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OWNER’S STAMP: SEPCOIII’S STAMP: SIDEM’S STAMP:

Signature Signature Signature

FOR APPROVAL

0 Issue for approval 17/12/2018

REV DESCRIPTION PREPARED CHECKED APPROVED DATE

Haya Power and Desalination Company B.S.C. (Closed)

SEPCOIII Electric Power Construction Co., Ltd.

Société Internationale de Dessalement

PROJECT: TITLE:
Al Dur Phase II IWPP
LOCATION: CONSTRUCTION ENVIRONMENTAL AND SOCIAL
BAHRAIN MANAGEMENT PLAN
PACKAGE:
Total Plant
DOCUMENT NO: REV:
AD2-C3-00-YDC-GGP-CON-00030 0
CONSTRUCTION ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN AD2-C3-00-YDC-GGP-CON-00030

Table of Contents
1. Introduction...........................................................................................................................................5

2. Terms and definitions...........................................................................................................................5

3. Scope and objectives.............................................................................................................................9

4. Project Brief Description....................................................................................................................10

4.1 Project Identification.........................................................................................................................10

4.2 Owner................................................................................................................................................11

4.3 EPC Contractor.................................................................................................................................11

4.4 Project General Description..............................................................................................................11

4.5 Main System.....................................................................................................................................12

4.6 Plant Arrangement............................................................................................................................15

5. Environmental and Social Policy........................................................................................................17

5.1 Environmental and Social Management System..............................................................................18

5.2 Project Specific Environmental and Social Goals............................................................................20

6. Environmental & Social Requirements..............................................................................................21

6.1 Complimentary Plans and Procedures..............................................................................................21

6.2 Legal and Compliance Obligations...................................................................................................21

6.3 E&S Owner’s Requirements.............................................................................................................21

6.4 National Requirements.....................................................................................................................22

6.5 International Finance Corporation (IFC) Requirements...................................................................24

7. Roles, Duties and Responsibilities......................................................................................................26

7.1 EPC Contractor.................................................................................................................................26

7.2 Subcontractors..................................................................................................................................27

7.3 Project Director.................................................................................................................................27

7.4 Project Manager/Construction Manager...........................................................................................27

7.5 Project HSE Manager.......................................................................................................................28

7.6 Division Construction Managers (Civi, Mechanical, Electrical)......................................................28

7.7 Subcontractors Project Managers.....................................................................................................29

7.8 Environmental Management Representative/Engineer....................................................................30

7.9 Subcontractor HSE Manager/Engineer.............................................................................................31


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7.10 Employees.......................................................................................................................................31

7.11 Visitors............................................................................................................................................31

8. Method Statement and E&S Aspects and Impacts Identification and Controls.................................32

8.1 Method Statement & Risk Assessment.............................................................................................32

8.2 Method Statement.............................................................................................................................32

8.3 Expectations for Method Statement..................................................................................................32

8.4 E&S Aspects and Impacts Identification and Controls....................................................................33

8.5 Risk Assessment Register.................................................................................................................34

9. Competence, Training and Awareness...............................................................................................34

9.1 Type of E&S Training......................................................................................................................34

9.2 Competence Assessment...................................................................................................................34

9.3 HSE and E&S Induction Program....................................................................................................35

9.4 E&S Training for Management and Supervision.............................................................................37

9.5 Emergency Evacuation Training......................................................................................................37

9.6 HSE and E&S On-going Training....................................................................................................37

9.7 Visitors..............................................................................................................................................38

9.8 Environmental Protection and Social Responsibility Training.........................................................39

10. Bulletin Boards, H&S and E&S Notices and Signs..........................................................................40

10.1 Use of signs and notices..................................................................................................................40

10.2 Design of Signs and Notices...........................................................................................................40

10.3 Location of Signs and Notices........................................................................................................42

11. Management of Subcontractors........................................................................................................43

11.1 Competence assessment during contract award..............................................................................43

11.2 Pre-start review and approval of H&S and E&S MP and competent resources.............................48

11.3 Competence Assessment of HSE and E&S Staff...........................................................................49

11.4 Coordination of Subcontractor’s works..........................................................................................50

11.5 Monitoring and Management of Subcontractor’s E&S Management and Performance................50

11.6 Actions to be taken to correct substandard E&S Performance.......................................................51

12. E&S Meetings and Communication.................................................................................................52

12.1 Programme of Meetings..................................................................................................................52

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12.2 E&S Kick-off Meetings..................................................................................................................53

12.3 Client E&S Meeting........................................................................................................................54

12.4 Minutes of Meeting.........................................................................................................................54

13. Communication and Review.............................................................................................................54

13.1 Communications.............................................................................................................................54

13.2 Performance Review.......................................................................................................................55

13.3 Communicating E&S Commitments..............................................................................................56

14. Environmental Incident Reporting and Investigation.......................................................................57

14.1 General............................................................................................................................................57

14.2 Damage to environment and Reporting System.............................................................................57

14.3 Investigation....................................................................................................................................57

15. Emergency Response Plan................................................................................................................61

15.1 General............................................................................................................................................61

15.2 Emergency Response Team............................................................................................................61

15.3 Emergency Resources.....................................................................................................................61

15.4 Emergency Medical Services..........................................................................................................62

15.5 Emergency Communication...........................................................................................................62

15.6 Emergency Preparedness (Natural and Manmade).........................................................................63

15.7 Fire Prevention & Portable Fire Extinguishers...............................................................................64

15.8 Fire Prevention for Construction....................................................................................................65

15.9 Prevention and Response to Spills and Accidental Discharges......................................................66

15.10 Evacuation Exercise......................................................................................................................68

15.11. Emergency Contact Phone Numbers...........................................................................................68

16. Environmental and Social Audits.....................................................................................................69

16.1 Internal E&S Audits/Self-Assessment............................................................................................69

16.2 External Audits...............................................................................................................................70

16.3 Control of Non-conformance..........................................................................................................70

16.4 E&S Observations recording and follow up...................................................................................71

17. Reports..............................................................................................................................................73

17.1 EPC Contractor Weekly E&S Report.............................................................................................73

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17.2 EPC Contractor Monthly E&S Report............................................................................................73

17.3 Subcontractors Monthly E&S Report.............................................................................................73

17.4 Owner’s E&S Reporting requirements...........................................................................................73

17.5 E&S Key Performance Indicators Recording and Statistics...........................................................73

17.5.1 Leading Indicators.......................................................................................................................74

17.5.2 Lagging Indicators.......................................................................................................................74

18. Recruitment Policy...........................................................................................................................75

19. Forced and child labor policy...........................................................................................................75

20. Disciplinary, Incentive & Recognition Programme.........................................................................76

20.1 HSE and E&S Disciplinary.............................................................................................................76

20.2 HSE and E&S Incentive.................................................................................................................76

21. Employee’s Handbook......................................................................................................................77

22. Environmental and social mitigation, management measures and monitoring requirements..........77

22.1 Air Quality......................................................................................................................................77

22.2 Noise and Vibration........................................................................................................................79

22.3 Marine environment, hydrodynamics, water & sediment quality..................................................81

22.4 Biodiversity (terrestrial)..................................................................................................................81

22.5 Geology, Soils and Groundwater....................................................................................................83

22.6 Solid and liquid waste management...............................................................................................85

22.7 Chemicals..................................................................................................................................... 88

22.8 Tourism and recreation...................................................................................................................91

22.9 Traffic and access...........................................................................................................................91

22.10 Socio-economics...........................................................................................................................95

22.11 Cultural heritage and archaeology................................................................................................97

22.12 Landscape and Visual Quality......................................................................................................99

22.13 Health and Safety..........................................................................................................................99

23. Documentation................................................................................................................................113

24. Forms..............................................................................................................................................113

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1. Introduction

This Construction Environmental and Social Management Plan (CESMP) has been prepared by the EPC
Contractor for Al-Dur Phase II IWPP, Bahrain by the EPC Contractor. The CESMP provides a system and
procedures to address and manage potential environmental and social impacts associated with all the stages
of the Project. This CESMP, details the environmental and social mitigation and management measures to be
implemented during project construction, testing and commissioning phases. The measures herein have been
developed by the project team following input from relevant environmental and social regulatory agencies,
project ESIA and HSE Management Plan requirements.

This CESMP details the project structures and plans to manage environmental and social performance of the
project during site preparation, construction and commissioning activities. It will be the responsibility of the
EPC Contractor (and its subcontractors) to enforce the commited requirements and principles in this CESMP
in order to mitigate and manage environmental and social impacts throughout the construction phase of the
project.

EPC Contractor and Subcontractor personnel engaged on the project will be required to fully comply with
the requirements of this CESMP in order to limit the potential for environmental harm and regulatory non-
compliance.

This plan has been prepared by EPC Contractor based on:


 E&S impacts and risks identified during the ESIA Study.
 Applicable national regulations and standards.
 Conditions of Bahrain national, regional and local government permits, licenses and approvals.
 Lender requirements i.e. Equator Principles, IFC Performance Standards.
 Commitments made on behalf of the project team.

2. Terms and definitions

Owner: Haya Power and Desalination Company B.S.C.


Contractor: SEPCO III ELECTRIC POWER CONSTRUCTION CORPORATION
Contractor: Power Construction Corporation of China
Contractor: Société Internationale de Dessalement
Project: Al-Dur Phase II Independent Water and Power Project

Table 1 – Definitions
Concept Definition
Accident Event which has given rise to injury, ill health or fatality.
CESMP objective CESMP goal in terms of CESMP performance that an organization sets
itself to achieve. The Objectives associated to the goals shall be SMART
(Specific, Measurable, Achievable, Relevant and Time-bound) and linked
directly to the owner CESMP KPI's.
CESMP performance Measurable results relate to SMART objectives and linked directly to owner
CESMP KPI’s and these are cascaded through the organization at all levels.
Competent The combination of training, skills, experience and knowledge that a person
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Concept Definition
has and their ability to apply them to perform a task safely.
Continuous improvement Continuous improvement is a recurring process that enhances the project’s
Environmental and Social management system and improves its overall
E&s Management performance. Continuous improvements must be
consistent with the project’s E&S policy and can be achieved by carrying
out internal audits, performance measurement, management reviews,
analyzing data, implementing corrective and preventive actions, etc.
Contractor EPC contractor of the project
Environmental and Social A business plan for Environmental and Social to prevent and/or reduce
policy losses in an organization.

An Environmental and Social policy set out general approach and


management commitments together with the arrangements that must be put
in place for managing Environmental and Social matters in the business. It
is a unique document that says who does what. The policy is usually made
up of three parts:

(1) A Statement of Intent. A written policy statement which shows the staff,
and any other person, the company’s commitment to Environment and
Social matters management and its continuous improvement, providing the
general Environmental and Social objectives of the organization.

(2) Organization details. This section identifies the Environmental and


Social roles and responsibilities of everyone in the organization and
identifies the channels of communication within the organization.

(3) Arrangements. This section explains how the company policy will be
implemented with the practical means for achieving the identified
Environmental and Social objectives.
Hazard Something with the potential to cause harm or damage to environment or
cause adverse health effect on a person.
HSE Supervisor: As part of the HSE team verify the correct implementation of the
Environmental and Social policy, plans and procedures, and make sure that
employers and workers put them into practice and follow safety laws; it is a
key role to prevent accidents, injuries and health concerns in the workplace.
Incident Undesired event with a set of conditions or circumstances that have the
potential to cause injury or ill health.
Work-related event(s) in which an injury, ill health, property damage,
environmental incident or fatality occurs, or could have occurred.
An incident where no injury, ill health, or fatality occurs may also be
referred to as a “near-miss”, “near- hit”, “close call”. An emergency
situation is a particular type of incident.
Management of change A systematic approach to dealing with change, both from the perspective of
an organization and on the individual level, proactively addressing and
adapting to change, controlling change, and effecting change.
Non-Conformance The non-fulfillment of specified requirements.
Procedures Document describing the purpose and scope of an activity and the specific
way the activity is to be performed to an achieved project requirement. It
includes an auditable series of steps defining roles, responsibilities, and

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Concept Definition
tasks to transform a defined input into a defined output.
Risk assessment It’s a technique for evaluating the likelihood that an incident will occur and
the likely consequences if it were to occur.
The objective of risk management is the reduction of the level of risk “as far
as reasonably practicable”. The project decides whether or not the risk is
acceptable based on effective assessment methods.
Serious Accident An accident that causes a permanent total or partial disability or death to a
worker, or causes injury to more than one worker, or leads to losses in
production and equipment .
Subcontractor Any person or company having a contract directly or indirectly with
Contractor for carrying out any part of the work and including each tier of
subcontractor, sub-subcontractor and so forth.
Tool Box Meeting "Toolbox Talks", "Toolbox Topics", "Safety Chats", "Tailgate Meetings" is
(TBM) a brief safety talk or meeting about a specific subject at the beginning of the
shift. These talks can be done in a variety of ways but are typically a brief
(5-10 minutes) interactive discussion meeting on a safety-related topic.
Toolbox Topics are used to cover a variety of short safety training subjects
and to remind employees each day before they go to work about the
importance of being safe.
We Talk Safety A tool that allows Management and line supervision to set up a systematic
(WTS) approach to constructive correction of unsafe behaviour as well as being a
tool for praising safe work. The safety conversation shall be carried out by
the Line Supervisor and a management representative.
Injury or illness An injury or illness is considered work-related if an event or exposure in the
work environment caused or contributed to the condition or significantly
aggravated a pre-existing condition.
Near Miss An event or circumstance which has the potential to cause serious physical
(NM) or psychological injury, unexpected death, or significant property or
environment damage, but did not actualize due to chance, corrective action,
and/or timely intervention. A near miss is a free lesson in proactive risk
management and error prevention.
Environmental Incident An incident or set of circumstances which results in a leak, spillage or other
release or deposit of a substance. Relates to exceeding allowed emission
limits to ground, air and water.
Fatality (FTL) An accident that causes loss of life.
Lost Work Case An injury or illness that results in days away from work. An injury/illness
(LWC) will be classified as a lost work case when the next normal shift is missed.
Lost Work Hours (LWH) Working Hours lost by the Lost Work Case
Restricted Work Case If the employee is not capable of carrying out his normal work which results
(RWC) in alternative duties being given. Does not involve lost work days.
Restricted Working Hours Working Hours lost by the restricted Work Case.
(RWH)
Medical Treatment Case Illness or injury requiring medical treatment in order to combat disease or
(MTC) disorder.
First Aid Case (FAC) Any minor injury or illness which requires immediate and typically one-off
treatment by a trained first aider. Does not normally require further
treatment.
Other incident types  Property damage which warrants notification to management, involving

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Concept Definition
damage to company, personal or contractor assets, property or
equipment.
 Vehicular damage/incident which warrants notification to management,
involving light or heavy goods vehicles (NOT rolling stock).
 Security Incident which warrants notification to management, involving
theft of property or assets, assault, information loss, drugs and alcohol,
firearms, fraud etc from company, personal or contractor assets
property or equipment.
Damage to reputation which warrants notification to management, which
may result in adverse media attention which may lead to a negative business
impact.
Housekeeping Inspection A housekeeping inspection consists of a formal, scheduled, walk-through of
(HKI) facilities identifying any deviations to the content of the approved
5S/housekeeping procedure. Project Managers shall decide if 5S will be
implemented on their sites or not.

List of Abbreviations

Table 2 – List of Abbreviations


DEFINED TERM MEANING
Bahrain Kingdom of Bahrain
CARs Corrective Action Requests
CCGT Combined Cycle Gas Turbine
CCPP Combined cycle power plant
CESMP Construction Environment and Social Management Plan
COD Commercial Operation Date
EMR Environment Management Representative
EPC Engineering, procurement, construction and commissioning.
EPC Contractor SEPCO III and SIDEM
ESIA Environmental and Social Impact Assessment.
ES Environmental Supervisor
E&S Environment and Social
EWA Electricity and Water Authority
HSE Health Safety Environment
HSEM Health Safety and Environmental Manager
IFC International Finance Corporation
ISO International Organization for Standardization
IWPP Independent Water and Power Plant
LWDC Lost workday Day Case
MOM Minutes of Meeting
NC Non-Conformances
PPE Personal Protective Equipment
PSF Bahrain Public Security Forces (Bahrain State Police)
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DEFINED TERM MEANING


PTW Permit to Work
QA/QC Quality Assurance/Quality Control
RA Risk Assessment
RWC Restricted Workday Case
SCE Bahrain Supreme Council for Environment
SDS Safety Data Sheets
SEA Social and Environmental Assessment
SEPCOIII SEPCOIII Electric Power Construction Co., Ltd.
SIDEM Société Internationale de Dessalement
SWP Safe Work Procedure
TMP Traffic Management Plan
TRC Total Recordable Case
WBG World Bank Group
PM Particulate Matters
PM10 Particulate Matters of 10 μm (micrometers) or less
PM2.5 Particulate Matters of 2.5 μm (micrometers) or less
H2S Hydrogen Sulfide
CO Carbon Monoxide
NOx Oxides of Nitrogen
SO2 Sulphur Dioxide

3. Scope and objectives

3.1 Scope

EPC Contractor is responsible for E&S Management and provision of all Manpower, Materials and
Equipment and the performance of all works and services required for carrying out and completion of the
Works in accordance with the EPC Contract including making good any defects.

The scope of this CESMP covers the mitigation and management measures to be implemented for the
potential Environmental and Social aspects and impacts associated to the construction, testing and
commissioning phases of Al-Dur Phase II Independent Water and Power Project from day 1 until COD (01
June 2022).

3.2 Project CESMP Objectives

The main objective of the CESMP is to ensure appropriate environmental and social management practices
are followed during all the phases of the project as well as to demonstrate compliance against the national
and relevant international environmental and social requirements. The objective of the CESMP at various
stages of the project planning and implementation are as follows:

3.2.1 Construction Phase


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 To identify potential sensitive receptors and related potential and social impacts due to construction
works.
 Establish necessary preventive / control measures to mitigate and manage the potential environment
and social impacts.
 To establish a framework for the development of an environmental and social management system to
be implemented by the EPC Contractor to manage environmental and social issues throughout the
construction phase.
 To develop a frame work to ensure all foreseeable risks are identified.
 To develop a monitoring and auditing program including parameters, locations and frequencies to
ensure appropriate implementation of mitigation measures, regulatory compliance and early
detection of any significant environmental and social impacts.
 To regularly evaluate construction activities to identify any changes to the construction programme
and the need to update this CESMP and any other plans (if required).
 To ensure fully compliance with all applicable national.
 To ensure fully compliance with project specific requirements such as contractual, lenders’
requirements, etc.
 To ensure that the provisions of the CESMP are strictly followed and implemented.
 To demonstrate the solid E&S Performance throughout the project.

3.2.2 Commissioning and Testing Phase

 To prevent deterioration of environmental and social components regarding air, water, soil, noise,
community, society, and to improve the safety of end users and communities.
 Ensure compliance with Environmental and Social standards and requirements during the Pre-
commissioning and Commissioning stages of the project

These objectives are to be achieved through:

 Establishing a high level of environmental and social awareness and discipline;

 Identifying areas of high risk and carry out risk assessments;

 Ensuring that personnel are fully instructed with respect to the requirements of E&S;

 Promoting a proactive approach to Environment and Social issues;

 Monitoring the effectiveness of Environment and Social mitigation and management measures by
conducting regular scheduled audits/inspections and tracking of incidents.

4. Project Brief Description

4.1 Project Identification

The project name is Al-Dur II IWPP. This shall be the only name used to identify the project on all
official documents issued by the Project Team, Vendors, and Subcontractors.

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4.2 Owner
Haya Power and Desalination Company B.S.C.

4.3 EPC Contractor

SEPCO III ELECTRIC POWER CONSTRUCTION CO., LTD. and SIDEM

4.4 Project General Description

The Project Site is located on the coast immediately south of the existing Al Dur Power and Water Plant
Phase I facility, which is around 34 km south of Manama, Kingdom of Bahrain. The site elevation is
approximately three (3) to fifteen (15) meters above sea level (high astronomical tide) and has an area of
approximately one hundred ninety-two thousand five hundred squared meters (192,500m2).
The location of the Site is set out in the map below:

Figure 1 – Project Geographical Location

Al-Dur II IWPP project includes the design, construction, commissioning and testing of a high efficiency gas
fired power generation facility and a desalination facility. The scope of the Project includes not only supply
of the main power generation production facilities on the Site but also all equipment and services necessary
for the complete installation and safe and prudent operation and maintenance of the Plant. The project
schedule is shown in the appendix 7 for reference.

The Project will be developed as an Independent Water and Power Project (IWPP) comprising of a natural
gas combined cycle gas turbine with a net power capacity of 1,524MW and a seawater reverse osmosis
desalination plant with a 50MIGD net capacity. The Project will be developed on a Build Own and Operate
(BOO) basis.

The Project will make use of the existing seawater intake and outfall components, currently in use for the
operation of the Al Dur Phase I. Hence, the scope of the Project will include the survey and assessment of
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the site on-shore components, the development, design, engineering financing, construction, commissioning,
operations and maintenance of the IWPP as well as project infrastructures and facilities.

4.5 Main System

The Plant configuration is as follows:

 Four gas turbine units;


 Two condensing steam turbine units;
 6 Synchronous Generator for Gas Turbines and Steam Turbines
 Four Heat Recovery Steam Generators;
 2 Induced draft seawater cooling towers
 1 desalination plant with seawater reverse osmosis (SWRO) technology, including a sea water intake
pumping system;
 The gas turbines of the Plant is designed for dual fuel capability. The Plant is designed to run with
natural gas and is expected to operate on imported RLNG in its life time.

Descriptions of the Project’s facilities, infrastructure, processes and technologies are provided in the
subsections below.

4.5.1 Power Generation

Power Generation Units


The Power Generation Unit will consist of four (4) gas turbine generators (GTG), four (4) Heat Recovery
Steam Generator (HRSG) systems and two (2) steam turbines (ST) (arranged in a 4-4-2 configuration)
designed to generate up to 1,524.6 MW (net) of power. The turbines will operate on natural gas only and will
operate on simple or combined cycle modes.

Under combined cycle operation, the exhaust gas system from the GTGs will direct hot exhaust gases into
the HRSG in order to produce steam to operate the Steam Turbines. After the exhaust gases have passed
through the HRSG boiler, they will be emitted through the main stack associated with the HRSG. The bypass
stacks will enable the plant to run under simple cycle operation when required. When operating in simple
cycle, the entire HRSG and steam turbine system will be bypassed resulting in emissions from the bypass
stacks associated with the GTGs. Four 60m high by-pass stacks, 1 per GTG, and four 60 m high main stacks,
one per HRSG are included in the proposed design. The GTGs will be supplied by Siemens and will be
SGT5-5000 types. The STs will also be supplied by Siemens and will be SST5-5000 type. The project
Sponsors concluded that Siemens with the largest advanced F-class 50Hz fleet, are the best fit for the Project
as it provided the best GT performance and the best optimized combined cycle performance.

Fuel
The project will operate exclusively on natural gas, supplied by Tatweer Company and will be delivered via
the existing gas receiving station that is in place at Al Dur Phase 1. It is anticipated that RLNG fuel will be
utilised in the future, which would also be delivered via the same existing gas receiving facility.

There are no provisions in the projects design or requirements by EWA for backup liquid fuel. However, the
Project will incorporate emergency power supplies through smaller diesel generating units to ensure the safe
and shutdown of all components in the event of emergency. As such a small diesel fuel tank will be
incorporated on-site and will be re-fuelled by road tanker (as applicable).

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Emissions Monitoring and Abatement Technologies
In order to ensure that the operation of the plant is compliant with the applicable regulations on emissions
discharges, the plant will be powered by natural gas as the primary fuel which will eliminate emissions of
sulphur dioxide (SO2) and particulates. The Siemens GTGs will be equipped with low NOx burners and will
have emissions monitoring via Continuous Emissions Monitoring System (CEMS) on both the main and
bypass stacks, for monitoring concentration of Oxides of Nitrogen (NOx) and Carbon Monoxide (CO).

Power Block Cooling


Power block cooling will be provided on a closed loop basis by mechanical induced draft counterflow
cooling towers. The project will include either 40 or 48 cooling cells. The circulating water will be pumped
to the top of each cell to a distribution header from where it is discharged through spray nozzles. The water is
cooled by evaporative (main effect) and sensible cooling as it descends.

The use of the closed loop cooling system will minimise the need for water and reduce the residual influence
of thermal effluent on the receiving marine environment. Based on an ambient sea temperature of 30ºC, the
incorporation of minimal blowdown from the cooling towers is expected to result in a thermal temperature
increase (ΔT) of 2.1ºC when mixed with other discharge streams prior to the outfall.

4.5.2 Water Desalination

Sea Water Reverse Osmosis


The Seawater Reverse Osmosis (SWRO or RO) plant performs the main function of separating the dissolved
salts from the seawater to generate permeate water that is used in potable processes following further
remineralisation. Separation is achieved by forcing seawater through membranes, with high pressure being
used to drive the process. In contrast to normal osmosis, the reverse osmosis process results in the separation
of almost all the dissolved salts and also removes bacteria as well as other ions.

The RO plant will consist of 2 independent blocks (50% of the total project capacity each) and each be
configured with multiple independent trains. Each train will consist of a series of pressure vessels, a cartridge
filter, a high-pressure pump, an isobaric energy recovery device and one or two booster pumps. An energy
recovery has been included in the design to reduce the required pumping energy.

The RO membranes separate the water into two streams; the permeate (which has passed through the
membrane and has had most of the dissolved constituents removed) and the concentrate/brine (which
contains the dissolved solids). The seawater concentrate is returned to the sea through the exiting outfall and
the permeate is treated in a second pass to make it potable.

Pre-treatment system
A pre-treatment system will be incorporated to ensure that the necessary volume of seawater is available for
the RO membranes and that specific requirements in relation to chemical / biological parameters (as
indicated by the manufacturer) are maintained at all times.

Pre-treatment system for each of the Desalination Units will consist as a minimum the following:
 Coagulation and flocculation;
 Dissolved Air Flotation system followed by Dual Media Filters;
 Filter backwash and air scouring system;
 Sludge handling and treatment system; and
 Potabilization.

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Potable water produced via the RO process has a low mineral composition. Drinking water therefore requires
the addition of mineral content via the following:

 Carbon dioxide dosing system suitable for drinking water purpose;


 Lime stone filter system (or) lime water dosing system with facilities to prepare lime water;
 Potable Water chlorination system (using food grade hypochlorite or chlorine dioxide); and
 pH correction system and other necessary dosing system.

To ensure that the minimum requirements for potable water quality are met, three analysers will be installed
to monitor quality. The first analyser will be at the Potable Water storage tank located immediately after the
potabilization process. The other two analysers will be located after the storage tank and before the Al Dur
Forwarding Station (Water Delivery Point) in order to re-confirm the condition of the potable water.

4.5.3 Common Facilities (Al Dur IWPP Phases I & II)

Seawater Intake, Screening, Chlorination and Pumping


The project will make use of existing seawater intake (in use by the Al Dur Phase I), eliminating the need for
additional offshore construction activities. As such, only minor onshore works will be required to connect
the existing infrastructure to the Project and to include additional infrastructure (pumps, bar screen with
mechanical rakes for debris collection, debris pit, motorised mesh screen with automatic backwash, etc.).
The total intake water for the Al Dur Phase II Project has been estimated in 32,514 m3/hr.

It is noted that the existing seawater intake includes a sub-surface pipeline with intake headers approximately
1.5km offshore perpendicular to the coastline from the Al Dur Phase 1 Project. Seawater intake pipelines
will be routed from the existing Seawater Intake Infrastructure to the Project site using a corridor of
undeveloped land between the shoreline and the boundary of the Al Dur Phase 1 and the Project. The
connection from the existing Seawater Intake Infrastructure to the new CCGT and SWRO will supply of raw
water for the cooling requirements of the CCGT and potable water production by the SWRO. Seawater must
be conditioned to ensure it is of a suitable quality for use in the CCGT and the SWRO plant. The chlorination
requirements of Al Dur Phase II intake water supply have already been considered during Al Dur Phase I,
and an electro-chlorination facility is already in place and in use by the Al Dur Phase I. Like the entire
intake/outfall arrangement, this was designed to have sufficient capacity to meet the chlorination requirement
of both Al Dur Phase I and Phase II.

Seawater Outfall
The thermal and brine effluent will be discharged to the Arabian Gulf through the existing seawater outfall at
Al Dur Phase 1, eliminating the need for additional offshore construction. Seawater outfall pipelines will be
routed from the Project to the existing Outfall connection at the outfall channel.
The total discharge to the sea is estimated in 20,929m3/hr (brine and minimal thermal effluent) including
approximately 0.01 ton/h of treated wastewater.

Gas Supply
The Natural Gas supply headers for the Project are already constructed and in operation as a common line for
the Al Dur Phase 1 project. Branch connections are provided in the existing Gas Facilities to which the Al
Dur IWPP Phase 2 project will connect to.

4.5.4 Additional Project Components

The following main additional components will be included as part of the Project:
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 400 KV GIS Substation.
 Two-lane dual carriageway access road from the existing road located in the western extent of the plot.
 Internal 7m wide road for accessing existing seawater intake connections from the Phase 2 Project.
 Wastewater: The following liquid waste water facilities are included in the design.
 Oily waste water collection and treatment system.
 Collection of chemical drains, regeneration waste of demineralization plant, neutralisation /
attenuation of all chemical wastewater streams.
 RO pre-treatment wastewater treatment system (including separate collection system and adequate
sludge dewatering and treatment equipment).
 Domestic and sanitary wastewater treatment plant.

Following treatment in accordance with Bahrain SCE regulations and standards and IFC requirements, the
fully treated effluent streams will be discharged through the existing outfall together with the thermal and
brine effluent.

4.5.5 Project Associated Facilities

Also, the project will also cover the following Project Associated Facilities:

Project Entrance and Road Access Connection


Access to the project site will be via a newly constructed 4-lane, two-way, dual carriageway connection to
the adjacent highway, at the existing junction.

Gas Connection and Regulation Station


The connection of the CCGT component of the Project to the existing gas receiving station will be a short
section of pipeline measuring no more than 200m to a gas regulating station within the project boundary.

Electrical Interconnection Facilities


The High voltage power generated in Al-Dur II IWPP will be output to the Bahrain grid via a 400kV Gas
Insulated Switchgear (GIS) station located adjacent to the project. The switchgear station will be constructed
by EWA and will be ready by 1st March 2020. The EPC Contractor will be responsible for constructing the
projects power connection to the substation. The GIS Substation will be operated by EWA.

4.6 Plant Arrangement

The Site is located on the coast immediately south of the existing Al Dur Phase I plant. The Site has an area
of approximately 192,500 m2. The Plot Plan (OTS Part A, Appendix C, DOC. No. AD-001) shows the Site
and Temporary Area to be allocated to the project. The Temporary Area located on the Phase III site shall be
used only for storage and temporary offices.

Simultaneously to this project (Al-Dur II IWPP), the 400 KV Gas Insulated Switchgear (GIS) Substation will
be constructed and operated by EWA (The Electricity and Water Authority of the Government) and will be
located adjacent to the Site.

The seawater to Phase II will be supplied from the existing Seawater Intake/Outfall Facilities, which is the
shared facility built under Phase I.

The common Gas Connection Facility (GCF) is owned and operated by Tatweer Company, from there gas
will be supplied for Phase II.
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Figure 2 – General Layout

4.6.1 Temporary Areas

Additionally, the arrangement of temporary areas is shown below:

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Figure 3 – Temporary Facilities Layout

5. Environmental and Social Policy

The Environmental and Social requirements for Al-Dur II IWPP are included in the Health, Safety, Security,
Environment and Social Responsibility Policy, which is shown below:

EPC Contractor Policy on Health, Safety, Security, Environment and Social Responsibility (HSSE & SR)
applies across all our activities in Al-Dur Phase II Independent Water and Power Project (Al-Dur II IWPP)
and is designed to help protect people and the environment. It includes aims aligned to our customer’s policy
so as to meet its expectations towards HSSE & SR.

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EPC Contractor recognizes that by integrating sound HSSE & SR management practices into all aspects of
the project, we can ensure a safe, secure, healthy and environmentally and socially responsible workplace for
all the employees and the community around the project.

To achieve this, EPC Contractor will:

 Effectively monitor and manage HSSE & SR matters as any other critical business activity;

 Formally implement HSSE & SR requirements in all construction activities and incorporate systems to
mitigate and manage the impacts associated.

 Promote a culture in which all employees share our HSSE & SR Commitment.

 Establish clear HSSE & SR objectives, strategies and action plans.

 Maintain our commitment for the effective implementation and the continuous improvement of the
HSSE & SR management system.

 Strive to prevent pollution of the environment, injuries, ill health and hazardous conditions

 Provide a continuous program of education and learning to enhance skills and increase HSSE & SR
awareness.

 Ensure that gender equality is fully incorporated in all our work as a universal human right.

 Comply with all statutory regulations from Bahraini Government, the IFC Standards as well as
internationally recognized best practices applicable to the project.

 Engage competent subcontractors, vendors and suppliers who will comply with this HSSE & SR Policy.

 Pursue the goal of no harm to people.

 Preservation of flora and fauna around the construction site and demonstrate active stewardship of
biodiversity.

 Respect local people’s culture and heritage.

 Act responsibly towards our stakeholders, employees, business partners and towards the communities
we operate in.

This HSSE & SR Policy is consistent with the EPC Contractor companies (SEPCOIII and SIDEM) corporate
expectations and values and there is a transparent cascade of the HSSE & SR matters from their Head
Offices to the Al-Dur II IWPP.

EPC Contractor accepts responsibility for the effective implementation of this policy.

5.1 Environmental and Social Management System

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Both SEPCOIII and SIDEM Corporate HSE and Human Resources Departments have developed the
corresponding corporate standards, based on ISO14001:2015 and OHSAS18001:2007, so as to provide
guidance on the development and implementation of Environmental and Social Management Systems to
ensure that every Business Unit worldwide operates in an aligned, standardized and common way.

Both SEPCOIII and SIDEM Companies, as EPC Contractor in Al-Dur II IWPP, have established,
implemented and maintained a Risk-based Integrated E&S Management System based on:

 IFC’s Performance Standard 1: Assessment and Management of Environmental and Social Risks and
Impacts. January 2012
 IFC’s Environmental and Social Management System Implementation Handbook. November 2015
 Environmental and Social Management Toolkit. November 2015
 Environmental and Social Management System Self Assessment and Improvement Guide. October
2015
 ISO14001:2015 and OHSAS 18001:2007 standards
 EPC Contractors’ Corporate HSE and HR Standards.

The System has considered in its development, the size of the project, the nature of its activities, the
conditions and facilities which are part of the business.

EPC Contractor’s E&S Management System is also intended to assure the project's compliance with local
legislation, permits and contractual obligations under the Environmental & Social Impact Assessment,
throughout the duration of the Contract, from Site mobilization to the Facility Provisional Acceptance Date, to
plan, control, manage, monitor, report on and enforce environmental and social matters.

Top Management shall ensure the availability of resources and necessary information to support the operation,
measurement, analysis and implementation of the effective actions to achieve the planned results from the
Management System and its continuous improvement.

The Integrated Management System will be reviewed periodically to ensure that it continues being effective
and appropriate for the business activities of the EPC Contractor and its projects, as well as the E&S impacts
and the significant risks of safety and occupational health, present in the site.

The E&S Management System of the EPC Contractor, within the EPC frame of every site, gives an organized
plan to manage the activities related to E&S in the EPC processes, as well as a structure to anticipate and to
respond to the internal and external changes, for the continuous improvement.

The aim of the E&S Management System will be a key management tool used to facilitate implementation,
tracking and reporting management and monitoring measures identified as part of this CESMP. Throughout
the construction phase, activities will be managed in accordance with the requirements stipulated within this
CESMP as well as according to the requirements of the project-specific ESMS.

The management of E&S issues for all the EPC activities (including EPC Contractor’s, subcontractors, vendors
and/or suppliers) shall be based on the following:

 Applicable national regulations and requirements.


 Lenders requirements i.e. Equator Principles III (2013) and IFC Performance Standards (2012), World
Bank Group Environmental and Safety (EHS) Guidelines (2007) etc.
 ISO 14001:2015 and OHSAS 18001:2007.
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 Ensuring that the requirements of the contracts are fulfilled.
 EPC Contractor´s E&S Policy implementation and monitoring.
 Integration of E&S issues in all business areas and by every company working in the project.

EPC Contractor shall ensure that:

 The Project’s E&S Policy, Objectives and Plan are communicated to everyone.
 E&S risks associated to construction and commissioning activities must be understood and managed
effectively.
 Workers are competent to carry out their designated work.
 Subcontractors will be required to issue the relevant environmental and social plans, which shall be
reviewed and approved by the EPC Contractor before the activities start, and that shall be aligned to
Owner’s E&S Plans and Procedures.
 The effectiveness of the E&S Management System, compliance with expectations, legal, contractual and
lenders requirements, must be assessed and measured and opportunities for improvement shall be
identified and implemented.
 E&S issues shall not be compromised in order to achieve any other objective.
 Construction E&S Management Plan is updated periodically.
 Performance is openly reported.
 Consequences for non-compliance: E&S violations are not condoned, tolerated and accepted as the
norm, and strict disciplinary action shall be taken against violators as per the EPC Contractor
disciplinary procedures.

5.2 Project Specific Environmental and Social Goals

The Environmental and Social Goals of Al-Dur II IWPP project are to:

 Develop the project in an environmentally, socially-responsible, sound and sustainable manner.


 Full compliance of the IFC standards requirements applicable to the project by their integration into Al-
Dur II IWPP E&S Management System.
 Full compliance with the Environmental and Social Requirements specified in the Project’s
Environmental and Social Impact Assessment.
 Incorporate environmental and social/labour agency requirements and conditions of permits and
approvals.
 Demonstrate to the regulatory agencies that an adaptable management system is in place for the project.
The CESMP will form the basis for evaluation of project construction by the agencies.
 Provide a safe working environment for the employees through an effective risk management so that
harm or any loss is minimized.
 Ensure the protection of ecological components and environmental resources valued by the public.
 Full compliance with applicable E&S Regulations
 Zero damage to the Environment
 Zero Public/Community and Neighbor complaints during Construction and Commissioning activities.
 Ensure safe and proper relations are maintained with local communities.
 Maintain environment-friendly working areas and good housekeeping.
 No spillages during construction and commissioning
 No prohibited releases
 Plant designed and Materials selected to optimize energy requirements
 Provide a frame work for responsibility and reporting by members of the project construction team.
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 To ensure that designs and specified materials take full account of the need for the Plant to be
constructed, commissioned, operated and maintained safely without threat to the environment.

6. Environmental and Social Requirements

6.1 Complimentary Plans and Procedures

This project CESMP sets out the management plans and procedures which will be required to compliment
the E&S requirements to this CESMP.

The EPC Contractor has developed E&S procedures to be applied on all projects. The Procedures sets out the
required E&S arrangements for specific work elements. E&S forms are used to maintain relevant records and
registers related to processes detailed within this E&S Plan.

Project method statements shall incorporate the requirements of this project CESMP and, where appropriate,
the requirements of:

 Legal & Contractual HSE and E&S requirements (Bahraini regulations).


 Lenders’ Requirements with regard to IFC Standards, as outlined in the point 6.5 of this plan.
 EPC Contractor HSE Management Plan
 EPC Contractor safe work procedures (SWP) requirements.
 Contract specifications (e.g. BS / ANSI).
 EPC Contractor environmental and social impact assessment register of mitigation and management
measures.

6.2 Legal and Compliance Obligations

HSE Department shall collate E&S laws and regulations in time through the below mentioned sources:

 National, state E&S competent authorities.


 World Bank Group and the International Finance Corporation.
 Professional E&S journal and/or magazine.
 Electronic media, such as E&S laws and regulations website.
 Relevant law issuing departments.
 Relevant interested parties, such as Owner / Company HO.

The completeness and validity of E&S laws and regulations which are collected and subjected to internal
audit (quarterly) to ensure full compliance to the latest legal requirements.

6.3 E&S Owner’s Requirements

EPC Contractor shall comply with its obligations (with respect to the Contractor, its subcontractors and
otherwise) under and in accordance with the Contract. The contractual rights owed to the Owner will be met
in full.

 Owner’s HSSE and CSR Policy


 Al-Dur II IWPP Appendix V – HSE Management Plan requirements
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 Al-Dur II IWPP Appendix B – Project Management Specifications
 Al-Dur II IWPP Owner’s Technical Specifications Part A (OTS)
 Al-Dur II IWPP Owner’s Technical Specifications Part B (OTS)

6.4 National Requirements

The following Bahraini regulations have been identified and they will be thoroughly reviewed as per the
Legal Requirements Procedure, in order to verify the applicability scope to the project, and further
compliance throughout the life of the project:

Table 3 – List of Applicable National Requirements

SN. Name of Act Edition Remark


Labour
1. Bahrain Labor Law 2012
2. Ministerial Order No. 40 – Requirements for Labor Accommodation - 2014 2014
3. Ministerial Order No. 3 – Banning Work During Noon Time - 2013 2013
4. Order 24 of 1976 in relation to the Social Insurance Law 1976

5. Ministerial Order No. 32 of 2013 regulating occupations in which it is


2013
prohibited from employing women.
6. Ministerial Order No. 24 of 2013 reducing the maximum working hours for
2013
certain categories of workers, industries or jobs as required.
7. Ministerial Order No. 25 of 2013 determining the occupations for which
2013
workers may be present at the workplace for more than eleven hours a day.
Ministerial Order No. 27 of 2013 determining the jobs or cases which, for
technical reasons or due to working circumstances, require the continuance of
8. work without a rest period and determining the difficult or arduous works in 2013
which a worker is entitled to a rest period calculated as part of the effective
working hours.
9. Order No. 3 for 2013 regulating working hours outdoors. 2013

10. Ministerial Order No. 1 of 2013 concerning the Official Holidays for
2013
Employees Working in the Private Sector.
11. Law No. 30 of 2005 with respect to amending certain provisions of the Law
2005
No. 23 of 1976 to promulgate the Labour Law for the private sector.
12. Order No. 11 of 1977, with respect to the hours of work during the holy month
1977
of Ramadhan for non-Muslim workers
13. Order No. 20 of 1976 limiting days of feasts, seasons, other occasions and
1976
seasonal work on which workers may be required to work overtime
Chemical Management
Ministerial Order No. 15 of 2014 with Respect to Determining and Regulating
14. the Necessary Services and Precautions for the Protecting of Workers During
2014
Work from the Hazards of Highly Flammable Liquids, Gas and Chemical
Substances
15. Ministerial Order No. 3 – Banning the importing, manufacturing and
2014
circulation of asbestos material and product which contain this material
Ministerial Order No. 4/1999 on Licensing work in maintaining equipment
16. and buildings that contain asbestos, removal and transportation of this material 1999
and disposal of its waste
Law No. 54 of 2014 Approving the Unified Law (Regulation) of the Gulf
17. Cooperation Council (GCC) for the Arab States on the Control of Substances 2014
that Deplete the Ozone Layer.

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18. Edict 6/2013 on amending Edict 4/2006 with respect to Hazardous Chemicals
2013
Management
19. 2006
Edict 4/2006 on Hazardous Chemicals Management
20. Edict 7/2002 with respect to control on import and use of banned and severely
2002
restricted Chemicals
21. Resolution No.7 of 2002 on the control of the importation and use of
2002
prohibited and severely restricted chemical substances
Environment
22. Resolution No. 10 of 1999 on environmental standards (air and water). 1999

23. Resolution No. 2 of 2001 amending Resolution No. 10 of 1999 on


1999
environmental standards (air and water). ARABIC
24. Resolution No. 3 of 2001 amending Resolution No. 10 of 1999 on
1999
environmental standards (air and water).
25. Legislative decree no.8 of 1997 with respect to adding a new article to
1996
legislative decree no.21 of 1996 with respect to the environment.
26. Decree-Law 8/1997 on adding a new Article to Decree-Law 21/1996 on the
1997
Environment
27. 1996
Decree-Law 21/1996 on the Environment
28. 2006
Edict 10/2006 on emissions of air pollutants from sources
29. Resolution No. 5/ 2005 regarding environmental conditions required in service
2005
activity sites
30. Resolution No. 3/2005 on the environmental requirements and standards in
2005
work sites
31. Ministerial Order No. 2/2001 on amending some provisions of Edict 10/1999
2001
regarding Environmental Standards (Air and Water)
32. Edict 3/2000 on approving the consultation offices specialized in
2000
environmental assessment of projects and environmental studies
33. 1999
Edict 10/1999 regarding Environmental Standards (Air and Water)
34. Ministerial Order No. 1/1999 with respect to Control on Substances that
1999
Deplete the Ozone Layer
35. Resolution No. 2 of 2001 on Environmental Standards (Air and Water),
2001
amending Resolution No. 10 of 1999;
Municipal bye-law no.3 of 1996 with respect to delegating the required
36. officers to carry out the inspection duties in accordance with legislative decree 1996
no.21 of 1996 with respect to the environment
37. Ministerial Order No. 8 of 2002 on Standards for Pollutants and Emissions
2002
from Vehicles and Inspection.
Waste Management

38. Ministerial order no. 1 of 2001 with respect to managing waste hazardous to
2001
health care
39. Edict 7/2013 on amending Edict 3/2006 with respect to Hazardous Waste
2013
Management
40. 2006
Edict 3/2006 with respect to Hazardous Waste Management
41. 2005
Resolution No. 4/2005 on the management of used oils
42. 2001
Edict 1/2001 on management of hazardous waste of health care
43. Resolution No. 5 of 1977 regulating the collection, transportation and disposal
1977
of waste
44. Ministerial Order of 2002 on hazardous waste management 2002

Biodiversity Protection

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45. Decree No. 10 - Protection of marine resources, environment and wildlife of


2005
its powers 2005
46. Preservation of the national wildlife and their natural habitat in the gulf co-
2014
operation council states
47. Decree 43/2005 on re-structuring the Public Commission for the Protection of
2005
the Marine Resources, Environment and Wildlife
48. Decree-Law 20/2002 with respect to the Regulation of Fishing and
2002
Exploitation of Marine Resources
49. Decree-Law 12/2000 on amending some provisions of Decree-Law 2/1995 on
2000
Wildlife Conservation
50. 1995
Decree-Law 2/1995 on Wildlife Conservation
51. Edict 4/2007 on authorizing some Public Commission for the Protection of the
2007
Marine Resources, Environment and Wildlife staff to act as Judicial officers
52. Edict 5/2005 concerning the ban on the hunting and trading of Bahraini
2005
nightingales and bustards
53. Legislative decree no.50 of 2002 with respect to the formation of the general
2002
organization for the protection of marine, environment and wildlife wealth
Ministerial Order no.26 of 2003 with respect to formation of board of directors
54. of the general organization of marine and environment wealth in addition to 2003
wildlife protection
Ministerial Order no.6 of 2003 with respect to vesting some officers of the
55. marine wealth directorate, at the national commission for protection of marine 2003
wealth, environment and wildlife with the power of summary arrest

6.5 International Finance Corporation (IFC) Requirements

A. IFC Performance Standards on Environment and Social Sustainability (2012)

The IFC Performance Standards are a key component of the IFC’s Sustainability Framework and directed
towards clients (i.e. party responsible for implementing and operating the project that is being financed),
providing guidance on how to identify risks and impacts. The IFC Performance Standards are designed to
help avoid, mitigate, and manage risks and impacts throughout the life of a project as a way of doing
business in a sustainable way, including stakeholder engagement and disclosure obligations of the client in
relation to project-level activities.

The IFC Performance Standards (2012) are listed below:

I. Performance Standard 1: Assessment and Management of Environmental and Social Risks and
Impacts;
II. Performance Standard 2: Labor and Working Conditions;
III. Performance Standard 3: Resource Efficiency and Pollution Prevention;
IV. Performance Standard 4: Community Health, Safety and Security;
V. Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living
Natural Resources;
VI. Performance Standard 8: Cultural Heritage.

B. IFC General Environmental Health and Safety (EHS) Guidelines (2007);

The World Bank Group International Finance Corporation (IFC), Environmental, Health and Safety (EHS)
General Guidelines of April 2007 superseded the World Bank Handbook issue of 1998.

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In terms of specific guidelines to control environmental externalities (e.g. wastewater quality etc.), EHS
guidelines have been set out by IFC and the World Bank Group to provide general guidelines for its
members when involved in a Project or when providing financial support to a project. These guidelines
contain general and industry-specific examples of Good International Industry Practice (GIIP).

In summary, it should be noted that the following IFC EHS Guidelines are relevant to this project:

• General EHS Guidelines, Environmental:


- Air Emissions and Ambient Air Quality;
- Energy Conservation;
- Wastewater and Ambient Water Quality;
- Water Conservation;
- Hazardous Materials Management;
- Waste Management;
- Noise;

• General EHS Guidelines, Occupational Health & Safety:


- General Facility Design and Operation;
- Communication and Training;
- Physical Hazards;
- Chemical Hazards;
- Biological Hazards;
- Radiological Hazards;
- Personal Protective Equipment (PPE);
- Special Hazard Environment; and
- Monitoring.

• Community Health & Safety:


- Water Quality and Availability;
- Structural Safety of Project Infrastructure;
- Life and Fire Safety (L&FS);
- Traffic Safety;
- Transport of Hazardous Materials;
- Disease prevention; and
- Emergency Preparedness and Response.

• Construction and Commissioning:


- Environment;
- Occupational Health & Safety; and
- Community Health & Safety.

C. IFC EHS Guidelines for Thermal Power Plants (2008);

D. IFC EHS Guidelines for Electric Power Transmission and Distribution; and

E. IFC EHS Guidelines for Water and Sanitation (2007).

F. The Equator Principles III (2013);

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The Equator Principles (EPs) are a voluntary set of guidelines for assessing and managing environmental and
social risks in project financing and have become the project finance industry standard for addressing
environmental and social issues in project financing globally.
In accordance with Equator Principles III, projects located in Non-Designated Countries (i.e.includes
Bahrain), the Assessment process evaluates compliance with the then applicable IFC Performance Standards
on Environmental and Social Sustainability (Performance Standards) and the World Bank Group
Environmental, Health and Safety Guidelines (EHS Guidelines).

G. World Bank Group General and Sector-specific Environmental Health and Safety (EHS) Guidelines
(2007-2008).

H. Workers’ accommodation: processes and standards (joint publication of the IFC and EBRD).

7. Roles, Duties and Responsibilities

This section of the CESMP details the roles and responsibilities, including reporting protocols of the Project
Construction Team with respect to the effective environmental and social management of the Project.
The Organization Charts in the appendixes 6 and 7 represents the main key positions from the EPC
Contractors SEPCOIII and SIDEM.

7.1 EPC Contractor

Compliance with this CESMP is required by the EPC Contractor at all times with designated personnel fully
trained and knowledgeable and will have responsibility over the CESMP measures.

EPC Contractor will also ensure that personnel involved with the Project have completed the environmental
and social training and induction on site.

EPC Contractor shall:

 Obtain relevant E&S permits, consents and authorization prior to the site works;
 Ensure that all construction activities are conducted in a manner that protects the environment and social
relationships with the public and the surrounding communities;
 Comply with national labor laws and Lenders requirements i.e. IFC Performance Standards; and
 Be fully responsible for ensuring the implementation of the CESMP.
 Ensure that the resources needed for the implementation of this CESMP are available.
 Ensure regular updates of this CESMP are undertaken to ensure that it remains appropriate to the
purpose and context of the project, and that any change of direct and indirect impacts are identified and
managed accordingly.
 Ensure suitable preparation and implementation of complimentary plans and procedures on site
subject to internal reviews and audits.
 Ensure that any sub-contractor engaged to carry out project related tasks complies with the
provisions of this CESMP at all times by reviewing their environmental and social performance and
carrying out environmental and social awareness sessions, audits and inspections as appropriate.

The project team will be responsible to bring to the attention of the Site HSE Team any environmental and/or
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social non-compliance and to immediately inform the Owner should any non-conformance or incident that
occurs onsite that could negatively impact the environment and/or the social responsibility.

7.2 Subcontractors

All the Subcontractors shall demonstrate a proactive attitude towards environmental and social concerns and
shall be responsible for providing information to EPC Contractor that demonstrates their activities are in
compliance with applicable standards.

With regard to the designated Subcontractors directly responsible for specific activities such as waste
transport and disposal will be duly approved and registered with the Competent Authorities. EPC Contractor
and Owner shall duly acknowledge the registration documents, prior to commencement of activities.

7.3 Project Director


 The EPC Contractor’s Project Director is head of the EPC Contractor line management structure for the
Project and has overall responsibility and accountability for environmental and social performance on the
Project.
 EPC Contractor’s Project Director is responsible for ensuring consistency with the relevant legislative
standards of Bahrain. When on site, EPC Contractor’s Project Director will demonstrate commitment to
the Project CESMP by participating in compliance audits and reviewing overall E&S performance against
stated objectives.
 Project Director is in charge to coordinate all relevant procedures in the event of an emergency. He shall
ensure that the Emergency Response Plan is followed and that all resources (technical, communication,
human, equipment and material, information) are available for the complete implementation of the
Emergency Response Plan.

7.4 Project Manager/ Construction Manager


Reporting to the EPC Contractor Project Director, the EPC Contractor Site Manager is accountable, either
directly or by oversight, for the project team and Contractors in respect to environmental and social
performance on site through:

 Monitoring compliance with applicable E&S aspects of Bahrain Government regulations; lenders
requirements (i.e. IFC Standards), the Engineering, Procurement and Construction (EPC) contract; and,
Project specific development and approval guidelines including those of the Client;
 Ensuring the implementation, monitoring, review, and where required – updating, of the relevant
environmental and social actions and controls detailed in this CESMP;
 Ensuring all Contractor personnel receive site specific induction training that incorporates E&S concerns
raised in this CESMP and - as far as is reasonably practical, ongoing E&S awareness training;
 Ensuring all department Managers and Subcontractors manage their work scope with full compliance to
this CESMP and that each Contractor effectively manages specific E&S risks or exposures in areas under
their control;
 Ensuring the effective investigation, reporting and communication of E&S issues, incidents, grievance
cases and their status to all appropriate parties as defined in this CESMP and contract documents;

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 Relating closely with the various Department Managers and the HSE Manager in ensuring appropriate
resources are allocated to effectively discharge their allocated responsibilities under this CESMP;
 Ensuring any complaints received are managed in accordance with this CESMP;
 Active participation in auditing of site Contractors in relation to E&S performance and adherence to this
CESMP.

7.5 Project HSE Manager


The Project HSE (Health, Safety and Environmental) Manager reports to Project Manager. HSE Manager
performs a key role in the implementation, maintenance, and monitoring of compliance to this CESMP. The
responsibilities of this position include:
 Conducting the initial E&S aspects and impact analysis and development of this CESMP;
 Liaising with regulatory authorities;
 Auditing and ongoing monitoring of E&S performance and identifying activities with potential E&S
impacts which have not been adequately covered by the CESMP, advising the Project Manager and
subcontractors of any potential risks and where necessary, issuing of noncompliance notices and /or
reviewing this CESMP or the relevant subcontractor CESMP;
 Reviewing EPC Contractor’s CESMP;
 Conducting routine scheduled field inspections and audits of construction activities on site in order to
assess compliance to this CESMP, permit and approval conditions, and adherence to Bahrain Government
E&S regulations;
 Ensuring the Project Manager is informed in a timely manner of all non-compliances and E&S incidents;
 Participating in E&S incident investigations and assisting in the development and implementation of
corrective/preventive actions;
 The maintenance of appropriate E&S Management System records including copies of applicable current
legislations, permits, approvals and licenses, audit and incident reports, and weekly/monthly Project E&S
field inspection and progress reports measuring actual performance against stated objectives;
 Conduct and /or organize environmental and atmospheric monitoring as required;
 Conducting E&S inductions as part of the Project induction process for all new employees and
developing and implementing ongoing E&S awareness training programs, maintaining appropriate
records; and
 To maintain an E&S complaints register and to ensure all complaints are investigated and recorded in
accordance with legislative provisions and this CESMP.

7.6 Division Construction Managers (Civil, Mechanical, Electrical)


The Division Construction Managers reporting to Construction Manager have direct day to day
responsibility for managing the activities of their teams as well as the subcontractors under their control and
for monitoring and ensuring compliance by subcontractors with the relevant environmental and social
guidelines established for the Project. These responsibilities include:

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 Ensuring subcontractors submit complying with relevant Bahrain Government regulations covering the
environmental and social aspects, impacts and control strategies associated with their particular scope of
work.
 Ensuring Subcontractors develop and effectively implement an environmental and social surveillance and
auditing program including monitoring schedules and associated documentation to record overall
environmental and social performance, identify areas of under-performance or where corrective actions
are required, and to monitor compliance with this CESMP and relevant legislation;
 Ensuring that all Subcontractor personnel under their control are aware of their environmental and social
responsibilities and that all new employees are provided with initial induction and ongoing awareness
training which details their environmental and social responsibilities and E&S concerns associated with
their particular scope of work and the necessary control measures to be implemented;
 Conducting routine daily monitoring of Subcontractors environmental and social performance and
compliance with the Project CESMP and, when requested, assist the Project HSE
 Manager to conduct scheduled E&S audits ensuring any corrective or preventative actions from Action
Item Requests or Non-Compliance Reports (NCRs) are implemented and closed out within the stipulated
time frame;
 Ensure that the weekly and monthly CESMP reports and checklists from each Subcontractor are
completed correctly and on time reviewing the same for accuracy prior to signing off and forwarding to
the Project HSE Department;
 Ensure that all E&S incidents, issues, or concerns are reported immediately to the Project HSE Manager
and that the appropriate action is taken in a timely manner to eliminate, control, or remediate any spills,
accidents, or potential exposures.
 Ensuring also that the appropriate documentary records are maintained and /or submitted in accordance
with this CESMP;
 Ensure that all E&S complaints are handled in a prompt and courteous manner and in compliance with
the guidelines contained in this CESMP.

7.7 Subcontractors Project Managers


 Each Subcontractor has environmental and social responsibilities during the performance of their various
activities on the Project in particular;
 The submission of their own CESMP which complies with Bahrain regulations, the contents of this
Project CESMP, and the nomination of an E&S representative prior to conducting work on site;
 The preparing and implementing of and specific E&S control plans deemed necessary by the Site
Manager or his nominee to correct identified deficiencies or to enhance overall E&S performance and
compliance on the Project;
 Taking all necessary precautions or actions in relation to any activity conducted on the Project that may
potentially cause environmental harm and ensuring compliance with this Project CESMP and relevant
regulations including the development and implementation of an E&S monitoring program;
 Providing initial and ongoing E&S awareness training including induction training for all new employees
detailing each individual E&S responsibilities and key aspects of the Project CESMP and their own E&S
objectives and compliance plans, and any other details specific to their individual work scope on the
Project;

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 The immediate verbal reporting to the responsible EPC Contractor’s Manager – or in their absence, the
EPC Contractor’s Project HSE Manager, of all E&S incidents, non-conformances, or concerns and the
timely implementation of corrective actions or remediation strategies to control or ameliorate the extent
of environmental harm;
 The submission of E&S incident reports and weekly /monthly inspection and compliance reports to the
EPC Contractor’s Manager – or in their absence, the EPC Contractor Project HSE Manager, in a timely
manner to assist in the compilation of the weekly /monthly E&S reports; and
 Ensure that all E&S complaints are handled in a prompt and courteous manner and in compliance with
the guidelines contained in this CESMP.

7.8 Environmental & Social Management Representative/Engineer


The EPC Contractor’s Environmental & Social Management Representative (ESMR) provides independent
auditing and advice to ensure E&S compliance of the Project with legislative requirements.
The ESMR will have a thorough understanding of E&S regulations and internationally recognized best
practices. The ESMR shall be a suitable qualified and experienced in E&S issues relating to construction
activity. The ESMR will report to the HSEM on E&S issues in the ESMP and assist the HSEM in
maintenance and continual improvement of the ESMP.
Throughout the duration of construction, the ESMR will undertake site inspections during any construction
activities identified in the CESMP that require the ESMR’s attendance. The ESMR will have responsibility
for:
 Considering and advising on matters specified within the Statement of Commitments and compliance
with E&S matters;
 Certifying all activities defined by EPC Contractor have controls for the identified E&S and/or
community impacts;
 Periodically monitoring EPC Contractor’s E&S activities to evaluate the implementation, effectiveness
and level of compliance of on-site construction activities with the CESMP and associated plans and
procedures, including carrying out site inspections at least fortnightly;
 Recording and providing a written report to EPC Contractor’s construction management on non-
conformances with the CESMP and requirements of EPC Contractor to undertake mitigation measures to
avoid or minimize any adverse impacts on the environment including reporting required changes to the
CESMP;
 Directing EPC Contractor’s construction management to stop work immediately where considered
necessary, if in the view of the ESMR an unacceptable impact on the environment is likely to occur, or
require other reasonable steps to be taken to avoid or minimize any adverse impacts; and
 Reviewing corrective and preventative actions to ensure the implementation of recommendations made
from the audits and site inspections.
 Reviewing the CESMP;
 Certifying that minor revisions to the CESMP are consistent with the approved CESMP;
 Providing regular reports to the construction manager on matters relevant to carrying out the ESMR role,
including notifying the construction manager of any stop work recommendations.

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ESMR will immediately advise EPC Contractor’s construction manager of any incidents relevant to the
Project Statement of Commitments resulting from construction that is not dealt with expediently or
adequately by EPC Contractor.
 Compile information necessary to track Project activity progress against this CESMP’s requirements;
 Execution of regular control and visual check-up compliance with CESMP during relevant activities;
 Enforce E&S procedures directly during relevant activities;
 Report all incidents and non-compliance to HSEM;
 Conducts audits and inspections as required by the CESMP;
 Stop operations that may adversely impact the environment;
 Prepare monthly report for review by the HSEM.
 Understanding E&S aspects and procedures relevant to activities under his/her supervision;
 Maintain incident register and complaints register;
 Maintain the training register and attendance form;
 Maintain records of the E&S inspections and audits; and
 Monitor compliance of Project activities to the CESMP requirements, report non-compliances to the
HSE manager and provide recommendations for remedial actions;

7.9 Subcontractor HSE Manager/Engineer

The Subcontractor HSE Manager/Engineer will directly liaise with the EPC Contractor’s HSEM to ensure
that the activities comply with the requirements of the CESMP. The responsibilities of the Subcontractor
HSE Manager/Engineer will include but are not limited to the following:
 Implement appropriate mitigation measures for specific activities identified in the monitoring programs;
 Report actual and potential E&S incidents to the Site HSE Team through the HSEM;
 Ensure the E&S control in this CESMP are being implemented across the control site;
 Ensuring changes to the CESMP are communicated to staff;
 Inform staff of E&S requirements; and
 Conduct training and tool box talks containing E&S information.

7.10 Employees
It is the duty of every employee while at work to:
 Attend Environmental and Social Induction Training and maintain full awareness of all rules and
regulations on E&S Management Plan, specifically maintaining segregation of waste materials;
 Carry out all activities in a safe manner under the principle of respect for human life and nature;
 Recognize, intervene and report unsafe E&S management conditions to their immediate line manager;
 Carry out regular housekeeping activities;
 Wear appropriate personal protective equipment when carrying out waste management activities.

It is responsibility of each and every employee to work safely and efficiently, and to be aware of the
importance of health, safety and the environment whilst at work. Those failing to comply with the EPC
Contractor’s E&S regulations and procedures or any contravention of this CESMP will be subject to
disciplinary action.

7.11 Visitors

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Even though visitors are not expected to carry out any activity at site, they shall also comply with the
minimum requirements of this CESMP which include:
 Attend Environmental and Social Induction Training and maintain full awareness of all rules and
regulations on E&S Management Plan;
 Conduct his/her visit in an environmentally friendly manner.
 Respect local customs and rules.
 Carry out his/her visit in a safe manner under the principle of respect for human life and nature;

8. Method Statement and E&S Aspects and Impacts Identification and


Controls

8.1 Method Statements and Risk Assessments

Method statements and Risk Assessments will be produced for all site work activities. As Principal
Contractor, EPC Contractor will review & comment where necessary, on Method Statements & Risk
Assessments before work begins from each subcontractor. This is carried out for 100% of all the
Construction and Commissioning activities and/or any other activity considered of high risk within the scope
of the project. Contractor Method Statements and Risk Assessments shall be submitted to Owner for
approval, prior to tasks being undertaken.

8.2 Method statement

This project CESMP sets out the general E&S arrangements and key processes methodologies to be applied
to the project. Specific task related arrangements shall be detailed within project Method Statements.

Project method statements shall incorporate the requirements of this project CESMP and always considering
the requirements of:

 Legal & Contractual E&S requirements


 EPC Contractor E&S procedures (SWP) requirements
 Contract specifications (e.g. BS / ANSI)
 Lenders requirements and applicable International Standards / Industry best practice (e.g. H&S
Executive)
 EPC Contractor risk register / task specific risk assessment control measures
 EPC Contractor E&S impact assessment register control measures

8.3 Expectations for Method Statement

EPC Contractor Line Management shall approve their own task Method Statements and Risk Assessments
for all work activities. After internal approval, EPC Contractor shall submit all Method Statements and Risk
Assessments to Owner for final approval. Risk Assessments shall be part of such Method Statements and all
the documents shall meet legal and contractual requirements and reflect the contractor’s desire to achieve the
best and safest practices in all the activities carried out by EPC Contractor and its subcontractors within the
scope and during the whole life of the Al-Dur II IWPP project.

Method Statements (along with their Risk Assessments) shall document how risks associated with
identifiable tasks will be controlled. EPC Contractor shall review all contractor and subcontractors method
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statements and their risk assessments prior to the start of work. To ensure that every site task by personnel or
subcontractors receives proper HSE and E&S preparation, immediately before commencement of permitted
work, a method statement will be developed by the individual, or team carrying out the task. In so doing,
those carrying out the task shall confirm that the method statement remains valid or identify and document
any additional hazards present and any additional control measures or systems of work required to carry out
the task taking into account its specific HSE as well as E&S requirements. Should the task change, an
additional review shall be completed and, if out with the scope of a permit or the applicable risk assessment
and method statement, supervision must be informed to ensure appropriate steps can be taken.

In the development of the Method Statements the person in charge shall take into account the following
criteria:

Table 4 – Method Statements Expectations


Content Expectations

Activity The task or activity shall be accurately identified clearly describing the planned
activity including set up and clearance where appropriate
Capability The activity is within the recognized competence of the contractor’s work team.
Relevant competency requirements should be stated including for emergency
procedures
Presentation The method statement is coherently presented and accurately describes a logical
sequence of work that is easily understood by the work team. This based upon
WHO, WHAT, WHERE, WHEN AND HOW
Subcontractors Each contractor must review the risk assessments/method statements of their
subcontractors.
Organization and The document must show a clear team structure.
coordination Coordination of activities
Permit or authorizations
Contact details for key personnel involved
Adequacy The scope of the method statement and the level of control for significant findings
must be adequate for the undertaking.
Risks associated with Environmental and Social aspects must be addressed in
sufficient detail so that risks and controls are readily understood and are
unambiguous.
Common risk assessments/method statement may be submitted for approval even
though they have been previously approved. Method Statements and Risk
Assessments packs should therefore be tailored to the specifics of the tasks at hand
and the associated environment.
Emergency Procedures/requirements should be detailed

Every department shall have the control of their own Method Statements (and Risk Assessments) and the
department’s in charge of this process shall verify the status of each one of the documents developed and/or
submitted for approval to Owner’s representatives. Spreadsheets will be developed so as to track down the
status of their Method Statements and Risk Assessments.

8.4 E&S Aspects and Impacts Identification and Controls

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For the development of Risk Assessments for the Construction and Commissioning activities, EPC
Contractor shall comply with the requirements listed in the E&S impact assessment carried out in the ESIA.
EPC Contractor shall implement into the Construction and Commissioning activities’ Method Statements
and Risk Assessments, all the E&S Mitigation and Management Measures identified in the ESIA.

A detailed list of E&S Mitigation and Management measures is provided in the appendix 2 – ESIA
Requirements, of this plan. This appendix has been entirely prepared from the E&S Mitigation and
Management Measures listed in the ESIA’s Volume 2 – Main Text, Tables and Figures.

8.5 Risk Assessment Register

A Risk Assessment Register shall be established to control E&S risks. The Appendix 9 – Risk Assessment
Register shows a baseline Risk Assessment Register for the main Construction and Commissioning activities
to be carried out by the EPC Contractor in Al-Dur II IWPP. This register shall be reviewed and updated at
least every 6 months and/or when new requirements are arised during the Construction, Pre-Commissioning,
Commissioning and Startup stages of the project.

9. Competence, Training and Awareness

9.1 Type of E&S Training

E&S Training Matrix shall be prepared to identify target groups based on the training needs analysis. E&S
matters shall be included in the matrix. The Training Matrix will list all the positions defined in the general
organization chart of the EPC Contractor, from the Project Director to the lowest levels of the organization.
Based on the job description of each position, the matrix will show the type of training courses that the
employee shall receive, such as Grievance, Waste Management, Spill Prevention and Response, among
others. In the case of E&S training requirements, all employees from the EPC Contractor and its
subcontractors shall attend without exemption all the E&S training courses. E&S training shall be mandatory
for all the employees.

The E&S training matrix will be part of the document “E&S Training, Awareness and Competence
Procedure – AD2-C3-YDC-GGP-CON-00036”.

9.2 Competence Assessment

General competency and skill requirements should define the knowledge and skills employees need to
perform their work properly, efficiently and to an acceptable level of quality. E&S training required by codes
and standards applicable to the organization should also be identified. E&S requirements shall be part of the
training requirements for all the employees.

Management should consider analysis of current and future expected competence needs when determining
training and competence needs.

9.2.1 Sources for determining competence

The following sources could be used for determining competence:


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 Future demands related to strategic and operational plans and objectives

 Anticipated management and workforce succession needs

 Changes to the organization’s structure’s, processes, tools and equipment

 Evaluation of the competence of individual people to perform defined activities

 Statutory and regulatory requirements, and standards, affecting the organization and its interested parties

 Risk assessment outputs.

9.2.2 Techniques for identifying competence

The process for identifying competencies/training needs could include the following techniques:

 Feedback from employees and supervisors

 Information from baseline risk assessments

 Information from change management processes

 Reviews of work procedures

 Reviews of incident investigations

 Review of personnel information e.g. position descriptions, performance reviews

 Review of training program feedback

 Review of international codes and standards

9.3 HSE and E&S Induction Program

All employees, including visitors, must attend a site-specific environmental and social induction training
presented by EPC Contractor/ Subcontractor prior to the start of work or as required when site conditions
change such as when there is a change in the construction phase and/or during pre-commissioning and start-
up. The goals set for the project, the project safety rules and regulations and the No Accident philosophy will
be communicated to all employees, supervisors and managers. The course will also emphasize the
importance of human life and promote employee ownership and accountability by utilizing behavior-based
safety techniques.

The subcontractor will give the new hire internal orientation and submit the copy of attendance list to HSE
department before the start of the site work.

The orientation shall include but not limited to following:

 HSSE & SR policy,

 E&S management,

 Awareness of significant potential impacts associated with the project.


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 Awarenes of valuable resources and protection measures that need to be considered by all staff.

 Awarenes regarding the proximity and sensitivity of nearby residents and communities to the project.

 Internal grievance procedures and allowances for worker welfare.

 Soil contamination prevention


 Water and wastewater management
 Air quality
 Noise and vibrations
 Solid and hazardous material (correct use, storage, delivery, recycle, re—use)
 Storm water management
 Ecology and biodiversity
 Traffic and transportation
 Tocio economic issues
 Cultural heritage and archaeology
 Landscape and visual impact
 Hazard Identification,

 Basic PPE,

 Emergency Response plan,

 Disciplinary procedure,

 Site Health, Safety, Social and Environmental rules,

 Security procedure,

 Applicable Health, Safety, Social and Environmental legalization and regulations.

 The way of reporting of incident/near miss incident.

 Permit to Work and Risk Assessment basics.

 The welfare provisions in the project.

All project staff, workers and visitors entering the work area shall attend a site induction. A site induction
briefing shall be prepared and delivered by the project HSE team.
Attendance at induction shall be recorded and attendees issued with a training sticker to be placed on the
hard hat in order that evidence of attendance can clearly be seen.
Staff and workers who remain on site for more than one year shall attend the induction again to refresh and
reinforce the E&S message.
A short induction shall be developed by the HSE team for one off visitors to site who will not engage in
manual work. Records of this induction shall be retained.
Induction materials shall be made available in the English and local languages relevant to the majority of
workers.

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HSE and E&S Induction for Pre-Commissioning and Commissioning stages shall be developed and
implemented prior to start those stages at the project. All employees who have already received Construction
HSE and E&S induction shall attend as mandatory the HSE and E&S Induction for Pre-Commissioning and
Commissioning stages.

9.4 E&S Training for Management and Supervision

All managers and supervisors will attend a special Safety Leadership Skill-path training course that aims to
equip supervisors with the knowledge and skills to fulfill their safety roles, duties and responsibilities.

All HSE officers will attend a Safety Personnel Development course. This course aims to equip the safety
officers with the skills and knowledge to perform their duties. The course is similar to the supervisor training
mentioned above but concentrates on the roles, duties and responsibilities of HSE officers. In addition, it
includes safety administration and procedures and field execution safe work practices as per the project
safety manual and procedures.

9.5 Emergency Evacuation Training

The Emergency Preparedness Plan will be communicated to all visitors and new employees through the
project orientation program as well as through specific training courses about the theme.

Visitors and labor will be trained on what actions to take in an emergency.

Emergency response team members e.g. emergency committee manager, fire wardens, site doctors, site
nurses, first aiders, ambulance operators, fire fighter etc. shall be trained on the complete response
procedure.

All records of training on emergency preparedness and response shall be kept on file as part of the contractor
records.

9.6 HSE and E&S On-going Training

It is recommended that all staff receive refresher training on an annual basis to ensure that their HSE and
E&S knowledge remains fresh and current. Ongoing HSE and E&S Training program will be developed
based on:
 The current focus of the Health and Safety Executive’s attention.

 Risk assessment and method statements.

 Construction Site Health, Safety and Welfare.

 Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR)

 Behavioral safety.

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The refresh training for First Aiders, scaffolders, slingers, etc. shall be based on the statutory and industry
defined requirements.

In summary, E&S requirements will be communicated to the employees through Training and Awareness
sessions such as:

Table 5 – Communication of E&S Requirements


Induction All staff, both temporary and permanent, working on the project will undergo
Environmental and Social Awareness Training, in their own language, as part of
their initial induction process.

An Individual Awareness Plan will be provided for all staff, which identifies the
necessary requirements and responsibilities of that individual in relation to their
role and the activities they will be working on.

Tool-Box Talks Part of the induction program will comprise various tool-box talks. These talks
provide the appropriate level of training and awareness to allow staff to
undertake their jobs in an environmentally and socially responsible manner.
They include aspects such as Emergency Response Procedures and the use of
spill prevention and clean-up kits and their corresponding appropriate disposal.

Tool-box talks will be given by the responsible personnel nominated by the


Contractor’s HSE manager including the Subcontractors HSE Manager.

Training Refresh As a minimum, refresher courses will be held for all staff on an annual
basis. They will occur more regularly where an individual’s role has the
potential to lead to a significant impact. Site inspections will be used to identify
staff that are either underperforming and/or failing to perform in accordance
with their training.

These individuals will be given additional training and will be monitored more
closely during site inspections.

Management Those responsible for undertaking inspections and site audits will be required to
Training attend a wider Management Training Course. This course will not only provide
training on giving tool-box talks and undertaking inspections but also will
include the wider E&S requirements of the contract that are contained in the
CESMP such as the mechanisms of reporting non-conformances, the need and
purpose for weekly/ monthly reviews, and the necessity to regularly review and
update environmental and social management and performance against the
project program/activity schedule.

The Contractor’s HSE manager will be responsible for monitoring those


individuals on the Management Training Course to identify those staff who are
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not effectively managing/implementing the environmental and social
requirements. Additional training will be provided to these individuals. The
“Owner‟ will periodically review the induction and training process.

9.7 Visitors

All visitors must comply with the Construction Environmental and Social Management Plan as well as the
HSE Management Plan, must receive site orientation training before entering the site. The Site Orientation
session shall include the explanation of all matters with regard to Environmental and Social requirements
that the employees must comply with.

All employees shall also comply with the instructions given by site staff.

All visitors shall be accompanied whilst on site. This is to ensure their safety in the event of an emergency
and to ensure that they do not inadvertently enter areas where they may be placed at risk of personal injury,
and/or areas of restricted access for security or confidentiality reasons. All visitors shall be easily
recognizable by the wearing of a visitor I.D. badge and color-coded PPE that makes them easily recognizable
as a visitor to the site.

9.8 Environmental Protection and Social Responsibility Training

 EPC Contractor’s managers and Subcontractor Site Managers shall be responsible for ensuring that all
Project personnel under their control receive both initial and continuous sufficient environmental and
social awareness training to ensure they are familiar with their environmental and social responsibilities
under the Project CESMP.

 Project induction will provide all new site employees with an overview of the Project environmental and
social management system and key aspects of the Project CESMP prior to allowing access to the
worksite.

 In addition, each individual contractor shall be required to provide all new employees with
environmental and social induction training which addresses their own environmental and social
management system of which the minimum details are:
 Individual responsibilities under the plan;
 Risk management strategies for accessing potential E&S impacts and for developing appropriate
control strategies for any activity perceived to pose an E&S risk;
 Key E&S concerns and associated control strategies;
 How hazardous or dangerous goods will be handled;
 Waste minimization, recycling, and disposal guidelines;
 Incident and emergency response actions including reporting and recording guidelines;
 Complaint handling procedure.

 The Induction Training program will be provided to Project’s Environmental Management


Representative for adequacy review prior to inductions taking place.

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 EPC Contractor and subontractor HSE representatives shall conduct on-going E&S awareness training
for key issues throughout the Project through the use of targeted presentations/literature at daily job pre-
starts, toolbox meetings, etc.

 EPC Contractor’s construction management and subcontractors shall maintain a register of all
environmental and social training provided which records the nature of the training, dates, the names of
persons trained, and trainer details as well as any refresher training that may be required.

 Prior to construction, the Project Construction Team will receive training on this CESMP, applicable
environmental and social legislative requirements. Additionally, prior to each new phase of construction
the Project Construction Team will meet on-site to discuss site-specific measures and objectives, and to
ensure environmental and social responsibilities are clearly understood and any deficiencies are
addressed. The training will include:
 Overview of all the significant E&S issues relating to construction identified during the E&S
assessment and planning of the Project.
 Obligations of each team member with respect to E&S Management.

10. Bulletin Boards, Health, Safety and E&S Notices and Signs

Contractor and the subcontractors shall set up around the Site a suitable and sufficient number of bulletin
boards exclusively dedicated to HSE and E&S matters. These notice boards will be erected in key areas
(offices, mess areas, etc.).

Contractor and the subcontractors will be responsible for the display in appropriate locations notices
applicable to their specific construction operations and processes.

10.1 Use of Signs and Notices

EPC Contractor shall provide adequate signs and notices to inform, instruct and control personnel and other
parties with respect to health, safety and/or E&S requirements whilst on company premises. Signs and
notices shall be used to:

1. Identify hazards present in work areas


2. Prohibit unauthorized entry to designated work areas
3. Restrict entry to designated work areas to personnel operating under a permit-to-work system
4. Inform requirements for wearing of personal protective equipment
5. Prohibit certain activities in designated areas, such as smoking, driving, eating, etc.
6. Advise general requirements for health and safety, and environmental and social.
7. Provide general information on health, safety and environmental and social management
8. Promote health, safety and E&S management by communication of reminders of safety awareness,
performance results, etc.
9. Communicate the location of Emergency Response equipment such as fire extinguishers or emergency
safety showers.

Signs and notices shall be maintained in good condition at all times.

Personnel shall not deliberately deface, change, damage, or otherwise interfere with any signs or notices
related to health, safety and environmental and social management.
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10.2 Design of Signs and Notices

All signs and notices related to control of health, safety and the environment shall have written information
and/or instructions in proper language. Signs and notices in English or other languages (Arabic, Hindi) shall
be provided where persons who carry out work activities are not able to read in local language.

The design of signs and notices shall comply with the international colour-coding and design system as set
down below:

Table 6 – Type of Safety Signs


Type of Sign/Notice Description

Prohibition Shape – circle


(means MUST NOT, DO NOT DO, STOP) Colour – Circular band and cross-bar in RED on WHITE
background
Red colour over 35% of sign/notice

Mandatory Shape – circle or square/rectangle


(means MUST, MUST DO) Colour – BLUE
Blue colour over 50% of sign/notice

Warning Shape – triangle


(means CAUTION, RISK OF DANGER, Colour – Triangular band in BLACK on YELLOW
HAZARD) background
Yellow colour over 50% of sign/notice

Fire Exit or Safe Condition Shape – square/rectangle


(means SAFE WAY, WHERE TO GO, Colour – Green
WHERE TO FIND)
Green colour over 50% of sign/notice

Fire Equipment Shape – square/rectangle


(means FIRE-FIGHTING EQUIPMENT) Colour – Red
Red colour over 50% of sign/notice

Some other safety signs may not fully comply with the color-coding guidelines. However, those signs shall
have a clear message regarding the prohibition, restriction and/or any other instruction that the employees
shall obey and follow, such as the DANGER signs.

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Figure 4 – Special Signs without additional colors

Pictorial representations and drawings on signs and notices shall be used to encourage recognition and
understanding.

All signs and notices shall be clearly legible and recognizable.

10.3 Location of Signs and Notices

All signs and notices shall be located in positions where the information and instructions given on the
signs/notices are clearly visible and views of the signs/notices are unobstructed.

An adequate number of signs and notices shall be provided such that information and instructions are
communicated to all persons at all points where such persons may gain access to company premises or work
areas.

Figure 5 - Schematic diagram of prohibition sign

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Figure 6 - Schematic diagram of Caution sign

Figure 7 - Schematic diagram of PPE requirement sign

11. Management of Subcontractors

11.1 Competence assessment during contract award

Prior to award contract, subcontractors shall be evaluated by contractor according to Subcontractor


Qualification Procedures which will be in line with the applicable Bahraini regulations, lenders requirements
such as IFC Standards and the IFC’s Good Practice Note “Managing Contractor’s Environmental and Social
Performance”, Owner’s requirements such as the OTS’s documents as well as EPC Contractor HSE and
E&S Plans and Procedures listed in the reference section of this plan. The evaluation of subcontractors shall
include E&S and HSE requirements applicable to their scope of work in the project. and detail welfare

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aspects, including whenever required the adequacy of each Subcontractor’s HSE Management plan. The
provision of welfare facilities, among others shall include, but not limited to, adequate potable water, proper
shelter, transport, dining and rest areas, ablution facilities, recreation facilities, prayer areas, among others.

Project Commercial Department is responsible for inspecting subcontractor’s HSE and E&S qualifications,
and HSE Department shall fill Subcontractor HSE Qualification Evaluation Form.
Subcontractors shall not be selected to work with the contractor based simply on price. Subcontractors are
supply partners whose performance reflects directly on the contractor.
Subcontract works shall meet the HSE and E&S performance requirements set out in the contractor Safe
Working Procedures (SWP) and relevant local HSE and E&S regulation. The requirements of the contractor
SWP shall be incorporated into method statements by all supply partners (subcontractors / contractors /
vendors).

Table 7 – Subcontractor safety qualification evaluation form (part 1)


SUBCONTRACTOR SAFETY QUALIFICATION EVALUATION FORM

Section A - Subcontractor/Project Information

Subcontractor Name:

Address:

Street Address:

City:

Country:

Mail Code:

Phone-No.:

Fax No.:

Section B - Contractor:

Contractor Name:

Project Name:

Project/Contractor No.:

Project Location:

City:

Country:

Mail Code:

Section C - Evaluation:

Person Completing the


FOR CONTRACTOR USE ONLY
Evaluation

Phone-No.:

Fax No.:

Street Address:

City:

State:

Zip:

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Country:

Mail Code:

Phone-No.:

Title:

Signature:

SUBCONTRACTOR SAFETY QUALIFICATION EVALUATION FORM

1. INJURY/ILLNESS STATISTICS
(use the previous three years' Injury and Illness Records to complete the following):

YEAR: Year_____ Year_____ Year_____

NUMBER OF LOST WORKDAY CASES

NUMBER OF RESTRICTED WORKDAY CASES

NUMBER OF INJURIES / ILLNESSES REQUIRING


MEDICAL ATTENTION BY A PHYSICIAN

NUMBER OF FATALITIES

NUMBER OF EMPLOYEE HOURS WORKED

2. SERVICE CATEGORY (CHECK ONE):

NONRESIDENTIAL BUILDING ELECTRICAL EQUIPMENT

HEAVY (Non-Highway) CONSTRUCTION STEEL ERECTOR MECHANICAL

PLUMBING, HEATING AND AIR GENERAL OTHER (Specify)


CONDITIONING CONTRACTOR ________________

3. SUPERVISOR SAFETY MEETINGS


DO YOU HOLD ON-SITE SAFETY MEETINGS WITH FIELD SUPERVISORS?
NO
YES, If so how often?

WEEKLY BI-WEEKLY MONTHLY LESS OFTEN, AS NEEDED

4. SAFETY INSPECTIONS
DO YOU CONDUCT PROJECT SAFETY INSPECTIONS? NO YES

WHO CONDUCTS THIS INSPECTION?

HOW OFTEN?

WEEKLY BIWEEKLY MONTHLY LESS OFTEN, AS NEEDED

5. ACCIDENT RECORDS
HOW ARE ACCIDENT STATISTICS REPORTED?

REPORTED HOW OFTEN ARE THEY REPORTED?

NO YES MONTHLY QUARTERLY ANNUALLY

ACCIDENTS TOTALED FOR ALL


COMPANY

ACCIDENTS TOTALED BY PROJECT

SUBTOTALED BY SUPERINTENDENT

SUBTOTALED BY SUPERVISOR

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6. ACCIDENT REPORTING

WHO RECEIVES ACCIDENT STATISTICAL REPORTS


WITHIN YOUR COMPANY?

HOW OFTEN ARE THEY REPORTED?

YES NO MONTHLY QUARTERLY ANNUALLY

FIELD SUPERINTENDENT

VICE PRESIDENT

PRESIDENT/CEO

7. WRITTEN SAFETY PROGRAM

DO YOU HAVE A WRITTEN SAFETY PROGRAM? YES NO (PLEASE PROVIDE A COPY OF THE
PROGRAM.)

8. SAFETY PROGRAM ELEMENTS


DOES YOUR SAFETY PROGRAM INCLUDE THE FOLLOWING ELEMENTS?

YES NO N/A YES NO N/A

CORPORATE SAFETY POLICY CRANE & RIGGING

HEAD PROTECTION VEHICLES

EYE PROTECTION FOOT PROTECTION

HEARING PROTECTION HAND TOOLS

RESPIRATORY PROTECTION LADDERS & SCAFFOLDING

FALL PREVENTION WELDING & CUTTING

PERIMETER GUARDING HANDLING OF REGULATORY


INSPECTIONS

HOUSEKEEPING MEDICAL EVALUATION &


EXAMS

FIRE PREVENTION & CONFINED SPACE


PROTECTION

FIRST AID PROCEDURES COMPRESSED GAS CYLINDERS

EMERGENCY PROCEDURES SUSPENDED WORK BASKETS

TOXIC SUBSTANCES ASBESTOS WORK

TRENCHING & EXCAVATION SANDBLASTING

SIGNS & BARRICADES ACCIDENT INVESTIGATION

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ELECTRICAL SUBSTANCE ABUSE

9. NEW EMPLOYEE SAFETY ORIENTATION:


DO YOU HAVE A SAFETY ORIENTATION PROGRAM FOR NEW HIRES? NO YES IF YES, DOES IT
INCLUDE ANY OF THE FOLLOWING?

YES NO N/A YES NO N/A

HEAD PROTECTION HAZARD COMMUNICATIONS

EYE PROTECTION TRENCHING & EXCAVATION

HEARING PROTECTION SIGNS & BARRICADES

RESPIRATORY PROTECTION ELECTRICAL

FALL PREVENTION CRANE & RIGGING

HOUSEKEEPING VEHICLES

FIRE PREVENTION & FOOT PROTECTION


PROTECTION

FIRST AID EMERGENCY HAND TOOLS/POWER TOOLS


TREATMENT

EMERGENCY EVACUATION LADDERS & SCAFFOLDING


PROCEDURES

ACCIDENT/INCIDENT WELDING & CUTTING


REPORTING

SUBSTANCE ABUSE

10. SUPERVISOR SAFETY TRAINING:

DO YOU HAVE A PROGRAM TO DEVELOP NEWLY NO


HIRED OR PROMOTED SUPERVISORS?
YES, IF YES, DOES IT
____________________________________

INCLUDE ANY OF THE FOLLOWING?

YES NO YES NO

SAFE WORK PRACTICES ACCIDENT REPORTING &


INVESTIGATION

SUPERVISOR SAFETY EMPLOYEE DISCIPLINE


RESPONSIBILITIES

SAFETY MEETINGS EMPLOYEE ORIENTATION

EMERGENCY PROCEDURES SUBSTANCE ABUSE


AWARENESS/PREVENTION

FIRST AID PROCEDURES

11. EMPLOYEE SAFETY MEETINGS:

DO YOU CONDUCT EMPLOYEE SAFETY NO


MEETINGS?
YES, IF YES HOW OFTEN?
__________________________________

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WEEKLY
BIWEEKLY
MONTHLY

12. COMPANY SAFETY PROGRAM MANAGER:

IDENTIFY THE PERSON (TITLE) WITHIN YOUR COMPANY DIRECTLY RESPONSIBLE FOR THE SAFETY PROGRAM

MANAGEMENT:

NAME

TITLE

COMPLETED BY:

PHONE:

TITLE:

DATE:

Table 8 – Subcontractor safety qualification evaluation form (part 2)


SUBCONTRACTOR SAFETY QUALIFICATION EVALUATION FORM

SATISFACTORY UNSATISFACTORY INCOMPLETE


RESPONSE

INJURY AND ILLNESS STATISTICS

SERVICE CATEGORY NA

SUPERVISOR SAFETY MEETINGS

SAFETY INSPECTIONS

ACCIDENT RECORDS

ACCIDENT REPORTING

WRITTEN SAFETY PROGRAM

SAFETY PROGRAM ELEMENTS

NEW EMPLOYEE SAFETY


ORIENTATION

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SUPERVISOR SAFETY TRAINING

EMPLOYEE SAFETY MEETINGS

COMPANY SAFETY PROGRAM NA


MANAGER

SUBCONTRACTOR QUALIFICATION APPROVED DISAPPROVED APPROVED WITH


STATUS EXCEPTION

EVALUATOR DATE

APPROVER DATE

11.2 Pre-start review and approval of H&S and E&S MP and competent resources

Subcontractor shall have adequate H&S and E&S performance, and provide the following information to
maintain H&S and E&S standard at site:
 HSE plan.

 CESMP

 HSE and SR Policy.

 HSE and E&S Risk assessments.

 HSE Management organization.

 HSE and E&S Training details.

 Provide resources and assistance to assure compliance with minimum expectations.

 Confirmation that PPEs to be used is properly selected and maintained.

 Confirmation that machineries and equipment to be used is properly selected and maintained.

 Confirmation that equipment operators are qualified and properly trained.

 Confirmation that they will comply with EPC Contractor HSE and CESMP Plans.

 Insurance details.

 The Subcontractor should provide the eligible physical examination certificate of all employees to
Contractor’s HSE department before start working, or else, forbidden working.

 Subcontractor shall assign HSE personnel according to the national regulation rate per construction
employees, or every 40 workers, whatever is stricter.

Special detail shall be given to the approval of the HSE and CESMP Plan of the Subcontractors. Each
subcontractor shall submit the plans prior to start the works onsite, to their specific EPC Contractor’s HSE
Department for its adequacy to the scope of the subcontractor’s activities, if required.
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Subcontractors HSE and E&S Plans shall be submitted to Owners’ HSE Department for their review and
comments, as well.

Subcontractor’s HSE and E&S Plans shall meet or exceed the HSE and E&S requirements of EPC
Contractor HSE Plan and CESMP, as per their scope of activities.

11.3 Competence Assessment of HSE and E&S Staff.

Subcontractors shall comply with the requirements of Owner’s HSE staff qualifications stated in the EPC
Contract for Al-Dur II IWPP, Appendix V. The Subcontractor on-site staff shall include HSSE personnel
who shall be appropriately qualified as detailed in the table below: “Competence requirements for EPC HSE
Personnel”. Deviations from the below minimum requirements are by exception and with the Owner’s prior
written approval.

Table 9 – EPC Contract Requirements for HSE Staff Qualifications


Position Qualification IOSH HSE Experience English Fluency Owner Approval
Accreditation
HSE Manager Technical degree Full Membership >10 years in power/ CEFR – B2, Interview before
plus of professional renewables industry Independent User, arrival at site and
IOSH/NEBOSH organization/ and construction Upper Intermediate 3 month probation
recognised institute sector(s) as HSE Proficiency period
international HSE professional determined face to
degree/diploma (accumulated) face or video
conference
Senior HSE Technical degree Full Membership >10 years in power/ CEFR – B2, Interview before
Advisor plus of professional renewables industry Independent User, arrival at site and
IOSH/NEBOSH international and construction Upper Intermediate 3 month probation
recognised organization/ sector(s) as HSE Proficiency period
international HSE institute professional determined face to
degree/diploma (accumulated) face or video
conference
HSE Supervisor Technical or trade Membership of >7 years in power/ CEFR – B1, Review of CV
Diploma in related professional renewables industry Independent User, before arrival at
or similar industry international and construction Intermediate site and interview
plus organization/ sector(s) as HSE Proficiency by exception
IOSH/NEBOSH institute professional determined face to
recognised (accumulated) face or video
international HSE conference
degree/diploma
HSE Engineer Technical or trade Membership of >4 years in power/ CEFR – B1, Review of CV
Diploma in related professional renewables industry Independent User, before arrival at
or similar industry international and construction Intermediate site and interview
plus organization/ sector(s) as HSE Proficiency by exception
IOSH/NEBOSH institute professional determined face to
recognised (accumulated) face or video
international HSE conference
degree/diploma
HSE Officer Technical or trade Associate >4 years in power/ CEFR – B1, Review of CV
Diploma in related membership of renewables industry Independent User, before arrival at
or similar industry professional and construction Intermediate site and interview
plus international sector(s) as HSE Proficiency by exception
IOSH/NEBOSH organization/ professional determined face to
recognised institute (accumulated) face or video
international HSE conference
degree/diploma

11.4 Coordination of Subcontractor’s works

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Coordination of Subcontractor’s works is the responsibility of the Planning Department. On a daily basis,
EPC Contractor management shall organize a daily meeting in order to review the progress of the project
activities. All the head of departments shall attend this meeting in order to report the achieved progress of the
day as well as the planned activities for the day ahead.

As an attendee of this meeting, the HSE Department representatives will be informed of the ongoing
activities in order to control the HSE and E&S issues related to the activities through the Permit to Work
System of the Project.

All construction activities shall be carried out within the Permit to Work System guidelines, as per the point
No. 14 of the Project’s HSE Management Plan. Compliance of the HSE and E&S requirements by
subcontractors shall be reviewed by applying the Daily PTW Audits.

11.5 Monitoring and Management of Subcontractor’s E&S Management and Performance

Subcontractor management shall implement the Monthly Area Safety Assessment program. Areas will be
determined according to field supervisor area of responsibility and craft. Subcontractor management,
supervisors and field safety officers shall actively participate in the program and conduct monthly safety
assessment audits of all the work areas to quantitatively evaluate and document the assessment. Unsafe acts
and/or conditions noted during daily inspections and weekly audits shall be corrected immediately. The
following further outlines the program:

 The assessment will be scored by reducing the total possible points in a category by one point for each
deficiency noted.

 Subcontractor shall immediately correct all deficiencies noted on the assessment within 24 hours or
provide a written explanation as to why a deficiency was not corrected.

 Subcontractor shall provide a written corrective action plan, signed by Subcontractor management
within 24 hours of receipt of the assessment to contractor’s management for a safety assessment scoring
below 80%

EPC Contractor HSSE and Construction representatives shall be part of the team carrying out these monthly
safety assessments.

Owner’s HSSE and Construction representatives are always welcomed to join these monthly safety
assessments to subcontractors.

11.6 Actions to be taken to correct substandard E&S Performance

Quarterly E&S Assessments shall be part of the performance tracking for subcontractors as per the point 18.1
of this plan. However, EPC Contractor E&S representatives shall carry out daily inspection throughout the
site, verifying the compliance of the E&S requirements of the activities carried out by EPC Contractor and
its subcontractors. Daily Observations reports shall be issued by EPC Contractor HSE Department in the
events where unsafe acts and unsafe conditions are observed during such daily inspections. The timings for
closing out findings and to implement corrective actions shall depend on the level of risk representing to the
Health and Safety of the employees and/or the severity of the effect to the Environment. This deadline timing
shall be set up as per the decision of the EPC Contractor HSE Manager and Owner’s HSE Manager, when
needed.

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In the event of a work stoppage based on E&S deficiencies, the Subcontractor shall immediately remove the
workforce from the work area and correct the E&S deficiencies by allowing only the people in the area that
are competent to make the area safe.

Subcontractor shall ensure no other work is being performed during this time. Should the estimated time
from the outset to make the area safe be longer than four hours or where life threatening/imminent danger
situations exist, then the area will be hard-barricaded and a sign placed with the wording “Unsafe Area –
Authorized Access Only. Name and contact details of the Barricade responsible supervisor. Estimated
duration of the barricading”.

Before the workforce is allowed back in the area, Subcontractor shall ensure the area is re-inspected by EPC
Contractor and Subcontractor’s HSSE Representatives and field supervisor and note corrective actions taken
and declare the area safe for work.

11.6.1 Disciplinary Action

EPC Contractor and Subcontractors will implement a disciplinary policy and procedure and include the
requirements of the Contractor. Apart from Subcontractor’s own internal disciplinary procedure, Warning
Letter System will be applied, in the system, the violations are divided as follows:

 Minor violation
 Serious violation
 Very serious violation

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Figure 8 – Warning Letter System

12. E&S Meetings and Communication

12.1 Programme of Meetings

12.1.1 Contractor shall hold a regular project E&S review or E&S meeting to ensure the continual sharing
and communication of key E&S information.

12.1.2 Project E&S reviews shall be held monthly as part of the HSE Monthly Meetings. The project E&S
review shall be attended by the following personnel:

Mandatory

 Project Manager / Construction Manager


 Division Construction Managers
 Project HSE Manager
 Environmental & Social Management Representative/Engineer

12.1.3 The Project E&S Review shall include an agenda to cover:

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 Review of previous MOM actions list
 E&S NCR’s status
 HSE and E&S management and performance statistics (lagging and leading)
 Grievances received and their status
 Contractors Management and Performance
 New Subcontractors on-site – introductions
 Subcontractor’s E&S reports (5 minute each)
 E&S Inspection/tours findings
 Incidents Review and Lessons Learnt (including Near Misses)
 Disciplinary Actions and Awards Schemes
 Review of performance and management of key E&S Issues
 Housekeeping
 Traffic Management (including road conditions, etc.)
 Access Control (including security, fencing, etc.)
 Welfare
 Diesel and hazardous substance storage and management
 Training (including inductions)
 Updates to CESMP
 Look ahead for 4 weeks – focusing milestones and major E&S related activities, scheduling and
coordination of works packages, subcontractor activities and review method statements and risk
assessments
 Laws and regulations updates
 Any Other Business

Following the project E&S review, a second E&S review shall be held with Subcontractors. This review
shall be chaired by the Project HSE Management. Subcontractors HSE representatives shall attend along
with a representative from operations.
The Project HSE Management shall prepare an agenda for this meeting that shall include the minimum
issues set out in above.

12.2 E&S Kick-off Meetings

Prior to the start of work at each site, a kick-off meeting between Contractor and Subcontractors shall be held
and attended by related Personnel - Site Manager, HSE Manager and Construction Manager and
Subcontractors Key Personnel. The following items shall be discussed.

 Nature and Scope of Work


 Site E&S Specific Work Plan & E&S Program
 Method Statements and Risk Assessment
 Reporting and Investigation Procedures of an Incident
 Health, Safety, Environmental, Social and Security Issues or Issues of current Concerns
 Community Relations
 Emergency Response
 Welfare Provisions
 Community and Social Requirements

12.3 Client E&S Meeting

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Contractor will attend Client E&S meeting and comply with client’s meeting procedures. Solve the issues
raised by the client in the meeting on time or at least before the deadline mentioned.

12.4 Minutes of Meeting

Minutes of meeting will be prepared and circulated to all attendees and relevant personnel. Formal minutes
shall be taken, action plans generated, and records maintained for all project E&S meetings. The
communication of minutes shall be in line with project document control procedures.

13. Communication and review

13.1 Communications

E&S information shall continually be communicated and Environmental and Social practices promoted
through all the stages of the project.

All workers shall attend daily toolbox talks or briefings to communicate and reinforce planned control
measures. No worker shall be instructed to commence work without being advised of the relevant hazards
and his duties with regard to his own, and other workers, health and safety.

The project HSE team shall prepare, publish and distribute throughout the site, E&S themed posters relevant
to the work in progress. These shall assist in reinforcing and supporting a safe approach to work. E&S notice
boards shall be placed at site and office access points and in rest / canteen areas. Notice boards shall display
pertinent E&S information (posters / statistics / restrictions etc.).

Project Director shall initiate an E&S award scheme, where employees are rewarded for their efforts in E&S.
The HSE Manager shall administer the awards scheme on behalf of the Project Director.

Communication / promotion materials shall be made available in the major languages relevant to the
majority of workers.

E&S alerts shall be produced where learning opportunities can be gained from HSE and E&S incidents. E&S
alerts shall be shared with all business divisions and supply partner companies.

Employees shall be encouraged to allow two-way communications with regard to their E&S concerns or
improvement suggestions via grievance form.

E&S boards will be located on the project to provide up-to-date information regarding E&S issues and
emergency contact details.

The following Communication Schemes shall be followed:

Table 10 – Communication schemes


Internal Communication and The Contractor’s HSEM will have overall responsibility to
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Reporting communicate the E&S requirements of the CEMP to all staff
including any updates. This will include appropriate site
inductions, training and tool-box talks.

Staff Communication There is a requirement for the content of the CESMP to be


effectively communicated to all staff. Accordingly, it is the
Contractor’s requirement to ensure the appropriate translation of all
documents into languages that can be understood by all employed
personnel.

It will also be the Contractor’s responsibility to communicate the


requirements of the CESMP to all illiterate site staff and those for
whom English is not their first language.

Owner/ Contractor Communication A single point of contact between the Contractor and Owner will
and Reporting be established. This will be used as a mechanism to report any
changes to the construction processes, methods and/or program that
could require modifications to working practices in terms of
environmental and social management, incidents and non-
conformances.

Communications with the Public and All dealings with the public shall be managed by the Project
Media Director or his designee. No contact will be made with the media
unless authority has been given explicitly by Owner.
Communication with Government All dealings with the Authorities shall be managed by the Project
and/or other regulator entities Director, the Administration Manager and the EPC Contractor’s
Public Relations Officer. No contact will be made with the
authorities unless approval has been granted explicitly by Owner.

13.2 Performance Reviews

Regular review by the HSE manager is required to evaluate the performance of this CESMP and maintain
continual improvement, suitability and effectiveness of the procedures contained herein.

A formal review of this CESMP taking into consideration all environmental and social records (e.g. filed
complaints with corresponding corrective actions taken, environmental non-compliances and
internal/external audit reports) shall be undertaken by HSE manager as per the Project manager audit
schedule and the updated CESMP shall be submitted to the Head office HSE manager for review.

Construction environmental and social performance and adherence to the requirements in this CESMP are
within the scope of the weekly E&S meetings and monthly Site HSE Committee meetings.

Table 11 – CESMP Reviews


Weekly Reviews Weekly reviews chaired by the Contractor’s HSE manager and attended
by the Subcontractor HSE Manager will be held to review performance
and coordinate the proceeding week’s work schedule of activities;
highlighting specific environmental and social measures that are to be
implemented accordingly.

The review will form part of the wider meeting agenda for the project

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and will be additionally used to provide an opportunity for attendees to
report the findings of their inspections together with any
continuous/recurring issues.

The following key aspects will be reviewed weekly:

 findings of the daily and weekly inspections;


 instances of non-conformances and corrective action;
 complaints; and where necessary;
 training requirements.

Minutes will be taken and actions recorded at each meeting for review
by HSE manager.
Monthly Project One of the Weekly Reviews will form a Monthly Review. This will be
Environmental and Social chaired by the Contractor HSEM and attended by those present at the
Review Weekly Reviews.

The review will be used to:


 consider performance in that month compared to other months as
informed by the site inspections, audits and monitoring data; and
develop a plan of action for activities undertaken in the preceding
month.

This will be reported in the Monthly Performance Report supplemented


with KPI’s (key performance indicators).

13.3 Communicating E&S Commitments

Senior management support, as described earlier, shall generate an environmentally and socially responsible
culture as a platform for fully implementing this CESMP. In addition:

 Daily toolbox meetings onsite shall include environmental and social management implementation as an
agenda item;
 Weekly E&S meetings onsite shall include discussion and review of environmental and social matters;
 Monthly environmental and social review meetings shall be held onsite for relevant staff including
internal teams and representatives from the Subcontractors; and
 In addition to the proposed formal training, opportunities for raising awareness of the importance of
environmental protection and social responsibility shall be identified and implemented throughout the
Project.

14. Environmental Incident Reporting and Investigation

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14.1 General

Incidents shall be managed in accordance with Accident Reporting, Investigation Procedure (AD2-C3-00-
YDC-GGP-CON-00040).
The project induction shall educate site staff and workers on the response steps in the event of an incident or
accident related to Environmental issues. This shall be regularly reinforced during tool box talks and
briefings.
Simple emergency response flowcharts which are contained within the Emergency Response and Crisis
Management Plan and the Spill Prevention Plan shall be posted in site offices and in welfare facilities.
Where appropriate, alternative language versions shall be prepared by the EPC Contractor HSE team.

14.2 Damage to environment and Reporting System

 An incident that results in environment damage must be reported immediately.

 In the event of environment damage incident on the project, the related employee must report to the
HSE Manager immediately by verbal/SMS notification of an incident. And the HSE Manager arranges
the related Environmental engineer to investigate the incident and make the preliminary incident
report. All preliminary written reports have to be submitted within 24 hours.

14.3 Investigation

The purpose of an incident investigation is to identify the root cause and the contributory factors in order that
it can be prevented from recurring in the future.

In case of incidents involving Environmental Pollution, the following must be checked by trained
investigators:

 Equipment being used

 Affected areas

 Materials or chemicals being used

 Safety devices in use

 Position of appropriate guards

 Position of controls of machinery

 Damage to equipment

 Housekeeping of area

 Weather conditions

 Time of day

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And then the following document to be reviewed:
 The witness statement

 Photographs as evidence

 A layout of the incident site

 Approved RA/Method statement/operation manual

 Engineering drawing

 Training record.

 Qualification certificate of personnel/machinery

At the conclusion of an incident investigation, a meeting will be held at the work site of the incident to
establish the cause and proper corrective actions which have to be taken.

The following personnel will attend this meeting:

 Contractor HSE Manager

 Contractor Environmental & Social Representative/Engineer

 Subcontractor’s HSE Manager

 Sub/Contractor Construction Manager / Engineer in charge

 Owner HSE Manager (optional)

There will be obliged to investigate the facts which caused damage to the environment in order to detect the
causes of these events.
The incident investigation methodology to be taken is:

 Data Collection

 Data integration

 Determination of causes

 Selection of the main causes

 Management of the causes

 Establish corrective actions to address these causes, assigned to each of such shares deadlines, and
responsible media.

 Recording of research: report

The figure No. 9 shows the flowchart of the basic steps to investigate incidents related to Environmental
issues.

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The figure No. 10 shows the format to use for the investigation and documentation of the incidents.

Figure 9 – Incident Investigation flowchart

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Figure 10 Incident/accident investigation report

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15. Emergency Response Plan

15.1 General

An Emergency Response and Crisis Management Plan (AD2-C3-00-YDC-GGP-CON-00016) shall be


developed for the project by the contractor HSE team. The EPC Contractor recommended format shall be
used following approval from Owner. This shall be a controlled document and shall be formally issued to
relevant staff and stakeholders.
Local emergency services shall be consulted as necessary during the planning of project emergency
procedures.
First aid and medical facilities shall be implemented in line with the General HSE and E&S Requirements.
Should contractual or local requirements require additional measures then these shall be implemented. First
aid and medical facilities shall be clearly sign posted. Only authorized first aiders and the site nurse shall be
permitted to open and use first aid supplies.

15.2 Emergency Response Team

Organization in the event of emergency requires the coordinated action of the Emergency teams comprising
the various supervisors mentioned in the procedure. These emergency teams will consist of:
 Emergency Committee Manager

 An Alarm and Evacuation Team (personnel responsible for activating the emergency siren)

 A First Aid team (first aid post medical assistance)

 A First response team (site personnel).

 A Second intervention team (personnel external to the site, such as fire fighters, civil protection, etc.)

 Access Control Surveillance service.

Emergency
Committee
Manager

Alarm Team Evacuation Extinguishing


First Aid team
Team team

Figure 11 – Emergency Response Organization

15.3 Emergency Resources

An Emergency Response Vehicle will be available at site, as well as staff specially trained to drive it.

The provision of these services will be complemented with the provision of a first aid kit, located in the
working facilities, in the room used to treat and attend accident victims.
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A group of workers should be formed so that, when someone gets hurts, there could be always a person with
knowledge in first aid techniques and standards to assist the injured.

A group of fire fighters who have the knowledge in method of firefighting and usage of firefighting
equipment shall be established at site.

Spill kits, absorbing materials, containers, eye washing facilities, PPEs etc. for any environmental emergency
involving the spillage or leakage of chemical, oil or fuel shall be available at site, which can be immediate
utilized by emergency response team.

Fixed telephone numbers for communication with the emergency and medical service will be established.
Reserved emergency numbers will be displayed in all the information boards and to be used in an emergency
situation.

Technical means: fire extinguishers will be strategically placed according to their effectiveness.
Multipurpose powder extinguishers and CO2 will be distributed throughout the plant. The Fire extinguishers
are to be of the appropriate type and appropriate at pertinent locations with unrestricted accessibility. All
personnel should at least know how to use them.

Table 12 – Portable Fire Extinguishers

Technical protection Location

ABC DCP and CO2 fire extinguishers Distributed in: offices, living quarter,
warehouse, Electrical room, welding work
zones, oil storage area. etc.

Manpower: All workers should be aware of the Emergency Response Plan and their roles and responsibilities
in an emergency situation.

15.4 Emergency Medical Services


The goal of emergency medical services is to either provide treatment to those in need of urgent medical
care, with the goal of satisfactorily treating the present conditions, or arranging for timely removal of the
patient to the next point of definitive care. (This is most likely an emergency department at a hospital.)
Emergency medical service exists to fulfill the basic principles of first aid, which are to Preserve Life,
Prevent Further Injury, and Promote Recovery.

15.5 Emergency Communication

Mobile Phones will be the main communication method for emergency purposes.
Location of accidents will be clearly communicated by area according to the area identification system
All emergency contact numbers will be saved on all project line management’s mobile phones.
All emergency contact numbers will be clearly displayed in all project site working and office areas.

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Plot plans indicating assembly points and evacuation routes will be clearly displayed in all project site
working and office areas.
A simple process flow of the steps to take will be clearly displayed in all project site working and office
areas.
As per hazard study, include and indicate by area specific hazards and safety precautions on the final
approved layout plan.

15.6 Emergency Preparedness (Natural and Manmade)

Emergency preparedness plan defines all levels of responsibility, procedures, and resources required for
preparedness, response, and recovery from the impact of natural and manmade incidents.

This element describes the minimum emergency preparedness requirements that the EPC Contractor shall
fulfill in order to ensure the availability of all the resources needed to made the Emergency Response Teams
be capable to face all kind of potential emergencies.

15.6.1 Emergency Assessment

EPC Contractor is responsible for developing an assessment, probability estimation and impact of
foreseeable and/or potential incidents in Al-Dur II IWPP. The assessment shall take into account the
potential effects to:

• Employees
• Communities
• Facilities (from both construction site and 3rd parties)
• Assets
• Business Continuity
• Operations

EPC Contractor Departments and subcontractors are responsible to prepare the ‘emergency risk assessment’
for use in all kind of emergencies.

15.6.2 Identify Emergency Scenarios

The first step in determining emergency response resource requirements is to develop a list of credible
potential emergency scenarios, assess the consequences of each, and then decide how to best address them in
the planning process. Some examples are as follows:

 Fire/explosion
 Flammable gas release
 Diesel spill release
 Hazardous substance spill
 Fatalities/multiple injury/illness/hospitalization
 Traffic incidents
 Natural disaster (e. g. earthquake, hurricane)
 Building collapse
 Medical emergency involving multiple casualties
 Epidemic

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 Food poisoning
 Security incident
 Business interruption

Appropriate emergency response strategies must be developed based on the following considerations:

1) Protect the life of personnel and third parties


2) Minimize business interruptions, asset losses, and property damage
3) Minimize environmental effects
4) Preserve business reputation

The EPC Contractor shall develop a detail Emergency Response Plan that will describe the response
procedures, organization, communications, and resources to be used in all kind of likely emergencies
throughout all the stages of the project. Each EPC Contractor’s Department and subcontractor shall be
responsible for ensuring that all supervisory and key personnel fully understand their respective role in a
major emergency within their works of responsibility. This shall also include the continual readiness and
availability of communication devices, support equipment, vehicles, materials, and other necessary
resources.

The EPC Contractor shall be responsible for developing a comprehensive emergency response plan
providing clear guidelines for establishing:

 Procedures to control the emergencies


 Evacuation plans and assembly areas
 Emergency Response Teams Organization
 Incident command center setting up
 Logistics (medical, shelter, water and food supplies)
 Damage control team to prevent secondary losses
 Orderly recovery of operations
 Emergency Drills

EPC Contractor shall also develop the Emergency Response Plan based on the actions to minimize the
potential impacts on the surrounding communities and 3 rd party facilities due to the identified emergency
scenarios. Also, EPC Contractor shall establish the basic guidelines to follow in case of potential
emergencies that may arise in the facilities surrounding Al-Dur II IWPP (Al-Dur Phase I plant, Gas Station,
Substation).

Apart from natural disasters and deliberate attacks, all efforts must be directed at the prevention of any
emergency prior to it to occur. A mechanism to anticipate these types of emergency shall be established. The
information may either come from stakeholders, government agencies and other interested parties. The
relevant incident shall be analyzed and tracked by project emergency team and shall alert the project
management on the potential effect and developing situation of the emergency situation.

15.7 Fire Prevention & Portable Fire Extinguishers

The Fire Prevention Plan is part of a program to promote the conservation of property and continuity of EPC
Contractor activities in the project as well as protection of safety to life by adequate fire prevention and fire

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protection measures in the plant. Proper preventive maintenance of equipment as well as adequate training
are important aspects of a viable fire prevention program.

15.8 Fire Prevention for Construction

Good Housekeeping shall be maintained in all work areas. (Accumulation of flammables is prohibited.)

Fire protection equipment will be provided in all areas where combustible materials are present. Regular
inspections will be made by the HSE Department to assure that fire extinguishers, hoses, reels and hydrants
are in good working order. No unauthorized use of fire hydrants, hose stations and post indicator valves
(PIV) will be permitted without authorization from EPC Contractor HSE Department.

A clear access to all fire protection equipment will be maintained. (Including extinguishers, hose reels,
hydrants, etc.)

Fire protection equipment is to be used only for that purpose.

Fire lanes inside of all buildings shall be maintained and kept clear.

Smoking will be permitted only in designated areas.

15.8.1 Requirements

Contractor/Subcontractor shall at a minimum comply to the following requirements:

 Develop and present for review a fire prevention-training program and implement it to the work force.
 Adequate distance for firefighting equipment shall be maintained between temporary structures and
permanent facilities.
 The use of wood or combustible temporary shacks around permanent buildings under construction shall
be minimized. All temporary shacks shall be kept a minimum distance of 20 meters from the perimeter
walls of such buildings.
 Temporary buildings and shelves and storage containers in warehouses shall be built of non-
combustible materials.
 Fireproofed cabinets or other fire-resistant storage facilities shall be used wherever important
documents are stored.
 Provide portable or permanently mounted extinguishers shall be available within 10 meters of a
workforce involving welding, burning or the use of an open flame.
 Each welder shall use welding blankets in order to contain weld splatter.
 At least one permanently mounted fire extinguisher shall be provided in each building near the door.
Additional extinguishers shall be mounted so as to have one available within 20 meters of any point
inside the building.
 Extinguishers shall be located within 15 meters of any point on the perimeter of material stored in fuel
or combustible materials storage areas. Additionally, these areas shall be identified with signs restricting
vehicle access and prohibiting fire ignition sources and smoking.

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 A permanently mounted extinguisher shall be placed on each item of mobile industrial equipment
having a diesel or gasoline engine, and on all welding machines.
 All fire prevention/firefighting equipment shall be inspected monthly to ensure they are in a good
working order and replaced if faulty. Records of inspections shall be maintained for review, as
applicable.
 EPC Contractor shall establish channels of communication and working arrangements to obtain the
assistance of the site firefighting resources and Civil Authorities.
 Fuel containers shall be of metal and equipped with an air-vent.
 Fuel trucks will be properly grounded when refueling equipment. Equipment shall be switched off
during refueling.
 Stored oxygen cylinders shall be separated from gas cylinders by either a fire-retardant partition of at
least 2 meters high or a minimum distance of 6 meters away.
 Contractor shall provide a layout of temporary facilities that incorporates all the fire prevention
requirements.
 To prevent ignition hazards, electrical wiring and equipment shall be installed in accordance with the
National Electrical Code.

15.9 Prevention and Response to Spills and Accidental Discharges

The most common environmental emergency in construction site is the oil and chemical spill, which is a
potential cause for soil contamination, groundwater and water pollution. Spills of hazardous materials may
include:
 Gasoline
 Diesel
 Adhesives
 Hydraulic oil
 Lubricating oil and grease
 Cleaning solvents
 Paint and paint thinners
 Concrete from release agents
 Sewage Water
 Chemical Substances used in the Pre-Commissioning and Commissioning Stage

The ERP must be prepared to cover all potential risks of accidents or spills and will be made known and
available to all workers within the construction site. Key personnel will know and understand their
responsibilities as well as coordinate their response actions with their subordinates.

Each individual will be introduced to their Line Supervisor and HSE team members during the induction
training. Emergency services shall be notified as necessary by the Supervisor or HSE Team members.
A variety of equipment and personal protective equipment may be needed to support a chemical or oil spill
incident response. A list of equipment is detailed below:
• Sand
• Sand bags
• Buckets and shovels
• Storage containers

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• Spill kit

Sand stocks will be dry and buckets and shovels readily available. Mechanical loading shovels, excavators
and dump trucks may also be available for sand distribution and clean up. Storage containers for
contaminated materials and earth will be in place, located in the waste storage area, labeled and treated as
hazardous waste. These material are to be used to contain and clean up pollution/spills, proper care will be
taken to dispose of any absorbent materials properly. The Supervisor and Environment Coordinator will keep
stocks well maintained and replenished.
In the event of a chemical or oil spill, the following measures will be taken:
• Notify Supervisor or Environment Coordinator
• Only attempt containment and clean-up operations of spilt substances when it can be performed
safely
• If spilled material is flammable, eliminate sources of ignition near spill area
• Evacuate personnel and neighbours if they are at risk
• Secure the area and establish perimeter control at a safe distance from the spill.

Oil Spill Response Options

Remedial action to collect and remove all materials contaminated by the oil spillage or leakage event is to be
taken immediately. The following actions are required:

 Any oil remaining on the ground is to be collected using oil spill kit. The spill is to be surrounded by
the kit and then the area of the spill is to be slowly reduced by enclosing the absorbent. The absorbent
pads will be used to absorb the oil. Once all of the oil on the ground surface has been collected, the
absorbent agents themselves are to be appropriately stored and disposed of.
 All contaminated materials are to be handled as hazardous waste. The contaminated material shall be
collected and appropriately stored. A hazardous waste vendor will collect this material.
 Contaminated materials will be stored in plastic barrels with tightly closing lids. These barrels are to
be stored in a concrete lined bund if available. In absence of such a bund at the site, a double plastic
lined bund will be used. Barrels will be placed on plastic or wooden pallets in the temporary double
plastic lined bund and not directly on the plastic.
 All contaminated materials that cannot be collected and disposed are to be cleaned in-situ. This
cleaning is to be undertaken by an approved service providers.

Chemical Spill Response Options

The following actions are to be taken in case of a chemical spill:

 Only attempt containment and clean-up operations of spilt substances when it can be performed safely.
 If spilled material is flammable, eliminate sources of ignition near spill area.
 Liquid spills – The spill path will be blocked or diverted and then soaked up using an absorbent material
such as sand.
 Gaseous leaks – A gaseous leak must be stopped at the source as soon as possible and will then be
dispersed in the air.
 No spills will be rinsed away.

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 Contaminated soils and clean-up materials from spills will be handled properly using personal
protective equipment, stored in a suitable container that is labeled and stored in the appropriate location
for subsequent disposal.
 Any stockpiles of remnant contaminated materials will be covered.
 Contaminated materials will be stored in plastic barrels with tightly closing lids. These barrels are to be
stored in a concrete lined bund if available. In absence of such a bund at the site, a double plastic lined
bund will be used.
 Barrels will be placed on plastic or wooden pallets in the temporary double plastic lined bund and not
directly on the plastic.

15.10 Evacuation Exercise

Contractor will identify suitable and appropriate assembly point areas.

These areas will be communicated to all employees and visitors.

Evacuation routes must be identified and marked by all Subcontractors to the closest designated assembly
points.

The Identified areas must have a sign so that employees can clearly identify the area in case of an
emergency.

If evacuation from the project is total, the main site offices shall be informed and the designated meeting
point shall be identified previously by the EPC Contractor Management Team.

The evacuation will be started on the orders of the Emergency Manager in charge, who will be responsible
for vacating the plant.

The order to evacuate will be made by activating the corresponding alarm or will be given verbally.

Members of the Evacuation Team or the Emergency Manager-in-charge shall ensure that all the employees
have left their work stations. They should then be counted at the specific assembly point in order to ensure
that no one is missing. Should anyone be missing or absent, the Emergency Teams shall be duly informed of
this fact.

Regular practice of evacuation drills will be conducted biannually to ensure that all personnel are aware of
evacuation routes and assembly point and what to do in case of emergency.

15.11 Emergency Contact Phone Numbers

Table 13 - List of Emergency Contact Numbers

Name Designation Telephone / Mobile

Kong Lingfeng SEPCOIII Project Director +971 58 833 5075


Pang Zhongjian SEPCOIII Vice Project Manager +973 3233 5782

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Zhang Liang SEPCOIII Vice Project Manager +973 3937 1442

Ju Zhiqiang SEPCOIII Chief engineer +971 52 589 8159

Gerardo Alvarez Sanchez SEPCOIII HSE Manager (International) +973 3836 7160

Pan Changhui SEPCOIII HSE Deputy Manager +971 52 589 9578

Zhu Hailin SEPCOIII Construction Manager +973 3949 8454

Sun YaoWu Electrical Manager +973 3822 4575

Li Fangyin SEPCOIII Administrative Manager +973 3384 8363

Liu Weiyi SEPCOIII Civil Department +973 3806 4721

Guo Wenbo SEPCOIII QC Department Manager +973 3949 8378

Li Yang SEPCOIII HR Manager +973 3837 7693

Frédéric Meyer SIDEM Project Director +33 6 26 15 03 43

Frédéric Denison SIDEM Project Manager +33 1 49 95 77 76

Rémi Leclainche SIDEM Site Manager +966 53 003 4217

Sylvain Biez SIDEM Construction Manager +973 35 971 000

Emmanuel Belnas SIDEM Civil Manager +973 38 044 724

TBD SIDEM HSE Manager TBD

Anoop Yohannan Deputy HSE Manager +973 35 483 722

16. Environmental and Social Audits

E&S Audit will be part of the HSE and SR Internal and External Audits.

16.1 Internal E&S Audits/Self-Assessment


On a quarterly basis EPC Contractor HSE Head Office staff or EPC Contractor Regional HSE Department
shall conduct an HSE & SR Audit to the project, which shall include the assessment of the E&S
requirements of the Project. The aim of the review is to verify that EPC Contractor Al-Dur II IWPP project
management is complying with the internal EPC Contractor HSE & SR Procedures as well as the Owner’s
and Bahraini HSE & SR requirements applicable to the project.

Also, on a quarterly basis, EPC Contractor shall conduct HSE & SR Audits to the Subcontractors. EPC
Contractor reserves the right to apply HSE & SR audits more frequently, if subcontractors are achieving low
marks in previous audits.

During this internal E&S Audit, the HSE Team shall:

 visit all the areas of the project


 have meetings with staff in charge of the E&S of the subcontractors

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 ensure the fulfilment of the specifications of the CESMP
 analyze any deviations
 decide if deviations call for no-compliance notice
 open non-conformities (if needed)
 follow up on the non-conformities
 prepare a report (summary, conclusions, correctives actions)
 report the status/situation to the Project Manager and/or the HSE Manager

Environmental compliance audit checklist is shown in the appendix No. 10:

16.2 External Audits

EPC Contractor shall coordinate a 3rd party HSE & SR Audit to its HSE & SR Management System,
including the HSE & SR Management System of the Subcontractors. This external audit shall be carried out
every 6 months. This audit shall be conducted by a 3 rd party consultant with recognized international
reputation and with thorough knowledge of Bahrain regulations as well as Lenders requirements (IFC
Standards). The audit may include the participation of Owner HSE Department staff.

16.3 Control of Non-conformance

The EPC Contractor shall be responisble for developing an Environmental & Social Non-Conformity Report
Form as part of the Project-specific ESMS. This report shall be part of the E&S Audit Procedure (AD2-C3-
00-YDC-GGP-CON-00037) and shall be used to identify the root cause of the issue so that the deviation can
be corrected and the potential for any future instances can be prevented. The personnel responsible for E&S
issues on site is responsible for reporting E&S Non-Conformancies. It shall be noted that Non-
conformancies can be raised not only from formal auditing process but also from daily E&S observations
identified during daily, weekly, monthly walkthroughs, management visits and/or any other source of
identification of deviations to the E&S Management System.

Findings or Deviations shall be evaluated on the basis of the following classifications:

Table 14 – Type of HSE and S&E Audit Findings


Non-conformities (N): Failure to fulfill one or more requirements of the management system or
a situation that raises significant doubt about the ability of the client's
management system to achieve its intended outputs.

The causes of the identified nonconformities must be analyzed and


the planned corrective actions effectively implemented.

The auditor generally verifies the effectiveness of corrective action in an


on-site follow up audit unless verification is possible on the basis of
submitted new documentation.

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Minor non-conformities In individual cases some of the requirements of the management system
(MiN): are not fulfilled completely. However, this does not jeopardize the
effectiveness of the management-system.

The causes of the identified deficiencies shall be analyzed and the lead
auditor informed of the intended corrective actions.
The auditor generally verifies the effectiveness of corrective action in an
on-site follow up audit unless verification is possible on the basis of
submitted new documentation.

Opportunities for Aspects that would lead to management system optimization.


improvement (I): Implementation by the organization is recommended.

Positive aspects (P):


Positive aspects of the management system meriting special mention

Based on this classification, the HSE and E&S Audit findings will be classified. The audited team shall
develop an HSE and E&S Audit Tracking spreadsheet in which all the findings will be followed up. The
audited team shall set up deadlines for closing out the findings and the auditor team shall review and
approved them. Deadlines shall consider the criticality of each point as well as the risk that they represent for
the Health and Safety of the Employees and the Facilities as well as the Impact to the Environment. On a
weekly basis, the HSE and E&S Audit Tracking spreadsheet shall be updated by the audited team and shared
with the auditor as well as the management team of EPC Contractor as well as the Owner.

An HSE and E&S Audit Tracking spreadsheet format is shown in the Figure No. 12

Last update

Al-Dur 2 IWPP Project


Health, Safety and Environmental Department
HSE and E&S Audit Action Tracker

Type of Date of issue Proposed Current


No. Observation Actions Follow up by Close date Comments
action detection closing date Status
1
2
3
4
5
6
7
8
9
10
11
12

Figure 12 – HSE and E&S Audit Tracking Spreadsheet

16.4 E&S Observations recording and follow up

Where substandard performance is observed, the subcontractor will be issued with a formal Project E&S
Corrective and Preventative Measure Notice and appropriate action shall be taken to rectify the non-
compliance or fault as per the Non-conformance, Corrective and Preventive Action requirements of the E&S
Audit Procedure AD2-C3-00-YDC-GGP-CON-00037.

The below image is H&S and E&S Observations Daily Report. On a daily basis HSE staff records the
deviations found in the site. The report is submitted to the concerned responsible manager or his designee so
as to follow up the observations until their close-out.

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Figure 13 – HSE and E&S Daily Observations Report form

Also, the EPC Contractor and Subcontractors HSE Department records each one of the observations in the
H&S and E&S Observations Action Tracker (see image below).

Al-Dur 2 IWPP Project


Health, Safety and Environmental Department
H&S and E&S Observations Action Tracker

Month:
Proposed
Date of issue Current
No. Date Category Observation Picture Control Measure Type of Deviation Follow up by closing Close date Comments
detection Status
date

Figure 14 – H&S and E&S Observations Action Tracker

With the use of the H&S and E&S Observations Action Tracker, the EPC Contractor HSE Department will
be able to follow up the observations until their closing out. Also, this Action Tracker will serve to prepare
the H&S and E&S Observations statistics in which trends are identified based on the type of observations

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identified on a monthly basis. These statistics are part of the H&S and E&S Section for the Construction
Progress Monthly Report.

17. Reports

17.1 EPC Contractor Weekly E&S report

The project HSE team will feedback to their respective HSE manager on a weekly basis Saturday to
Thursday. The following headings are to be used: Incident update, Areas of concern, Resource requirements
(to the HSE team), forthcoming week requirements, among others.

17.2 EPC Contractor Monthly E&S report

A project report containing E&S Performance will be issued on a monthly basis covering the following
items:

1) Key E&S items and activities occurring and undertaken during the period;
2) Status of compliance of the ESIA requirements.
3) A series of proactive and reactive performance measures detailing key findings and actions taken to
address any deficiencies or promulgate learning opportunities;
4) Suitable analysis and trending results for the E&S Observation Reporting system;
5) For record keeping purposes suitable proactive and reactive statistics;
6) Engagement status of each subcontractor e.g. work hours per SOR raised, inspections and meetings
attended;
7) Upcoming E&S challenges;
8) Hours worked in the field by both EPC Contractor and each subcontractor;
9) Any other reasonable E&S performance request from the Project Team.

17.3 Subcontractors Monthly E&S report

Contractors shall prepare their own monthly E&S report analyzing their own company performance and
identifying action to be taken to ensure continual improvement is achieved. A copy of this report should be
issued to the EPC Contractor HSE Manager within 1 week of the period end. This report should also include
progress against the Subcontractors E&S Action Plan.

17.4 Owners E&S Reporting requirements

EPC Contractor Monthly E&S Report shall prepare a monthly report with the E&S Reporting Requirements
specified by the Owner. EPC Contractor shall comply with this requirement as well as any other E&S legal
reporting requirement stipulated in the Bahraini laws applicable to the project.

EPC Contractor shall use the E&S reporting formats specified by the Owners.

17.5 Environmental and Social Key Performance Indicators Recording and Statistics

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As part of the E&S Reports, EPC Contractor shall prepare the statistics of all the relevant Key Performance
Indicators.

EPC Contractor shall make use of the data available to continuously work to drive up standards in health,
safety, social and environment, employing a range of Key Performance Indicators (KPI’s) to track specific
objectives.

E&S KPI Targets shall be set up at the beginning of the project and compliance shall be verified on a
monthly basis by the HSE Manager. KPI Target compliance shall be reported on a monthly basis as part of
the Construction Progress Monthly Report.

KPI's are a valuable way of monitoring lagging or leading performance. Tracking them is an integral part of
EPC Contractor E&S Management System.

While lagging indicators can be used to track incidents that have occurred (past data) and assist in sourcing
the root of the problem, leading indicators are more predictive by nature, and will help EPC Contractor to
address and prevent potential issues and incidents from occurring in the first place.

A good KPI is a ‘SMART’ KPI:

Specific – it should be clear what is being measured


Measurable – it should be measurable against set standards
Achievable – target a realistic/achievable goal
Relevant – it should offer insight into overall safety performance
Timely – KPI’s should follow a set time-frame

The HSE Department will monitor several indicators that impact on the Environment, such as but not limited
to:

17.5.1 Leading Indicators:


 Number of E&S Training
 E&S Inspections
 E&S Programs implemented
 E&S Practices implemented
 Proactive Practices held
 Revision of E&S Procedures and CESMP
 Top Management Tours
 Preventive Maintenance
 E&S Campaigns
 E&S Audit and Monitoring
 Preventive Housekeeping

17.5.2 Lagging Indicators:

Although EPC Contractor will always strive to prevent loss in the project, when E&S cases may occur, EPC
Contractor shall pay attention and get focused on the corrective actions derived from the analysis of HSE and
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E&S incidents. These HSE and E&S incidents will be considered as lagging indicators and they will be
monitored and tracked through proper statistics on a monthly basis. The type of lagging indicators to
consider are as follows:

 Electricity consumption
 Raw Water Consumption
 Potable Water Consumption
 Treated Waste Water
 Hazardous Waste Generation
 Non-Hazardous Waste Generation
 Waste Recycled
 Environmental Incidents
 Grievance cases
 Social complaints

In order to assess and to identify trends, the man-hours generated by the man power working in Al-Dur II
IWPP will be recorded on a daily basis and reported on a monthly basis.

18.0 Recruitment policy

In order to maximise the socioeconomic benefit, the project will seek to employ local workers where
possible and where appropriate, the project will offer training to enhance the development of skills within the
local workforce. The number of local population employed in the project need to be monitored to assess the
effectiveness of the Recruitment Policy that which will be developed for the construction and operational
phase of the plant.
There is a specific procedure (Recruitment Policy plan AD2-C3-00-YDC-GGP-CON-00077) describing the
approach.

19.0 Forced and child labour policy

Introduction
EPC Contractor ‘No Forced and Child Labour Policy’ is based on the Company’s commitment to find
practical, meaningful and culturally appropriate responses to support the elimination of such labour practices.
It has been formulated in consideration with the acts. It therefore endorses the need for appropriate initiatives
to progressively eliminate these abuses.

Policy
EPC Contractor does not employ any person below the age of eighteen years at the workplace. EPC
Contractor prohibits the use of child labour and forced labour at all its units. No employee is made to work
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against his/her will or work as bonded/forced labour, or subject to corporal punishment or coercion of any
type related to work.

Implementation
This policy will be publicly available throughout the project and clearly communicated to all employees in a
manner in which it can be understood through induction programmes and policy manuals. The
implementation of the policy is the responsibility of the unit’s human resources department and the security
staff, who do not permit minors to enter the site as workers. There is zero tolerance policy towards its breach.
Employment contracts and other records, documenting all relevant details of the employees, including age,
are maintained at all units and are open to verification by any authorized personnel or relevant statutory
body.

Monitoring & Audit


Periodic checks shall be conducted by the Human Resources department to ensure there are no abuses of the
labour policies.

20. Disciplinary, Incentive & Recognition Programme

20.1 HSE and E&S Disciplinary

To ensure all employees/subcontractors/suppliers etc. adhere to the required HSE and E&S standards by
making them aware of any shortcoming and identifying the necessary improvements to be achieved, the
disciplinary action with enforcement policy shall be introduced.

The enforcement policy consists of NCR, warning notice (see figure No. 9), and both concerned departments
and subcontractors should note that, failure to comply with the requirements and time scale indicated in any
of these notices, will result in the matter being referred to project management. On being informed of the
violations, and after confirming that these have still not been attended to, Project Director will approve the
corresponding disciplinary action to the concerned subcontractor.

20.2 HSE and E&S Incentive

The EPC Contractor Good Practice Awards is one of the main elements of the Healthy Workplaces
Campaign, designed to highlight the best examples of managers and employees working together for risk and
loss prevention.
The awards aim to demonstrate the benefits of following good safety and health practices. Winners will be
expected to show strong management leadership and active worker participation in safety and health. EPC
Contractor will be looking for the best examples of mutual collaboration and benefit. Entries are welcome
from all employers and workers, safety and health professionals and practitioners, and those providing
assistance and information at the workplace level.

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21.0 Employee’s Handbook

EPC Contractor shall develop an Employee’s Handbook with regard to Health, Safety, Social and
Environmental matters. For that purpose, EPC Contractor will take into account as base the following
documents:

 CIRIA’s Site safety handbook (fourth edition) (C669)


 CITB Construction Site Safety Environment Book (GE 700Es/14)
 CITB Construction Environmental Manual (CENVMAN)
 IFC Performance Standards

22.0 Environmental and Social Mitigation, Management Measures and


Monitoring Requirements

This Construction Environmental and Social Management Plan is the vehicle for implementing the EPC
Contractor’s Environmental and Social Management System. It is intended to set out the minimum standards
for all project related activities and to provide a framework for managing and mitigating the environmental
and social issues associated with the site.

The Construction Environmental and Social Management Plan has been prepared based on the guidelines
listed in the Environmental and Social Impact Assessment for Al-Dur II IWPP based on the IFC
Performance Standards and the Bahraini legal requirements applicable to the project. The following sections
describe the Environmental and Social Mitigation and Management Measures that the EPC Contractor shall
implement during the Construction and Commissioning of the project as well as the monitoring requirements
stipulated in the project’s ESIA.

22.1 Air Quality

Air quality impacts associated with the project are to be managed during construction and commissioning.
Construction activities will result in increased air emissions from fugitive dust, particulates, fumes and
gaseous pollutants.

It is expected that the main activities, which will impact air quality through the generation of fugitive dust,
gases and other chemical substances, include:

 Excavation, stockpiling and other earthworks;


 Transportation of materials and personnel;
 Stockpiling of spoil material from excavation and dredging will generate airborne particulates that may
be dispersed under windy conditions.
 Unloading, transportation and handling of chemical substances during pre-commissioning and

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commissioning activities.
 Burn of fosil fuels during the Commissioning and Startup activites of the Gas Turbines.

22.1.1 Mitigation and Management Measures:

The Appendix No. 2 – Section 1.1 and 1.2 of this plan describe the mitigation and management measures to
be implemented by the EPC Contractor with regard to Air Quality during the Construction and
Commissioning stages of the project.

Some of the relevant requirements that EPC Contractor will implement, among others, are the following:

 Water sprays for dust suppression will be used over aggregate storage piles, internal unsealed access
roadways and work areas. Application rates will be specific to atmospheric conditions and the intensity
of construction operations.
 Where applicable, sealed roads will be swept to remove deposited material that could generate dust.
 Dust generating activities (particularly clearing and excavating) will be avoided or minimized during
dry and windy conditions (15 km/h).
 Vehicle speed limits of 20 km/h will be imposed on all construction vehicles.
 Vehicle and machinery movements during the construction works will be restricted to designated areas.
 Construction vehicles will use sealed roads wherever possible to prevent any loss of load, whether dust,
liquid or soils.
 Rumble grids and wheel wash facilities will be used at each construction site exit to remove mud and
dust from vehicles and minimize material being transferred onto a public road or footpath.
 In the event of a spillage, spilled material will be removed as soon as practicable within the working day
of the spillage.
 Vehicles transporting material to and from the construction site will be covered immediately after
loading (prior to traversing public roads) to prevent wind blowing dust emissions and spillages.
 Tailgates of road transport trucks will be securely fixed prior to loading and immediately after
unloading
 Should visible dust emissions occur at any time, works generating the dust emissions will cease, so that
emissions of visible dust cease.
 There will be a progressive rehabilitation strategy for exposed surfaces. Revegetation activities will
proceed as soon as work activities are completed within a disturbed area.
 Inspection of hazardous chemicals systems with regard to fugitive emissions, small leaks and/or venting
of fumes to the atmosphere. Leak tests shall be carried out on a monthly basis and leaks shall be fixed
immediately.
 Transportation of chemical substances shall be according to the requirements of the SDS of the material.
 Individual drums of chemical substances shall always be with the cap/plug firmly tightened so they
don’t represent a spill risk and/or fugitive emissions concern.
 Loading and unloading of chemical substances shall be carried out through systems designed for such
purpose. Connections of hoses and/or any other chemical transference system shall always be in good
condition and firmly tightened. This activity shall be done in areas where good ventilation (natural or
forced) exists.

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22.1.2 Monitoring Requirements:

The Appendix No. 2 – Section 1.3 of this plan describes the monitoring requirements to be implemented by
the EPC Contractor with regard to Air Quality during the Construction and Commissioning stages of the
project.

Some of the relevant monitoring requirements to be implemented, among others, are the following:

 Visible observations of dust will be made at all times during construction.


 Monitoring will be undertaken at all locations where construction activities could generate fugitive
emissions.
 Weekly and monthly monitoring is to be reported.
 Additional dust/hazardouschemicals monitoring may be required in response to any complaint or
following the issue of an NCR
 Exhaust will be monitored if visual checks reveal black smoke or bad odour fumes; this is particularly
applicable to fixed site plant and specialized equipment.
 Internal air quality will be monitored if activities are occurring in confined spaces.
 Monthly check of vehicle logs to ensure that servicing and maintenance checks of vehicles are
undertaken as they are due.
 Monitoring will be daily during significant dust generating activities or during periods of high winds
(>15 km/h), otherwise weekly. The HSE team will determine the frequency of monitoring, either
daily/weekly monitoring depending on the environmental condition and work activities. Wind speed and
direction will be observed prior to conducting dust generating activities to determine the potential for
dust nuisance to affect sensitive areas.
 The monitoring locations will be determined at the onset of construction activities, and the air quality
analysis results will be assessed against the relevant air quality objectives.
 Construction vehicles and other combustion sources such as generators and compressors are potential
sources of air pollution due to the generation of emissions including CO, NOx, SO2 particulates. All the
vehicles and generators will be maintained at least every six months.

22.2 Noise and Vibration

Noise and Vibration Management


The various construction plant and equipment required for the Project will generate noise that may create
nuisance to nearby sensitive receptors. Although there are no residential areas immediately adjacent to the
project site, noise levels generated by construction activities have an occupational risk on the workers.
Noise impacts must therefore be controlled to ensure that IFC standards are met at the boundary or where
there are sensitive receptors such as worker accommodation on site or at adjacent locations.

A program of construction noise monitoring will be required at representative and boundary locations on a
weekly basis to ensure that construction noise does not exceed the recommended limits.

Objectives

Identification, prevention and control of excessive noise and vibration during construction and maintain

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noise levels within the construction zone in accordance with the requirements of the Bahrain Environment
Regulations and and IFC EHS General Noise Guidelines.

22.2.1 Mitigation and Management Measures:

The Appendix No. 2 – Section 2.1 and 2.2 of this plan describe the mitigation and management measures to
be implemented by the EPC Contractor with regard to Noise and Vibration during the Construction and
Commissioning stages of the project.

Some of the relevant requirements that EPC Contractor will implement, among others, are the following:

Equipment Management

 All vehicles and mechanical plant will be fitted with effective exhaust silencers and maintained in good
working order.
 All generators and compressors adjacent to the camps will be “sound reduced” models fitted with
properly lined and sealed acoustic covers that shall be kept closed when the machines are in use, and all
pneumatic tools will be fitted with mufflers/silencers of the type recommended by the manufacturer.
 Electrically powered plant will be preferred, where practicable, to mechanically powered alternatives.
All mechanically powered plant should also be fitted with suitable silencers.
 Machines used intermittently will be shut down in intervening periods or throttled down to a minimum.
Unnecessary idling, revving and inappropriate use of equipment is prohibited.
 All pumps will be fitted with effective exhaust silencers and maintained in good and efficient working
order. All dewatering pumps to be “sound reduced‟ models fitted with properly lined and sealed
acoustic covers.
 All stationary plant will be covered where practical. Where feasible, stationary equipment will be
orientated and located away from noise-sensitive locations.
 Where reasonably and practical, the overnight operation of generators and compressors will be
prohibited using a mains source instead. Where their use is required, measures will be employed to
avoid noise transmission beyond the site boundary.
 All construction vehicles will be serviced on a weekly basis to ensure their idling speeds are maintained
and tire-pressures inflated to reduce noise levels.

Noise Management

 Diversions and accesses will be carefully designed to include road layout that minimizes traffic delays
and allows the free flow of traffic. Access routes will be away from noise-sensitive locations.
 Special regard shall be paid to minimize noise at the site boundaries. Such measures shall typically
include: the sensitive location of site offices, the construction compound and stockpiles; the use of
mobile noise screens and the silencing of plant as described above.
 Where noise levels exceed 85dB (A) noise protection devices shall be provided to personnel on-site.
This will be recorded using the Monitoring Register.
 All areas where workers will be exposed to excessive noise levels, that is 85 dB(A) and above, will have
clear warnings signs. In these areas, workers will be required to wear appropriate personal protective
equipment such as ear plugs/protectors.
 All employees and subcontractors will be advised on the need to minimize noise levels during induction
training and toolbox talks.
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 The contractor and their subcontractors will, at all times, carry out all work in such a manner as to keep
any disturbance from noise and vibration to a minimum.
 Delivery vehicles should be prohibited from waiting within or near the site with their engines running.
The movement of heavy vehicles during the night will be avoided wherever practical.
 Vibration monitoring will be carried out in areas likely to be affected.

Personal Protection
Precede mitigation should be taken at first, and the Contractor and subcontractors will provide the necessary
PPE (ear mufflers and plugs) where individuals are exposed to persistent high noise levels.

22.2.2 Monitoring Requirements:

The Appendix No. 2 – Section 2.3 of this plan describes the monitoring requirements to be implemented by
the EPC Contractor with regard to Noise and Vibration during the Construction and Commissioning stages
of the project.

Some of the relevant monitoring requirements to be implemented, among others, are the following:

Noise Monitoring
 Weekly monitoring (between 10-15 minutes) at the Project contractor camps and at Project site
boundaries will be undertaken using internationally acceptable methodology and equipment to ensure
that activities at site do not exceed boundary thresholds or impact upon receptors outside of the site. The
noise levels will be assessed according to construction guidelines for construction noise, taking into
consideration the proximity of any sensitive receptors, time of day and location of the activity. The
maximum allowable limits at 1m outside the fence is 70 dB(A).

22.3. Marine environment, hydrodynamics, water & sediment quality

22.3.1 Mitigation and Management Measures:

The Appendix No. 2 – Section 3.1 and 3.2 of this plan describe the mitigation and management measures to
be implemented by the EPC Contractor with regard to Marine environment, hydrodynamics, water and
sediment quality during the Construction and Commissioning stages of the project.

22.3.2 Monitoring Requirements:

The Appendix No. 2 – Section 3.3 of this plan describes the monitoring requirements to be implemented by
the EPC Contractor with regard to Marine environment, hydrodynamics, water and sediment quality during
the Construction and Commissioning stages of the project.

22.4 Biodiversity (terrestrial)

22.4.1 Mitigation and Management Measures:

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The Appendix No. 2 – Section 4.1 and 4.2 of this plan describe the mitigation and management measures to
be implemented by the EPC Contractor with regard to Biodiversity during the Construction and
Commissioning stages of the project.

Some of the relevant requirements that EPC Contractor will implement, among others, are the following:

Habitat & Vegetation Preservation


 In order to prevent excessive disturbance of the ecological diversity of the site and adjacent areas, the
extent of lay down areas will be minimised to prevent further degradation on the site.
 Invasive and pest species will be removed /destroyed. Removal measures will be developed by the
Contractor’s HSE manager and shall include methods that do not use wide-scale chemical treatment that
may impact on the local environment.
 Specific conditions related to the protection of animals and plants from the ESIA will be implemented;
 Existing dune vegetation will be retained on site, where possible;
 Prior to site clearing all permits will be obtained;
 Native wildlife (animals), including snakes, will not be handled and/or killed;
 Pesticides will be only be used where necessary and will be selected considering ecological toxicity and
biodegradability. Only pesticides approved by the Bahraini government will be used and handled by an
approved pest control service;
 Pesticides and fertilizers will be stored, mixed and applied in accordance with manufacturer’s
recommendation and so that there is no overspray (mist) contacting non-target areas, or no ground
runoff of excess liquid into drains, waterways and away from target areas;
 Where animals may be harmed or threatened, or are interfering with construction works or pose a safety
risk to workers, Owners environmental representative will be contacted to arrange for the animal to be
moved off-site;
 If injured or dead animals are encountered on site, Owners environmental representative will be
contacted.
 Silt traps are to be regularly maintained and desilted in an appropriate manner and location in order to
sustain maximum silt removal efficiencies at all times.

Pest Management

The following management measures will minimize any potential problems:

 There will be proper sanitation at all building structures within the construction zone. This would
include facilities such as the labor camp and other temporary buildings.
 Suitable washing and sanitation facilities for workers will be provided in food storage and eating areas.
Hand washing prior to eating will be emphasized to all workers at the labor camp. This can greatly
reduce problems with ants, cockroaches, flies, rodents and other pests that are attracted indoors by food
scraps, spilled drinks and food packaging.
 There will be frequent inspection of pest populations especially at the labor camp and around refuse
containers. Water will not be allowed to accumulate in and around areas in the building structures of the
labor.
 Any pesticides used at the site will be treated as hazardous materials and stored and used appropriately
by trained personnel.

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22.4.2 Monitoring Requirements:

The Appendix No. 2 – Section 4.3 of this plan describes the monitoring requirements to be implemented by
the EPC Contractor with regard to Biodiversity during the Construction and Commissioning stages of the
project.

Some of the relevant monitoring requirements to be implemented, among others, are the following:

Biodiversity Monitoring Plan

EPC Contractor shall implement the Biodiversity Monitoring Plan AD2-C3-00-YDC-GGP-CON-00075.

Habitat & Vegetation Preservation


 Daily visual observations of live fauna and burrow locations by workers at the commencement of
working activities, and general observations throughout the day – to inform evacuation of specific
burrows
 Monthly the HSE Team will plan a route, inside and nearby areas of the plant, to check the presence of
flora/fauna, any spot of pollution or degradation, changes in the landscape and everything that could
have changed because of the works. These will then be documented and kept as record.
 Any ecological impacts occurring during site clearance, land preparation, cut and fill activities will be
monitored and recorded.
 Soil erosion will be monitored. Weekly inspection of soil erosion abatement structures such as silt traps,
outlet structures and drainage system will be conducted.

22.5 Geology, soils and groundwater

Water quality management during the construction phase will be closely related to management of soil
erosion and sedimentation, as excessive erosion and siltation will contribute to water quality deterioration.
Other aspects of water quality management will also include management of waste disposal from
site/clearing works, solid waste, sewage, dewatering from deep excavations, surface runoff and sanitary
wastewater arising from construction worker’s camps as well as potential pollution of oil and grease from
waste oils, fuels and lubricants from machinery.

Objective:

Guarantee groundwater quality and supply on and immediately adjacent to the EPC Contractor construction
site in accordance with the requirements of Bahrain regulations and IFC. In addition, objectives also include,
maintaining soil structure and quality and preventing contamination on and immediately adjacent to the site
and ensuring that all waste water generated as a result of construction activities is appropriately collected,
treated and disposed.

22.5.1 Mitigation and Management Measures:

The Appendix No. 2 – Section 5.1 and 5.2 of this plan describe the mitigation and management measures to
be implemented by the EPC Contractor with regard to Geology, soils and groundwater during the
Construction and Commissioning stages of the project.
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Some of the relevant requirements that EPC Contractor will implement, among others, are the following:

Pollution Control Management Measures

Pollution prevention measures will be included to ensure the correct storage of high-risk chemicals/wastes.
This will include:
 The use of double skinned vessels and sealed bund areas that have a 110% carrying capacity of the
contained materials;
 All maintenance yards, vehicle (washing) and chemical and waste storage areas will be carefully
designed. All areas will be located on hard-standing impermeable surfaces, with appropriate sealed and
separate self-contained drainage systems that are maintained on a regular basis to prevent excessive
siltation.
 Any soils identified for import onto site should be sampled and tested to ensure compliance with
appropriate screening values. Material should be tested in accordance with a specification agreed in
accordance with related standards and regulations, for heavy metals (aluminium, arsenic, cadmium,
chromium, cobalt, copper, iron, lead, manganese, mercury, nickel, selenium, silver, vanadium, zinc),
pesticides, polycyclic aromatic hydrocarbons and total petroleum hydrocarbons;
 Chemical transfer/refuel etc. will be restricted to specific areas that will be subject to the same controls
as above;
 Fuel storage areas will be segregated from dewatering water to avoid contamination of settlement water
resource;
 No fuel storage or refuel will be permitted within 100m of the coastline or dewatering channels;
 Waste oil and grease from the construction site will be collected in suitable drums and sent out for
proper disposal. Records of such material will be maintained.
 All surface water runoff from areas of chemical and waste storage should be intercepted and treated or
stored and tested for compliance before release to waste water treatment plant;
 Part of the site inspection will include an integrity inspection of all site pipe work, hoses, watering units
etc. to check for leaks/losses;
 Specific wastewater collection facilities will be provided onsite. These will be installed and maintained
so as to facilitate wastewater/wash water collection. Wastewater discharge to open land or drains will
not be permitted without approval from the Contractor’s HSE manager.
 Temporary sanitation facilities such as modular self-contained septic tank systems or portable toilets
will be provided at the construction site. A tank from a licensed disposal company will empty these
facilities on a regular basis.
 Records of all disposals will be maintained by the subcontractors and provided to the contractor.
 Construction debris will be disposed of in proper designated areas well away from coastal waters;
 Only excavated materials will be used for backfilling, with the exception of additional top-soils. The
source of imported top-soils will be verified prior to its use onsite.
 The use of any piles or excavations will be supported by a risk assessment to ensure that appropriate
mitigation is identified to avoid the contamination of groundwater through the creation of new migration
pathways through these works.
 Any drains, sediment traps, waste storage units etc. will be maintained on at least a fortnightly basis.
 Concrete batching and washout of concrete mixing equipment will be controlled to prevent the potential
release of sediment into waterways.
 In the particular case of the wastewater and sewage, they will be sent into a holding tank. An authorized
company will dispose the wastewater. It is believed that it is not necessary to carry out any monitoring
sample, unless an incident takes place.
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 When commissioning phase starts, it is necessary to review this point, due to the waste water system
will be functioning, and some parameters will have to be measured based on the type of discharge from
the source.

Spill Control and Emergency Response


 Emergency Response Procedures will be enforced and audited. Staff will be appropriately trained and
monitored in spill prevention and clean-up procedures. Spill Prevention Plan AD2-C3-00-YDC-GGP-
CON-00062 shall be implemented by the EPC Contractor in order to verify that pollution of soil and
groundwater is avoided at all times.
 Spill kits will be provided at all significant locations, in all vehicles and will be given to all appropriate
personnel. Their disposal upon use will be in accordance with specific waste management controls.

Oil Spill Collection and Storage

Remedial action to collect and remove all materials contaminated by the oil spillage or leakage event is to be
taken immediately. The following actions are required:

 Any oil remaining on the ground is to be collected using oil spill kit. The spill is to be surrounded by the
kit and then the area of the spill is to be slowly reduced by enclosing the absorbent. The absorbent pads
will be used to absorb the oil. Once all of the oil on the ground surface has been collected, the absorbent
agents themselves are to be appropriately stored and disposed of.
 All contaminated materials are to be handled as hazardous waste. The contaminated material shall be
collected and appropriately stored. A hazardous waste vendor will collect this.
 Contaminated materials will be stored in plastic barrels with tightly closing lids. These barrels are to be
stored in a concrete lined bund if available. In absence of such a bund at the site, a double plastic lined
bund will be used. Barrels will be placed on plastic or wooden pallets in the temporary double plastic
lined bund and not directly on the plastic.
 All contaminated materials that cannot be collected and disposed are to be cleaned in-situ. This cleaning
is to be undertaken by an approved service providers.

22.5.2 Monitoring Requirements:

The Appendix No. 2 – Section 5.3 of this plan describes the monitoring requirements to be implemented by
the EPC Contractor with regard to Geology, soils and groundwater during the Construction and
Commissioning stages of the project.

22.6 Solid and liquid waste management

22.6.1 Mitigation and Management Measures

The Appendix No. 2 – Section 6.1 and 6.2 of this plan describe the mitigation and management measures to
be implemented by the EPC Contractor with regard to Solid and Liquid Waste Management during the
Construction and Commissioning stages of the project.

Some of the relevant requirements that EPC Contractor will implement, among others, are the following:

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22.6.1.1 Waste Management
EPC Contractor shall implement the Waste Management Procedure AD2-C3-00-YDC-GGP-CON-00061.
The procedure will be the guideline for proper waste management in the project. The waste information
(quantities, qualities, storage, disposal, deviations, incidents) will be shown in the monthly report.

The Project will generate the following wastes:


 Dredging and excavation stockpiles, including dewatering facilities;
 Municipal solid waste;
 Construction debris and recyclables;
 Scrap metal, used oil, chemical and hazardous wastes;
 Medical wastes; and
 Sanitary waste.

The plan assures the following information:

• Quantities of all types of waste which are taken off site, where and how the waste was disposed of.
• Approx. estimates of the quantities and types of waste recycled, reused, or recovered
• List of persons in charge of the waste management
• List of government approved companies which are providing the service to transport and dispose of
waste.

22.6.1.2 Collection and Temporary Storage of Waste

 Waste will be stored in containers or skip bins, and not stockpiled directly on unsealed ground;
 Recycling waste will be stored in separated areas or containers, and not mixed with other waste types;
 Sufficient space will be allocated for waste collection vehicles;
 Waste removal from the site will be scheduled so that there is always a waste skip available for use on
site, and that waste skips/container do not overfill;
 Waste will only be collected by local government approved waste transporters;
 Any temporary waste storage areas (not contained in bins or containers) will be covered and/or
surrounded by a screen mesh fence to prevent it being wind-blown across the site and into coastal
waters and adjacent property;
 Liquid wastes including waste oil and liquid chemicals will be stored in sealed drums/containers, on a
concrete surface and under a sun/rain shelter.
 Waste Disposal - All waste will be taken to local government approved facilities, according to type
(general/hazardous).
 Record Keeping - All waste removal records will be maintained, and reported as required in the
monthly environmental performance report;

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 Records that will be kept and made available to the Contractor’s HSE manager include;
receipts/invoices/dockets from the waste transport subcontractor and the waste receiving facility; these
records will be kept in a Waste Register, which records collection dates, type of waste, quantities, waste
transport company, destination, and signature of an authorized person.

22.6.1.3 Hazardous Waste Management

 Hazardous waste such as oil, used batteries, solvents may be generated during the construction phase.
Hazardous waste must be treated, stored and disposed in compliance with related standards.
 All storage of hazardous waste will be in an appropriately located bund hard standing surface, which
will be located in clearly signposted designated areas.
 Surplus hazardous materials will be reclaimed or recycled, if possible. Appropriately licensed
subcontractors will dispose of all hazardous materials at designated hazardous waste facilities.
 Appropriate clean up facilities will be located at each hazardous storage area with the disposal and
clean-up of hazardous materials and substances will be performed by properly trained personnel.
 The generation of hazardous waste will be avoided by substitution of non- hazardous substances where
such substitution does not adversely affect or impair the process. In all processes, the generation of
hazardous wastes will be minimized to the greatest extent as possible.
 Subcontractors on site will be responsible for the disposal of this material and will be required to
demonstrate that such materials are removed and disposed of by licensed subcontractors in government
designated areas.
 All hazardous wastes (including used oil) must be kept in proper containers, labeled appropriately and
stored properly. In the event of any spill or accidental discharge of any scheduled waste, the EPC
Contractor must be notified immediately with all records being maintained by the designated
coordinator.

22.6.1.4 Waste Recycling Plans and Commitment

Protection of the environment is EPC Contractor’s business. Key environmental considerations include the
reduction of waste and the re-use and recycling of waste materials.
 EPC Contractor will require to its employees as well as the subcontractors to implement waste
recycling practices that can contribute to the reduction of disposal of waste.
 EPC Contractor will be focused on the recycle of wooden material from packs so as to be used to
prepare temporary facilities that can contribute to the reduction of raw wood consumption and/or
purchase. Wooden waste material shall be considered as material for sale as well as for donation for
the local communities.

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 Waste material usually called scrap shall be stored accordingly and to be sold to the recycle companies
that may exist in the country. Scrap will also be considered to be used to prepare temporary facilities
such as shelters, pedestals, temporary access platforms, etc.
 Paper will also be considered as a point for recycling, especially in the offices. Paper can be collected
and be sold, and/or be donated to schools for encouraging students to recycle this waste and to sell it
and see the benefits for implementing recycling programs not only at school but also at home.

22.6.2 Monitoring Requirements:

The Appendix No. 2 – Section 6.3 of this plan describes the monitoring requirements to be implemented by
the EPC Contractor with regard to Solid and Liquid Waste Management during the Construction and
Commissioning stages of the project.

Among the relevant monitoring requirements are the following:

Inspection of the storage of non-hazardous and hazardous materials will be conducted on a weekly basis
within the project site to ensure proper storage of materials and hinder the potential occurrence of spillage.

22.7 Chemicals

22.7.1 Mitigation and Management Measures:

The Appendix No. 2 – Section 7.1 of this plan describe the mitigation and management measures to be
implemented by the EPC Contractor with regard to Chemical Management during the Construction and
Commissioning stages of the project.

Some of the relevant requirements that EPC Contractor will implement, among others, are the following:

Hazardous Chemical Procedure

EPC Contractor shall implement the Hazardous Chemicals Procedure AD2-C3-00-YDC-GGP-CON-00067


in order to comply with this requirement.

Refuelling

EPC Contractor shall apply environmentally friendly practices to the activities of loading (refueling) of
diesel (fuel) to storage tanks as well as combustion engine equipment (heavy and light vehicles, small diesel
pumps, air compressors engines, portable power generators, etc.) used in the facilities and areas under the
EPC Contractor and subcontractors’ responsibility.

The accidental release of fuel during handling or dispensing may adversely affect the environment and/or
provoke fire incidents. The following protection measures are intended to prevent fire incidents as well as
loss or escape of product and, in the event of a spill, to control the impact of the spill on the environment.

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Every construction area shall have a specific place designated for refueling operations. In the event that
equipment cannot be taken to those refueling places, the environment protection and fire prevention
guidelines shall be followed without exception.

Refueling shall be carried out in well ventilated areas, keeping a distance of at least 15.24 meters from hot
works and/or open flames, and 5 meters from flammable storage areas.

The area shall have a grounding point in which the diesel tanker chassis shall be connected through a
grounding cable with a clamp (or alligator-type clip) in both ends.

The following safety signs shall be displayed in enough quantities and dimensions in the refueling area:

-No smoking
-No electronic devices/mobiles allowed
-No hot works/open flames allowed
-Danger: Flammable Substance
-Prohibited the access to non-authorized employees
-Fire extinguisher sign
-Fire extinguisher sand bucket sign
-Access/Egress signs
-Road direction arrows signs
-Speed limit signs
-Caution: System under pressure”
-Emergency Contact Numbers

2 dry chemical powder fire extinguisher of 6 kg. shall be permanently kept in the area, beside the fire
extinguishers of the vehicles.

2 plastic buckets full of sand shall be kept for contingency.

A spill kit shall be permanently kept in the area.

The area shall be located where the refuel operations cannot be disturbed by vehicles or other equipment.
The fuel storage area must also be located away from drainage channels.

Refueling points shall be:

a) At 30 m away from water streams, rivers, lakes, canal or natural watercourse;


b) At 3 m of a property line;
c) At 3 m of any building
d) At a distance that the nozzle, when the hose is fully extended, will not reach within 1.5 meters of a
building opening.

The diesel tanker shall have a grounding point specific for that purpose.

Diesel tanker shall be equipped with at least 2 6-kg dry chemical powder fire extinguishers.

Diesel tanker shall be equipped with dispensing nozzles with automatic-closing type.

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Diesel tanker shall have an easily accessible and clearly identified shutoff device, such as switch or circuit
breaker, to shut off the power for the diesel pump in case of emergency.

Diesel transfer pump shall be properly mounted onto the diesel tanker chassis.

Transfer pump shall be for diesel or liquid fuel services.

Transfer hoses shall not exceed 50 feet (15.24 meters) in length and shall be rated for liquid fuel service as
well as for the liquid fuel pump discharge pressure.

Valves, connectors, pipelines and instruments installed for the transfer of diesel, shall be rated for the use of
flammable liquids as well as the discharge pressure of the transfer pump.

All diesel tankers shall be properly labeled with a red strip in a white background, indicating the name of the
product (“Diesel”) and the sign: “Danger: Flammable”.

Misuse or alteration of the fuel transfer system shall not be allowed.

All heavy equipment/vehicles to be fueled shall have proper caps installed in their diesel tanks.

All diesel tankers shall be subject to a proper maintenance.

Daily Inspection should be carried out by Operator/Driver. Check for fuel system and their components,
leakage or any damage

Diesel tankers shall be attended by qualified and authorized personnel at all times during loading and
unloading operations.

Only designated operators shall conduct refueling operations.

Operators and diesel-powered vehicle operators shall be trained in the specific hazards with regard to Diesel
handling (MSDS), PPE required for flammable substance handling, Fire Prevention and the Emergency
Response Procedures in case of Fire and/or Flammable substance spillages.

Personnel/ Operators engaged dispensing diesel must be familiar with:


a. Emergency Mobile numbers
b. Proper operation of firefighting equipment provided.

22.7.2 Monitoring Requirements:

The Appendix No. 2 – Section 7.2 of this plan describes the monitoring requirements to be implemented by
the EPC Contractor with regard to Chemicals during the Construction and Commissioning stages of the
project.

Among the relevant monitoring requirements are the following:

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EPC Contractor shall implement a weekly inspection routine of all the Hazardous Chemical Storage areas as
well as the locations where Hazaroud Chemicals are used.

22.8 Tourism and recreation

22.8.1 Mitigation and Management Measures

The Appendix No. 2 – Section 8.1 and 8.2 of this plan describe the mitigation and management measures to
be implemented by the EPC Contractor with regard to Tourism and Recreation during the Construction and
Commissioning stages of the project.

22.8.2 Monitoring Requirements:

The Appendix No. 2 – Section 8.3 of this plan describes the monitoring requirements to be implemented by
the EPC Contractor with regard to Tourism and Recreation during the Construction and Commissioning
stages of the project.

22.9 Traffic and access

22.9.1 Mitigation and Management Measures

The Appendix No. 2 – Section 9.1 and 9.2 of this plan describe the mitigation and management measures to
be implemented by the EPC Contractor with regard to Traffic and Access during the Construction and
Commissioning stages of the project.

Some of the relevant requirements that EPC Contractor will implement, among others, are the following:

Traffic Management

This section of the manual defines the scope and approach for achieving our aim of preventing vehicle
incidents on our projects. It covers planning and management issues, site layout including access control and
measures to ensure the safety of drivers, pedestrians and vehicles.

Pedestrian routes should be clearly separated from vehicle routes by fencing and/or a kerb, or other suitable
means; be wide enough to safely accommodate the number of people likely to use them at peak times; allow
easy access to work areas; be kept free from obstructions and tripping hazards; have clear signs designating it
as a pedestrian route and be illuminated for use in hours of darkness.

Traffic management team shall designate temporary safe vehicle routes throughout the project. Designated
safe vehicle routes and speed limits shall be cascaded to all subcontractors working within the project and
visiting suppliers.

Temporary roads shall be graded and compacted prior to use.

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The safe vehicle route shall have traffic and speed limit signs posted along the route. Maximum speed limit
on all project sites shall be 20 kph. Signs shall be of sufficient size, shall be elevated and shall be reflective.
Appropriate warning signs shall be posted. Where possible, signage shall be in multiple languages.

Concrete jersey barriers are preferred for heavy traffic routes. Where necessary concrete jersey barriers shall
be utilized. The use of heavy-duty barricades will depend on risk assessment.

Excavations shall be protected with hard barricade when adjacent to traffic routes. Flashing warning lights
shall be installed should no other means of illumination be provided.

Traffic routes will be kept free from obstruction and have sufficient clearance for its use, so far as is
reasonably practicable.

 Where sand and other dusty material is transported to the site, trucks will not be overloaded and will be
appropriately covered / sheeted to eliminate the contamination to the air.

 A safe parking area will be established, and personnel will be made aware. Parking will be permitted in
designated areas only, where designated vehicle parking areas are constructed; all vehicles shall be
‘reverse parked’. Vehicles shall not be parked in such a manner as to slow down, hinder, or interfere
with the free flow of traffic. Vehicles shall not be parked so as to block or interfere with the use of fire
hydrants or fire equipment.

 Access roads from the entrance to the site will be compacted and sprayed with water to minimize the
dust generated from the vehicles and trucks.

 The construction vehicles leaving the site will be appropriately cleaned (provisions of wheel-washing
facilities or high-pressure hose to ensure all vehicles leaving the site are in a satisfactory state of
cleanliness).

 All the vehicles used in the site shall be appropriately maintained.

 Vehicles shall not be left unattended with the motor running. Vehicles parked on site shall be left open
with the keys in the ignition switch should it be necessary to move it in case of an emergency.

 All vehicles on the property will be there at the risk of the vehicle’s owner. Neither Owner/ nor Project
Management Team accepts responsibility for damage to or theft of such vehicles.

All vehicles will have as a minimum, certificates of registration, insurance & taxation, driving license as per
the type and class of vehicle, certificate of fitness and permit from the local transport authorities.

All loads transported in a pick-up (or utility) truck or other cargo vehicles shall be securely fastened, and the
weight shall not exceed the manufacturer's specifications and legal limits of the vehicle. Sufficient straps,
chains, etc. should be applied to secure equipment to prevent movement. Use of appropriate lashing
arrangements and headboards should be used to secure loads in a safe manner.

Dangerous goods shall be transported in accordance with international standards and codes of Bahrain.
Similar, the transports of large equipment to the site shall require an assessment of the routes, including
considerations of road condition, bridge, power line, local permission and the loads.

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All equipment and materials will be transported in containers by ships and lorries from the supplier’s
factories to the site.

Dust management on Roads

Dust management is one aspect of Traffic and Air Quality that EPC Contractor shall implement during all
the earth moving activities, as well as in the temporary roads that the project will have for the access of
employees, vehicles and heavy equipment to the construction areas in the project.

Adequate measures should be taken to prevent the formation of, or to suppress as close to the source as
practicable, all dust generated from earth moving activities and from the traffic of vehicles in temporary
(non-paved) roads.
All earth moving activities shall comprise of water spray in order to reduce the dust generated in the
environment. Loose rock should be adequately wetted during loading, transport and unloading underground.
Excavated material should not be exposed to wind during transport and it shall be covered.
If any stone-crushing equipment is used underground, adequate measures should be taken to prevent any dust
from becoming airborne.

Speed limits

The speed limit of vehicles shall be 20 km/hr.

Safety signs shall be displayed every 50 meters all along the roads, showing the speed limits.

Traffic bumps shall be considered for special cases and they shall be installed with the approval of the
Owner and EPC Contractor Management.

Vehicle access

Vehicle access shall follow the guidelines listed in the point 68.2 of this Project’s HSE Management Plan.

Flagman

Flagman is the person who is in charge of directing the movement of large vehicle on a work site, they are
often called traffic marshals or banksmen. In other words, flagmen are employees who provides temporary
traffic control.

Flagmen should be used in circumstances where other control measures are not possible.

Vehicle flagmen will be the eyes and ears of the vehicle driver and they will ensure not to put the driver or
anyone else in danger.

Flagmen shall be provided by EPC Contractor and its subcontractors when:

 There are road diversions


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 Vehicle reversing
 Heavy vehicle movement
 Heavy traffic situation
 Bad weather condition
 Vehicle with large loads

The basic requirements for flagmen are:

 Fully trained
 Know what responsibilities a flagman has
 Know the main causes of accident due to the absence of flagman
 How to prevent common accident
 Understand about equipment and machinery
 The correct procedures for maneuvering equipment.
 Direct site traffic in a construction site.
 Understand the risk involved with directing off highways traffic.
 Be able to carry out role of vehicle flagman with confidence.
 Use a clear agree system of signaling.
 Be visible to drivers at all time.
 Stand in safe position.
 Wear hi viz clothing.
 Ensure that signals are clearly seen.

22.9.2 Monitoring Requirements

The Appendix No. 2 – Section 9.3 of this plan describes the monitoring requirements to be implemented by
the EPC Contractor with regard to Traffic and Access during the Construction and Commissioning stages of
the project.

Some of the relevant monitoring requirements to be implemented, among others, are the following:

EPC Contractor HSE Department will be in charge to monitor the generation of dust in the site by carrying
out weekly dust assessment through a portable dust monitor in order to determine the amount of dust
particles present in the workplace environment. The particles to be monitored will be PM10 and PM2.5. EPC
Contractor shall comply with dust limits set up in international and local regulations. EPC Contractor shall
generate a report in order to record the dust monitoring measurements, indicating the monitoring locations
and the levels of dust, as per the guidelines mentioned in the Environmental and Social Impact Assessment
of the project and/or as per Bahraini Requirements.

EPC Contractor shall verify on a daily basis that the water spray of roads is carried out.

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22.10 Socio-economics

22.10.1 Mitigation and Management Measures:


The Appendix No. 2 – Section 10.1 and 10.2 of this plan describe the mitigation and management measures
to be implemented by the EPC Contractor with regard to Socio-economics during the Construction and
Commissioning stages of the project.

Some of the relevant requirements that EPC Contractor will implement, among others, are the following:

22.10.1.1 Stakeholder Engagement

EPC Contractor will implement the Stakeholder Engagement Plan AD2-C3-00-YDC-GGP-CON-00009

The greater the level of stakeholder engagement, the more thorough the identification of potential impacts
will be. Early engagement and ongoing dialogue with stakeholders will lead to earlier identification of
potential stakeholders’ issues and risks before they arise, and it will contribute to a stronger and more
suitable relationship between stakeholders and project proponent. Stakeholders engagement is regarded as
key for resolving grievances and issues.
The stakeholder engagement plan process is as follows:

 Stakeholder identification and analysis (development of stakeholder register).


 Development of appropriate engagement and information dissemination tools.
 Notification and invitation to participate and comment.
 Scoping and baseline engagement meetings with key informants and affected community
representatives.
 Recording issues raised and commitments.
 Recording activities undertaken within the process.
 Development of a specific Stakeholder Engagement Plan (SEP) appropriate to the scope of the project
to guide the engagement process during the Project’s lifetime.
 Updates of the SEP throughout the life of the project, shall be carried out by EPC Contractor HSE
Manager.
 Facilitating ongoing stakeholder input into project design and implementation.
 Ongoing engagement of stakeholders throughout construction, operation and commissioning of the
Project.

22.10.1.2 Infrastructure and Resource Management/Sustainability

Objective:
To promote resource efficiencies, water/energy conservation and sustainable construction measures.

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Resource Efficiency Measures

 Good practice measures will be implemented by the EPC Contractor and their Subcontractors such as
turning off lights, computers, air conditioning units and printers overnight. Low energy lighting will be
used across the site.
 Materials demand rates will be used to ensure an effective purchase strategy where possible, preventing
the long-term storage of materials that would be adversely affected by the heat and humidity.
 Batch quantity information will be prepared for all major repetitive activities so that there are no
excessive waste during preparation.
 Staff will not be allowed to rest in vehicles to prevent excessive fuel waste through the need to use air
conditioning. Appropriate facilities will be provided for the staff to be used for periods of rest.
 All subcontractors will adhere to a forward-developed Energy Conservation Program comprising
measures to: prevent unnecessary journeys, prioritize the sourcing of local materials, include energy
efficiency measures in site offices (such as locating offices in shaded areas), car-sharing, seeking to use
alternative/low emission fuel sources for machinery and construction transport etc.
 EPC Contractor and Subcontractors will be required to investigate the possible reuse of construction
waste (wood, metals, concrete blocks etc.) onsite.

22.10.1.3 Social Management

Objective
To ensure a safe and conducive living and working environment for the employees and ensuring the
construction activities does not adversely affect the surrounding local communities.

The Social Management mitigation measures that will be taken, in construction, commissioning and start-up
phases are the following:

 Develop public and employee communication procedures and notice boards, to provide a means for
raising any grievances.
 Facilitate access to information by the public; ensure transparency in the Social actions implemented.
 Establish and maintain a sound worker-management relationship.
 Provision of workers accommodation, social and health facilities in line with international good
practice.
 Promote the fair treatment, non-discrimination and equal opportunity of workers.
 Comply with labor laws and standards.
 Provide complaints mechanism for employees and an action plan to address them.
 Implement a worker demobilization program, which provides for information provision, communication
and support to workers for seeking alternative employment, upon completion of work contract.
 Prevent or minimize impact on community by implementation of the HSE Management Plan.
 Construct a fence line around project.
 Prepare Emergency Response Plan.
 Maintain open communication channels with local communities.
 Provide training and awareness for workers and appropriate information of project activities to the local
communities.
 In the event of high humidity, regular monitoring for Legionella should be implemented and corrective
measures adopted to minimize risk to workers.

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 Provide construction program schedule to nearby population, which informs the work activities, timings
and locations, and explains mitigation measures implemented.
 Ensure that traffic access to the nearby villages is never hindered, by providing clearly indicated
alternative routes
 Notify community of any disruptions to services with a minimum of 1-week notice.

22.10.2 Monitoring Requirements:

The Appendix No. 2 – Section 10.3 of this plan describes the monitoring requirements to be implemented by
the EPC Contractor with regard to Socio-economics during the Construction and Commissioning stages of
the project.

22.11 Cultural heritage and archaeology

22.11.1 Mitigation and Management Measures

The Appendix No. 2 – Section 11.1 and 11.2 of this plan describe the mitigation and management measures
to be implemented by the EPC Contractor with regard to Cultural Heritage and Archaeology during the
Construction and Commissioning stages of the project.

Some of the relevant requirements that EPC Contractor will implement, among others, are the following:

22.11.1.1 Chance find Procedure

EPC Contractor shall implement the Chance Find Procedure AD2-C3-00-YDC-GGP-CON-00058

This procedure has been developed in accordance with EPC Contractor E&S policies as well as with the
requirements listed in the Al-Dur II IWPP’s Environmental and Social Impact Assessment in relation to
findings of archaeological heritage during the construction activities in the project, following the IFC
Performance Standards (PS8).

The purpose of the procedure is:

 to avoid significant adverse impacts to cultural heritage


 to describe the provisions for managing chance find through a process which will be applied in the event
that cultural heritage is subsequently discovered.
 to describe the Cultural Heritage mitigation and management measures to implement from the ESIA
report for Al-Dur II IWPP, derived from IFC Performance Standards.

The complete Chance find procedure is the standalone document AD2-C3-00-YDC-GGP-CON-00058.

General Management Criteria

As stated in Al-Dur II IWPP’s ESIA report Volume 2:

Based on the observations made during the site visits and a basic secondary research, there are no features
of cultural value or evidence suggesting the presence of archaeological features within the proposed Project
footprint.

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No archaeological sites within or nearby the Project site have been referenced in publicly held data such as
the Bahrain Authority for Culture and Antiquities website.

Excavation and earthwork activities can result in damage and destruction of undiscovered archaeological
artefacts.

Given the absence of cultural heritage features and lack of evidence of previous land use before industrial
development took place in the area, the presence of archaeological features within the project footprint is
likely to be low.

A “Chance Find Procedure” will however be incorporated within the project CESMP such that in the
unlikely event any items of archaeological significance are discovered, these can be appropriately managed
by archaeological experts and identified, recovered and preserved.

Specific management methods and mitigation measures

The following points detail the management methods and mitigation measures/actions identified in case of
previously unknown cultural heritage (e.g. archaeological findings) is encountered unexpectedly in the
Construction phase.

a) Should an archaeological and cultural property be found on the Project Site during land excavations,
all the construction activities will be stopped immediately. EPC Contractor HSE Manager shall be informed
immediately. EPC Contractor HSE Manager shall contact the Owner’s project team who in consequence
shall contact the Bahrain Authority for Culture and Antiquities.

b) Where artefacts or archaeological remains are encountered, the site will be clearly signed/delineated
with high visibility flagging to impede access and prevent any damage or loss of the artefacts which have
just been found. Species shall not be disturbed until a competent professional assessment is made and
remedial actions consistent with Bahrain laws and regulations are fulfilled.

c) Contractor crew to be informed during morning toolbox meeting about any suspected archaeological
finds to avoid disturbance.

d) Further construction activities will be conducted along with the instructions of the authorities.
Implementation of the authority’s decision concerning the management of the finding shall be strictly
followed.

e) Construction works shall be resumed only after permission is granted from the relevant local
authorities. Constructions and physical interventions will not be allowed on the protected and cultural assets.
Substantial repair, construction, installation, drilling, partial or complete demolition, burning, excavation or
similar works will be considered as construction and physical intervention.

f) Record keeping shall be done with the support of the appendix 1 – Chance find form and appendix 2 –
Chance find register.

g) Chain of custody instructions for movable finds shall be done as per the guidance of the Bahrain
authorities.

8 Removal of any archaeological artefacts from the siteby site workers is strictly prohibited.

22.11.2 Monitoring Requirements:

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The Appendix No. 2 – Section 11.3 of this plan describes the monitoring requirements to be implemented by
the EPC Contractor with regard to Cultural Heritage and Archaeology during the Construction and
Commissioning stages of the project.

The following Cultural Heritage and Archaeology monitoring requirements shall be followed by the EPC
Contractor during the whole Construction phase of the project:

Table 15 Cultural Heritage and Archaeology - Monitoring Requirements


Monitoring Parameter Frequency & durations Monitoring location
Construction
Archaeological Undiscovered Daily continued visual The Project area requiring
Resources & Artefacts archaeological remains observations by site staff excavations, earthworks or grading
within the Project site involved in excavations. during construction and
Commissioning

22.12 Landscape & visual quality

22.12.1 Mitigation and Management Measures

The Appendix No. 2 – Section 12.1 and 12.2 of this plan describe the mitigation and management measures
to be implemented by the EPC Contractor with regard to Landscape and Visual Quality during the
Construction and Commissioning stages of the project.

Some of the relevant requirements that EPC Contractor will implement, among others, are the following:

22.12.1.1 Landscape and Visual Impact

Objective
To ensure the works do not lead to adverse visual impacts resulting in complaints.

Visual Impact
 Good housekeeping procedures will form part of the daily inspections across the whole construction site
to reduce the visual impact and maintain a safe working environment.
 Induction training will focus on an individual’s responsibility towards general housekeeping and the
need to protect the Owner and the Contractor’s public E&S image.
 The Contractor’s HSE manager shall manage the maintenance of all fencing throughout the construction
period and a check on its integrity will form part of the inspection process.
 Consider the use of cut-off to lighting columns to reduce the instances of light spill into the wider
landscape setting.
 Complaints about untidiness and/or nuisance will be recorded as part of the Complaints Register
procedure and reported at the weekly review.

22.12.2 Monitoring Requirements:

The Appendix No. 2 – Section 12.3 of this plan describes the monitoring requirements to be implemented by
the EPC Contractor with regard to Landscape and Visual Quality during the Construction and
Commissioning stages of the project.

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22.13 Health and safety

22.13.1 Mitigation and Management Measures

The Appendix No. 2 – Section 13.1 and 13.2 of this plan describe the mitigation and management measures
to be implemented by the EPC Contractor with regard to Health and Safety during the Construction and
Commissioning stages of the project.

Some of the relevant requirements that EPC Contractor will implement, among others, are the following:

22.13.1.1 Grievance Procedure

EPC Contractor shall establish a grievance mechanism designed to receive and facilitate resolution of
concerns and grievances on the Project’s environmental and social performance.

The mechanism will seek to resolve concerns promptly, using an understandable and transparent consultative
process that is culturally appropriate, readily accessible, at no cost, and without retribution to the party that
originated the issue or concern.

The steps to raise and follow a grievance is fully described in the document Grievance Management
Procedure AD2-C3-00-YDC-GGP-CON-00063.

The following is a summary of this procedure:

This Grievance Management Procedure is designed to facilitate the lodging, acceptance and closure of
grievances coming primarily from Affected Communities, but also from other interested stakeholders and
project workers.

Grievances may arise from local hiring, unplanned impacts and infrastructure damage as they relate to the
Project’s environmental and social commitments. The GMP is available to any party that wishes to
communicate a grievance to the EPC Contractor whether it be an individual, non-governmental organisation,
community based organisation, other community group, local or international employee. A grievance will be
considered genuine and evaluated if a party considers itself genuinely impacted due poor environmental and
social performance.

The GMP is available on a voluntary and non-excluding basis. It does not affect anyone’s rights to use the
Bahraini judiciary system in any way, nor does it replace the public mechanisms of grievance and conflict
resolution. However, EPC Contractor believes most grievances can be quickly resolved by discussing the
issues and agreeing mutually acceptable solutions in a less official setting.

EPC Contractor will assure the implementation of the Subcontractors’ own Grievance Procedures, which are
aligned with this procedure and are fully enforced. This is done by reviewing and approving their Grievance
Procedures, ensuring their teams in charge understand their responsibilities, and by ensuring that grievances
are being logged, followed-up and closed-out in a timely manner. EPC Contractor retains the right to
intervene if a Subcontractor has not closed-out any genuine grievances after the second attempt or within a
reasonable period of time.

Specific grievances in relation to labour or procurement contracts shall be followed up through the EPC

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Contractor’s or Subcontractors’ Procurement or Human Resource Departments, as applicable.
Grievances will be handled through the HSE Department Manager of EPC Contractor and Subcontractors.
These teams will be trained prior to the start of the project and shall receive, centralise and process all
grievances for their area of responsibility. They will deliver grievances to the appropriate departments within
the EPC Contractor and/or Subcontractor organisations, implement systems to organise, track and document
all responses and deliver summary reports to management.

The HSE Manager will propose means to resolve grievances, monitor the Procedure, and hold regular
meetings to collect grievances in the field and provide feedback to communities. Grievances may also be
raised during formal stakeholder meetings which will be handled through this procedure.

EPC Contractor will inform the local communities, its workers and subcontractors’ workers about the
Grievance Mechanism and provide (on posters) contact details how people can launch a complaint via:

• The HSE Manager - verbally;


• Telephone;
• Email or
• Letter;

All contact details and means of submitting a complaint will be widely and regularly published, throughout
the duration of the project, through posters at key locations and verbally by EPC Contractor’s employees.

Contact Details
All stakeholders with internet access can contact EPC Contractor with a grievance or feedback through the
following contact information:

Email: al-dur2.site@sepco3mena.com
Telephone: +973 3452 2750
Address:
SEPCOIII BAHRAIN CONSTRUCTION COMPANY W.L.L.
Road 3649, Building 2750, Flat 1
Block 436, Al-Seef
Bahrain

Email: sidem.bahrain@veolia.com
Telephone: +973 3307 0009
Address:
SIDEM BAHRAIN
P.O. box no: 80387 Kingdom of Bahrain 123456

During the duration of the Project, the EPC Contractor’s HSE Department Office will be established where
individuals may lodge a grievance verbally, or in writing using the form in Appendix A. Also, grievance
boxes will be placed in the main gates in the Security Guard Offices. All Subcontractors shall place a
grievance box in their offices, as well.

Anonymous grievances are not expected to be common due to the community structure in the area.
Workforce grievances or feedback to be handled through anonymous locked drop boxes in worker
accommodation and canteens, or through a system designed by the EPC contractor and subcontractors.
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Bulletin boards will be used to post responses to anonymous complaints as appropriate.

All forms will be in Arabic and English. For Subcontractors, forms should be in the language understood by
its workforce as well as Arabic and English. The HSE Manager of EPC Contractor and Subcontractors shall
have support from Public Relations Officers (PRO’s) for the translation of Arabic documents and/or for the
grievances conveyed verbally from the local community.

Grievance Handling and Resolution


Grievances should be handled according to the following steps:

a) The HSE Manager will learn as much as possible about the case, including:

• Who?
• What?
• Where?
• When?
• Why?

b) EPC Contractor shall acknowledge receipt of any grievance as soon as possible, but up to seven days from
the date it was submitted and shall inform the complainant about the timeframe in which a response can be
expected. For reasons of confidentiality and to protect the safety and security of EPC Contractor personnel,
the contact details of individual staff members will not be released to external parties / complainants.

c) The findings of all the investigations will be entered into the grievance file and used to determine
eligibility. If the Grievance is considered to be ineligible the HSE Manager will contact the complainant
within 3 working days and explain that the complaint was not recognised as eligible.

d) For all types of Grievances, the HSE Manager will listen attentively to the person while he/she expresses
his/her grievance. In many cases, simply listening with empathy helps to calm the situation.

e) During this first meeting if the grievance is resolved, the case is considered closed and it is registered as
such.

f) If a grievance is more complex, EPC Contractor and/or the Subcontractor shall conduct an investigation to
verify whether the grievance is genuine as related to project commitments. This is done in the presence of the
person or the representatives of the local community lodging the grievance. EPC Contractor will investigate
fully all grievances submitted, and will involve other departments, Subcontractors and senior management as
required in the process in order to fully understand the circumstances that led to the grievance being raised.
This should be performed in a timely manner to avoid delaying the resolution of a grievance. EPC Contractor
will aim to resolve any grievances within 30 days from the date that it was received. This timeframe can be
extended to 60 days for more complex grievances, if required.

g) The local authorities and/or representatives may be invited to attend the investigation if the grievance
requires their involvement.

h) The Government and Community Relations team will communicate and explain the grievance to the
appropriate person in EPC Contractor or in the Subcontractor organisation.

• Example, if the grievance involves one of the workers, they will contact the head of human resources

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of his/her subcontractor, and also his/her direct supervisor, as well as the worker himself/herself. If the
complaint is environmental in nature it will be reviewed by an environmental professional within the team
and so on.

i) The HSE Manager will consult other departments to determine the practical corrective action(s) or
mitigation of the grievance.

• Nature of the corrective action;


• Time in which it must be implemented;
• Person responsible for implementation; and,
• Log information in the Grievance Registry.

j) Subcontractors ensuring compliance with construction related environmental and social commitments
shall:

• Consider proposed solutions with their construction team for agreement and execution;
• notify and discuss proposed corrective actions with EPC Contractor HSE Manager and Construction
Management and the party that raised the grievance within 7 days and agree an implementation schedule;
• Obtain written authorisation to proceed with the corrective actions, as needed, e.g. repair third party
infrastructure, etc; and,
• Execute corrective actions under supervision of EPC Contractor HSE Manager.

k) If the complainant accepts the corrective actions, they sign a letter of acceptance and the grievance is
closed subject to a 15 days monitoring period.

l) EPC Contractor and/or the Subcontractor shall implement the agreed actions/solutions.

m) If the proposed solution or executed solution is not accepted by the complainant, the grievance is elevated
to a Grievance Review Committee.

n) EPC Contractor and/or the Subcontractor HSE Managers will consider if improvement to procedures or
practices could reduce the probability of recurrence. EPC Contractor shall coordinate any changes to plans,
procedures and methods with the Subcontractors within contractual restrictions.

Grievance Review Committee (GRC)

The GRC will be set up by EPC Contractor to address complaints as a result of the project implementation.
The GRC will include the EPC Contractor HSE Manager, Public Relations Officer, other representatives
from EPC Contractor as needed, local authorities, Subcontractors representatives and at least two
representatives from local communities. A coordination of resolutions within the GRC will be the EPC
Contractor HSE Manager’s responsibility.

All grievances shall be dealt with on a case by case basis. However, all will require further discussions with
complainants and community members to mitigate perceptions that resolutions unfairly benefit EPC
Contractor and/or Subcontractor.

If attempts to resolve a grievance through the regular steps mentioned above do not result in an acceptable
grievance resolution, the grievance may be elevated to the Government authorities.
Documentation pertaining to an unresolved grievance will be given to the Government authority, who will

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seek and give opinion about how to resolve the case and who will attempt to resolve the case through
conciliation.

As a last resort, aggrieved parties have a right to take legal action. This is a more formal rights-based
approach that shall only be taken if all other approaches have failed or when there are serious conflicts about
facts and data. The final decision will be taken by the arbitrator or courts based on compliance with laws,
policies, standards, rules, regulations, procedures, past agreements or common practice.

Grievance tracking
Once a verbal or written grievance is received, it will be screened for validity (e.g. to ensure that nothing is
blatantly false) and logged into a central grievance mechanism database. An extract of the database can be
found in Appendix B. Grievances shall be assigned a case number and records of communication /
consultation shall all be attached with the relevant entry and filed. The database shall be monitored regularly
for recurring grievances so that appropriate mitigation can be developed.

EPC Contractor anticipates that the following direct impact grievances could be categorised as follows:

• Possible impacts on marine life


• Possible impacts on fish and fisheries catch
• Job issues
• Third party injuries or conflicts
• Damages to infrastructure
• Loss of livestock (goats, camels)
• Damage and temporary interruption of access roads
• Road congestion
• Nuisance caused by noise or dust
• Unplanned use of land
• Environmental issues (soil and water contamination, erosion, damage to wildlife or vegetation,
hunting and fishing, improper right of way restoration, etc)
• Behaviour of personnel
• Community health and safety
• Cultural issues.

Categorising grievances will allow EPC Contractor to establish trends and adapt its own, and Subcontractor’s
management system where needed to improve environmental and social performance and reduce the overall
number of grievances resolved.

If a grievance is the result of a non-compliance to project environmental and social project commitments and
could result in harm to people or serious environmental impact, the HSE Manager will consult directly with
the Project Director and the Deputy Project Managers and may recommend a temporary suspension of an
activity. Any member of staff or Subcontractor has the right to refuse or stop work that is unsafe.

It is voluntary for the individual making the grievance to provide personal information.

Should EPC Contractor receive a grievance that is not related to Al-Dur II IWPP but with regard to the
neighbor sites around the project, the complainant will be advised with regard to what institution they shall
submit their grievance. These grievances will not be tracked.

Grievances Outside of the EPC Contractor Grievance Procedure

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Following best practice, all grievances and claims from local communities should be accepted and no
judgment made prior to investigation, even if complaints are minor. However, several types of grievances
deserve special consideration and possible redirection to other grievance resolutions channels, such as:

a) Complaints clearly not related to the Project: It is sometimes difficult to determine which issues are
related to the project and which are not. If in doubt, employees designated to receive grievances should
accept the complaint and assess its legitimacy. Making upfront agreements with communities as to which
types of claims are and are not project-related will help avoid misunderstandings in individual cases.

b) Complaints constituting criminal activity and violence: In these cases, complainants should be
referred to the formal justice system.

c) Commercial disputes (i.e. subcontractor not paying to third parties): Commercial matters shall be
stipulated for in contractual agreements and issues shall be resolved through a variety of commercial dispute
resolution mechanisms or civil courts.

d) Issues related to Governmental policy and Government institutions: It is not uncommon for
communities to use EPC Contractor grievance mechanisms to bring complaints related to aspects of project
implementation that are a responsibility of, and implemented by, public institutions and their officials—for
example, issues related to the resettlement process handled by local governments for the project needs. The
private sector is not obliged to address such complaints. Communicating clearly to local communities about
the role, responsibilities, and limitations of the EPC Contractor Grievance Mechanism is a must, but it may
not suffice in practice. Governments may not have enough capacity (either resources or processes) to handle
grievances, or they may be inaccessible to affected communities. At a minimum, the EPC Contractor shall
decide to pass the grievances to authorities and let the communities know how to follow up.

Grievance Procedure for Workers

In parallel to the Grievance Mechanism for external individuals and communities, EPC Contractor will
ensure that a mechanism is in place to manage the grievances raised by the project workers (including, but
not limited to, reporting of HSE issues to the EPC Contractor management) that is in line with both Bahraini
legislation as well as IFC Peformance Standard 2, Labour and Working Conditions.
Grievances from the EPC Contractor-employed workers working on the construction site will be managed
directly by HSE Manager in coordination between the Public Relations Officer and the Human Resources
Manager.

At the same time, grievances from workers employed directly or indirectly by subcontractors will be
managed by each responsible party, the overall performance of which will be reported to EPC Contractor
Management on a regular basis.

The principles underlying the Grievance Mechanism for subcontractor-employed workers are the same as the
ones for external parties/stakeholders. In addition, workers will be guaranteed that the use of the grievance
mechanism will not affect in any way their retribution or working rights.

The grievance mechanism for workers will follow the same steps, as outlined in this Grievance Management
Procedure in accordance with Bahraini Labour Law and will be the responsibility of subcontractors’ Human
Resources Departments, including:

• Disclosure of the Grievance Procedure for workers.


• Receiving and recording worker-related grievances.
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• Assessment and investigation of such grievances.
• Developing Resolution and Response to the complainant.
• Regular reporting to EPC Contractor.
• Close out of the complaint.

Worker grievances should be kept as confidential as possible, particularly in cases of alleged bullying,
harassment or whistleblowing.

Workers raising a grievance in good faith shall not be subject to any form of retaliation. Examples of such
possible grievances or concerns include possible violations of policies, rules, or legal requirements relating
to Health, Safety, Security, Environment and Social issues, and responsible operations.

22.13.1.2 Workers Accommodation Requirements

Security

 A security fence will be erected around the camp to provide a safe and secure environment for the
occupants of the camp.
 A guard-house shall be built at the entrance to the camp to prevent unauthorized persons from entering
the camp.
 The following will apply to employees and visitors to the contractor office & camp:
1) All personnel entering shall show his project ID badge to enter office & camp. No exceptions will
be made to this rule.
2) All visitors shall be registered with the gate guard signing on a logbook specifically provided for
that purpose. A visitors’ ID badge shall be issued upon surrender of the drivers’ license or passport,
etc.
3) Visitors may not walk around in the office or in the camp without permission and should be
escorted.
4) Visitors will not be allowed to remove any property from the camp unless in possession of a
material exit permit signed by the Administration Manager or camp boss.
5) No visitors may stay overnight unless the stay has been arranged with the Administration Manager
or camp boss.
6) Camp perimeter will be subjected to regular scheduled patrols. All result of patrols shall be logged.
7) The Administration Manager and camp boss will have the responsibility to ensure that these
requirements are adhered to.

Vehicle Access

 No industrial vehicles will be allowed to park in the office or camp. Vehicles will be parked in parking
area.
 Private vehicles may be parked in the office area and camp, but only in designated areas and after been
registered prior to entry. No maintenance of private vehicles is allowed at the CAMP area and no
vehicles may be parked in a way that prevents the free flow of traffic and serves as obstruction to fire
and emergency utilities. Security guards shall have full authority to search all vehicles entering/exiting
the camp.

Fire prevention
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 A fire management plan based on the fire risk assessment shall be implemented and prevention system
consists of the following:

1) Fire extinguishers
2) Information campaign
3) Organization and training
4) Regular inspections of all firefighting equipment

 A regular maintenance program of all fire detection and suppression system and equipment shall be
established and records of inspections, adjustments and repairs shall be maintained.
 Firefighting equipment shall be strategically located and identified with appropriate signs and type.
Access to fire extinguishers and hose reels shall be kept unobstructed at all times.
 The placement of firefighting equipment is critical to an effective firefighting program. The following
information is therefore considered when the locations for the firefighting equipment are identified:
1) Activities (Kitchen, Car park, Accommodation, Fuel storage).
2) Classes of fire.
 Fire extinguishers shall be placed in such a way that no person need to run more than 20m to reach an
extinguisher or fire hose reel.
 Fire extinguishers and fire hose reels shall be checked monthly, recorded, and serviced annually by a
competent person.
 Do not overload outlets and extension cords. Contact Facilities Management for help in identifying
whether a circuit is overloaded. Extension cords may only be used for temporary purposes. Permanent
wiring must be installed for long term needs.
 Identify cord insulation damage. Inspect and report any damage to switches, fixtures, and wires. Ensure
wires are not pinched, especially under and around furniture.
 Use three-prong plugs to provide protection from electrical shock.
 Know where fire extinguishers are located and know how to use them! Take a fire safety class from the
HSE department.
 Space heaters shall be used with caution. One (1) m of clearance must be maintained on all sides of the
heater. The heater shall be fitted with an auto-turn off feature if overheated.
 Smoking is not permitted where any flammable liquid is being use, including offices and document
rooms.
 All electrical equipment shall be turned off when not in use. If possible, at the end of the working day
all equipment that are not required to operate overnight shall be turned off at the wall socket points.
Electrical sockets shall not be overloaded.
 The fire risk assessment will be reviewed and updated on monthly basis.
 The camp boss has the responsibility to ensure that the fire detection and prevention equipment are
maintained and serviced at the specified intervals.
 The camp boss is also responsible for ensuring that a fire drill is performed periodically with the results
recorded and lessons learned are acted upon.

Medical Arrangements

 Medical arrangements shall be made to provide for the medical treatment of its residents, personnel or
employees with injuries, illness and the provision of first-aid and general medications.
 A full-time nurse/s will be on duty at the medical facility or first-aid station.
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 Employees can visit the medical facility under the following circumstances:
1. Injuries (including accidental toxic gas inhalation), Illness (unhealthy condition of body or mind)
 The nurse in charge of the medical facility and has the responsibility to ensure that the facility is kept to
meet an acceptable standard regarding service, equipment, material and medications.

Noise and air quality control.

 No activity that can generate dust or noise is allowed at the CAMP area.
 Noise levels at all CAMP areas shall comply with the local and international standard.
 Properly maintain equipment, lubricate and tighten loose parts that can cause noise.
 Locate noisy equipment in areas where its effects are less detrimental, and house it or install noise
dampers.
 Use barrier walls or dividers to isolate noise sources. Use of buffers or acoustically treated materials
which can absorb noise that might otherwise travel further. Using rubber pads to insulate vibrating
equipment can also help to reduce noise;
 Select the least noisy equipment possible when purchasing office equipment. When making a choice
between two or more products of equal specifications, sound levels shall be included as a consideration
for purchase and use.
 Conduct periodic noise and dust measurements at the CAMP area.

If necessary, medical hearing checks on workers exposed to high noise levels shall be performed periodically
in compliance with the IFC EHS Occupational Health and Safety Guidelines (April 2007) regarding noise
exposure limits.

Drinking Water

An adequate supply of drinking water, which complies with the national standard, will be provided in all
places of employment. Cool water shall be provided during hot weather. Drinking water will be clearly
marked.
A routine testing on drinking water will be made to ensure compliance with the national standard.
Only approved potable water systems will be used for the distribution of drinking water. Drinking water will
be dispensed by means that prevent contamination between the consumer and source. Potable drinking water
dispensers will be designed, constructed, and serviced to ensure sanitary conditions, capable of being closed
and will have a tap.
Use of a common cup (a cup shared by more than one worker) is prohibited without the cup being sanitized
between uses. Employees will use cups when drinking from potable water coolers/containers. Unused
disposable cups will be kept in sanitary containers and a waste receptacle will be provided for used cups.

Kitchen and Food Hygiene

 Food shall be consumed in mess rooms.


 No cooking shall be allowed in sleeping quarters.
 Canteen and related facilities on areas, projects or installations shall be established, operated, and
maintained in compliance with the health and sanitation recommendation from local authorities.
 Kitchen shall be constructed of proper materials.

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 Food items shall be stored in a well-lit and air-conditioned room. Food shall be stored in a way as to
ensure good stock rotation (first in, first out). Cleaning chemicals, detergent, mops and brushes shall not
be kept in food stores
 No smoking in the kitchen and sufficient fire extinguishers shall be located in kitchen and mess halls.
 The Administration Manager shall ensure that every catering employee possess a valid medical fitness
certificate from local officials.
 All food waste should be cleared regularly and managed as per waste management plan.

Washing and Sanitary Arrangements


 The sanitary units in the office or camp will at all times be kept in a clean and healthy condition. It shall
be cleaned on a daily basis and shall form part of the camp boss inspections.
 Sufficient toilets will be available on the CAMP. Septic tanks will be installed and be regularly emptied
by a licensed waste contractor and transported to an approved sanitary waste facility off site.
Alternatively, a sewage water treatment system may be installed at the CAMP in order to reuse the
water.
 The laundry facilities will be kept clean and tidy at all times.
 Employees will be trained to minimize water consumption and ensure an understanding of wastewater
issues.
 In the event of high humidity, regular monitoring for Legionella should be implemented and corrective
measures adopted to minimize risk to workers.
 The camp boss will ensure that the necessary material safety data sheets are kept on file for every
chemical used in the camp. The HSE department will assist on request.

Emergency Procedure

The CAMP emergency response will be managed as per the emergency response plan.
In case of an emergency, communication will be done via the public address system or hand-held
megaphones and will be managed by the emergency response team under the camp boss leadership. Public
address announcements will be used to assist personnel in their safe escape and evacuation.
The evacuation routes and safety signs shall be clearly indicated and these signs shall be updated on a timely
basis.
The Emergency plan may include:
1) Training program.
2) Designated emergency team.
3) Emergency monitoring.
4) Environment emergency response.

The camp boss under HSE Department guidance has the responsibility to ensure that the address system is
operational at all times. His mobile phone shall be used as a 24-hr. communication link for camp
emergencies.

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The HSE department will do a monthly inspection and audit of the camp and this will be documented.

Inspections

HSE manager or his designee shall conduct monthly inspection to the accommodation of the employees in
order to verify that IFC, International and Local requirements are fulfilled.

22.13.1.3 Security Plan

General

The contractor has the overall responsibility for security access control at the project.

Control Measures

All project employees, including subcontractors and/or vendors and visitors shall use only the designated
gate for entrance and exit to and from the job site and lay-down facilities. Procurement and contract
personnel will make arrangements with vendors and subcontractors so that they will know which gate to use
and specific area location on the project.

Access of project personnel, subcontractors, vendors and visitors, vehicles and equipment will only be
allowed with a valid entry pass.

Subcontractor shall complete the application forms correctly and submit all supporting documentation to the
contractor via their representative for review and processing.

After processing subcontractor’s completed documentation, contractor will issue numbered, reasonably
tamper proof ID badges to subcontractor employees once received safety indoctrination and other required
training, vehicle passes for vehicles and equipment passing the inspection.

Use of photographic equipment inside the plant is strictly forbidden without specific approval of contractor.
No photographic or any other imaging devices will be allowed on the project without proper approval of
contractor.

No radios, cassette players or CD walkmans shall be allowed on site with the exception of passenger vehicles
and offices.

Identification Control

Security will conduct random searches of vehicles, lunch boxes, property and personal carry items of project
personnel and visitors as they enter or exit the project. Bags and attached case hand-carried by persons
authorized to have access shall be voluntarily presented for inspection to the security guards on duty at the
main gates.

Material Control

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All tools and materials, other than trash (general waste, non-hazardous waste), that is removed from the
project must be accompanied by a material exit pass. All trash that is removed from site will be checked by
security to verify the content.

a) Incoming Material

All packages for delivery to personnel on site shall be inspected by the security guards at the access gates.
The addressee shall be informed about the arrival of the package prior to inspection. After inspection, the
package may be collected by the addressee, or stored in the Security office, depending on the addressee’s
advice or the contents of the package.

All incoming deliveries of supplies, materials and equipment for the project shall be accompanied by a
material entry pass, or a delivery note, if from a vendor. Security will examine the material and/or equipment
and compare with the delivery note or material entry pass and notify site management of the delivery.
Security will retain a copy of the material entry pass or delivery note. Delivery materials will have to be
escorted from the main gates by a representative, to the warehouse or its final destination.

b) Outgoing Material

All supplies, materials, equipment to be taken off the site or lay-down facilities shall be presented for
inspection to the security guards on duty at the gate and signed off by the security manager or supervisor.
The corresponding gate pass for said items shall be presented to the security guards on duty.

The hazardous waste can only be transferred by certified environment company, and the Waste Transfer
Note shall be checked by the gate security guards at the same time.

A designated representative(s) of Management must sign the material exit pass to authorize material exit. All
signatures will be checked against a list of authorized signatories, which will be maintained at the security
office. A copy (original) of the gate pass shall be retained with the Security.

Additional Security guidelines

Project security shall remain on site through to handover of the facility and each gates of the site shall be
controlled by the security. The security shall:

 Report all security issues on site to contractor Security Manager and Supervisor.
 Control all personnel and vehicles entering or leaving project.
 Conduct security patrols on site, office, camp and external site areas to check for any fire,
environmental spills, and perimeter fence, security of site offices, buildings, and storage compounds.
 Monitor for any other irregularities or suspicious behavior.
 Enforce parking regulations or restrictions where applicable.
 Control all personnel to use correct pedestrian walk ways on the project.
 Check the speeding of vehicles on the site and surrounding areas.

22.13.1.4 Project Site Sanitation and Temporary Housing and Offices

The temporary site facilities shall be designed and constructed to meet the legal requirement and ensure the
facilities provided are conducive and sufficient for the wellbeing, health and safety of the workers.
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This facility shall be laid-out and constructed so that the following factors are taken into account:

 Stationary equipment i.e. generators, power distribution panels are obstruction free and located 15m
apart from flammable / combustibles.

 Aisles and access ways are adequate and continuous.

 Designated area for hot work operations such as welding, cutting, grinding, etc., are isolated from
flammable or combustible materials such as paints, solvents, acetylene or work area that may create or
increase potential risk to fire such as carpentry shops.

 Orderly arrangement of equipment, materials and portable buildings to prevent congestion of activities
and traffic.

 As soon as the temporary site facility is completed, the required quantity of first-aid fire extinguisher
equipment shall be installed without delay at strategic locations as planned.

 After having the temporary facility provided with adequate fire extinguishing equipment, it must be
ensured that enough spare of the same is available, for use at work site.

Facilities for sleeping, dining, medical, sanitation and recreation, as well as grocery/convenience markets,
cleaning/laundry services, etc., shall be provided in accordance to the requirements inside camp.

Sleeping and living rooms shall be air-conditioned and maintained with good housekeeping.

Camps shall include a fully equipped kitchen(s) and dining room(s) suitable for the preparation of high-
quality meals. Dining facilities shall be provided with tables, chairs, utensils and cutlery.

Camps and project support facilities shall include adequate purpose-designed lighting for all parking areas,
roads and around buildings and outdoor facilities.

Toilet facilities shall be easily accessible and shall be of durable and hygienic construction consistent with
their purpose and shall have adequate lighting, ventilation and a continuous supply of water.

A medical center shall be provided with certified nurse. The facility shall be equipped to deal with first aid
cases and other minor injuries.

A training center located at the entrance of site, white boards, poster, TV etc. training facilities shall be
available for E&S training.

22.13.1.5 Medical Surveillance

EPC Contractor will provide or arrange subcontractors to perform regular health surveillance for all site-
based workers on such issues as:

 Dermatitis
 Noise Induced Hearing Loss

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 Hand arm Vibration Syndrome
 Musculoskeletal problems

Also, EPC Contractor will require support from Government medical institutions so as to carry out health
surveillance campaigns including general health checkup and available vaccination programs.

22.13.2 Monitoring Requirements:

The Appendix No. 2 – Section 13.3 of this plan describes the monitoring requirements to be implemented by
the EPC Contractor with regard to Health and Safety during the Construction and Commissioning stages of
the project.

23. Documentation

A project filing system shall be developed for the project. All project related communications will be via the
Owner's document control system. Hard copy records shall be held in clearly labeled level arch files. An
index of the project E&S files shall be prepared. Hard copy records shall be available for inspection and / or
audit at all times.

Soft copy records shall be uploaded into the Project Management Information System. A folder structure for
soft copy records shall be prepared on this system.

Project records shall be retained in accordance with EPC Contractor corporate procedure Document &
Records Control.

All Subcontractor's HSE and E&S Plan, emergency plan, risk assessment etc. have to be reviewed and
approved by EPC contractor before they start work as part of a formal documented process.

24. Forms

EPC Contractor shall develop and use E&S Forms so as to leave evidence and recording of its activities in
Al-Dur II IWPP, including E&S requirements inspection forms. Also, E&S forms are one of the key points
to face E&S Audits.

EPC Contractor shall ensure that every aspect that requires to be monitored and/or recorded, have formats or
checklists that can be used by the employees. Some samples are included in the Appendix No 3 of this Plan.
However, the full core of E&S forms will reside as annexes of each one of the E&S procedures to be
developed and implemented by EPC Contractor in Al-Dur II IWPP.

END

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