Trobell Hse Plan

I i l
HEALTH SAFETY AND ENVIRONMENTAL

MANAGEMENT SYSTEM
TROBELL INTERNATIONAL NIGERIA LIMITED
Address: No 11 Nyemweli O.N. Nsirim Layout,

Tombia extension, G.R.A Phase II, Port Harcourt, Rivers State, Nigeria.
E-Mail tom.sede@trobell.com, lawal.garba@trobell.com

Tel: 08033047961, 08131011152
Submitted on
December 22nd, 2020

TROBELL INTERNATIONAL NIGERIA LTD
DOCUMENT TITLE: COMPANY HSE MANUAL
DOC NO: PHIS-CHSE-MLA-0001 REV: 0 DATE: 29-10-2019 STATUS: APPROVED
TABLE OF CONTENT
S/N Description Page No.
1. Table of content 1
2. Introduction 2
3. Policies 3
4. Organisation, Responsibilities, Resources, Standard and 20

Documentation
5. HSE Organizational Chart 21
6. HSE Communication 26
7. Risk Analysis and Management 29
8. HSE Training 30
9. Accident/Incident Investigation and Reporting 31
10. Work Permit System 32
11. Action in Case of Fire Alarm 34
12. Emergency and Evacuation Procedure 38
13. Safety Audit and Inspections 41
14. Environment 42
15. Material Handling 47
16. Transportation 53
17. Security 61
18. Good Housekeeping 62
19. HSE Performance Indicators 63
20 Closure 64
At TROBELL INTERNATIONAL NIGERIA LTD Safety is the way we do Business Page 1

INTRODUCTION
At TROBELL INTERNATIONAL NIGERIA LTD, we strongly believe in Quality

and implementation of world’s best practices and standards.
Our success and trust of our clients is based on our ethics, quality work,
business practices, project management systems, competent human resources
and timely completion of projects. TROBELL INTERNATIONAL NIGERIA LTD
is a professional engineering and oil & gas services firm with proven expertise
in structural, civil, electrical, mechanical, building and environmental
engineering. Our portfolio of services also encompasses town planning and real
estate as well as a range of engineering support services including project
management and contract administration.
We pride ourselves on our ‘smart’ approach to delivering projects.
In everything we do, we work to ensure our clients obtain the
optimal outcome possible
To achieve this objective TROBELL INTERNATIONAL NIGERIA LTD relies on

the managerial and technical capabilities as well as the continuous
development of its workforce, and on an increasingly lean and entrepreneurial
organization.
The objective of this HSE plan is to promote Health, Safety & Environment of
person working with TROBELL INTERNATIONAL NIGERIA LTD and prescribe
certain rules, procedures and safe practices in order to create a working
environment free of condition and factors that might contribute to an accident
or injury /Illness. The Specific HSE plan will provide guide line for safe execution
of project.
"HSE IS EVERYBODY’S BUSINESSS"

POLICIES

TROBELL INTERNATIONAL NIGERIA LTD COMPANY HSE POLICY
It is policy of TROBELL INTERNATIONAL NIGERIA LTD to carry out all its work
in a way that provides healthy and safe working practices and avoids risks of injury to
anyone as a result of the activity for which the company is responsible.
The overall responsibility for Health, Safety & Environment rests at the
highest level, however, all individual employees have important responsibility
towards HSE and must participate in carrying out policy. Appropriate training,
supervision and information are provided to encourage and enable to carry
out their duties safely.
Regular Inspection and monitoring of the activities is undertaken and

accidents or incidents are investigated promptly so that appropriate action
is taken to prevent from reoccurrence. Unsafe work practices by an individual can
often lead to accidents even in safe working environment.
It is therefore our goal to eliminate both unsafe working condition and unsafe work
practices.
It is the policy of our company to;

➢ Comply with all regulations governing Health, Safety & Environment at the job site.
➢ To take expedient actions to correct or isolate unsafe
conditions or work practices
➢ To promote Health, Safety & Environment awareness
➢ Hold each employee accountable for their individual responsibility
for Health, Safety & Environment
➢ Every reasonable effort will be made to assure that employees can
accomplish the safe completion of assigned tasks.
➢ No task is so important, nor so urgently, that we cannot take the time to do it safely.
THOMAS A. SEDE
Managing Director
Trobell International Nigeria Limited

COMMUNITY AFFAIRS POLICY

MISSION STATEMENT
As a leading company in oilfield construction activities, spanning across various
communities, we are committed to the yearnings and development of our host
communities. This we have demonstrated by integrating our community affairs to our
HSE operations.
It is our policy that: our host communities shall have the knowledge of our mission
before commencement of work and a mutually beneficial relationship shall be
maintained during and after our operations.
FOCUS
▪ To minimize to the barest minimum, the impact of our operation on our working
environment.
▪ To reduce to the barest minimum project related CA conflicts/disturbances.
▪ To enlighten our host communities on the benefits derivable from community related
project.
▪ To enhance our host communities’ awareness about HSE issues.
STRATEGY
▪ Liaising with genuine representative of our host communities before commencement

of work.
▪ Establishing Community Affairs Committees for projects with host communities.
▪ Having bi-monthly Community/Affair meeting where all CA issues are discussed and
resolved in favour of both parties.
▪ Having a resident P.R.O on our work location as a liaison officer between the
company and our host communities.
▪ Establishing the “CA Award for peaceful Co-existence” for host communities without
disturbances during our operations.
VISION
“To carry out our work safely without disturbances”
THOMAS A. SEDE
Managing Director

NO SMOKING POLICY
TROBELL INTERNATIONAL NIGERIA LTD prohibit smoking on site. And

where Smoking may be carried out, it has to be done at a designated place.
Hazardous areas should be marked with a” No Smoking” Sign Conspicuously

Placed.
THOMAS A. SEDE
Managing Director

DRUG AND ALCOHOL POLICY
TROBELL INTERNATIONAL NIGERIA LTD in compliance with statutory

regulations of Oil Minerals Safety Regulations Act (1997) sections 56 sub-
section a (ii) and b, do hereby state that:
❖ No worker shall consume alcoholic liquor and hard drug on duty.

❖ No worker shall be admitted on duty while under the influence of alcohol
or hard drug.
❖ No worker on herbal alcoholic drug will be allowed to resume duty.
❖ No excuse will be accepted from any worker who violates this policy.
THOMAS A. SEDE
Managing Director

OCCUPATIONAL HEALTH POLICY
All staff of TROBELL INTERNATIONAL NIGERIA LTD shall be medically fit

and shall remain so, while their employment lasts.
We shall maintain an insurance against any liability that may result in the event
of any personnel suffering occupational diseases or any impairment to health
resulting from our operation.
The company’s retainer ship clinic shall handle all routine medical and medical
emergencies.
Only certified and competent site nurse can man the first aid box and administer
first aid any operational areas. Records of medications administrated or injuries
MUST be kept at site and base office.
Compliance with this policy is a MUST.
THOMAS A. SEDE
Managing Director

REWARD/ SANCTION POLICY

In line with the principle of enhanced HSE management, the HSE incentives
policy shall be used as a tool of motivation for continuous enhancement of the
HSE performance of the workers. On the other hand sanctions shall be placed
on violators of HSE rules as this would go a long way to keep employees
focused on the importance of the HSE rules.
CATEGORIZATION:
There shall be incentives in the following categories
• End of year HSE award.

• Quarterly HSE bonus.
• Departmental HSE bonus.
• MD’s award for the best HSE conscious worker of the year.
• Project Manager’s award for the best HSE conscious driver/operator of the
year.
TYPE:
Incentives shall be in award (PLAQUES, CERTIFICATES, GIFTS ETC) and or

monetary gift to be determined by the management.
Sanctions shall include suspension, pay cut, or dismissal depending on the

magnitude and severity of the violation.
SELECTION
The central safety committee shall make selection process after the pre-
selection exercise by the sponsor department/unit.
This policy shall be subject to review in line with the dictates of time
THOMAS A. SEDE
Managing Director

JOURNEY MANAGEMENT POLICY

Transportation is a very important part of any project. Materials and personnel
are moved from one location to the other and the risks involved in these
movements are high. Hence, an effective Journey Management plan is
required.
TROBELL INTERNATIONAL NIGERIA LTD appreciate the fact that most

accidents resulting from different mode of transportation are usually serious and
could be fatal. Hence she has put in place an effective Journey Management
Policy.
All Journeys should be made during the day with the vehicle in good condition,
all accessories and spare parts in place with enough water, oil and gas.
All Journeys will be carried out with the driver being pre-informed of the trip, the
estimated distance and the journey time. Driver must stay within speed limits
and choose the service route to be taken.
As a matter of fact, the supervisor must discuss the journey with the driver
before departure. The driver must avoid over indulgence in eating/drinking and
be physically and mentally fit. If the driver is discovered to have taken alcohol,
or any intoxicating drug, he will automatically be disqualified from making the
trip.
No driver is expected to use his phone during the course of the journey.
THOMAS A. SEDE
Managing Director

SEAT BELT POLICY
All company vehicles are fitted with seat belt. Drivers and passengers shall
always use seat belt when traveling in company vehicles at all times.
This is one of the ways the company ensures proper implementation of its
journey management system.
It is the duty of drivers to ensure that personnel carried in the company vehicles
complies with this policy.
THOMAS A. SEDE
Managing Director

ACCESS CONTROL POLICY
Access to Restricted Area is on permission basis. All visitors, authorized

personnel or representatives of SPDC; are expected to sign in and out in the
corresponding register provided.
Visitors to site shall be briefed on behavior on site, clothed with appropriate

PPE and shall be escorted by the safety officer, as conditions for admittance.
Material issuances vouchers and ID Cards will be used for identification.
THOMAS A. SEDE
Managing Director

SECURITY POLICY
An essential part of the overall company’s management is the management of

the lives of the company’s personnel, clients and third party’s personnel and
client or third party’s equipment or facility.
To ensure effectiveness in this management, the company as a matter of policy,

takes responsibilities of security of all personnel, client representatives and third
party in all our work sites and premises.
In furtherance of this, the company shall employ trained (unarmed) security

officers. Also the services of licensed and professional security organizations
shall be secured on retainership basis to boost the overall company security
system.
However local security men from community, where we operate will also be
engaged.
Armed security agencies, such as Mobile Police, Air Force, Army, or Navy shall
not be used in any of our work sites. They shall however be invited in riot
situation, which are out of control of the Nigerian Policy force.
THOMAS A. SEDE
Managing Director

SUB-CONTRACTING POLICY
When sub-contracting, TROBELL INTERNATIONAL NIGERIA LTD shall

consider the full satisfaction of its client by adopting the following policy.
Sub-contractors will be chosen from the client list if any otherwise, we will look
for the experienced and reputable sub-contractors.
In order to encourage local growing industries, the Company gives priority to

Nigerian sun-contractors so far they can guaranty the required client standards.
Selecting a good sub-contractor will not relief the Company from its obligation,
in that we shell supervise the entire execution of the job.
It is our supervisor’s responsibilities to ensure the sub-contractor adherence to

required quality standards, work programme and HSE rules.
THOMAS A. SEDE
Managing Director

WASTE MANAGEMENT POLICY
Waste constitutes environmental nuisance if not properly collected, handled

and disposed. Waste shall therefore be collected, handled and disposed of in
an environmentally friendly manner as not to cause injury or damage to plants,
animals and the environment (the soil water and air).
Industrial wastes and site wastes shall be collected separately in bins market
accordingly. In remote locations, biodegradable waste shall be disposed off in
pits and backfilled. Non- degradable waste (but combustible ones) shall be
incinerated with proper precautions taken not to cause air pollution. Non-
degradable and incombustible waste shall be collected, crated and conveyed
for disposal at Government approval disposal sites.
In all however, proper precaution shall be taken to avoid discharge of pollutants

in the air, land or water. Dumping of wastes into creeks, rivers and other
watercourses is not allowed.
THOMAS A. SEDE
Managing Director

PERSONAL PROTECTIVE EQUIPMENT (PPE) POLICY
It is the policy of TROBELL INTERNATIONAL NIGERIA LTD to provide

relevant and high quality personal protective Equipment: coverall safety-
shoes/Rain-boots, Hardhats, Hand-gloves etc.
Continually, the management shall enforce the effective use and maintenance
of available personal protective equipment, which entails regular conditions
audits and replacement of defective ones.
Site safety officers and supervisors shall continue to monitor compliance with
this policy.
THOMAS A. SEDE
Managing Director

HSE AUDIT/ INSPECTION POLICY
Due to the sophistication of all our equipment, work tools, nature of operations
coupled with man’s imperfection, unsafe acts and conditions are inevitable.
These Act and Conditions if not observed, checked and controlled or completely
eliminated can result in accidents. TROBELL INTERNATIONAL NIGERIA LTD
recognize this fact and therefore has it as a policy to carry out frequent HSE
Audit at all its work sites and operations.
All front line supervisors are mandated to carry out site HSE audits, make
reports and forward same to the HSE Committee who reviews the report and
follow up actions to ensure corrective measures are implemented in good time.
The HSE management committee ensures that training on HSE Audit,
Management and Technical Safety Audits are carried out. Reports are compiled
recommendations made and followed-up ensuring compliance.
It is the responsibility of all the work force to carry out HSE Audit both in and
outside their department’s area of operation and report to the site HSE Officer
or their immediate supervisors.
Repeated violation of Audit recommendations will be discouraged and positive

attitudes toward safety rewarded.
This policy shall apply to all forces and all is required to read, understand and
abide by this policy.
Reports on audits shall be published on the notices board.
THOMAS A. SEDE
Managing Director

VISIBLE MANAGEMENT COMMITMENT TO HSE

ESTERDON GLOBAL RESOUCES LTD management recognizes the fact that
there can be no meaningful progress without strong management support. We
therefore regard HSE as part of line managers’ daily responsibilities alongside
schedule financing, productivity and morale.
The Managing Director and the General Manager visit work areas regularly to
monitor HSE, wearing the required P.P.E., and discussing HSE with employees
and carrying out audits.
The company management holds her HSE meeting quarterly and HSE is also
an important agenda on all business meeting. Serious disciplinary action is
usually taken for serious and repeated breaches of HSE rules.
Line supervisors are empowered to stop work if they feel that the work is not
safe. Adequate funds are always allocated for the creation of safe working
conditions.
Good HSE performance is always rewarded and the HSE department is fully
staffed with not only experienced personnel but also competent ones.
It is the management’s responsibility to ensure that all employees are properly
equipped and trained, and to motivate them to work safely.
The right attitude is the key to progress.
THOMAS A. SEDE
Managing Director

ENVIRONMENTAL POLICY
Our policy in TROBELL INTERNATIONAL NIGERIA LTD. concerning her

immediate environment is to impact on it AS LOW AS REASONABLY
PRACTICABLE (ALARP), so as to achieve a sustainable development in its
entire ramification.
Implications of our policy are:
 TROBELL INTERNATIONAL NIGERIA LTD. will plan all her activities in

such a way that her operations will not jeopardize natural resources.
 TROBELL INTERNATIONAL NIGERIA LTD. will care, be diligent, prepare

environmental plan (EMP), integrate EMP into project life cycle and will adopt
good housekeeping before, during and after our project.
 TROBELL INTERNATIONAL NIGERIA LTD. will operate in all project so

as to reduce:
 Occupational/General health problems.

 Contamination of surface/underground water.
 Flooding and erosion.
 Destruction of aquatic life.
 Filtration of water bodies.
THOMAS A. SEDE
Managing Director

3.0 ORGANISATION, RESPONSIBILITIES, RESOURCES, STANDARDS

AND DOCUMENTATION
3.1 HSE ORGANISATION
3.2 Key Personnel
The following personnel are responsible for the implementation of HSE

objectives.
1. MR. THOMAS A. SEDE Managing Director
2. MR. MUHAMMADE DANJUMA General Manager
3. FUBARA D. FRANCIS HSE Co-ordinator
4. Engr. DORNU NGBAA Project Manager
5. VERABA GOSPLE D QA/QC / SUPERVISOR
6. DELE GODWIN B SAFETY OFFICER
7. GLORIA YOUNG SITE NURSE

HSE ORGANISATIONAL CHART
MANAGING DIRECTOR/CEO
MR THOMAS A. SEDE
General Manager HSE Manager

DANJUMA M. M. Fubara D. Francis
QA/QC Officer Project Manager HSE Coordinator

Vereba Gosple D Engr. Dornu Ngbaa Dele Godwin
HSE Adviser Nurse / First Aider

Kynsley Offong Gloria Young

JOB DESCRIPTIONS OF KEY PERSONNEL
DUTIES AND RESPONSIBILITIES
MANAGING DIRECTOR
THOMAS A. SEDE
➢ Directs and control all the activities of TROBELL INTERNATIONAL NIGERIA

LTD in accordance with the policies, strategies and objectives laid down by the
Board of Directors;
➢ Supervises the company’s organization and is responsible for appointing and
defining the tasks for the different functions;
➢ Implements the general policy laid down by the company in respect of Quality;
➢ With the back-up of the Operations Manager, Project Managers and QA/QC
Manager, supervises the correct implementation of the company’s Quality
Management System.
➢ Analyse Quality costs in order to assess the adequacy and efficiency of the
company’s Quality Management System and define the objectives to be met for
continuous improvement.
GENERAL MANAGER
DANJUMA M. M.
➢ Directs and control all the activities of TROBELL INTERNATIONAL NIGERIA

LTD.in accordance with the policies, strategies and objectives laid down by the
Board of Directors;
➢ Supervises the company’s organisation and is responsible for appointing and
defining the tasks for the different functions;
➢ Implements the general policy laid down by the company in respect of Quality;
➢ With the back-up of the Operations Manager, Project Managers and QA/QC
Manager, supervises the correct implementation of the company’s Quality
Management System.
➢ Analyze Quality costs in order to assess the adequacy and efficiency of the
company’s Quality Management System and defines the objectives to be met for
continuous improvement.
In addition to these responsibilities he shall:
➢ Oversee all HSE issues in the absence of the Managing Director.
➢ Head investigation panel for middle level accident.
➢ Direct line managers on the implementation of HSE policy on site.
➢ Lead audit team for top management HSE audit.
➢ Visits sites regularly to ensure site HSE compliance.
➢ Administers consequence management for HSE violations.
➢ Initiates review panel for HSE documentation.
➢ Sets up programmes for HSE incentives and training.

PROJECT MANAGER
Engr. DORNU NGBAA
➢ Defines competencies required for HSE management within TROBELL

INTERNATIONAL NIGERIA LTD organization.
➢ Assures and provides adequate resources and time to manage the project.
➢ Has an understanding of SPDC’s guidelines for the monitoring of HSE in
contracts.
➢ He has overall responsibility of all aspects of the project;
➢ Represents the company and maintains appropriate level of relationships with
the Client representatives;
➢ Supervision and administration of all subcontracts;
➢ Define the objectives, identify the constraints and plan Project activities;
➢ Define the Project’s organization structures;
➢ Supervise the application of the control system in order to ensure achievement
of time, cost and quality objectives;
➢ Implement the Quality Assurance program;
➢ Supervision of purchasing, expediting, inspection and testing activities;
➢ Ensures the periodic and final reporting of all activities;
➢ The Project Manager shall be the HSE focal point in this Project;
HSE CO-ORDINATOR
FUBARA D. FRANCIS
The HSE coordinator shall be responsible for checking that the work is carried out in
accordance with governing HSE regulations and in-house standards. He must be
qualified according to SPDC requirements, as a professional HSE adviser or an
adviser seconded from line management. Must have attended appropriate training
courses and received basic qualification relevant to TROBELL INTERNATIONAL
NIGERIA LTD.’s work, e.g. swimming, driving and first aid.
His duties consist of, but not limited to:
➢ Preparation of HSE work plans and procedures;

➢ Visit the site regularly to monitor and advise on HSE duties laid down in the HSE
Plan and Site Specific Security Plan.
➢ Advice the Project Manager on matters related to Health, Safety and
Environmental issues.
➢ Be reasonably familiar with SPDC’s HSE Policies, documents and emergency
procedures, particularly those relating to the work at site.
➢ To make sure that all HSE precautionary measures are in place and also to
advise when necessary.
➢ Liaison with HSE Personnel of the Client in order to co-ordinate activities
pertinent to HSE of personnel and equipment.
➢ Collection and updating of statistical data relating to accident and incidents on
site.

QAQC OFFICER
VEREBA GOSPLE D
The QA/QC Officer reports to the head of QA/QC function but shall maintain close
liaison with the Project Manager and SHELL Inspection personnel. His duties include
but not limited to the following:
➢ Prepare the Project QC/QC Plan in connection with the Project Manager and the
QA Manager at head office;
➢ To make sure that all HSE precautionary measures are in place and also to
advise when necessary.
➢ Verify that the quality related activities are in accordance with applicable codes,
specifications and regulations;
➢ Ensure recording, updating and distribution of documents and information, i.e.
procedures, drawings, plans, reports and certificates;
➢ Identify any deficiency, promote corrective actions and verify their
implementation;
➢ Verification of the Quality Assurance implementation by a system of scheduled
Quality Audits;
➢ Ensure surveillance at Client’s works;
➢ Evaluation of the Suppliers and Vendors quality systems;
➢ Ensure that measures are taken in order to identify and prevent acceptance of
defective materials;
➢ Ensure collection of documentation and certificates related to materials
purchased by TROBELL INTERNATIONAL NIGERIA LTD and its Vendors.
➢ Prepare QC plans for production phases and review quality plans issued by
Clients and vendors;
➢ Ensure the inspection and testing in compliance with established QC plans;
➢ Ensure the compliance of final documentation to be issued to the Client with
Project requirements;
SITE HSE OFFICER

DELE GODWIN B
➢ Make requisition for all safety personnel equipment and lifesaving appliances.
➢ Acts as secretary to the HSE management committee.
➢ Liaise with projects and site Engineers to establish safety training needs.
➢ Liaise with clients safety functions in matters of safety requirements, especially
training
➢ Organize formal safety training for all employees as may be necessary.
➢ Develop safety procedure guides for specific activities in liaison with line
supervisor
➢ Serve as secretary of management safety committee and collate all line
committee activities
➢ Carry out scheduled and unscheduled safety inspection of all sites.
➢ Join in all accident investigations and give wide circulation of findings.
➢ Monitor employee compliance with statutory and clients' safety rules and
regulations.

➢ Develop emergency procedure guides in consonance with clients' procedure.

➢ Advice management on safety incentive schemes relevance to the overall
safety programmes.
➢ Keep record/statistics of safety performance in the company.
➢ Review performance with company management, line supervisors and entire
staff at the end of the year.
➢ Periodically 'feel' the company safety pulse and brief management accordingly.
➢ Liaise with governmental bodies in regulatory matters as necessary.
➢ Periodically holds meetings with representatives of host communities as advice
the management on necessary recommendations.
SITE NURSE
GLORIA YOUNG
The Site Nurse / First Aider shall among other HSE activities do the followings:
➢ Administer First Aid as the need arises.

➢ Report to the Safety Officer all health hazards observed at site.
➢ Monitor health of all workers at site.
➢ In case of emergency, shall be alert and attend to all injuries and refer to the
retainership clinic in conjunction with the HSE officer.
➢ Maintain the sick bay.
➢ Initiate MEDEVAC procedures if need be.
➢ Replenish contents of First Aid Box as at when due.
WORKMEN
• Attend all courses and meeting as schedule
• Maintain good house keeping
• Adhere to good working procedure.
• Wear personal protective equipment (PPE) appropriately.
• Keep tools and equipment in designated areas.
• Report any observed incident to site supervisor and safety officer

HSE COMMUNICATION
Effective communication is essential for the development of a safety culture within the
organization, this will be implemented through:
➢ Dissemination of TROBELL INTERNATIONAL NIGERIA LTD HSE Policy to all
personnel, and instruction on its use.
➢ Distribution of HSE Safety Notices, periodic health and safety briefing notes etc.,
to employee. Promoting open communications between management and
workforce on safety matters. Ensuring health and safety issues are included on
the agenda at management meetings.
➢ Promoting hygiene, health and safety awareness by disseminating information
such as accident and injury statistics, and articles, which have a direct impact
upon the health, hygiene and safety of the workforce
➢ Weekly safety meetings.
➢ On the job instructions (toolbox meeting).
➢ On the job “Ten Minutes Specking” (One-on-One).
➢ Effective signs indicating hazards and escape routes.
The HSE MS shall have visible lines of communication for:-
➢ Effective flow of consultation

➢ Information
➢ Correspondence
➢ Reports.
Internal lines of communication shall provide for: -
➢ Site co-ordination
➢ Co-ordination between Corporate and Line Management
External lines of communication shall provide for:
➢ CLIENT and customers

➢ Sub-contractors and services
➢ Local authorities and communities.

All HSE concerns shall be seriously considered and reported through the lines of
communication in an open manner.
SITE INDUCTION
The Site Induction training will be performed on all new arrivals (for person who have
not been on the site before) within the first day on site. The subjects to be covered by
the Site Safety Supervisor will, in the main, consist of:
Safety Policy and Safety Management Structure
Safety / Site Organization
Environmental Education
Government Regulation / Oil and Gas Industry Requirements
Accident Prevention
Fire prevention / Protection / Fighting
SITE FACILITIES
Typical mountain risks (General and work area climatology and altitude effects)
Geographical orientation and instruments
Survival techniques, Emergency and alert evacuation plan.
The extent to which the site induction training will take place will depend on the nature
of the work and hazards inherent in that work.
In addition, more intensive induction training will be given to Supervisors, Foremen and
senior members of site staff.
After issue of basic safety gear to personnel, the Site Safety Supervisor will take all new
arrivals on a tour of the Site. During this tour he will; Show escape routes and muster
points

Show location of safety equipment such as fire extinguishers, fire hoses, breathing
apparatus, first aid kits etc
Indicate specific hazards and precautions, including any restricted / hazardous areas
and who may go in there.
Give a general guided tour of all the main areas of the site.
On completion of the induction talk and tour of the site, the Site Safety Supervisor will
ensure that new arrivals have received a copy of the safety handbook.
SUPERVISORY MEETINGS
At least once a moth, regularly scheduled meeting is to be conducted by the Safety

Supervisor and attended by all supervisors to the foremen level.
Its agenda shall include discussion of the previous accidents, any unsafe work, material
or equipment reported by the inspectors. It shall include also the planning for the next
period for all activities and their safety requirements.
Those meetings shall study also the needs for the safety materials information bulletins,
training and the tool box meetings.
Reports of the supervisory meetings shall be provided to the Project Management and
Safety Department and Operations Director.
TOOL BOX MEETINGS
All Supervisors and Safety Inspectors are to lead the weekly individual meetings for
working crews. This ensures that every worker is quite conscious of his week’s duties
and their hazards answer any questions, initiate discussions. Inspect the safety
conditions of all mechanical equipment, materials stored and proposed work manner.
They shall discuss the accidents and deficiencies, if any that occurred in the previous
week.

TEN MINUTE SPEECH (ONE-ON-ONE)
Safety Inspector, during his daily job site inspections shall held individual ten Minute
Speech to personnel involved in the fumigation and pest control who are caught in
violating of safety rules and regulations or in unsafe acts or conditions.
SAFETY SUGGESTION BOX
TROBELL INTERNATIONAL NIGERIA LTD encourages the conducting of external

HSE promotions whereby the Company can demonstrate its commitment to HSE
matters in all its activities. Such promotion is a Suggestion Box, which enables the
Company to share its knowledge and expertise to the benefit of the employees.
SAFETY HAND-BOOKS
During the initial induction course, a “Safety Handbook for Civil Engineering and
Construction activities” shall be distributed to all new employees.
RISK ANALYSIS AND MANAGEMENT
All potential hazards related to the Settling Tanks Revamp at MPN Facilities operations
to be performed by TROBELL INTERNATIONAL NIGERIA LTD shall be systematically
identified, the risks assessed and appropriate actions taken and implemented by:
Developing and maintaining hazard identification and risk assessment procedures and
criteria (Risk Analysis).
Identifying hazards and risks and eliminating / controlling these to a reasonably,

practicable, in the following order of preference:
➢ Eliminating or minimizing of hazards by assessment

➢ Providing safe working procedures along with the necessary safety training to
minimize exposure to remaining hazards.
➢ Providing personal protective equipment
➢ Systematically reviewing all operations to identify hazards and risks.

➢ Documenting the process of hazard identification, assessment of risk, selection

of controls and records of implementation.
A qualification risk analysis of the project operations will be carried out prior to contract
activities starting. In a systematic approach, it shall be implemented and reviewed by
experienced competent personnel, using their Professional and operational knowledge
and best judgment to identify and rank the risk associated with each activity.
HSE TRAINING
Good safety awareness training is important to all employees, especially for those
learning a new trade. It is also essential to keep Supervisors and skilled Operators up-
to-date current safety techniques and practices.
Therefore in addition to the induction training, the Site Safety Supervisor shall ascertain
any extra safety training that will be required for employees, and shall either perform
the training himself, assign other site personnel to perform the training, or in certain
circumstance, arrange for personnel to attend external training courses.
In addition to standard skill training courses for skilled operators, the type of safety
training which may be required could be; first aid, fire teams and firefighting, use of
breathing apparatus, Supervisors training etc.
The following guidelines as a minimum shall be adhered to:
An activity Training Matrix shall be instigated identifying specific disciplines and training
requirements and shall be approved by the Operations Manager.
A formal activity specific Safety Induction Course shall be given to all employees on the
activities;
All employee safety training shall be recorded and kept in a central point.

ACCIDENT / INCIDENT INVESTIGATION AND REPORTING
DEFINITIONS
An incident is an unplanned or unwanted event, which could have resulted in actual

injury or illness, property damage, environmental damage, loss of man-hour or adverse
public relationship impact.
A hazard is an uncorrected unsafe act or condition, which has the potential to cause an
accident and which imposed a level of risk that is not as reasonably practicable.
All accidents and hazards must be reported. This is to enable remedial actions to be
taken to prevent a recurrence, for personal injury/ illness it ensures early treatment and
is also the mechanism for activating a workers compensation claim.
Hazards may be reported on either a TROBELL INTERNATIONAL NIGERIA LTD
Hazard / Incident Report form or the Hazard Report included in the Safety Notebooks.
The latter should be attached to a Hazard / Incident reports form by the supervisor who
then processes it in same way as previously described.
Accident / Incident Reporting for all accidents, personnel injuries and casualty, damage
and fires shall be implemented as follows:
In the event of fatal accidents or serious injuries, satisfactory investigation will be carried
out by the Safety Supervisor, Safety Inspector and Operations Supervisor and Manager
and will be reported verbally followed by a written report to TROBELL INTERNATIONAL
NIGERIA LTD Management at Head Office.
All event involving fire and/ or damage to TROBELL INTERNATIONAL NIGERIA LTD
or Oil and Gas Industry properties, plant and equipment will be reported in writing to
TROBELL INTERNATIONAL NIGERIA LTD.
Where a Near Miss is recorded it shall be reported and where necessary investigated
and appropriate corrective actions taken to prevent re-occurrence.
Monthly safety reports shall be submitted to Oil and Gas Industry safety department and
contract owner.

Accident shall be reported using TROBELL INTERNATIONAL NIGERIA LTD

ACCIDENT / INCIDENT report form or Oil and Gas Industry report form if specifically
required.
WORK PERMIT SYSTEM
Permit to Work procedures are intended to maintain a high level of plant safety by
reducing the chance of misunderstandings when non-routine activities are to be carried
out at the same amount in time.
In the Operational Area non-routine will be taken to mean anything other than the
normal operation of the plant and therefore even planned maintenance will be
considered “non-routine activity”.
OBJECTIVES OF THE PERMIT TO WORK SYSTEM
➢ To ensure correct isolations from process and power.

➢ To ensure the proper authorization of non-routine work.
➢ To make clear to the person carrying out the work and others working with
him, the potential risks involved and the precautions necessary to
minimize those risks.
➢ To ensure that the responsible for the work area is aware of all work being
carried out in that area.
➢ To provide a record to show a safe system of work has been employed
and that the precautions necessary have been considered and
implemented.
➢ Coordination of different activities to prevent conflicting activities.
PERMIT AVAILABILITY
The original of the Work Permit and all other certificates will be retained on the job.
The copy of the Work Permit and all other certificates will be retained in the Permit to
Work Administration system.

FUNCTION OF WORK PERMIT
A work permit authorizes specific works to be conducted in a restricted area. This serves
a record that steps have been taken to ensure safe working conditions in the area.
In this proposed revamp project, TROBELL INTERNATIONAL NIGERIA LTD shall
strictly follow Oil and Gas Industry Work Permit System. Application for Work Permit
must be made 24 hours before the commencement of the work activity. Any activity will
not start until all conditions on work permit are completely met.
GENERAL REQUIREMENTS
Before the commencement of any construction activity in a restricted area work permit
is necessary.
The work at site must be performed according to the instructions and precautions on
the work permit.
The authorized Business owner (Representative) has the responsibility to stop the work
and advise the Operation Supervisor any time safety on the job does not meet the
condition of the work permit.
The Company’s copy of the work permit shall remain on the job site at all time for the
duration of the activity in the work permit.
Where an incident or emergency occurs the Permit to Work will be withdrawn
immediately pending confirmation to restart work.
Administration of work permit procedures shall be in compliance with Oil and Gas
Industry Requirements.
LOCK-OUT / TAG-OUT SYSTEM

Whenever our employees work on or near equipment and could be injured as a result
of energy in the system, the equipment shall be isolated from its energy sources.

In the event of Gas systems, precautions will be taken by rolling blinds before work on
the system will take place.
The following additional precautions will be taken:
Oil and Gas Industry’s Operations shall identify and isolate all required lines and
equipment before Contractor employees will accept a line to work on. Contractor
supervisors may assist operations as requested.
Locks and hold tags will be provided to employees to put on isolation panels after
operations has put their locks on. Work Permit Receiver Person, must also put his own
lock to insure safety.
Lockout keys will be kept by the Work Permit Receiver Person for his own lock. The
transfer of keys will be done in the presence of the employees Supervisor.
WORK PERMIT DURATION

MPN Loss Prevention personnel attached to the job shall specify the period of time for
which a
Work Permit is valid on the Permit.
ACTION IN CASE OF FIRE ALARM
When the Fire Alarm is sounded, all work must stop. All personnel are to proceed to
the nearest muster point on foot. Vehicles/cranes etc must be left switched off with the
ignition keys in them. When the All Clear is sounded the permit holder must seek advice
from the Area.
Operator if a false alarm, then verbal instructions from the Area Operator is sufficient to
recommence work. However, if it was a real fire alarm, then conditions at the work site
may have changed and the safety officer must revalidate the work permit before work
can start again.
WORK COMPLETION
When the work specified in the Work Permit is complete, the Permit Holder must clear
up the work site so that both the work and the site are in a safe and tidy condition. He

then signs the hand-back section of the Work Permit for the work and returns the
documentation to the point of issue.
RULES FOR ANY WORK THAT INVOLVE ENTRY INTO A

CONFINED SPACE
A confined space is any partially enclosed space where there is some risk of: reduced
oxygen, accumulation of toxic, flammable or explosive material or where means of
entry/exist are limited.
This includes not only complete body entry but also when only head is inserted into the
confined space as follows:
➢ Manholes
➢ Hatches
➢ Pipe ends
Following are some examples of confined spaces:
➢ Vessels Tanks
➢ Drains Sumps
➢ Excavations Pits
➢ Trenches Piping
➢ Culverts
Hot work is any non-routine activity, on or near equipment containing flammable

substances, which involves a source of ignition, e.g. work on fuel tanks. Hot work also
incorporates the non-routine use of ionizing radiation or radioactive sources.
At no time may work be carried out which is not described on the Work Permit.
ISOLATION AND WARNING TAGS
Out of Service Tags

➢ Are designed to keep faulty, unsafe or unserviceable equipment out of use, or to

identify valves or switches, which should not be operated for process or
mechanical reasons.
➢ An “Out of Service Tag’ must be placed on every point of isolation of the
equipment concerned.
➢ An “Out of Service Tag’ must never attach to equipment to protect people whilst
they are working on that equipment. A danger Notice must be used to protect
personnel working on equipment.
DANGER NOTICE
Are designed to protect personnel working on equipment. The person whose name
appears on the notice can only remove a Danger Notice.
PERMIT TYPES AND APPLICATIONS.
Cold Work Permit

Any non-routine work that does not involve:
➢ A source of ignition
➢ Confined space entry
➢ Opening systems, which are expected to contain Hydrocarbons.
➢ Opening systems, which are expected to contain Hydrocarbons.
➢ Any non-routine works in a pressurized building with air intake protected
by Fire & Gas system.
As above but including the use of:
➢ Non-Intrinsically safe meters

➢ Heat shrink guns
➢ Power tools.
NOTE: No naked flames, No Coating, No grinding.
HOT WORK PERMIT
Any non-routine work in the Operational Area that involves a source of ignition
as follows:

➢ Vehicles Diesel Powered tools

➢ Petrol powered tools Coating
➢ Burning Grinding
➢ Grit Blasting Other Blasting
➢ Concrete Chipping Concrete Drilling
➢ Metal Chipping Power Drilling
➢ Use of flash cameras use of instruments that require batteries
➢ Use of cameras with batteries use of Hilti/Ramset guns (Powder tools)
➢ Use of explosive items Use of electrical equipment, which is not approved
for the designated zone Use of ionizing radiation possession use of
radioactive sources Hot work shall be applied for on a special hot work
form
Confined Space / Gas Work Permit
➢ Any non-routine work on the Operations area that involves entry into a
confined space. A confined space is any partially enclosed space where
there is some risk of:
➢ Reduced oxygen.
➢ Accumulation of toxic, flammable or explosive material
➢ Where means of entry /exit are limited.
➢ This includes not only complete body entry but also when only the head
is inserted into the confined space as follows:
➢ Manholes
➢ Pipe Ends
➢ Hatches
Following are some examples of confined spaces:
➢ Columns Ducts
➢ Drains Sumps
➢ Exchanges Tanks
➢ Furnaces Vessels
➢ Excavations Pits

EMERGENCY / EVACUATION PROCEDURE
It is the responsibility of each member of project management and supervision to

familiarize himself with the Emergency Procedures, which apply to the plants in which
he has employee working.
The HSE Supervisor and the Nurse, after investigation of the job site
ACTION TO BE TAKEN
When an emergency condition exists or on hearing the ‘Stop Work Alarm” every
supervisor shall ensure the following:
All work is stopped at once
All equipment is shut down
All men are evacuated to a pre-determined assembly point
A roll call is taken and every man is accounted for
No one is permitted to return until notification has been received from the MOBIL’s alarm
or Plant supervisor of his representative that it is safe to do so.
Emergency Preparedness
The idea of emergency preparedness is among other things to:
- Save life
- Assist the injured
- Reduce damage to company or client’s property or resources and the
environment.
Drill
Drill such, as fire, medical evacuation, security and general emergency shall be held
from time to time in order to prepare workers for real life situations. Participation by all
personnel on the
Project shall remain mandatory, and report of the drill documented. Drills shall be
conducted forth nightly.

FIRST AID
The main objective of first aid is to save life, prevent further injury and aid for recovery.
First aid being the first help or assistance given at once to the injured person or to those
taken suddenly ill before taking him/her to the hospital, the first aider must be observant,
resourceful, sympathetic, gentle and cheerful.
He of course has to do the first thing quickly, quietly, methodically without panic. Give
artificial respiration if breathing has stopped every second counts.
Stop bleeding if any. Guard against or treat for shock by moving the casualty as little
as possible and handling him gently.
Do not attempt too much, do the minimum that is essential to save life and prevent the
condition from worsening.
Reassure the casualty and of those around, so as to help lessen anxiety.
Do not allow people to gather round, as fresh air is essential.
Do not remove clothes unnecessarily.
Arrange for the removal of the casualty to the company retained hospital as soon as
possible.
Above all, first aid lectures shall be organized for staff once every month. These
lectures will be conducted by in-house or by external trainers, as management deemed
necessary. Staff shall
attend these lectures in nominated batches.
Attendance registers shall be kept. The safety officers and First-Aid personnel shall
organise, schedule and execute the lectures with management approval.
Medical Care
All TROBELL INTERNATIONAL NIGERIA LTD beyond first-aid shall be referred to the
company’s retained clinic for adequate medical attention. Such TROBELL
INTERNATIONAL NIGERIA LTD shall be properly documented and followed by the
personnel department as well as safety.

MEDICAL EVACUATION
All medical evacuations from work site shall be conveyed in the company’s
vehicles/speed boat for that purpose. However, should there be TROBELL
INTERNATIONAL NIGERIA LTD occurring within client’s facilities, their articulated
medical procedure will take precedence.
MUSTERING
All personnel who enter the job site must make themselves familiar with the muster point
nearest to their work place as well as an alternative muster point should conditions
prevent access to the closed one. All occupants of buildings must know duties in the
event of an alarm, the evacuation procedures of that building and the location of the
nearest muster point and an alternative one.
In a site emergency all personnel, with the exception of Security Personnel and
members of the TROBELL INTERNATIONAL NIGERIA LTD Emergency Support Team,
who have been allocated emergency response duties, shall muster at the designated
muster points. Personnel working on the facilities must ensure that they have suitable
means of communication with them.
Their fire wardens will devise people, who muster at Non-operational Muster Locations,
when it is safe to resume normal duties. People at Operational Muster Locations must
remain at the muster point until the “All Clear” is sounded.
Those personnel who are caught at a remote location or cut off and unable to make
their way to a muster station must ensure that they advise Main Gate security of their
name, company, location and number of persons at that position.

SAFETY AUDIT AND INSPECTION
All activities, on land, shall be audited at regular intervals by HSE coordinator.

Auditing shall be performed with the use of standard check-lists and Audit-reports and
shall define needed corrective actions in function of nonconformity highlighted during
the inspection of the job-site.
On-site monthly Inspection, to define job-site status, shall be carried out by HSE
coordinator with the use of standard forms reporting the results of the inspection to the
Operations Manager and to the HSE Manager.
Disciplinary Action
The maintenance of a good safety programme will occasionally require disciplinary
action. TROBELL INTERNATIONAL NIGERIA LTD is committed and responsible for
correcting its own employee’s work habit and, if necessary, the admonishing of an
unsafe individuals.
TROBELL INTERNATIONAL NIGERIA LTD disciplinary plan may entail a first incident
warning, second incident probation, third incident immediate dismissal depending on
the nature and seriousness of the offence.
HEALTH
During the performance of the Project programmed works, the following topics will be
developed for implementation, aiming at establishing and preserving the highest
standard of health and hygienic conditions for the entire work force in the worksite:
➢ Medical fitness of workers and periodical checks

➢ First aid training general prophylaxis training and reference courses.
➢ Hygiene control at the work site
➢ Occupational health preservation programme
➢ Medical facilities, instrumentation and medicines
➢ Medical staff availability at the work site
➢ Sanitary inspection of critical areas at the work site
➢ Accident prevention programme
➢ Emergency preparedness.

ENVIRONMENT
TROBELL INTERNATIONAL NIGERIA LTD confirm its commitments in performing the
PROJECT- contractual works with the least possible impact on the environment and in
absolute compliance. With all NIGERIAN applicable Laws, Regulations, Guidelines and
terms of approvals issued by Environmental Authorities.
I. TROBELL INTERNATIONAL NIGERIA LTD shall pay due regard to the

environment by acting to minimize any impact which may arise from
Construction activities.
II. This includes assessing the types of materials and substances that are
currently in use and substituting them with more environmentally friendly
materials.
The working environment should be safeguarded during the execution of this contract
from all forms of environmental hazards like pollution, oil spills and others capable of
tampering with the natural ecosystems.
We shall ensure that:
➢ No damage is done to the environment

➢ All work sites are reinstated to their original form before final demobilization.
➢ We discourage all activities capable of tampering with the environment.
➢ Spillage of waste oil is avoided and any accidentally discharged waste oil spills
are contained and cleaned up.
➢ All waste are disposed of by conventional methods
➢ Areas of environmental hazards shall be sealed, roped off, shielded and
protection for the safety of the workers provided.
➢ Waste disposal experts would be contacted when and where necessary.
➢ Necessary HSE awareness, concerning environmental safety, is created.
➢ Containers rejects and other waste shall be conveyed to clients approved dump
area or borrow pit with appropriate storage facility.
➢ Disposal shall be through conventional method. Waste disposal resources shall
be provided on site for proper house keeping

Waste Management
Waste constitutes serious hazards to the health of the personnel, environment and the
neighborhood especially when it is not properly collected, handled and disposed of.
To eradicate these hazards resulting from our activities, the company shall embark upon
valid assessment of source, types and quality of waste that are generated and employ
an acceptable strategy in the evacuation of waste.
The strategy will include the engagement of our specialists in environmental and waste
management, when and where necessary, provision of waste disposal and recording
waste
Evacuation procedures; and approved waste dump areas and in accordance with
establish HSE d client and government laws on waste matter.
WASTE DISPOSAL
TROBELL INTERNATIONAL NIGERIA LTD environmental policy requires reduction

and control of solid/Chemical wastes, with incineration method of disposal. All wastes
must be disposed of in compliance with the HSE procedure for Disposal of Hazardous
Wastes.
The correct disposal of all waste is essential to ensure compliance with legislation, as
well as ensuring good industry work safety practices. Incorrect sorting and disposal of
hazardous waste could lead to serious injury or death of personnel. It is TROBELL
INTERNATIONAL NIGERIA LTD policy that no hazardous waste shall be disposal of on
client or TROBELL INTERNATIONAL NIGERIA LTD site.

This section outlines the notification procedure necessary to ensure the correct disposal
of all hazardous waste likely to cause pollution. The full procedure can be found in the
TROBELL INTERNATIONAL NIGERIA LTD HSE Manual.
The waste focal point for TROBELL INTERNATIONAL NIGERIA LTD activities is the
site environmental coordinator who is responsible for ensuring that all waste is disposed
of in an acceptable environmental manner and according to all local and state laws.
The site waste coordinator is responsible for arranging hazardous waste disposal under
the instruction of the site environmental officer.

The TROBELL INTERNATIONAL NIGERIA LTD employee in charge of a job generating

waste materials must contact the site environmental coordinator who will help determine
whether or not the waste is likely to be hazardous.
Schedule Wastes
Where disposal is not feasible, the wastes shall be properly stored at the temporary
waste storage area. Waste should be stored in covered containers, which are durable
and will able to prevent spillage or leakage into the environment; the containers should
be clearly labeled, for identification and warning purposes. The waste is handled by
contractor and will be incinerated.
TROBELL INTERNATIONAL NIGERIA LTD notifies the department of environment of

schedule wastes generated in the plant. Prior to any scheduled shutdown of the plant
source, type and estimated quantity of wastes expected are identified. This will ensure
proper preparation for handling, storage, disposal etc. is promptly made.
Oil and Chemical Spill
Oil and chemical spills can represent a potential threat to the Plant, personal safety and
the environment. Immediate action should be taken in the event of all spills to minimize
the consequences of the spill.
The first action should be to locate and stop the source of the spill. If this cannot be
done or involves a threat to your safety call the emergency number.
Containment of the spill is also important to minimize the chances of oil or chemical
entering the storm water system and potentially the ocean. Small spills should be
cleaned up immediately using an appropriate absorbent material.
If the spill is more severe call the emergency number or use a Plant Radio to advise
operations of the situation.
All spills over 20 liters must be reported to the Environmental Coordinator.

Hazardous Substances General

TROBELL INTERNATIONAL NIGERIA LTD procedures and systems for control of
hazardous substances are intended to comply with FEPA regulations.
Restrictions
Unnecessary procurement, storage and handling of hazardous substances must be

avoided or eliminated.
All substances, which have not previously been used at the site, must be reviewed for
possible hazards before the order is placed. Reviews of this type should be conducted
by the person responsible for the technical aspects of the job concerned, together with
the relevant line supervisor (s) and assisted as necessary by occupational health and
safety specialists. The TROBELL INTERNATIONAL NIGERIA LTD HSE Manager must
approve the introduction of any new hazardous substance to the job site.
Those persons directly handling possibly hazardous substances must not do so until
they have satisfied themselves that they have identified the material, and if it is classed
as hazardous, they have established the practices to be adopted.
All accidents or operational upsets having an influence on the environment shall be
reported in the incident reporting system.
Information
Essential information must be provided as follows:

Material Safety Data HSE etc (MSDS’s) provided by manufacturers, producers and/or
suppliers of hazardous substances.
Clear identification of hazardous substances in pipes and vessels, and registers of
hazardous substances used or produced in the workplace.
The TROBELL INTERNATIONAL NIGERIA LTD Chemical Hazard Management
system contains a computerized database of supplier MSDS’s and supports
maintenance of workplace registers, both of which are requirements of the HSE
Policies. MSDS’s are also available from the Waste Coordinator.

CONTROL
Exposure of personnel to hazardous substances must be kept to levels as low as

reasonably practical and in all cases, below levels set by regulations and relevant
Nigerian and /or of international exposure standards, taking due account of all
precautionary notes on the application of such standards.
➢ Exposure and/or environmental control measures must be evaluated and

implemented in the following order of preference:
➢ Elimination of the need for the hazardous substance
➢ Substitution with a less hazardous substance
➢ Civil Engineering measures, such as enclosure and/or ventilation
➢ Administrative measures, such as restricting access /exposure via job rotation.
RADIOACTIVE MATERIAL
All exposures to ionizing radiation shall be avoided. No practice involving exposure of

personnel to ionizing radiation shall be adopted.
Persons working with sources of ionizing radiation shall:
➢ Obey all notices, instructions and work procedures

➢ Report to the supervisor any defects in equipment or procedures.
➢ Obtain approval from Radiation Focal Point to operate radiation-emitting
apparatus; by having all work permits signed.
Use all radiation protection devices including protective equipment and personal
dosimeters in the correct manner.
Be licensed by the regulatory body to operate radiation-emitting apparatus
TROBELL INTERNATIONAL NIGERIA LTD HSE policy on Radiation Safety shall be
adhered to at all times
Recommendations by Radiation Advisory Committee are to be followed.

ENVIRONMENTAL MONITORING
TROBELL INTERNATIONAL NIGERIA LTD maintains a regular monitoring schedule

for its effluent and emissions they are in full compliance or better than the government
regulations.
In cases of noncompliance it shall be reported to authorities.
MATERIAL HANDLING
STORES
➢ All stored items must be adequately labeled

➢ Dangerous substances must be stored only in secluded areas with restriction
signs such as “No smoking” for inflammable materials.
➢ However items must be stored on lower shelves, while lighter ones occupy the
upper she lives.
➢ Stores items must be adequately shielded from weather affects
➢ Exists and entrances must be left cleared all the time
➢ Good house-keeping must be kept always
➢ Power equipment in the stores must be switched off before leaving for the day’s
work.
MANUAL HANDLING
Where you intend to lift any load, the followings procedures applies;
➢ Keep your back straight

➢ Tuck in your chin
➢ Stand with your feet slightly apart with the right foot forward and firmly planted.
➢ Bend your knees not your waist
➢ Grip the load firmly and closely to your body
➢ Lock your elbows and lift
➢ Thin rise slowly with the load

Do not try to lift something, which is too large for you to get a good grip on it. Do not
run. Avoid carrying a load that will obscure your view, particularly when using stair ways
or on elevated sites.
Do not try to lift heavy loads by yourself. Get help to lift heavy loads.
PLANTS/EQUIPMENT
All plants and equipment on site must be operated by experienced and skilled
personnel. The plants and equipment must be regularly be inspected and vice in
accordance with the maintenance schedule. Unauthorized persons shall be debarred
from tempering or operating any plant or equipment on site.
Oil and Gas Industry Equipment
Before use in the plant, Coating machines, air compressors and cranes must be
checked and a certificate issued by:
i) Civil Engineering electrical section for generator, cabling, sockets of Coating

machines.
ii) Civil Engineering mechanical workshop section for air compressors cranes
engines of Coating machines.
The certificate must be revalidated every six months and displayed in the prominent
place on the equipment. It is the responsibility of the contractor to make sure that the
above is carried out.
Equipment register shall be kept for all equipment by maintenance. Information about
Inspection Schedule and update of Inspection Schedule shall be included in register.
Fire extinguishing equipment is compulsory for all vehicles
All mobile equipment must have a stop sign attached to the appropriate button, key or
devise that is used to shut down the machine.

PORTABLE EQUIPMENT
Preferably, drills grinders etc. it to be pneumatically powered If electrically powered

equipment is use, it must be of a double insulated type. Non-double insulated portable
equipment will be confiscated. Extension lead cabling, sockets and plugs must be
inspected by Civil Engineering section. Tagging should be made every sixth months.
Earth leakage tripping units and isolating transformers are available from Civil
Engineering section (PEE).
All portable equipment etc must be handled with care.
Use only the equipment that is in good working condition.
Inspect tool before use.
Ensure portable equipment or tools are used for the job it is designed for.
Repair all detective power tool/equipment immediately
HAND TOOLS
Only use tools in good condition. Broken or damaged tools and makeshift tools must
not be used and will be confiscated without warning. This includes:
➢ Mushroom headed chisels, punches, and drifts.

➢ Hammers with broken or loose shafts or chipped heads.
➢ Spanners with splayed jaws.
➢ Screwdrivers and files without handles
➢ Pipe extensions applied to spanners.
➢ Workbenches should be stowed safely.
➢ Tools should be stowed safely.
➢ This applies particularly to overhead work

SPARK PRODUCING TOOLS
All tools powered by motive power (electricity, air) are considered to be capable of
producing incentive sparks and a permit to work must cover their use in the restricted
areas.
COLD TOOLS
Those tools, which depend entirely on manpower, are considered to be cold tools from
which the possibility of producing an incentive spark is remote and their use may be
authorized by a permit to work. Remember that all work in confined spaces requires an
entry permit.
PORTABLE LIGHTING
Wandering lead lamps, portable clusters etc. are to be obtained from Civil Engineering
electrical department. The use of non-authorized equipment is not allowed. Instructions
about voltage etc. can be obtained from Electrical Department (PPE).
Flame Cutting Equipment
- Bottles shall inspected and certified

- Bottles shall not be brought into vessels
- Bottles gauges shall be in working order
- Flashback arrestors shall be fitted on the outlet from oxygen and gas bottles
- Bottles shall be in good condition i.e. No bent valves, no extensive corrosion and
a current pressure test date stamp.
- Bottles shall be maintained in an upright position and chained onto the trolley
- Repairs to tubing shall be made in a proper manner i.e no PVC tape repair
- Houses shall be maintained and be in good condition.
- Bottle valves shall be shut when not in use. In addition, when flame cutting is in
an enclosed space, the torch and associated tubing must be removed from the
enclosed space when not in use.

Bottles and flame cutting equipment not in use shall be parked only on dedicated places
outside of the plant. At the end of every day tubes shall be removed from the plant to
dedicated places.
When hot work is done in plant a habitat or tarpaulin is recommended to direct sparks.
COATING EQUIPMENT
Maximum open circuit voltage of Coating equipment including quivers shall be limited
to 50 Volts ac. or 110 Volts dc.
Work piece return cable shall be connected directly to the work piece to provide good
earthling connection. Insulated connectors of locking types shall joint the sections of
Coating cable.
The length of supply cable to a Coating transformer shall be limited to four meters. Minor
cuts in Coating cable are to be repaired with self-fusing tape (not PVC)
Cable lengths between repairs shall exceed 10 meters and the length of the tape applied
shall be less than fifteen centimeters cable length.
INDUSTRIAL GAS CYLINDER
Cylinders intended for the storage of compressed gas are the subjects of special
standards as to material and method of construction, the pressure that they are tested,
and the maximum pressure to which they can be filled.
All gas cylinders shall be color-coded and certified. An instruction about color-coding is
available from Civil Engineering Department.
Mishandling gas cylinders can result in explosions. When using Coating gas in a
workshop, the cylinders should be outside the building and manifold to a piping system
to provide the gas at the place of work. Such piping systems should be marked to
identify the gases.
To prevent the interchange of fittings between cylinders to combustible gases and non-
combustible gases, the valve outlet is screwed left hand and right hand respectively.
Provision should be made on gas cylinder trolleys for the safe storage of hoses.

Gas cylinders other than those associated with breathing apparatus must never be
taken into confined spaces and gas torches and hoses must be removed when the work
is completed or whenever work is temporarily suspended at the end of the workday.
When regulator head from an empty cylinder is transferred to a full one the regulator
screw must be completely unscrewed. The cock on the cylinder must be opened very
gradually to prevent
Any pressure shock to the regulator head. Failure to observe these precautions will
result in putting great pressure suddenly on the regulator, which can cause it to
disintegrate.
LADDERS
Ladders should in principal be used on flat level ground only. Wedges or other loose
material should not be used. The top of the ladder should be securely clamped or
lashed with wire or polyprolene rope during use. If this is not possible it should be held
firmly (footed) by another person. The ladder should be placed at a safe angle, i.e. up
to 1 out.
Ladders, which have damaged stiles or rungs, must not be used, but brought to the
attention of supervision. If they cannot be repaired immediately they shall be removed
from site.
Wooden ladders shall be inspected regularly.
Metal ladders must not be used near unprotected live electrical conductors.
Aluminum ladders must not be used in areas where they may come in contact with
caustic material.
Pipe work below 75 mm (3”) in diameter must not be used as a ladder support.
The ladder should always be of sufficient length for the job, i.e 1 meter (3’3”) above the
place of landing and above the highest rung to be reached by the feet of the person
working on the ladder.

LIFTING GEAR
Lifting gear for the execution of small jobs may be borrowed from mechanical tool store
when it is specified that the contractor must supply its own lifting tackle, the following
rule applies.
SLINGS
The minimum standard for TROBELL INTERNATIONAL NIGERIA LTD Lifting

Equipment shall apply.
Wire rope slings, the eyes that are closed ferules (swaged type).
Webbing slings (spanner set type).
The Safe Working Local must be clearly marked on the sling and a certificate of
manufacture must be available for the sling. The slings shall be inspected regularly
according to instruction from inspection department.
Types, which may not be used at TROBELL INTERNATIONAL NIGERIA LTD
Homemade wire slings the eye of which is closed by splicing
Chain slings
Insulated wire slings
TRANSPORTATION
The movement of personnel and property is an important exercise to the management

of the company. Therefore, all safety measures shall be brought to bear in whatever
means of transportation to be embarked upon by our personnel.
ROAD TRANSPORTATION
All vehicles must have valid statutory papers at any given time to be used in the
operations.
All vehicle particulars such as vehicles license, insurance certificate, road worthiness
certificate, and any other document such as driver'’ license should be handy at all times.

Company’s internal proficiency test should be conducted before drivers are being
deployed to drive any of the company’s vehicles.
Drivers and front seat passengers must wear their seat belts while the vehicle is on
motion.
No passengers or worker shall be conveyed in an open vehicle and pick-up truck.
All vehicles shall be equipped with fire extinguishers (portable), two triangular reflectors,
one jack and wheel spanners and spare wheel/tyre.
The necessary safety check should be routinely carried out daily such as oil, water,
brake fluid, lights, trafficators, wipers etc.
All drivers must be prepared to drive according to or within speed limits, to stop at all
cross-roads, should not over-load and prevent excessive speeding.
All accidents involving company’s vehicles must be reported immediately as per injuries,
damage and cause of accident for immediate investigation.
No employee will be permitted to drive under the influence of alcohol or drugs or without
a valid and appropriate driving license.
Giving lifts in company’s vehicle is strictly prohibited, except in cases of emergency or

requisition by local authorities or client.
Unsafe, discontinuous or reckless driving is not tolerated by the company.
Getting on or off a vehicle while it is in motion is strictly forbidden.
Drivers are discouraged from driving at night except during emergency.
Driver must be issued with Journey Hazard management.

ROAD TRAFFIC REGULATIONS
All regulations, which are applicable to vehicles on the public roads, apply inside
TROBELL INTERNATIONAL NIGERIA LTD premises
Controls for access to process and non-process area will be developed.
General Rules
The driver is responsible for the safety of all passengers and shall inspect the vehicle
each day before use.
Seat belts shall be worn at all times when vehicle is in motion
No private cars will be allowed on the job site without the approval of the Project
Manager or his designated.
Always look at the rear of the vehicle before reversing and sound the horn in congested
areas before backing.
Obey all speed limits and regulations and always give pedestrians the right of way.
When refueling a vehicle, be sure to shut off the engine. During refueling no smoking is
allowed and mobile telephone shall be shut off.
Safety Belts
Safety belts shall be worn in the vehicles all time while under transport except for forklift
trucks. This applies to both residential area and industrial area as well as outside. Not
wearing Safety Belt is considered a serious offence. A formal warning will be issued if
caught not complying with this rule.

Special Rules Concerning Drinking and Driving.
See chapter on Alcohol and Drugs for advice.
Instruction to Passengers in vehicles
Passengers in vehicles must be seats provided. The used seats shall be provided with
safety belts except for the buses. They must not stand while vehicle is in motion and
must not travel in the same compartment as an unsecured load.
Maximum number of passengers:
Closed Van 8 persons
Pick –up 8 persons
3-ton truck designed for bus transport 14 persons
5-ton truck designed for bus transport 20 persons
Rules about the use of lights
Low beam shall be used as dusk gathers
Headlights shall be used at dark
Full beam shall be used only when there is no other traffic.
Site Traffic Regulations
No person shall drive a vehicle on site for which he/HSE does not hold the relevant
class of license. The speed limit for light vehicles is 30 km/h and for mobile plant and
heavy vehicles (those exceeding two tons in weight) is 10 km/h. The speed limit of 10
km/h applies in the vicinity of shutdown /project work. The maximum clearance under
pipe racks is 5.5 meters.
All cranes must travel along roads with their booms down. A guide, to avoid collisions
with process equipment, in another vehicle or walking, must accompany all cranes
maneuvering in the process areas.

Vehicles are to be parked in designated parking zones unless the vehicle must be close
to the job to allow it to be used for work. In all circumstances vehicles shall be parked
so as not to obstruct access for emergency services. The vehicle keys are to be left in
the ignition.
Occupants of vehicles fitted with seat belts must wear them whilst driving on site. Riding
on vehicles is not permitted where there is no vehicle manufacturer’s seating provided.
When vehicles with a load in excess of ten tons require Operational Area access and
they need to cross plant road bridges, their route must be approved by the Technical
Director before being permitted on site.
Vehicles
The use of vehicles within the site is strictly controlled to minimize the risk to personnel
and plant. The Nigerian Road Traffic Act applies within the site boundaries; site specific
regulations take precedence. All traffic signs rules and all drivers shall observe barriers.
Vehicle Inspection
All vehicles entering the Plant are to be maintained in a safe operating condition and
shall be inspected at six-month intervals or as required. Vehicles, which fail any part of
the inspection, will not be permitted to access site until they have been repaired and re-
inspected. Vehicles, which have passed inspection, can be identified by a round sticker
on the top near (passenger) side of the windscreen. The sticker colors change each
six-month to aid Identification of vehicles due for re-inspection. Vehicles are either given
renewed transponder access or a blue vehicle Inspection Card.
WATER TRANSPORTATION
The Quarter-Master is in-charge of the craft and all instructions and safety regulations
passed by him must be complied with.
Always remain seated in the cabin at all times unless instructed otherwise.
Embark and disembark only when craft has fully secured along-side.
The transportation of workers in water-borne and swampy areas will be by house-boat,
and speed-boats.

Induction or briefing should be conducted to the people on the use of life-jackets and
vest during emergency before commencement of journey.
Life jackets and vests should be stocked inside the boat in easy access in TROBELL
INTERNATIONAL NIGERIA LTD of emergency.
Personnel should not be allowed to wear safety shoes or helmet inside the boat.
AIR TRANSPORTATION/HELICOPTER
All passengers boarding the Aircraft and Helicopter should observed all necessary
precautions and follow the lead of the pilot
All passengers should seat calmly and fasten their seat-belt
The life jacket punch should be strap around your waist
Wear your earmuffs and obey all instructions from the pilot and crew.
Disembark only when instructed to.
Walking around the back of the aircraft should be avoided because the Rotor is very
dangerous.
Do not carry long objects horizontally and light items to be properly hand carried.
Do not inflate your lift jacket until you are out of the Helicopter.
PERSONAL PROTECTIVE EQUIPMENT (PPE)
Personal Protective Equipment refers to the protective, i.e. the materials given to a
worker to safeguard against the hazard involved in the duty he has to perform. Such
protective gadgets includes but not limited to the followings:

FOOT AND TOE PROTECTION
All safety shoes or boots should be in serviceable or usable conditions.
Safety boots and shoes that are damaged should be replaced.
In swampy area, safety jack boots, jungle or rain boots should be used. Such safety
shoes or boots must have steel cap.
COVERALLS
All coverall or work cloths should be worn and maintained in good state and shall not
be transferable.
Workers should not work bare chest or put coverall in oil, chemicals or any other
dangerous products.
Ragged clothing’s, loose or torn clothing should be replaced, particularly when working
near running machinery.
Avoid wearing over-sized or under-sized overall.
EAR PROTECTION
Workers working close to load or high noise area should wear ear muffs aid plugs as
required and avoid wearing unserviceable ear protective equipment.
Restricted sign in noise hazard areas should be displayed.
RESPIRATORY PROTECTION
Respiratory protection should be in a serviceable condition such as face mask, nose
covers, breathing apparatus, dust hoods and shield etc.
Respiratory protective equipment should be worn to avoid inhalation of dangerous and
harmful substances.
Appropriate respiratory system, eye wear and protective clothing must be worn when
sand-blasting, using a spray gun for painting and in the presence of dangerous dust.
Discard equipment when it is dirty or unserviceable and replace stock immediately.

HEAD PROTECTION
Safety hats are to be worn during over-head or working in hazardous areas that could
result in a head injury.
Inappropriate use of hard hats shall not be accepted
Damaged or unserviceable hard hats must be replaced as soon as reported.
Hard hats should have fastening traps to grip hat properly to the head to avoid frequent
falling off from head.
HAND PROTECTION
When working or handling corrosive substances ensure covering your hands with
rubber hand gloves.
Special hand protection such as gauntlets shall be used by operators etc.
Torn or worn out gloves must be replaced as soon as reported and gloves should be
worn to avoid hand injury.
All lifting or any menial work must be done with hand gloves
Various kinds of hand gloves exit, which must be according to the required work
involved.
FACE PROTECTION
Safety goggles or suitable eye protection must be worn on all jobs involving drilling,
handling chemicals or other corrosive materials.
Face shield and goggles must be in serviceable condition.
Aprons and leggings should be provided to those who face hazards of Fumigation
chemicals and maintained in serviceable condition.
FIRE SAFETY
Every worker or employee should be familiar with the fire emergency procedure on client
site, location or work place you are deployed or working.
The operating procedure for firefighting equipment such as the different fire
extinguishers should be familiar with all workers and employees.

Extinguishers must be checked at regular intervals at least once a year.

Remember to refill any extinguisher used as a cause of fire or leakage
Do not use water, foam extinguisher, spray hose to fight electric fire.
All employees must abide to the “No smoking” regulations either at a gas plant or in an
atmosphere which may be contaminated with flammable vapours.
Never store inflammable products in confined areas. All fumigation and pest control
jobs at the site must be permitted by work permitted before operation.
Always be sure that sources of heat and flames are kept away at all times and never
use flammable liquids as cleaning fluid.
Do not use defective electrical plugs or socket and do not overload a socket outlet. Don’t
get trapped while fighting fire and abandon the premises without hesitation to pick-up
your belonging in cases of fire.
Save your life first before anything else while abandoning any firefighting, ensure your
way of escape is safe and do not shut doors and windows on your exit to escape.
Do not obstruct fire exits and extinguishers. Watch out the direction of the wind before
fighting fire.
Dispose of all combustible waste, rags, papers and other rubbish in the appropriate
manner.
Attack fire at an early stage using the equipment provided in your work area.
SECURITY
In order to ensure that high standards are maintained for protection of human and
material resources used in our operations, we shall:
Employ full time security personnel to monitor security of human and material resources
within the working site, offices and designated residential areas.
Ensure that each personnel in any area of our operation have appropriate identity
marks/card with him/her, which must be presented on demand when the need arises.
Monitor all entries into our premises and site by the use of tag or log-in/log-out system.

Provide emergency alarm system and whistles to alert personnel in cases of robbery
emergency.
Check stealing by prohibiting all forms of hawking, screening of visitor (s) in our
premises, sites and offices.
Ensure that every person entering our working areas or premises declares his identity
and personal belonging at the gate. Proper documentation of the person’s identity shall
be made, stating date, purpose of visit, time in and out recorded.
Ensure authentic gate passes and waybills are presented to the security personnel to
authorize exit of materials from company premises and sites.
Provide adequate escort for specific vehicles as need arises.
In addition to the above listed steps, we shall consider security matters to be a crucial
part of our Health, Safety, and Environment and Security obligations. To achieve the
above targets, we shall:
Ensure the provision of healthy, dedicated and trained security personnel who shall be
properly dressed to carry out the job.
Organize in-house training programmes for all security procedures.
GOOD HOUSEKEEPING
Maintain strict control of all potential pollution sources to ensure pollution is avoided.
Reducing to a bare minimum, waste resulting from execution of the work and ensuring
that it is property disposal of:
Ensuring that urinating and defecation anywhere other than sanitary facilities is totally
prohibited. Strict guidelines will be issued to this effect as part of the conditions of
employment and a possible reason for termination.

HSE KEY PERFORMANCE INDICATORS
2018 2019 2020
COMMUNITY DISTURBANCE 0 0 0 0 0 0
FATALITY 0 0 0 0 0 0
LOST TIME INJURY (LTI) 0 0 0 0 0 0
LOST TIME INJURY (LTIF) 0 0 0 0 0 0
MEDICAL TREATMENT CASE (MTC) 0 0 0 0 0 0
FIRST AID CASE (FAC) (INJURIES) 0 0 0 0 0 0
UA/UC/NM 1040 567 1040 783 1040 849
HAZARD IDENTIFICATION REPORT 1040 624 1040 812 1040 986

(HIR)
ROAD TRANSPORT 0 0 0 0 0 0
ACCIDENT/INCIDENT (RTA/RTI)
TOTAL RECORDABLE CASE (TRCF) 90/Month 90/Month 90/Month 90/Month 90/Month 90/Month
LTI FREE CUMM MAN- HOUR 110,720 104,648 110,720 106,062 110,720 108,184

S/N Leading Indicators Plan Actual Lagging Indicators Plan Actual

1 Premob activities 100% Exposure Hours 0
2 Adequate controls for key 100% Fatalities Zero

hazards
3 100% Lost time Injuries Zero

Mobilization Activities
4 HSE Trainings 100% Total Recordable Cases Zero
5 Management Field 100% High Risk Incidents Zero

inspections
6 HSE Audits/Inspections 100% Unsafe acts/unsafe conditions 500
7 100% Kilometer driven Zero

Emergency Drills
8 Compliance to work 100% Motor vehicle incidents Zero

procedures
9 100% Security incidents Zero
HSE Meetings
10 100% Waste Generated Zero

Stop work exercised

CLOSURE
Our Health, Safety & Environment program is
planned to protect you and prevent accidents.
Your sincere co-operation is most important.
Report any unsafe acts and unsafe conditions

that may cause accidents or incidents to HSE
Corporate Department.
We are extremely proud of our Health, Safety &

Environment records.
Help us make it better.
"SHARE THE PRIDE WITH US"

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I i l

HEALTH SAFETY AND ENVIRONMENTAL

TROBELL INTERNATIONAL NIGERIA LIMITED

Address: No 11 Nyemweli O.N. Nsirim Layout,

E-Mail tom.sede@trobell.com, lawal.garba@trobell.com

December 22nd, 2020

S/N Description Page No.

4. Organisation, Responsibilities, Resources, Standard and 20

7. Risk Analysis and Management 29

9. Accident/Incident Investigation and Reporting 31

10. Work Permit System 32

11. Action in Case of Fire Alarm 34

12. Emergency and Evacuation Procedure 38

13. Safety Audit and Inspections 41

15. Material Handling 47

18. Good Housekeeping 62

19. HSE Performance Indicators 63

At TROBELL INTERNATIONAL NIGERIA LTD Safety is the way we do Business Page 1

At TROBELL INTERNATIONAL NIGERIA LTD, we strongly believe in Quality

To achieve this objective TROBELL INTERNATIONAL NIGERIA LTD relies on

"HSE IS EVERYBODY’S BUSINESSS"

At TROBELL INTERNATIONAL NIGERIA LTD Safety is the way we do Business Page 2

At TROBELL INTERNATIONAL NIGERIA LTD Safety is the way we do Business Page 3

TROBELL INTERNATIONAL NIGERIA LTD COMPANY HSE POLICY

Regular Inspection and monitoring of the activities is undertaken and

It is the policy of our company to;

At TROBELL INTERNATIONAL NIGERIA LTD Safety is the way we do Business Page 4

COMMUNITY AFFAIRS POLICY

▪ Liaising with genuine representative of our host communities before commencement

At TROBELL INTERNATIONAL NIGERIA LTD Safety is the way we do Business Page 5

TROBELL INTERNATIONAL NIGERIA LTD prohibit smoking on site. And

Hazardous areas should be marked with a” No Smoking” Sign Conspicuously

At TROBELL INTERNATIONAL NIGERIA LTD Safety is the way we do Business Page 6

DRUG AND ALCOHOL POLICY

TROBELL INTERNATIONAL NIGERIA LTD in compliance with statutory

❖ No worker shall consume alcoholic liquor and hard drug on duty.

At TROBELL INTERNATIONAL NIGERIA LTD Safety is the way we do Business Page 7

OCCUPATIONAL HEALTH POLICY

All staff of TROBELL INTERNATIONAL NIGERIA LTD shall be medically fit

Compliance with this policy is a MUST.

At TROBELL INTERNATIONAL NIGERIA LTD Safety is the way we do Business Page 8

REWARD/ SANCTION POLICY

There shall be incentives in the following categories

• End of year HSE award.

Incentives shall be in award (PLAQUES, CERTIFICATES, GIFTS ETC) and or

Sanctions shall include suspension, pay cut, or dismissal depending on the

At TROBELL INTERNATIONAL NIGERIA LTD Safety is the way we do Business Page 9

JOURNEY MANAGEMENT POLICY

TROBELL INTERNATIONAL NIGERIA LTD appreciate the fact that most

At TROBELL INTERNATIONAL NIGERIA LTD Safety is the way we do Business Page 10

SEAT BELT POLICY

At TROBELL INTERNATIONAL NIGERIA LTD Safety is the way we do Business Page 11

ACCESS CONTROL POLICY

Access to Restricted Area is on permission basis. All visitors, authorized

Visitors to site shall be briefed on behavior on site, clothed with appropriate

Material issuances vouchers and ID Cards will be used for identification.

At TROBELL INTERNATIONAL NIGERIA LTD Safety is the way we do Business Page 12

An essential part of the overall company’s management is the management of