CEYLON PETROLEUM CORPORATION

MANUAL FOR
THE HEALTH, SAFETY & ENVIRONMENTAL
MANAGEMENT SYSTEM

Document number:

HSE-117258-000 / Revision 0 / 16.10.2015

Project title:

CONSULTANCY SERVICES FOR FEASIBILITY STUDY ON CONSTRUCTING

A JET A1 TRANSFER PIPELINE FROM MUTHURAJAWELA TERMINAL TO
BIA AND ASSOCIATED DEVELOPMENTS (SRI LANKA)

Project Owner:

CEYLON PETROLEUM CORPORATION (CPC)

PREPARED BY APPROVED BY

_____________________ _______________________
P. – M. P. SPANIDIS S. PHILOPOULOS
ASP/RDC Consortium ASPROFOS Quality Manager
Project Manager

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CONTENTS

1. GENERAL – PRESENTATION.............................................................................................................. 3
2. SCOPE – APPLICATION ..................................................................................................................... 4
3. REFERENCES ..................................................................................................................................... 5
4. HSEMANAGEMENTSYSTEM (PART OF THE INTEGRATED MANAGEMENT SYSTEM) ....................... 6
4.1 General ....................................................................................................................................... 6
4.2 HSEPolicy .................................................................................................................................... 6
4.3 Planning ...................................................................................................................................... 6
4.3.1 Risk Identification and Assessment of Hazards to Occupational Health and Safety
and of Environmental Aspects ...................................................................................................... 7
4.3.2 LegalandOtherRequirements ............................................................................................... 9
4.3.3 Objective Targets and Program(s)...................................................................................... 10
4.4 Implementation and Operation................................................................................................ 10
4.4.1 Resources, Roles, Responsibilities, Accountability and Authorities .................................. 10
4.4.2 Competence, Training and Awareness .............................................................................. 11
4.4.3 Communication, Participation and Consultation ............................................................... 12
4.4.4 Documentation .................................................................................................................. 13
4.4.5 Control of Documents ........................................................................................................ 13
4.4.6 Operational Control ........................................................................................................... 14
4.4.7 Emergency Preparedness and Response ........................................................................... 14
4.5 Checking.................................................................................................................................... 15
4.5.1 Monitoring and Measurement........................................................................................... 15
4.5.2 Evaluation of Compliance................................................................................................... 15
4.5.3 Incidents Investigation – Nonconformity, Corrective and Preventive Actions .................. 16
4.5.4 Control of Records.............................................................................................................. 17
4.5.5 Internal Audit ..................................................................................................................... 17
4.6 Management Review ................................................................................................................ 18
ATTACHMENT: Structure of the HSE-related activities of the Integrated Management
System ................................................................................................................................................ 19

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CEYLON PETROLEUM CORPORATION

1. GENERAL

ASPROFOS was established in April 1983, as a joint venture between Hellenic Aspropyrgos
Refinery (HAR) and Foster Wheeler Italiana. In 1988, after completion of the HAR
Upgrading Project, the Company became a wholly owned HAR subsidiary. Since 1998,
ASPROFOS belongs to the Hellenic Petroleum (HELPE) Group of companies, the largest
integrated Greek company in the energy sector.

ΑSPROFOS is a leading engineering and energy consulting company in Southeast Europe

and operates in accordance with internationally recognized standards and practices.

As an independent company, ASPROFOS plays an instrumental role in supporting the

Hellenic Petroleum investment programs, by providing a wide range of services, including
engineering, project management, construction supervision and consultancy, which are
directly associated with the integration and implementation of the Group’s investments to
the existing refining facilities. Provision of similar services, to other clients in Greece and in
other South-eastern European countries, has followed an expanded trend in recent years,
which is linked to the company’s high degree of reputation and solid presence.

In recent years ASPROFOS has accomplished goals set, achieving increased turnover and
profits and has entered into a new period of growth. The company is certified by the new
ISO 9001:2000 Quality Standard, has participated in international bids and has successfully
cooperated with international companies.

Since its establishment, ASPROFOS has been playing an active role in most large energy
infrastructure projects that have been implemented in Greece, by providing a variety of
services, such as basic and detailed engineering, project management and construction
supervision services. Indicative projects include:

 the large scale Greek Natural Gas Project, which involved construction of the
country's high pressure transmission system and an LNG receiving terminal
 the expansion of the gas transportation network to the Greek-Turkish border
 upgrading and expansion projects that have been implemented in HELPE refineries
of Athens (Aspropyrgos & Elefsina) and of Thessaloniki
 the construction of a polypropylene plant in Thessaloniki refinery

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 fuel pipelines in Greece and FYROM

 the 390 MW HELPE power plant in Thessaloniki.

2. SCOPE – APPLICATION

This document is prepared to provide the core elements of ASPROFOS Integrated

Management System (IMS) related to Occupational Health, Safety and Environmental
issues and their interaction and provide direction on the operation of the specific parts of
this management system. The Integrated Management System also encompasses Quality
Management issues, which do not necessarily fall under the scope of this Manual.

IMPORTANT NOTE

This document describes the HSE Policy and HSE Management of ASPROFOS for the
projects it undertakes.

ASP/RDC Consortium declares that will apply this document in the course of the project:

‘’CONSULTANCY SERVICES FOR FEASIBILITY STUDY ON CONSTRUCTING A JET A-

TRANSFER PIPELINE FROM MUTHURAJAWELA TO BIA AND ASSOCIATED
DEVELOPMENTS (SRI LANKA)’’,

taking into consideration all the legal and regulatory requirements of Sri Lanka’s State
regarding the HSE factors, as well as, the requirements of the international codes and
standards related to the establishment, application, development, monitoring and
review of the HSE systems.

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3. REFERENCES

The last revisions of the following documents shall be considered:

ISO 9001 Quality Management Systems, Requirements

ISO 9000 Quality Management Systems, Fundamentals and
Vocabulary
ISO 19011 Guidelines for Quality and/or Environmental
Management Systems Auditing
OHSAS 18001 Occupational Health and Safety Management System,
Requirements
OHSAS 18002 Occupational Health and Safety Management System,
Guidelines for the Implementation of OHSAS 18001:2007
ISO 14001 Environmental Management System, Requirements with
Guidance for use

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4. HSE MANAGEMENT SYSTEM

4.1 General Requirements

The present manuals organized according to the paragraphs of chapter 4 of the OHSAS
18001 (ΕΛΟΤ 1801) and ISO 14001 standards. Any reference to the HSE Management
System should be understood to mean the aspects of the ASPROFOS IMS related to Health,
Safety and Environmental (HSE) issues. Attachment I schematically presents the company’s
Integrated Management System aspects related to HSE issues.

4.2 HSE Policy

AF has accepted a Health, Safety and Environment (HSE) Policy, which is in accordance to
ISO 14001 and OHSAS 18001 as well as to the requirements of Integrated Management
System (IMS) of ASPROFOS.

The Policy is included in ASPROFOS Integrated Management System Manual Volume I

Section 2.

4.3 Planning

The planning of the system for Occupational Health and Safety and Environmental
Management respectively consists of the following phases:

Occupational Health and Safety Environmental Management

 Identification of the hazards  Identification of Environmental
Aspects
 Identification of relevant Laws and  Identification of relevant Laws and
Regulations Regulations

 Evaluation of the hazards and their  Evaluation of the environmental

impact on health and safety aspects and the impacts on the
environment
 Classification of the hazards  Classification of the environmental

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Occupational Health and Safety Environmental Management

according to risk aspects according to risk

 Objectives Setting / Objective sand  Objectives & Target Setting /

Program(s) Objectives, Targets and Program(s)

 Establishing operational control  Establishing operational control

practices to maintain health and practices to maintain and protect
safety at the work place the environment

The following paragraphs of this chapter present the methodology used for:

 Recognition and evaluation of the hazards and the environmental aspects

 Recognition of laws and regulations
 Establishment of goals, aims and programs

The above subjects are analyzed in the relevant ASPROFOS procedure.

4.3.1 Risk Identification and Assessment of Hazards to Occupational Health and Safety
and of Environmental Aspects

For the identification of hazards and environmental aspects two different procedures are
followed as presented in the chart below:

Occupational Health and Safety Environmental Management

 All activities that can impact  Creation of flow charts

health and safety at work are  Identification of the
identified and all related risks are environmental aspects related
taken in to consideration to:
 Routine and non-routine activities;
 Emissions to air
 Activities of all persons having
 Releases to water
access to the workplace

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Occupational Health and Safety Environmental Management

(including contractors and
 Releases to land
visitors)
 Use of primary and natural
 Human behavior, capabilities and
resources
other human factors
 Identified hazards originating  Use of energy
outside the workplace capable of  Energy emissions, i.e. heat,
adversely affecting the health radiation or vibrations and
and safety of persons under the noise
control of the organization  Products and services
within the workplace  Physical attributes such
 Hazards created in the vicinity of assize, shape, color,
the workplace by work-related appearance, etc.
activities under the control of the
organization  The environmental aspects can
 Infrastructure, equipment and be direct or indirect. They can
materials at the workplace, happen in normal or abnormal
whether provided by the conditions and during
organization or others emergencies. They can have a
 Changes or proposed changes in positive or negative impact.
the organization, its activities, or  They are assessed according to
materials the methodology chosen by the
 Modifications to the OH&S company and classified according
management system, including to their severity.
temporary changes, and their
impacts on operations,
processes, and activities any
applicable legal obligations
relating to risk assessment and
implementation of necessary
controls
 The design of work areas,
processes, installations,
machinery/equipment, operating
procedures and work

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Occupational Health and Safety Environmental Management

organization, including their
adaptation to human capabilities
 Risks are assessed and a written
assessment of occupational risks
is drafted considering the
obligations (Law 3850/2010) and
the requirements of OHSAS
18001.

The risk assessment data for occupation a health and safety (Written Occupation al Risk
Assessment) and the environmental aspects are updated regularly and whenever necessary
due to the following:

 Changes to the equipment or activities of the company

 Changes to the mode in which activity is carried out
 Changes in legal or regulatory provisions or new scientific data
 Occurrence of incidents, accidents or emergencies as well as complaints by
outsiders
 Any other factor that can influence the data and evaluation results

4.3.2 Legal and Other Requirements

The second step is the identification of legislative requirements. Applicable legislative

requirements are compiled in the relevant documented procedure.

Defined legislative requirements will provide input to:

 the definition of objectives,

 identification of training requirements to ensure the HSE competency obliged by
legislation is in place,
 preparation of procedures as a part operational control element of the system
mainly to ensure compliance with legislation.

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4.3.3 Objective Targets and Program(s)

Taking into consideration:

 the severity of HSE risks and the hierarchy of environmental aspects

 the company policy, and
 the basic parameters that can affect the performance of the System,

the company establishes objectives, targets and program(s). The objectives and targets are
a result of the Management’s aim and effort to continuously improve the performance and
overall implementation of the System anticipating, preventing and reducing any negative
impact to human health and safety as well as to the environment. Wherever possible the
targets are measureable.

The programs define the actions that the company has to take in order to implement the
objectives and targets that it has set. The programs include:

 Objectives and targets,

 Actions for improvement and personnel responsible to execute them,
 Required means and
 Time schedules and timeframes.

The company has instituted relevant procedure that defines the objectives, targets and
Environmental program(s).

4.4 Implementation and Operation

4.4.1 Resources, Roles, Responsibilities, Accountability and Authorities

ASPROFOS corporate management has appointed specific responsibilities and roles for its
personnel so that the Integrated Management System can be applied and enforced
continuously.

For the proper operation of the Integrated Management System regarding HSE issues,
ASPROFOS corporate management has selectedand appointed distinct representatives

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responsible for the Integrated Management System related to Health and Safety on the
one hand and the Environment on the other.

Especially for occupational health and safety a significant contribution is made by the
statutorily-mandated bodies within the company. The Safety Engineer and the
Occupational Doctor contribute with their own proposals and advice to increase the
company’s aware ness and responsiveness to issues concerning health and safety.

The company’s employees are responsible for adapting and complying with the procedures
that have been established so that all activities are carried out with safety and without risk
to their health, while keeping the protection of the environment in mind.

4.4.2 Competence, Training and Awareness

According to the activities carried out by each employee and the impact, which these
activities can have on humans and the environment, the following factors are examined:

- Academic knowledge
- Experience and skills
- Necessity for provision of additional training which will help improve employee
performance regarding the application of the HSE aspects of the Integrated
Management System, which will reduce the possibility of risks of accidents and as
far as environmental protection is concerned, will anticipate any negative
environmental impact.

All persons that can have an impact on the Occupational Health, Safety and Environment
receive appropriate training before assuming any responsibilities. This training is named
introductory training.

Through the course of each year the following activities are carried out:

- Internal training by specialized company personnel

- External training by recognized educational institutions

Training needs and requirements can come about as result of various factors such as:

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- Taking on new activities or projects or change of domains of activity

- Changes in laws or regulatory provisions
- Changes in organizational structure
- Retraining of personnel in order to maintain a high degree of awareness
- Incidents and nonconformities

The training requirements and needs are presented to the Management in order to acquire
adequate resources and approval to plan their implementation.

The company has established documented procedures relevant to training, skills and
experience.

4.4.3 Communication, Participation and Consultation

Company issues regarding matters related to Occupational Health, Safety and the
Environment are communicated to the company’s personnel and to all external parties
concerned. This communication may encompass:

- Issues that have arisen as a result of applying the system

- Issues that have come about due to legal and regulatory requirements
- Issues raised by competent authorities, clients or other relevant parties.

Issues arising from communication related to the Integrated Management System are
reviewed during the annual Management System review (see paragraph 4.6 below).

Internal communication issues regarding occupational health and safety are of particular
interest. The employees and the established bodies (i.e. Safety Engineer, Occupational
Doctor) consult with Management on a quarterly basis. The personnel’s opinion and their
participation regarding the improvement of the System are taken into serious
consideration.

The company has established documented procedures relevant to the above.

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4.4.4 Documentation

Documentation of the Integrated Management System related to HSE issues includes the
following:

- The Occupational Health, Safety and Environment Manual

- Procedures
- Work Procedures
- Printed Material

The company has established documented procedures relevant to the System’s

documentation.

4.4.5 Control of Documents

The company has established a procedure regarding documents control. The documents
issued by the company are divided as follows:

- Internal documents (documents created by the company for its needs)

- External documents (documents the company acquires from third parties which
influence the system’s operation such as legislation, permits, etc.)

Through this procedure the company has defined the way in which it:

- Issues and approves documents

- Follows and distributes documents
- Revises and reissues documents

Whenever deemed necessary, the System’s documents are reviewed and updated,
especially in cases due to operational or legislative changes.

The company has established documented procedures relevant to Document Control.

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4.4.6 Operational Control

The company identifies the operations and activities related to the identified risks to
occupational health and safety as well as environmental aspects.

The inspection of activities related to identified risks to occupational health and safety as
well as identified environmental risks contain the established practices which reduce
negative and increase positive impacts and repercussions to humans and the environment.
These practices may contain:

- Rules of established practices necessary to avoid negative consequences in the

application of the Integrated Management System in Health, Safety and
Environmental issues.
- Inspection of the activities of personnel, collaborators and procurement.
- Establishment of criteria, deviation from which may cause non-conformity.

The company has established documented procedures relevant to Operational Control.

4.4.7 Emergency Preparedness and Response

Emergencies are natural or technical conditions that can lead to dangerous situations to
humans and the environment. Emergencies are identified during the design of the system.
These can include the following:

- Natural disasters caused by earthquakes or floods

- Accident prone situations resulting from fire or gas / liquid emissions.
- Other situations

The company has developed scenarios to confront each identified company emergency.
Emergency readiness exercises are scheduled to take place on a regular basis.

Emergency response scenarios are updated on a regular basis.

The company has established a procedure relevant to response to emergencies.

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4.5 Checking

4.5.1 Monitoring and Measurement

The company has established a system that monitors and measures parameters that have
substantial repercussions to occupational health and safety and to the environment. These
measurements pertain to the performance of the System and can refer to:

- Established indicators for monitoring aims, goals and programs

- Consumption of environmental parameters (i.e., resources, waste production,
energy parameters, etc.).
- Measurements of natural and harmful factors to health and safety during work
- Monitoring of incidents, health and safety issues, emergencies and non-
conformities.
- Other parameters related to the effectiveness of the System.

Wherever measuring equipment is used, it should be examined for its reliability (calibration
/ precision).

The company has established a procedure relevant to the above.

4.5.2 Evaluation of Compliance

The company is committed to apply the laws and regulatory provisions regarding
occupational health and safety and the environment. Compliance to all these provisions is
examined:

- During the daily application of the System by monitoring the criteria that have been
set on the operational activities and are a result of the legal and regulatory
provisions
- During regular inspections for conformity with statutes (laws and permits) and
practices which are executed on the basis of Internal Audits and Inspections
- During the evaluation of new laws and regulatory provisions or amendments

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Records from evaluation results regarding compliance are kept and reviewed during
Management Review (see paragraph 4.6 below). In the event of diversions, Management
takes all necessary actions to eliminate them so that compliance with the statutory
provisions is ensured.

4.5.3 Incidents Investigation – Nonconformity, Corrective and Preventive Actions

4.5.3.1 Incidents investigation

Incidents investigation refers only to matters concerning Health and Safety.

Incidents are events related to work that have caused or have the possibility of causing a
work related accident or occupational disease (regardless of severity) or even death. These
incidents are classified as follows:

- Identified work accidents or occupational diseases

- Situation which came close to being hit or calling for an emergency
- Emergencies

On the basis of the investigation the following are examined:

- Determination of basic deficiencies in the System that can lead to an incident

- Recognition for the need to take corrective actions
- Recognition of opportunities to take preventive actions and continuous
improvement
- The method and informing the results of the investigation

The management of incidents (taking corrective and preventive actions) is undertaken

according to the following paragraph.

4.5.3.2 Non-Conformity, corrective and preventive actions

The company has created an appropriate documented procedure in order to identify not
only non-conformities, but also opportunities for improvement. After the identification of
the non-conformities, possible future non-conformities or opportunities for improvement,
the following actions are taken:

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- An analysis of the possible causes takes place

- The possible causes are evaluated as well as the need to take action
- The appropriate actions, the responsible parties and the time schedule for the
implementation of these actions are defined

Upon completion of the actions, their traceability is verified.

4.5.4 Control of Records

The records are the total of the evidence of implementation of the Integrated
Management System produced. The records:

- Are recognized in every relevant procedure

- Remain protected and recoverable (especially for electronic records)
- Are preserved by the suitable person in charge for a specified time
- Are legible, identifiable and traceable

The company has established a documented procedure relevant to the management of

documents.

4.5.5 Internal Audit

Internal audit is the IMS application evaluation and verification activity which the company
undertakes with independent auditors appointed by Management. The auditors can be
trained company personnel or external collaborators.

Internal audits are programmed and take place according to the relevant documented
procedure and can have the following as aims:

- The evaluation of compliance to the law and regulatory provisions

- Conformity with the requirements of the OHSAS 18001 and ISO 14001 standards
- Conformity with the HSE requirements of the Integrated Management System
which the company is committed to implement

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The frequency of audits can vary according to the variance shown by each activity and
registered findings / non-conformities during the year or from previous non-conformities.
The frequency of audits cannot be less than once per year for all company activities

4.6 Management Review

The Management’s review is one of the basic elements of the Integrated Management
System. The review takes place at least on a yearly basis and its agenda includes as a
minimum the issues stated in paragraphs 4.6 of the OHSAS 18001 / ISO 14001 standards.
Apart from those, the following issues are also included:

- The results from the internal and external audits

- The evaluation of the compliance results regarding laws and other regulatory
provisions
- Communication (internal / consultations and external)
- The performance of the Integrated Management System regarding HSE, as well as,
the progress of the objectives / targets and program(s)
- The status of the corrective and preventive actions, the non-conformities and
incidents
- Changes, deriving from any origin, that can have an impact on the System
- Follow-up actions from previous management reviews
- Proposals for improvement

The reviews bring about an improvement to the System and clarify needs for resources and
for updating of the policies and objectives/targets.

Management Review is covered by a relevant ASPROFOS documented procedure.

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ATTACHMENT: Structure of the HSE-related activities of the Integrated Management System

CONTINUOUS IMPROVEMENT OF THE

HEALTH AND SAFETY & ENVIRONMENT RELATED ASPECTS
OF THE INTEGRATED MANAGEMENT SYSTEM

§ 4.2 HSE POLICY

LAWS CERTIFICATION
REGULATIONS § 4.3 PLANNING § 4.6 MANAGEMENT REVIEW SANCTIONS
STANDARDS - Environmental Aspects
- Risk Recognition & Evaluation
And Definition of Control § 4.5 CHECKING
Measures - Measurement and Monitoring CLIENTS
CLIENTS - Legal Requirements - Investigating Incidents, Non- PUBLIC
PUBLIC - Objectives, Targets, AUTHORITIES
Conformities, Corrective and
AUTHORITIES Program(s) Preventive Actions
- Evaluation of Compliance
- Internal Audits
COMMUNITY -Control of Records COMMUNITY

§ 4.4 IMPLEMENTATION AND

OPERATION
- Resources Involved SATISFACTION
REQUIREMENTS - Communication SYSTEM
- Operation Control
INCOMING - Documentation and Control of PERFORMANCE
Documents
- Confronting Emergencies

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