H S E M

HSE MANUAL
Document Number: MAN1008
INDEX
1.
2.
3.
4.
OBJECTIVE ........................................................................................................................................... 2
SCOPE ................................................................................................................................................... 2
REFERENCES ....................................................................................................................................... 2
RESPONSIBILITIES............................................................................................................................... 3
4.1
4.2
4.3
5.
6.
7.
8.
Employer’s OHS Responsibilities.........................................................................................................................3
Employer’s Environmental Responsibilities .........................................................................................................3
Employee’s Responsibilities.................................................................................................................................4
QAS POLICIES AND OBJECTIVES ...................................................................................................... 4
MANAGEMENT COMMITMENT, RESPONSIBILITY AND REVIEW...................................................... 4
AUDIT REQUIREMENTS ....................................................................................................................... 4
EMERGENCY REQUIREMENTS AND RESPONSES............................................................................ 5
8.1
8.2
8.3
8.4
8.5
8.6
8.7
8.8
8.9
9.
Emergency Response Team (ERT) .....................................................................................................................5
Emergency Initial Response Guide (EIRG) .........................................................................................................5
Raising The Alarm................................................................................................................................................6
Reporting the Emergency ....................................................................................................................................6
Alert ......................................................................................................................................................................6
Evacuation............................................................................................................................................................6
Emergency Assembly Areas ................................................................................................................................6
Evacuation Training .............................................................................................................................................7
Emergency Management Training .......................................................................................................................7
MANAGING ACCIDENTS/INJURIES/ILLNESSES/HAZARDS .............................................................. 7
9.1
10.
10.1
10.2
10.3
10.4
10.5
10.6
11.
11.1
11.2
11.3
12.
12.1
12.2
12.3
12.4
12.5
13.
13.1
13.2
13.3
14.
Reporting Procedure ............................................................................................................................................7
RISK ASSESSMENT.......................................................................................................................... 7
Assignment of Responsibilities and Resolution of Hazards.................................................................................8
Incident Investigation ...........................................................................................................................................8
Hierarchy of Controls ...........................................................................................................................................9
Generation of Recommendations and Resolution .............................................................................................10
Selection of a Resolution ...................................................................................................................................10
Closure ...............................................................................................................................................................10
TRAINING ........................................................................................................................................ 10
Identification of Training Needs..........................................................................................................................10
Induction Requirements .....................................................................................................................................11
Safe Operating Procedures (SOP).....................................................................................................................11
FITNESS FOR WORK ...................................................................................................................... 11
Pre-Employment Medicals .................................................................................................................................11
Prior Medical Conditions ....................................................................................................................................11
Hearing...............................................................................................................................................................12
Tetanus ..............................................................................................................................................................12
Smoking .............................................................................................................................................................12
INJURY MANAGEMENT.................................................................................................................. 12
First Aiders .........................................................................................................................................................12
First Aid Boxes ...................................................................................................................................................13
Rehabilitation......................................................................................................................................................13
CONTRACTOR MANAGEMENT...................................................................................................... 13
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Page 1
1. OBJECTIVE
The purpose of this document is to ensure all KMI personnel have the necessary information and policies
required to manage the safety and environmental performance of the organisation.
The methodology and responsibilities in this document have been designed to ensure that KMI provides and
maintains a healthy and safe working environment, to comply with all applicable Occupational Safety and
Health (OHS) Regulations, and manage all environmental requirements.
2. SCOPE
This Health, Safety and Environment (HSE) Manual covers all KMI sites and applies to all operations of the
company.
2.1 ABBREVIATIONS
OS&H Occupational Safety and Health.
HSE Health, Safety and Environment.
EMS Environmental Management System.
QMS Quality Management System.
ERT Emergency Response Team.
EIRG Emergency Initial Response Guide.
HSEQ Health Safety Environmental Quality.
SOP Safe Operating Procedure.
PPE Personal Protective Equipment.
QMR Quality Management Representative.
3. REFERENCES

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Occupational Safety and Health Regulations 1996 (Western Australia)
Occupational Safety and Health Act 1984 (Western Australia)
Environmental Protection Act (Western Australia)
Relevant Acts, Regulations, Legislation Laws and Standards.
These documents are located on the K:/ drive for viewing.
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4. RESPONSIBILITIES
4.1
EMPLOYER’S OHS RESPONSIBILITIES
KMI obligations relating to the safety of personnel on site can be described under two main headings;
 Statutory requirements
 Common Law duty of care
Statutory safety requirements are found in a number of Acts and Regulations identified in the organisations
Legal Register.
Obligations under the duty of care require KMI to;
a)
b)
c)
d)
e)
Provide a safe place of work,
Provide a safe system of work,
Provide and maintain a safe plant and equipment,
Provide competent staff to manage and supervise the work and employees.
Provide instruction and training.
More specifically, all KMI Managers and Supervisors will:

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4.2
Remain directly responsible for the health and safety of their employees.
Comply with applicable HSE laws and regulatory requirements.
Fulfil all HSE responsibilities and accountabilities as directed by KMI.
Implement effective HSE systems, procedures and work instructions.
Provide and maintain a safe and healthy working environment for all employees.
Provide and maintain safe systems of work, equipment and materials for all activities.
Ensure all workplace risks are assessed and controlled.
Ensure employees are provided with appropriate training, instruction, information, supervision and
protective equipment.
Report, investigate and follow-up all incidents promptly.
Take all reasonable steps to actively manage any injured employee, including facilitating their return
to work as soon as practicable after an injury or illness.
Complete, document and monitor the effectiveness of all corrective actions and risk controls.
Ensure the best fit is achieved between employee capabilities and physical job demands.
Demonstrate continuous improvement in OS&H performance and injury prevention.
EMPLOYER’S ENVIRONMENTAL RESPONSIBILITIES
AS/NZS ISO 14001:2004 specifies that requirements for an Environmental Management System (EMS)
enable an organisation to develop and implement a Policy and Objectives which take into account legal
requirements and other requirements to which the organisation subscribes, and information about significant
environmental aspects. Although KMI is not certified to ISO14001, the company aims to satisfy the
requirements as part of its business operation.
Consideration is given to:
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Reclaim, reuse and recycling (waste management);
Emissions to air;
Treatment of water waste;
Control of hazardous material;
Protection of drains from contamination and spills;
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Housekeeping;
Site inspections; and
Packaging and transportation.
A site safety and environment inspection is conducted monthly. The data is uploaded onto the ERP under
the appropriate KMI NCR. Any actions required are entered on the ERP as an audit and assigned to the
appropriate person until resolved.
Planning and execution of site inspections is the responsibility of the relevant Managers.
4.3
EMPLOYEE’S RESPONSIBILITIES
All personnel have a legal responsibility to work safely and take reasonable care for the safety of others and
themselves.
This responsibility extends to the enforcement of the organisation’s HSE policies as described in this
document.
It is a requirement of employment that every KMI employee will:
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Act safely at all times, taking responsibility for themselves and others affected by their actions;
Comply with applicable HSE laws and regulatory requirements;
Report all injuries, hazards, damage to plant and equipment;
Minimise waste going into landfill;
Keep our premises clean and tidy;
Help to prevent pollution;
Advise the management of KMI of any workplace-related injury or illness;
Consult with the Manager prior to commencing any task if unsure about the safety of the task, system
of work or for any other safety-related reason;
Use all protective equipment as directed, and keep it in good working order;
Participate in all HSE related meetings, information briefings and training courses as directed; and
Disclose information about their work history or physical health that could adversely affect their ability
to meet the safety requirements or demands of any job for which they are employed or likely to be
employed.
5. QAS POLICIES AND OBJECTIVES
The organisations HSE policy is described in the QMS Policy Statement MAN1010. This document identifies
the strategic level requirements of the HSE Management System.
The organisations current HSEQ objectives and priorities are described in QMS Objective Statement
MAN1011.
6. MANAGEMENT COMMITMENT, RESPONSIBILITY AND REVIEW
Procedure MAN1001 Management Responsibility and Review identifies the methodology for ensuring the
QMS meets all HSE related requirements and is reviewed regularly to ensure compliance.
7. AUDIT REQUIREMENTS
HSE auditing and QMS compliance is achieved through Site Inspection and audit processes identified in
Procedure AUD1001 Internal Audits.
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All system procedure/activity non-conformances observed shall be recorded in the audit report. Any
recommendations shall be noted on checklists and uploaded as evidence or copy of the procedure and
summarised in audit report, with appropriate action plan noted.
8. EMERGENCY REQUIREMENTS AND RESPONSES
Emergency situations on site may arise without warning, in a range of forms and for a variety of reasons. The
potential for these conditions lies in the nature of the systems and process, the characteristics of the process,
substances and the geographical location of the facilities.
Potential on-site emergencies include but are not restricted to:
a)
b)
c)
d)
e)
f)
g)
h)
i)
Fire;
Explosion;
Structural failure;
Toxic or environmentally significant contamination and spills;
Vehicle accidents;
Terrorism, crime and bomb threats;
Severe weather conditions;
Illness and injury to personnel; and
Accidental release of materials.
The effects of these conditions range from a localised incident to a full evacuation of all personnel.
Any serious incident, accident or emergency that constitutes a risk to personnel or the environment must be
reported to the Chief Warden. This is necessary to ensure that appropriate resources are mobilised to deal
with the emergency quickly and effectively, and that appropriate responses are given to the media.
Under no circumstances is any member of staff or any contractor engaged by KMI to communicate directly
with any media representative without express authority from the Managing Director of KMI.
Any request for comment should be courteously declined, stating;
“A company representative will be available for comment later”.
Step by step instructions and initial responses to possible emergency situations are given in the Emergency
Initial Response Guide for your location.
8.1
EMERGENCY RESPONSE TEAM (ERT)
The ERT is a group of people consisting of a Chief Warden, several Area Wardens and Communications
personnel. The team is identified by a yellow, white or red hard hat in the case of an emergency. Deputy
Wardens are nominated and trained in the absence of Area Wardens. Each person is trained in their
particular role for preparation of an emergency.
The company’s Emergency Response Teams (ERT) are identified on the safety notice boards.
8.2
EMERGENCY INITIAL RESPONSE GUIDE (EIRG)
The EIRG is a comprehensive guide of what to do in the case of an emergency. This guide identifies the
following:
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instructions on what to do in all types of emergency
the persons responsible for specific tasks during an emergency
the methods of notification of an emergency
resolution flowchart
list of emergency contacts
site plan
incident resolution flowchart
list of emergency contacts
All staff can access this guide at the site notice boards.
8.3
RAISING THE ALARM
Once an incident has occurred or an emergency situation is identified, individuals closest to the incident shall
assess the situation, immediately raise the alarm via air horn and send for assistance via the ERT.
8.4
REPORTING THE EMERGENCY
Any emergency should be reported in the first instance to Reception via the telephone. Refer to Emergency
Initial Response Guide for current details for your site.
8.5
ALERT
An alert is issued to all personnel to warn of potential evacuation. In preparation for an evacuation, switch off
all electrical equipment, gather personal belongings and wait for further instructions.
8.6
EVACUATION
In the event of an evacuation, all personnel shall be notified to make their way quickly to the closest identified
safe assembly area. Do not leave the assembly areas or re-enter the building unless instructed by the Chief
Warden.
8.7
EMERGENCY ASSEMBLY AREAS
Once the EVACUATION has been initiated, all personnel visitors and contractors are to make their way to
the designated Emergency Assembly Areas.
In some circumstances only a partial evacuation may be required. Area Wardens will manage partial
evacuation and instruct staff not directly affected by the emergency to return to their work.
Any instructions given by the Chief Warden or Area Wardens must be followed.
DO NOT LEAVE THE EMERGENCY ASSEMBLY AREAS UNLESS GIVEN EXPRESS AUTHORITY TO DO
SO BY THE CHIEF WARDEN.
The evacuation will be cancelled by the Chief Warden or the Fire and Emergency Services in attendance,
and any instructions relayed through the Area Wardens.
Ensure you are aware of the assembly areas, evacuation routes and emergency exists. Your site
emergency assembly areas are a chosen safe site for personnel to gather for a head count in the event of an
evacuation.
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8.8
EVACUATION TRAINING
Evacuation training for all personnel and specific training and debriefing for the Emergency Response Team
is conducted at annual intervals and coordinated by the responsible Manager.
8.9
EMERGENCY MANAGEMENT TRAINING
Scenario based emergency training is undertaken as part of the evacuation training held at annual intervals.
9. MANAGING ACCIDENTS/INJURIES/ILLNESSES/HAZARDS
9.1
REPORTING PROCEDURE
Any incident that may, or actually did cause injury or damage to the environment or plant and equipment
must be reported on the ERP (NCR manager). An Incident Report shall be initiated by the individual reporting
the incident, and the person in charge for that work area must be notified immediately.
10. RISK ASSESSMENT
The purpose of a Risk and Hazard Management Procedure is to provide guidance in relation to hazard
identification, risk assessment and risk control in the workplace. KMI applies an industry recognised method
of risk and hazard management to HS&E, commonly referred to as S.A.M.
S = “Spot the Hazard” refers to the source of potential harm or a situation with potential to cause
harm to life, health, property, or the environment.
A = “Assess the risk” refers to the assessing the risk level = consequence x exposure x probability.
This method is used to prioritise risk control measures by determining the nature of the consequence,
exposure to the hazard and the likelihood/probability of the injury, illness or disease taking place.
M = “Make the change” refers to the risk control process used to identify practicable measures for
eliminating or reducing the likelihood of injury, illness or disease in the workplace.
The table below is to be used to rank risk priorities, and complete the investigation component of the Incident
Report.
Frequency
Likelihood
Consequence
Almost Certain
15
10
6
3
1
A
19
14
9
5
2
B
(One in 3 years)
22
18
13
8
4
C
(Once in 10 years)
24
21
17
12
7
D
(Once in 30 years)
25
23
20
16
11
E
(Once in 100 years)
(Once per Year +)
Likely
Occasional
Unlikely
Rare
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High Risk
5
4
3
2
1
Medium Risk
Severity
Low Risk
Minor
<$10k
<$7k
Minimal
Minor
Routine
Medical
$10k-50k
$7k-$14k
Localised
Serious
Minor
LTI
$50k-$100k
$14k-$70k
Short term
Serious
Localized
Disability
$100k-$1m
$70k-$240k
Long Term
Major
National
Fatality
$1m+
$240+
Catastrophe
Significant
International
Injury
Production
Equipment
Environment
Legal
Reputation
The responsible Managers must then progress the NCR according to the level of risk. Medium risk hazards
must be expedited by the Manager with an appropriate degree of urgency. High risk hazards must be
brought to the attention of a Quality Management Representative as soon as practicable.
10.1
ASSIGNMENT OF RESPONSIBILITIES AND RESOLUTION OF HAZARDS
Low risk hazards can be resolved using the “Spot the hazard, Assess the risk, Make the changes” (S.A.M.),
methodology and resolved in the work area, or discussed and resolved through the Toolbox Meetings. The
completion of an NCR is primarily for reporting purposes and the resolution will be included in the initial
report.
A risk assessment must be completed for all medium and high risk activities,
The process for risk assessment and creation of a Safe Operating Procedure is:
1.
2.
3.
4.
Identify the JOB STEPS.
Identify the HAZARDS.
Identify the PRECAUTIONS.
Create the DOCUMENT.
The risk assessment provides a framework for the creation of a Work Instruction/SOP for the task. A Work
Instruction is a document containing detailed instructions that specify exactly what steps to follow to carry out
an activity.
An Incident Investigation Team consisting of the QMR,OHS Consultant and the party reporting or injured as
a result of the hazard and a safety representative, must be created for Medium and High risk incidents.
Risk Level
Low
Manager to delegate or lead investigation, and initiate resolution.
Medium
Manager to lead investigation, Management to initiate resolution.
High
10.2
Assignment of responsibilities
Management to lead investigation and initiate resolution.
INCIDENT INVESTIGATION
The investigation of an incident is not intended to assign blame, and this must be made clear to all parties
during the investigation. The investigation must consider;
a.
b.
c.
d.
The circumstances leading up to the incident?
What actually occurred?
What could have occurred?
How the incident happened?
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e.
f.
g.
h.
i.
j.
k.
10.3
How the incident can be prevented from occurring again?
Was training available and followed?
Was the training adequate?
Is the work structured correctly?
Is the work organised appropriately?
Is the workplace laid out appropriately?
Are there alternative methods?
HIERARCHY OF CONTROLS
The Hierarchy of Controls is an escalating list of alternatives for the resolution of hazards. It identifies a
preferred order of controls from most effective to least effective that are designed to;
a) Eliminate the risks of a hazardous work process and to minimise the risk of injury or disease.
b) Reduce the risk of exposure to a hazardous substance.
Where regulations require specific methods to control the risk, these must be complied with.
The Hierarchy of Controls is;
10.3.1 Elimination
Remove the hazard or hazardous work practice from the workplace. This is the most effective control
measure.
10.3.2 Substitution
Substituting or replacing a hazard or hazardous work practice with a less hazardous one.
10.3.3 Isolation
Isolating or separating the hazard or hazardous work practice from people involved in the work or people in
the general work areas from the hazard. This can be done by installing screens or barriers, or marking off
hazardous areas.
10.3.4 Engineering Control
If the hazard cannot be eliminated, substituted or isolated, an engineering control is the next preferred control
measure. This may include the introduction of different equipment, modifications to existing equipment, or to
provide guarding for hazardous equipment.
10.3.5 Administrative Control
This involves introducing work practices that reduce the risk. A risk assessment may be initiated and a work
instruction or Safe Operating Procedure (SOP) created for a hazardous task that describes task specific
training and a method of work.
10.3.6 Personal Protective Equipment (PPE)
PPE should be considered only where no other form of control is practicable or appropriate, or the use of
PPE will improve protection.
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These control measures are not mutually exclusive. A combination of these controls can be used to help
resolve a hazardous situation, and should be used to generate alternative resolutions.
10.4
GENERATION OF RECOMMENDATIONS AND RESOLUTION
The incident investigation should consider any and all alternative resolutions generated as a result of the
assessment. Where possible, those directly involved with the task or process should be included in the
investigation, or consulted to identify alternative resolutions from different perspectives. This will assist the
generation of high quality alternatives, and improve the chance for successful implementation of any change
resulting from the investigation.
All identified HSE issues will be escalated to the highest level required to affect an appropriate resolution.
Managers are responsible for ensuring that any corrective/remedial actions identified during incident
investigations are followed through to completion and that such actions are clearly documented. In instances
where corrective actions are not completed, managers will ensure that clear reasons for no action are also
documented.
Wherever a regulatory authority is involved in an incident investigation, inspection or follow-up, KMI will
ensure that a nominated representative is present, monitors the activities of, and acts as the KMI liaison with
the regulatory authority.
All KMI employees will participate in and co-operate with incident investigations and reporting requirements
as a condition of employment.
10.5
SELECTION OF A RESOLUTION
The selection of one alternative, or range of alternatives as appropriate, must be the result of consultation
within the investigation team, and ratified by the appropriate level of authority depending on the original level
of risk and the cost associated with the resolution.
The resolution must be appropriate to the risk, reasonable given the resources available to the organisation,
and most importantly; address the hazard sufficiently to eliminate or significantly reduce the risk associated
with the hazard.
10.6
CLOSURE
Once personnel have been trained, processes changed to reduce risk, or the hazardous situation removed,
the incident report can be closed out.
11. TRAINING
Managers are responsible for ensuring appropriate training is delivered prior to work taking place. Employees
or Contractors are not to undertake any hazardous process without prior training. The following safety related
training forms part of the Safety Management System.
11.1
IDENTIFICATION OF TRAINING NEEDS
Once a new process has been developed and entered into the quality system, the information must be
disseminated to the relevant staff. The Quality Management Representative and OHS Consultant determine
who is required to undergo training in the process and initiate training based on the Work Instruction.
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11.2
INDUCTION REQUIREMENTS
Induction training has been developed for all staff, contractors and visitors to ensure all personnel on site are
aware of all site specific safety hazards and requirements, and to provide sufficient information that they may
comply with these requirements.
All new employees must complete an online induction upon commencement of employment. A record of the
completion of induction is automatically recorded in EzyInduct.
All visitors must sign in and out of the Visitors Log to ensure everyone on site is accounted for in the event of
an emergency or evacuation. Visitors must be escorted at all times.
Contractors/Visitors must report to the relevant personnel to sign in and out.
All inductions are to be conducted by a suitably experienced and qualified staff member.
Visiting truck drivers or customer representatives collecting goods are not required to complete an induction.
Regular Transport Operators and their drivers can view the relevant Traffic Management Plan for the site
they are visiting, identifying site safety rules and traffic management directives.
11.3
SAFE OPERATING PROCEDURES (SOP)
A SOP must be created where a medium to high risk still remains following the identification, investigation,
analysis and mitigation of a hazard. A SOP is a written guideline for procedures while recognising the
potential risks and hazards associated with carrying out a particular task.
All employees required to undertake a medium to high risk task must undergo process specific training in the
form of Safe Operating Procedures or SOP. This training must be completed before any staff member or
contractor may perform any hazardous task.
A full list of SOP’s is available for viewing in the QAS on the ERP.
12. FITNESS FOR WORK
Regulations require the Company to provide a safe place and system of work, and for employees to work
safely, with due care and consideration for the safety of others.
Policies are in place outlining the Company’s rights under our duty of care obligations.
12.1
PRE-EMPLOYMENT MEDICALS
New employees may be required to complete a pre-employment medical at a medical provider selected by
the company. This medical is designed to identify potential job/ability issues and provide a base line for
ongoing health management.
12.2
PRIOR MEDICAL CONDITIONS
It is a condition of employment that candidates fully disclose any prior medical condition that may affect the
candidate’s ability to fulfil the requirements of the position for which they are employed.
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12.3
HEARING
12.3.1 Personal Testing
An audiometer test is conducted at the discretion of the company on warehouse personnel to measure
changes in an individuals hearing by a licensed hearing aid specialist. Further audiograms shall be taken
where exposures are over 85 decibels per 8 hour shift or where continued deterioration to hearing is
occurring. Any employee whose hearing deteriorates by 10 decibels or more from a baseline hearing test
shall be retested to verify the results. All results are filed under on the individuals personnel file.
12.3.2 Area Noise Monitoring
Noise surveys are conducted to determine the level of exposure to harmful noise through the use of
machines and equipment. An on-site noise survey is carried out in the warehouse every 5 years by an
external party to identify items of equipment and operations which have the potential to exceed the exposure
standard. High risk areas where noise is relatively constant shall be monitored more closely. Any unusual
readings are recorded as an incident via the ERP to ensure appropriate resolution. All data is recorded once
testing is complete on the ERP Inspection module.
12.4
TETANUS
Employees who sustain an injury whilst on site shall be offered a tetanus booster injection if more than 10
years have lapsed since the last one.
12.5
SMOKING
OS&H Regulations and Smoking Regulations under the Health Act apply to workplaces. Smoking of tobacco
products is considered a health hazard, and as a result, all KMI sites are designated as “Smoke Free” to
ensure employees are not put at risk from passive smoke.
Smoking is prohibited on site at all times, except in designated smoking areas as shown on the Traffic
Management Plan. Employees who fail to observe these instructions will be disciplined and repeat offences
may lead to further disciplinary action and/or dismissal.
13. INJURY MANAGEMENT
Where an injury occurs on site, the injured party must be attended to by a qualified First Aid Officer that has
been appropriately trained and authorised to practice First Aid by the company. The First Aid Officer will
initiate the Incident Report and form part of the Incident investigation Team where required.
If an injury requires further medical attention this will be conducted by a Company authorised medical
provider.
13.1
FIRST AIDERS
First aid is the immediate treatment given to someone suffering an injury or illness. First aid must be
administered by a qualified “First Aider” that has had some level of formal training.
In selecting and determining the number of First Aiders needed at a workplace consideration should be given
to;


The hazards identified at the workplace;
Assessment of the risks associated with the hazards;
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
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13.2
The size and layout of the workplace
The number and distribution of the workers;
The distance from the workplace to the nearest medical or ambulance service;
The number and distribution of workers, including those working shift work.
FIRST AID BOXES
A first aid box may be of any size, shape or type providing it is large enough to contain all the items required
for a particular workplace. It should be able to protect the contents from dust, moisture and contamination.
The first aid box should be kept securely closed to ensure the contents are kept clean and dry. First aid
boxes are located on the evacuation plan for the various sites.
13.3
REHABILITATION
The company is committed to provide rehabilitation and assistance to injured personnel, and will provide a
range of alternative duties or engage the services of a Rehabilitation Service Provider in the event of a
Worker’s Compensation Claim. A structured Rehabilitation Programme will be designed to assist the injured
person’s return to work.
14. CONTRACTOR MANAGEMENT
All contractors engaged to supply labour, or conduct construction, repair and maintenance services, must
provide details of appropriate insurances and demonstrate compliance with all company requirements for
induction and safety management whilst engaged by the company or performing work on any KMI site.
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