CLIENT

CLIENT

: ZCL CHEMICALS LTD.

PROJECT DESCRIPTION: API MANUFACTURING FACILITY UNIT- IV

DOCUMENT NAME: PROJECT HEALTH SAFETY AND RISK MANAGEMENT PLAN AND PROCEDURES

DOCUMENT NO.

: P363-DOCZ-HSE-PP-5000_Rev

Aevitas Pharmagro PROJ. NO.: P363

ZCL Chemicals Limited.

1806/807, 215, Atrium,Chakala, Andheri-Kurla Road,Andheri(E), Mumbai - 400 059. India.

APPROVAL AND AUTHORIZATION

REVISION DETAILS

INDEX

1. 0INTRODUCTION6

2. 0SCOPE7

3. 0PRINCIPLES OF HEALTH SAFETY AND ENVIRONMENTAL MANAGEMENT8

4. 0HSE POLICY AND OBJECTIVES9

5. 0ROLES AND RESPONSIBILITIES13

6. 0Statutory Requirement19

7. 0Subcontractors Management20

8. 0RISK ASSESSMENT PROCESS22

9. 0PRE-EMPLOYMENT MEDICAL SURVEILLANCE 24

10. 0ORIENTATIONS AND MEETINGS 25

11. 0HSE COMMUNICATION27

12. 0HEALTH AND SAFETY MEETINGS28

13. 0HEALTH, SAFETY AND ENVIRONMENTAL INCIDENT INVESTIGATIONS AND REPORTING30

14. 0INSPECTIONS35

15. 0EMERGENCY RESPONSE PLAN (ERP)38

16. 0SITE ACCESS AND SECURITY40

17. 0RECORD KEEPING REQUIREMENT43

18. 0MANAGEMENT OF CHANGE45

19. 0MANAGEMENT REVIEW47

20. 0WORK PROCEDURES48

A.1HOUSEKEEPING50

A.2COMPRESSED GAS CYLINDERS52

A.3PERSONAL PROTECTIVE EQUIPMENT (PPE)53

A.4HAZARDOUS MATERIALS MANAGEMENT57

A.5Machine Guarding60

A.6Working at Height61

A.7EQUIPMENT MAINTENANCE AND INSPECTION63

A.8VEHICLE AND MOBILE EQUIPMENT SAFETY64

A.9HAND AND POWER TOOLS67

A.10TRIPPING, SLIPPING AND FALLING HAZARDS71

A.11MANUAL LIFTING SAFETY73

A.12HAZARD IDENTIFICATION - BARRICADES AND WARNINGS74

A.13SAFE WORK PERMIT SYSTEM76

A.14TAGGING AND LOCKOUT79

A.15CONFINED SPACE ENTRY84

A.16ELECTRICAL SAFETY88

A.17OPERATING NEAR ELECTRICAL LINES90

A.18OPERATION AND INSPECTION OF CRANES AND HOISTS92

A.19USE AND INSPECTION OF RIGGING96

A.20ELEVATING WORK DEVICES98

A.21LADDERS, SCAFFOLDINGS AND FLOOR OPENINGS102

A.22WELDING, GRINDING AND CUTTING SAFETY105

A.23EXCAVATION, trenching AND SHORING SAFETY108

A.24FLAMMABLE AND COMBUSTIBLE LIQUIDS116

A.25HOT WEATHER118

A.26FIRE SAFETY121

A.27FIRE EXTINGUISHERS122

A.28PRESSURE TESTING124

A.29CHEMICAL CLEANING126

A.30RADIOACTIVE MATERIALS127

A.31EXPLOSIVE BLASTING130

A.32WILDLIFE SAFETY137

A.33INCLEMENT WEATHER138

1. 0 INTRODUCTION

This Project HSE Management Plan and Procedure summarizes the applicable health and safety regulations and procedures for the ZCL Chemicals API Manufacturing Facility Project. It will be periodically reviewed and updated in order to be adapted to changes that arise in the Project. Any infringement of the provisions of this Plan will result in disciplinary measures up to and including expulsion from the Project site.

The Plan is not exhaustive therefore, all Aevitas Pharmagro employees, client representatives, Contractors, suppliers, personnel and visitors must be familiar with the applicable legal requirements that are not explicitly mentioned in this document. In case of divergence between the requirements of the Project Health Safety and Risk Management Plan and the applicable local legislation, the stricter requirement will apply. When a reference to a standard is mentioned in this Plan, an equivalent standard may be substituted.

The fundamental objective of this Plan is to eliminate hazards to the health, safety and physical integrity of workers.

It outlines the measures to be implemented, programs to be set up and human resources to be deployed in order to prevent incidents.

Consequently, incident prevention on the Project site will be a priority not only during the construction period, but also during all other phases of the Project.

This Plan will help us achieve the Projects ZERO INCIDENT objective. Note that information concerning this Plan will be communicated to Contractors or subcontractors during bid solicitations and will be appended to contract documents.

This Plan is a tool that will be disseminated widely on the Project. All Contractors, suppliers, personnel and visitors must comply with its requirements, in order for the Project to be carried out safely and without incidents. In case of a dispute, Aevitas Pharmagros Plan will take precedence over all Contractor Health, Safety and Environment Plans.

2. 0 SCOPE

The Aevitas Pharmagro management team is committed to a healthy and safe working environment. The success of the Health, Safety and Environment Program depends on its implementation at every level throughout the organization and all personnel engaged in every project, facility and office. Experience shows that sound accident prevention techniques and principles result in a healthy, safe and productive workplace. To ensure the realization of this objective, this Project Health and Safety Risk Management Plan and Procedure is established to provide awareness and participation by all persons.

Prior to commencement of any work, all Aevitas Pharmagro employees, staff, management, its subcontractors, and their supervisors shall review and understand the contents of this Plan. The use of this manual will promote safety and environmental compliance as well as provide a consistent approach to achieving injury/incident-free performance.

All Sub-contractors will be responsible for safe work practices and conditions of their employees and subcontractors, and will ensure that the work does not result in hazards to themselves or to others. Every worker on at all sites will be required to adhere to the procedures and safe practices as defined by this Project Health and Safety Risk Management Plan & Procedure.

The overall goal of this plan is to maintain quality and integrity in all facets of construction, operation, and all other activities while maintaining the health and safety of all clients' personnel and the protection of property and environment.

This will be achieved by adopting policies of accident/incident prevention as follows:

1. Eliminating unsafe conditions. Accidents are caused by unsafe physical condition of equipment or mechanical, electrical exposure to the working environment.

2. Minimization of unsafe acts by providing competent supervision to ensure that workers use proper techniques and methods.

3. Taking advantage of every opportunity to correct unsafe acts or conditions before an injury occurs.

4. Avoiding, minimizing the negative impacts of actions on the natural environment.

5. Ensuring compliance to regulatory and industry standards.

3. 0 PRINCIPLES OF HEALTH SAFETY AND ENVIRONMENTAL MANAGEMENT

3.1 The Sub-Contractor has overall responsibility for the health, safety and environmental elements under its control in accordance with Aevitas Pharmagro's Project Health Safety and Risk Management Plan and Procedures. This responsibility will be maintained throughout its association with Aevitas Pharmagro.

3.2 The Sub-Contractor's health, safety and environmental program and its implementation will meet or exceed industry standards and the requirements of all governing regulatory bodies.

3.3 Copies of its Health, Safety and Environment Program will be made available to the Aevitas Pharmagro's Management team including their field supervisory staff, HSE personnel, and any Sub-Contractors for reference and implementation during their scope of work.

3.4 The Sub-Contractor will have its current safety and environment programs and historical performance records evaluated, and shall submit a written commitment to such objectives along with its bid submittal, if any.

3.5 The Sub-Contractor will be responsible to advise all its personnel and subcontractors of the project's safety and environment goals, policies, requirements and procedures in all orientation sessions. This will be a mandatory precedent before any person commences employment or visit at project site.

3.6 Each employee is responsible for his/her own safety and the safety of co-workers by following safe work procedures, and by reporting sub-standard acts and conditions to their immediate supervisor. Every worker has the right to refuse to perform work that he/she considers has unsafe conditions no penalties will apply for refusing to work in unsafe conditions.

3.7 Aevitas Pharmagro and Sub-Contractor management personnel will promote assist and participate in safety meetings, audits and reporting to reinforce the importance of safety and environment on the project site.

4. 0 HSE POLICY AND OBJECTIVES

4.1 Specific Policy Regarding Occupational Health and Safety on Construction Sites

This specific policy issued by Aevitas Pharmagro constitutes the minimum requirement in occupational health, safety and environmental matters and applies to the Project Construction site in Ankaleshwar, Gujarat. This specific policy constitutes the minimum requirement in such matters and applies to all construction sites. It is the object of a specific prevention program.

The safety of workers and other participants on Aevitas Pharmagro construction sites is a priority objective and takes precedence over any other activity or consideration.

On its construction sites, Aevitas Pharmagro aims at eliminating the very causes of dangers to workers health, safety and physical integrity.

Risks will be identified and managed by focusing on behaviors, perceptions and skills that will achieve growth and make the project safer.

Risks will be mitigated at the most fundamental level in project design, infrastructure, construction and operations. Any one risk could result in several different outcomes with incidents being only one of the possibilities.

Safety on construction sites is everyone's business: Aevitas Pharmagro, Contractors, Subcontractors, the Project Manager, worksite supervisory personnel, security personnel, the workers themselves and the organizations representing them.

Aevitas Pharmagro has identified measurable objectives which are specific and will be subject to periodic review to ensure continuous improvement. The following are the established Project health, safety and environmental objectives to which all the Project's participants will subscribe and strive to achieve:

1. Zero fatalities.

2. Zero lost time incidents (injuries and work-related illnesses).

Aevitas Pharmagro Management is committed to providing active leadership and full support in order to develop and maintain an industry-leading health, safety and environmental programs.

It is in the best interest of all parties to consider health, safety and the environment in every activity. Commitment to health, safety and the environment is an integral part of our organization, and we expect the full collaboration of all employees.

N.T. Balraj

February12st, 2015

With regard to occupational health and safety matters on worksites where Aevitas Pharmagro has a mandate, the Contractor agrees to a minimum involving the follow-up and following reports:

1. A written report on the nature of worksite risks and the identification of means for eliminating them, plus the identification of the manager in charge.

2. A monthly report on the frequency and seriousness indications from the worksite.

3. A report relating to every serious or fatal accident including the circumstances surrounding the accident, causes as identified and recommendations for avoiding a repetition of such an accident.

The Contractor is directly liable for the performance of its contract where safety is concerned.

The Contractor agrees to provide itself with the means and instruments enabling it to apply this policy on worksites; such means may include, among other things, contractual provisions or other means such as inspections, safety committee, etc.

The Contractor shall ensure that the organization of work on worksites and the methods and techniques in use are safe and do not prejudice the health of anyone.

In particular, the Contractor shall ensure the proper upkeep of the worksite and the providing of adequate sanitary facilities.

The Contractor shall ensure that the emission of a contaminant or other hazardous substance on the construction site does not prejudice the health or safety of anyone working on such site.

The Contractor shall ensure that worksite personnel have received adequate training and information regarding:

1. Risks arising from the work.

2. Means for avoiding a risk.

3. On-site First Aid services.

Each Contractor or Subcontractor, whose indication of frequency or indication of seriousness is deemed to be unacceptable, may be required by Aevitas Pharmagro to submit a recovery plan aimed at eliminating the life or health threatening risks for anyone on its worksite. It shall then immediately apply this recovery plan to the worksite.

4.2 Smoking policy

The Aevitas Pharmagros Project site is a non-smoking site except for areas designated for smoking. Smoking is prohibited in all vehicles and mobile equipment on site. Smoking is only permitted in designated areas provided with fire extinguishers, appropriate receptacle with caution board Please Stub Cigarettes / Bidees before throwing. Smoking-related waste and located a minimum of 50 meters from any potential hydrocarbon source or flammable material. Disposable lighters and self-striking matches are banned from the project site.

4.3 Health Safety and Environment Objectives

The following are the established project health and safety objectives to which all the project's participants will subscribe and strive to achieve:

1. No fatalities.

2. Zero lost time incidents (injuries and work-related illnesses).

3. Minimum medical treatments and First Aids cases.

4. Continuing reduction of incidents which could lead to any of the above.

5. No spills or environmental releases/impacts under their or Aevitas Pharmagro's control or authority.

6. All wastes disposed of in full compliance with prevailing legislation, Aevitas Pharmagro and/or ZCL Chemicals and Applicable Local rules and procedures.

7. Minimize wastes whenever possible and feasible through adherence to good engineering practice and sound environmental practices.

4.4 Sub-Contractor's Health & Safety Program

The Sub-Contractor will submit a copy of its written health, safety and environment program and policies prior to the start of any work. These programs shall comply with all prevailing applicable legislation and be approved by the Corporate Health and Safety Manager.

All Sub-Contractor's health, safety and environmental programs shall include the following elements:

1. A written health, safety and environment program document that includes the procedures and policies for effective health, safety and environmental management.

2. A current statement of HSE Policy signed by senior management.

3. A written health, safety and environment program document that includes specific policies and procedures for effective HSE management.

4. Implementation of the program with consideration for other contractors.

5. Convening regular site safety meetings and pre-work employees orientations.

6. Posting safety bulletin boards, signs and posters when approved by Aevitas Pharmagro and/or client/owner.

7. Promoting a consistently respectful, interested and enthusiastic attitude towards Aevitas Pharmagro's Project Health and Safety Risk Management Plan.

8. Ensuring that its supervisors are competent.

9. Performing inspections and audits where specified by prevailing legislative jurisdiction and/or Aevitas Pharmagro's Project Health and Safety Risk Management Plan and correcting all unsafe working conditions that are identified.

10. Installing and implementing adequate fire prevention equipment and procedures.

11. Provision of appropriate First Aid facilities, equipment and certified personnel sufficient treat its employees.

12. Provision of transportation to medical center's (doctors, clinics, hospitals, etc.) when required legislatively or contractually.

13. Applying adequate prevention measures and procedures against spills and other workplace hazards.

A copy of the Sub-Contractor's safety statistics for the previous five years shall be included with the Contractor's health, safety and environment programs. It shall include all recognized statistical (Worker Compensation, etc.) information that is applicable in the region where the project is being performed.

5. 0 ROLES AND RESPONSIBILITIES

5.1 Aevitas Pharmagro Project Manager

The Project Manager shall be responsible to:

1. Facilitate the implementation of Health and Safety processes, procedures and activities;

2. Ensure appropriate Health and Safety standards are developed and implemented;

3. Ensure project risks assessments are conducted;

4. Participate in investigations and ensure implementation of corrective actions following major accidents;

5. Ensure all necessary layers of protection required are provided to reduce risk to an acceptable level;

6. Ensure sufficient Health and Safety resources allocation;

7. Ensure training requirements are fulfilled;

8. Conduct observations while visiting site;

9. Attend Health and Safety meetings and ensure corrective actions implementation if deemed necessary;

10. Participate in the implementation of the Emergency Response Plan;

11. Review Health and Safety monthly reports and ensure correctives actions implementation;

12. Monitor the progress of Health and Safety activities and processes.

5.2 Aevitas Pharmagro Construction Manager

The Construction Manager shall be responsible to:

1. Ensure site-specific Health and Safety programs including training and communication programs are elaborated prior to onset of works;

2. Ensure compliance to projects policies, procedures and activities;

3. Inform quickly the ZCL Chemicals representatives and local authorities of any incident;

4. Review incident reports and ensure correctives actions implementation;

5. Monitor the progress of Health and Safety activities and processes;

6. Review the monthly Health and Safety report and implement corrective actions;

7. Conduct observations when visiting site;

8. Participate in the implementation of the Emergency Response Plan;

9. Ensure an induction training session is provided to all workers arriving at the site, that they are informed of the site particularities and the Health and Safety Program;

10. Ensure subcontractors submit corrective actions whenever required to;

11. Ensure Aevitas Pharmagro personnel are knowledgeable of the Health and Safety Program;

12. Setup subcontractors Health and Safety reviews;

13. Implement emergency response plan and coordinate activities;

14. Ensure subcontractors are committed to their site-specific Health and Safety program and to the Aevitas Pharmagro Health and Safety program;

15. Ensure Health and Safety contractual obligations are met;

16. Attend Health and Safety meetings and ensure corrective actions implementation;

17. Ensure subcontractors, undertake the required actions to implement this Health and Safety program at their expenses;

18. Take appropriate actions in case of non-compliances;

19. Ensure coordination of various works in order to eliminate hazardous situations that could result from the interaction of several subcontractors;

20. Ensure risk assessments are conducted and implement the necessary layers of protection required to ensure risks are reduced to an acceptable level;

21. Ensure each subcontractor attend a kick-off meeting prior to mobilization;

22. Ensure active participation and involvement of all workers;

23. Participate in incident investigations;

24. Implement site access through a security system;

25. Ensure coverage as per requirements in case of overtime, working alone, high risk works, works on more than one work shift;

26. Conduct monthly Health and Safety performance assessments of subcontractors;

27. Conduct Health and Safety performance assessment at contract closeout for each subcontractor;

28. Ensure subcontractors submit remediation plan in case of sub-standard Health and Safety performance;

29. Ensure that first aid kits and provisions are provided by each subcontractor.

5.3 Aevitas Pharmagro Health, Safety and Environment Manager/Engineer

The Health, Safety and Environment (HSE) Manager/ Officer reports to the Aevitas Pharmagro Corporate Health and Safety Manager, and implements and administers Aevitas Pharmagro's Project Health and Safety Risk Management Plan at project sites. He provides the Construction Manager and Sub-Contractors with guidance and advice to achieve the project's health, safety and environmental objectives.

The specific function of the Aevitas Pharmagro HSE Manager/Engineer is as follows:

1. Monitor and report on compliance with Aevitas Pharmagro Project Health and Safety Risk Management Plan by all Sub-Contractors and their personnel at sites.

2. Maintain knowledge of current governing regulations, codes and practices, and inform the Construction Manager whenever revisions to the site-specific Aevitas Pharmagro Project Health and Safety Risk Management Plan are required.

3. Ensure that the Sub-Contractor's health, safety and environmental procedures are incorporated into the Aevitas Pharmagro Project Health and Safety Risk Management Plan and Procedures.

4. Ensure that the Contractor supplies, maintains, operates and locates all safety, first aid, medical and fire-fighting equipment in accordance with legislated requirements. Confirm that the Contractor has reliable emergency medical transportation available.

5. Ensures undertaking of, or conducts investigations and reviews of all incidents such as accidents, incidents, health exposures, disabling injuries, and fatalities, and produce investigation reports for circulation to the required authorities.

6. Ensure that all personnel employed on a project comply with the applicable regulations, and maintain a co-operative working relationship with the relevant officials.

7. Prepare and file all HSE reports related to the project as required by ZCL Chemicals /legislation, and immediately transmit copies of such reports to the Client (if required), Construction and Project Manager as well as the Corporate HSE office.

8. Diligently record, file and keep safe all reports, including those required by governing regulatory agencies, until the end of the project, and then archive same with other project documents.

9. Ensure that the Sub-Contractor's HSE representative/Supervisors conduct daily toolbox safety meetings with their crews.

10. Conduct job specific HSE training programs for workers and staffs.

11. Conduct periodically Site HSE Meeting with subcontractor and maintain the record of it.

12. Ensure that the Sub-Contractor and its subcontractor/s provide health and safety induction/orientation sessions for all their personnel and visitors.

13. Provide a supply of safety and personal protective equipment for Aevitas Pharmagro personnel, and ensure that it is properly utilized and maintained. Maintained record of it.

14. Carry out Job Safety Analyses (JSA) with subcontractor and update accordingly and maintain copies for records.

15. Carrying out Risk Assessment (RA) with subcontractor and update accordingly and maintain copies for records.

16. Inspection of all electrical, mechanical, vehicles and lifting equipments and maintained record of it.

17. Review daily site health and safety inspection and reporting. Monitor as appropriate.

18. Issuance of stop work instructions when safety conditions require such action.

19. Provide assistance to contractors in the implementation of the Aevitas Pharmagro Project Health and Safety Risk Management Plan.

20. Initiate site-specific HSE reports as required and transmit copy of report to Client (if required) and Corporate HSE Office.

21. When applicable, monitor all aspects of traffic safety concerning staging, diversions, illumination, signals, and temporary signs/road markings. Maintain communications with relevant authorities.

5.4 Aevitas Pharmagro Engineers/Supervisors

1. Participate in risks review sessions and ensure that control measures are implemented;

2. Conduct planned HS inspections as required;

3. Participate in incident investigations;

4. Participate in Health and Safety meetings;

5. Ensure workers attend a Health and Safety induction training session prior to onset of work;

6. Ensure workers training and certification requirements and certification are met;

7. Ensure disciplinary measures follow-up and documentation;

8. Ensure proper reporting of workplace hazards;

9. Ensure an effective implementation of corrective actions.

5.5 Sub-Contractor Site HSE Representative

The subcontractor safety representative shall be responsible to:

1. Ensure implementation of Health and Safety Program;

2. Ensure non-compliances and unsafe conditions are readily addressed;

3. Assist incident investigations to determine root causes and ensure implementation of corrective actions;

4. Ensure workers are properly using the correct Personnel Protective Equipment (PPE) and safety devices for the work being performed, and that they are properly trained in the use of their tools/equipment and PPE.

5. Perform inspections on service ability of PPE, tools and equipment of work area;

6. Provide industrial hygiene and work environment monitoring including noise and air quality as required;

7. Conduct Emergency response drills;

8. Ensure that compliant firefighting equipment is installed and workers have been trained in their proper use;

9. Set a good example for workers by enforcing safety, industrial hygiene and environmental rules, regulations and standards;

10. Monitor and report daily to Aevitas Pharmagro and HSE Manager/Engineer on the subcontractors Health and Safety activities;

11. Participate in the Health and Safety Committee if required;

12. Conduct meetings to explain the safety measures associated with daily tasks and discuss Health and Safety information as issued by the Aevitas Pharmagro HSE Manager / Officer;

13. Ensure liaison with other subcontractor representatives and monitor their practices where they interface;

14. Ensure that First Aid / Medical facilities are equipped / staffed in accordance with legislated requirements.

15. Encourage safety suggestions from the workers.

16. Ensure prompt incident reporting and first aid assistance;

17. Provide HSE training to workers and staff as required.

18. Instruct workers on safe work practices and associated hazards;

19. Provide and maintain HSE records.

5.6 Sub-Contractor Supervisors

The specific safety- and environment-related functions of the Sub-Contractor's supervisors and foremen will include the following:

1. Set a good example for workers by enforcing safety, industrial hygiene and environmental rules, regulations and standards.

2. Instruct workers under their supervision on safe work practices, and the hazards associated with the assigned tasks at commencement of each work assignment.

3. Ensure that workers are properly using the correct personal protective equipment (PPE) and safety devices for the work being performed, and that they are properly trained in the use of their tools and equipment. Perform frequent checks on serviceability of all personal protective equipment (PPE) and tools/equipment.

4. Lead in the investigation of Sub-Contractor's accidents to determine all the facts necessary to take corrective action.

5. Conduct daily "tool box" talks to explain the safety measures associated with the tasks for the day, and discuss safety information that is issued by the Sub-Contractor's site safety representative and the HSE Manager/Engineer. Encourage safety suggestions from the workers.

6. Ensure that workers report all incidents/accidents, and ensure that prompt First Aid is administered to injured workers.

7. Conduct, document and implement Job Safety Analysis (JSA) and relevant requirements of same.

5.7 Workers

Any worker on site shall be responsible for:

1. His own safety and the safety of co-workers by complying to safe work procedures;

2. Be on guard at all times to prevent against his own safety risks, or putting others who might be working nearby at risk of bodily injury;

3. Use available PPE and protection devices;

4. Report any unsafe conditions and near misses to immediate supervisor;

5. Maintaining his work area clean and uncluttered;

6. Complying with danger indications and signs;

7. Refuse to undertake a task if he does not know the risks associated with it and for which he considers as unsafe conditions;

8. Refuse to operate equipment without proper training;

9. Be familiar with the HSE Program objectives, policies and procedures;

10. Be familiar with all safety information provided to him through posters, information bulletins and other means;

11. Request explanations to his immediate superior for measures and/or HSE directives, when necessary;

12. Participate in training as required;

13. Actively participate in meetings and sign attendance records.

6. 0 Statutory Requirement

Aevitas Pharmagro will ensure that at all times the Applicable Statutory Requirements shall be complied. A dedicated focus will be given to:

1. Indian Factory Act, 1948

2. Gujarat State factory act 1948 and rule 1963.

3. Building and Other Construction Workers Act, 1996

7. 0 Subcontractors Management

7.1 General Requirements

The Aevitas Pharmagros criteria will be outlined for procurement of materials, equipment and services. All work undertaken, equipment and materials by suppliers and vendors shall meet the Aevitas Pharmagro criteria. Health and Safety will be of primary consideration in contract awards, construction planning and execution.

Accordingly, each subcontractor:

1. Is directly liable for the performance of its contract where Health and Safety are concerned;

2. Agrees to provide means and instruments in order to apply this Health and Safety Program;

3. Ensure that the organization of work on site, methods and techniques in use are safe and do not endanger anyone;

4. Will be held accountable for all Health and Safety elements under his control throughout the life cycle of the project;

5. Will meet or exceed construction industry standards, requirements of Local Regulatory Bodies and Aevitas Pharmagro Health and Safety program;

6. Will be assessed based on their historical performance records over the last 3 years;

7. Will be advised of the ZCL Chemicals project goals, policies, requirements and procedures;

8. Ensure that the mandatory HSE orientation will be carried out prior to onset of employment on site;

9. Ensure each worker is responsible for his own safety and that of co-workers by following safe work procedures;

10. Ensure effective reporting of all unsafe conditions to the immediate supervisor;

11. Shall not apply penalties if a worker refuses to work in unsafe conditions;

12. Management representatives will promote, assist and participate in safety meetings, audits and reporting;

13. Shall submit a recovery plan aimed at eliminating risks upon Aevitas Pharmagros request.

Whenever its performance are deemed to be unacceptable. Each subcontractor shall submit a site specific Health and Safety Program consistent with requirements of this Program and inclusive of the following items:

1. Procedures applicable to its specific activities and policies for effective management;

2. Implementation of the program with consideration to other site subcontractors;

3. Convening of regular site safety meetings;

4. Strategic communication (safety bulletin boards, signs and posters);

5. Promotion of a consistently respectful, interested and enthusiastic attitude towards the Health and Safety;

6. Provision of competent safety supervision of all workers;

7. Inspections, audits, corrective actions of all unsafe working conditions;

8. Provision of appropriate first aid kits, equipment and certified personnel;

9. Installation of adequate fire prevention equipment, related procedures and training;

10. Assume a charge back for transportation to a medical facility upon Aevitas Pharmagro request.

Each subcontractor will ensure that the training requirements of the Health and Safety Program are assessed according to the scope of work during the pre-qualification process.

Subcontractors will be expected to provide their own training matrix to meet the Health and Safety program requirements before onset of work.

The training assessment will be based on:

1. Work at height;

2. Confined spaces entry;

3. Safe work permit;

4. Safe blinding;

5. Lock Out Tag Out;

6. Excavation;

7. Scaffold erection;

8. Temporary Electrical Lines and Connections;

9. Other Aevitas Pharmagro requirements.

8. 0 RISK ASSESSMENT PROCESS

8.1 Project Risks and opportunities

High-level risks are identified by a multidisciplinary team composed of Aevitas Pharmagro, Granules-Omnichem representatives and Subcontractors representative. Risks are listed in a risk register which provides details such as, owner, activity, risk level, control measures and action plans.

For every work package, risk identification and assessment shall be documented in a risk Register.

8.2 Control Measures

Throughout the projects life cycle, Aevitas Pharmagro will privilege these risk mitigation methods to obtain an As-Low-As-Reasonably-Practical (ALARP) level:

1. Elimination this is the most effective control method. In many cases, the risk can be designed-out or designed-in safety;

2. Substitution involves replacing the hazard or process with a safer one, e.g., replacing toxic solvents with detergents;

3. Redesign done where the processes can be redesigned to reduce or eliminate risk, e.g., modifying the exhaust system to reduce noise;

4. Separation the hazard from the person involves isolating the hazard from the person or the person from the hazard;

5. Defining safe behaviors list the safe behaviors required to execute the work properly, including conducting pre-start checks, etc.

6. Administrative measures JSA, Safe Work Permits, developing written step-by-step safe work procedure for the hazardous tasks;

7. Personal Protective Equipment (PPE) PPEs shall be used where the hazards are in place.

8.3 Risk Assessment

Hazards related to activities and risk associated with it shall be assessed and relevant control measure will be implemented. Risk Assessment of specific activities shall be done by the team of subcontractors supervisors, Aevitas Pharmagro Construction Manager, HSE Manager/Engineer and Supervisors and worker representative. Record of Risk Assessment shall be kept throughout the project life cycle.

The Risk Owner, risk Custodian and any other specialists (as required) review the risks at different frequencies depending on its level prior to implementation of control measures:

1. HIGH and VERY HIGH risks are reviewed on a monthly basis;

2. MEDIUM risks are reviewed every 2 months;

3. LOW risks are reviewed every 3 months.

8.4 Job Safety Analysis (JSA)

The purpose of the JSA is to assess and control risks associated with construction activities. It is also a tool to plan the job safely. Supervisors perform JSAs along with input of employees in the work activity and the support of HSE personnel.

A JSA has to be performed for any activity listed in the Risk Register prior to starting a new activity on site or when changes occur (new product, material, work organization, etc.). As long as the JSA reflects the current job, it shall be valid up to a month but reviewed and communicated weekly.

8.5 Work Permit System

Safe work permits are required for the following activities but not limited to:

1. Critical lifts;

2. Hoisting personnel;

3. Blasting;

4. Working with motorized aerial platforms;

5. Temporary structures related to high risk activities (swing staging, suspended work platform, etc);

6. Road closure;

7. Working near high voltage and power/electrical lines;

8. Chemical cleaning and air blowing;

9. System(s) testing, radiography;

10. Demolition (structural);

11. Excavation;

12. Lock-out and tag-out;

13. Hot work;

14. Confined space entry.

9. 0 PRE-EMPLOYMENT MEDICAL SURVEILLANCE

All workers including temporary workers shall be gone through Pre-Employment Medical surveillance. Each sub-contractor shall arrange this program for their workforce. Worker having any deficiency or disability shall not be deployed to critical activities. Record of medical surveillance shall be maintained throughout the project life cycle.

10. 0 ORIENTATIONS AND MEETINGS

10.1 Pre-Construction Safety Meeting with Sub-Contractors

The Sub-Contractor will attend a Pre-Construction Safety Meeting prior to the starting work at the work site. The following personnel, as a minimum, will attend any portion of the meeting dealing with HSE issues:

1. Aevitas Pharmagro Construction Manager.

2. Aevitas Pharmagro Health, Safety and Environment Manager/Engineer.

3. Sub-Contractor's Home Office Project Manager or equivalent.

4. Sub-Contractor's Senior Site Representative.

5. Sub-Contractor's Safety Representative/s.

10.2 Site Safety Induction/Orientation

The Sub-Contractor shall provide health and safety orientation for all its employees and subcontractors.

This orientation is a prerequisite to entering the site to work, except to those persons entering the site as a Visitor (Visitors must be accompanied by a designated, orientated project person, and will abide by the project safety regulations).

Workers who have attended the Sub-contractor's site safety orientation session shall be given an identification card (or hard hat decal) which will be retained by the employee and shall be produced on demand while on the work site.

During the orientation, the Sub-contractor will provide all additional company or contract specific information to their employees.

The safety orientation will include a review of the following:

1. ZCL Chemicals goals, objectives and policies;

2. Obligations and duties as per local legislation;

3. Health and Safety responsibilities;

4. Site layout and site access;

5. Communication and meetings;

6. Safe Work Procedures.

7. Vehicle/equipment operation and safety.

8. First aid procedures and medical facilities;

9. Work Permit System;

10. Incident reporting requirements;

11. Fire prevention and equipment;

12. Emergency response and muster points;

13. Personnel protective equipment (PPE);

14. Training and Certification;

15. Hazardous materials handling;

16. Housekeeping;

17. Specific work procedures and inspections;

18. Drug and Alcohol Policy;

19. Health and Safety incentives and collective rewards.

20. Other site rules and regulations.

The safety induction/orientation will be conducted in the morning, and workers will be allowed to proceed to their work place afterwards. In no event shall any worker commence work prior to having undergone orientation.

All workers who attend the induction/orientation session will be required to sign an attendance sheet and record of attendance shall be maintained throughout the project life cycle.

11. 0 HSE COMMUNICATION

11.1 Safety Bulletin Board

Aevitas Pharmagro will install safety bulletin boards on site, displaying safety notices, Emergency Response Plan, phonebook, minutes of safety meetings, Safety alerts and any other pertinent safety information. The subcontractors shall install safety bulletin boards near their working areas and keep all postings current and up to date.

11.2 Lessons learned

All lessons learned and high potential near misses will be communicated to the workforce by means of Toolbox meetings.

11.3 Emergency Contact Numbers

Emergency Contact Numbers shall be displayed at conspicuous location of site. The emergency contact numbers shall include:

Local Police Station

Fire Station

Nearest Hospital

Ambulance

Safety Manager/Engineer

Construction Manager

First Aiders

Emergency Rescue Team Members

11.4 Assembly Point

Assembly point/points shall be identified at project site.

It shall be away from Hazardous Material Storage.

It shall be near to the exit gate of Project site.

It shall have capacity of accumulating maximum number of workmen.

Fire Extinguishers should be provided at assembly point.

12. 0 HEALTH AND SAFETY MEETINGS

12.1 Tool Box and Pre-job Safety Meetings

A "tool box" meeting is a short meeting held by Subcontractors Site HSE Representative and each supervisor at the start of each shift to discuss with personnel the work of the day including special procedures, any potential hazards, all safety issues relating to the work, and any matters raised by the workers. Daily "tool box" meetings will be recorded in bullet format and an attendance record must be signed by all present.

Where a critical task is planned, a pre-job meeting will also be convened. Attendance should be limited to the workers on the task, their immediate supervisor(s), and safety personnel as required. A Job Safety Analysis (JSA) will be initiated, reviewed and then presented to the crew before each critical task begins.

The Aevitas Pharmagro HSE Manager/Engineer will advise and attend the meeting. He shall receive copies of Sub-Contractor's minutes and attendance records.

12.2 Health and Safety Committee

Aevitas Pharmagro and the Sub-Contractor will form a Joint Health and Safety Committee. The Committee will be Lead by Aevitas Pharmagro HSE Manager/Engineer. Representative from workers shall also include in committee.

12.3 Health and Safety Committee Meeting

Safety meetings on a project are an essential tool in continued development of a mutual understanding of Health and safety objectives, programs and issues.

The Safety Committee meets twice in a month to review all health, safety and environment related matters. Aevitas Pharmagro's HSE Manager/Engineer will prepare the agenda, with input from attendees. The Minutes of Minutes shall be distributed to all the attendees and also displayed in local language at Safety Bulletin Board.

Attendees will include:

1. Aevitas Pharmagro HSE Manager/Engineer.

2. Aevitas Pharmagro Construction Manager.

3. Sub-Contractor's representative(s).

4. Sub-Contractor's site HSE representative(s).

5. Workers representative(s).

Committee members will be conducting a joint work site inspection (Weekly Safety Walk Around) once before each regular meeting. Representatives from various areas and disciplines are to be included as required. The committee is not a policy making body but the normal divisions of authority should be respected.

It has responsibility to:

1. Promote collaboration between subcontractors and workers;

2. Receive suggestions and complaints from workers, workers representatives, union, association and subcontractors;

3. Analyze notices and inspection reports;

4. Analyze incident trends and near misses reports;

5. Transmit any requested information;

6. Notify members at least 48 hours prior to the meeting;

7. Ensure communication of the meeting minutes on the site bulletin boards in local language;

8. Support implementation of the Aevitas Pharmagro HSE Program.

Recommendations from the committee are expected and management will respond to the committees recommendations without delay.

12.4 Subcontractors Performance Review

During the construction coordination meeting, Aevitas Pharmagro will assess and document the Subcontractors HSE monthly performance. The Subcontractor achieving the best overall score is designated as the Subcontractor of the month.

Participants at this meeting shall be:

1. Aevitas Pharmagro Construction Manager;

2. Aevitas Pharmagro HSE Manager/Engineer;

3. Subcontractors Supervisors.

At the end of each contract, Aevitas Pharmagro will assess and document the subcontractors HSE overall Performance.

12.5 End-of Project Evaluation Meeting

Upon completion of the construction and pre-commissioning execution phases, ZCL chemical and Aevitas Pharmagro shall meet and review the safety performance of the project. This meeting will be documented with lessons learned and recommendations for future projects.

13. 0 HEALTH, SAFETY AND ENVIRONMENTAL INCIDENT INVESTIGATIONS AND REPORTING

All health, safety and environmental incidents will be investigated and reported for the following purposes:

1. To meet the requirements of the prevailing legislation (e.g., Directorate of Industrial Safety and Health (DISH), etc.). The Aevitas Pharmagro HSE Manager/Engineer will keep copies of all reports on file.

2. To ensure that workers affected receive the benefits to which they are entitled.

3. To provide information that may be useful in preventing similar occurrences elsewhere.

13.1 Incident Definitions

1. Fatality

A fatality is a death of a worker on the project or at the workplace resulting directly from an occupational illness or occupational injury. All fatalities will be classed in a separate category on the accident statistics (zero severity).

2. Critical Injury

A critical injury is one of a serious nature that:

a. Places life in jeopardy;

b. Produces unconsciousness;

c. Results in substantial loss of blood;

d. Involves the fracture of a leg or arm but not a finger or toe;

e. Involves the amputation of a leg, arm, hand or foot but not a finger or toe;

f. Consists of burns to major portion of the body; or,

g. Causes the loss of sight in an eye.

13.2 Environmental Discharge

An environmental incident involves spillage of 25L or more of contaminants and may impair environmental quality. Any incident which requires reporting to regulatory authorities is by definition an environmental incident, regardless of the quantities involved.

13.3 Occupational Injury

An occupational injury results from a work-related accident or exposure on the project or at the workplace that requires "first aid" or "medical aid" treatment (see following definitions for both).

13.4 Occupational Illness

An occupational illness results from an exposure to a chemical or physical agent on the project or at the workplace that causes illness that requires first aid or medical aid treatment.

13.5 First Aid Case

Any one-time treatment and subsequent observation of minor scratches, cuts, burns, splinters and so forth. This treatment is considered first aid even though provided by a physician or registered medical professional personnel.

13.6 Medical Aid Treatment Case

A medical aid case is any occupational injury/illness that involves neither lost workdays nor restricted workdays but which requires treatment by a physician or licensed health care professional at the physician's office or at a clinic or a hospital.

13.7 Lost-time Injury

A lost-time injury is an occupational injury or illness which renders the affected worker unable to report for work for more than the scheduled two days following the injury. For example, a worker is injured at work on a Monday and is off work the following two days - Tuesday and Wednesday and returns on the Thursday, the same week, would not constitute a lost time injury.

13.8 Lost time Day(s)

Lost time day(s) are the day(s) counted as a result of the injured worker, who is rendered unable to work following (the two day recover period post accident are not counted) and only day(s) counted are for the time the worker is off. Unscheduled work days (i.e. Saturdays and Sunday) are not counted as lost time days.

1. All lost workdays and restricted days associated with a lost time case are assigned to the calendar year and month in which the accident occurred. Reasonable estimates may be made as a final record to close out fiscal year statistics.

2. If a case involves medical treatment or loss of workdays prior to termination or layoff, then the case and days are entered appropriately as a medical aid or lost-time injury. The recording of days against the case stops as of the date of termination or layoff even though the employee may not be released for full duty.

13.9 Restricted (Modified) Work Cases

A restricted work injury is an occupational injury or illness where the worker returns to work and conducts a task that is within his post accident physical capacity. Restricted work cases are classified as a medical aid cases.

13.10 Reporting Standards

Any incident which had the potential to cause serious injury. Fatalities will be classified in a separate category, which will not be included in the injury severity calculations.

1. Lost Time Injury Frequency Rate is calculated by multiplying the number of Lost Time Injuries by 200,000 and dividing that result by the number of work hours expended during the time period of the report.

Number of Lost Time Injuries * 200,000

Number of hours worked

2. Injury Frequency Rate is calculated by multiplying the number of Lost Time Incidents and Medical Aids by 200,000 and dividing that result by the number of work hours expended during the time period of the report.

Number of Lost Time Injuries * No. of Medical Aid Cases * 200,000

Number of hours worked

3. Injury Severity Rate is calculated by multiplying the total number of workdays lost to injury and illness by 200,000 and dividing that result by the number of work hours expended during the time period of the report.

Number of Days Lost * 200,000

Number of Hours Worked

4. First Aid & Medical Aid Log is maintained by Aevitas Pharmagro and the Contractor's Medical Attendant for all treatments administered to site personnel for on-site and off-site treatment respectively throughout the project.

13.11 Occupational Health, Safety and Environmental Reporting

Serious accidents and injuries are required by legislation to be reported to the authorities. The HSE Manager and the Sub-Contractor will research the reporting requirements at the start of the project, and prepare a procedure on the reporting of serious accidents and injuries.

Examples of accidents or injuries that must be reported include:

1. An injury or accident that results in death.

2. An injury or accident that results in a "critical injury"- viz., one of a serious nature that:

a. places life in jeopardy

b. results in unconsciousness

c. results in substantial loss of blood

d. involves the fracture of a leg or arm

e. involves amputation of a leg, arm, hand or foot

f. consists of burns to a major portion of the body

g. causes the loss of sight in an eye.

3. An unplanned or uncontrolled explosion, fire or flood that causes a serious injury or that has the potential of causing a serious injury.

4. The collapse or upset of a crane, derrick or hoist.

5. Any environmental incident above/beyond the legislatively established threshold level or that established by the client or Aevitas Pharmagro. There are additional reporting requirements with respect to other categories of incident, inclusion of prescribed information and/or professional engineer's report, etc. Such prescribed (by Regulation) reporting requirements shall continue to remain the responsibility of the Sub-Contractor involved.

Aevitas Pharmagros Project Management Team shall complete the Preliminary Incident Report for critical injuries, lost time injuries, fatalities and environmental discharges and submit to the Manager Corporate H&S and/or Manager Corporate Environment within four hours of the incident.

13.12 Reporting Initial Occurrence (First Aid)

Any occurrence of injury or illness reported to a First Aid station, to supervision or to a medical treatment centre will be recorded in detail in the Contractor's First Aid Treatment Log. Entries in the logbook will be by the Trained First Aider (Medical Aid Attendant), or the designated First Aid Representative of the Sub-Contractor and the information will be kept confidential. First Aid Treatment Books of all Sub- Contractors are subject to audit by the Aevitas Pharmagro HSE Manager/Engineer.

13.13 Reporting Medical Aid

Any occurrence that becomes a Medical Aid Case will be recorded on a Medical Aid Treatment Log maintained by the Sub-Contractor. A copy will be provided to the Aevitas Pharmagro HSE Manager/Engineer.

All Sub-Contractors are required to promptly advise the Aevitas Pharmagro HSE Manager/Engineer and Construction Manager of the occurrence of a Medical Aid case.

In addition to being recorded on the Medical Aid Treatment Log the Medical Aid case will be investigated by Aevitas Pharmagro, and the Sub-Contractor will complete an Accident Investigation Report.

13.14 Reporting Lost Time Accident

When an employee experiences an injury or work-related illness, the employee has the right to be examined by a doctor. Should the employee choose not to be so examined, the Medical Aid Attendant may require such an examination in any event, if it is felt to be necessary.

In the event the doctor determines the employee should take time off work in addition to the day after the accident occurred, the accident becomes a Lost Time Accident (LTA). Lost Time Accidents require the completion of at least the following forms:

1. Preliminary Incident report to be issued to Corporate within four hours by PM Team.

2. The medical doctor completes the appropriate Worker's Compensation form(s) promptly following his examination, diagnosis, referral, and/or treatment of the worker.

3. The Sub-Contractor (employer) is responsible for filing the Employer's Report of Accident and Illness (normally within 72 hours of the Lost Time Accident occurrence). A copy of this report will be filed with the Aevitas Pharmagro HSE Manager/Engineer.

Each LTA will be reviewed with the Sub-Contractor's senior site management representative and the Aevitas Pharmagro HSE Manager/Engineer within 24 hours of the occurrence. All LTA's will be reported by the Aevitas Pharmagro HSE Manager/Engineer to the Construction Manager, and will be recorded on the Lost Time Accident Report that is submitted on a monthly basis (whether lost time accidents occurred during the month or not).

13.15 Monthly HSE Statistics Reporting

1. Sub-Contractor Reporting

Each month (no later than the 2nd working day of the following month) the Sub-Contractor will submit to the Aevitas Pharmagro HSE Manager/Engineer a Sub-Contractor's Monthly HSE Report detailing lost time accidents, Medical Aids, First Aids, near misses, lost work days, man-hours worked, and mobile equipment incidents.

2. Aevitas Pharmagro Reporting

Following receipt of the HSE statistics from the Sub-Contractor/s the Aevitas Pharmagro HSE Manager/Engineer will compile the Monthly Safety Statistics Summary, and submit it to the Construction Manager by the 3rd working day of the month following. Details of all lost time accidents, Medical Aids, First Aids, near misses, lost work days, man-hours worked, and mobile equipment incidents will be attached, as well as steps that were taken to prevent further recurrences.

Additionally, minutes of all safety meetings and inspections, a summary of all significant safety achievements and individual Sub-Contractor statistics reports will be attached. Subsequently, Monthly HSE Report (all sub-contractors) shall be transmitted to Corporate HSE Office.

14. 0 INSPECTIONS

Aevitas Pharmagro will perform frequent safety and housekeeping inspections (formal and informal) of the Sub-Contractor's work storage areas and equipments with the inspection checklists. These inspections are in addition to the safety and housekeeping inspections that the Sub-Contractor will perform, and do not substitute the Sub-Contractor's inspections.

The Sub-Contractor will be advised of any infraction and/or potentially unsafe condition, and will take corrective action immediately, where possible. If immediate corrective action is not possible, the hazard(s) will be properly barricaded and identified as "unsafe" until proper corrective action can be taken.

Aevitas Pharmagro's HSE Manager/Engineer will follow up on all infractions to ensure that corrective action is taken promptly. The Construction Manager will formally advise the Sub-Contractor if action is not taken promptly on any unsafe condition - this may result in work stoppage or other action against the Sub-Contractor.

14.1 Weekly Safety Walk Around

It is a planned inspection carried weekly with active participation of following personnel:

1. Aevitas Pharmagro HSE Manager/Engineer.

2. Aevitas Pharmagro Construction Manager.

3. ZCL Chemicals Management Representative.

4. Sub-contractor/s Management Representative.

5. Workers Representative.

In this inspection the personnel will decide one area of site for inspection. These inspections identify any unsafe condition and act, any specific hazard, safety requirements or any other safety issues and accordingly recommend the best practice. Report of weekly walk around will be distributed to all the attendees.

14.2 Pre-Inspection Procedure

1. Be familiar with the work locations;

2. Be prepared to review Incident Logbook to identify incident trends;

3. Review previous inspection reports with the intention of reviewing problem areas;

4. Develop a checklist of commonly reported hazards from previous site inspections;

5. Identify safe work procedures and planned work activities;

6. Identify activities that are high risk for injury using the risk register;

7. Ensure inspections are given adequate time to carry out an effective inspection.

14.3 Inspection Procedure

The procedure for conducting a planned safety inspection is as follows:

1. Take the time to observe the activities and use the checklist.

2. Take immediate corrective action where there is an imminent danger;

3. Record all existing unsafe acts or conditions;

4. Verify that previous recorded hazards have been corrected;

5. Identify corrective action required for each unsafe act or condition;

6. Identify personnel responsible for each corrective action and assign a date/time for completion.

14.4 Health safety and Environment Audit Program

The primary objective of a Safety Audit is to verify that HSE plan is being properly and effectively implemented. It will also identify any shortcomings in each program and provide recommendations to make improvements.

Monthly Internal Audits of varying degrees of detail will be implemented on the project.

Internal Audits will be initiated by Aevitas Pharmagro's HSE Manager/Engineer and will be carried out in consultation with a Subcontractor's site HSE representative.

Copies of all audit documentation will be transmitted to Aevitas Pharmagro's Construction Manager and Subcontractor representative.

Corporate audits will be conducted every three months by Aevitas Pharmagro Corporate HSE Manager.

14.5 Performing the Audit

The concern will be clearly outlined and corrective action will be recommended. Corrective action will include the activity required for resolution to the problem, the individual responsible, the time allotted to correct the situation, and suggestions for preventing recurrence of the problem in the future.

14.6 Audit Follow Up

The Sub-Subcontractor's senior management representative is ultimately responsible for the implementation of all corrective actions recommended in the Audit Finding Reports. At an appropriate time, Aevitas Pharmagro's HSE Manager/Engineer will inspect the site to ensure all corrective action has been satisfactorily performed, will sign-off the Audit Finding Report(s) accordingly, and will complete the audit plan and report.

14.7 Health and Safety Incentive Program

Aevitas Pharmagro strongly supports the subcontractors incentives program and initiatives. In addition to that Aevitas Pharmagro will implement an incentive program providing positive reinforcement and benefits for safe behavior on site.

14.8 Subcontractor Performance Review

Based on their monthly performance record, a subcontractor will be identified as subcontractor of the month. The winning subcontractor will be communicated throughout the site along with pictures with Aevitas Pharmagro management representatives.

15. 0 EMERGENCY RESPONSE PLAN (ERP)

15.1 Subcontractors ERP Requirements

Subcontractors shall be using the guidelines of Aevitas Pharmagro ERP requirements to implement their own site specific set of procedures. Minimal expectations are:

1. Support Aevitas Pharmagro in case of ERP activation;

2. Train their personnel on ERP procedures, policies and reporting requirements;

3. Assign trained personnel for emergency response:

a. Communication

b. Firefighting equipment

c. Decontamination

d. First aid and high angle rescue procedures

e. Incident investigation and critical procedures

4. Carry out area quarterly drills and debriefing sessions;

5. Maintain daily worker list to be used in the event of an evacuation;

6. Inform employees of the designated mustering points;

7. Assist with notification, First Aid, securing of site, as indicated by the designated site Emergency Coordinator, Fire Safety Coordinator;

8. Maintain workplace to reduce fire or spills and ensure safe evacuation;

9. Carry out documented weekly inspections for all emergency equipment with corrective actions if applicable;

10. Install signs for clear and effective localization of portable extinguisher and hoses;

The ERP includes alert process, chain of communication, and general procedures for the following occurrences:

1. Medical emergencies and rescue;

2. Evacuation;

3. Explosion, fire, smoke;

4. Extreme weather conditions;

5. Spills;

6. Bomb and telephone threats.

Subcontractors shall develop specific ERP related to their activities and provide emergency equipment and resources.

15.2 Emergency Procedures

All Contractors emergency procedures will be approved by Aevitas Pharmagro prior to site implementation. Each site Sub-Contractor's site emergency procedures will be posted in a conspicuous manner and in local language, at appropriate locations nearest to his scope of work, and protected from the weather. A current copy of the Sub-Contractor's emergency procedure should be available for reference.

16. 0 SITE ACCESS AND SECURITY

Security personnel will ensure a 24/7 coverage and do inspection rounds across site.

16.1 Workers Access

All workers will enter and exit the site by designated access points only. Site access will be monitored using Identity card system which will be provided by respective contractor.

Subcontractors shall implement their own control process to ensure their daily man count is accurate and take into account workers on sick-leaves and away from work.

One time visitor will not be require Health and Safety induction/orientation if they are escorted by an oriented person.

16.2 Identification

Upon successful completion of the orientation training, sub-contractor shall provide Identity cards to workers. ID card shall be return upon employment termination. It is mandatory for all workers to bring in ID card when accessing the site

Visitors will be given a temporary (1 day validity) visitor ID card that shall be worn at all time of visit and returned at the end of the visit.

16.3 Authorizations

Site tours shall be authorized by the Aevitas Pharmagro Construction Manager. The use of photographic equipment on site shall be authorized by the Aevitas Pharmagro Construction Manager.

16.4 Vehicles Access

1. All work related vehicles accepted on site shall meet safety standards including:

2. Audible back-up alarm.

3. Have seat belts;

4. 2 KG fire extinguisher;

5. First aid kit;

6. Display the vehicle pass at all times.

16.5 Traffic and parking safety

The benefit of this practice is that you can drive away forwards after work with a full field of vision and not be caught unaware by some other driver or pedestrian who is also rushing to get home.

To promote safe-driving practices, Aevitas Pharmagro strictly implemented speed limits are imposed at all site work areas, paved, unpaved and temporary access roads. The speed limit is:

10 kph

Overtaking is strictly prohibited.

All vehicles must give way to police, ambulances and emergency vehicles like fire, safety and security during emergencies.

Reverse-in parking practice shall be implemented by all personnel using the site parking lot. This practice allows personnel to drive away forwards with a full field of vision and not be caught unaware by other driver or pedestrian.

The following practices shall be treated as Site Traffic Violation and Security Violation

Notice will be issued for each violation:

1. Using mobile phone whilst driving;

2. Not wearing seatbelt whilst driving;

3. Ignoring security guards instruction and not stopping when required to do so;

4. Driving without valid driving license;

5. Car unattended while engine is running;

6. Parking in unauthorized parking place;

7. Driving aimlessly or recklessly;

8. Overloading and inadequate seating arrangements;

9. Poor maintenance of vehicles;

10. Vehicle registration not matching with license plate number;

11. Misuse of vehicle passes - pass number and plate number not matching;

12. Cutting corners;

13. Parking in any manner to obstruct the traffic flow / leaving broken down vehicles unattended in the sites;

14. Failing to give signals (indicators);

15. Exceeding the designated speed limit;

16. Overtaking;

17. Ignoring traffic signs;

18. Crossing road intersection without stopping;

19. Carrying passengers in vehicles not designed to carry passengers or without seating arrangements and hardtop roofs;

20. Driving without head-lights (day and night);

21. Embarking and disembarking passengers or materials whilst the vehicle is in motion;

22. Offering lifts to unauthorized person;

23. Not slowing down and stopping at the security gates or check points;

24. Ignoring others right of way;

25. Driving under the influence of alcohol or drugs.

16.6 Heavy, Mobile and Lifting Equipment

Subcontractors shall provide a valid copy certifying that all equipment (owned or rented) to be

mobilize on site has been inspected by a competent person to the Aevitas Pharmagro HSE Manager / Engineer before utilization. Each subcontractor shall certify that all mobile, heavy and lifting is compliant to Gujarat Factory Rules, 1950. Certification shall be in the prescribe Form No. 37.

Supplemental documents and/or dated periodic inspection records shall also be handed out to Aevitas Pharmagro upon arrival on site and made available at all times during mobilization. Daily logbooks shall be kept for each equipment and be available upon request. Lifting equipment shall have a load chart and display its maximum capacity.

17. 0 RECORD KEEPING REQUIREMENT

17.1 Record Maintenance

The ZCL Chemicals Project, subcontractors and consultants shall maintain detailed records and statistics relating to Health and Safety, Security and Emergency Preparedness in accordance with due diligence requirements and to assist in monitoring the effectiveness of the Health and Safety Program.

Records will be retained to ensure data are:

1. Retained;

2. Accessible;

3. Maintained and traceable.

17.2 Record Retention Duration

The following shall be used as a guideline for record retention duration:

1. Ten Year Retention

a. Kick-Off meetings records

b. Toolbox meetings records

c. Health and Safety Committees minutes and inspection reports

d. Task specific safety meetings

e. Emergency drills and simulation reports

f. Planned Inspection reports

g. Job Hazard Analysis

h. Work Permits

i. Safe Work Procedures

2. Twenty Year Retention

a. Aevitas Pharmagro meetings Records

b. First aid reports

c. First aid treatment records and logbooks

d. Incident investigation reports

e. Records of emergencies

f. Inspection reports;

g. Compliance and audit reports

3. Permanent Retention

a. Workers orientation records;

b. Scaffolding and temporary structures records and certification (high-risk activities);

c. Rigging equipment inspection records and certification;

d. Heavy and mobile equipment certification and inspection records;

e. Specialty trainings records;

f. Medical and industrial hygiene surveillances records;

g. Records of safety violations;

h. Records resulting from Refusal to Work.

18. 0 MANAGEMENT OF CHANGE

18.1 Policy

Management of Change (MOC) is the process of ensuring strict control and communication of any potential change to project specifications, standards, procedures, controlled design documents, materials, equipment, execution plans, or commercial contracts. As a minimum the following aspects will be addressed:

1. To control change consistent with regulatory requirements;

2. To ensure that all aspects of change are properly registered, documented, tracked and communicated to the project team in a concise and controlled manner;

3. To ensure a change is not proposed or implemented unless there is a basis around improving safety, operability, maintainability, legal, or environmental/regulatory/ community, and to document the same;

4. Assign appropriate levels of approval for changes.

A risk assessment shall be performed prior to implementation of any change to ensure that it does not introduce risks to people, property and surroundings. This exercise must take into consideration both planned and unplanned changes and sudden or gradual changes.

All areas of potential change must be considered:

1. Equipment, processes and lay-out;

2. Operation and maintenance procedures;

3. Design, construction, repair and maintenance;

4. Materials used and inherent properties;

5. Organizational structure and responsibilities;

6. Personnel training or competency requirements;

7. Personnel changes.

18.2 Responsibilities

The management of change process shall involve Aevitas Pharmagro representatives, subcontractors supervisors, workers and ZCL Chemicals representatives.

18.3 Records

Changes shall be documented and include the following information:

1. Reasons for the proposed change;

2. Risk assessments;

3. Authorization and date;

4. Checklist prior to implementation;

5. Any other relevant documentation and drawings.

19. 0 MANAGEMENT REVIEW

A management review will be held twice a year and/or upon completion of any portion of the project to assess any gap in regards to projects goals, objectives and performance during the period of review.

The list of participants includes but is not limited to:

1. Aevitas Pharmagro Project Director

2. Aevitas Pharmagro Project Manager

3. Aevitas Pharmagro Construction Manager

4. Aevitas Pharmagro HSE Manager/Engineer

5. ZCL Chemicals representatives.

20. 0 WORK PROCEDURES

20.1 Common Hazards

1. Oxygen deficiency or noxious gases in confined spaces;

2. Carbon monoxide exposure caused by engines running inside enclosures;

3. Toxic gas emissions caused by use of fuel fired heaters with inadequate ventilation;

4. Release of solvent vapors while using waterproof glues and paints;

5. Inhalation of, or skin contact with, paints, varnishes and coatings particularly those which are urethane or epoxy-based;

6. Inhalation of hazardous dusts occurring from sand blasting and rock drilling activities;

7. Exposure to airborne zinc (symptoms of Metal Fume Fever) caused by cutting or burning galvanized metal;

8. Chemical burns caused by skin contacts with lime, wet concrete, cement products and acids;

9. Noise-induced hearing loss caused by worker exposure to prolonged excessive noise.

10. Poor air quality, complicated by temporary construction enclosures (proper planning and consideration of equipment types, enclosure size, air changes and ventilation will prevent most air quality problems);

11. Collapse of stored or stacked materials due to improper chocking;

12. A load may shift on a truck during transit and collapse when the tie-downs are released;

13. Ergonomic hazards related to the work environment and use of equipment and machinery.

14. Subcontractors shall remain aware of these aspects of occupational health and safety, implement risk control measures and provide the required protective devices for the protection of the worker.

20.2 Job Safety Analysis (JSA)

Subcontractors that are assigned critical tasks must complete a job safety analysis before carrying out the work. Such analyses must be done when activities are performed on the work site as per risk assessment section of this HSE Program.

Job safety analyses will be completed by the Aevitas Pharmagro HSE Manager/Engineer, sub-contractors HSE representative and supervisor / foreman in conjunction with the workers. The goal is to not only inform all workers involved and to make them aware of the risks associated with a critical task, but also to find appropriate measures of protection to prevent any hazards.

The following situations qualify as a critical task:

1. Tasks that can create a serious accident if it is not executed properly;

2. New tasks that workers are not familiar with;

3. Tasks that require a large number of people;

4. Tasks with a high risk of hazard due to the nature of the work;

5. Changes to any aspect of the work:

6. Unforeseen changes to the work estimate;

7. Significant changes to the work environment;

8. Unforeseen changes to the work team structure.

20.3 Procedures

The Aevitas Pharmagro HSE Manager/Engineer, sub-contractors HSE representative and supervisor/foreman break down the task into steps, in order to highlight the critical elements for each one.

For each step, the supervisor and his team will identify the associated risks. The objective here is to assess what elements could pose as a hazard to the workers. Such hazards include:

1. Physical: lighting, noise, falls, etc.

2. Ergonomic: body position, material transportation, etc.

3. Chemical: paints, acids, solvents, gas emissions, etc.

4. Biological: viruses, insect bites, etc.

5. Psychosocial: fatigue, worked hours, experience, etc.

Once the risk level is known, the team member will decide if such a risk is acceptable, and will identify any necessary measures to reduce the risk and proceed with the task. In the case where the team member determine that a task has an unacceptable risk level, they must decide on the mitigation measures to be taken to complete the task safely. Where necessary, it is important that the supervisor establishes additional mitigation measures to ensure that everything is in place to prevent any hazards while the critical task is carried out.

Once all the risk assessment process has been realized, the supervisor and his team have to determine the most adequate mitigation measure. If the risk cannot be completely eliminated, they must decide whether the risk can be reduced by:

1. Engineering measures (guarding, ventilation, etc.);

2. Administrative measures (procedures, work instructions, etc.);

3. Personal protection equipment (PPE).

Each worker who has participated in the JSA must sign the JSA form.

The supervisor/foreman must then submit the JSA form to Aevitas Pharmagro HSE Manager/Engineer with the work permit.

A.1 HOUSEKEEPING

Aevitas Pharmagro recognizes the importance of good housekeeping practices in its areas of work.

Subcontractors are responsible to ensure that its work and lay-down areas are maintained in an orderly fashion and free of debris at all times. Aevitas Pharmagro reserves the right to maintain good housekeeping by cleaning up the subcontractors work area and back charging for the service.

Gutkha, pan masala, tobacco and other such material is not allowed at site. Spitting at site is strictly prohibited. Waste bins shall be kept on different location at site, and regular removal of waste from waste bin shall be carried out to avoid over filling and spreading of waste at the site.

Floors, platforms, stairs and walkways will be kept free of loose materials at all times.

All equipment, tools and materials used on the site will be removed from the work area and returned to the proper storage area upon completion of each job.

Garbage, material, or tools will not be permitted to be thrown from elevations. Lower in containers or special chutes.

Nails shall not be left protruding from formwork of other material. They will be bent over or removed completely.

Materials will be well secured, especially at elevations, to avoid movement during windy conditions.

Areas in the proximity of emergency equipment such as fire extinguishers, hoses, and emergency personal protective equipment shall be kept clear at all times.

Hoses, cables and cords will be kept in an orderly manner to prevent tripping hazards. Electrical and welding cables will not be allowed to lie in pools of water. Where possible, cables will be suspended above the ground, or will be protected from mechanical damage if they cannot be suspended. Unused hoses and cables will be rolled up and stored. Unless cables and hoses remain in an orderly manner, they will be rolled up on a frequent basis as determined by Aevitas Pharmagro.

Oily rags will be disposed of in closed metal containers - not with other garbage.

Hydrocarbons or chemicals will not be intentionally spilled onto the ground or into the sewer system. Spills will be reported and cleaned up immediately.

Rubbish, debris, and other materials will not be permitted to blow around freely. Daily clean-ups will be performed to collect all wind-blown materials.

A.1.1 Materials Stockpiling

Workers should avoid circulating at the bottom of the slopes of stockpiled materials.

Materials should be stockpiled at least 1 meter or greater distance from trenches and openings.

Materials must be stockpiled on a solid, leveled and stable base and effectively blocked, if necessary.

Materials such as pipes must have a restraining system to prevent the pile from spreading or collapsing or pipes from rolling.

Remove pipes from ends of pile.

Do not stack pipe higher than 1.5 meters (5 ft.).

Stockpiled materials must be checked to ensure that pieces are not sticking out into driveways or walkways.

While working or walking on a pile of materials, soils, rock, etc. workers must ensure that the slopes are stable and that they can safely go up or down the pile.

Check all bundles for broken or weak tie wires or bands before attempting to unload. Place slings on structural steel before releasing binder chains.

Do not allow piles to exceed ten bags in height unless the face of the piles is supported by the walls of a storage bin or enclosure.

Cross-pile bagged materials on skids and pile only to a convenient height. The height depends on the nature and ability of the mechanical aids used and the weight of the bagged materials.

Do not stockpile material on a scaffold beyond the safe loading capacity.

A.2 COMPRESSED GAS CYLINDERS

All cylinders and related equipment will be handled and stored in full compliance with all applicable legislation.

A.2.1 General

Compressed gas cylinders shall:

1. Be clearly identified in accordance with applicable legislation with regard to contents.

2. Be kept on a specially designed cylinder trolley with retaining chains when in use.

3. If transported by crane, hoist, or derrick, be handled in suitable cradle, nets, or skip boxes never by rope, chain slings, or slings choked around the body. Ensure securely stored before moving.

4. Have hoses and gauges removed, and valve guards installed whenever cylinders are transported, stored, or not in use.

5. Have cylinder valves and gauges kept clean and free from oil, grease and other hydrocarbons.

6. Be protected from physical damage, and kept away from areas where they can absorb undue heat or be a hazard in a fire situation.

7. Not be placed in confined spaces or non-ventilated areas.

8. Not be placed near electrical panels, or in proximity to welding grounds.

9. Not lift cylinders by the protective cap/guard.

10. Cylinders shall only be refilled by authorized dealers.

11. Empty cylinders shall be identified and separated from full cylinders and a protected cap shall be attached, and damaged cylinders shall not be used nor shall they be repaired but shall be returned to the supplier. Damaged or leaking cylinders must be tagged.

12. Before commencing work, check all joints with soap solution for any leak.

A.2.2 Storage

1. Compressed gas cylinders shall be stored, used and transported in a secure, upright position, even when empty.

2. Oxygen cylinders will be separated from highly combustible materials, especially oil and grease and other fuel gas cylinders by a minimum of 8 meters, or by a 1.5 meter high non-combustible barrier.

3. Storage areas will be clearly identified regarding contents of cylinders, and empty cylinders are to be marked as such.

4. Storage racks will be specifically designed to keep cylinders upright.

5. "No Smoking" and other appropriate warning signs shall be posted in the area.

6. Fire extinguishers shall be placed in the immediate vicinity.

A.2.3 Regulators and Hoses

1. Flashback devices shall be installed at both the regulator and torch end of oxygen/fuel gas systems used for cutting or torch welding.

2. Before connecting gauges to compressed gas cylinders, the valve shall first be opened (away from personnel or ignition sources) slowly to clear any debris.

3. Grease or oil shall not be applied to any cylinder threads or gauges. Instant combustion will take place if hydrocarbons are exposed to pure oxygen.

4. Before removing hose assemblies the cylinder valves will be closed, and then the hoses will be bled of gas by opening the regulating valves at the torch.

5. Hoses will be inspected for leaks frequently, particularly at the connections.

6. Hoses will not be placed where they will become a tripping hazard, run over by vehicle traffic, or crushed in doorways. Unventilated areas such as gang boxes or cabinets cannot be used to store hoses containing flammable gases.

7. Follow all manufacturer/distributor recommended pre-light and lighting procedures and guidelines.

A.3 PERSONAL PROTECTIVE EQUIPMENT (PPE)

A.3.1 General

Employees will wear appropriate personal protective equipment (PPE), for their performance of their normal work. MSDS and manufacturers specifications will be carefully checked to ensure that the type of equipment and material is suitable for the hazard.

Close fitting shirts and/or jackets, and long pants (all in serviceable condition, without rips, tears, etc.) will be worn at all times throughout the jobsite work area.

Shorts and sleeveless shirts are prohibited. Work clothes should be fire resistant and free of chemical contamination. Offices, lunchrooms, and other designated areas may be excluded from certain aspects of this policy with prior written authorization of Aevitas Pharmagro.

Special protective clothing (i.e., coveralls, protective rubber suits, and leg protectors for power saw operators) will be worn, as specified. Clothes that burn easily or meIt (i.e., polyesters and nylon) shall not be worn.

Sub-Contractors will ensure the availability, proper use, care and will require their workers to wear PPE, necessary for the workers' protection. Prior to use, all workers will be trained in the proper use and care of PPE. Workers will properly wear all such items where a hazard is known to exist or in situations where the workers personal safety is enhanced through its use.

All personnel, including visitors entering an active construction site will be properly equipped with approved safety footwear, head and eye protection. All articles of PPE will conform to IS standards or will meet the requirements of other recognized standards.

The Sub-Contractor is responsible to ensure that the following approved PPE, at a minimum, is available and used by employees.

A.3.2 Body and Limb Protection

Long trousers and long sleeved shirts (no muscle shirts, shorts, etc.) will be worn at all times.

Gloves shall be worn by workers at all times. Gloves shall be of the correct type, style, material, etc. to adequately mitigate hazards.

Leather jackets/apron and chaps (leather limb protection) (or equivalent fire-resistant material) will be worn for protection during welding and other hot processes.

A reflective, orange colored security traffic vest shall be worn at all time on the construction site.

Safety footwear conforming IS: 5852-1996 / IS: 11226 1993 standard shall always wear while on project site, incorporating box-type toe protection, sole/shank puncture protection.

Heavy equipment operators within enclosed cabins are exempt from wearing hard hats while operating, but enforced when the operator leaves the cabin. IS: 2925-1984 confirming hard hats and liners shall be worn in compliance with all manufacturers recommendations.

Except as indicated, protective headgear must be worn at all times by all workers and visitors on the site except for confines of offices, lunchrooms and washrooms.

A.3.3 Eye Protection

Eye protection is intended to protect against hazards like flying particles, chemical splashes, radiation (e.g. welding) sparks, etc. Clean eye and face protection regularly, and replace when lenses become pitted or scratched.

All eye and face protection must meet IS: 5983-1980, IS: 7524(Part-I)-1979 and IS: 9973-1981 impact and compliance requirements:

Approved eye glasses complete with permanently attached side shields (IS: 9973-1981 Eye and face protection compliant) to be worn at all times except when using other eye safety wear (e.g. welding hood, cutting glasses, etc.).

Tinted or shaded glasses shall not be worn at night, indoors or in poor light conditions. Specially designed safety eye protection (OTG) will be worn over any non-approved eyewear.

1. Contact lenses are prohibited in all working/operating areas.

2. Goggles, face shields and cutting and burning goggles must IS compliant.

3. Flash glasses (shade 3 or 4) are