Neom Incident reporting procedure

ENVIRONMENTAL PROCEDURES
INCIDENT IDENTIFICATION, INVESTIGATION

AND REPORTING PROCEDURE
NEOM-NEV-PRC-704 Rev 01.00, November 2021
©NEOM [2021]. All rights reserved.

Document history
Revision code Description of changes Purpose of issue Date

Issued for
Rev 01.00 First Issue 14.11.2021
Implementation
Document approval
Prepared by Reviewed by Approved by

Name Noel Woods Bevan Van Blommestein Damien Trinder
Job Title Senior Manager Senior Assurance Specialist (Acting) Chief Environmental
Environmental Officer
Assurance
DOCUMENT CODE: NEOM-NEV-PRC-704 REVISION CODE: 01.00 PAGE 2 OF 36

Contents
1 INTRODUCTION ................................................................................................................... 4
2 PURPOSE ............................................................................................................................. 4
3 SCOPE .................................................................................................................................. 4
4 DEFINITIONS AND ABBREVIATIONS ................................................................................ 4
5 ROLES AND RESPONSIBILITIES ...................................................................................... 5
6 PROCEDURE ....................................................................................................................... 5
6.1 Incident Management and Reporting Process – Class A, Level 3 ....................................... 5
Recognise ............................................................................................................................. 6
Categorise ............................................................................................................................. 6
Respond ................................................................................................................................ 7
Call ........................................................................................................................................ 7
Mitigate .................................................................................................................................. 7
Notify ..................................................................................................................................... 8
Investigate ............................................................................................................................. 8
Report .................................................................................................................................... 8
Rectify Root Causes ............................................................................................................. 9
Check Corrective Actions ...................................................................................................... 9
Records ................................................................................................................................. 9
6.2 Incident Management and Reporting Process – Class A, Level 1 and Level 2 .................... 9
7 RELATED DOCUMENTS ................................................................................................... 10
APPENDIX A: INCIDENT CLASSIFICATION FLOWCHART ............................................................. 11
APPENDIX B: INCIDENT REPORTING AND RESPONSE FLOWCHART ........................................ 13
APPENDIX C: REPORTING THRESHOLD MATRIX .......................................................................... 15
APPENDIX D: SUGGESTED RESPONSES PER INCIDENT TYPE ................................................... 18
APPENDIX E: NEOM INCIDENT WITNESS STATEMENT FORM ..................................................... 21
APPENDIX F: ENVIRONMENTAL INCIDENT ROOT CAUSE ANALYSIS TOOL (EIRCAT) ............ 23
APPENDIX G: ENVIRONMENTAL INCIDENT NOTIFICATION FORM .............................................. 26
APPENDIX H: ENVIRONMENTAL INCIDENT INVESTIGATION REPORT FORM ........................... 29
APPENDIX I: INITIAL INVESTIGATION / DATA GATHERING TECHNIQUES ................................. 35
List of Tables
Table 4-1: Abbreviations ......................................................................................................................... 4
Table 4-2: Definitions ............................................................................................................................. 4

1 Introduction
NEOM requires a proactive approach to prevention of environmental incidents. Where environmental
incidents do occur, Contractors shall take immediate and expedient action to mitigate environmental
impacts. Contractors shall also investigate the root cause of the incident to ensure that effective
corrective actions are implemented to prevent the reoccurrence of the incident.
2 Purpose
To define the process by which Contractors manage, report, and investigate environmental incidents,
with a view to identifying and addressing incident root causes to prevent reoccurrences.
3 Scope
This procedure relates to all environmental incidents which occur as a result of construction and
development at NEOM. This procedure also includes incidents associated with the provision of
materials and services to NEOM construction and development activities.
An Environmental Incident is defined as an occurrence or set of circumstances, because of which

pollution (air, water, noise, and land) or an adverse environmental impact has occurred, is occurring, or
is likely to occur.
All Contractors are required to report Environmental incidents in accordance with the requirements of
this procedure Environmental Incident Notification, Investigation and Reporting.
Appended to this procedure are the following related forms:
• NEOM Incident Witness Statement Form (NEOM-NEV-PRC-704_FRM01)

• Environmental Incident Root Cause Analysis Tool (EIRCAT) (NEOM-NEV-PRC-704_FRM02)
• Environmental Incident Notification Form (NEOM-NEV-PRC-704_FRM03)
• Environmental Incident Investigation Report Form (NEOM-NEV-PRC-704_FRM04)
4 Definitions and Abbreviations

Table 4-1: Abbreviations
Abbreviation Explanation
EIRCAT Environmental Incident Root Cause Analysis Tool
ESIA Environmental & Social Impact Assessment
NCR Non-Conformance Report
NEV NEOM Environment Department
PEC / PMC Project Environmental Consultants / Project Management Consultant
Table 4-2: Definitions
Term Definition
Environment NEOM regulatory agency tasked with the delivery of environmental protection and
Department sustainable land use and development.
Environmental An occurrence or set of circumstances, because of which pollution (air, water, noise,
Incident and land) or an adverse environmental impact has occurred, is occurring, or is likely
to occur.

Term Definition
Employer The Employer is a NEOM entity or a Project Management Consultant (PMC)

designated by NEOM to be responsible for the planning, designing,
constructing, or managing and operating a particular asset or a group of assets.
5 Roles and Responsibilities

Contractor is responsible for:
1. Responding in an appropriate and timely manner to all environment incidents.
2. Reporting all Class A Environmental Incidents to Employer and NEOM Environment Department
(NEV).
3. Thoroughly investigate all Class A Environmental Incidents and implement effective and
appropriate corrective action.
4. Recording all Class B Environmental Incidents (Minor Environmental Harm Events) in a register.
5. Ensuring that registers of Class A and Class B Environmental incidents are maintained and
available for review/audit at all times.
Employer is responsible for:

1. Ensuring that all incidents are correctly reported and in adherence to the timeframes and details
required by this procedure.
2. Ensuring that all incidents are investigated, and that corrective action is implemented and
effective in preventing reoccurrence of incidents.
3. Reviewing incident investigation reports to ensure that they contain the required level of detail to
support development of effective corrective action.
4. Supporting the contractor in incident investigation and development of corrective actions.
NEV are responsible for:

1. Conducting trend analysis of incidents and formulating training / awareness / technical support
activities to prevent reoccurrence of incidents.
6 Procedure
Class A, Level 3 environmental incidents are generally localised and of relatively low impact. These
types of incidents are normally managed, reported and investigated at a site level by Contractor
personnel (Contractor Environmental Managers) supported and guided by Employer Environmental
Specialists. The process for managing, reporting, and investigating Class A, Level 3 incidents is
detailed below in Section 6.1.
The process for managing, reporting, and investigating Class A, Level 1 and 2 incidents is detailed
in Section 6.2
6.1 Incident Management and Reporting Process – Class A, Level 3
Contractor shall implement an Incident Management and Reporting process that adheres to the
below listed steps and subsequent detailed requirements.
Step 1 - Recognise
Step 2 - Categorise
Step 3 - Respond
Step 4 - Call - 1 Hour
Step 5 - Mitigate

Step 6 - Notify - 24 Hrs
Step 7 - Investigate
Step 8 - Report - 72 Hrs
Step 9 - Rectify Cause Fix
Step 10 - Check Corrective Action
Step 11 – Records
Recognise
1. Environmental incidents are likely to happen as a result of the occurrence of unplanned events. In
many cases, persons (those carrying out a task or operating plant or equipment) are present at the
time of the incident occurring.
2. It is imperative that persons present during an environmental incident and/or who witness an
environmental incident have the capacity to recognize an environmental incident. This is achieved
through environmental training and awareness, which is detailed in NEOM-NEV-TRP-801.
3. Environmental Incidents include any of the following non-exhaustive list:
a. Fuel / Oil Spill on Land (Incident Type 1)
b. Inadequate Waste Management Incident Type 2)
c. Chemical Spill on Land (Incident Type 3)
d. Excessive Environmental Noise (level (from Equipment or Activity) (Incident Type 4)
e. Fuel / Oil Spill on Water (Incident Type 5)
f. Damage to cultural heritage (Incident Type 6)
g. Chemical Spill on Water (Incident Type 7)
h. Unplanned atmospheric emissions (Incident Type 8)
i. Waste-water discharge to Land (Incident Type 9)
j. Unplanned release of water (Incident Type 10)
k. Loss of / Damage to Fauna (Incident Type 11)
l. Loss of / Damage to Flora (Incident Type 12)
m. Complaints related to Environmental Factors (noise / dust / light / traffic / public roads / etc.)
(Incident Type 13)
n. Topographical modifications which have not been assessed / approved (Incident Type 14)
o. Other types of incidents with moderate / major environmental impact (Incident Type 15)
4. Where persons are not present at the time of the incident, the incident should be recognised and
identified during the daily environmental inspection or reported by Contractor’s workers who have
cause to frequent the location where the incident has occurred.
5. Contractor shall ensure that all workers are made aware of the requirement for recognizing and
reporting environmental incidents (both Class A and Class B, see section 5.1.2) to Contractor
Environmental Manager. This should be part of the environmental induction to the site and
periodically addressed in weekly environmental Toolbox Talks.
6. Contractor Environmental Manager shall be available at all times to receive notification phone calls
alerting them to the occurrence of environmental incidents.
7. Contractor Environmental Manager will ensure that their telephone contact details are widely
communicated to Contractor’s workforce, to ensure that incidents can be quickly reported.
Categorise
1. Having identified the occurrence of an environmental incident, the Environmental Manager should
immediately categorise the incident.
2. An incident classification system has been developed and is summarised in Appendix A - Incident
Classification Flowchart:
▪ Class A – Level 1 – Catastrophic / Severe Incident – Reportable to NEOM and NEV
▪ Class A – Level 2 – Major / Moderate Incident – Reportable to NEOM and NEV

▪ Class A – Level 3 – Minor Incident – Reportable to NEOM and NEV
▪ Class B – Minor Environmental Harm Event – NOT Reportable to Proponent and NEV
3. Class B Environmental Incidents do NOT require an emergency response and can generally be
dealt with by site-level non-emergency response personnel.
4. Class A Environmental Incidents requires a response provided by either the Contractor Emergency
Response Team and/or by external Emergency Response Services.
5. Appendix C provides details of reporting thresholds for each type of environmental incident.
Contractors shall ensure that Appendix C is referred to and applied when making a determination
as to the Class (and therefore reporting requirements) of each environmental incident.
6. Having established what Class the incident is, Appendix C also provides details of how Levels of
Class A incident are categorised.
Respond
1. Contractor shall immediately respond to all Class A and Class B environmental incidents, as
summarised in Appendix B Incident Reporting and Response Flowchart.
2. The response will be determined by the classification of the incident, the spatial and temporal nature
of the incident, environmental receptors affected, etc.
3. Contractor should refer to their Emergency Response Plan for detailed requirements for responses
to a range of environmental incidents. Suggested responses to environmental incidents are
included in Appendix D.
4. Initial responses should broadly follow the below steps
a. Stop – identify the source of the incident and stop the activity / equipment / process / work
generating the source
b. Notify – the emergency response team (Class A - Level 3); the emergency services (Class
A – Level 2 & 1); Proponent and NEOM Sector (by phone)
c. Contain – contain the source of incident to limit the extent of the affected area.
Call
1. Contractor Environmental Manager shall immediately inform Employer and NEV via phone call.
2. Contractor shall not call any external emergency services, without first consulting Proponent and
NEOM Environment and seeking direction.
3. Contractor Environmental Manager shall relay the following information during the phone call:
a. Name of the Contractor Environmental Manager
b. Name of the Project
c. Category of Environmental Incident
d. Incident Typology
e. Time of incident
f. Details of initial response
g. Incident details – quantities involved, receptors affected, etc.
Mitigate
1. Contractor shall ensure that measures to mitigate environmental impacts resulting from the
environment incident are implemented.
2. Mitigation measures should be detailed in the Contractors Emergency Response Procedure.
3. Contractors shall ensure that, where applicable, all environmental media and emergency response
materials affected by the environmental incident are stored and disposed in accordance with
Proponent requirements and with relevant regulatory requirements.

Notify
1. Having responded to the environmental incident and mitigated the effects of the incident, Contractor
Environmental Manager shall, within 24 hours of the incident occurring, provide to NEOM and NEV,
an Environmental Notification Report using the NEOM Incident Notification Report Form.
2. The Environmental Notification Report (Appendix G) should be fully completed and must contain a
suitable level of detail to provide Employer and NEV with a comprehensive and coherent overview
of the incident situation.
3. The Notification report should comply with the following guidelines:
a. Date, time, and specific location of incident
b. Names, job titles, and department of persons involved
c. Names and accounts of witnesses
d. Events leading up to incident
e. What persons involved were doing at the moment of the accident
f. Events and circumstances at the time of the incident (environmental conditions, tasks,
duration, equipment, tools, materials, etc.)
g. Events immediately following the incident – response / mitigating actions
h. Environmental impact (media affected, extent, etc.)
Investigate
1. Following the containment and mitigation of the environmental incident, the Contractor shall
conduct a detailed investigation into the environmental incident using the NEOM Incident
Investigation Report form.
2. Contractor should assemble an Environmental Incident Investigation Team to investigate the
incident.
3. The Investigation Team should have a Lead Investigator to coordinate the investigation process
and must be trained and competent.
4. The incident investigation should, as a minimum, include the following:
a. Interview of eyewitnesses and generate witness statements using the NEOM Incident
Witness Statement Form provided in Appendix E.
b. Interview of persons involved in the activity that led to the incident.
c. Obtain available photos and video footage that may capture the initial moments of the
incident.
5. Having established who was involved, the process (task) involved and the plan (equipment,
machinery and/or vehicles) involved, the Contractor shall attempt to establish the Root Cause of
the incident by conducting a Root Cause Analysis.
6. Contractor should conduct the Root Cause Analysis by using the Environment Incident Root Cause
Analysis Tool (EIRCAT), provided in Appendix F.
7. Contractors shall identify the Root Causes and Contributory Factors associated with the
environmental incident.
Report
1. Contractors shall submit the Environmental Incident Investigation Report (using the report template
provided in Appendix H) to Employer and NEV within 72 hours of the incident occurring.
2. Appended to the Environmental Incident Investigation Report should be witness statements,
records (training / equipment checks / equipment maintenance), additional photos and the
completed EIRCAT form.
3. The report (Section 14) should detail the corrective actions required by the Contractor to rectify the
Root Causes and Contributory Factors that led to the incident.
4. Contractor corrective actions should be detailed on a Contractor Non-Conformance Report (NCR)
Form and the process of implementing that corrective action, managed through the Contractor’s
NCR process.

Rectify Root Causes
1. Contractors shall ensure that the root causes identified during the incident investigation process is
rectified, by applying the Contractors NCR Process. Appendix F contains an EIRCAT which the
contractor shall use to assist them determine root causes.
2. Contractor shall ensure that appropriate documentation is generated which records the NCR
process. This documentation should, as a minimum, include:
a. Non-Conformance Report
b. NCR action plan – which details those actions to be taken to rectify the root cause
c. Evidence that the items identified in the NCR Action Plan have been implemented e.g.,
training records, revision of procedures, relevant internal communications, lessons learned
events, etc.
3. Contractor shall ensure that all NCR related documentation is collated and held on file, for audit
by Proponent.
Check Corrective Actions
1. Contractors shall periodically and routinely check that the applied corrective action has been
effective.
2. Where Contractors have multiple projects across NEOM, Contractors shall apply the corrective
action broadly across their organisation to ensure that the potential for similar environmental
incident to occur elsewhere in NEOM is prevented.
3. Evidence of broader implementation of corrective action shall be available for audit by Employer.
Records
1. The Contractor shall keep documented records of all environmental incidents and events at the
work site.
2. All incident records must be securely retained as long as the site / service are operational plus ten
years thereafter. Incident records shall be made available to Employer and NEV on request.
3. The Contractor shall maintain a register of all environmental incidents on site. Registers shall be
subject to audit by Employer and NEV.
4. Contractor shall be required to provide environmental incident summary data as part of
Environmental Routine Reporting requirements.
6.2 Incident Management and Reporting Process – Class A, Level 1 and Level 2
1. Step 1 – Recognise – as detailed in 6.1.1

2. Step 2 – Categorise – as detailed in 6.1.2
3. Step 3 – Respond – as detailed in 6.1.3
4. Step 4 - Call - 1 Hour – as detailed in 6.1.4
5. Step 5 – Mitigate – as detailed in 6.1.5
6. Step 6 - Notify - 24 Hrs – as detailed in 6.1.6
7. Step 7 – Investigate.
a. Conduct an Environmental Incident Investigation Meeting, which should be attended by
Employer; NEOM Projects; NEV.
b. At the meeting agree the investigation team, investigation approach, investigation scope
and investigation methodology (e.g., Ishikawa; 5 Why; etc)
c. Document the investigation approach in an Incident Investigation Plan.
d. Conduct the investigation.
8. Step 8 - Report - 72 Hrs – as detailed in 6.1.8
9. Step 9 - Rectify Cause Fix – as detailed in 6.1.9
10. Step 10 - Check Corrective Action – as detailed in 6.1.10
11. Step 11 – Records – as detailed in 6.1.11

7 Related Documents
1. NEOM Incident Notification Report Form – Appendix G
2. Environment Incident Root Cause Analysis Tool (EIRCAT) – Appendix F
3. NEOM Environmental Incident Investigation Report Form – Appendix H
4. GAMEP Environmental Standards - Prevention of Major Accidents

Appendix A: Incident Classification Flowchart


Appendix B: Incident Reporting and Response Flowchart


Appendix C: Reporting Threshold Matrix

Environmental Incident Minor Environmental Harm Event
REPORTABLE to NEOM & NEV NOT Reportable to NEOM & NEV
Incident
# • Phone Call – 1 Hour
Type Reportin Recordin • Record on Minor Environmental
• Notification Report – 24 Hours
g g Harm Event Register
• Incident Investigation Report –
Protocol Protocol • Register shall be subject to audit
72 Hours
• More than 5L • Less than 5L
Fuel / Oil Spill • More than 3m2 Surface area • Less than 3m2 Surface area
1
on Land • Immediate pathway / risk of extended pollution • No immediate pathway entered
• Percolated / ponded more than 2cm • Percolated / ponded less than 2cm
• Any off-site escape of hazardous waste
Inadequate
• Offsite escape of non-hazardous waste causing Minor off site escape of non-hazardous waste (e.g.,
2 Waste
nuisance or harm to sensitive habitat (e.g., major minor off-site litter)
Management off-site litter)
• More than 5L • More than 5L
Chemical Spill • More than 3m2 Surface area • More than 3m2 Surface area
3
on Land • Immediate pathway / risk of extended pollution • No immediate pathway entered
• Percolated / ponded more than 2cm • Percolated / ponded less than 2cm
Excessive
Environmental
• 3 dB(A) over local / ESIA limit • Intermittent exceedance of noise levels as a result
4 Noise (Activity
• Noise emissions leading to a public complaint of a temporary activity
and
Equipment)
Fuel / Oil Spill
5 • Any fuel / oil spill on water is reportable
on Water
Discovery
and/or Damage • Any discovery/damage of archaeological / heritage site / artifact is reportable
6
to cultural • Any near miss damage to cultural heritage is reportable
heritage
Chemical Spill
7 • Any chemical spill on water is reportable
on Water
• Short release (˂5 minutes) of atmospheric
Unplanned • Prolonged release (˃5 minutes) of atmospheric
emissions which are clearly visible
8 atmospheric emissions which are clearly visible
• Odour detectable by humans found to be
emissions • Odour emissions leading to a public complaint
unpleasant
Waste-water • More than 20L
• Less than 20L
9 discharge to • More than 5m2 Surface area
• Less than 5m2 Surface area
Land • Immediate pathway / risk of extended pollution
Unplanned
• Over 5000L of potable water • Less than 5000L of potable water
10 release of
• Over 1000L of flushing water • Less than 1000L of flushing water
water
Loss of / • Any injury or fatality of terrestrial threatened / iconic species are reportable
11 Damage to • Any injury or fatality of marine Threatened species are reportable
Fauna • Any fishing / fish kills are reportable
Loss of /
12 Damage to • Any loss of plant species or habitat or area of conservation value on or off site is reportable
Flora
• Any complaint from a member of the public or
• Informal complaints
Community
13 Complaints • Complaints generated by somebody from within
• Any complaint generated by somebody outside
the project site
of the project site
• Any form of topographical change / modification • Any form of topographical change / modification
Topographical
14 which has not been assessed and approved by which has not been assessed and approved by
modifications
NEV is reportable NEV is reportable
• Other incidents that result in moderate / major
15 Other
environmental hard

• Phone Call – 1 Hour
Reporting • Notification Report – 24 Hours
Incident Protocol • Incident Investigation Report – 72 Hours
#
Type
Class A, Level 1 Class A, Level 2 Class A, Level 3
• More than 5L
• More than 3m2 Surface area
Fuel / Oil Spill
1 • Immediate pathway / risk of extended
on Land
pollution
• Percolated / ponded more than 2cm
• Any off-site escape of hazardous waste
Inadequate
• Offsite escape of non-hazardous waste
2 Waste
causing nuisance or harm to sensitive habitat
Management
(e.g., major off-site litter)
• More than 5L
• More than 3m2 Surface area
Chemical Spill
3
on Land • Immediate pathway / risk of extended
pollution
• Percolated / ponded more than 2cm
Excessive
Environmental
• 3 dB(A) over local / ESIA limit
4 Noise (Activity
• Noise emissions leading to a public complaint
and
Equipment) Level 3 criteria plus:
Fuel / Oil Spill • Requires
5 Level 3 criteria plus: • Any fuel / oil spill on water is reportable
on Water mobilisation of
• Requires
Damage to substantial local • Any discovery/damage of archaeological /
6 cultural notification to heritage site / artifact is reportable
resources
MEWA.
heritage • Requires assistance • Any near miss damage to cultural heritage
• Significant amount
Chemical Spill of other agencies
7 of material • Any chemical spill on water is reportable
on Water • Requires
released; material
evacuation of • Prolonged release (˃5 minutes) of
of a more
Unplanned impacted area and atmospheric emissions which are clearly
hazardous nature
8 atmospheric a substantial visible
• Significant near
emissions isolation area • Odour emissions leading to a public
miss environmental
• Disrupts the BAU complaint
event
operations of other
• Requires isolation • More than 20L
Waste-water sectors
of impacted area • More than 5m2 Surface area
9 discharge to • Release is major or • Immediate pathway / risk of extended
Land the material is pollution
Unplanned extremely toxic.
• Over 5000L of potable water
10 release of
• Over 1000L of flushing water
water
• Any injury or fatality of terrestrial threatened
Loss of /
/ iconic species are reportable
11 Damage to
• Any injury or fatality of marine Threatened
Fauna
species are reportable
Loss of /
• Any loss of plant species or habitat or area of
12 Damage to
conservation value on or off site is reportable
Flora
• Any complaint from a member of the public
or Community
13 Complaints
• Any complaint generated by somebody
outside of the project site
• Any form of topographical change /
Topographical
14 modification which has not been assessed
modifications
and approved by NEV is reportable
• Other incidents that result in moderate /
15 Other
major environmental hard

Appendix D: Suggested Responses per Incident Type

Response Guidelines - Oil and Fuel Spills
• Wear protective clothing.
• Prevent further release at source.
STOP
• Remove sources of ignition.
• Prevent access to the site.
NOTIFY • Categorise Incident and notify responsible party as per Incident Notification Protocol
• Implement measures described within the relevant Material Safety Data Sheet (MSDS).
• Use absorbent materials for clean-up, e.g.: sand or pads to absorb excessive materials
and dispose of within plastic bucket so not to transfer spill.
• Do not rinse away spills.
CONTAIN • If spills migrate, create temporary bunds using soil, sandbags, or spill kit materials.
• Any contaminated materials will be considered as Hazardous Waste, and therefore
mitigation measures for Hazardous Waste Management must be implemented.
• If drains are located nearby, install drain seals.
Response Guidelines – Chemical Spills

• Wear protective clothing.
STOP
NOTIFY Categorise Incident and notify responsible party as per Incident Notification Protocol
• Use absorbent materials for clean-up, e.g.: sand or pads to absorb excessive materials
and dispose of within plastic bucket so not to transfer spill.
• Do not rinse away spills.
• If a spill is migrating create temporary bund using soil, sandbags, or spill kit materials.
CONTAIN
• Any contaminated materials will be considered as Hazardous Waste, and therefore
mitigation measures described in the Hazardous Waste Management control plan must
be implemented.
• If drains are located nearby, install drain seals.
Response Guidelines – Leakage of Gaseous Substance

• Identify the source.
STOP • Provide aeration to area.
• If not practicably possible to contain gaseous leak, weather conditions must be checked
CONTAIN to assess the most likely direction the pollutants will take. If there is a risk (however
slight) to human health, affected areas and immediate environs must be evacuated.
Response Guidelines – Release of Excessive Dust / Bulk Powders

STOP • Prevent further release of dust e.g.: if split pipe, stop transferring dust until pipe is
replaced/repaired.
• Under dry conditions, dampen area using a bowser or similar to prevent wind-blown
dust (unless dry dust can be reclaimed immediately for re-use, by use of specialist
equipment.
CONTAIN
• When dampening the site down, ensure the resulting mixture/run-off does not enter any
drains or groundwater.
• Deploy dust suppression bowsers (or roads sweepers in wet conditions) on any hard
surfaces affected by dust.

• Cover materials which are being transported or large exposed stockpiles or relocate
exposed stockpiles where possible.
Response Guidelines – Noise Incidents

• Assess the situation and associated noise level.
STOP • If any complaint has been received, it may be necessary to meet the complainant.
• Make a judgement of what can be done, if anything, to minimise the noise propagating
from the site on factors such as remaining duration of the works.
• Initially ensure all plants are maintained, and with correct appliance, to prevent
CONTAIN excessive noise.
• Conduct work near sensitive receptors during daytime hours only.
Response Guidelines – Accidental Archaeological Finds
• Stop work immediately.
STOP • Cordon affected area to prevent further disturbance.
• Contact The Proponent Environmental immediately for advice on how to proceed.
• Cease works in and around the cordoned off site until receiving a no objection from the
Proponent Environmental.
CONTAIN
• Implement response procedure in accordance with the Proponent Environmental
requirements.

Appendix E: NEOM Incident Witness Statement Form

NEOM – ENVIRONMENT INCIDENT WITNESS STATEMENT FORM
Statement Date Witness Statement Reports are to be completed by Incident

Investigators to record information from any person who
directly witnesses and incident or those who may have any
Incident Ref # information regarding an incident.
WITNESS DETAILS:
Incident Date: Incident Time:
Name: Date of Birth:
Mobile Number:
Employer: Occupation:
Duties at time of incident:
STATEMENT:
Name Signed Date

Appendix F: Environmental Incident Root Cause Analysis Tool (EIRCAT)

Environmental Incident Root Cause Analysis Tool - EIRCAT
The ERICAT tool is to be used as part of the investigation of all Class A, Level 3 incidents.
Use the below table to consider what materials / equipment were involved in the incident and what activities (Task) was being conducted at the time
of which the incident occurred. Who was involved (Personnel), what were the working conditions (Environment) and what role did management
systems or lack thereof play in the incident occurring? The root cause can be established by considering the below incident elements. Every question
must be answered by ticking the Yes / No cells assigned to each question.
1 Material / Equipment Yes No 4 Environment (continued) Yes No
1.1 Container failure 4.6 High Noise Levels
1.2 Defective equipment 4.7 Inadequate alarm systems
1.3 Defective tools 4.8 Inadequate illumination
1.4 Equipment unfit for purpose 4.9 Inadequate storage facilities
1.5 Equipment failure 4.10 No / inadequate signs / notices
1.6 Equipment or materials not secured 4.11 Presence of Dust
1.7 Erosion of material 4.12 Presence of Fumes
1.8 Expired products 4.13 Presence of Gases
1.9 Improper handling of materials 4.14 Presence of Vapours
1.10 Improper storage of materials 4.15 Presence of Vibration
1.11 Lifting equipment 4.16 Temperature extremes
1.12 Release of hazardous substance 5 Management Yes No
1.13 Spillage of material 5.1 Communication
1.14 Use of unsafe / substandard equipment 5.1.1 Confusing instructions
2 Task Yes No 5.1.2 Inadequate communication of procedures
2.1 Boredom of mundane task 5.1.3 No / inadequate pre-task instructions
2.2 Changes to working hours 5.1.4 Vague / incorrect instructions
2.3 Checks / checklists not completed 5.2 Planning
2.4 Equipment not checked 5.2.1 Deviation from procedure
2.5 Habit / personal preference 5.2.2 Env Inspections not conducted
2.6 Handling (lifting, pushing, pulling) 5.2.3 Inadequate hazard controls
2.7 Improper loading 5.2.4 Inadequate identification of job hazards
2.8 Improper use of equipment 5.2.5 Inadequate implementation of procedures
2.9 Improper use of tools 5.2.6 Inadequate inspection / monitoring
2.10 Improper waste disposal 5.2.7 Inadequate oversight / supervision
2.11 Inadequate repair 5.2.8 Inadequate preventive maintenance
2.12 Routine / monotony 5.2.9 Inadequate response to prior hazard / incident
2.13 Struck against 5.2.10 Inadequate response to prior hazard / incident
2.14 Struck by 5.2.11 Inadequate supervision of task
3 Personnel Yes No 5.2.12 Inadequate work planning
3.1 Changes to personnel 5.2.13 Lack of policies / guidelines / procedures
3.2 Communication barriers 5.2.14 No / inadequate risk assessment
3.3 Distracted by other activities 5.2.15 Planned general inspections not conducted
3.4 Defects not reported 5.2.16 Unclear assignment of responsibility
3.5 Fatigue 5.3 Training
3.6 Hearing deficiency 5.3.1 Competency and training needs not identified
3.7 Improper decision making 5.3.2 Inadequate assessment of required skills
3.8 Inadequate peer-to-peer communication 5.3.3 Inadequate emergency response teams
3.9 Lack of job-knowledge 5.3.4 Inadequate induction / training
3.10 Skills deficient 5.3.5 Inadequate instructor qualifications
3.11 Sensory deficiency 5.3.6 Inadequate new employee orientation
3.12 Poor judgement 5.3.7 Inadequate practice of skills
3.13 Poor reaction times 5.3.8 Inadequate refresher training
3.14 Process deviation by individual 5.3.9 Lack of coaching
3.15 Routine activity without thought 5.3.10 New work methods introduced without training
3.16 Vision deficiency 5.3.11 No / inadequate sub-contractor training
4 Environment Yes No 5.3.12 Supervisor implied haste
4.1 Animals / insects / pests 5.4 Resources
4.2 Clutter or debris 5.4.1 Inadequate equipment
4.3 Esthetical / Visual impact 5.4.2 Inadequate funds / personnel
4.4 Flooding / Inundation of water 5.4.3 Inadequate instructions / orientation / training
4.5 Hazardous arrangement / layout 5.4.4 Inadequate training equipment
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Using the elements considered above, please provide a short explanation of why you believe the incident occurred (no more than 3 lines):
Root Cause (RC) Contributory Factor (CF)

Defined as a condition within a chain of events that influences the incident in one or more of the following ways - a) Likelihood, b) Severity or c) Time.
Defined as the original, or primary fault in a system that causes a chain of events that result in an environmental incident. By eliminating the
Removing a Contributory Factor will not prevent the incident but may reduce its Likelihood and/or Severity or increase the time it takes for the incident
Root Cause a chain of events will not start and the incident will not occur.
to occur.
List the root causes (RC) below. (RC#1 is the primary root cause, while RC#2 is the next most relevant root List the Contributory Factors (CF) below. (Contributory factors are ranked in order of descending relevance (#1 -
cause, etc.) most relevant, #2 - second most relevant, #3 - next most relevant))
RC#1 CF#1
RC#2 CF#2
RC#3 CF#3

Appendix G: Environmental Incident Notification Form

Environmental Incident Notification Report Form
Report No. Report by:
Date of Incident: Contractor Name:
Time of Incident: Type of Incident:
Where did the N

GPS Cor-
incident occur? ordinates
E
Brief Description of Incident
Describe Immediate Actions Taken
Long term Actions To Take
Current Status of Incident

Photographs of Environmental Incident
Fig: 1 Date/Tim Fig: 2 Date/Tim

e: e:
Location & Location &

coordinates: coordinates:
Description Description
Fig: 3 Date/Tim Fig: 4 Date/Tim

e: e:
Location & Location &

coordinates: coordinates:
Description Description

Appendix H: Environmental Incident Investigation Report Form

Environmental Incident Investigation Report Form
REPORT #:
PART 1 – TO BE COMPLETED BY CONTRACTOR
1. The Incident is related to which Project site?
Contractor Name:
Project Name:
Environment Manager Name:
Project Managers Name:
2. Who was involved in the incident investigation?
Investigation Team Leader’s Name:
3. When did the environmental incident occur?
Date of environmental incident: Specify date as dd.mm.yyyy
Time of environmental incident: Specify time as HH:MM hrs
4. NEOM Environment who was notified of the environmental incident?
Name and position of person notified:
Notified by telephone (Yes / No): If Yes, specify time of call (HH:MM):
Name and position of person who

notified NEOM Environment:
5. When was the Environmental Incident Notification Report submitted to NEOM Environment?
Date of notification: Specify date as dd.mm.yyyy
Time of notification: Specify time as HH:MM hrs
6. Where persons involved in the incident? (specify ‘NA’ if Not Applicable)
Name of primary person involved:
Primary person occupation:
Name of secondary person involved:
Secondary person occupation:
Name of Witness #1

Name of Witness #2
7. Was equipment involved in the incident? (specify ‘NA’ if Not Applicable)
Type of equipment:
Equipment ID / registration number:
8. Where did the incident occur?
Describe the location of the incident:
Provide GPS Co-ordinates of the

incident location N E
Provide a map of the incident location in the box below. Highlight on the map the position where the incident took place. Consider using Google Earth
or Google Maps
9. How can the incident be best classified? (Please tick the appropriate box(es))
Inadequate Waste Management

Fuel / Oil Spill on Land (EI1)
(EI2)
Excessive Environmental Noise

Chemical Spill on Land (EI3)
(EI4)
Fuel / Oil Spill on Water (EI5) Damage to cultural heritage (EI6)
Unplanned atmospheric emissions

Chemical Spill on Water (EI7)
(EI8)
Waste-water discharge to Land

Unplanned release of water (EI10)
(EI9)
Loss of / Damage to Fauna (EI11) Loss of / Damage to Flora (EI12)
Complaint (Please Specify) (EI13) :

10. Incident Photos
Include two photographs that are representative of the conditions associated with the environmental incident.
11. Describe the Environmental Incident
Please provide a detailed description of the incident including: the conditions which led to the incident occurring; weather conditions at the time,
equipment / persons involved; whether the incident resulted in an actual or potential impact on the environmental; quantity of materials involved;
immediate actions following the incident

12. Root Cause(s) Definition: A root cause is the deepest cause in a causal chain of events, that result in an Environmental incident.
Use the Root Cause Analysis Tool (RCAT) in Appendix A of this document to determine the root cause. Root Cause #1 shall be the primary root cause
and Root Cause #2 shall be the next most relevant root cause.
Root Cause #1
Root Cause #2
13. Contributory Factors Definition: A condition within a chain of events that influences the incident in one or more of the following ways – a) Likelihood, b) Severity or c) Time
Use the Root Cause Analysis Tool (RCAT) in Appendix A of this document to determine the contributory factors. Contributory factors 1 – 3 are ranked
in descending order of relevance.
Contributory Factor #1
14. What corrective actions are required to rectify the Root Causes and Contributory Factors?
Corrective Action(s) Responsible Person Target Date
15. What preventive actions are required to prevent reoccurrence of the conditions which led to the incident?
Preventive Action(s) Responsible Person Target Date

16. What documents are you attaching to this investigation report as supporting evidence? (Tick as appropriate)
Witness Statement Correspondence
Training Records Records relating to equipment
Additional Photos RCAT Analysis: (Mandatory)
Other Records: (Please specify)
17. Sign-off by Contractor
I confirm that the information contained in this investigation report is accurate and representative of the facts associated with the incident.
Signed (Project Manager) Date:
Signed (Environment Manager) Date:

Appendix I: Initial Investigation / Data Gathering Techniques

Initial Investigation / Data Gathering Techniques
Aim of Investigation – Find the Root Cause
Gather Information
Take Photographs / Measurements / Sketches
Collect details of People / Papers / Plant / Processes (4Ps)
People
Speak to supervisory personnel
Seek any witnesses
Ask 6 W – WHO - WHAT – WHERE – WHEN – HOW
Get observation on events – BEFORE – DURING – AFTER incident
Use sketches / diagrams to help the witness
Engagement an impartial translator if required
Paper
Ask for documentation to identify company / contractor involved – permits; forms;

correspondence
Take photos of truck trip tickets
Obtain / record details of MSDS’s
Obtain / record specifications of equipment
Plant
Record types and numbers of plant and equipment involved
Processes
Understand and record layout of process plant associated with the incident

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ENVIRONMENTAL PROCEDURES

INCIDENT IDENTIFICATION, INVESTIGATION

NEOM-NEV-PRC-704 Rev 01.00, November 2021

©NEOM [2021]. All rights reserved.

Revision code Description of changes Purpose of issue Date

Prepared by Reviewed by Approved by

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©NEOM [2021]. All rights reserved.

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An Environmental Incident is defined as an occurrence or set of circumstances, because of which

Appended to this procedure are the following related forms:

• NEOM Incident Witness Statement Form (NEOM-NEV-PRC-704_FRM01)

4 Definitions and Abbreviations

EIRCAT Environmental Incident Root Cause Analysis Tool

ESIA Environmental & Social Impact Assessment

NCR Non-Conformance Report

NEV NEOM Environment Department

PEC / PMC Project Environmental Consultants / Project Management Consultant

Table 4-2: Definitions

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©NEOM [2021]. All rights reserved.

Employer The Employer is a NEOM entity or a Project Management Consultant (PMC)

5 Roles and Responsibilities

Employer is responsible for:

NEV are responsible for:

6.1 Incident Management and Reporting Process – Class A, Level 3

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Check Corrective Actions

1. Step 1 – Recognise – as detailed in 6.1.1

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Response Guidelines – Chemical Spills

Response Guidelines – Leakage of Gaseous Substance

Response Guidelines – Release of Excessive Dust / Bulk Powders

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