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TANK SAFE ENTRY PROCEDURE

Fuel Oil Storage Tanks

TOOL BOX & SAFETY MEETING

All personnel who are working in the project will be required to attend this meeting. All known risks will be discussed and preventive action taken to ensure that every one understands the risks involved.

VENTILATION

Tank to be entered must have been ventilated for a minimum period of twenty -four consecutive hours. This is to be done by using air driven trumpet blowers placed at the bottom manhole area blowing air in and exhaust through the roof top manhole of the tank. If it is not possible, then ventilation to be done wherever this is available entry point into the tank. LEL levels will be monitored on an hourly basis for the first twelve hours.

MAN ENTRY

Man entry into the tank is not permitted unless the following procedures have been followed: LEL & H2S alarms have been placed in key points around the tank to monitor gas levels. A qualified third party surveyor certification is required for safe man entry to the tank. Breathing mask apparatuses have been checked for leaks, five minute escape packs are full of emergency air, air lines are secured with clip to prevent them from coming unlocked in tank and cascade system is full of air prior to tank entry. This checklist is to be done before every tank entry. Men to have proper PPE; steel toed rubber gum boots, chemical proof disposable coveralls, chemical and cotton gloves, safety glasses, helmets. (Note: men working inside the tank will not be required to wear helmet and safety glasses while using breathing apparatus.). Breathing apparatus will be used up to pumping out/demucking of the sludge. Ventilation of the tank to be checked by our safety officer in regular intervals up to finish the cleaning job. Explosion proof lights to be installed as soon as possible after man entry. First team into tank will install the lights to appoint nearest the man-way to

illuminate the exit area at all time. Additional lighting will be moved to area being cleaned prior to pumping activity. (Note: every man will be issued an explosion proof hand held flashlight for emergency lighting. Flash light will be checked at regular intervals to make sure that it is in good working condition). Tank cleaning crews will be divided into two teams of six changing shift every one hour, team will consist of one pump operator(foreman) and five cleaners (Note: this process of changing shift will be continue only up to demucking/pumping out the sludge from the tank bottom). Tank cleaners will not be allowed in the tank without a supervisor/foreman. Tank entry & exit time will be noted on a whiteboard outside of the man-way and will be monitored by the supervisor of the tank along with the man-way watchman. Drinking water will be plentiful and placed near working platform. Tank cleaners will be encouraged to drink plenty of water prior to entering the tank and after exiting from the tank.

******************************************** SCAFFOLDING

All materials need to be used in erection of scaffolding to be inspected by the safety officer, project supervisor and scaffolding inspector. All materials to be used in this project should be suitable quality and in good condition, and free from any defect likely to affect their strength materially. Items not meeting the standard should be discarded. Scaffolding boards are manufactured from seasoned timber and should be required thickness as per standard. All Scaffolding technicians are completed their basic scaffolding Techniques and Safety training from approved scaffolding training institution. All scaffolding technicians to wear normal PPE and always work with safety belt and helmet. One safety officer will be at site to monitor the risk involved in scaffolding work and inspect the basic scaffolding techniques & safety measures are taken as per required standard. Scaffolds should be erected by trained scaffolders or other competent persons possessing adequate experience of such work. In Erection of scaffolding the scaffolding supervisor and inspector to be discussed Base & Height Ratio. Ensure the high safety and quality on erection of the scaffolding. Use necessary secured ladders as per scaffolding standards. Provide necessary supporting

and securing the erected scaffolding from outside the access. If the height of the scaffolding is more than 15 meter a third party certification will be provide for the safety and quality of the scaffolding. The usage of the erected scaffolding will be allow only after the Inspector will finish his inspection and install scaff tag for the using of scaffolding. When boards are being handed up or down a scaffold or in any similar situation all persons not directly involved should be well clear. Always take a firm grip. Pass the board in one smooth movement rather than tossing it or lowering it in a series of separate handholds. Any small injury to the hands from splinters may cause the board to be dropped. When passing the board to someone else, do not push and do not let go until they control at least two third of it or say that it is under control. Do not pass boards backwards without looking.

A proper ladder system should be available to use clear access to the scaffolding from ground to first level and level to up levels as per scaffolding standards.

During dismantling no component should be removed which endangers the stability of the remaining structure. If dismantling has reached a stage where a critical member has to be removed e.g. a tie or brace, the stability of the structure should be assured by fixing a similar member lower down. The following precautions should be observed: Do not remove all ties Do not remove all bracing first Do not remove all the intermediate and board end transforms Do not remove all intermediate guard rails.

**************************************** POWER TOOLING AND HIGH PRESSURE WASHING

Qualified safety officer has personally checked first the conditions and connections of the all power tools and High pressure washing machines.

Electric power operated tools shall either be of the approved double insulated type or grounded. The use of electric chords for hoisting or lowering tools shall not be permitted. Pneumatic power tools shall be secured to the hose or by some positive means to prevent slipping. Tools shall have a safety device on the nozzle to prevent accidental ejection of fasteners, nails and straplers. Compressed air shall not be used for cleansing purpose unless effective measure taken against flying particles. In all hydraulic power tools the fluid used shall be of fire resistant type and shall retain its operating characteristic at the most extreme temperatures to which will be exposed. The manufactures safe operating pressure for hoses, valves, pipe, filters and other fitting shall not be exceeded. Every cartridge operated tools where there is potential hazard of flying pins and splinters, shall be fitted with guards of sufficient size and shall be firmly held with the surface. All pneumatic power tools should be secured with proper safety fittings connected with air compressor, air manifold and each power tool end fittings. The technicians who are using these power tools should be highly experienced and ensure all protective measures to be taken for personal protection. Only trained and instructed persons shall operate high pressure water jetting equipment. Whenever high pressure washing is going on the area will be isolate with barriers or tiger taps. When washing work carry out with chemical additives, extra precaution shall be taken and no adjustments to the equipments shall be attempted when it is under pressure. The diesel generator, air compressor and vehicles in use at site should be fixed proper spark arrestors at the time of using each equipments and vehicles. Men to have proper PPE; steel toed rubber gum boots, chemical proof disposable coveralls, face shield, hydro blasting suits, chemical & cotton gloves, safety glasses, hard hats. Ensure safety belts are secured with available scaffolding supports when the work is progressed at scaffolding acess.

ABRASIVES/ GRIT BLASTING AND PAINTING

No person shall be employed in this operations unless he has been trained and experienced in that work. Every blasting operatives and

blasting crew members shall be provided with and shall use appropriate respiratory and other PPE. If a blasting helmet is required to be used , it shall be positive air pressure type, and be provided with in line air filtering device in the air delivery line to blasting helmets. An automatic safety shut off control shall be provided to the blasters hand control. Blasting area shall be barricaded to provide protection to other workmen and equipment. A minimum five years experienced sand blasters only use for this project. All blasters will be experienced from Dubai dry dock, Lamprell and MIS. All persons involved this job already finished safety training from Dubai Dry Dock and holding their T card. The required standard will be attain by our experts by ensuring quality and safety measures. All equipment using for the blasting purpose will be in good safety condition and environment friendly. Protective covering will be taken to the environmental protection from blasting dust and pollution.

Safety requirements will be taken for painting on confined space and open space: Prominent display of appropriate sign boards at the paint storage area and space to be painted. Cordoning of painting and storage areas Supply of sufficient forced ventilation No hot work in the space to be painted No hot work with in 3m of the common bulkheads in the adjacent tanks Provision of adequate explosion proof lights with cables in good condition Use of cartridge type respirator / air fed mask Proper blanking /isolation of pipelines leading to other compartments Ensure the required painting standard is meet before final inspection. Required protective covering will be ensured before commencing the spray painting at out side premises like loading arm painting at port side.

MISCELLANEOUS

Discharge hoses / air hoses will be roped together to avoid disconnection while under pressure. Discharge hoses on the loading platform to be secured by chain to prevent them from coming loose and striking someone while under pressure. This action will result from the hose being partially choked and finally forced to clean by pump pressure. Plastic sheeting shall cover ground underneath the potential spill points. This sheeting will be monitored for wear and replaced when necessary. These areas are normally the area underneath the skiploading platform, underneath the diesel driven power packs and air compressors. Also, whenever a hose connection is to make loose, plastic sheeting will be placed underneath the connection to prevent possible oil spill onto the ground area. All lifting slings, shackles etc used in loading and unloading equipment will be checked for wear and tear and should be utilized at 50% of their rated capacity. Visual checks should be done on lifting pad-eyes etc prior to attaching shackles & slings to equipment that will be raised. No person shall be allowed to work underneath a lifted object. All personnel shall be allowed to voice their concern for safety to the supervisor, if the situation warrants a review of the work procedure, then all work will be stopped and the work procedure and risk will be evaluated and reviewed. Preventative measures will be implemented to negate the risk before work is continued.

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TRANSPORTATION OF EQUIPMENT & MATERIAL AT SITE

Objective : Transportation of equipment, labour and materials

Pre- Contract meeting: A pre-contract meeting with client personnel. All supervisory personnel who will be involved in this operation must attend this meeting. So as to discuss what equipment, personnel, lifting gear and Spill Prevention Kits will be needed to perform this transportation efficiently and safely. During this meeting a route will be decided to transport the equipment etc, the transportation site foreman. Pre-job meeting: The transportation site foreman will meet with his crew an hour before the estimated time of starting the job to check and make sure that all equipment and personnel confirm to the safety standards set up by Client and contractors own safety standards. Job Procedures: Tanker setup for pumping of fresh water, Trailer/ pickup setup to load and unload equipments, scaffolding materials and consumables. Vehicle to be parked and chock blocks to be used while loading and off-loading Vehicle driver will not be allowed to sit in the cab of the trailer while pumping the fresh water in to the tanker. Engine to be switched off while loading and off-loading . No trailers/truck will be allowed to move with out the load being tied down as per the procedure of Client. No trailers/trucks to reverse without a signal man .The signal man to make sure that he is not between trailer or any other equipment while backing the trailer. Site foreman to make sure that there is plenty of drinking water for his personnel on location , and adequate rests for trailer/truck drivers. Spill Kits will be supplied to all trailers/trucks in case of spill. In case of spill the check list will be given as per the procedure of Client. Site foreman to make sure that certification for personnel in hand.

A Convoy policy to be followed for movements of trucks from one location to another, the trucks to follow a lead vehicle.

Spill Prevention Procedure ENOC has to issue Spill prevention Procedure for plant site and in case of road spills or major accidents. Personnel Safety Equipment TELCON will supply the normal personnel safety equipments to its employees. ( e.g. Hard hat, Coveralls, Safety Glasses, Safety Shoes) spill Kits will be provided. Truck Loading , Movement & Safety Truck Speed to a maximum of 40kms per hour & 20kms. per hour on elevated roads. Transportation to be done only in daylight hours If possible a route plan to be given to all drivers No mobile phones to be used while driving.

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HEALTH SAFETY AND ENVIRONMENT POLICY In this policy to conduct activities in a manner designed to minimize HSE risks, protect health and safety of employees, contractors, customers, the community at large and the environment in which the company activities are conducted . Through active participation of all employees and contractors, will strive to manage HSE risks with the goal preventing accidents, injuries and occupational illness, progressively minimizing environmental impact by reducing in discharges and using energy efficiently, and producing safe, quality products. We believes that Good HSE performance will contribute to the success of the business and will treat HSE issue on par with all primary business objectives. The Management is committed to prevent any Accident and to manage the Hazards to level's of tolerance, to this objective shall: Ensure that the HSE policy is available & understood by all concerned, implemented to fulfill the HSE requirements in all company business activities, review and update these policy whenever necessary in line with the developments in technology and changes in legislation. Formulate/ review / update a high standards that will meet the statutory requirements for Health, Safety and Environment. Encourage support and pursue the continual improvement of Health and Safety at work and of its Environmental performance. Support and promote a high standard of preventive and corrective health care and execution of effective Occupational and public health programs. Implement and support programs to promote and improve safe working methods and practices also ensure road and marine traffic safety. Formulate, support and promote the environmental protection programs to minimize the environmental impact affected by its activities. Ensure by design quality assurance, auditing and inspecting that facilities are built to meet internationally accepted or internal standards for safe and healthy working, safe and clean production and for fire prevention.

Ensure by procedures, techniques, inspection and audits, that facilities are maintained to a high standard and are operated so that they are safe and reliable and present a practice minimum risk of injury to people, leakage, fire or breakdown. Report and analyze any accident with follow-up recommendation to prevent recurrence, with accountability for all lost time accidents and Department Head level as a minimum. This applies equally to the company and to its tenants or contractors. Promote awareness of and develop skills in life saving, Safety and Environmental protection for staff, tenants and contractors, employee through communication, training and other appropriate means. Work with Government Departments, Local Authorities technical advisors and professional bodies as appropriate and take the initiative, where necessary, to promote practicable and improved codes of practice and regulation in the field of Health, Safety and Environment Protection. Consider and evaluate tenants / or contractors performance with regard to Health, Safety and Environmental Protection when selecting the tenants and contractors apply Health, Safety and Environment Protection standards fully compatible with company HSE guideline. Commit to a program of continual renewal and replenishment of HSE policy, goals and objectives in line with the aim of promoting Continuous improvement of process methodologies.

ENVIRONMENTAL PROTECTION

It is the policy of our company to ensure that its activities are conducted with full concern for safeguarding the physical environment and to comply with relevant environmental laws and regulations. A system of procedures has been implemented to minimize waste, incorporate environmentally safe practices with in its operations and inform employees of their continuing obligations to conduct all activities in compliance with the company policy.

HEALTH, SAFETY and ENVIRONMENTAL MANAGEMENT SYSTEM

Comprising of ISO 14001:2004 and OHSAS 18001:2007 Standards This manual is a property of

Telcon International Marine Services LLC

P.O. Box 93781, Al Jadaf, Dubai, United Arab Emirates. COPYRIGHT No part of this manual may be reproduced in any form by print, photocopy, microfilm or any other means wholly or in part or disclosed to any person outside Telcon Internationals Marine Services LLC without the written permission of the Management.

REVISION SHEET Nature of Revision

Revision Number

Date

Originated/ Revised by

Reviewed by

Approved By

0

01/02/2009

Origination

Chandramoha n

Manoj

Manoj

B B B MANUAL HOLDERS LIST Copy Number HSE01 HSE02 HSE03 HSE04 HSE05 HSE06 Document Holder Managing Director/ Commercial Director

MR

Sales / Marketing

Admin / HR

Finance / Accounts

Procurement / Stores

HSE07 HSE08

Operations Projects / QHSE

LIST OF CONTENTS Description of the HSE Management System Manual Management System Procedures Scope Reference Publications Terms and Definitions HSE Management Requirements General Requirements Policy Planning Planning of Hazards/Aspects Identification, Risk/Impact Assessment and Controls Measures Legal and other Requirements Objectives and Targets Management Programs Implementation and Operations Structure and Responsibilities

Training, Awareness and Competency Communications and Consultations Documentation Document and Data Control Operation Control Emergency Preparedness and Response Checking and Corrective Actions Performance Monitoring and Measurement Evaluation of Compliance Nonconformance, Corrective and Preventive actions Records Internal Audit Management Review Appendices Annexure 1 ­ HSE Policy Annexure 2 ­ Organization Chart Description of HSE Management System Manual This HSE Manual is a property of Telcon International Marine Services LLC, Dubai, UAE for the compliance of Health, Safety and Environmental Management Systems in line with the international standards of ISO 14001:2004 and

OHSAS 18001:2007 and will be hereafter defined as HSE Management System or HSEMS.

The TIMS HSE Management System has been developed to provide detailed information and resources required to effectively manage Health, Safety and Environment. All the relevant policies and objectives are defined and clearly stated. The organizational structure and associated responsibilities for all parts of the business are highlighted and the arrangements put in place (e.g. standards, procedures, rules and regulations, etc.) to ensure that all policies are implemented, controlled, monitored and improved as required. The implementation of and compliance with HSE Management System is the responsibility of all personnel. The manual provides the means of enabling everyone to fulfill that responsibility and meet the specified HSE objectives. The HSE Management System is comprised of the following: corporate policy statement and standards, procedures, checklist and other associated documentation. B. Management System Procedure

Scope The scope of Telcon International Marine Services LLC includes "Provision of marine services including tanker vessels / storage tanks cleaning, scaffolding, sand blasting, hydrotesting, painting & rental of waste management equipments." Reference Publications This document ­ HSE Manual is made based on the reference and the requirements of ISO 14001:2004 and OHSAS 18001:2007 standards. Documents related to this HSE manual include: Health, Safety and Environmental Manual (HSEM) HSE Management System Procedures (HSEMSP) HSE Operational Control Procedures (HSEOCP) HSEMS Forms(HSEF) Terms and Definitions For the purpose of this document, the following terms and definitions apply.

3.1 TIMS HSEMS HSEM HSEMSP HSEOCP STANDARDS MD MR OM GM AI HSEC MSDS Telcon International Marine Services LLC Health, Safety and Environmental Management System Health, Safety and Environment Manual HSE Management System Procedures Health, Safety and Environment Management System Operational Control Procedures ISO 14001:2004 and OHSAS 18001:2007 Managing Director Management Representative Operations Manager General Manager Administrationincharge HSE Coordinator Material Safety Data Sheet Terms

PPE 3.2. Accident Audit

Personal Protective Equipment

Definitions An unplanned event giving raise to death, ill health, injury, damage or other loss to the property and environment. A systematic examination to determine whether activities and related results conform to planned arrangements and whether these arrangements are implemented effectively and are suitable for achieving the organization's policy and objectives. Approval granted to an employee by his Department Head/Supervisor for the purpose of performing a service. Process of enhancing the HSE management system, to achieve improvements in overall HSE performances, in line with the organization's HSE Policy. A set of service supplied and invoiced by suppliers of TIMS. Activity performed by a qualified and competent organization applying its own methods in accordance with the terms and contract between TIMS and the supplier. The document which is prepared, reviewed, approved, distributed and revised in a controlled manner to ensure that the right document will be available and to avoid use of obsolete documents. Action taken to eliminate the causes of a detected nonconformance in order to prevent recurrence. The surroundings in which an organization operates, including air, water, land, natural resources, flora, fauna, humans and their interrelation. An element of an organization's activities or products or services that can interact with the environment. Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization's environmental aspects. Any document used for reference apart from the HSE Procedure (e.g. service specification, standards like ISO 14001) A source or situation with a potential for harm in terms of injury or ill health, damage to property, damage to environment or a combination of these. A process of recognizing a hazard/aspect and defining its characteristics. The part of the overall management system that includes organizational structure, planning, activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing, and maintaining HSE standards.

Authorization Continual Improvement Contract

Controlled Document Corrective Action Environment Environmental Aspect Environmental Impact External Document Hazard Hazard/Aspect Identification HSE Management System

HSE Objectives HSE Team

Goal, in terms of HSE performance, that an organization sets itself to achieve. A group of employees (department heads/staff and QHSEC) of the organization who implements, communicates and maintains the HSE management system requirements and top management vision/commitment. An individual or group concerned with or affected by the HSE Management System performance of the organization. Unplanned event which has the potential to lead to accident. A group of management comprising of MD, department heads/managers and QHSEC for ultimate decision making for implementation of HSE Management system. Action of controlling and verifying that activity, services, products, etc. are as required. Any deviation from work standards, practices, procedures, regulations, management system performance etc. that could either directly or indirectly lead to injury, or illness, property damage, damage to environment, or a combination of these. Overall intentions and direction of an organization related to its HSEMS performance as formally expressed by top management. Action taken to eliminate the cause of potential nonconformity, defect or other undesirable situation in order to prevent recurrence. The procedure contains instructions for carrying out activities under the control of the system. Document stating results achieved or providing evidence of activities performed. Any document recounting the result of an activity performed by a person, department, section or unit. The time period up to which the record shall be kept before it is either discarded or destroyed. A combination of the likelihood and consequence(s) of a specified hazardous event occurring. An overall process of estimating the magnitude of risk and deciding whether or not the risk is tolerable. A freedom from unacceptable risk of harm. Fundamental deficiency that results in a nonconformance and must be corrected to prevent recurrence of the same or similar nonconformance. The document, preparation, review, approval, distribution and revision of which are not necessary to be done in controlled manner.

Interested Parties Incident Management Team

Monitoring NonConformance

Policy Preventive Action Procedure Record Report Retention period Risk Risk Assessment Safety Root Cause Uncontrolled Document

4. HSE Management System Requirements 4.1. General Requirements 4.1.1 Telcon International Marine Services LLC Organization Telcon International Marine Services LLC (TIMS) employees dealing with particular areas of work and responsibility and is supported by the Management Team are identified. Relevant procedures outline the activities and processes for each area of work. TIMS maintains an organization chart showing the organization structure. (Annexure 002). 4.1.2 Company Profile We TELCON INTERNATIONAL MARINE SERVICES LLC., under TELCON GROUP is one of the leading Marine and Industrial/Oil fields tank cleaning company in the UAE, established in the year 1997 with registered offices in most of the Emirates. In Marine field we are registered contractors for Vela International, Dubai Dry Docks, MIS, Lamprell and various commercial vessel owners and shipping agents. In Industrial tank farms we are the contractors for Shell Market (ME) Limited, Horizon Fze, Eppco, Enoc and various small and medium type tank farms. We have an established our registered office in Al Jadaf Ship Dockyard in Dubai, with a aspirate office and 10000 sq. ft workshop space. Our group head office in Sharjah Clock Tower Building and separate registered offices in Abu Dhabi, Fujairah and Ras Al Khaimah. In addition to the above workshop space we are holding additional warehouse and fenced yard facility in Sharjah. We can mobilize our workforce to attend a site anywhere in the Arabian Gulf. If the situation demands we put riding crews on board to carry out voyage repairs. Almost 85% of the labour trained from Dubai Dry Dock, MIS and Lamprell. Near to 10% workers already trained and medically certified for confined space entry. Most of the scaffold technicians are already finished their training from approved third party training consultants. 20% of the cleaners already finished the safety training from Shell and EPCL. 4.2 HSE Policy

HSEMS Policy of TIMS identifies the organization's commitment to excel and achieve a safe working environment within the organization operational structure and continually improve through setting and achieving objectives. The policy is endorsed by the Managing Director of Telcon International Marine Services LLC. Personnel at all functional levels shall be responsible for adhering and contributing in carrying out duties to achieve the same. Reference Document ­ Global QHSE Policy, Annexure001. This policy is reviewed by top management and communicated to all the employees and interested parties of the organization. 4.3 Planning Hazards/Aspects Identification, Risk/Impact Assessment and Controls TIMS establishes and maintains an ongoing procedure for identification of hazard/aspects and the assessment of risks/impacts, and the implementation of necessary and appropriate control measures for routine/normal and non routine/abnormal activities indulging with human occupational health and safety and having access to work place environment. Applicable Procedures ­ Hazards Identification and Risks Assessment, HSEP002 and Aspects Identification and Impact Assessment, HSEP001. 4.3.2 Legal and Other Requirements TIMS establishes and maintains a procedure for identifying and accessing the legal and regulatory requirements as applicable to the HSE management system. The organization monitors, reviews and updates the relevant information on the revisions/changes on legal requirements and ensures the same is communicated to its employees and other interested parties for compliance. Applicable Procedure ­ Legal and Other Requirements, HSEP 003 Reference Procedure ­ Communication and Consultation, HSEP 006 4.3.3 Objectives and Targets TIMS establishes and maintains its objectives and targets with the help and advice

from top management at each relevant function or activities in the organization. This is reviewed by the management at planned intervals for necessary updates and improvements. TIMS takes into account of the following during phrasing the objectives and targets: legal and other requirement significant aspects and impacts, technological and financial options, operational, and business requirements, the views of interested parties and output of management review meeting TIMS shall establish and maintain documented objectives and targets at different levels of the company. Actual performance against specified targets shall be measured and documented quarterly. The specified objectives and targets shall be consistent with and reflect corporate HSE objectives. Corporate Objectives: TIMS is committed to achieve the following HSE objectives: To prevent accidents and incidents at the workplace and to ensure that where they occur, preventive measures are taken to prevent recurrence. To promote the health and safety of all its employees and all others affected by its operation. To provide a healthy workplace for all its employees. To protect the environment by ensuring that all emissions and discharges which have a negative effect on the environment are eliminated and controlled. The establishment and maintenance of safe and environmentally sound working practices and procedures for all its operations. To set a high level of health, safety and environmental standards and performance and to provide training to employee to enable them to meet these. To create an awareness of sound, health and environment working practices in all its employees. To maintain and improve the competency of the employee. The provision and maintenance of all facilities, plant and equipment in a safe condition for operational use. To comply with all UAE legislative and statutory requirements concerning health, safety and environment protection. To set standards which demonstrate commitment to health, safety and environmental protection in all aspects of its operations and which at minimum, meet the relevant local statutory and customer requirements for health, safety and environmental matters as these may affect its own employees and others. The provision and maintenance of effective response procedures and contingency plans for any emergencies.

The maintenance of an effective review and monitoring system to enable needs and trends analyzed, performance measured and swift effective action taken as and where necessary. The maintenance of an effective system of joint consultation and communication between all employees, on all matters concerning health, safety and environmental protection. The provision of competent advice and support to line management to enable them to achieve health, safety and environmental protection objectives. Local Objectives: The company shall set specific and quantitative objectives and targets for health, safety and environment aspects. The objectives shall have the following characteristics: Specific Measurable Achievable Realistic Time bounded 4.3.4 Management Programs TIMS management establishes and maintains the applicability of management program(s) for achieving the company's targets and objectives involving designated responsibilities and authorities at relevant functions and levels. TIMS shall establish and maintain annual HSE plans. The yearly plan will reflect the following: HSE objectives and targets Personnel responsible for achieving objectives and targets The means and time scale by which they are to be achieved The management also ensures that the management program(s) are reviewed regularly at planned intervals as deemed necessary. 4.4 Implementation and Operations 4.4.1 Structure and Responsibilities 4.4.1.1 Roles and Responsibilities

The ultimate responsibility for the HSE management system of TIMS rest with line management through Top Manager through to every employee. The organizational chart shows the interrelationship of positions and functions within TIMS and the path of responsibility and authority in relation with management systems. The responsibility, authority and interrelationship of every employee who manages, performs and verifies work affecting health, safety and environment are defined as below. At all levels of the organization personnel must be: Responsible for the health and safety of those they manage, themselves and others with whom they work with; Responsible for the protection of the surrounding environment and conservation of natural resources; Responsible for the health and safety of persons who may be affected directly or indirectly by the activities they control, e.g. contractors and members of the public; Aware of the influence and effect that their acts or omissions could have on the effectiveness of the HSE Management System. Top Management is particular have the responsibility of leading by example by demonstrating their commitment through their active involvement in achieving continual improvement of HSE performance. Demonstration of this commitment will be achieved by the active involvement of senior management in the following elements of the HSE Management System within their areas of control: Ensuring that the HSE Management System requirements are established, implemented and maintained in accordance with ISO 14001 and OSHAS 18001; Ensuring compliance with all statutory requirements; Ensuring compliance with all client requirements; The setting of targets and objectives, and making all personnel under their control aware of their responsibilities in the successful achievement of these targets and objectives; The auditing of the HSE Management System to ascertain to the above mentioned standards; Ensuring corrective actions are initiated, implemented and completed to rectify all nonconformances identified from the audit process, and Monitoring and reporting of the performance of the HSE Management System for management review and the subsequent for improvement. LINE RESPONSIBILITIES The responsibility for the health, safety and welfare of all personnel and any other persons who may be affected by our business activities, the protection of the environment from any negative effects, and quality of the provided service is the responsibility of the line management.

Line Management are therefore responsible for the formulation and adoption of safe and environmentally sound working systems, practices and procedures, which comply with the aims and objectives specified in the HSE Policy and with all statutory and clients requirements. Management: It is the responsibility of designated managers that all work activities under their control are carried out in accordance with the HSE Policy through the formulation and adoption of safe and environmentally sound working systems, effective and efficient practices and procedures which meet the HSE standards and comply with all statutory and client requirements. These responsibilities will be met by applied management commitment and active involvement in the following elements of the HSE Management System: The development of HSE objectives and targets to meet HSE standards; The development of plans and programs to meet these objectives and targets; The auditing of these plans and programs, measuring progress, identifying deficiencies and ensuring corrective actions and any shortcomings in performance are rectified; The development of appropriate controls to ensure that all activities are carried out in accordance with the arrangements specified in the HSE Management System Manual; The development and maintenance of effective emergency response procedures and ensuring all personnel under their control are made aware of their specific responsibilities in the event of an emergency; Ensuring that all personnel under their control are made aware of their individual HSE responsibilities and are assessed against these responsibilities; The proper training of all personnel under their control to a level of competence which enables them to carry out their duties to the required standards of health, safety and environment protection; The selection and use of subcontractors who meet HSE standards and the monitoring of their work to ensure these standards are met and maintained; Ensuring that all incidents involving, or having the potential to cause injury to persons, or damage to property, equipment or the environment, are thoroughly investigated and reported. The aim being is to identify both immediate and basic causes as a means of preventing recurrence; Ensuring all corrective and followup actions from incident investigation reports are initiated and reported; Ensuring all customer complaints are reported, followedup, analyzed, and proper action taken for correction; Ensuring that any deficiencies in equipment, standards and operational procedures are rectified; Ensuring suitable arrangements are made for effective communication and consultation on all HSE matters to supervisors, employees and contractor personnel; Leading by example and developing a high degree of HSE awareness among all

personnel; Assuring effective communication and liaison with the HSE Department to obtain the information, advice and guidance required in order to meet the above listed responsibilities; Ensuring assessments of all hazardous substances in use availability to all relevant personnel; Ensuring that all personnel are aware of the processes which involve the use of hazardous substances and that personnel take the necessary precautions to prevent exposure; and Ensuring that all personnel are trained to use, handle and store all hazardous substances and are aware of any contingency plans in place and how to implement them. Supervisors: It is the responsibility of supervisors to ensure that all work activities under their control are conducted properly, safely and in a manner which has no negative on the environment. This will be achieved by ensuring that: All statutory and client requirements are met; They are actively involved in the implementation of all HSE plans and programs and fully understand their role in the implementation process; All personnel under their control are appropriately trained; All personnel under their control are made aware of the actions and responsibilities required of them in the event of an emergency; All personnel under their control are aware of the hazards associated with their work activities with regard to health, safety and environmental and environmental protection; All personnel under their control carry out their duties in accordance with HSE standards; Equipment is maintained in a safe condition and in good working order. All incidents involving, or having the potential to cause injury to persons, or damage to property, equipment or the environment are reported and thoroughly investigated. They, at all times, lead by example, showing visible commitment and active participation in achieving continual improvement in HSE standards; They assure effective communication and consultation with all personnel under their control to encourage their commitment and active participation in achieving continual improvement in HSE standards; They will ensure that hazardous substances are issued in a restricted manner and that data sheets are available to all personnel using these substances prior to any work taking place. Employees: All TIMS employees have the responsibility to ensure that they carry out their duties in a manner which does not cause harm to themselves or any other person who may be

affected directly or indirectly by their action and will not have negative effect on the environment. It follows from this that all personnel have the right, and a duty, to refuse to carry out any work activity which is demonstrably unsafe and that it has the potential to affect or cause harm to themselves, others, to the environment, and quality of the service/product. Stop the job immediately if there is a doubt about the safety of the operation, or the impact it may have on people or the environment to assess the hazards and control the risks. To fulfill these responsibilities all personnel must ensure that: They perform their work in accordance with the HSE Policy, standards and procedures; They are aware of the emergency procedures and the actions and responsibilities required of them in the event of an emergency; They cooperate fully in the implementation of HSE plans and programs; They report immediately to their supervisor details of any incident or any situation which has the potential to cause harm to themselves, others or the environment; They keep their work areas clean, tidy and ensure that all emergency routes/exits and fire fighting equipment remain unobstructed; They must not misuse any item provided to them for their health, safety or protection of the environment, and must report any loss or damage immediately; They must make full and proper use of any control measures, including personal protective equipment, and to report any loss or defect to their supervisor; They will use, handle and store hazardous substances in the prescribed manner; They will cooperate fully in the monitoring of the workplace. HSE Department: The HSE Department has the following responsibilities: Custodian of the HSE Management System; The provision, review, and update of all HSE documents, including statement of policy, the HSE Management System Manual and all relevant standards and procedures; The monitoring and auditing of management performance on statutory requirements; The provision of information within the organization on statutory requirements, approved codes of practices and company standards; The provision, maintenance and monitoring of the effectiveness of emergency response procedures and contingency plans; The establishment and maintenance of HSE training standards; The initial assessment of subcontractors to ensure they meet the required HSE standards and the subsequent monitoring and auditing of subcontractors to ensure the standards are maintained; The monitoring and review of the reporting, investigation and followup to incidents; The recording and dissemination of incident information and statistics;

The provision of advice and assistance in the areas of emergency response, operational safety, HSE management, unsafe acts/condition auditing, incident analysis, HSE training, environmental protection, waste disposal, hazard management, environmental impact assessment; The assurance that all MSDS are updated and revised on a regular basis; The assistance and support to clients and external bodies during the auditing of the HSE Management System and ensure that any deficiency highlighted is rectified in an effective and timely manner. 4.4.2 Training, Awareness and Competency TIMS establishes and maintains a procedure for identification and selection of competent personnel to perform specific tasks in related activities to create a safe work environment within the company. TIMS personnel shall receive training of a specific type and level that is appropriate for their routine and emergency work assignments, in compliance with the requirements of the company as stated in Training Procedure. If need arises for specific/specialized training requirement, external training programs are organized with approval of the MD/MR who is responsible for identifying training needs and revalidation of training program. Personnel performing specific tasks are assigned and qualified on the basis of education, training and experience against the position's competence and qualifications specified in the job descriptions. Effectiveness of training is determined by assessment and certification, interview and observation of performance. Training needs are discussed and identified at the management review, and plans drawn up. Applicable Procedure ­ Competency, Awareness and Training, HSEP007. 4.4.3 Communications and Consultations Effective communication is an essential element of HSE Management System. This refers to the communication of information within the organization but also to/and from external sources (clients, legal authorities, contractors, public, etc.). TIMS has established a procedure to communicate within the organization and interested parties the following: HSE policy; Objectives and targets; Significant aspects/impacts; Legal requirements;

Organizational requirements. TIMS will utilize all means available to facilitate the effective communication of information, both formal and informal, i.e. written, verbal (meetings, telephone, presentations, seminars), electronic (internet, telefax, video presentation), visual (overheads, posters, etc.) Applicable Procedure ­ Communication and Consultation, HSEP006. 4.4.4 Documentation Structure The Organization HSEMS documentation consists of three levels as follows: Level 1 HSE Management System Manual (HSEM) describing the overall activities of TIMS briefing the company history, commitment to the HSEMS. Level 2 HSE Management System Procedures (HSEMSP's) to meet the requirements of international standards and organizational requirements. Level 3 ­ HSE Operational Control Procedures (HSEOCP) which identify approaches to managing taskoriented activities that relate to HSE MS hazards/aspects and risks/impacts. Level 4 consists of records and HSE MS Forms relating to level 2 and 3 documentation. 4.4.5 Document and Data Control MR manages the preparation, review, approval, distribution and update of documents associated with the HSEMS. Document Control is made to ensure that the correct versions are available for issue or use and to prevent the use of obsolete documents or incorrect information. Documents are reviewed and approved to ensure that they are fit for the intended use and any subsequent changes are also subject to a revision, review and approval process prior to distribution. In addition, TIMS applies controls to the receipt and distribution of relevant external documents such as standards, industry codes, product specifications and literature, federal rules and regulatory requirements. This includes identifying the latest versions of documents and clearly marking obsolete documents when retained for reference purposes. Applicable Procedure ­ Control of Documents, HSEP004.

4.4.6 Operation Control TIMS has established and maintained documented procedures: For those situations where the absence of a procedure could lead to deviations from the HSEMS policy, objectives and targets. Related to the identified HSE hazards/aspects of goods, equipment and services purchased and/or used by the organization. For design of workplace, process, installations, machinery, operating procedures and work organization, including their adaptation to human capabilities in order to eliminate or reduce environmental impacts at their source. Procedures are reviewed and revised based upon corrective and preventive actions recommended as the result of incidents or as an audit outcome. Emergency Preparedness and Response TIMS has established and maintained plans and procedures to identify the potential for, and response to incidents and emergency situations, to prevent and mitigate the likelihood of HSE risks/impacts. to review emergency preparedness, response plan and procedure after the occurrence of an incident or emergency situations. to test the practical effectiveness of the same. Applicable Procedure ­ Emergency Preparedness and Response, HSEP009. 4.5 Checking and Corrective Actions 4.5.1 Performance Monitoring and Measurement TIMS has established and maintained procedure to monitor and measure HSEMS performance on regular basis. This procedure includes: Qualitative and quantitative measures appropriate to the needs of the organization; Monitoring of the extent to which organization's HSEMS objectives are met; Proactive measures of performance that monitor compliance with the HSE management program, operational criteria and applicable legislation and regulatory requirements; Reactive measures of performance to nonconformances and other historical evidence of deficient HSEMS performance; Recording of data and results of monitoring and measurement sufficient to facilitate subsequent corrective and preventive action analysis; Calibration and maintenance of monitoring and measuring equipments. Applicable Procedure ­ Performance Monitoring and Measurement, HSEP010.

4.5.2 Evaluation of Compliance MR verifies and monitors organization's compliance with applicable legal regulatory and other requirements on regular basis. Items identified as part of the regulatory compliance audit that suggest a specific lack of compliance is documented and resolved as required by accidents, incidents, nonconformance, corrective and preventive action, HSEP008 and legal requirements, HSEP003. 4.5.3 Nonconformance's and Corrective/Preventive Action TIMS has established, implemented and maintained a procedure for dealing with actual and potential nonconformity and taking corrective/preventive action. This procedure includes: The handling, investigation and determining the root causes of nonconformances Taking action to mitigate any consequences arising from nonconformance and reoccurrences; The initiation and completion of corrective and preventive actions; Confirmation of effectiveness of the corrective and preventive actions; Review through risk assessment for all proposed corrective and preventive actions prior to implementation; Action taken is appropriate to the magnitude of the problems and the HSE risks/impacts encountered. Any changes in the documented procedure resulting from corrective and preventive actions is recorded and implemented. Applicable Procedure ­ Accidents, Incidents, Nonconformance, Corrective and Preventive Action, HSEP008. 4.5.4 Records TIMS has established and maintained procedure for identification, storage, protection, retrieval, retention and disposal of records. These records are legible, identifiable and traceable to the activities involved. Records are maintained, as appropriate to the system and to the organization, to demonstrate conformance to HSEMS and Standards. Applicable Procedure ­ Control of Records, HSEP005.

4.5.5 Internal Audit TIMS has established and maintained procedure for conducting audits at planned intervals: To determine whether the HSE Management system: Conforms to planned arrangements for HSE MS including the requirements of International Standards; Has been properly implemented and maintained; Is effective in meeting the organization policy and objectives; To provide information on the results of audits to management; To review results of previous audits. This procedure includes: the responsibility and requirements for planning and conducting audits, reporting results and retaining associated records; the determination of audit criteria, scope, frequency and methods. Auditors are trained and conduct audits, and are independent of their particular areas of work and responsibility. MR prepares the annual audit schedule and auditors are then required to arrange, conduct, report and followup on their assigned audits. The results of audits are collated and reported by the Management Representative for discussion and followup during Management Review Meetings to ensure any areas of concern or particular opportunities for improvement are addressed. Applicable Procedure ­ Internal Audit, HSEP011. 4.6 Management Review The Top Management along with respective managers reviews the TIMS HSE Management System at planned intervals to ensure it's continuing suitability, adequacy and effectiveness. MR maintains the records of the management reviews. Management review includes: Results of internal audits and evaluation of compliance with legal requirements and with other requirements to which organization subscribes; Communication(s) from external interested parties, including complaints; HSEMS Performance of the organization; The extent to which objectives and targets have been met; Status of corrective and preventive actions; Follow up actions from previous management reviews; Changing circumstances, including developments in legal and other requirements; Recommendation for improvements;

Any decisions and actions related to possible changes to HSEMS Policy, objectives, targets and other elements of the HSEMS, consistent with the continual improvement. Management Review Procedure defines the Management Review Process. Applicable Procedure ­ Management Review, HSEP012. 4.7 Appendices (Attached) 4.7.1 Annexure 1 HSE Policy 4.7.2 Annexure 2 Organizational Chart

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