid and
2 8
certified skills certificate (National Certificate).
3 Submitting falsified EHS related documents. 2
Failure to maintain and perform proper Housekeeping,
4 12
Maintenance and LINIS BAGO ALIS.

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EHS PROCEDURE
Section ENVIRONMENTAL HEALTH AND SAFETY
Doc No. PR-01-EHS-015 Subject EHS Violation
Revision No. 1 Effectivity Date: September 27,2021 Page 4 of 6

Operating Construction Heavy Equipment with defective critical

5 4
part or built in safety devices.
6 Using substandard, worn out or damage lifting gear. 8
7 Lifting load without Tag Line. 4
8 Performing lifting activity without adequate Rigger. 6
Failure to elevate / secure wires and cables overhead and/or to a
9 5
safe location. Failure to provide proper insulations and marking.
Unsecured, unprotected oxygen-acetylene cylinders, leaving
10 them lying on the ground / floor. Oxy-Ace Stations, trolleys, rack, 4
valve caps not provided.
Using of uninspected Power tools / mechanical tools (without QR
11 8
code and inspection records)
Failure to provide machine guards for power hand tools and
12 equipment such as but not limited to; grinder, cutter, one bagger 5
mixer, table saw, compressor, concrete vibrators, etc.,
Deliberately throwing tools, materials that could result/ has
13 4
resulted to property damage &/ or personal injury.
Work related incident resulting injury and property damage to
14 11
public.
Deliberately concealing or providing false information about
15 10
incident/accident.
Wilful violation of EHS Procedure, Guidelines and Policy that
16 4
caused near miss.
17 Inappropriate use, damage or removal of EPRP equipment. 4
Unsanitary acts, urinating or defecating anywhere at the jobsite
18 4
aside from the designated toilets or urinals.
19 Allowing workers to perform activities in an unsafe condition. 1
20 Performing activity in unsafe condition or in imminent danger. 1
Allowing work activity to start or continue without adequate
21 6
supervision.
5
22 Not following the EHS Bulletins requirements / conditions

23 Not wearing prescribed PPE in general PPE Zone 9

C. SERIOUS EHS VIOLATION

Sanction;

1st Offense : Permanently Barred in all MDC Projects

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EHS PROCEDURE
Section ENVIRONMENTAL HEALTH AND SAFETY
Doc No. PR-01-EHS-015 Subject EHS Violation
Revision No. 1 Effectivity Date: September 27,2021 Page 5 of 6

GOLDEN RULES
No. Particular
Affected
1 Performing High Risk Activity without Approved WAS and WAT. 4
2 Not wearing prescribed PPE for high risk activity. 9
Failure to secure high-risk activity permit before commencement
3 3
of activities.
4 Using unsafe working platform / un approved working platform 7
Allowing to operate Construction Heavy Equipment without valid
5 8
3rd Party Certificate.
Operate Construction Heavy Equipment without valid 3rd Party
6 8
Certificate.
Unauthorized alteration, modification of safety devices of
7 4
Construction Heavy Equipment, Tools, Machine and Equipment.
8 Unauthorized entry to restricted area. 3
9 Moving the suspended load over the top of workers. 4
Allowing workers to hook up and unhook the lifting gear load to
10 4
the lifting equipment (Tower Crane, Mobile Crane, etc.).
Unauthorized use/operation of electrical and/or mechanical
11 3
equipment.
Tampering / illegal electrical wiring connections to circuit
12 breakers/electrical panel boxes and etc., Unsafe wiring 4
installation / connections.
Failure to provide fall protection when working at heights
13 5
(protection Panel, Barricade with toe board, Inverted Umbrella,
14 Failure to perform Lock-Out/Tag-out rule (LOTO). 5
Unauthorized removal/ tampering of safety signs / traffic signs /
15 4
barricades or barriers / protective coverings.
Failure to get approved permit before removing safety protection
16 and failing to reinstall safety protection after completion of 7
works if required.
Wilful violation of EHS Procedure, Guidelines and Policy that
17 4
resulted to injury and damage to property.
18 Smoking on prohibited, undesignated areas / locations. 2
19 Unauthorized cooking / Cooking on undesignated area 2
Forcing workers to perform activities in an imminent danger
20 1
situation.
Failure to disclose during medical examination any pre-existing
21 10
.medical condition that contributed to the cause of accident.
Improper disposal of wastes (solid, liquid or emissions) which
22 2
may contaminate or pollute the environment.

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EHS PROCEDURE
Section ENVIRONMENTAL HEALTH AND SAFETY
Doc No. PR-01-EHS-015 Subject EHS Violation
Revision No. 1 Effectivity Date: September 27,2021 Page 6 of 6

Performing activity creating significant environmental

disturbance to nearby establishment or community (e.g.
23 2
excessive noise and dust) which may result to complaints and
cases.).
Deliberately not cooperating during scheduled/random
24 inspections/audits to check compliance against EHS 2
requirements.
Allowing simultaneous activity directly below or within the
25 working at heights activity without fall protection, effective 4
barricades and warning signs
Failure to deploy dedicated crew to remove nail after stripping
26 5
works
Using substandard PPE and /or allowing/issuing substandard PPE
27 9
to their employee
Failure to secure materials/tools that may fall by lanyard or
28 5
barricading

5. Retention Period

From September 2021 to September 2026.

6. Annex

Notice of EHS Violation (FR-01-EHS-039)

Notice of Violation Memo (FR-01-EHS-040)

Prepared by: Reviewed by: Approved by:

AM Dela Vega GR Saunders GR Saunders

EHS System & Audit Manager Division Head Division Head

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