Pln-Hse-Pta-0001 Hse Plan

SASA New PTA Complex Project
HEALTH, SAFETY & ENVIRONMENTAL (HSE) PLAN
REVISION
APPROV
Rev Date Descript Prepar ALCheck Approved
. ion ed ed BY
By By
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Doc. No PLN-ERP-PTA-001
New PTA Complex Project Release Date 16.06.2021
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HEALTH SAFETY & ENVIROMENTAL Rev. No: 00
PLAN Page No: 2 / 109
Table of Contents:
1 DEFINITIONS & ABBREVATIONS......................................................................................6
1.1 Definitions......................................................................................................................... 6
1.2 Abbreviations..................................................................................................................... 7
2 INTRODUCTION.................................................................................................................. 9
2.1 Purpose & Scope..............................................................................................................9
3 HSE MANAGEMENT SYSTEM OVERVIEW......................................................................10
3.1 HSE Management System..............................................................................................10
3.2 Golden Rules of Safety & Life Saver Rules..................................................................14
4 POLICY, LEADERSHIP AND COMMITMENT...................................................................15
4.1 HSE Principles / ‘Goal Zero’ Approach.........................................................................16
5 OBJECTIVES, TARGETS & LEGAL REQUIREMENTS....................................................17
5.1 Objectives....................................................................................................................... 17
5.2 Legal Requirements, Standards and Guidance............................................................18
5.3 Health, Safety and Environmental Performance Targets............................................19
6 ORGANIZATION, ROLES, RESPONSIBILITIES & RESOURCES....................................22
6.1 Roles and Responsibilities............................................................................................23
6.2 Project Manager.............................................................................................................. 24
6.3 Site Manager................................................................................................................... 25
6.4 Discipline Managers / Engineers...................................................................................26
6.5 Project HSE Manager.....................................................................................................26
6.6 HSE Engineer(s)............................................................................................................. 28
6.7 HSE Inspector(s)............................................................................................................. 29
6.8 Medical Personnel.......................................................................................................... 30
6.9 Line Supervisors (includes Supervisors, Foremen and Team Leaders)....................30
6.10 All Project Personnel / Employees..............................................................................31
6.11 Low Tier Construction Sub-Contractors..................................................................32
7 HAZARDS AND EFFECTS MANAGEMENT PROCESS...................................................33
7.1 General............................................................................................................................ 33
7.2 Hazard Identification......................................................................................................33
7.3 Construction and Completions.....................................................................................33
7.4 Initial Hazard Identification............................................................................................34
All rights reserved. Contains confidential information and may not be copied, used, reprinted or distributed by others
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7.5 Risk Assessments.......................................................................................................... 34

7.6 Method Statements.........................................................................................................35
7.7 Hazards & Effects Register............................................................................................35
8 TRAINING & COMPETENCY.............................................................................................35
8.1 HSE Induction................................................................................................................. 36
8.2 Trainings ........................................................................................................................ 37
8.3 Competency.................................................................................................................... 37
9.1 HSE Documentation.......................................................................................................38
9.1.1 Project HSE Plan........................................................................................................38
9.1.2 Project HSE Field Manual..........................................................................................38
9.2 Implementation & Operational Controls.......................................................................39
9.3 Safe Working Practices / General Safety Rules...........................................................39
9.3.1 Personal Protective Equipment................................................................................41
9.3.2 Fire Prevention and Protection.................................................................................42
9.3.3 Excavations................................................................................................................ 44
9.3.4 Permit to Work (PTW)................................................................................................45
9.3.5 Hot Work..................................................................................................................... 46
9.3.6 Confined Space Entry................................................................................................49
9.3.7 Safe Isolation (Energy Isolation)...............................................................................50
9.3.8 Lifting Operations......................................................................................................50
9.3.10 Safe Working at Height..........................................................................................55
9.3.11 Electrical Safety.....................................................................................................59
9.3.12 Housekeeping........................................................................................................ 62
9.3.13 Traffic Management...............................................................................................62
9.3.14 Hazardous Materials Storage and Handling.........................................................64
9.3.15 Pressure and Leak Testing....................................................................................67
9.3.16 Drugs, Alcohol and Smoking................................................................................68
9.3.17 Workshops............................................................................................................. 68
9.3.18 Worker Camps........................................................................................................69
9.3.19 Welfare, Amenity Provision, Catering, Sanitary, Personal Hygiene...................70
9.3.20 Office Safety................................................................................................................ 71
9.3.21 Noise and Vibration...............................................................................................75
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9.3.22 Night Operations....................................................................................................75

9.3.22 Weather Conditions...............................................................................................76
9.4 HSE Performance Monitoring and Reporting...............................................................77
9.5 Records & Records Management..................................................................................77
10 COMMUNICATION & CONSULTATION............................................................................78
10.1 Quaertrly HSE Committee Management Meetings..................................................78
10.2 Weekly HSE Meetings................................................................................................79
10.3 Weekly Construction Progress Meetings.................................................................79
10.4 Stand Down Meetings................................................................................................79
10.5 Toolbox Talks............................................................................................................. 80
10.6 Behavioural Safety Observation Programme..........................................................81
10.7 HSE Walkdowns and Observations..........................................................................81
10.8 Feedback from Site Personnel..................................................................................81
10.9 Safety Bulletin Boards...............................................................................................82
10.12 Reporting................................................................................................................ 82
11 CRISIS AND INCIDENT MANAGEMENT...........................................................................82
11.1 Incident Investigation, Analysis and Reporting......................................................82
11.2 Emergency Response...............................................................................................83
12 COMPLIANCE ASSURANCE AND CORRECTIVE ACTION.............................................86
12.1 Compliance Assurance.............................................................................................86
12.2 Audits.......................................................................................................................... 86
12.3 Inspections................................................................................................................. 87
12.4 Corrective Actions.....................................................................................................89
12.5 HSE Management Review.........................................................................................89
13 LOW TİER SUB-CONTRACTORSS MANAGEMENT AND REQUIREMENTS..................90
13.1 Low Tier Construction Sub-Contractors Qualification and Evaluation.................90
13.2 Low Tier Construction Sub-Contractors Responsibilities......................................90
14 ENVIRONMENTAL MANAGEMENT..................................................................................91
14.1 Environment Management and Environmental Monitoring Plan...........................91
14.2 Waste Management Plan (WMP)...............................................................................92
14.3 Spill Prevention and Response Plan........................................................................93
15 HEALTH MANAGEMENT PLAN........................................................................................93
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15.2 Fitness to Work.......................................................................................................... 93

15.3 First Aid Facilities......................................................................................................94
15.4 Occupational Health and Hygiene............................................................................94
15.5 Water Quality and Waste Water................................................................................95
15.6 Hearing Conservation Program................................................................................95
15.7 Hazard Communication Program.............................................................................96
15.8 Respiratory Protection Program...............................................................................96
16 SOCIAL MANAGEMENT AND MONITORING MEASURES..............................................96
16.1 Labour......................................................................................................................... 96
16.2 Grievances and Complaints......................................................................................97
16.3 Accidents.................................................................................................................... 97
16.4 Local Society and Labour Environment...................................................................98
17 INCENTIVE PROGRAM AND DISCIPLINARY ACTIONS..................................................98
18 ATTACHMENTS............................................................................................................... 100
ATT-1 HSE Policy................................................................................................................ 100
ATT-2 Management Commitment Statement....................................................................101
ATT-3 Legal Requirements.................................................................................................103
ATT-4 TRAINING MATRIX...................................................................................................107
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1 DEFINITIONS & ABBREVATIONS
1.1 DEFINITIONS
OWNER: SASA
CONTRACTOR: The Consortium formed by Técnicas Reunidas SA and Treunidas Rup Insaat
Ve Taahhüt Limited Sirketi for Engineering Works & Services, Supply and Construction Work
of PTA Complex Project in Adana, Turkey.
CONSTRUCTION SUBCONTRACTOR: METROPOL İNŞAAT.
Project: NEW PTA COMPLEX PROJECT
Low Tier Low Tier Construction Sub-Contractors: A party engaged by METROPOL
İNŞAAT. Low Tier Construction Sub-Contractors for the different phases of the project is the
firm or person who takes a portion of a contract.
Third party: A person or an organization other than the OWNER, Engineer, METROPOL
İNŞAAT, Low Tier Construction Sub-Contractors or worker.
Assessment (or evaluation): The process of analyzing and evaluating hazards. It involves
both causal and consequence analysis and requires determination of likelihood and risk.
As Low as Reasonably Practicable (ALARP): To reduce a risk to a level which is as low as
reasonably practicable involves balancing reduction in risk against the time, trouble, difficulty
and cost of achieving it. This level represents the point, objectively assessed, at which the
time, trouble, difficulty and cost of further reduction measures become unreasonably
disproportionate to the additional risk reduction obtained.
Audit (HSE): Independent, systematic and documented process of objectively obtaining and
evaluating verifiable evidence to determine that HSE controls:
are complete and consistent,
are (cost-) effective and efficient,
safeguard the resources and promote their effective use,
provide, and protect the integrity of, required records and information,
allow for compliance with policies, chosen standards, laws and regulations,
Audits are an integral component of any assurance process.
Health, Safety and Environmental Management System (HSEMS): Company structure,
responsibilities, practices, procedures, processes and resources for implementing Health,
Safety and Environmental Management.
Hazard: The potential to cause harm, including ill health and injury, damage to property,
products or the environment; production loss or increased liabilities.
Hazard Assessment: The process whereby the results of an analysis of a hazard are
considered against judgement, standards, or criteria that have been developed as a basis for
decision-making.
Risk: A term which combines the chance that a specified undesired event will occur and the
severity of the consequences of the event.
Risk Assessment: Is the process of quantifying the extent of risk by examination of the
adequacy of existing control measures.
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Incident: An undesired event that has caused or could have potentially caused personal
injury, illness and / or damage (loss) to assets, production or harm to environment or third
party.
Accident: Is an unplanned, unwanted event that resulted in an injury, occupational health,
and damage to property, and property loss, loss of business, or environmental damage, leak
or spill.
Near miss: An event or chain of events which could have the potential to caused fatality,
injury, illness and/or damage (loss) to assets, the environment, company reputation or third
parties.
Lost Time Incident: If an employee is unable to work on his next scheduled shift because of a
work-related injury or illness due to work environment.
Restricted Workday Case (RWD): Is a work-related injury that results in where the employee
the day after the event was assigned to a temporary job, or worked at a permanent job less
than full-time, or worked at a permanently assigned job but were unable to perform all duties
normally assigned to them.
Medical Treatment Case (MTC): Is a work-related injury that requires treatment by the out of
site medical staff and sources where there is no lost day after the incident.
First Aid Case (FAC): Is one-time treatment and subsequent observation of minor cuts,
scratches, burns, splinters, and other similar injuries, which do not ordinarily require medical
care.
Environmental Accident: Is an accident that arises from work site and/or within impact area
of work site with significant environmental extent and negatively affecting environment or that
may affect in long term.
Relevant laws and regulations: Laws, statutes, regulations, approval standards and other
legal instruments applied to construction work. They also include those guidelines established
by relevant organizations that have legal binding force.
Legal Compliance: Means all the items and actions required by laws/regulations/decrees etc.
are fully implemented and compliance records are maintained.
Performance Indicator: A 'vital sign' indicator showing the extent of successful performance
against set criteria over time.
Scaffolding: A temporary structure composed of a temporary floor (work floor) and its
supports used by workers to safely carry out work at a high place, where there is a risk that the
workers might fall.
Standard: A prescribed set of rules, conditions or requirements. Standard is an all-inclusive
term denoting specifications, recommended practices, procedures, guidelines, philosophies
and handbooks.
1.2 ABBREVIATIONS
TR TÉCNICAS REUNIDAS
ALARP As Low As Reasonably Practicable
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ATEX Explosive Atmospheres

DCC Document Control Center
ERP Emergency Response Plan
ERT Emergency Response Team
SMP Social Management Plan
EPC Engineering, Procurement, Construction
HAZMAT Hazardous Material
HAZID Hazard Identification
HAZOP Hazard & Operability Study
HSE Health, Safety and Environment
HSEMS Health, Safety and Environmental Management System
IFC International Finance Corporation
ILO International Labor Organization
ISO International Standard Organization
KPI Key Performance Indicator
LOTO Lock-Out/Tag-Out
LTI Lost Time Injury
MSDS Material Safety Data Sheet
MS Method Statement
O&M Operations and Maintenance
PTW Permit to Work
PPE Personal Protective Equipment
QA/QC Quality Assurance/Quality Control
RA Risk Assessment
RAP Resettlement Action Plan
SWL Safe Working Load
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2 INTRODUCTION
The objective is the design, supply and installation of NEW PTA COMPLEX PROJECT
(hereinafter referred to as the Project).
This Project HSE Plan developed for the Project to provide Health, Safety and Environmental
Management System (HSEMS) to protect all project employees, project productions and
environment. The HSE Plan provides a description of the Health, Safety, and Environmental
component of the Project Management System and the execution of HSE activities on the
Project.
Low Tier Construction Sub-Contractors HSE Management system must meet the
requirements of METROPOL İNŞAAT HSE Management System.
Personnel safety and equipment integrity is assured through a risk management process
during design, engineering, procurement and construction in accordance with recognized
codes, standards, local regulations & practices and OWNER requirements. The risks are
evaluated, using qualitative and quantitative techniques, and reduced to levels as low as
reasonably practical (ALARP) by appropriate engineering and managerial methods. The
continuing integrity of plant and equipment is controlled through the implementation of
Management Procedures that cover the inspection, operation, monitoring, maintenance and
modification.
HSE Management System information is contained in a hierarchy of documents covering
relevant activities and communicated in an open manner throughout the Project. The
documents are reviewed periodically and updated where necessary to reflect change and
experience. Key documents are subject to formal distribution control procedures.
With the commitment of ‘Goal Zero’, the Project will be supported by a Project Management
Commitment Statement. All incident/injury and hazard records, follow-up scheduling and
statistical analysis are recorded and trends established for management intervention.
2.1 PURPOSE & SCOPE

The purpose of the Project HSE Plan is to provide a system and strategy that enables Health,
Safety, and Environmental Policies and business objectives to be achieved via successfully
performing the Project work in compliance with METROPOL İNŞAAT requirements, the legal
requirements and the requirements of the contract.
This Plan defines the execution strategy, sphere of influence, Low Tier Construction Sub-
Contractors responsibilities, interfaces, execution strategy and methodologies for
implementation of the aforementioned requirements. It is designed to complement the Project
actions, schedule, and provide a disciplined framework for management of aspects of HSE
activities for the Project.
This Plan is applicable to all phases and functional aspects of the work scope for the Project.
All Low Tier Construction Sub-Contractors shall develop HSE plans, programs and procedures
for their scope of work in line with this document or shall implement METROPOL İNŞAAT’s
HSE Plans, Programs, Procedures in full compliance.
This HSE plan completes the Site HSE Plan prepared by the CONTRACTOR and that any
applicable requirements described CONTRACTOR Site HSE Plan that have not been taken
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into account in METROPOL İNŞAAT HSE Plan will be complied with. In case some
requirements differ between the 2 said documents and the applicable legal requirements, the
more stringent requisition will prevail.
3 HSE MANAGEMENT SYSTEM OVERVIEW

3.1 HSE Management System
HSE Management System (HSEMS) provides the framework to enable the implementation of
specified standards, procedures and practices in a consistent manner. It defines the
application of HSE into the work practices, processes, and system. HSEMS identifies
requirements relating to HSE and provides the baseline for application and Project execution
in compliance with the Health, Safety and Environmental Management Systems requirements
prescribed in ISO 45001 respectively.
The purposes of the ISO 45001 Health and Safety Management System are:
• To assist organizations in the establishment and achievement of sound Health & Safety
and Environmental goals.
• To provide organizations with a practical Health & Safety and Environmental
Management System model that can be integrated with existing management systems.
• Intended to focus on HSE elements that an organization can reasonably be expected
to control.
• Not intended to increase or change the legal obligations of organizations.
Common principles of ISO 9001 Quality Management System with ISO 45001 Management
Systems are:
• Roles/Responsibilities
• Context of the Organization
• Leadership and Worker participation
• Competence Training and Awareness
• Communication
• Documentation
• Document Control
• Monitoring and Measurement
• Nonconformance, Corrective and Preventive Action
• Records
• Internal Audits
• Management Review
• Continual Improvement
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The elements of the ISO 45001 Management Systems are illustrated in Figure-1 and begin
with HSE Policy.
HSE POLICY
Hazard ID, Risk Assessment and Controls

Aspects and Impacts
PLANNING Legal and Other Requirements
Objectives, Targets and Programs
Resources, Roles, Responsibility and Authority

Competence, Training and Awareness
IMPLEMENTATION Communication
& Documentation
OPERATION Control of Documents
Operational Control
Emergency Preparedness and Response
CONTINUAL IMPROVEMENT
Monitoring and measurement

Evaluation of Compliance
CHECKING Nonconformity, corrective action and preventive action
Control of Records
Internal External Audits
MANAGEMENT REVIEW
Figure-1: Elements of the ISO 45001 Management Systems
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ISO 45001 Management Systems are structured on a cycle of continual improvement

(Figure2).
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ISO 45001 is a tool that provides a framework and a roadmap that enables to:
• Enhance and improve the overall efficiency and effectiveness of existing and future
environmental responsibilities and operations,
• Control the environmental impact of its activities and services,
• Continually improve its environmental performance, and
• Commit to corporate citizenship development and practices as strategic objectives.
ISO 45001 consists of the following elements:
• Environmental Management Planning
- Environmental Aspects and Impacts Assessments, which involves an
environmental risk assessment of activities;
- Legal and Other Requirements (i.e., Contract requirements);
- Objectives, Targets and Programs – The Aspects and Impacts Assessments and
the Legal and Other Requirements guide the preparation of Objectives, Targets
and Programs;
• Implementation and Operation
- Involves the participation of personnel, suppliers, METROPOL İNŞAATs, and
includes implementation, communication, training, reporting and emergency
preparedness;
• Checking and Review
- Critical to the effective measurement of progress and continual improvement;
• Management Review
- Provides a regular assessment of the effectiveness of the management system in
achieving environmental policies and objectives; and
• Continual Improvement
- Allows key aspects of the plan to be improved to better achieve objectives.
Similar to many of the ISO standards, ISO 45001 Occupational Health & Safety Management
System is also based on several principles. These include:
• Context of the Organization – Understanding the interaction between the organization's
key HSE conditions, external issues (such as legal, social, and political), and internal
conditions (such as products/services, culture, and strategic direction) is crucial to
determining the functionalities and goals of the HSE Management System
• Leadership Involvement – Top management of the organization must be actively
engaged in the management system;
• Worker Participation – Workers, as the primary stakeholders of an occupational health
and safety management system, have the right to be involved in management system
processes; and
• Planning – This covers several key components of an HSEMS, including the
identification of hazards and assessment of risks and opportunities, legal and other
requirements, and objectives and targets. The most notable addition to this section is
that hazards and risks, opportunities, and legal requirements are framed in the context
of risk and opportunity management.
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• Support – includes requirements for communication and documentation, as well as

competence and awareness (which were derived from the OHSAS 18001 standard's
“Competence, Training, and Awareness” clause). Within the Competence subsection in
the new standard, we see another instance of the emphasis on OHS performance. This
determines the necessary competence for workers that can affect the organization's
HSE performance
• Operation – Encompasses the elements of “Operational Planning and Control”
(formerly known as “Operational Control”) and “Emergency Preparedness and
Response.” Two themes are more prominent in this section - Management of Change
and Procurement. Establishment of a process(es) for the implementation and control of
planned temporary and permanent changes that can affect OHS performance is
required, and unintended changes must be reviewed for controls to minimize any
adverse effects.
• Risk Management – Implementation of an OH&S management system is driven by the
risk management needs of the organization – the hazards and risks identified and the
controls that are determined to be necessary to prevent injuries and ill health;
• Performance Evaluation – A common trend throughout the ISO 45001:2018 standard is
the inclusion of more concrete and specific requirements, as exemplified in the clause
covering “Monitoring, Measurement, Analysis and Performance Evaluation.”
• Performance Evaluation not only requires specifying what should be monitored and
measured, it also addresses methods; criteria; when monitoring and measuring should
be performed; and when results must be analyzed, evaluated, and communicated.
• Continual improvement, a management system mantra, cannot be achieved unless
processes are in place to measure performance.
3.2 Golden Rules of Safety & Life Saver Rules

METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall Implement
METROPOL İNŞAAT’s Golden Rules of Safety and life saver rules throughout the execution of
the Project.
METROPOL İNŞAAT shall communicate to all Low Tier Construction Sub-Contractors
personnel the Golden Rules and Life Saving Rules and enforce compliance during the
performance of the work.
Additionally, refer to TRSA Safety essentials Section 4.2 and "Right to Stop the Job Policy"
Section 4.1, detailed in the CONTRACTORS Site HSE Plan (10330-00-091-PD-0010).
Golden Rules:
1. Think Safety... Before starting work on any job, identify potential hazards and safety
precautions.
2. Act Safely... Obey all rules and procedures applicable to the job. Use proper equipment
for the job.
3. Report all incidents, near misses, unsafe conditions and unsafe practices.
4. Maintain good housekeeping... Remove unnecessary items from the workplace, and
keep job sites free of hazards. Maintain good hygiene.
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5. Inspect tools and equipment... Do not use faulty equipment. Report defects to ensure
repair or replacement.
6. Do not operate or repair equipment... Unless you are authorized and qualified to do so.
Do not remove or misuse guards or protective devices.
7. Drive safely... Obey all speed limits, traffic rules and wear your seat belt.
8. Understand emergency procedures... Know the alarms. Know your muster point(s) is
located. Know where fire extinguishers are and how to use them.
9. Observe all warning signs... that warn of existing hazards and advise of the precautions
to be taken.
10. Listen to the Tool Box Talks and briefings before job starts… Know hazards of the job
and the Permit to Work requirements. Discuss the job with your supervisor and co-workers.
Life Saver Rules:
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4 POLICY, LEADERSHIP AND COMMITMENT
Policy:
HSE Policy is given in Attachment-1.
Leadership and Commitment
All Low Tier Construction Sub-Contractors shall implement HSE Policy during executing their
scope of work in line with METROPOL İNŞAAT’s HSE Policies to achieve Project HSE
objectives.
A commitment has been made to achieve a high level of HSE performance, which will realize
a “Goal Zero” performance in accordance with the HSE goals and objectives of METROPOL
İNŞAAT. People at all levels in the Project organization are responsible for leading and
engaging the workforce in meeting Project Health, Safety, and Environmental goals and
objectives.
Project Leaders will be held accountable for accomplishing this by demonstrating correct HSE
behaviors, by clearly defining HSE roles and responsibilities, by providing the required
resources and by measuring, reviewing and continuously improving HSE performance. The
Project Management Team will provide strong visible leadership and continuously
demonstrate commitment to develop, operate and maintain, review and continually improve a
Project culture which empowers individuals to take responsibility for their safety and embrace
and accept nothing but responsible HSE behavior.
To ensure the correct level of synergy a Project Commitment Statement has been developed
and provided as attachment to this Plan. Low Tier Construction Sub-Contractors will ensure
the same commitment from all employees for developing a positive HSE culture throughout
the Project and ensure HSE resource availability as well as employee involvement in HSE
matters and initiative to continuously improve in HSE performance. Project HSE Commitment
Statement shall be signed by METROPOL İNŞAAT Project Management and Low Tier
Construction Sub-Contractors. The Project commitment statement demonstrates the Project’s
commitment to HSE where the leadership have made clear their expectations and
commitment to achieving the Projects HSE goals. These statements embrace everyone
associated with the Project.
Management Commitment Statement is given in Attachment-2.
Distribution and Availability
METROPOL İNŞAAT Management and Low Tier Construction Sub-Contractors shall ensure
that all concerned parties (including third party METROPOL İNŞAATs and vendors) are
communicated with a copy of the HSE Policy, Project Commitment Statement and Project
HSE Plan.
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HSE policies shall be prominently displayed on notice boards. All Low Tier Construction Sub-
Contractors shall display at respective locations for their scope of work.
The HSE Policy and commitment shall be discussed intermittently though trainings and
toolbox talk with the workers in their working languages and communicated during the
induction process.
4.1 HSE Principles / ‘Goal Zero’ Approach
METROPOL İNŞAAT will give high priority to the management of health, safety and
environment. Everyone who works for project, anywhere, has the responsibility for HSE.
Good HSE performance and the health, safety, environment and security of everyone who
works for the project are critical to the success of the business. The project goals are;
• No harm to any person,

• No harm to environment or to the property
• Fully compliance with applicable regulations
The Project target is zero incidents and accidents to achieve the objective of no harm to
people and no negative impact on environment. It is recognized that incidents will occur, and
any incidents that do occur will be investigated by the management and a report issued, but
the objective is clear, no harm to people and to prevent recurrence.
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall implement a proactive
approach to implement an incident free work process. This is through plans and procedures
for educating and training personnel and maintaining the Project site in a safe condition and
for the safe execution of work.
Low Tier Construction Sub-Contractors will implement a hazard and risk management
process; through this process Project hazards will be identified, analyzed and appropriate
control and recovery measures will be identified before the commencement of the work
activities. METROPOL İNŞAAT ensures all Low Tier Construction Sub-Contractors will
conduct risk assessments and method statements etc.
Low Tier Construction Sub-Contractors shall ensure implementation of METROPOL İNŞAAT’s

Golden Rules of HSE while executing the project. METROPOL İNŞAAT shall ensure Low Tier
Construction Sub-Contractors comply with and implement PTW system to ensure safe
completion of activities. Low Tier Construction Sub-Contractors shall comply with Project HSE
PLANs and procedures.
METROPOL İNŞAAT shall ensure development of key plans and procedures for operational
controls and implemented by all Low Tier Construction Sub-Contractors. Low Tier
Construction Sub-Contractors shall develop and/or use plans and procedures for their scope
of work and approved by METROPOL İNŞAAT and implement METROPOL İNŞAAT
requirements. List of key plans and procedures for the Project are given in Attachment 4
-Related Documents.
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors will ensure proper
communication; for example, through trainings, toolbox talks, HSE meetings, HSE bulletins
etc. to the workforce about all significant hazards and control measures identified. Also,
METROPOL İNŞAAT ensures Low Tier Construction Sub-Contractors will make all required
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control measures available to relevant employees and that employees will be made aware of
their proper use.
METROPOL İNŞAAT shall ensure various trainings will be conducted to ensure the required
level of employee competency to complete the project in a positive HSE manner in compliance
with the required HSE standards.
METROPOL İNŞAAT shall ensure various required HSE trainings will be conducted by the
Low Tier Construction Sub-Contractors for their scope of work and also provide required
additional trainings to ensure the required level of employee competency to complete the
project in a positive HSE manner in compliance with the required HSE standards.
METROPOL İNŞAAT will implement programs with the Low Tier Construction Sub-Contractors
to motivate and encourage positive HSE behaviors, such as Incentive Program incorporating
Project requirements.
Low Tier Construction Sub-Contractors will implement METROPOL İNŞAAT’s “Stop Work
Policy” that ensures all Low Tier Construction Sub-Contractors and METROPOL İNŞAAT
personnel are authorized to stop a perceived unsafe act without negative consequences to the
person who called for the stand down.
METROPOL İNŞAAT shall ensure that all Low Tier Construction Sub-Contractors implements
the Goal Zero/No Harm to People, Environment and Property Program. METROPOL İNŞAAT
and Low Tier Construction Sub-Contractors shall aim for the maximum benefit from the
program and direct the Goal Zero leads and facilitators influencing skills and natural concern
and interest in the well-being and safety of others and in raising the workforce safety
awareness without diluting the vision in the following forums:
• Toolbox Talks
• Task Instructions
• Trainings
• Unsafe acts and conditions intervention and reporting support
• HSE meetings
• Recognition events
• Current and emerging HSE risks & themes, lessons learned from incidents and success
stories should be shared and discussion facilitated.
5 OBJECTIVES, TARGETS & LEGAL REQUIREMENTS

5.1 Objectives
METROPOL İNŞAAT shall ensure all Low Tier Construction Sub-Contractors implement HSE
objectives in line with following Project HSE Objectives:
• To execute the Project in accordance with HSE Polices and defined standards on HSE
at work.
• Work environment that fosters prevention of incidents and delivers goal of zero
incidents and accidents and no harm to people.
• To engineer a safe, reliable, operable and maintainable facility, through simple and
effective design.
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• To ensure all facilities are designed, constructed, commissioned, maintained and

operated to a high and consistent standard.
• To ensure that sufficient hazard assessments carried out, that the Project may be
designed, constructed and operated to meet ‘As Low As Reasonably Practical’
(ALARP) principles.
• To implement appropriate procedures and controls to minimize any potential adverse
effects to ALARP.
• To minimize emissions and waste generation through justification of decisions taken
during the Project Phases.
• Maximize the efficiency of resources and energy usage throughout the Project.
• To demonstrate that no permanent damage or harm to the environment has occurred.
• To ensure the requirements of all applicable legislation are observed.
• To implement the HSE management system and deliver best in class performance in
the design and execution of the Project.
• Effective and visible Leadership & Commitment of Senior Project Management.
• Identification of HSE training and delivery, and skills requirements for all employees.
• Effective reporting & communication processes.
• Effective incident reporting & investigation process.
• Effective & efficient safe systems of work.
• Ensure motivation and recognition of HSE achievements.
• Effective audit, review and improvement process.
• Project deliverables that satisfy contractual specifications, relevant standards.
• An HSE Audit and review program assuring compliance with and effectiveness of,
systems and processes, reviewed and acted on by Project Management.
• Respect neighbors and contribute to local communities and societies.
• Provide continual improvement of Project through continuous updating from lessons
learned and implementation of necessary actions.
• An environment in which every individual takes personal responsibility for safety.
5.2 Legal Requirements, Standards and Guidance

METROPOL İNŞAAT shall comply and ensure all Low Tier Construction Sub-Contractors
comply with the all-applicable Safety, Health and Environmental Laws and Regulations,
internationally recognized standards for Health & Safety Environmental Management Systems
(ISO 45001) and Quality Management System (ISO 9001), with the local laws and regulations,
industrial best practices and most importantly the Contract.
In support of the best practice management strategy detailed above, METROPOL İNŞAAT
requires its Low Tier Construction Sub-Contractors to adopt and apply high HSE standards
and guidance, examples of which appear throughout this document.
All applicable Safety, Health and Environmental Regulations and all OWNER and METROPOL
İNŞAAT standards, procedures, instructions, rules and regulations will be updated in the legal
register.
The list of applicable Health & Safety and Environmental Laws, Rules, Standards and
Legislation for the Project is given in the Attachment-3.
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5.3 Health, Safety and Environmental Performance Targets

Project performance targets in the form of Key Performance Indicators (KPI’s) shall be
developed by METROPOL İNŞAAT for HSE compliance. Both “leading” and “lagging” HSE
KPI’s are used with a focus on “leading” indicators. This philosophy will ensure an emphasis
on the execution of proactive measures identified as those that reduce the risk of incidents
rather than relying on “counting” the number of incidents. KPI performance will be used to:
• Determine the effectiveness of this plan;
• Identify where opportunities for improvement exit;
• Assess the level of compliance of Low Tier Construction Sub-Contractors.
All Low Tier Construction Sub-Contractors shall implement initiatives to achieve these targets.
See below Table for the Project Key Performance indicators:
Table 1.0: Key Performance Indicators
All incidents will be reported and recorded which will also be a performance indicator of the
HSE Management of the Project. Reporting of following will be performance indicators of the
HSE Management on site.
HSE Key Performance Indicators

No Leading Indicators Target
1 HSE Audit - >= 1
HSE Communication # of Posters or Lesson Learnt placed on noticeboards in
2 - >= 6
1 month
3 Unsafe Practices and Conditions Reporting / (UPCR/Worked Hours) *1000 - >=0,9
4 Weekly HSE Meetings with Low Tier Construction Sub-Contractors 1/Week
5 HSE Walkdowns 1/Week
6 HSE Training Rate (Training Hours / Worked Hours) * 100 - >=0,85
7 (# of TBT performed issued in 1 month / Worked Hours) * 1000 - >=3
8 Emergency Drills in 1 year - >= 2
9 HSE Reporting to CONTRACTOR 1/Month
10 HSE Incentive Program / # of HSE Incentives per Month - >= 1
11 HSE Inspection Program / # of HSE Report per Week / HSE Officer - >= 6
No Lagging Indicators Target
1 No of fatalities 0
2 Lost Time Incident frequency rate (Frequency per 200.000 hours) < 0.05
3 Lost Time Incident severity rate (Frequency per 200.000 hours) < 0.18
4 Total Recordable Injury Rate (Frequency per 200.000 hours) < 0.18
5 Incidents reported and investigated %100
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Environmental/Social KPIs are provided in the HSE PLAN and are given in the table below.
Environmental/Social KPIs
1.0 Environmental Management System Target
1.1 Environment/Social Audits completed vs planned %100
1.2 Environment/Social Trainings completed vs planned %100
Total % of Environmental/Social non-compliances closed within the agreed
1.3 %100
timeframe
2.0 Pollution Prevention-Air Quality Target
2.1 % of monitoring results compliant with legal requirements and standards %100
2.2 # of complaints received related to dust and/or odor 0
3.0 Pollution Prevention-Noise & Vibration Target
3.1 % of monitoring results compliant with legal requirements and standards %100
3.2 # of complaints related to noise 0
4.0 Pollution Prevention-Land Target
4.1 # of spills to land of volume greater than 100 liters 0
5.0 Water Management Target
% tests/samples compliant with legal standards for potable water (as
5.1 %100
identified in standards & requirements)
# of complaints received regarding negative impact to third party water quality
5.2 0
or quantity
% of non-compliances raised by OWNER/Engineer which are closed within
5.3 %100
agreed timeframe
5.0 Waste Management Target
5.1 Non-hazardous waste generated (kg) N/A
5.2 Hazardous waste generated (kg) N/A
5.3 Waste recycled/reused (kg) N/A
% of non-hazardous & hazardous waste disposal compliant with legal
5.4 %100
requirements
6.0 Natural Environment-Eco System Target
6.1 # of Project related injured/dead fauna 0
6.2 # of incident/damage to sensitive areas 0
8.0 Traffic Management Target
8.1 # of Traffic or access related complaints received 0
8.2 # of Traffic incidents 0
8.3 Road traffic Accident rate < 0,65
9.0 Cultural Heritage Target
# of known archaeological/cultural heritage sites damaged during construction
9.1 0
activities
10.0 Labor Target
10.1 # of Workers N/A
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10.2 Man-hours worked N/A

The conditions by which these metrics (the statistical information as per KPIs) will be reported
will be specified to suppliers and Low Tier Construction Sub-Contractors to ensure uniformity
and standard reporting. Other aspects of HSE performance reporting will include but not
limited to items as shown in the table below. This is the framework for performance reporting
and will be completed on weekly and monthly basis for the Project and will be submitted to
OWNER/Engineer on regular basis;
Table 2.0: HSE Performance Reporting Table

Contractor Site HSE Plan document (10330-00-091-PD-0010) Monthly HSE Summary Report
shall be used for performance reporting. Mentioned and will be implemented.
6 ORGANIZATION, ROLES, RESPONSIBILITIES & RESOURCES
The Project has set up an organization to implement this Project HSE Plan, the resources and
their roles and responsibilities are described in this section. All Low Tier Construction Sub-
Contractors shall submit their HSE organization charts along with their HSE plans, programs
and procedures for METROPOL İNŞAAT’s review and approval. METROPOL İNŞAAT and
Low Tier Construction Sub-Contractors shall establish and maintain sufficient and competent
resources (people, equipment, materials, and information) needed to implement the HSE
requirements, comply with regulatory requirements and laws and deliver the Project HSE Plan
effectively.
METROPOL İNŞAAT shall have a dedicated HSE Manager assigned to the project during the
planning and execution of the work and is supported by site HSE personnel and independent
specialists where required. HSE Manager shall, on behalf of METROPOL İNŞAAT, be
responsible for coordinating all health, safety, and environmental (HSE) matters or aspects
related to METROPOL İNŞAAT and Low Tier Construction Sub-Contractors work activities,
meeting the pre-mobilization and start of construction deliverables, launching the key HSE
program; the preparation of the related safety procedures and the monitoring/control of their
implementation.
METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors will provide
dedicated HSE resources for the Project. Low Tier Construction Sub-Contractors shall allocate
sufficient, competent and fit for work resources to ensure the effective implementation of
HSEMS throughout the various phases of the work.
Low Tier Construction Sub-Contractors shall provide full time HSE personnel; sufficient
number of HSE Manager/Chief, HSE Engineers / HSE Supervisors as it is required by the
applicable laws. In case of any safety issues (field requirement, poor safety results, high risks,
night works) additional resources can be requested from the Low Tier Construction Sub-
Contractors.
The ratio for HSE Site officers to workers shall be as below:
There will be one HSE personnel assigned to site for every 50 workers.
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Project Manager / Site Manager / HSE Manager must be informed of every Low Tier
Construction Sub-Contractors HSE personnel in writing for approval. The notification must be
accompanied by the curriculum vitae of the person.
The Low Tier Construction Sub-Contractors shall assign and retain key management
personnel to be responsible for the management and implementation of all HSE matters
throughout the various phases of the work.
Overview of METROPOL İNŞAAT’s organization (Project Management Team) roles and

responsibilities are described below. Low Tier Construction Sub-Contractors shall describe
their HSE organization, roles and responsibilities in their respective HSE Plans for
METROPOL İNŞAAT’s review.
6.1 Roles and Responsibilities

METROPOL İNŞAAT Project Management team members and supervisory positions have key
roles in implementing and monitoring the Project HSE Management Plan. The main
responsibles for the Project are:
• Project Manager (overall responsibility)
• Site Manager (management of day-to-day HSE activities on site)
• Corporate HSE Manager (who continuously supports Project HSE Team in terms of
providing guidelines, input, advice and information on all HSE matters throughout the
Project)
Other Key Team members and Project personnel;
• Discipline Managers / Engineers
• Project HSE Manager
• HSE Engineers
• HSE Inspectors
• Medical Personnel / Paramedics
• Line Supervisors (Supervisors, Foremen and Team Leaders)
6.2 Project Manager

Project Manager have the overall responsibility for the Project HSE Management System and
are specifically has the overall responsibility to ensure that Project HSE plans are
implemented through the use of prescribed processes, procedures and safe working practices
and that supervisors, employees and Low Tier Construction Sub-Contractors reporting to them
are aware of HSE policies and managements HSE expectations.
The Project Manager has responsibility for the effective implementation of the Project HSE
Management Plan throughout all phases of the Project. The Project Management Team shall
support the Project Manager in this endeavor. Project Manager is required to demonstrate
leadership and commitment and provide resources to enrich the Projects HSE Culture in the
following ways:
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• Ensure legislative obligations are met and HSE policies are effectively deployed to the
operational areas through the planning process.
• Reporting to TR and collaborating with TR and OWNER
• Ensure resources (METROPOL İNŞAAT and Low Tier Construction Sub-Contractors) are
provided to the workplace that will result in a safe and healthy working environment and
fulfil Project requirements.
• Develop a positive safety culture and foster behavioral change.
• Promote positive safety culture and obtain commitment from all the project personnel to
achieve project “Goal Zero” target.
• Develop and implement Continuous Improvement Processes at all levels in the
organization for the project.
• Provide visible commitment to a safe and healthy work environment by ensuring regular
inspections are undertaken and participating in HSE meetings and training as required.
• Ensure all incidents are documented via incident reports and investigations reviewed and
review all incident reports.
• Plan, organize, lead and control the Project team in the provision of full range of
contracted activities.
• Ensure compliance to HSE PLAN and equipment/materials coming to site comply with
Environmental and Social Management and Standards.
• Support and progress the Project Environmental Programs, and specifically coordinate the
commitment & motivation, risk management, incident, investigation, emergency
preparedness and other elements for which he has responsibility.
• Deliver safe, environmentally sensitive and a cost-effective Project.
• Maintain awareness and promote project goals in respect of HSE PLAN.
• Monitor and regularly review safety performance against predetermined targets and
initiate program for continual improvement.
• Ensure adequate training is provided to employees in HSE issues.
• Ensure adequate and competent supervision is provided taking account of safety needs.
• Take action to immediately rectify any unsafe situations or acts and undertake appropriate
disciplinary action against persons and Low Tier Construction Sub-Contractors who may
fail to fulfil their HSE responsibilities.
• Ensure safe work procedures are defined and documented for each task and
implemented.
• Chair HSE meetings where necessary as required with OWNER, METROPOL İNŞAAT
and Low Tier Construction Sub-Contractors.
6.3 Site Manager

Site Manager plays a critical role at the interface of the planning, implementation and
monitoring phases of the Project HSE Plan. The Project Site Manager shall:
• Provide leadership to METROPOL İNŞAAT and Low Tier Construction Sub-Contractors
teams as it meets the overall objectives of the HSE Program.
• Promote the setting up of site HSE rules and regulations, and HSE procedures and
programs, including a comprehensive training programs, emergency procedures,
incentive award scheme, etc.
• Monitoring the completion of Project activities in accordance with the requirements of the
Project HSE Plan.
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• Ensure all Low Tier Construction Sub-Contractors aware of the HSE Policies and HSE
Plans and further effective implementation.
• Ensure a safe working environment through the implementation of the project HSE
management system, HSE policies, programs, procedures and safe working practices;
• Ensure all Low Tier Construction Sub-Contractors develop Hazards and Effects
Management process (Risk Assessment, Job Hazard Analysis, Method Statements) and
implement effectively.
• Demonstrate commitment through the effective allocation of resources and the active
promotion of HSE in the workplace.
• Lead all HSE communication program (monthly HSE committee meetings, weekly HSE
meetings, weekly construction progress meetings, HSE Walkdowns).
• Allocate responsibilities for safety critical positions at the workplace and ensure those
responsibilities are understood and carried out in compliance with the Project HSE Plan.
• Ensure developing safe working practices for all potentially hazardous tasks where there
is potential to injure persons or damage plant or equipment.
• Review reports prepared by the Project teams on audits, incident/near miss reports and
performance indicators.
• Actively participate in incident/near miss investigations, reviewing findings and promoting
recommendations to prevent recurrence.
• Ensure all plant and equipment provided by construction Low Tier Construction Sub-
Contractors is relevant to the task, is well maintained and can be operated with safety.
• Ensure procedures and facilities to manage first aid, firefighting and emergency response
capabilities.
• Ensure all Low Tier Construction Sub-Contractors comply with the relevant legislative,
policy and METROPOL İNŞAAT requirements.
• Ensure Low Tier Construction Sub-Contractors are fully informed of HSE requirements
prior to establishing a presence on the workplace.
• Review Low Tier Construction Sub-Contractors safe working procedures and HSE
Management Plans, where required, prior to approval to commence work on the project
workplace.
• Attend toolbox meetings and construction meetings as required as per the frequency and
schedule.
• Ensure all personnel are suitably qualified, experienced, fit to work and trained to
undertake their work activities in a safe manner.
• Ensure control measures are implemented and monitored.
6.4 Discipline Managers / Engineers

• Support the Site Manager ensuring that HSE targets and goals are achieved.
• Ensure safety performance and accountability and compliance to the safety program;
communicate safety requirements and Job Bulletins.
• Ensure that the works under their control are planned and undertaken in such a way as to
give foremost regard to health, safety and environmental protection, as well as fulfilling the
requirements.
• Ensure that risk assessments and method statements are produced for the works under
their control and the details of these are communicated to the relevant persons.
• As part of the risk assessment process ensure that members of the project management
team, who will be responsible for taking the preventative and protective measures
associated with the project operations, are competent and aware of their duties and
responsibilities.
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• To arrange for all levels of staff under their immediate control to receive, where
necessary, adequate and appropriate training in health, safety and environmental matters.
• Ensure that personal protective equipment is used.
• Monitor environmental performance in their areas/sections and carry out regular site
area/section inspections.
• Provide an interest in and enthusiasm for environmental and social matters and set a
good personal example.
• Coordinate and plan the work schedule to ensure that conflicts of interest between Low
Tier Construction Sub-Contractors do not occur.
• Direct line supervisors to ensure requirements for their roles and responsibilities for HSE.
• Attend weekly construction progress meetings which should include HSE topics.
• Ensure that concerned personnel and Low Tier Construction Sub-Contractors analyze all
hazardous work, identify any hazards with a serious loss potential and establish work
execution procedures.
• Ensure that work execution procedures have been provided for all hazardous work, and
they incorporate adequate provisions for HSE.
• Patrol the site daily and ascertain the status of the work and compliance with HSE
requirements.
• Promote housekeeping and waste disposal at the highest standard.
• Report to the Site Manager on any anticipated matters of concern and on topical matters.
6.5 Project HSE Manager

Project HSE Manager reports to Project Manager and Corporate HSE Manager and is
supported by site HSE personnel and independent specialists where required. Project HSE
Managers’ main duty is to advise and guide the Management on HSE issues and oversee Low
Tier Construction Sub-Contractors HSE performance and implementation of this HSE Plan
and program. HSE Manager shall be responsible for coordinating all Health, Safety, and
Environmental (HSE) matters or aspects related to METROPOL İNŞAAT and Low Tier
Construction Sub-Contractors work activities, meeting the pre-mobilization and start of
construction deliverables, launching the key HSE program; the preparation of the related
safety procedures and the monitoring/control of their implementation, including those related to
welfare of the workers.
The responsibilities and accountabilities of the Project HSE Manager are:

• Development of Project HSE elements of the HSE Management System, HSE supporting
plans and procedures and approve HSE Management procedures as required.
• Support and guide effective HSE Management System implementation on the Project.
• Ensure Low Tier Construction Sub-Contractors develop HSE Plans and procedures and
are consistent with Project requirements as applicable and are approved by METROPOL
İNŞAAT and implemented.
• Provide HSE expertise in support of the risk management process.
• Proactive in the investigation of incidents and near misses in accordance with Project
Incident Investigation procedure; Lead the investigations as required. Co-ordinate with
Low Tier Construction Sub-Contractors and ensure all incidents are reported and
investigated. Prepare the final incident reports and submit to METROPOL İNŞAAT
Management.
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• HSE Liaison with Low Tier Construction Sub-Contractors and/or regulatory authorities.
• Co-ordinate with all the Low Tier Construction Sub-Contractors for HSE performance data
collection to meet Project reporting requirements;
• Oversee HSE requirements for all phases and elements of the development for respective
sites.
• Participate in site/facility HSE audits and ensure compliance assurance programme is
effectively implemented for the Project.
• Provides support to Project Manager and Site Manager and his team on all technical and
commercial HSE related issues throughout all Project phases.
• Develop METROPOL İNŞAAT Management HSE Targets / Performance Standards for
the Project and monitor / review regularly.
• Ensure that all the hazards associated with the development are identified and assessed,
and that appropriate controls are put in place to reduce risks to ALARP.
• Monitor, audit and review implementation of the HSEMS and HSE Plans.
• Provide verbal and written reports to the Project Manager, the Project teams and
Corporate HSE functions on all aspects of HSE throughout the Project.
• Provide advice to Project team to resolve HSE issues in a timely and effective manner.
• Provide advice and information on HSE matters relating to all site / facility personnel.
• Maintain a daily working relationship with the HSE team, Low Tier Construction Sub-
Contractors in relation to their compliance with the provisions of the Project HSE Plan and
regulatory requirements.
• Coordination and scheduling of HSE review activities and meetings with METROPOL
İNŞAAT and Low Tier Construction Sub-Contractors.
• Ensure effective implementation of Golden Rules of Safety, Life Saver Rules, on the
Project and cascade the requirements to the Low Tier Construction Sub-Contractors for
implementation.
• Coordinate and organize HSE meetings, workshops etc. as per the Project HSE Plan and
schedule with Low Tier Construction Sub-Contractors and METROPOL İNŞAAT
Managements.
• Ensure METROPOL İNŞAAT personnel and the personnel of Low Tier Construction Sub-
Contractors are fully trained and competent with respect to all work activities to be
performed, including all HSE aspects of the work.
• Review the training programs and quality of trainings provided by the Low Tier
Construction Sub-Contractors and provide any additional training required.
• Ensure emergency preparedness and response plans and resources are readily available
at all the times and drills conducted regularly.
• Ensure medical facilities and medical resources are adequately provided for the Project.
• Ensure HSE Key Performance indicators for the Project are established and reviewed
regularly.
• Ensure METROPOL İNŞAAT and Low Tier Construction Sub-Contractors comply with the
legal requirements and review compliance periodically.
• Ensure the Project HSE requirements are communicated to all and verify compliance
through follow-up meetings and audits.
• Ensure effective communication aids such as (toolbox talks, meetings, notice boards,
posters etc.) are implemented.
• Review the effectiveness of the HSE Performance and report to Management as required;
• Review and monitor environmental control plans, i.e., Waste Management Plan.
• Promotes “Incident and Injury Free” strategy and “Goal Zero”.
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• Directs, manages and trains other field health and safety staff as necessary to attain HSE
management standards set by the Project;
• Supports Site Manager and other Project Team Members in all communications and
decisions with OWNER in relation to HSE.
6.6 HSE Engineer(s)

The site HSE Engineer(s) provide specialist information to the project management team, field
personnel and Low Tier Construction Sub-Contractors staff.
HSE Engineer(s) shall:
• Assist the Project HSE Manager in development of Project HSE elements of the Project
HSE Management System, HSE supporting plans and procedures and approve HSE
management procedures as required.
• Support and guide effective HSE Management System implementation on the Project.
• Ensure Low Tier Construction Sub-Contractors develop HSE Plans and procedures and
are consistent with Project requirements as applicable and are approved by METROPOL
İNŞAAT and implemented.
• Provide HSE expertise in support of the risk management process.
• Act as a team member for incident investigations as required. Co-ordinate with Low Tier
Construction Sub-Contractors and ensure all incidents are reported and investigated.
• Oversee HSE requirements for all phases and elements of the development for sites.
• Support Management by participating in site/facility HS audits.
• Provide field support to Construction Managers and Construction Supervision to guide on
HSE Safe working practices, Project HSE Requirements etc.
• Advise Project and site personnel of the requirements of legislation, guidelines, codes of
practice, standards, risk assessments and method statements relevant to the workplace.
• Ensure that Project HSE Plan requirements are consistently and comprehensively
deployed on site.
• Co-ordinate the workplace inspection program and assist with regular internal HSE audits
of the system and/or associated processes, procedures and work practices; Perform
inspections and audits.
• Assist in the development, implementation/delivery and revision of the HSE induction and
training programs.
• Ensure effective implementation of Project HSE initiatives such as toolbox talks etc.
• Communicate METROPOL İNŞAAT’s Golden Rules of Safety and Life Saver Rules to all
the Project personnel and ensure proper implementation.
• Ensure all Project activities are carried out safely and guide site supervision on the day-to-
day safety issues.
• Ensure Permit to Work implementation as per Project requirements;
• Participate in Emergency Response Drills and ensure all resources are readily available.
• Ensure HSE PLANs, Waste Management Plans etc. are implemented and monitor on
daily basis.
• Ensure and monitor the requirements for PPE, lifting operations, and working at heights,
using power tools, hazardous material storage and use etc. on Project.
• Ensure the Project HSE requirements are communicated to all and verify compliance
through follow-up meetings and audits.
• Coordination and scheduling of HSE review activities.
• Review the effectiveness of the HSE performance and report as required.
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• Assist in the identification, assessment and development of control mechanisms for

hazards in the workplace.
• Assist in the investigation and reporting of incidents on site.
• Ensure HSE information is systematically disseminated to all personnel.
• Co-ordinate the collection, recording and analysis of HSE data
6.7 HSE Inspector(s)

• Review the effectiveness of the HSE Performance and report as required.
• Assist in the identification, assessment and development of control mechanisms for
hazards in the workplace.
• Assist the Project HSE Manager and the HSE Engineer(s).
• Patrol the site as frequently as possible, and inspect current activities and working
conditions.
• Inform the Site Manager and Discipline Manager/Supervisors of any unsafe conditions or
violations, remedial action required, and record and retain the details.
• Prepare daily HSE reports and report to the Project HSE Manager & HSE Engineer on
major HSE activities and topics.
• Monitoring and implementing corrective measures on all matters relating to safety.
• Responsible for the evacuation of all personnel in his designated area in the event of an
emergency alarm, ensuring all personnel have cleared the area before he leaves.
Authorized to stop any unsafe activities of work.
• Liaise with the managers and engineers regarding any matters relating to safety.
• Carry out routine safety inspection within his designated area.
• Ensure PPE requirements are strictly observed by all site personnel. (Safety hard hats,
glasses, shoes, harnesses, etc.)
• Attend toolbox meetings conducted by foremen.
• Ensure good housekeeping is maintained at all times.
• Inspection of safety barriers.
• Check condition / storage of fire extinguishers within his area.
• Check crane certificates entering his area.
• Check crane operators, plant operators and driver licenses of personnel working within his
area.
• Ensure all plant and equipment is operated safely.
• Carry out safety checks on plant and equipment.
• Ensure that scaffolds are erected / modified only by qualified personnel.
• Control the implementation of HSE rules and regulations.
HSE Organization Chart
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6.8 Medical Personnel

• Ensure effective fitness to work process for METROPOL İNŞAAT personnel and ensure
Low Tier Construction Sub-Contractors have the fitness to work process to assure all the
personnel engaged on the project are fit for their work.
• Ensure that the entire Project personnel including Low Tier Construction Sub-Contractors
personnel fitness to work certificates are provided, verified.
• Ensure first aid facilities are established as per the Project requirements.
• Ensure Low Tier Construction Sub-Contractors provide required medical resources
including first aiders.
• Conduct health & hygiene inspections per HSE Plan inspection schedule.
• Implement health & welfare fitness programs to promote a healthy life style for all site
employees.
• Review/Audit pre-employment medical testing to ensure employees are fit for duty.
• Participate in medical emergencies and coordinate with Project management.
6.9 Line Supervisors (includes Supervisors, Foremen and Team Leaders)

• Demonstrate HSE leadership and management skills.
• Accept they are “key” to HSE performance and responsible for their crews’
implementation of HSE practices.
• Identify and control hazards by ensuring Job Hazard Analysis and MS developed for
critical activities and implemented.
• Know, understand and supervise their work with the expectations and standards of HSE
policies and procedures and fully apply the Project HSE Plan.
• Demonstrate leadership and performance, which promote individual responsibility and
which endorses the “Incident and Injury Free” philosophy.
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• Be directly responsible and accountable for HSE performance and compliance with
requirements applicable to their areas of supervision.
• Take all reasonable action to optimize the HSE performance of his subordinates.
• Initiate incident/ near miss investigations and participate and assist in the preparation of
required reports.
• Effectively implement toolbox talks on the Project.
• Ensure that personal protective equipment (PPE) is used.
• Communicate METROPOL İNŞAAT Golden Rules of Safety and Life Saver Rules and
implement throughout the Project.
• Implement project PTW system where applicable and ensure precautions taken as per the
PTW system requirement.
• Stop unsafe acts and correct unsafe conditions.
• Use toolbox talks, risk assessments and safe work instructions to identify hazards in work
tasks of their crews & implements controls to keep the job site safe & incident free.
• Report near misses and investigate to avoid reoccurrence.
• Check with work crews for any health-related issues prior to starting work by monitoring
health of work crews.
6.10 All Project Personnel / Employees

All personnel employed on the Project are responsible and accountable for:
• Accepting individual responsibility for their own safe behavior as well as sharing
responsibility with their fellow workers and line supervision to “look out for their own as
well as their co-workers” safety.
• Complying with and constructively participating in the Project HSE activities of the Project
HSE Management System.
• Work in a safe manner at all times and contribute to the implementation of the “Incident
and Injury Free” philosophy.
• Take reasonable care for the safety of themselves and other personnel who are at the
workplace and who may be affected by any acts or omissions on their part.
• Comply with the safe working policies, procedures and practices adopted by METROPOL
İNŞAAT as part of the safe working system.
• Co-operate with their OWNER in ensuring that their workplace is as safe and healthy as is
reasonably practical.
• Report to their supervisor any hazard or potential hazard in the workplace or any incident,
personal injury, accident or near miss, HSE observations (unsafe acts and unsafe
conditions) that may have occurred during the course of the work to the supervisory staff
immediately.
• Correctly use, store and maintain personal protective equipment issued for the protection
of workers against workplace hazards.
• Follow all verbal or written safe work procedures, practices and directions.
• Observe all warning signs and notices.
• Attend toolbox meetings and pre-start meetings.
• Complying with HSE requirements which apply to an individual’s work activities.
• Maintain the work area in an orderly condition.
• Wear PPE appropriate for the work activities.
• Comply with work instructions and permits.
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6.11 Low Tier Construction Sub-Contractors

All Low Tier Construction Sub-Contractors engaged on the Project shall conduct their work
activities and meet their duty of care responsibilities in compliance with this Project HSE Plan,
METROPOL İNŞAAT HSE Policies & procedures and the relevant legislation for the work
activities performed.
The Low Tier Construction Sub-Contractors has the responsibility to:

• Take all reasonable measures to prevent damage, injury or loss to property and personnel
of METROPOL İNŞAAT and all other persons who may be affected by the Project.
• Develop and implement Project specific HSE plans and/or procedures in line with Project
HSE Plan & procedures for their scope of work and must be approved by METROPOL
İNŞAAT and/or comply with METROPOL İNŞAAT’s HSE Plans and Procedures.
• Low Tier Construction Sub-Contractors shall allocate sufficient, competent and fit for work
resources to ensure the effective implementation of HSE throughout the various phases of
the work.
• Implement and enforce the requirements of the Project HSE Plan and procedures,
regulations and codes as they apply to the scope of work.
• To take all reasonable measures to ensure no damage to the environment.
• To observe and comply with all Environmental rules and regulations.
• Meet their legal and their HSE obligations as required by the Contract.
• Co-operate with METROPOL İNŞAAT personnel to ensure HSE plans are effectively
implemented and a safe working environment is maintained.
• Provide sufficient performance data and information that will demonstrate the Low Tier
Construction Sub-Contractors compliance with prescribed performance targets and
commitment to continuous improvement.
• Complete designated safety activities and submit weekly and monthly performance
reports to METROPOL İNŞAAT’s Project HSE Manager.
• Respond positively to employee safety suggestions and take appropriate action to correct
any unsafe conditions.
• Effectively implement Project HSE programs such as METROPOL İNŞAAT’s Golden
Rules of Safety, Life Saver Rules, Emergency Response Plans etc.
• Provide required trainings to their employees as per the approved training matrix.
• Reinforce positive safety initiatives and behavior by being part of the HSE observation
(safe - unsafe act & condition) process;
• Implement disciplinary procedures when any of their employees fail to comply with their
responsibilities.
• Develop / implement incentive program procedures when any of their employees fail to
comply with their responsibilities.
7 HAZARDS AND EFFECTS MANAGEMENT PROCESS

7.1 General
All Project hazard and effects will be systematically managed to ensure that facilities will be
designed, constructed, installed and commissioned to enable safe, secure, healthy and
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environmentally sound performance throughout the operational life of the facility. METROPOL
İNŞAAT and Low Tier Construction Sub-Contractors shall carry out a systematic assessment
of all Health, Safety and Environmental risks during planning and design, construction,
installation, inspection, pre-commissioning activities. Necessary plans and procedures will be
developed for mitigation measures of the environmental impacts and relevant monitoring
requirements. Low Tier Construction Sub-Contractors shall participate in the HSE studies
carried out by METROPOL İNŞAAT and implement the requirements as applicable for their
respective scope of work.
7.2 Hazard Identification
Hazard identification will initially take a very wide perspective so as not to miss any
foreseeable hazards, which have the potential to cause a major accident. No hazard will be
rejected from fuller assessment without careful consideration and the presentation of sound
evidence that it is not significant.
Systematic hazard identification exercises will be conducted and will involve, where
appropriate, the participation of members of the workforce.
7.3 Construction and Completions
METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors will adopt various
‘Hazard and Effects Management Process’ techniques to identify hazards in construction and
commissioning phases to assess their likelihood and consequence, analyzing the cause and
implementing control measures to manage the risk to ALARP effectively in consistency with
Low Tier Construction Sub-Contractors procedures and guidelines and approved by
METROPOL İNŞAAT. METROPOL İNŞAAT shall guide Low Tier Construction Sub-
Contractors and participate where required to ensure all hazards analyzed and control
measures identified to reduce the risk to an ALARP condition for respective scope of works.
The process of hazard and effects management:

• Hazard Identification
• Risk Assessments
• Method Statements
These assessments will be conducted such that they can reflect how the identified HSE
hazards and risks are to be managed throughout the applicable project phases.
The results of the assessments shall be incorporated into the work plans, method statements
and further reflected in the Permit to Work, where applicable.
Specific risk assessments for every routine task shall be carried out in the form of RA.
Assessments will be performed for all “non routine” operations which present potential
hazardous operations.
Method Statements will be used to communicate to the workforce performing the task the
Health, Safety and Environmental hazards and control measures to be implemented prior to
the commencement of work.
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7.4 Initial Hazard Identification
Risk assessments shall be prepared by Low Tier Construction Sub-Contractors prior work
commence. Identified hazards and risks shall be hold in Hazard Identification Log and RA shall
be updated according to new condition of the works and hazards and risks. All RA prepared by
the Low Tier Construction Sub-Contractors shall be submitted to METROPOL İNŞAAT for
approval.
7.5 Risk Assessments
Hazard assessments of tasks / jobs shall be performed using the Risk Assessment Matrix.
Risk Assessments is a process used determine hazards and control measures to all activities,
tasks. Generic risk assessments are particularly applicable to activities or tasks that are
usually carried out in a similar way by a number of people at different work places, such as,
manual handling, scaffolding etc. However, care must be taken to ensure that the
activities/tasks/workplaces really are similar and that the generic assessments are applicable
for the local circumstances. Factors to consider include;
• Are the activities/tasks/hazards, etc. really the same?
• Is the working environment the same?
• Are the employees, etc. covered by the same assessment?
Specific risk assessment must be conducted for non-routine activities and tasks or where
generic assessments are not applicable for the local conditions, circumstances or workplace.
In many cases, information developed for generic assessments can provide valuable input to
specific assessments.
Specific risk assessment requirement shall be determined by the supervision team for every
individual activity and where Permit to Work requiring a specific risk assessment to identify the
control measures for the activity.
Where appropriate a specific risk assessment will be developed for the following:
• Non-routine or one-off tasks.
• New tasks or introducing new work methods.
• Routine tasks being carried out in unusual circumstances.
• When new staff are performing a significant task for the first time.
• A job with a risk of release.
Risk Assessments will be prepared by the Low Tier Construction Sub-Contractors work team
either engineer or supervisor/ HSE supervisor engaged in the task/activity. Risk Assessments
will be reviewed by METROPOL İNŞAAT line supervisor and HSE department and the
finalized document will be signed off and will be communicated to all members of the work
team during toolbox talk meeting.
7.6 Method Statements
Low Tier Construction Sub-Contractors shall develop Method Statements for the activities for
the scope of work to ensure the appropriate safeguards are identified for the safe execution of
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the job and submit for METROPOL İNŞAAT approval. The Method Statement shall include the
safety precautions.
7.7 Hazards & Effects Register
The Hazard & Effects Register lists all hazards identified from hazard identification. Its purpose
is to provide a system that will enable the Project to identify and review hazards, assess
potential risks and implement appropriate control measures.
Progressively Hazards can be added from review of Hazard / Near Miss Reports, Incident
Reports, Safety Inspections and Audits.
METROPOL İNŞAAT shall ensure all Low Tier Construction Sub-Contractors will establish
Hazard and Effects register for their scope of work.
8 TRAINING & COMPETENCY

METROPOL İNŞAAT shall ensure that all his personnel and the personnel of Low Tier
Construction Sub-Contractors are fully trained and competent with respect to all work activities
to be performed, including all HSE aspects of the work. For personnel, with roles responsible
for the execution of HSE critical activities, where action (or inaction) while performing such
tasks could lead directly to a significant incident, special safety training modules and
competence assurance requirements, including licensed third-party certification as required by
local regulations shall be implemented.
METROPOL İNŞAAT shall ensure that all personnel engaged in the performance of the work
are physically fit, competent, qualified and/or experienced to perform their respective duties.
METROPOL İNŞAAT shall ensure that the line management and supervisory personnel
including Low Tier Construction Sub-Contractors are competent to identify and assess HSE
risks systematically.
METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors provide required
trainings for their personnel for the work scope and shall monitor the quality of the training
provided. METROPOL İNŞAAT will require the quality of training to be improved and shall
work with the Low Tier Construction Sub-Contractors until the quality of training issue is
resolved in a sustainable manner to satisfaction of METROPOL İNŞAAT or alternatively take
over and provide the required trainings.
Prior to commencement of work at the Project, METROPOL İNŞAAT shall ensure that all
personnel engaged on the worksites attend a HSE Induction course to make them fully aware
of the associated hazards and precautions to take with respect to the related work and work
site.
HSE Inductions and all HSE Training requirements for the Project are detailed in HSE Training
Program.
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8.1 HSE Induction
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors personnel shall attend the
Project HSE Induction training before commencing the work.
All Low Tier Construction Sub-Contractors workforces will be inducted by Low Tier
Construction Sub-Contractors HSE Departments before undertaking any workplace duties.
(METROPOL İNŞAAT Project HSE Manager shall review and approve the induction and HSE
training contents).
The Induction course shall cover as a minimum:

• METROPOL İNŞAAT, Low Tier Construction Sub-Contractors HSE Policies and Safety
Rules.
• Project Disciplinary Policy.
• METROPOL İNŞAAT Project Management Commitment & importance of HSE.
• Emergency Response arrangements.
• Goal Zero/ No Harm to People Program.
• Security Arrangements.
• Safe Work Practices.
• Incident Reporting & Investigation.
• Emergency Response.
• Medical Facilities.
• METROPOL İNŞAAT Golden Rules of Safety & Life Saver Rules.
• Commuting policy compliance to ensure safe driving / travel.
The Induction has benefits including:

• Introducing the new employee to key personnel.
• Allows Management to express its commitment to and importance of safety and health.
• Provides opportunity to ensure HSE expectations are understood.
• Ensures the employee is versed in administrative procedures associated with the job.
• Provides feedback to Management through a competency-based assessment on how well
the inductions are understood, relevancy of the content and effectiveness of the facilitator.
The induction process is just the first step in ensuring the new employee is made fully aware of
the potential hazards in their workplace and their role within the safety program.
Employees to the Project will be presented with an ID Card on completion of the induction.
All visitors to site shall be given an outline briefing of their responsibilities as contained in the
formal induction. Such visitors shall be given an information card stating the Project safety
rules. Visitors shall be provided with necessary PPE - hardhats, boots, safety spectacles etc.
and accompanied at all times on site. Low Tier Construction Sub-Contractors must inform
METROPOL İNŞAAT HSE department about their visitors before visitors arriving to the site.
8.2 Trainings
In the course of execution of the Project, METROPOL İNŞAAT shall ensure Low Tier
Construction Sub-Contractors provide required trainings for their personnel for the work scope
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and shall monitor the quality of the training provided. Low Tier Construction Sub-Contractors
shall prepare and submit the training procedure for approval. METROPOL İNŞAAT shall work
with the Low Tier Construction Sub-Contractors or alternatively take over and provide the
required additional trainings. HSE training program shall include the increasing awareness of
local security issues, safety, safe ways of working. Such training program shall include details
of types of training modules and the modules content required from induction training through
to job hazard analysis, PTW training, etc. to task related topics such as working at heights,
confined space, etc.
Additionally, the training program developed by the OWNER and CONTRACTOR shall be
implemented as required during the project.
Each Low Tier Construction Sub-Contractors shall develop training matrix for the respective
scope of the work in line with METROPOL İNŞAAT’s HSE Training Matrix (A tentative listing of
the trainings and the target groups for the training is provided and this list shall be revised as
project progresses further) and submit along with their HSE plans for approval.
HSE Training Matrix for the Project is given in Attachment-4.
METROPOL İNŞAAT’s and Low Tier Construction Sub-Contractors’ personnel shall participate
in any additional trainings that may be provided by METROPOL İNŞAAT.
All trainings will be recorded in HSE Training Cards specific to the Project. All Project
employees will be provided with a HSE Training Card and all trainings will be recorded.
Training tags in different colors (tag colors shall be determined by METROPOL İNŞAAT) shall
be prepared by the Low Tier Construction Sub-Contractors and sticked on hardhats after
giving induction training to the employees. No personnel shall enter project construction area
without receiving induction training and without hardhat tags. Some works require special
trainings such as working at height, confined space, scaffolding, hot works, working on live
electrical lines, if any personnel would perform these works then they have to receive these
trainings first otherwise they cannot perform these jobs without receiving trainings.
8.3 Competency
METROPOL İNŞAAT shall ensure to provide an integrated HSE team comprising of
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors HSE personnel for the site
activities fulfilling the minimum qualification, experience and number of personnel.
METROPOL İNŞAAT shall ensure that the line management and supervisory personnel are
competent to identify and assess HSE risks systematically and versed with and are capable to
define the standards, plans, procedures and resources necessary to manage them.
METROPOL İNŞAAT shall ensure to setting up a robust competence assurance process

within own and Low Tier Construction Sub-Contractors organizations that allows for each
individual engaged in the performance of the work to:
• Provide information, instruction, training and supervision so that people are competent to
carry out their work safely in their area of responsibility.
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• Identify and record the positions that require competence assurance and the respective
proficiency levels, basing these on craft and HSE-related competence requirements
described in: local legislation, industry standards for technical and operational competence,
and Project requirements.
• Assess, verify and record the competence of individuals against the requirements defined
for each individual’s position.
• Verify that all required training and certification/licensing has been completed to meet legal
requirements.
• Verify that individuals have the required HSE-related technical and operational
competences before allowing him/her to perform the respective duties.
• Review competence assessments as part of the individual performance review process.
• Manage any competence gaps through an agreed and documented plan, inclusive of level
of supervision and support required.
9 PLANNING, DOCUMENTATION, IMPLEMENTATION & OPERATIONAL APPROACH
9.1 HSE Documentation
HSE documentation for the Project forms the basis for implementation of the HSE
Management System.
9.1.1 Project HSE Plan
The Project HSE Plan, this document, is the prime document in the HSE document hierarchy
for the Project for activities to be performed. It specifies the commitment, the approach and the
methodology for HSE Management System implementation for the Project.
9.1.2 Project HSE Field Manual
Project HSE Field Manual contains lower tier HSE Plans, METROPOL İNŞAAT specifications,
guidelines, Project specific procedures and forms for application on the project. It has the
following sections:
Section 1 Project lower tier HSE Plans and Procedures such as Environmental
Management Plan, Emergency Response Plan, Risk Assessment Procedure,
Low Tier Construction Sub-Contractors HSE Plans, programs and procedures
approved by METROPOL İNŞAAT.
Section 2 Project HSE Forms & Checklists; that are required for the process of
administration of the HSE Management System for the Project.
Section 3 Risk Assessments, Safe Work Instructions, Method Statements and the others
to be developed and effectively implemented for the Project ensuring that
ALARP conditions have been achieved.
9.2 Implementation & Operational Controls

Implementation of the Project HSE Requirements and Operational Controls as per applicable
legislations, standards and the contract include but not limited to as follows;
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• Detailed design HSE philosophy will be developed to establish a consistent engineering

approach and safety studies in line with Project requirements.
• The safe working practices / construction operational controls shall be used for the
execution of this Project will be described in this Project HSE plan, other lower tier HSE
plans developed by the Low Tier Construction Sub-Contractors HSE plans and procedures
in line with Project HSE plan and procedures approved by METROPOL İNŞAAT for the
Project scope of work to give importance for risk associated with particular activities to
identify control measures and implement effectively to reduce the risk to ALARP.
• Implementing Golden Rules of Safety and Life Saver rules throughout the execution of the
Project.
• Environmental operational controls are in line with Project standard requirements described
in HSE PLAN.
9.3 Safe Working Practices / General Safety Rules

Safe working practices, construction operational controls and general safety rules shall be
used for the execution of this Project are described in this HSE Plan, other lower tier plans and
required project specific procedures and instructions.
The rules represent the minimum requirements for METROPOL İNŞAAT and Low Tier
Construction Sub-Contractors staff to ensure that safety is an integral part of each task
performed.
The important following Project specific requirements / general safety rules are bulleted below
and defined in below sections. These will provide guidance for preparing Operational Controls
for construction activities and also provide guidance for executing early construction works on
the Project to avoid delays;
• HSE bulletin board or similar will be available at camp site and posted announcements
shall be followed and obeyed including Low Tier Construction Sub-Contractors.
• Employees shall comply with all posted signs and instruction labels. When in doubt, the
employee is to request instructions from his supervisor or HSE professionals.
• No guest without accompanying supervisor or manager shall be accepted in the site.
• Fighting, wrestling or other horse-play on the job site is strictly forbidden.
• Possession of weapons of any type or introduction of explosives to the site is prohibited.
• Sleeping in worksite facilities is forbidden.
• Lighting fires for warming purposes is forbidden
• Employees using prescribed medicines shall inform the supervisors prior to work.
• Equipment, tools, machines, vehicles, materials or scrap shall not be removed from the job
site without approval of the supervisor.
• Tools, vehicles or equipment which are quarantined or signed with “out of order” sign shall
not be used.
• No tool, vehicle or equipment shall be modified without approval of the supervisor.
• Use of mobile phones while driving is forbidden.
• Driving with head lights on during every vehicle movement is a project rule and shall be
obeyed including all kinds of roads.
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• Employees are not allowed to ride on any equipment or vehicle unless a seat is expressly
provided and fixed with a seat belt.
• All equipment and vehicles shall be parked at a safe distance away from terraces and
trenches.
• Employees are not allowed to sit or lie down behind or in front of parked equipment or
vehicles.
• Unless specified otherwise, every cable shall be considered “live” at the work site and camp
site and necessary precautions shall be taken.
• Use of hand-held mobile phones or radios in close proximity to electric detonators or
detonating cords, fuel or flammable storage areas is forbidden.
• Use of portable heaters should be avoided wherever possible. Portable heaters should not
be used in areas where flammable gases, vapors or combustible dusts may be present.
• Working under power lines shall be avoided as much as possible. If unavoidable a
supervisor and a banksman shall be dedicated for monitoring the activity.
• Cable management shall be achieved all around the work places. Cable mess shall be
avoided as practical as possible.
• Assigned repairmen or mechanics shall make repairs on equipment or tools. Other
employees are prohibited from making repairs.
• Use of hand-made tools is forbidden.
• Safety guards of the equipment or machinery shall not be removed. Moving or rotating
parts of the equipment shall not be touched. Attention shall be paid to the equipment which
has warning signs of auto-starts.
• Guards of angle grinders shall not be removed for any reason and only disks with suitable
rpm shall be used.
• No safety equipment or guards provided on tools and equipment shall be removed or
blocked during operations, except during repairs. Such safety equipment or guards shall be
replaced after repairs and before reusing tools or equipment.
• Maintain alertness for unusual sounds which may be an early indication of a defect. If
unsure stop the machine, report it to supervisor immediately and stay at the controls until
an authorized mechanic arrives.
• Transport vehicles shall not be overloaded.
• While working in hot weather, give regular breaks and allow your body cool down by
drinking cold drinks. If you do not feel well, request for medical help. Do not take
unnecessary risk.
• Working alone where no other personnel exist in close proximity shall be avoided.
• If you are under influence of psychological problems that prevents you from working safe,
inform your supervisor.
• The speed limits identified for the Project sites must be obeyed at all times.
• Individuals must be seated while in moving vehicles and seatbelts must be worn.
• Individuals shall ride with their bodies completely within the body walls of the vehicle.
• Individuals shall not wear finger rings, jewelry, loose clothing or flapping clothing or have
rags or other objects extending from pockets or belt when in the immediate proximity of
moving machinery, motors, engines, etc. Personnel on site shall not wear shorts.
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• Employees must report all accidents in which they are involved immediately to their
supervisor.
• All tools and equipment must be inspected by the user prior to use for damage or defects
and to insure their safe and proper operation.
• Working and walking surfaces are free of tripping hazards including shear connectors,
reinforcing bars, anchors, or threaded studs which may project vertically from beams or
other work surfaces.
• Safe work procedures followed during all erection work to ensure no component is left
inadequately supported at any time. No crane slings lowered until the component is fixed in
place by other means.
• All steel erection work completed by competent personnel using all required PPE, including
fall arrest equipment.
• All uncompleted structures are left in a safe and stable condition, capable of surviving
foreseeable weather conditions at the end of each work period.
• All temporary decking structures required to provide access, are securely fixed in place and
compliant with the Project requirements.
• Safe access systems and fall protection systems are installed and if required inspected /
tested before they are needed.
• Where required dual language warning signs will be posted.
9.3.1 Personal Protective Equipment

METROPOL İNŞAAT shall provide his personnel and ensure that the personnel of Low Tier
Construction Sub-Contractors are provided with, in sufficient quantity (including a site stock),
all personal protective equipment (PPE) necessary for the safe performance of their assigned
tasks, including the minimum requirements which are described in METROPOL İNŞAAT PPE
Procedure and other clothing necessary for protection from adverse weather conditions, all
conforming to local regulations and recognized international standards and manufacturing
codes. Special PPE shall be made available and shall be used when regulations, MS and RAs
and/ or the PTW indicate such requirement.
PPE and coveralls shall be provided to the employees, as well as replaced when necessary,
absolutely free of charge
PPE should be approved type and in compliance with the requirements specified in
METROPOL İNŞAAT PPE Procedure.
METROPOL İNŞAAT shall guide and ensure Low Tier Construction Sub-Contractors use the
involved substances MSDS, individual Method Statements and Risk Assessment to identify
the need of any additional or specific PPE required to perform the individual tasks and shall
ensure that such of an approved type and quality are provided prior to the task execution.
METROPOL İNŞAAT will ensure that all workers and persons visiting worksites are equipped
with appropriate PPE. As a minimum, all workers and visitors shall wear steel-toed shoes or
boots, hardhats, safety glasses with appropriate side shields and adequate coveralls in the
general areas of construction or on the work decks, and hearing protection in designated
areas.
All personnel shall receive training in the safe and proper use of PPE required for their work.
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Joint surveys and spot inspections shall be carried out by METROPOL İNŞAAT and Low Tier
Construction Sub-Contractors HSE departments and other representatives to ascertain that
PPE is available on site, is effectively worn and to enforce usage.
HSE Personnel shall use red helmets at PROJECT Site.
9.3.2 Fire Prevention and Protection

There are three components which are required for a fire to start. This is expressed as the Fire
Triangle, which requires ignition, fuel and oxygen. Fire prevention and fire-fighting methods
are based on removing one of the three elements.
Ignition sources:
• Electricity – overloaded circuit, faulty equipment
• Naked flames – candles, matches etc.
• Heaters – electric, gas/oil fired
• Hot processes – welding, grinding
• Hot surfaces – radiators, cookers etc.
• Lighting – halogen lights, hot lights, etc.
• Smokers’ materials- cigarettes, matches, lighters
• Arsons or vandalism
Fuel Sources:
• Combustible building components
• Flammable gases, liquids and volatile substances such as paints, varnishes, thinner
• Components of the structure itself such as some composite panels and timber
• Waste materials, rubbish
• Protective coverings, scaffold sheeting
• Fuel for portable equipment, LPG, acetylene etc.
Oxygen Sources
• The main sources of air are natural airflow, doors and windows. Air conditioning and
oxidizing chemicals are the other possible sources.
The fire prevention program will be based upon objectives given below:
• Prevention of fires
• Early detection
• Control of fire spread
• Extinguish fire promptly
Prevention of Fires
METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors are implementing
following practices;
• Regular clean-up of debris.
• Regular thorough inspections of the work areas and buildings to detect and eliminate fire
hazards or the potential sources of fire.
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• Safe storage, handling and use of combustible materials.
Detect Fire Early
Detecting fires early would reduce the damage significantly that the fire could give to the
surrounding. Therefore, all personnel must be constantly alert in detecting fires and any fire
shall be treated seriously.
Control of Fire Spread
• METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall provide enough fire
extinguishers of the correct type and size.
• The fire extinguishers will be strategically located.
• Fire extinguishers will be made highly visible.
• Fire extinguishers will be clearly marked on the site drawings.
• Fire equipment will have instructions on use which will be visible to users.
• All fire equipment will be regularly inspected.
Extinguishing the Fire
The extinguishing of fire often involves critical matters of judgement, which are best exercised
by trained firefighting personnel.
However, it may be necessary to control the fire until trained firefighting personnel can decide
on the correct method to extinguish.
The level of training to be provided to site firefighting personnel will be dependent on the site
principal of either a passive or active response to fire fighting.
The person discovering a fire will alert all personnel in the immediate vicinity and will
immediately thereafter follow the published instructions relative to reporting fires.
The evacuation procedure, emergency phone number for reporting fires will be prominently
displayed and advised to site personnel at induction training.
When fire occurs, the nearest supervisor will be responsible for all immediate fire suppression
or control work until relieved by appointed, authorized personnel.
METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors compliance with the
fire prevention requirements and local regulatory obligations in respective areas and in
operations. Low Tier Construction Sub-Contractors shall prepare risk assessments and fire
prevention and protection procedure according to the objectives mentioned above.
9.3.3 Excavations
Excavation works are among the most hazardous construction operations and presents
serious hazards to all workers and other parties involved. Cave-ins pose the greatest risk and
are more likely than some other excavation-related incidents to result in worker fatalities.
METROPOL İNŞAAT shall ensure that workers enter trenches only after adequate protections
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are in place to address cave-in hazards. Other potential hazards associated with excavations
include:
• Falls into excavations or trenches
• Tripping over equipment, debris and spoil
• Excavated material or other objects falling on workers
• Exposure to underground services or overhead electrical cables
• Unstable adjacent structures
• Mishandled or poorly placed materials
• Hazardous atmosphere (noxious gases/lack of oxygen)
• Toxic, irritating or flammable and explosive gases
• Incidents involving vehicles and other mobile equipment
METROPOL İNŞAAT shall prepare Method Statement for Excavation works and ensure that
all Low Tier Construction Sub-Contractors comply with the requirements specified in the
procedure. Low Tier Construction Sub-Contractors shall prepare and submit their Excavation
Procedure for approval.
The key points are to be followed during the excavation works as a minimum are summarized
below:
• For all excavations, required PTW shall be obtained prior to start any excavation work.
• Test trenches shall be dug by hand shovel in areas where un-located or unmarked cables
or lines are suspected or are known to exist.
• Shoring/ Benching/ Slopping shall be provided for excavations exceeding 1.8 m in depth.
• Proper Access and egress shall be provided to enter into the excavations.
• Where personnel are working in a trench 1.5 meters deep or more, there will be one or
more ladders and/or safe ramp access every 15 meters to provide routine and emergency
exit from the bottom to the top edge of the trench.
• Daily excavation and shoring inspections shall be conducted by a competent person and
observations noted and documented.
• Temporary crossing for personnel shall be provided over any trench in excess of 0.5 meters
in depth.
• Passage over pits, trenches and ditches shall be provided using flying bridges with a width
of not less than 1 m which shall be enclosed on both sides with railings with a height of not
less than 1.1 m, such railing being sheeted from the bottom up to the height of 0.15 m and
provided with a guard rail at a height of 0.5 m from the decking.
• Excavated area whose depth is less than 1,5 m will be closed with soft barricades, e.g.,
warning tapes and ropes with ribbon attached. Deep excavated area which depth is greater
than 1.5 m will be closed with hard barriers, e.g., guard rail made by scaffold tube or steel
or any equivalent materials. Soft Barriers should be located 1,5 meters or more from the
edge of excavation.
• Deep excavations shall be adequately battered, shored, fenced and inspected prior to first
entry on a daily basis or following severe weather.
• Construction Low Tier Construction Sub-Contractors shall appoint a competent Authorized
Person for excavation for each job.
• All moving machinery involved in excavation or site preparation, i.e., bobcats, grinders,
excavators, etc. shall be fitted with reverse motion audible alarms. For such machinery
movement during the work a flag person shall be provided to control against personnel
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injury (no personnel allowed within 2.5 meters from the moving parts of the machinery) or
asset damage. The flag persons shall be trained and periodically reminded of the dangers
of moving machinery.
• Signs, barricades and flag persons shall be provided to protect all workers and other
persons from fall and injury. Barricades/covers requirements of guard rails and flashing
lights, illumination (during hours of darkness) to secure excavations, floor openings and/or
road blockages shall be put in place by the respective Low Tier Construction Sub-
Contractors.
METROPOL İNŞAAT/Low Tier Construction Sub-Contractors shall develop a Method

Statement / Job Hazard Analysis for excavation activities.
METROPOL İNŞAAT shall carryout periodic audits on Low Tier Construction Sub-Contractors
excavation works to ensure all the requirements are implemented and complied.
9.3.4 Permit to Work (PTW)
A Permit to Work system is a safe system of work procedure shall be designed to protect
personnel & plant and is a formal written system used to control certain types of work which
are identified as extremely hazardous. It consists of an organized and predefined safety
procedure. It forms a clear record of all foreseeable hazards which have been considered in
advance.
Project Construction Areas:

METROPOL İNŞAAT shall comply with, follow and implement CONTRACTOR’s Permit to
Work Procedure (10330-00-091-PD-0016 PTW PROCEDURE) along with all relevant registers
and PTW forms. PTW system shall cover all work activities/locations for all project
construction activities.
Low Tier Construction Sub-Contractors shall comply with METROPOL İNŞAAT PTW system
for Project construction activities as applicable and agreed. METROPOL İNŞAAT shall ensure
that all authorized PTW signatories are trained and assessed competent according to their
specific authorities and roles. Trainings for the PTW administration will be provided by
METROPOL İNŞAAT HSE Department. METROPOL İNŞAAT shall keep an up-to-date list
with all authorized signatories.
METROPOL İNŞAAT shall create a list of activities requiring a work permit or authorization
associated with the work e.g.:
• Hot works
• General Works
• Entry into confined spaces
• Critical Lifting operations
• Electrical works / Energy Isolation- LOTO
• Plus, any other high-risk activities, as identified by risk assessments.
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9.3.5 Hot Work

Hot work is any work that involves burning, welding, using fire- or spark-producing tools, or
that produces a source of ignition. When hot work is to be carried out in the project areas/
facilities, PTW shall apply and Low Tier Construction Sub-Contractors shall ensure full
compliance with the permit requirements.
Workers performing hot work such as welding, cutting, brazing, soldering, and grinding are
exposed to the risk of fires from ignition of flammable or combustible materials in the space,
and from leaks of flammable gas into the space, from hot work equipment.
Potential Hazards:
• Getting burned by fires or explosions during hot work.
• Injury and illness caused by hot work (such as, welding fumes, UV light, sparks, noise, or
skin injury).
• Accumulation of toxic gases within a confined space.
• A hazardous atmosphere exists in oxygen-deficient (atmospheric concentration of less than
19.5 percent) or oxygen-enriched (atmospheric concentration of more than 23.5 percent).
• Falling or rolling injuries from improper gas cylinder storage.
• Valve opening or break off, exposing workers to toxic fumes and flammable gas, caused by
improper gas cylinder storage.
• Gas cylinders causing fires or explosions.
• Grinding (that results in sparks, noise, eye and skin injury from flying metal filings, grinding
wheel pieces, etc.).
• Having fingers or hands caught in the grinding wheels, resulting in amputation.
• Being struck by portable grinder, etc.
METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors have the competent
personnel to operate, inspect and maintain equipment to be used for hot work in ‘Classified
Areas’ and manage the hot work under PTW, perform a job specific risk assessment and
identification of controls as part of planning the work. Required control measures such as
shielding (fire blankets), fire watchers, fire extinguishers, fire hoses shall be implemented. The
hot work permit required work areas shall be identified by the Low Tier Construction Sub-
Contractors’ HSE Departments and informative warning signs shall be posted.
Hot work in offices, temporary buildings shall be performed under Permit to Work system, and
include a job specific risk assessment and identification of controls as part of planning the
work. Low Tier Construction Sub-Contractors shall comply with METROPOL İNŞAAT’s PTW
Procedure.
METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors provide gas testing
equipment and have competent personnel trained as Gas Testers (GT) familiar with the
Authorized Gas Tester role and responsibilities, the gas monitoring equipment and calibration
requirements. GT shall intervene if flammable gas concentrations exceed the established set
points; Stop the work and investigate reasons for deviation; Define and communicate
corrective action before resuming the work. If required, METROPOL İNŞAAT shall provide
additional trainings for Low Tier Construction Sub-Contractors GT.
Low Tier Construction Sub-Contractors shall ensure mechanics, supervisory personnel, pipe
fitters, welders and helpers receive training on site, regarding the craft specific safety at work
and ensure only qualified and authorized personnel use welding and cutting materials
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(equipment) that they have passed the mandatory on site hot work training and have been
provided with the additional required PPE, i.e., welding mask, apron, welder gloves, face
shield.
Welding & Cutting:
All Low Tier Construction Sub-Contractors shall comply with the following key requirements as
a minimum:
General:
Welding machines shall be properly grounded and tested for resistance. When a mains supply
is used, there must be a readily accessible switch near to the transformer or rectifier to cut off
the mains supply. Welders shall not lean against a grounding conductor whilst manipulating a
live electrode.
When materials (equipment) or large pipes are filled with inert ‘backing gas’ to facilitate inert
gas welding, measures shall be taken to prevent the welders or other workers from entering
the materials (equipment) and ensure adequate ventilation.
Welding performed on structural members, high-pressure lines and lifting appliances must be
performed by project endorsed welders.
METROPOL İNŞAAT PTW as applicable a Hot Work Permit form will be completed before any
hot work involving welding or cutting activities begin. A copy of the permit must be retained at
the job site.
Where applicable, a fire watch will be identified and assigned to any welding and/or cutting
operation performed outside the safe welding area.
Cylinder valves must be turned off when not in use.
Two fire extinguishers will be provided with each welding machine, one to be kept at the work
and the other at the machine. Appropriate PPE shall be worn by welders and helpers all the
time during the welding and cutting activities.
Arc Welding:
• Welding sets shall be in good condition, properly maintained, and locally grounded, with
drip trays.
• Isolation switches on welding sets shall be readily accessible.
• Terminals and live components shall be adequately protected.
• Cables shall be frequently inspected to ensure the insulation is intact.
• Damaged cables or electrical holders shall be properly repaired or replaced.
• Proper cable connectors shall be used when connecting runs of cables.
• Provide GFCI’s (Ground Fault Circuit Interrupter) for hand held power tools that are plugged
into the welding machine auxiliary outlet.
• Electrode connector insulation shall be free of cracks or damage, and all connections made
tight.
• The welder and helpers shall wear welding hoods. The lens shade shall be 10 to 14,
depending on exposure.
• Safety goggles fitted with opaque sidepieces (side-shields) shall also be worn under the
hood to protect from flying debris.
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• Gloves, safety boots, aprons, and leggings especially approved for welders should be worn
for added body protection.
• Remove combustible and flammable material from the work area, or cover with fireproof
material.
• Do not stand in water while welding; water is an excellent conductor of electricity and a
shock could occur.
• Erect welding curtains around work as a flash barrier and spark barrier. Arc welding flash
can injure unprotected eyes.
• Fire blankets shall be used to cover hot work areas wherever deemed by PTW.
Gas Cylinders:
• All gas cylinders (oxygen, acetylene, nitrogen, compressed air, etc.) used on work locations
or construction camps shall be in compliance with the local regulations, within the valid test
period and in proper condition (valves, no corrosion, etc.) fitted with protective valve caps
and correctly identified i.e.:
- Color code,
- Type of gas, tag/serial number, weight of the cylinder, and last test date etc. stamped
on the cylinder,
- Pressure test certificate of the cylinder.
• METROPOL İNŞAAT shall ensure that all associated equipment including regulators and
hoses are fit for purpose and in safe working condition.
• Cylinder storage facilities shall be constructed such that cylinders containing different gases
are segregated, which must be clearly indicated (using color coding), never mixing empty
and full gas cylinders.
• The cylinder storage should provide weather protection and have openings ensuring
adequate natural ventilation.
• Gas cylinders shall be stored in an upright position with the valve protective cover screwed
on and properly secured with chains or gates.
• Fire-fighting facilities shall be provided.
• Oxygen cylinders shall be stored separated from fuel gas or acetylene cylinders by at least
6 meters or by a wall of 2 meters height, having a fire resistance rating of at least half an
hour.
• Lighting, if provided, must be of a flameproof type.
• Where metal frames or cages used for transportation the content identification and date of
load testing should be displayed on frame.
• The frames shall be kept away from exposure to sun, heat and excessive vibration and in a
space with sufficient natural ventilation.
• When cylinders are stored in an enclosed space, the space must be declared a confined
space and clearly demarcated as such or sufficient continuous ventilation must be provided.
Gas Welding & Cutting:

• Compressed gas cylinders shall not be taken into confined spaces or buildings. Where
absolutely necessary those spaces will be clearly demarcated, as confined spaces and a
strict access control shall be established.
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• Torches and supply hoses shall be disconnected and depressurized outside the confined
space before being left unattended.
• Cylinders shall be in trolleys, or tied off when on Site.
• Hoses shall be properly color coded to the internationally recognized standard for the gas
being used, in good condition and fitted with hose connectors attached by permanent clips.
• Cylinders shall never be stored or used in a horizontal position but shall be secured in an
upright position. Empty cylinders shall also be separated from full cylinders. Bottles will be
stored in a secure upright position with valve stems protected and separated from
flammable and combustible substances.
• In-line check valves and flash back arrestors are to be installed in the oxygen and acetylene
hoses between the bottle regulator and the cutting or heating device.
• All welding cables will be completely insulated and ground connections will be secure to
prevent sparking.
• Where applicable, a fire watch will be identified and assigned to any welding and/or cutting
operation performed outside the safe welding area.
• Cylinder valves must be turned off when not in use.
METROPOL İNŞAAT shall inspect / audit Low Tier Construction Sub-Contractors’ welding and
cutting activities to ensure the compliance.
9.3.6 Confined Space Entry
A Confined Space is a fully or partially enclosed space:

• that is not designed and constructed for continuous human occupancy;
• has limited or restricted means for entry or exit;
• where there is a risk of injury or health effect from hazardous substances or conditions.
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall identify and list the
confined spaces and confined space work and associated hazards and work activities
requiring isolation, testing and control.
METROPOL İNŞAAT shall ensure effective implementation of a procedure at all work

locations to manage the risk of Confined Space Work (CSW). Low Tier Construction Sub-
Contractors shall prepare and submit the Confined Space Entry procedure for approval.
The CSW procedure shall describe local regulatory requirements, roles, responsibilities,
competence and monitoring requirements and rescue arrangements. Supervisors shall be hold
accountable for making sure that personnel are informed of the existence and Hazards of
Confined Spaces.
Low Tier Construction Sub-Contractors shall develop job specific RAs for critical works in
confined spaces and obtain approval from METROPOL İNŞAAT HSE department and shall
implemented along with the respective Permit to Work process.
CONTRACTOR Confined Space Procedure (10330-00-091-PD-0018) shall be implemented
during the project.
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9.3.7 Safe Isolation (Energy Isolation)

METROPOL İNŞAAT shall implement energy isolation and Lock-Out/Tag-Out (LOTO) and
shall be applied in conjunction with the Permit to Work procedure.
Low Tier Construction Sub-Contractors shall comply with Lock-Out/Tag-Out procedure and
PTW requirements.
Low Tier Construction Sub-Contractors shall implement isolation and LOTO procedures,
including locks, tags and warning signs in conjunction with METROPOL İNŞAAT’s PTW
procedure for work on live systems and equipment at construction camps, project works and
temporary facilities involving invasive work, i.e., installation and/or maintenance of pressure
containing, electrical and instrument systems and materials (equipment).
Only authorized competent personnel are allowed to execute any isolation. Low Tier
Construction Sub-Contractors shall maintain an up-to-date list of competent authorized
personnel that can authorize and/or execute isolations.
Low Tier Construction Sub-Contractors shall set up a system in place whereby the keys used
for isolation are strictly controlled; locks or tags are not removed other than by the personnel
that have placed them or by authorized persons as defined in the lock out tag out procedure;
devices that are locked or tagged are not operated or energized; tags are removed and
returned as specified by the lock out tag out procedure.
METROPOL İNŞAAT shall audit Lock-Out/Tag-Out system along with PTW periodically to
ensure effective implementation.
9.3.8 Lifting Operations
A lifting operation is an operation concerned with the lifting and lowering of a load. A load is
the item or items being lifted which could include a person or people. Lifting operations in
construction occur during transportation of material from the storage place to the place where
it is being processed and during the processing of materials. A load includes any material or
people that are lifted or lowered by lifting equipment.
Hazards of using lifting equipment:
The hazards: associated with the use of lifting equipment in construction are:
• Hazards related to the loads, e.g., crushing due to impact of moving objects or loads falling
from vehicles because they are not slinged properly or the wrong type of slings were used.
• Hazards from moving vehicles or collapsing structures, i.e., cranes falling over because of
improper fixation or strong wind, unsafe loads, loads exceeding the safe weight limits,
trapping/crushing risk in the use of Mobile Elevated Work Platforms (MEWPs) while working
at height, falling from height, limbs or bodies caught in machinery.
• Falling from lifting platforms or being crushed when the platform moves.
• Hazards related to poor environment that may interfere with communication between
workers or concentration needed for the task (noise) or cause sweaty, slippery objects
(heat, poor ventilation).
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• Contact with overhead electrical cables.

Possible causes of these hazards may be: poor mechanical design (breaks in use, not
powerful enough, components fracture or malfunction), poor workplace design, malfunction of
the (manual, mechanical, electronic) signaling system, not using the proper equipment for the
purpose or misuse (not using as designed, e.g. the load was too heavy), loads insecurely
attached, poor maintenance (breaks or emits noxious gases) or untidy workplace, human error
when operating machines or erecting scaffolding.
Lifting Operations are detailed in Lifting Procedure.
Low Tier Construction Sub-Contractors shall develop a lifting and hoisting procedure and
resourced inspection program for their scope of work in line with METROPOL İNŞAAT Lifting
Procedure and submit for approval to ensure that all equipment to be used for Lifting and
Hoisting is fit for service - inspected, maintained and certified in line with the manufacturer’s
recommendations and local regulations.
Low Tier Construction Sub-Contractors shall appoint a competent Lifting and Rigging
Superintendent to perform all lifting operations safely. Classification of lifts and other
guidelines provided below:
Classification of lifts:
Depending on the weight, height and the diameter of the load to be lifted, lifts shall be
classified as follows. Should any criteria be met, then the subsequent requirements shall be
fulfilled.
High risk work environment crane lifts include, but are not limited to, the following examples
and restrictions/requirements:
• Any part of a crane whose boom or boom attachment is working within 10 meters of any
hydrocarbon and/or pressurized piping areas. This includes cranes having to suspend a
load over vessels, piping, and/or equipment containing hydrocarbons, steam, or other
pressurized liquids.
• Any part of a crane whose boom or boom attachment is working within 10 meters of any
populated/traffic areas. This includes cranes having to suspend a load over pedestrians,
vehicle traffic, occupied construction equipment, and/or occupied buildings.
• Any crane lift that requires an attachment(s) to the main boom (except those used as a
“super lift” device).
• When using adjustable devices attached below the hook.
• When using adjustable devices to transfer a load from the crane hooks.
Heavy Lifts:
Loads above hundred (100) tons;
Loads between seventy (70) and hundred (100) tons that, due to their volume and shape, or
due to the area of installation, require special studies.
Loads exceeding 85% of the rated capacity of the crane or derrick.
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Operations involving two (2) or more cranes.

Man basket lifting.
Any crane lifts with explosion/fire/high heat hazards.
Any crane working near energized power-lines. When working less than 1-1/2 fully extended
boom lengths from energized power-lines, a designated signalman shall ensure the following
minimum distances are maintained:
Any crane working near energized power-lines. When working less than 1-1/2 fully
extended boom lengths from energized power-lines, a designated signalman shall
ensure the following minimum distances are maintained:
Line Voltage Absolute Limit of Approach
Up to 50,000 volts 3.0 meters/10feet
50,000 to 250,000 volts 6.1 meters/20 feet
Over 250,000 volts 7.6 meter/25 feet
Local PTW procedures shall be followed when work is performed within the above limits.
Special critical crane lifts, hazardous by their nature and requiring special training, rigging,
and/or boom attachments, include, but are not limited to, the following examples and
restrictions/requirements:
• Heavy Lifts.
• Tailing, tandem (multiple), or turning lifts:
o De-rate all cranes involved in tandem lift by 25% of the load chart. (Possible
exception prior approval for “super lift” configurations.) Utilize cranes of same size,
manufacturer, and model, if possible, (except tailing lift) for tandem (multiple) and
turning lifts.
o Have a separate approved “Critical Lift Plan” on Site prior to the lift each time one of
these types of lifts is performed.
o Have assigned a rigging competent person in charge of actual lift coordination.
• Crane suspended personnel platforms (man baskets):
o Only allow work from or transport by a crane suspended personnel platform
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(man basket) when conventional means of performing the work or reaching the
workplace (such as personnel hoist, ladder, stairway, aerial lift, elevating work
platform, or scaffold) would be more hazardous or are not practical because of
structural design or worksite conditions.
o Have an approved “Critical Lift Plan” on Site prior to the lift.
o Have a Crane Suspended Personnel Platform (man basket) Permit properly
completed, signed, and on Site prior to the lift.
o De-rate the crane by 50% of the load chart.
o Do not perform crane suspended personnel platform (man basket) lifts in wind
speeds exceeding 25 km/h (15 mph – 13 knots – 7 meters/second).
o Have prior written approval from CONTRACTOR Construction Management for
crane suspended personnel platform (man basket) operations that are performed
at night.
o At each Site, prior to hoisting employees on the personnel platform, and after any
repair or modification, the platform and rigging shall be proof tested to 125 percent
of the platform’s rated capacity by holding it in a suspended position for five
minutes with the test load evenly distributed on the platform (this may be done
concurrently with the trial lift). After proof-testing, a competent person shall inspect
the platform and rigging. Deficiencies found must be corrected and another proof
test conducted. Do not lift personnel until the proof testing requirements are
satisfied.
o All man baskets shall be attached to the main hook block with free-fall device.
o Back-up wire rope or sling shall be installed in case of the main rigging device
fails.
o Man basket in auxiliary hook or on the ply-jib is prohibited.
o Man basket shall have a head protection; any variation shall be approved by the
CONTRACTOR Site HSE Manager.
o Bar around inside the man basket cage shall be installed for hook-up purposes.
o A load test shall be conducted every shift for all man basket operations before the
approval of the PTW.
• Night-time crane lifts:
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o Have an approved “Critical Lift Plan” on Site prior to each crane lift performed at
night.
o Have specific prior written approval for crane lifts performed at night.
o Have proper lighting, sufficient to perform the lift safely.
o On rubber tires or pick and carry lifts
o Have the on rubber and pick and carry lift duties stated on the manufacturer’s
crane
load chart for this duty to be an acceptable option.
o Have the crane operator confirm that the proper recommended tires are fitted
(sand tires are not acceptable).
o Have the crane operator confirm the proper recommended tire pressure and that
the tires have no obvious defects.
o Have the travel surface level, free of potholes, and with acceptable ground
conditions. Travel speed shall not exceed 4 km/h (2.5 mph).
o Have the load secured to prevent any swing into the crane structure. Snubbing or
tag lines shall be used. Have travel procedures, as specified by the manufacturer,
followed (e.g., the turntable swing-lock pin should be engaged during travel).
Note: Traveling with a load is an inherently hazardous procedure that requires
extra precautions to ensure operations are conducted safely.
For all these critical lifts, a “Critical Lift Plan” shall be prepared and submitted by METROPOL
İNŞAAT, reasonably in advance before lifting operation commence, to CONTRACTOR that will
add any comment or return it within forty-eight (48) hours before lifting start.
This plan may admit future extension as required by specific conditions and shall be included:
• Cranes, lifting mechanisms and rigging equipment.

• Plan view and side views showing operation lifting details.
• Accurate load drawings (sizes, weight, position, center of gravity, slinging method).
• Supplier Recommendations and Instructions.
• Prior checking of all items, including lifting lugs and shackles.
• Definition of all operations from load reception to final positioning including all prior
provisions required.
Lifts that exceed 95% of the load chart for any given configuration of the crane are not
permitted.
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Each day of a Critical Lift, the METROPOL İNŞAAT in charge of the lifting shall hold a pre-lift
safety meeting. CONTRACTOR Site Manager and/or Construction Manager, and the Site HSE
Manager shall attend this meeting together with any involved employee in the lifting activity.
Low Tier Construction Sub-Contractors shall implement a process in place to identify and
subsequently plan and manage critical lifts. METROPOL İNŞAAT shall assess the identified
critical lifts, and complex lifts early in the planning of construction activities, to decide whether
an independent lifting specialist should be involved.
A rigging inspection shall be carried out by the Low Tier Construction Sub-Contractors for the
complex and critical lifts and submit for approval.
If the heavy lifts / critical lifts to be carried out, METROPOL İNŞAAT shall obtain PTW and
implement the requirements, CONTRACTOR PTW Procedure (10330-00-091-PD-0016) shall
be implemented.
METROPOL İNŞAAT shall ensure all Metropol İnşaat employees and Low Tier Construction
Sub-Contractors establish competence assurance for Project personnel who supervise or
perform lifting and hoisting operations and who inspect and maintain lifting equipment. Crane
operation, banking, rigging and signaling shall be performed by competent persons, who have
been assessed and authorized by METROPOL İNŞAAT and have been certified as required
by local regulations. Crane banks men; riggers and signalers shall wear distinctively colored
safety hardhats or clothing.
Lifting gear consists of wire or webbing slings, chains, lifting lugs, shackles, pad eyes etc.
Lifting gear shall comply with applicable international standards and industry accepted codes
of practice and shall be marked. All lifting gear shall have a test certificate or letter of
conformity supplied by the manufacturer.
All lifting equipment including cranes (crawler, tire mounted etc.), and boom trucks shall be
inspected by authorized inspection agency with valid test Certificates as per the local
regulations.
Lifting gear will be inspected and maintained on a quarterly basis by competent personnel with
an appropriate color-coding system and registers. Lifting gear will also be inspected prior to
use by work supervisor / foreman and / or rigging supervisor.
Personnel Lifting:
Work permit including lifting studies, job safety analysis and risk assessment regarding
personnel lifting shall be prepared by Low Tier Construction Sub-Contractors and submitted to
METROPOL İNŞAAT for approval. All personnel lifting shall be carried with the equipment
which is designed for lifting people, shall be appropriately and clearly marked. Only such
designed and marked equipment shall be used for this purpose.
9.3.10 Safe Working at Height
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Work at height is the biggest single cause of fatal and serious injury in the construction
industry. Over 60% of deaths during work at height involve falls:
• from ladders, scaffolds, working platforms and roof edges and,
• through fragile roofs or roof lights.
METROPOL İNŞAAT aims to make sure work at height is properly planned, supervised and
carried out in a safe manner. METROPOL İNŞAAT shall ensure all Low Tier Construction Sub-
Contractors will comply with their ‘duty of care’ responsibilities by identifying working at heights
hazards and ensuring the risk of injury is either eliminated or reduced to an acceptable level.
Dos and don’ts of working at height:
Do…
• as much work as possible from the ground
• ensure workers can get safely to and from where they work at height
• ensure equipment is suitable, stable and strong enough for the job, maintained and
checked regularly
• take precautions when working on or near fragile surfaces
• provide protection from falling objects
• consider emergency evacuation and rescue procedures
Don’t…
• overload ladders – consider the equipment or materials workers are carrying before working
at height. Check the pictogram or label on the ladder for information
• overreach on ladders or stepladders
• rest a ladder against weak upper surfaces, e.g., glazing or plastic gutters
• use ladders or stepladders for strenuous or heavy tasks, only use them for light work of
short duration (a maximum of 15 minutes at a time)
• let anyone who is not competent (who doesn’t have the skills, knowledge and experience to
do the job) work at height
Scaffolding:
METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors set up a process for
managing the safe erection, inspection, use and dismantling of scaffolds as per requirement of
applicable Regulations / European Standard (EN 12810, EN 12811) or equivalent.
Low Tier Construction Sub-Contractors shall ensure that all personnel, who build, operate,
inspect and maintain scaffolds, mobile work platforms and equipment for lifting people (e.g.,
winches, basket transfer equipment, fall protection equipment) are competent to do so and
that the materials and methods used for the erection and installation of scaffolds and ladders
comply with the applicable Regulations and EN 1004, EN 12810, EN 12811 Standards or
equivalent.
Low Tier Construction Sub-Contractors shall ensure that all scaffolds are erected modified or
dismantled only by persons who are fully trained and qualified for the type of structures they
are working with.
No scaffold will be used unless thoroughly inspected by a competent person before it is first
taken into use, after erection or substantial alteration and every 7 days thereafter.
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Scaffolds shall be inspected by a competent person on a daily basis when in use and tagged
accordingly.
The inspection arrangements shall incorporate the use of the Scaffold Tag system.
Low Tier Construction Sub-Contractors shall appoint a scaffolding supervisor to manage
scaffolding activities on site. The scaffolding supervisor shall:
• Ensure that scaffold materials are to the correct standard.
• Check that Low Tier Construction Sub-Contractors scaffolding personnel are competent
and conduct additional training where necessary.
• Set up a system for inspection of scaffolds including use of a scaffold tag system. A simple
safe-unsafe, green-red system is recommended.
• Set up a system for controlling modifications to scaffolds.
• Plan, coordinate and monitor all the scaffold erection, dismantling and inspection activities.
Ensure adequate supervision.
• Conduct inspections and audits on construction Low Tier Construction Sub-Contractors
scaffolding activities.
All work areas, walkways and platforms which are more than 1 meter above ground level or
the platform below shall be provided with solid guard rails, both upper and intermediate.
Whenever possible, the ladders should be built within the structure of multilevel scaffolds to
minimize the potential fall distance and when it is not possible to do so and the potential fall
distance is greater than 6 meters a ladder-climbing device such as an inertia reel fall arrestor
shall be used.
During scaffold erection, modification and dismantling hard barricading shall be put in place to
prevent unauthorized personnel from entering the area where objects can fall from height, a
safety watch shall be ensured and signs shall be posted (men at work, etc.).
Ladders:
METROPOL İNŞAAT shall ensure that all Low Tier Construction Sub-Contractors will provide
and use only ladders meeting METROPOL İNŞAAT standards and International Standards for
access to and egress from work places.
Damaged ladders shall be removed from the job site, and repaired or destroyed.
• Ladders must not be painted.
• Ladders shall not be used on top of the work platform of any scaffold.
• One man only on a ladder at a time.
• Do not use a stepladder to gain access to roofs or other elevated surfaces.
• Fully open the stepladder on four legs and never lean it against walls for support.
• Never stand on the top step.
• Extend ladder 1 meter above the landing area.
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• Set at a 4:1 slope (vertical / horizontal).

• Tie off to a secure structure.
• Overlap ladder sections by 1.2 meters up to 11 meters in length. Overlap ladders by 1.5
meters up to 14.6 meters.
• Put a man at the ladder base to hold it steady,
• Do not carry tools or material. Lower or raise tools or material by a rope and/or bucket.
Keep both hands free for climbing the ladder.
• Do not lash or tie ladder sections together.
Working at Heights:
METROPOL İNŞAAT shall comply and ensure Low Tier Construction Sub-Contractors comply
with the requirements such as precautions against fall from height, means of access for Work
at Height, Personal Protective Equipment for Work at Height specified in fall prevention
program.
All Low Tier Construction Sub-Contractors shall provide fit for purpose training for all their
personnel, involved in working at height. Low Tier Construction Sub-Contractors shall provide
trainings for their personnel.
All work areas, walkways, platforms, etc. where there is a risk of fall, whether permanent or
temporary, are to be encompassed by an approved guard-rail (with top rail+ middle rail + toe
board) securely fastened and are to provide safe, sturdy surfaces maintaining the approved
load.
Low Tier Construction Sub-Contractors shall ensure that personnel visually inspect fall
protection equipment and ladders before each use and that fall protection equipment and
ladders that fail inspection are not used.
METROPOL İNŞAAT shall ensure all Low Tier Construction Sub-Contractors will put in place
a monitoring and communication program to ensure compliance while work has been carried
out at height with the following:
• Tie off 100% of the time when wearing personal fall protection equipment.
• Tie off includes moving to and from the work height, and when working within 2 meters of a
roof edge or work platform without a guardrail.
• Periodically and visually inspect Fall Protection Equipment before each use.
• Tie off personal fall protection equipment to a stable and acceptable tie off point, using a fit-
for-purpose harness and lanyard.
• The design of structures and the planning of work shall allow for the fitting of lifelines to
facilitate tying off.
• Use a ladder climbing safety device, such as an inertia reel fall arrestor, when climbing up
or down ladders 6 meters or longer.
Low Tier Construction Sub-Contractors shall set and implement procedures or instructions that
describe compliance with work at height program and the tie-off rules above and this
information will be communicated to the workforce through toolbox talks etc.
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Removal of grating or handrails from permanent staircases and platforms will be only carried
out after obtaining respective PTW. Floor openings shall be securely covered and sign posted.
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall implement a rescue
plan for all work at heights, to ensure that there is an efficient response to any incident
involving persons falling from heights. The plan shall specify actions to rescue persons who
have fallen, are suspended in their harness and could develop suspension trauma. The
personnel involved in emergency response shall be trained accordingly and the rescue plan
shall be drilled regularly.
Mobile Elevated Work Platforms:
Operators of mobile work platforms e.g., cherry pickers, scissors lifts, manlifts etc. will be
specifically licensed/authorized to operate the platforms, be trained and competent on the type
of lift to be operated.
Persons riding in or working from mobile work platforms must wear an approved safety
harness securely connected to a suitable anchor point on the platform. The mobile work
platforms should be operated on level and firm ground conditions in order to alleviate the
possibility of overturning.
There must be adequate clearance in order to prevent the mobile work platform colliding with
adjacent structures, overhead power lines, other vehicles etc. Barricades will be erected
around the machine, to cover the total work area, while work with MEWP is in progress. A
competent person will subject mobile work platforms to regular inspections and maintenance.
Safe working loads and the permitted number of persons on the platform must be clearly
marked as per the manufacturers requirements and may not be exceeded.
MEWPs will not be used as material lifts. Workers will not be allowed to exit the work platform
to gain access to work faces. Workers will not be allowed to stand on the handrails of the
MEWP.
When moving the MEWP from one work area to another only the operator will be allowed in
the basket and it will be done with the assistance of a flagman.
MEWP’s may not be moved from one work area to another with the boom extended.
While working from a MEWP the area below will be controlled by a banks man to prevent
unauthorized access to the area under the MEWP.
METROPOL İNŞAAT shall audit working at height regularly to ensure effective implementation
of working at heights (scaffolding, ladders, tie-off, etc.) performed by the Low Tier Construction
Sub-Contractors.
9.3.11 Electrical Safety

An electrical hazard can be defined as:
• Dangerous condition where a worker could make electrical contact with energized
equipment or a conductor, and from which the person may sustain an injury from shock;
and/or,
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• Where there is potential for the worker to receive an arc flash burn, thermal burn, or blast
injury.
Many injuries attributed to an electrical accident at a construction site are preventable.
However, injuries occur despite this due to the following:
• Vehicular wiring or battery defects
• Faulty tool wiring
• Overhead power line
• Underground power line problems
• Electrical hazards with standing pools of water
In particular following shall be applied;

• Identify the location of any overhead lines or underground cables that run across or close to
the working area and plan the work to typically include suitable signage, hand digging
where appropriate, safe clearance distances, etc.
• Work crews shall be informed on a daily basis of the location, voltage and height/depth of
the lines to which they will be working in close proximity, the nature of the electrical hazards
that may be present and the controls applicable
• Low Tier Construction Sub-Contractors shall be in liaison with METROPOL İNŞAAT and
the authority concerned to ensure that transmission lines and underground cables are
isolated, but will nevertheless treat all lines as potentially live and work accordingly.
• All related equipment, attachments shall be efficiently earthed at all times, with earthing
stakes driven well into the ground and surrounding soil kept damp during dry conditions.
• Work Permits will be applied wherever dictated by Task Risk Assessment or other hazard
identification techniques.
• METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors develop and
implement through regular inspection and maintenance, that worn and defective cables,
leads or equipment are adequately repaired or replaced as necessary.
• Emergency response procedures shall include the case of inadvertent power line contact
and first aid training will include instruction on treatment for electrical shock and burns.
• All temporary electrical panel boards shall be installed ELCB (Electrical Circuit Breaker).
METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors comply with the
electrical safety requirements for the Project. Low Tier Construction Sub-Contractors shall
prepare and submit the Electrical Safety procedure for approval or implement METROPOL
İNŞAAT Electrical Safety Procedure.
All work or alterations, including temporary work, to any electrical equipment will only be
undertaken by suitably qualified and competent electrical personnel.
Low Tier Construction Sub-Contractors shall appoint a person who is competent in electrical
safety to develop and maintain the electrical safety rules in line with internationally recognized
standards and local regulations for their scope of work.
Temporary electric power shall be used for work in non-hazardous areas only. In all other
cases the electrical equipment shall be either intrinsically safe, ex-proof or its presence and
use shall be strictly controlled by the respective PTW requirements.
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Power & Hand Tools:
Power and hand tools shall be inspected on quarterly basis and tagged with different colors
designated for each month or any tagging method announced by METROPOL İNŞAAT. No
power and hand tools shall be used without color tags.
All Low Tier Construction Sub-Contractors shall comply with the following key requirements as
a minimum:
Hand Tools:
• All hand tools shall be regularly inspected before and after use, and before storage.
• All hand tools shall be inspected and color coded as per approved Project color coding
system or approved tagging system.
• If wear or damage is observed, the tool should be withdrawn from use for repair or for
disposal.
• Hand tools are regularly cleaned and, where necessary, lightly oiled as a protection against
corrosion.
• Chisels with mushroomed heads shall either be reshaped or discarded before being struck
by a hammer.
• Broken handles on hammers, shovels, or other tools shall not be used. Tape repairs are not
allowed.
• Hand tools shall not be misused, i.e., a wrench for a hammer, a screwdriver for a chisel, or
pliers as a wrench.
• Hand tools shall be properly stored and preserved.
• Use of shop-fabricated tool (home-made tools) is strictly prohibited.
Power Tools:
• All portable power tools should not exceed voltage rating as per project standards, are
manufactured of sound materials, and are free from defects and properly grounded.
• Shall be plugged into a Ground Fault Circuit Interrupter (GFCI).
• Proper PPE shall be worn when using electrically operated hand tools.
• Rotating tools should be switched off and held until rotation has completely stopped before
they are set down.
• Shall have a 3-wire ground cord and 3-prong ground plug, or be electrically double
insulated.
• All power tools shall be inspected and color coded as per approved Project color coding
system.
• Systematic maintenance shall be carried out as per schedule for all power tools
• Before using any power tool, it should be inspected for defects and cord damage, e.g., cuts,
splices, or exposed internal wires at plugs etc.
• Defective electric tools shall be repaired or replaced.
• A functioning dead-man switch shall operate all portable electric tools. Trigger locking
buttons shall be disabled.
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• Any powered tool designed with guards shall be equipped with those guards during use.
(Guards protect against contact with belts, gears, shafts, pulleys, sprockets, spindles,
drums, fly wheels, and saw blades and other moving parts).
• Hand operated circular saws shall have a guard that can be adjusted, so that it only
exposes that part of the blade making the cut.
• Provide an emergency shut-off switch clearly identified and accessible on each fixed tool.
• Proper PPE shall be used while using power tools.
Pneumatic Tools:
• Air compressors shall always be used under the supervision of a competent person.
• All compressed air hoses shall be of the correct size to fit the tool being used. Any joint in
the hoses shall be made with a proper coupler and secured by safety wire (whip lash). The
hose length shall be kept as short as possible and placed so as not to be subjected to
damage.
• Do not exceed manufacturer's safe operating pressure for tools, hose, pipe, valves, or
fittings.
• Install and use safety clips or retainers on impact tools to secure attachments from being
expelled.
• High pressure airless spray guns shall have devices to prevent trigger pull until the safety
device is manually released.
• Proper PPE shall be used while using any pneumatic tools.
9.3.12 Housekeeping
All work locations including camps, workshops, and offices are to be maintained with the
highest regard for good housekeeping practices. Although general housekeeping
considerations are intended to include aspects of maintaining a well-organized work place, the
safety aspect of these considerations is given the highest priority. Monitoring of housekeeping
standards will be carried out during area inspections. All Low Tier Construction Sub-
Contractors shall carry out regular housekeeping for their area of work activities.
METROPOL İNŞAAT will maximize good housekeeping by:
• Regular monitoring of the worksites.
• Discussion at HSE Meetings. Site personnel will be reminded that they have the main
responsibility for the maintenance of good housekeeping standards.
• The need for good housekeeping practices will also be discussed at Project meetings, HSE
inductions and toolbox talks.
• Housekeeping inspections will be included in regular inspections / audits.
As a minimum housekeeping standard will involve ongoing daily checks to ensure:

• Overall site cleanliness and tidiness.
• Escape routes are maintained free of obstruction at all times, identified and illuminated
• Tools, materials or debris do not impede access to emergency equipment
• The avoidance of walkway obstructions and tripping hazards.
• All tools onsite are in good condition and suitable for the job.
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• Tools, surplus materials or debris are removed from the worksite as soon as they are
known to be surplus to requirements.
• Removal of flammable materials.
• Appropriate storage of all hydrocarbons and other chemicals.
• Waste to be disposed of in an approved matter as per legislations and Contract
requirements.
9.3.13 Traffic Management
METROPOL İNŞAAT shall ensure all Low Tier Construction Sub-Contractors implement a
Transport Safety Policy and Plan for all dedicated traffic for the Project in and outside the
project area, which covers:
• Vehicle / Equipment standards (HGV, light vehicles, buses, trailers, etc.) and fitness for
purpose and service;
• Driver competency including training, assessment and ongoing awareness;
• Drivers to have in their possession a valid driving/operator’s license, issued by a relevant
public authority, for the class of vehicle being operated.
Low Tier Construction Sub-Contractors’ personnel shall follow all local laws while driving in
order to execute the work.
METROPOL İNŞAAT shall specify the rules for driving in the work locations.
METROPOL İNŞAAT shall ensure that Low Tier Construction Sub-Contractors provide speed
limit postings where appropriate in the work locations and construction camps. All drivers and
operators must comply with speed limits.
No personnel shall be carried on the heavy equipment, cranes, buckets, in operator cabs and
etc.
All drivers and heavy equipment operators must have valid licenses. Low Tier Construction
Sub-Contractors must submit copies of licenses of operators and drivers to METROPOL
İNŞAAT HSE department.
Cranes&heavy equipment shall be inspected quarterly basis and maintained in accordance
with the manufacturer instructions.
All vehicles on the Project shall be loaded and operated within the design limits. Maximum
loads should be made fully visible on all such units. When loaded they shall comply with and
be operated within the local regulations weight limits on axle loadings.
Loads on the trucks shall be covered with appropriate material to prevent dust generation and
fall down. The loads on any vehicle shall be secured against fall down.
Vehicles and equipment shall be used in accordance with the production intensions.
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall ensure that all vehicles
used for Project activities are inspected and maintained in safe working order.
Driver Management:
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall have a road safety
communication program in place, which shall as a minimum consist of regular, at least
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monthly, meetings with drivers at worksite locations, daily toolbox meetings with drivers to
discuss road safety, blind spots and other topical health and safety issues.
The driver must be competent and drive in accordance with the National Road Transport
procedures and at all times seat belts must be worn.
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors personnel shall not use a
mobile phone while driving.
Seatbelt will be worn while in a car, taxi, bus, truck, crane, forklift truck or other vehicle for the
execution of the work.
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall provide random drug
and alcohol checks for all professional drivers and operators.
Transportation of Heavy or Oversized Equipment:
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall ensure that
transportation of materials (equipment), must comply with the following:
• Cabin protection must be provided against loads slippage;
• Carrying capacity must not be exceeded;
• Speed limit according to the type of materials (equipment), regulations and road condition.
• Cargo stability and load distribution must be ensured, by using fit for purpose trailers, as
well as calculations on the number and position of securing points.
• Particular attention must be paid when overall dimensions of cargo exceed those of vehicle
or unbalanced objects transported.
• Cargo must be secured to the body or deck of the vehicle by means of chain or slings with
fastening devices; welded blocks can also be used.
• Equipment brakes must be locked and gear must be engaged.
• Local Road Transport regulations and requirements.
• Transport of flammable liquids and gases requires special vehicle or arrangement and must
be submitted for approval.
• Double escort vehicles shall be implemented when transporting flammable liquids and
gases.
Please refer to Traffic Management Plan of the Project for details on management of traffic
and transport safety.
9.3.14 Hazardous Materials Storage and Handling
A hazardous material can be defined as “a material that because of its quantity, concentration,
acute or chronic toxic effects, carcinogenicity, teratogenicity, mutagenicity, corrosivity,
flammability, explosiveness, radioactivity or physical, chemical or infectious characteristics,
may pose a hazard to human health or the environment when improperly treated, stored,
disposed of or otherwise managed".
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METROPOL İNŞAAT shall ensure compliance with applicable regulations through ongoing
monitoring of implementation of operational procedures. Periodic inspections of hazardous
materials management activities will ensure compliance with local legislation, applicable
standards and OWNER requirements.
METROPOL İNŞAAT shall ensure that Low Tier Construction Sub-Contractors perform
storage and handling of hazardous materials in accordance with currently accepted industry
practices and complies with METROPOL İNŞAAT requirements and local Laws and
Regulations. The minimum requirements to be followed are described below:
General Measures for Impact Avoidance and Mitigation:
General measures for handling of hazardous materials are given below:

• METROPOL İNŞAAT will maintain an inventory of hazardous materials including a
summary of the physical and chemical properties of the materials held or generated, to
ensure that these are understood and that appropriate measures are in place to mitigate
the potential hazards posed by them both to humans and the environment; this will include
provision of MSDSs for all stored materials and details on the segregation of potentially
reactive materials.
• Appropriate Personal Protective Equipment (PPE) will be made available to personnel
involved in fuel and hazardous material handling operations; all relevant personnel will be
trained in the use and maintenance of PPE.
• All personnel will be trained in the use of fire extinguishers.
• Fuel storage and handling areas will be located away from offices and domestic facilities.
• Hazardous material storage areas will be protected from rainfall and direct sunlight.
• Materials will be clearly labelled, segregated, protected from general access and stored on
pallets to prevent the contamination of runoff.
• Suitable fire-fighting equipment will be located close to hazardous material storage areas.
• Surface runoff/storm water drainage from material storage areas will be directed through a
perimeter drainage system to collection sumps and sediment traps.
• Oil-filled electrical appliances will be maintained in good and fire-resistant condition.
• The overall volume of hazardous materials purchased and present on site will be minimized
through careful stock control and materials inventory.
General Storage of Hazardous Chemicals:
Chemicals should always be stored separately away from other materials and access to
chemical storage must be limited to authorized persons only.
Storage must conform to compatibility restrictions. Typically, solvents, acids, bases, reactive,
oxidizers and toxins will be stored separately. The manufacturer's instructions and MSDS must
be followed for the storage of chemicals. Any chemicals with high reactivity should be stored
separately (i.e., chemicals that react with each other).
At the entrance of each Storage area for hazardous chemicals, a table showing incompatibility
for storage of the different chemicals’ substances will be displayed.
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Labelling:
All containers, carboys, jerry cans, bottles containing chemicals must be clearly and
distinctively labelled detailing product identity, associated hazard, statutory warning,
manufacturer’s name, date of opening and date of expiry etc. Labels could be mark, sign,
device, stamp, seal, sticker ticket, tag or wrapper.
Label should contain: Product identifier, supplier identifier, risk phrase, precautionary
measures and first aid measures as per MSDS.
Fuel and Fuel Products:

Hazard classes, potential impacts and safe handling procedures for fuel products are as given
below:
Potential
Material Handling Procedure PPE
Impact
Diesel Water and soil Do not get in eyes, on skin, or on clothing. Chemical goggles
contamination Avoid breathing vapors, mist, fume, or dust. Do Neoprene or nitrile
not swallow. May be aspirated into lungs. gloves
Wear protective equipment and/or garments if
exposure conditions warrant. Wash thoroughly Protective garments
after handling. Launder contaminated clothing Ensure adequate
before reuse. Use with adequate ventilation. ventilation
Keep away from heat, sparks, and flames.
Store in a well-ventilated area. Store in a
closed container. Bond and ground during
transfer.
Motor oil Soil Wear protective clothing and impervious Chemical goggles
contamination gloves when working with used motor oils. Neoprene or nitrile
gloves
Protective garments
Vehicle Negligible risk Minimize breathing vapor, mist, or fumes. Chemical goggles
grease with proper Avoid prolonged or repeated contact with skin. Neoprene or nitrile
handling Remove contaminated clothing; launder or dry- gloves
clean before re-use. Remove contaminated
shoes and thoroughly clean before re-use; Protective garments
discard if oil soaked. Cleanse skin thoroughly Ensure adequate
after contact, before breaks and meals, and at ventilation
end of work period. Product is readily removed
from skin by waterless hand cleaners followed
by washing thoroughly with soap and water.
To prevent fire or explosion risk from static
accumulation and discharge, effectively ground
product transfer system in accordance with the
national fire regulations. Keep containers
closed when not in use. Do not store near
heat, sparks, flame or strong oxidants.
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Compressed Gas Cylinders:
Compressed gas cylinders shall be kept securely stacked inside the purpose-built rack in up-
right position to prevent accidental fall. These cylinders must be kept away from heat or open
flame. The protective cap should always be kept in place while transporting the cylinders. The
cylinder should be transported using a suitable trolley and under no circumstances should a
cylinder be dragged.
Oxygen cylinders must be stored at least 6 meters away from the cylinders of acetylene.
Safety “No Smoking” signs shall be provided. Suitable fire extinguishers shall be provided at
the storage area.
Flammable & Toxic Chemicals:
Such chemicals shall be stored inside a well-ventilated room, far away from any source of
ignition or heat. Moreover, such chemicals should be stored at least 15 cm from floor level in
order to provide adequate containment under them in case of spillage and in comparatively
cold place without exposure to direct sunlight. An extraction duct closer to floor level must be
provided in the store, where flammable vapors heavier than air might be released from such
chemicals.
Material Safety Data Sheets (MSDS):

The Safety Data Sheet (MSDS) for each chemical/hazardous material shall be available at
worksite. The Low Tier Construction Sub-Contractors shall ensure all workers involved in
handling of such hazardous material will use the required protective equipment and are trained
in first aid procedures against the accidental exposure as defined in the MSDS.
The locations of storage areas shall be marked on to a site plan showing details of substance
type and quantity, supported with a copy of the MSDS for the Emergency Plan and use of the
emergency services.
Empty containers shall be removed as soon as possible and arrangements made for their safe
disposal.
All storage areas must be conspicuously marked inside and out with signs: “Flammable - Keep
Fire Away - No Smoking”.
9.3.15 Pressure and Leak Testing

METROPOL İNŞAAT shall ensure that Low Tier Construction Sub-Contractors develop
Method Statements and RA which includes material, tools, and equipment and hazard
assessments and control measures for the activity and obtain approval prior to commence of
pressure and leak testing activities.
Low Tier Construction Sub-Contractors shall ensure all personnel involved with testing shall be
aware of and trained in the procedures to be implemented and familiar with the hazards and
risks associated with the activity.
Controls / gauges must be located at a safe distance from the equipment to be tested and
gauges shall be clearly visible to the operator controlling the pressure.
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Standard warning signs are to be strategically posted on equipment being tested and at the
perimeter of the test area. Lookout personnel are to patrol the area perimeters continuously
during the testing operation.
Safety valves of adequate size, properly set, seated and marked with the set pressure, shall
be installed in the test supply line to prevent the test pressure from being exceeded. Only
acceptable medium for leak testing shall be used; usually nitrogen or water.
Systems which have contained air following the test shall be inserted prior to the introduction
of hydrocarbons to avoid any possible explosive pockets during process phase.
METROPOL İNŞAAT shall supervise and ensure Low Tier Construction Sub-Contractors
perform pressure testing activities safely.
9.3.16 Drugs, Alcohol and Smoking

It is the policy of METROPOL İNŞAAT to maintain a work environment free from the influence
of alcohol and other drug abuse. Accordingly, METROPOL İNŞAAT prohibits the consumption,
use or influence of alcohol during working hours and prohibits the use of illicit drugs at any
times. This includes to/from and during work or when conducting business on behalf of
METROPOL İNŞAAT. Low Tier Construction Sub-Contractors’ employees have to be free
from alcohol, illicit drugs and controlled substances. Low Tier Construction Sub-Contractors
will maintain a similar policy regarding its own premises during working hours.
METROPOL İNŞAAT will have a program for drug and alcohol abuse prevention and random
testing.
METROPOL İNŞAAT will enforce programs that will ensure the workforce under his
management, Low Tier Construction Sub-Contractors or visitors are free from the effects of
alcohol or drugs during work periods, mid-day breaks and travel journeys to and from the
worksite.
Any incident involving illicit drugs or controlled substances will be brought to the attention of
the appropriate law enforcement agency.
METROPOL İNŞAAT will immediately remove personnel violating the policy from the
premises.
Random alcohol testing may be applied for all personnel but especially for operators and
drivers of heavy vehicles. (Cranes, excavators etc.)
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors will note the following
important requirements for the site, applicable to all personnel:
• Smoking, weapons and drug/alcohol policies are to be posted on site.
• No smoking in the work sites at all times. “No smoking” signs will be respected at all times.
Designated smoking areas will be addressed for the site, which shall be away from the any
gas exposure and other hazardous areas. Designated smoking areas are to be protected
from rain and sun and equipped with extinguishers and ashtrays.
• No smoking within site vehicles.
Individual violators of the above smoking rules may be subject to immediate dismissal.
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9.3.17 Workshops
There are many engineering activities and operations involving the use of machine tools and
equipment in construction that may pose hazards unless suitable precautions are taken.
Authorized competent persons will only carry out all operations covered by this section. Their
names will be registered in the appropriate logs. Safety measures shall be provided for
machines, equipment and machine tools (grinders, electric, liquid, gas, oxyacetylene welding
units, etc.) installed in an electromechanical or vehicle maintenance workshop. The number of
potential hazards in a workshop will vary on the size and complexity of activities carried out.
Workshops will;
• be provided with adequate fire-fighting equipment - have adequate number, size and type
of fire extinguishers located at adequate and strategic points of the building, the storage
area and other facilities;
• be well illuminated;
• be adequately ventilated and where necessary have local exhaust ventilation;
• have a good standard of housekeeping;
• only contain flammable material necessary for the day-to-day operation of the workshop;
• have clearly identified pedestrian routes and, where possible, reversing of mobile plant
should be avoided;
• have an inspection scheme for all tools and equipment so that they are safe to use;
• have gas bottles racked and gas welding bottles should be fitted with a flashback arrestor;
• control the use of naked flames;
• have adequate sanitary and hygienic washing facilities;
• have procedures for waste management of used oils, tires, batteries, brake and clutch
linings etc.
9.3.18 Worker Camps

When Workers Camp of Metropol İnşaat is built Camp Site Management plan shall be
developed and put in implementation.
As General:
Conditions and standards of worker camps will be as per contract requirements, local laws and
upon approval by the CONTRACTOR and OWNER. Camps will operate and be located in an
area that will not disturb or negatively impact, causing social or environmental damage to the
community or workers. This includes;
• Health and safety plans and emergency management will include worker camps,
workshops and offices.
• All camps, workshops and offices will contain gender separate ablution facilities and where
appropriate, gender separate sleeping facilities and gender separate recreation facilities (if
appropriate).
• Purchase or rental of land or structures/facilities and any renovations will be in line with
relevant resettlement policy requirements and local laws.
• No trees will be cut for facilities and the areas will be rehabilitated back to at least the pre-
project state or better condition.
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Monitoring of health and sanitation standards for the worker camps will be performed in
accordance with the Project HSE PLAN
Measures against Insect and Pest Nuisance:

METROPOL İNŞAAT will at all times take the necessary precautions to protect the personnel
employed on the site from insect and pest nuisance, and to reduce their danger to health.
METROPOL İNŞAAT will comply with all the regulations of the local health authorities,
including use of appropriate insecticide.
These requirements shall be implemented in METROPOL İNŞAAT site offices, canteens, and
other welfare facilities.
9.3.19 Welfare, Amenity Provision, Catering, Sanitary, Personal Hygiene

METROPOL İNŞAAT will provide sufficient messing facilities to the personnel. The messing
facilities will be serviced, maintained and subjected to regular inspections.
HSE personnel, doctor and administration manager / camp manager will audit messing
facilities, staff and also accommodation facilities on a regular basis.
Toilet / washing / shower / drinking water / rest facilities will be in suitable locations and
sufficient numbers for the personnel on site. They will be cleaned regularly and maintained in a
hygienic manner by dedicated personnel.
Employees handling food will be supplied with 2 pairs of uniforms, aprons, caps and safety
shoes. They must maintain a clean, neat and tidy appearance and must be rigorous in matters
of personal hygiene. Any medical disorder of any nature, including cuts and temperatures,
must be reported to a supervisor who will re-assign duties until medical clearance has been
obtained. Food Handlers shall have health and hygiene trained and certificated as per Turkish
Food Hygiene Regulation and medical reports for these employees will be collected once a
year.
Food Storage:
Refrigeration and freezer facilities will be provided. Frozen food will be defrosted in
refrigerated cabinets. Facilities will keep frozen food at –18 degrees Celsius, chilled food
between –3 and +1 degrees Celsius, and refrigerated food between 1 and 4 degrees Celsius.
All cooked food will be kept separate from uncooked food.
Fish and meats will be stored in dedicated separate freezers.
Walk-in freezers/chillers will be provided with internal lighting. An external temperature
indication will be given and the store will be readily opened from inside.
Sufficient food storage will be provided to cater for emergencies.
Food will be stored such that a first in first out system is in operation. Storage will be on raised
shelves. Food store must be maintained clean, tidy and pest free.
No cleaning materials will be kept in food stores.
Transportation of food:
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Points to Note during Food Transportation

Proper Protection of Food
Food should be stored and transported according to their categories, for example: transport
raw food and cooked food separately to avoid cross- contamination;
Non-packaged ready-to-eat food should be protected properly or stored in appropriate and
lidded containers;
Food should be protected from direct sunlight or rain during transportation;
Food transportation vehicles should not be used for transporting other goods (especially
chemicals and waste).
Paying Attention to Transportation Temperature and Time

Food should be transported by vehicles fitted with temperature monitoring equipment, with chill
temperature at below 5oC, freezing temperature at - 18oC or below, and hot-holding
temperature at above 60oC;
Before loading food, which needs to be kept at low temperature (such as refrigerated or frozen
food), the temperature monitoring equipment of the transportation vehicle should be checked
to ensure that it functions effectively and the temperature in the compartment reaches the
appropriate level;
9.3.20 OFFICE SAFETY

Design and Layout
Ergonomics principles are essential in workspace layout and design, especially in areas like
seating, work posture and tool design, and environmental factors such as lighting and
ventilation.
When designing a workstation, it is necessary to consider:
 If the layout of the workplace accommodates the required equipment.

 The flow of work and movement of people.
 The work position that best suits the task.
 Material storage and handling.
 If space permits employee access to materials, tools and work items.
 The work motion and work posture.
 The location of controls and displays.
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Site offices should properly accommodate employees. Sufficient clearance should be provided
for the movement of the head, shoulders and/ or knees when employees are carrying out the
task.
Special consideration for Site Office design shall be taken into account, such adequate
distance between work stations, in order to ensure adequate control against COVID-19
outbreak. Refer to the attachment COVID 19 PREVENTION & PROTECTION PLAN (PLN-
CVD-PTA-002) for more details.
Temperature
A hot or humid environment increases the physical demands of the work on the employee and
may rapidly tire him/her. On the other hand, cold working environments may prevent muscles
from warming up properly and increase the risk of injury.
The conditions of the indoor environment in Site offices can also have an impact on employee
comfort and well-being, and hence should be assessed.
Lighting
Sufficient and suitable lighting, whether natural or artificial, should be provided for employees
to perform their tasks. Lighting should allow employees to see displays, move and use
equipment and controls safely, accurately and efficiently. Glare should be avoided to enable a
comfortable visual environment for employees.
Even at low levels, unwanted sounds can constitute health and safety hazards by increasing
stress levels, and impairing communication and concentration. Sudden unexpected noises can
startle and cause accidents. At high levels, noise can cause such problems as headaches,
nausea and hearing loss.
Noise prevention begins with identifying all of the noise sources in the office. Furnish walls,
ceilings, and other large surfaces with sound absorptive materials. Use office dividers to
reduce or redirect sound away from workstations. Soft floor surfaces will reduce noise. Heavy
drapes or sound-absorbing wall decorations will also help.
Emergency Response Plan for Offices
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Metropol İnşaat shall be followed and implemented “Emergency Response Plan” of the Project
(PLN-ERP-PTA-004), incorporating the necessary drills and taking into account the different
emergency scenarios.
The instructions shall be revised and updated when deemed necessary. Updated information
shall be posted in all CONTRACTOR Site offices.
Personnel shall:
 Be familiar with the escape routes, the emergency exit layouts, the location of fire
extinguishers, and the manual push buttons.
 Do not block escape routes or exits, or access to fire-fighting equipment.
 Do not move fire extinguishers.
 In case receive visitors in the building, ensure they also become familiar with the
emergency exit layouts. Accompany them in all circumstances, and ensure they arrive
safely to the muster point.
To prevent fires, they shall:
 Do not use open flames or unusual uncontrolled sparks equipment without special
authorization from the Emergency Marshall.
 Do not place heat sources near combustible materials.
 Inspect their work place and turn off all office electrical equipment at the end of the day.
 Remember that smoking is not allowed in the facilities.
 Keep liquids away from electrical / electronic equipment.
 Avoid accumulation of boxes and files.
Office Safety Rules
General Office Rules:
 Do not open the windows during windy days to avoid ceiling panels falling.
 Hold on to the handrail when going up or down the stairs. Do not look at phones or any
document while going up or down the stairs.
 All sensitive documentation to be removed from desks and locked. CONTRACTOR
offices will be locked after finishing the working day with no access for janitorial staff
and all sensitive documentation to be removed from desks and locked.
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 There will be elements to clean the boots in the entrance of the offices and disposable
plastic covers for the boots.
 Wet floors will be signaled.
 Janitorial Services will be available in the offices.
 Cleaning products will be kept in the offices in specific areas.
Parking Areas:
 Respect the speed limit of the parking areas.

 It´s strictly forbidden to drive in opposite direction.
 Respect sign posts, especially pedestrian crossings.
Pedestrian Access:
 Always use pedestrian crossings. Don’t walk on the road but on the sidewalk.
 Do not look at your phone or any document while crossing the streets
Smoking Ban:
 Smoking in toilets or inside Site offices is strictly forbidden.

 Smoking is only allowed in designated smoking areas.
Drugs & Alcohol:
 The use, possession or been under the influence of drugs and alcohol is forbidden.
Inspections and Audits

Weekly HSE Inspections of CONTRACTOR Site Offices shall be carried out by
CONTRACTOR Site HSE Team. Records of these inspections and follow up of corrective
actions shall be maintained and shared to promote HSE improvement.
Site offices will be audited by CONTRACTOR Corporate Audit Team as part of

CONTRACTOR Corporate Construction HSE Internal Audit.
CONSTRUCTION SUBCONTRACTORS shall implement similar Site Office inspections and

audit programs.
Incident and Accident
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Any incident or accident shall be investigated. Metropol İnşaat shall follow and implement the
requirements stated in CONTRACTOR “Incident Investigation Procedure” (10330-00-091-PD-
0019).
9.3.21 Noise and Vibration

METROPOL İNŞAAT will make every practicable effort to reduce noise levels legally specified
noise exposure upper level, subject to the length of the work shift. METROPOL İNŞAAT will:
• Conduct a noise assessment,
• Take steps to prevent or control the risks,
• Where possible eliminate exposure to noise at source,
• Control exposure to noise,
• Provide personal protective equipment (PPE),
• Provide information and training,
• Regularly monitor and review the effectiveness of the measures.
To minimize the noise on the construction site and nearby communities, the following
measures will be taken.
• Low noise/vibration type of equipment will be used. (e.g., oscillating rollers and similar
equipment with reduced noise/vibration).
• The construction machinery being in intermittent use will be shut down or throttled to a
minimum.
• Noise reduction devices on machinery will be used and aging machinery will not be used.
• Periodic checks on vehicles will be used to ensure noise is minimized.
• Construction machinery and other equipment will be well-maintained and serviced regularly
during construction works.
• Consultation with community to warn of inconveniences and provide advice on household
measures residents can do in mitigation.
• Optimized transportation management to avoid needless truck drives
• In case noise limit values at the construction site exceeded 80 dBA, ear protection devices
will be used by the workers; and in the nearby residence will not exceed the standard 42
and 55 dBA in the night-time and daytime, respectively.
• There will be no night time work or deliveries unless special permission is gained from the
OWNER and local authorities – will only be granted in rare cases.
• PPE will be provided to all workers for exposure to high noise activities
METROPOL İNŞAAT will be responsible for damages to any structures or property that are
proved to be resulting from construction works and will repair and/or compensate for such
damages.
Monitoring
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Noise and vibration monitoring will be conducted on a regular basis. Monitoring shall be
implemented as per CONTRACTOR CONSTRUCTION ENVIRONMENTAL
MANAGEMENT PLAN (10330-00-091-PD-0011)
9.3.22 Night Operations
It is anticipated that some work on sites may be required during hours of darkness. There will
be no nighttime work or deliveries unless special permission is gained from the OWNER and
local authorities – will only be granted in rare cases. In those cases, local regulations and the
following illumination guidelines will be followed:
• All means of egress will be illuminated with lighting as per the requirements of the local
regulations.
• Illumination will be arranged so that failure of any single until will not leave any work area in
total darkness.
• The portable lighting and other lamps & fixtures will be guarded and secured to preclude
injury to personnel.
• Open fluorescent fixtures will be provided with wire guards, lenses, tube guards and locks
or safety sockets that require force in the horizontal axis to remove the lamp.
• Lamps used for general illumination shall be protected from accidental breakage or contact.
Protection will be provided by elevation of at least 2 meters from the normal working
surface.
• Night work operations must be submitted to METROPOL İNŞAAT HSE Department by Low
Tier Construction Sub-Contractors minimum 24 hours before to arrange work schedule and
assign a full-time site supervisor and HSE personnel. Low Tier Construction Sub-
Contractors must assign HSE personnel for the work areas to observe HSE applications at
work areas. Low Tier Construction Sub-Contractors must consider rest periods of HSE
personnel.
• Low Tier Construction Sub-Contractors must provide sufficient illumination for all work
areas and personnel walkways, otherwise night work operations cannot be performed.
Minimum Lighting Requirements:

Function Illuminance - lx (lm/ft²)
Access ways
- General Outdoor 33 (3)
- Exit ways, walkways, ladders, stairs 110 (10)
Construction Areas
- General Outdoor 33 (3)
9.3.22 Weather Conditions

METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall make the following
arrangements, as minimum:
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• Make arrangements for work at low temperature

• Have in place a plan to commence activities after adverse weather conditions,
• Provide enough capacity of rest areas with heating facilities,
• Provide shaded areas for protection of materials, equipment etc.,
• Ensure supervision of work areas after heavy rain and snow,
• Ensure appropriate drainage for rain water, provide enough number of pumps,
• Ensure appropriate conditions for activities influenced by weather (e.g., welding, tie ins etc.)
• Ensure appropriate conditions for materials sensitive to low temperatures;
• Provide functional Personnel Protective Equipment (PPE) related to weather conditions.
• Proper arrangements shall be made to ensure proper comfort of people in case of low
temperatures at site.
Above list is not exhausted and other arrangements might be required before, during or after
the period of adverse weather.
Summer season in the project area is very hot and dry, consequently awareness campaigns
and trainings shall be implemented during summer season. Information shall also be
communicated via HSE boards and proper signages throughout the project site.
There shall be sufficient number of water supplies, shaded rest areas. Rotation of workers and
arrangement on working hour may be considered as well.
9.4 HSE Performance Monitoring and Reporting
METROPOL İNŞAAT shall coordinate with Low Tier Construction Sub-Contractors to provide
a consolidated weekly and monthly reports of HSE performance, including injury and
occupational illness; environmental statistics and the results of monitoring effectiveness of
HSE management elements such as trainings, toolbox talks quality and attendance, field
inspections and audits, inspections of equipment, housekeeping, etc.; the leading as well as
the lagging HSE KPIs. Proposed Weekly and Monthly HSE reporting formats shall be provided
to Low Tier Construction Sub-Contractors.
Low Tier Construction Sub-Contractors will submit a monthly report to METROPOL İNŞAAT.
METROPOL İNŞAAT will submit HSE Report to CONTRACTOR on monthly basis and
Environmental and Social Management and Monitoring Report on monthly basis.
9.5 Records & Records Management
The records for monitoring and measurement are to be identified through the requirements of
the Contract and Legal Requirements. Low Tier Construction Sub-Contractors shall maintain
appropriate Project HSE records to demonstrate conformance to the Project HSE
Management Systems as applicable. Comprehensive safety records will be properly identified,
collected, indexed, filed at the Project HSE Office and they shall include as a minimum:
CONTRACTOR "Monthly HSE Summary Report" (10330-00-091-PD-0010-Tmp03) shall be
implemented as per section 18 of CONTRACTOR Site HSE Plan.
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• Project Specific Plans (Project HSE Plan, HSE Field Manual, Procedures etc.)
• Risk Assessments, Method Statements;
• Certificates (induction and training, first aid, medical etc.);
• Coordination documents (letters/memos etc.);
• Documents prepared and issued at site;
• Project HSE minutes of meetings;
• Tool box talks records;
• Training / Induction Program Records;
• PTW forms and administration records
• Audit /Inspection reports;
• Accident / Incident reports;
• Monthly reports;
• Waste generation and transportation records;
• Monitoring records such as Noise monitoring records, Air emissions monitoring records etc.
• Lifting tackles and crane or equipment inspection records, 3rd party certificates;
• Incident/Accident Records, log of all cases reported and treated;
• Infringement Reports and traffic violations;
10 COMMUNICATION & CONSULTATION
Effective communications are vital to the successful implementation of the HSEMS and this
Project HSE Plan. Communications take many forms but their common objective is to improve
understanding of health, safety and environmental matters. For an active safety culture to exist
within an organization a number of mechanisms need to be in place to allow two-way
communications between all personnel. METROPOL İNŞAAT acknowledges that effective
consultation and extensive participation by personnel is essential for the desired safety culture
to exist. Through communication it is intended to obtain the support, co-operation and
commitment of all workforce and interested parties. METROPOL İNŞAAT shall keep effective
communication aids with Low Tier Construction Sub-Contractors, OWNER and Engineer.
10.1 Quarterly HSE Committee Management Meetings
METROPOL İNŞAAT shall establish HSE Committee which includes Senior Managers, HSE
Representatives of Low Tier Construction Sub-Contractors. This committee shall meet at least
monthly to review performance, initiate improvements, to reward good individual and/or group
HSE performance, and to address significant risks, issues, anticipated problems in future
works.
METROPOL İNŞAAT Project Manager or Site Manager will chair these meetings and this
meeting held once a month shall comprise the following members of the Project Management
Team:
• Project Manager / Site Manager
• Project HSE Manager
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• Low Tier Construction Sub-Contractors Senior Representative

• Low Tier Construction Sub-Contractors Senior HSE Representative
• Low Tier Construction Sub-Contractors Senior Construction Representative
• Site supervisors’ representative, workers’ representative
The monthly management meetings will be used as a forum to advance health, safety and
environmental awareness. The HSE focus of the Management Meeting is to discuss HSE
progress, seek to advance co-operation on matters affecting HSE issues between all parties.
The HSE objectives/outcome of the monthly Management Meeting as a minimum are as

follows:
• To review and discuss ongoing programs / measures taken to ensure the health and safety
of the work force and the protection of the environment;
• To review and discuss serious accidents / incidents;
• To review HSE trends and statistics and, where appropriate, discuss actions to be
implemented based on this data;
• To consider any outstanding corrective actions as detailed in HSE audits, and make
recommendations; and
• To promote and develop management strategy for HSE progress.
10.2 Weekly HSE Meetings
Weekly HSE meetings shall be chaired by Project HSE Manager, and provide the means for
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors HSE Representatives to
participate in active discussion; promoting and considering ideas and suggestions from any
member of the meeting on any matter affecting health and safety of the work force and
protection of the environment; resulting in action items, recommendations and safety
campaigns as appropriate.
Discussions are concerned with measures to improve workforce involvement in promoting

Occupational Health and Welfare, Safe Systems of Work, and implementing best practices
designed to improve health, safety and environmental protection, and in addressing project
HSE issues and concerns in a timely and effective manner.
10.3 Weekly Construction Progress Meetings
All Weekly construction progress meetings shall open with a discussion on site HSE issues.
Concerns shall be tabled and reviewed and necessary action items raised shall be
implemented immediately with an objective of continuous improvement in construction HSE.
10.4 Stand Down Meetings
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Stand Down meetings are held when serious accident and incident occurred, and are attended
by Senior Representatives of METROPOL İNŞAAT, Low Tier Construction Sub-Contractors
and Senior HSE Staff of all represented parties.
The objectives of the Stand Down Meeting are:

• To present detailed data on serious and High Potential Recordable Incidents;
• To review and discuss incident findings;
• To define preventive measures to eliminate hazards to workforce and the environment;
• To develop and approve recommendations and action items for each incident; and
• To capture “Lessons Learned” for cascading to workforce, and other parties as required as
Safety Alerts.
10.5 Toolbox Talks
The depth of coverage is dependent upon the level of existing knowledge relating to the work
activity. The following items must be covered in all Toolbox Talks:
• Highlight the relevant Permits to Work and the associated hazards and control measures;
• Discuss Task Risk Assessments and whether any additional or unforeseen hazards exist;
• Discuss relevance of procedures and method statements and whether any revisions are
necessary;
• Discuss whether the whole team is familiar with the work;
• Discuss any hazards which may emanate from other activities in the vicinity of the work;
• Discuss relevant Health & Safety topics, Environmental Management issues, potential
hazards, incidents occurred etc.
Two-way communications will be encouraged and an interpreter must be present if needed.
Tool Box talk record sheets must be filled in and held at the workplace for the duration of the
work, before being returned to the respective departments for filing. METROPOL İNŞAAT and
Low Tier Construction Sub-Contractors’ Senior Management shall participate in Toolbox Talks
regularly to demonstrate the commitment and leadership.
Toolbox Talks on daily basis:
METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors supervisors give
daily Toolbox Talks at the beginning of each workday or each shift and the commencement of
a new task. These will be conducted by the line or task supervisors, in a language understood
by the workforce and will address the application of safety rules and procedures to the hazards
of current work whether work permit required or not.
To ensure maximum effectiveness, Toolbox Talks shall be conducted at the location where the
task will be performed. The Toolbox Talk is to be specific to the location and task in hand and
is not a general safety talk. The supervisor is to ensure that his work group is provided with the
information and instructions required to fully understand the hazards involved in completing
the task and the safe work processes required to safely execute the task – brief summary –
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with the RA and PTW requirements, tools fitness for purpose and service and location
hazards, i.e., access, egress, emergency response, concurrent activities should be covered by
the Toolbox Talk.
Method statements and risk assessments are going to be major sources for toolbox talks.
Toolbox Talk shall be documented and kept together with the specific PTW, if such, at the
work location. Duration of the team talk will be no less than 10 minutes. In the case of
particularly hazardous operations (for example, confined space entry) team talk duration will
be appropriate to the task undertaken.
Toolbox Talks on weekly basis:
The appropriate METROPOL İNŞAAT and Low Tier Construction Sub-Contractors HSE staff
and supervisor will conduct weekly toolbox talks. Topics will be given to supervisors by
METROPOL İNŞAAT HSE team. Attendance signatures will be obtained. Items should be
covered with weekly Toolbox Talks are actual or relevant HSE topics, general / potential
hazards, lessons learned from incidents occurred etc.
10.6 Behavioral Safety Observation Program
METROPOL İNŞAAT will implement the behavioral observation program in line with the
OWNER’s Program. This will involve training of METROPOL İNŞAAT and Low Tier
Construction Sub-Contractors Supervisors to carry out observations of their co-worker’s
behavior and determine whether this is safe or unsafe. They will be trained to feed this back to
the workers concerned in an appropriate manner, reinforcing good behavior when it is seen.
Each observer will feed back the results of his observations into a data base system that will
summaries the results. The results will be fed back each week to the workforce in toolbox
talks.
10.7 HSE Walkdowns and Observations
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors Site Managers, HSE
Managers, Supervisors and other employees are expected to continuously check/observe the
activities in terms of health, safety and environment during the execution of their work.
Weekly HSE Walkdowns shall be conducted with the participation of Senior Representatives
of METROPOL İNŞAAT (PM, Site Manager and any members of Management), Low Tier
Construction Sub-Contractors and Senior HSE Staff of all represented parties at work field.
Scope and attendees of HSE Walkdown shall be determined by Site Manager and HSE
Manager.
All employees at the site are expected to observe activities whether at their field or not and
have responsibility to intervene/correct unsafe acts or conditions and inform their supervision
as soon as possible. Those observations will be recorded in simple HSE Observation Cards
which will be available at various locations on site.
Those HSE Walkdowns or Observations will act as inspections but they will be less formal and
be an integral part of the job aiming to take the corrective actions immediately. All HSE
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Walkdowns or Observations findings will be shared with responsible parties & Low Tier
Construction Sub-Contractors and corrective actions will be tracked via register until closure.
10.8 Feedback from Site Personnel
It is important that all METROPOL İNŞAAT personnel and Low Tier Construction Sub-
Contractors form an active part of the Health, Safety and Environmental Management process.
Lines of communication need to be developed from site personnel through their supervision
and management to Senior Management.
Mechanisms for feedback can include:

• Recording of concerns / recommendations and other feedback from Tool Box Talks; HSE
Observations and concerns / recommendations raised with site supervision;
• Safety Suggestion Program will be implemented so any site worker may submit
suggestions for improvement. Safety Suggestion boxes will be placed in key areas on site.
Any major issues on health, safety and environment generated by site personnel, should be
tabled at the weekly HSE meeting, or raised to the monthly Management meeting if applicable.
The conclusion of these discussions should always be communicated back to the work force
and source.
10.9 Safety Bulletin Boards
At the entrance to Project facilities, Low Tier Construction Sub-Contractors shall erect safety
notice boards, which will display to all visitors and Project personnel a brief statistical
statement of Project HSE Performance by “current month” and “cumulative to date”.
Low Tier Construction Sub-Contractors HSE Dept. will make necessary arrangements for HSE
bulletin boards to be erected in prominent position at the Project and site offices, workshops,
warehouses, accommodation blocks and canteens. These Bulletin boards shall be used for
the communication of safety awareness bulletins, HSE Policies, current safety issues, safety
awards etc.
10.10 Safety Slogans / Posters
Suitable and sufficient safety posters and slogans shall be displayed in prominent positions
throughout the Project facilities in order to raise personnel awareness of HSE. Safety posters
shall include current Occupational Health, Safety and Environmental topics, in particular when
used in conjunction with HSE Campaigns.
Where possible, posters with a strong visual message shall be given preference to written
information.
10.12 Reporting
All Toolbox Talks, safety bulletins and safety posters, “lessons learned”, etc., shall be
conducted or compiled in a multilingual format in order to ensure full comprehension amongst
a multinational workforce.
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11 CRISIS AND INCIDENT MANAGEMENT
11.1 Incident Investigation, Analysis and Reporting
The prompt reporting and thorough analysis of all accidents, incidents, near miss incidents
provides an important performance indicator. Low Tier Construction Sub-Contractors shall
prepare Incident Investigation & Reporting Procedure and submit for METROPOL İNŞAAT
approval which shall be in line with METROPOL İNŞAAT’s system and include as minimum
Incident reporting, classifications, investigation process, identifying root causes and analysis
etc.
All Low Tier Construction Sub-Contractors shall immediately report to METROPOL İNŞAAT
any incident, fire or explosion involving death or injury to Project personnel or any other person
and any other loss or damage to the facilities or equipment and also shall without delay also
report such events to the concerned Authority, as required by applicable local laws. A copy of
such report will be simultaneously sent to METROPOL İNŞAAT.
Low Tier Construction Sub-Contractors shall submit all notification reports and final incident
reports to METROPOL İNŞAAT using an agreed template and within proper durations.
Any incidents on Project premises shall be reported in accordance with the reporting system.
The Low Tier Construction Sub-Contractors shall notify METROPOL İNŞAAT immediately of
any incident arising from the work activities, including any near misses. The Low Tier
Construction Sub-Contractors shall cooperate and participate as necessary with METROPOL
İNŞAAT in any investigation of such incidents.
All injuries, non-accidental deaths, occupational illnesses, damages, security incidents,

environmental incidents and near misses shall be considered work related until proven
otherwise and reported to METROPOL İNŞAAT and shall be promptly (as soon as practical
after it occurred) and thoroughly investigated by METROPOL İNŞAAT and Low Tier
Construction Sub-Contractors Management.
All incidents shall be assessed and classified using the Risk Assessment Matrix.
The seniority of the investigation team and the extent and thoroughness of investigation and
analysis shall be based on the significance of the potential HSE risk.
All significant incidents and high potential incidents bring significant learning value and shall be
analyzed according to root cause analysis. The investigation report must include an analysis of
immediate and underlying causes and weaknesses in the HSE Management System and the
final classification of the incident based on the outcome of the incident investigation.
Accidents and incidents are viewed by METROPOL İNŞAAT as learning opportunities.

Identifying the immediate and root causes, correcting them and communicating lessons
learned help to ensure that they are not repeated.
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Detailed information on incident investigations, analysis of incidents, reporting requirements

including reporting to CONTRACTOR and local authorities are given in CONTRACTOR
Incident Management Procedure (10330-00-091-PD-0019)
11.2 Emergency Response
METROPOL İNŞAAT shall develop Emergency Response Procedures (ERP) and Low Tier
Construction Sub-Contractors shall prepare and submit the ER procedures for approval.
Emergency Response actions are detailed in METROPOL İNŞAAT “Emergency Response
Plan” (PLN-ERP-PTA-004).
METROPOL İNŞAAT Emergency Response Plan will be in line with CONTRACTOR

Emergency Response Plan (10330-00-091-PD-0013)
The key points of Emergency & Medical Response plans are listed below:
Emergency Response:
Emergency Response
Procedures outlines emergency incident scenarios that address the potential major incidents
at the work sites and construction camps, including security incidents, fire, explosions,
collapse of structures, serious injuries, exposure to chemicals and toxic materials, including
potential exposure to toxic gas, site evacuation, medical emergencies and potential
environmental incidents on land and to water and describing the response to various medical
emergency scenarios and medical evacuation procedures. The plan shall also address natural
occurrences such as lightning, storms and floods where relevant.
Emergency Response Procedures shall detail the emergency organization, responsibilities of

METROPOL İNŞAAT and Low Tier Construction Sub-Contractors Emergency Response
Teams (ERT), coordination, communications and call-out, work site evacuation, rescue of
injured persons and co-operation with relevant local authorities, national bodies, emergency
services & local industry; and emergency management, command structures, emergency
control resources and/or any other aid to handle the potential emergency scenarios. All
emergency response activities shall be coordinated with the Security services.
METROPOL İNŞAAT shall ensure to establish an organization that shows the members of the
Emergency Response Team including, CONTRACTOR, other Construction Subcontractors
and METROPOL İNŞAAT Low Tier Construction Sub-Contractors along with their roles and
accountabilities.
The Contingency Plan shall be put into effective use through emergency procedures. It
includes an inventory of all available means to cope with emergency situations, (for example:
evacuation, major disaster or wide-spread pollution), and the way to react to them and
inclusive of a list of all materials (equipment) and resources as required by local regulatory
requirements and METROPOL İNŞAAT Emergency Response Requirements. METROPOL
İNŞAAT shall liaison with authorities and for handling process emergencies on operating
locations and during commissioning. METROPOL İNŞAAT shall ensure all major Low Tier
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Construction Sub-Contractors provide materials (equipment) and resources as required by

local regulatory requirements and METROPOL İNŞAAT Emergency Response Requirements
including, but not limited to:
• Logistics support, mechanical handling devices, firefighting facilities, oil spill response
equipment and materials, ambulances, etc.
• Adequate first aid equipment; fire extinguishers; ambulance,
• Spill remediation equipment and other safety equipment.
• Location of such materials (equipment). How much notice needed to have them operational
on site and how to have them mobilized.
• Emergency Response Team composition.
• Communication protocol.
• All other details of interest.
Additionally, Low Tier Construction Sub-Contractors shall agree with METROPOL İNŞAAT for
provision of any material/ equipment required centrally for emergency support and handling
emergencies. (METROPOL İNŞAAT may provide required centralized emergency equipment
or if required Low Tier Construction Sub-Contractors may provide if requested by METROPOL
İNŞAAT).
METROPOL İNŞAAT shall appoint an Emergency Response Leader for ensuring that
Emergency Response Plans and procedures are followed during an incident and coordinate
with Low Tier Construction Sub-Contractors ERT, who must have competence level for
emergency response of “Skill” or higher; as well as the other members of the Emergency
Response Team. METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall
provide training to establish and maintain the competency of individuals and Emergency
Response Teams.
To ascertain that emergency procedures are well understood by Low Tier Construction Sub-
Contractors and other project personnel, METROPOL İNŞAAT shall conduct drills of its
emergency response regularly according to the program that includes desktop testing of
notification and activation procedures, Emergency Response Team communications and
communications with internal and external contacts, and mobilization exercises using
equipment and key regulatory agencies, METROPOL İNŞAATs and consultants and review
the drills roll-out to identify lessons learned and use these to improve training and procedures.
Training exercises (drills) to test the system and maintain the expertise of the teams involved
will be held at regular intervals in accordance with applicable laws and this will include all site
personnel.
Escape routes, leading to the muster area, shall be provided to enable all personnel to leave
an area in case of a hazardous incident. Escape routes shall be well marked, including signs.
Marking shall show the preferred direction of escape.
In all emergency situations, it is agreed between METROPOL İNŞAAT and Low Tier
Construction Sub-Contractors that mutual assistance is an understood requirement and that
any call for assistance must be promptly responded to.
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Low Tier Construction Sub-Contractors shall develop Emergency Response Plans for their
scope of work and area of work in line with METROPOL İNŞAAT’s Emergency Response Plan
for the project and submit along with their HSE plans for approval.
Medical Emergency Response:
METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors will establish
resources and maintain medical Emergency Response, which provides:
• First-aid treatment, including defibrillation, by a designated First Aider.
• Assessment and stabilization by a Medical Emergency Professional.
• Admission to and care at the nearest local hospital within four hours referral to an
appropriate specialist hospital (casualty specific).
METROPOL İNŞAAT will establish and maintain a Central Medical Facility at the main camp
and Office location and arrange provision of medical services as needed to the Project
personnel. Each Low Tier Construction Sub-Contractors shall establish and manage on all
work locations, a first-aid kit and certified First-Aider shall be stationed in case of an injury or
medical emergency. First-Aiders from Low Tier Construction Sub-Contractors shall be certified
by Authorized Governmental Department and managed by METROPOL İNŞAAT.
The Low Tier Construction Sub-Contractors MER Plan shall include the dispatch of first aid
station personnel plus coordinating METROPOL İNŞAAT’s Emergency Response Team
dispatch (if required) to the site of the medical emergency and arranging the transport of the
patient back to the first aid station and/or transfer to the clinic, a local medical facility or
emergency evacuation as appropriate.
METROPOL İNŞAAT is responsible for ensuring the co-ordination of Emergency Response
and Medical Emergency Systems for its area of responsibility and will maintain an Emergency
Response and Medical Emergency Response Plans at a high state of readiness. Training
exercises to test the system and maintain the expertise of the teams involved, will be held at
regular intervals and will include all personnel of the Project.
The site Emergency Response System is based on the following hierarchy in terms of the
actions to be taken in the event of an emergency:
• Safety of People;
• Protection of the Environment;
• Safeguarding of Commercial Considerations.
Low Tier Construction Sub-Contractors will work together with METROPOL İNŞAAT’s team to
ensure the Project Emergency Preparedness and Response System is effective aligned with
and complements METROPOL İNŞAAT’s Emergency and Medical Emergency Response
requirements.
12 COMPLIANCE ASSURANCE AND CORRECTIVE ACTION
12.1 Compliance Assurance
Revision Date
Compliance assurance is an integral part of the HSE Management System and fundamental in
the review and improvement process. It consists of different levels of audit for system
compliance, inspections and reviews. The audit records the level of implementation of the HSE
Management Systems and Project HSE Plan. It also highlights to management excellence in
performance, as well as any shortfalls and areas for improvement. Low Tier Construction Sub-
Contractors shall prepare and submit the Audits/Inspection Procedures for approval. HSE
related audits/inspections may be performed by local authorities at various times to ensure
compliance and any relevant permit requirements as per Turkish laws and regulations.
12.2 Audits
Level 1 Internal Audits
HSE Audits
Senior Management will carry out systems and compliance audits covering both METROPOL
İNŞAAT and Low Tier Construction Sub-Contractors at least once annually.
Project HSE Audits – This shall be performed as per the ISO 45001 Standards and Contract
requirements. Project HSE Plan to ensure HSEMS and the arrangements defined in the plan
are both understood and in place.
Technical HSE Audits
Objective: To provide assurance to Site Manager that the arrangements in place for the
prevention, control and mitigation of hazards associated with the relevant operation are in
place and effective.
Project HSE Team will conduct internal audit to a developed schedule to ensure compliance
with this HSE Plan, Environmental Management and Social issues, and Contract
requirements. Audits will cover both METROPOL İNŞAAT’s and Low Tier Construction Sub-
Contractors’ works and facilities.
12.3 Inspections
METROPOL İNŞAAT shall carryout required inspections and ensures Low Tier Construction
Sub-Contractors carryout HSE inspections as per the schedule to cover the activities and the
materials (equipment) at all work locations.
Work areas and permits shall be inspected by METROPOL İNŞAAT and Low Tier
Construction Sub-Contractors supervision on an informal ongoing basis to verify compliance
and to ensure that working personnel understand the precautions necessary to perform the
work safely and without harm to the environment. Any non-compliance shall be rectified
immediately. An investigation may be instituted, depending on the nature and/or frequency of
occurrence of the non-compliance.
Daily inspections shall be conducted by METROPOL İNŞAAT and Low Tier Construction Sub-
Contractors HSE officers. Any concerns identified shall be immediately brought to the attention
of the relevant Low Tier Construction Sub-Contractors discipline supervisor for appropriate
action.
Revision Date
A weekly site tour shall be conducted by a team comprising Site Manager, HSE Manager and
Low Tier Construction Sub-Contractors Site Managers, HSE Managers and Site Supervision
as appropriate.
Minimum Inspection requirements listed as below:
Daily inspections:
• HSE compliance including PTW compliance, site HSE walks, site environmental
management, protection and housekeeping (HSE Staff),
• All equipment fitness for purpose and fitness for service prior to use (Supervisors),
• Scaffolds and work platforms (Competent Authorized person),
• Vehicle fitness for service and cargo lashing (Drivers),
• Crane and Heavy Equipment inspections by checklist (Operators),
• Housekeeping (Supervisors),
Inspections shall be supported by checklists and inspection report forms.
Tool, Equipment, Machinery inspection requirements table:
Table 4
TOOL, EQUIPMENT OR MACHINERY RECURRENCE TAGGING SYSTEM
TO BE INSPECTED
Scaffolds, pedestrian crossing for Weekly Tag

trenches
Fall Prevention / Fall Protection devices Quarterly Checklist + taping
Rigging equipment Quarterly Checklist + taping
Ladders Quarterly Checklist + taping
Revision Date
TOOL, EQUIPMENT OR MACHINERY RECURRENCE TAGGING SYSTEM
TO BE INSPECTED
Electrical tools Quarterly Checklist + sticker
Manual tools Quarterly Checklist + taping
Cages/cradles for hoisting compressed Quarterly Checklist + taping

gas cylinders
Welding tools Quarterly Checklist + taping
Heavy Equipment and machineries Daily Checklist performed by

operator
Quarterly Checklist + sticker
Electrical equipment and systems Quarterly Checklist + sticker
Grounding inspection program Quarterly Checklist + sticker
Elevated Platforms Quarterly Checklist + sticker
Annually Third Party Certification
Cranes Daily Checklist performed by

operator
Quarterly Checklist + sticker
Annually Third Party Certification
12.4 Corrective Actions
METROPOL İNŞAAT shall ensure that responses to non-compliance findings and areas of
improvement from its own and the audits, inspections and reviews are documented. Low Tier
Construction Sub-Contractors shall implement all agreed recommendations from such audits,
inspections and reviews within the timeframe mutually agreed between Low Tier Construction
Sub-Contractors and METROPOL İNŞAAT.
Revision Date
Depending on the level of the audit, Project Management Team, Project HSE Manager and/or
HSE Engineers will specify the required corrective actions, delegate appropriate responsibility
for their implementation and set reasonable time frames for their completion.
Corrective actions and their associated information are entered on to the Project Action
Tracking Register at site; these include actions from all relevant sources (audits, inspections,
incidents, observations etc.) and their close-out status is reviewed regularly by Project
Management. A close out evidence file provides confirmation of the close out of the actions
raised.
12.5 HSE Management Review
Project HSE Management System shall be reviewed, at least once a year to ensure the
continuity, suitability, adequacy and effectiveness.
Project HSE Manager shall coordinate the Management Review. Project Manager shall chair
the review and to be attended by the HSE Management Review.
Management Review shall address among others the following:

• Follow-up actions from previous management reviews;
• Suitability of the Project HSE Policies;
• Results of audits and evaluation of compliance with applicable legal and other
requirements. Changing circumstances, including developments in legal and other
requirements related to HSE;
• Review the current Project HSE Plan and procedures to ensure it is applicable with its
intent meets the requirements of the ISO 45001 and Standards;
• The result of participation and consultation and relevant communication(s) from external
interested parties, including complaints;
• The extent to which objectives and targets have been met for continual improvement;
• HSE performance data or statistic i.e., accident, incident and near miss, status of incident
investigations, corrective actions and preventive actions;
• Adequacy of resources, i.e., finance, personnel, and material;
• Recommendations for improvement.
13 LOW TİER SUB-CONTRACTORSS MANAGEMENT AND REQUIREMENTS

13.1 Low Tier Construction Sub-Contractors Qualification and Evaluation
METROPOL İNŞAAT shall coordinate the pre-qualification of all prospective Low Tier
Construction Sub-Contractors companies and ensures that those companies have the
capabilities to comply with the Project HSE requirements.
METROPOL İNŞAAT Questionnaire is used for Low Tier Construction Sub-Contractors HSE
performance evaluation. Low Tier Construction Sub-Contractors’ selection and subsequent
contract award shall be done by METROPOL İNŞAAT.
Revision Date
The Low Tier Construction Sub-Contractors shall as a minimum comply with the following
requirements:
• Must show past and current HSE performance.
• Must have a documented process, including procedures and work instructions, or an HSE
MS, which shows that the Low Tier Construction Sub-Contractors can manage the HSE
risks.
• Must have a competence assurance process for its personnel and assure they are
competent.
• Must show that its training program supports the management of the HSE risks.
• Must have a fitness to work process for its personnel and assure they are fit to work.
• Must have tools or equipment suitable for the job and safe to use.
• Must provide sufficient and competent supervision.
13.2 Low Tier Construction Sub-Contractors Responsibilities
In addition to the responsibilities mentioned at section 6.11, Low Tier Construction Sub-
Contractors shall take all reasonable measures to prevent damage, injury or loss to property
and all Project personnel. Low Tier Construction Sub-Contractors shall execute the work within
the framework of METROPOL İNŞAAT HSE policies and the Project HSE requirements as
detailed in Project HSE Plan, programs and procedures.
Low Tier Construction Sub-Contractors shall comply with the requirements of the Project HSE
Plan, and other plans and procedures for their scope of work.
Low Tier Construction Sub-Contractors shall develop HSE Plan which includes the safe
working practices and procedures in line with Project HSE standard requirements, method
statements and risk assessments for their scope of work and submit for approval.
Low Tier Construction Sub-Contractors shall allocate sufficient, competent and fit for work
resources to ensure the effective implementation of HSE MS throughout the various phases of
the work.
Low Tier Construction Sub-Contractors shall provide required trainings consistent with training
matrix in line with their scope of work.
Low Tier Construction Sub-Contractors shall provide all resources (Such as material,
personnel, office, training room, equipment, internet, cell phone, radio, computer and etc.) to
their HSE personnel to be able to perform their jobs.
All Low Tier Construction Sub-Contractors engaged on the Project shall conduct their work
activities and meet their duty of care responsibilities in compliance with this Project HSE Plan,
METROPOL İNŞAAT HSE Policies and the relevant legislation for the work activities
performed.
14 ENVIRONMENTAL MANAGEMENT
METROPOL İNŞAAT will ensure that all operations including Low Tier Construction Sub-
Contractors operations are in compliance with local regulations and cause minimal impact to
the environment. All significant aspects and the sensitivity of the receptor environment will be
taken into account in managing environmental risk on the Project.
Revision Date
At all times during the performance of the work, METROPOL İNŞAAT shall ensure Low Tier
Construction Sub-Contractors take all necessary measures in order to prevent discharge from
any source whatsoever into the atmosphere, ground and water of any substance which might
cause pollution or be deleterious to life or environment such as smoke, dust, oil, radio-active
products or other atmospheric, ground or liquid pollutants.
Environmental and social management and monitoring actions for the Project are described
detailly in CONTRACTOR Environmental Management Plan (10330-00-091-PD-0011)
14.1 Environment Management and Environmental Monitoring Plan

Environment Management include the following key elements:
• Environmental Policy;
• Planning (environmental review and identification of risks associated with the project,
identification of legal and other requirements, environmental objectives and targets in
accordance with the Contract);
• Implementation (resources, roles and responsibilities, training, documentation, operational
control and emergency preparedness and response);
• Measurement and evaluation (monitoring of performance, corrective actions, records and
information management);
• Communication and reporting;
• Audits and reviews.
The METROPOL İNŞAAT is committed to continual improvement in environmental

performance through the setting of objectives and targets, with the monitoring of these through
our performance indicators to ensure they are achieved.
The environmental policy and environmental management system, which forms part of the
integrated management system, will be maintained and regularly reviewed to ensure
prevention of pollution, compliance with relevant legislation, meeting our client and community
expectations and that activities are controlled to minimize impacts from our significant
environmental aspects, which include:
• Waste
• Releases to water
• Use of resources
• Contamination of land
• Nuisance and amenity
• Emissions to air
• Archaeology & local history
• Wildlife.
To emphasize the importance of good environmental practice, METROPOL İNŞAAT will

communicate its policies, plans to all employees and to those who undertake work on its
behalf. To ensure the effective management of relevant environmental issues, METROPOL
İNŞAAT is committed to a program of ongoing training and awareness for all employees
including Low Tier Construction Sub-Contractors.
Revision Date
METROPOL İNŞAAT’s HSE PLAN describes all the impacts/aspects identified for the Project
and arrangements for environmental management to ensure our impacts are minimized, and
to set out management and employee responsibilities to achieve this.
14.2 Waste Management Plan (WMP)

METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors will act to minimize
the quantity of waste resulting from the work and shall dispose of waste in accordance with
applicable laws, rules, regulations and good industry practices. Furthermore, METROPOL
İNŞAAT shall guide Low Tier Construction Sub-Contractors to incorporate controls to reduce
waste generation into procedures and working practices and shall identify opportunities to
reuse waste for the same or alternative applications.
METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors’ garbage; unused
hazardous substances and scraps should be removed from site and suitably disposed in
accordance with environmental regulations and TR’s Waste Management standards.
METROPOL İNŞAAT shall ensure that the treatment and disposal of all effluents arising from
the work sites and construction camps by Low Tier Construction Sub-Contractors are in
compliance with METROPOL İNŞAAT requirements and local legislation.
METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors will identify and
keep records of all work-related generation of waste in accordance with METROPOL İNŞAAT
reporting requirements and local legal requirements.
METROPOL İNŞAAT shall audit Low Tier Construction Sub-Contractors Waste Management
Plans and arrangements regularly to ensure effective implementation and compliance.
CONTRACTOR Waste Management Plan (10330-00-091-PD-0012) details all the aspects of
management of wastes for the Project.
14.3 Spill Prevention and Response Plan

METROPOL İNŞAAT shall ensure and manage the Low Tier Construction Sub-Contractors to
take all necessary precautions to prevent accidental spillage of fuels and chemicals. Drainage
from potentially hydrocarbon or chemical contaminated areas should be prevented from
entering the surface water and soil. Contingency plans shall be prepared for any uncontrolled
release, spill, or leak. METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall
provide sufficient and suitable emergency response personnel and equipment to respond to
chemical spill emergencies; Contingency plans should include remediation measures, as
appropriate.
Low Tier Construction Sub-Contractors will maintain records of all spills of hazardous
substances and hydrocarbons and will report spillages in accordance with METROPOL
İNŞAAT requirements. Low Tier Construction Sub-Contractors shall perform quarterly drills on
spill response preparedness.
METROPOL İNŞAAT shall ensure provision of environmental training for all Low Tier
Construction Sub-Contractors Personnel.
Management of prevention and response for all spills are provided in METROPOL İNŞAAT
ERP, CONTRACTOR Environmental Management Plan (10330-00-091-PD-0011).
Revision Date
15 HEALTH MANAGEMENT PLAN
Low Tier Construction Sub-Contractors shall comply with METROPOL İNŞAAT requirements
regarding health management.
15.2 Fitness to Work

METROPOL İNŞAAT shall have and ensure Low Tier Construction Sub-Contractors have, as
part of its HSEP, an effective fitness to work process for their personnel to assure they are fit
to work. The fitness to work process shall as a minimum ensure compliance with local labor
law and regulatory requirements and METROPOL İNŞAAT’s ‘Drugs and Alcohol Policies’.
METROPOL İNŞAAT shall ensure that all personnel including Low Tier Construction Sub-
Contractors prior to engagement for the performance of the work have been examined by a
medical professional and issued with a valid ‘Medical Certificate of Fitness to Work’.
METROPOL İNŞAAT shall ensure that all the Project personnel including Low Tier
Construction Sub-Contractors, fitness to work certificates are provided, verified and records
kept with the Medical Department prior to commencement of work.
METROPOL İNŞAAT shall ensure that all Low Tier Construction Sub-Contractors identify all
job tasks requiring specific evaluation of fitness to work and carry out the fitness to work
evaluations and provide and resource a health monitoring program which shall also
compliance with local regulations.
15.3 First Aid Facilities

METROPOL İNŞAAT will establish and maintain a central medical facility at the site location
and arrange provision of medical services as needed to the Project personnel. Low Tier
Construction Sub-Contractors will be responsible for the evacuation and treatment of all
employees to the nearest designated hospital.
METROPOL İNŞAAT shall be responsible to coordinate and facilitate the organization of the
medical services and ensure Low Tier Construction Sub-Contractors and employees consent
as necessary, as well as all related administration services, i.e., insurance company
notifications, family liaison, visa’s paperwork, follow-up of the medical condition, etc.
METROPOL İNŞAAT shall ensure that all employees have an adequate health insurance
according to all applicable Occupational Health and Safety Laws and Regulations, appropriate
for the health risks associated with the type and location of the work, allowing prompt and free
access to public health care facilities and medical treatment, and in the case of expatriates,
inclusive of medical evacuation and repatriation services.
Low Tier Construction Sub-Contractors are responsible for ensuring that METROPOL
İNŞAAT guidelines are followed in the establishment of the First-aid stations, equipment and
the provision of medically qualified resources. METROPOL İNŞAAT guidelines are stipulated
in METROPOL İNŞAAT ERP (PLN-ERP-PTA-004) sub section (a) Medical Emergency
Revision Date
15.4 Occupational Health and Hygiene

METROPOL İNŞAAT shall ensure all Low Tier Construction Sub-Contractors will make
arrangements for close adherence to Occupational Health Requirements and guidelines of
applicable laws and regulations, Governmental Agencies and to be in line with METROPOL
İNŞAAT standards and guidelines.
METROPOL İNŞAAT shall ensure that Low Tier Construction Sub-Contractors arrange
required qualified personnel, measurement devices and other resources, as deemed
necessary to:
• Monitor areas under its custody which includes monitoring of chemicals, physical, biological
and ergonomics hazards;
• Perform Occupational Health Risk Assessments;
• Monitor personal exposure to hazardous substances, as applicable;
• Maintain the industrial hygiene records as per law, standards and requirements;
• Provide proper training and awareness of their employees, i.e., HIV/Aids;
• Participate in occupational health audits, inspections and surveys.
Low Tier Construction Sub-Contractors will pay due regard to METROPOL İNŞAAT’s
requirements for the following while performing their work:
• Noise attenuation and vibration control,
• Exposure to thermal and other forms of electromagnetic radiation,
• Hot surfaces,
• Dust and fumes,
• Substances hazardous to health
• Blood borne pathogens.
Measures to eliminate or mitigate these will be developed as a primary control measure.

Where this is not possible/practicable, secondary measures related to personnel restrictions
will be employed e.g., through the use of PPE.
Hygiene:
Temporary facilities will be maintained in accordance with the highest standard of cleanliness
and hygiene.
In eating areas, all waste and scrap food will be discarded daily into containers placed in the
area for that purpose.
Rules of cleanliness and order will be enforced amongst all personnel working at the site.
During the Covid 19 pandemic, specific requirements for hygiene shall be implemented as per
METROPOL İNŞAAT Covid 19 Prevention and Protection Plan (PLN-CVD-PTA-002)
15.5 Water Quality and Waste Water
Mitigation:
METROPOL İNŞAAT will:
Revision Date
• Arrange their own potable water supply to site(s) and shall comply with water quality
requirements under the Turkish laws and regulations regarding drinking water quality
standards,
• Perform regular checks that there is no release of pollutants from any equipment or plant;
intervals of not more than weekly and additional servicing and routine maintenance.
• Sanitation/ablution facilities for workers, placed at worksites will include facility for treatment
of waste and/or maintained in properly designed septic tanks and ensuring wastewater
cannot be released into the lakes, canal/river or other water bodies.
• Environmental drinking water and pollutant standards shall be confirmed or updated by
METROPOL İNŞAAT and strictly maintained.
Monitoring for water quality and waste water will be performed as per METROPOL İNŞAAT’s
HSE PLAN.
15.6 Hearing Conservation Program
Those tasks and areas where noise levels could induce hearing loss shall be identified and
assessed through the HRA and reduced to ALARP. The exposure of personnel to noise shall
be kept below 80 dB(A) / limits defined in local regulations for an eight-hour noise dose.
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall ensure:
• Personal monitoring of employees working in the identified high noise areas will be done.
• Approved types of hearing protection equipment are issued to employees working in high
noise areas;
• Employees working in high noise areas are trained on use of hearing protective equipment
and the hazards on noise;
• Employees who exposure high noise (over the noise limits defined in local regulations or
over 80 dB(A) for 8 hours a day continuously must use ear plugs or ear muffs.
15.7 Hazard Communication Program

METROPOL İNŞAAT and Low Tier Construction Sub-Contractors shall ensure up to date
Safety Data Sheets (MSDS) are available at work place and accessible to all employees.
• Labelling system is applied and followed as Project standards;
• All employees are trained on MSDS, labelling systems, and handling of hazardous
chemicals.
15.8 Respiratory Protection Program

• METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors identified
respiratory hazards at workplace
• METROPOL İNŞAAT shall ensure Low Tier Construction Sub-Contractors provided
approved types of Personal Protective Equipment (PPE) to the employees.
• Covid 19 pandemic conditions shall be taken cognizance of during the project.
• Approved and appropriate masks shall be used.
• Fabric masks shall be made of three layers of fabric: Inner layer of absorbent material, such
as cotton. Middle layer of non-woven non-absorbent material, such as polypropylene. Outer
layer of non-absorbent material, such as polyester or polyester blend.
Revision Date
During construction activities if social distance con not be maintained due to nature
of the work all workers shall use proper masks for protection from Covid-19.
While working, if safe social distance (minimum 2 meters) is maintained masks may
be removed. This safe distance shall be constantly monitored by task supervisor.
When medical masks used for covid-19 protection, medical masks (also known as
surgical masks) shall be:
• Composed of 3 layers of synthetic nonwoven materials

• Configured to have filtration layers sandwiched in the middle
• Available in different thicknesses
• Have various levels of fluid-resistance and filtration
16 SOCIAL MANAGEMENT AND MONITORING MEASURES
METROPOL İNŞAAT will work in accordance with social safeguards policies of OWNER and
in accordance with the Contract and Turkish legal requirements. Starting from the pre-
construction stage until operational acceptance of the Project facility, METROPOL İNŞAAT will
be responsible for the implementation of social safeguards management, monitoring,
measurement and analysis in accordance with the Contract requirements.
Frequency of monitoring will be at minimum of once in every three (3) months/quarterly basis
and also in cases of special events. Social monitoring results will be included in the Project
HSE reports.
The following social monitoring will be executed by METROPOL İNŞAAT
16.1 Labor
i) Employment and Livelihood
Mitigation - METROPOL İNŞAAT will:
• Maximize employment of local labor for construction works.
• Provide trainings for employment.
• Provide opportunities for women to be employed.
Monitoring – will be performed in accordance with HSE PLAN and will include:
• Nos of workers, disaggregated into male and female, from local areas, other parts of Turkey
and internationally- measured per month.
• Numbers and skills of people trained.
• Records kept and reported on age ranges for each type of worker including, but not limited
to Project Manager, Engineers, skilled, semi-skilled and unskilled workers.
ii) Child Rights and Age of Labor
Mitigation - METROPOL İNŞAAT will ensure that:
• Workers will be of working age, as per Turkish labor laws.
Revision Date
• All laws requiring specific construction tasks to be carried out within an age limit under
Turkish labor laws will be strictly followed.
• Records kept and reported on age ranges for each type of worker including, but not limited
to Project Manager, Engineers, skilled, semi-skilled and unskilled workers.
16.2 Grievances and Complaints

METROPOL İNŞAAT will design and implement complaints and grievance redress procedures
and will provide a non-prejudicial grievance investigation system among its staff and Low Tier
Construction Sub-Contractors for the same, whereby the concerns of local residents and
stakeholders over potential impacts of the Project can be addressed and resolved to
satisfaction of the parties.

• Nominate a Grievance/Complaints “Focal Point” among HSE staff.
• Through the focal point, will be responsible for receiving, registering passing on and
following-up on all complaints received.
• Meet with OWNER and Engineer regularly or as required to assist management of
complaints redress.
• Register of complaints indicating names and personal details of complainant, complaint and
resolution.
• Minutes of grievance redress meeting and other records of complaints resolution
16.3 Accidents
• Enforce a strict Traffic Management Plan.
• Enforce a strict HSE Plan (Project HSE Plan) addressing requirements based on the risks
of the tasks needing to be performed on the site.
• Follow rules on the road, as per “Traffic Management Plan”, rules and health and safety
requirements.
• Record all accidents and incidents that require a response or assistance while working both
on and off-site.
• Meet with OWNER and Engineer regularly or as required to assist management of
complaints redress.
• Accident and incident reports and records.
16.4 Local Society and Labor Environment
ii) Gender
Revision Date
Mitigation – METROPOL İNŞAAT will:

• Implement a sexual harassment and anti-discrimination policy and will provide a non-
prejudicial grievance investigation system among its staff and Low Tier Construction Sub-
Contractors for the same.
• Male and female separate sleeping quarters, staff rooms (if culturally appropriate), toilets
and washing facilities will be provided as stipulated in the contact at all long-term sites
established by METROPOL İNŞAAT (office/workshops/campsites/power plant site etc.). All
facilities will be in line with acceptable standards.
Monitoring – will be performed in accordance with HSE plan and will include:
• All data collected on personnel will be disaggregated into male and female for monitoring
purposes.
17 INCENTIVE PROGRAM AND DISCIPLINARY ACTIONS
METROPOL İNŞAAT and Low Tier Construction Sub-Contractors will develop incentive
program to encourage their employees for positive implementation; minimum one employee
shall be chosen from each Low Tier Construction Sub-Contractors by the Low Tier
Construction Sub-Contractors’ Managements and the employees shall be rewarded with as
sample items below;
a) The Employee of The Month (Certificate) (employee’s picture shall be shown on all safety
bulletin boards)
b) Appreciation Certificate
c) Money awards, gifts etc.
METROPOL İNŞAAT will develop disciplinary actions to prevent HSE violations and breaking
HSE rules, applicable laws and regulations. Details of the disciplinary actions are provided in
the Project Disciplinary Procedure. The incentive program and disciplinary actions will be
communicated to all employees during the Project employee orientation and Project safety
meetings such as toolbox meetings.
The following acts are considered as Major violations:

• Insisting on disregarding HSE rules although previously warned and received trainings,
• Carrying weapons,
• Stealing or malicious mischief,
• Obtaining material, tools or equipment on fraudulent orders or by misrepresentation,
• Fighting (aggressor or defender) or attempting bodily harm to another,
• Being in a partially or completely intoxicated state, or dealing, introducing, possessing, or
using intoxicating liquor or narcotics while at site premises,
The following irregularities are also considered serious and will result in immediate and
permanent banning of an individual from site who commits them on the property, unless
mitigating circumstances justify less drastic action:
• Violation of any criminal law,
• Borrowing or lending employee identification equipment,
• Intimidation or coercion of others,
Revision Date
• Climbing any fences or attempting to enter or leave the property except through regularly
designated passageways,
• Repetition or accumulation of less serious irregularities,
• Refusal to allow inspection by authorized representative of any packages or bundles while
entering or leaving the property,
Table 3
Disciplinary actions by severity
The severity increases one level if the same employee has a prior non-compliance in the same topic or any others higher
severity non-compliance in any other topic.
Minor Significant Severe Major
Intervention with the Intervention with the Intervention with the

employee and team employee and team leader employee and team leader
leader Intervention with the employee and team
leader
Report in writing as Report in writing as per Report in writing as per
per Project Project Observation Project Observation Report in writing as per Project Observation
Observation procedure Procedure Procedure
Procedure
Written notification to the Written notification to the

offender of the non- offender of the non-
compliance with the compliance with the Denial of site access permanently
SIGNIFICANT severity severity SEVERE to the
employee and superior
Attend a refreshing training Denial of site access

session permanently
18 ATTACHMENTS
ATT-1 HSE Policy
Revision Date
Being aware of the fact that preserving and improving the environment we live in and
occupational health and safety are inseparable parts of our business, our principles are:
• to do business in accordance with the current laws, regulations and other requirements
in force for all the sectors on a national and international scale,
• to engage in protective activities in order to ensure that our employees and
subMETROPOL İNŞAATs work in a healthy and safe work atmosphere,
• to use the natural resources efficiently in conformity with sustainable development
goals,
Revision Date
ATT-2 Management Commitment Statement
Management is committed to establish Management Systems to;

• Execute all activities in compliances with the legal regulations, OWNER
Requirements, Health, Safety and Environmental Management Systems
requirements prescribed in ISO 45001.
• Incorporate with the HSE laws and regulations, as applicable to the works.
• Ensure continuity of OWNER satisfaction established by the quality of products and
services, and achieve all Environmental, Social, Occupational Health and Safety
objectives.
• Take all precautions to ensure safety and occupational health of the employees,
• Protect the environment and utilize resources in the most efficient manner.
METROPOL İNŞAAT is committed to the protection of our personnel, property, the

environment and the public throughout the country and communities in which we work.
This commitment requires us to provide the best possible services to our employees,
clients, and shareholders, and lets us compete and grow in a global marketplace.
Our Management, Supervisors, and Employees are committed to maintaining a safe and
healthy work environment that complies with all applicable legislation, industry recognized
best practices, and respects the cultures of all individuals and communities in which we
have contact with.
Our Management Team is committed to providing the capital investment and the time to
fulfil our promise to provide a safe workplace free of foreseeable hazards, which could
pose a risk to property, the environment, our employees or the public.
We recognize that our Management, Supervisors, Employees and Low Tier Construction
Sub-Contractors are all equally responsible for supporting the HSE Management System,
eliminating hazards within our facilities and on all Project sites, following all of the rules
and procedures contained in our HSE Manual or other job specific HSE Plans, and to
complying with all the laws that govern our Project area.
METROPOL İNŞAAT recognizes its responsibility to be a steward of the environment. All

levels of our organization will work towards the goal of a zero footprint with the Project.
Revision Date
METROPOL İNŞAAT takes seriously the stewardship of the environment in which we

operate and make the commitment to protect the environment and to minimize the
disturbances to the land, water, wildlife, and plant life on all Project areas.
We will collaborate with other stewards from the areas in which we are working to design
processes to identify and reduce actual or potential risks to the environment, such as the
cause of fires, spills and other damage that might result environmental damage.
Project leaders will be held accountable for accomplishing this by demonstrating correct
HSE behaviors, by clearly defining HSE roles and responsibilities, by providing the
required resources and by measuring, reviewing and continuously improving HSE
performances. Project Management Team will provide strong visible leadership and
continuously demonstrate commitment to develop, operate and maintain, review and
continually improve a Project culture, which empowers individuals to take responsibility for
their safety and embrace and accept nothing but responsible HSE behavior.
Revision Date
ATT-3 Legal Requirements
List of Health and Safety Laws
 Law No. 6331 “Occupational Health and Safety Act” (official gazette No. 28339, Date 30
June 2012) which is also supported by Law No. 4578 “Labor Act 2003”.
 Regulation on Occupational Health and Safety Risk Assessment (published in the Official
Gazette No. 28512, dated 29.12.2012)
 Occupational Health and Safety Services Regulation (published in the Official Gazette No.
28512, dated 29.12.2012)
 Regulation on Occupational Health and Safety Committees (published in the Official
Gazette No. 28532, dated 18.01.2013)
 Regulation on Suspension of Operations at Workplaces (published in the Official Gazette
No. 28603, dated 30.03.2013)
 Regulation on Health and Safety Conditions in the Use of Work Equipment (published in the
Official Gazette No. 28628, dated 25.04.2013)
 Regulation on the Protection of Employees from the Hazards of Explosive Atmospheres
(published in the Official Gazette No. 28633, dated 30.04.2013)
 Regulation on the Procedures and Principles of Training of Employees on Occupational
Health and Safety (published in the Official Gazette No. 28648, dated 15.05.2013)
 Regulation on Emergency Situations at Workplaces (published in the Official Gazette No.
28681, dated 18.06.2013)
 Regulation on the Use of Personal Protective Equipment in the Workplace (published in the
 Regulation on Vocational Training of Workers to be Employed in Jobs in Hazardous and
very Hazardous Class (published in the Official Gazette No. 28706, dated 13.07.2013)
 Regulation on Health and Safety Measures to Be Taken in Workplace Buildings and
Additional Structures (published in the Official Gazette No. 28710, dated 17.07.2013)
 Regulation on Protecting Employees from Risks Related to Noise (published in the Official
Gazette No. 28721, dated 28.07.2013)
 Regulation on Protection Employees from Vibration-Related Risks (published in the Official
Gazette No. 28743, dated 22.08.2013)
 Regulation on Health and Safety Signs (published in the Official Gazette No. 28762, dated
11.09.2013)
 Regulation on Occupational Health and Safety at Construction Works (published in the
 Regulation on Dust Control (published in the Official Gazette No. 28812, dated 05.11.2013)
Revision Date
 Regulation on Prevention of large Industrial Accidents and Reduction of their Effects

(published in the Official Gazette No. 28867, dated 30.12.2013)
 Regulation on Occupational Responsibilities and Trainings of Workplace Physicians and
other Health Personnel (published in the Official Gazette No. 29209, dated 18.12.2014)
 Regulation on duties, Powers, Responsibilities and Trainings of Occupational Safety
Experts (published in the Official Gazette No. 29342, dated 30.04.2015)
International
In addition to national legislation, the Project will follow the standards and guidelines of
financing institutions and other relevant Good International Industry Practice (GIIP) standards
including:
• Occupational Health and Safety Management System (OHSAS) ISO 18001:2014;
• International Safety Management (ISM) Code 2010.
List of Environmental Laws
 The By-Law on Environmental Impact Assessment, which came into force upon its
publication in the Official Gazette numbered. 29186 and dated November 25, 2014;
 The Regulation relating to the Waste Management, which came into force upon its
publication in the Official Gazette numbered 29314 and dated April 02, 2015;
 The Regulation relating to the Assessment and Management of Environmental Noise, which
came into force upon its publication in the Official Gazette numbered 27601 and dated June
04, 2010;
 The Regulation amending the Water Pollution Control Regulation which entered into force
after it was published in the Official Gazette dated January 10, 2016 and numbered 29589.
 The Communiqué on Wastewater Treatment / Deep Sea Outfall Facility Design Approval
came into force after its publication in the Official Gazette dated July 04, 2011 and
numbered 644;
 The Regulation amending the Control of Waste Oils Regulation which entered into force
after it was published in the Official Gazette dated November 05, 2013 and numbered
28812;
 The Regulation on the Control of Waste Vegetable Oils, which came into force after it was
published in the Official Gazette dated June 06, 2015 and numbered 29378;
 The Regulation on the Control of Medical Wastes which entered into force upon its
publication in the Official Gazette dated January 25, 2017 and numbered 29959;
 The Regulation on the Control of Packaging Wastes which came into force upon its
publication in the Official Gazette dated August 24, 2011 and numbered 28035;
Revision Date
 The Regulation on the Control of Waste Batteries and Accumulators which entered into
force upon its publication in the Official Gazette dated August 31, 2004 and numbered
25569;
 The Regulation on the Control of Construction, Demolition and Excavation Wastes which
came into force after it was published in the Official Gazette dated March 18, 2004 and
numbered 25406;
 The Regulation relating to the Control of Soil Pollution and Contaminated Sites by Point
Sources which came into force upon its publication in the Official Gazette dated June 08,
2010 and numbered 27605;
 The Regulation on the Control of Industrial Air Pollution which came into force upon its
publication in the Official Gazette dated July 03, 2009 and numbered 27277;
 The Regulation on Ambient Air Quality Assessment and Management which was published
in the Official Gazette dated June 06, 2008 and numbered 26898;
 The Regulation on the Control of Air Pollution originating from Heating which came into
force upon its publication in the Official Gazette dated January 13, 2005 and numbered
25699;
 The Regulation on the Control of Exhaust Emissions which came into force after it was
published in the Official Gazette dated November 30, 2013 and numbered 28837;
 The Regulation on the Permissions and Licenses Required to Be Obtained as per the
Environmental Law which came into force upon its publication in the Official Gazette dated
September 10, 2014 and numbered 29115 and the Regulation amending the Permissions
and Licenses Required to Be Obtained as per the Environmental Law Regulation which
entered into force after it was published in the Official Gazette dated September 21, 2016
and numbered 29834;
 The Environmental Audit Regulation which entered into force upon its publication in the
Official Gazette dated November 21, 2008 and numbered 27061;
 The Regulation on the Management of End-of-Life Tires which came into force after it was
published in the Official Gazette dated November, 25, 2006 and numbered 26357;
Nature and Wildlife:

 Law No. 2863 on the Conservation of Cultural and Natural Assets (as amended by Law No.
5226),
 Law No. 4342 on Pastures,
 Law No. 5403 on Soil Conservation and Land Use,
 The Aquatic Products Law No. 1380
 The Regulation on Aqua Products which came into force upon its publication in the Official
Gazette dated August 10, 2005 and numbered 25902;
Revision Date
 The Regulation on the Conservation of the Wetlands which came into force upon its
publication in the Official Gazette dated May 17, 2005 and numbered 25818;
 Law No. 4915 on Terrestrial Hunting.
International Treaties Recognized by Turkey

 “Biodiversity Convention” as ratified by Law No 4177 of August 29, 1996 and published in
the Official Gazette No 22860 of December 27, 1996,
 “Convention on the International Trade of Endangered Species of Wild Animals and Plants”
as published in the Official Gazette No 22672 of June 20, 1996,
 “Convention on the Protection of Wildlife and Habitats in Europe” (BERN CONVENTION)
taking effect upon its publication in the Official Gazette dated January 09, 1984 and
numbered 18318 after ratification under Cabinet Decree No 84-7601,
 Convention on the Preservation of Wetlands of International Significance Especially as the
Habitat of Water Birds” (RAMSAR Convention) as ratified by Cabinet Decree No 94/5434 of
March 15, 1994 and published Official Gazette No 21937 of May 17, 1994,
 “International Convention on the Protection of Birds” as ratified by Law No 797 of December
01, 1996 and published in the Official Gazette No 12480 of December 17, 1996,
 Convention on the Protection of World Cultural and Natural Heritage” as published in the
Official Gazette No 17959 of February 14, 1983.
Owner’s Project HSE & Social Documents
SASA-PLN-HSS-002 Traffic Management Plan
SASA-PLN-SOC-002 Grievance Mechanism Procedure (External and Internal)
SASA-PLN-HSS-001 Community Health and Safety Management Plan
SASA-PLN-HSSE-003 Training Plan
SASA-PLN-SOC-003 Human Resources Management Plan
SASA-PLN-SOC-004 CONTRACTOR Management Plan
SASA-PLN-SOC-005 Cultural Heritage Management Plan

SASA-PLN-HSSE-004 Camp Site Management Plan
Contractor’s Project HSE Documentation

Revision Date
Code Procedure Title
10330-00-091-PD-0011 CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN
10330-00-091-PD-0012 WASTE MANAGEMENT PLAN
10330-00-091-PD-0013 EMERGENCY RESPONSE PLAN
10330-00-091-PD-0015 SAFE COMMISSIONING PLAN
10330-00-091-PD-0016 PTW PROCEDURE
10330-00-091-PD-0017 WORKING AT HEIGHT PROCEDURE
10330-00-091-PD-0018 CONFINED SPACE PROCEDURE
10330-00-091-PD-0019 INCIDENT INVESTIGATION PROCEDURE
10330-00-091-PD-0020 SCAFFOLDING PROCEDURE
METROPOL İNŞAAT Project HSE Documentation
Code Procedure Title
PLN-ERP-PTA-001 SITE HSE PLAN
PLN-ERP-PTA-002 COVID-19 PREVENTION AND PROTECTION PLAN
PLN-ERP-PTA-003 TRAFFIC MANAGEMENT PLAN
PLN-ERP-PTA-004 EMERGENCY RESPONSE PLAN
ATT-4 TRAINING MATRIX
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NEW PTA COMPLEX

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SASA New PTA Complex Project

HEALTH, SAFETY & ENVIRONMENTAL (HSE) PLAN

7.5 Risk Assessments.......................................................................................................... 34

9.3.22 Night Operations....................................................................................................75

15.2 Fitness to Work.......................................................................................................... 93

ATT-4 TRAINING MATRIX...................................................................................................107

1 DEFINITIONS & ABBREVATIONS

ATEX Explosive Atmospheres

2.1 PURPOSE & SCOPE

3 HSE MANAGEMENT SYSTEM OVERVIEW

Hazard ID, Risk Assessment and Controls

Resources, Roles, Responsibility and Authority

Monitoring and measurement

Figure-1: Elements of the ISO 45001 Management Systems

ISO 45001 Management Systems are structured on a cycle of continual improvement

• Support – includes requirements for communication and documentation, as well as

3.2 Golden Rules of Safety & Life Saver Rules

Life Saver Rules:

4 POLICY, LEADERSHIP AND COMMITMENT

HSE Policy is given in Attachment-1.

Leadership and Commitment

4.1 HSE Principles / ‘Goal Zero’ Approach

• No harm to any person,

Low Tier Construction Sub-Contractors shall ensure implementation of METROPOL İNŞAAT’s

5 OBJECTIVES, TARGETS & LEGAL REQUIREMENTS

• To ensure all facilities are designed, constructed, commissioned, maintained and

5.2 Legal Requirements, Standards and Guidance

5.3 Health, Safety and Environmental Performance Targets

HSE Key Performance Indicators

10.2 Man-hours worked N/A

Table 2.0: HSE Performance Reporting Table

6 ORGANIZATION, ROLES, RESPONSIBILITIES & RESOURCES

The ratio for HSE Site officers to workers shall be as below:

Overview of METROPOL İNŞAAT’s organization (Project Management Team) roles and

6.1 Roles and Responsibilities

6.2 Project Manager

6.3 Site Manager

6.4 Discipline Managers / Engineers

6.5 Project HSE Manager

The responsibilities and accountabilities of the Project HSE Manager are:

6.6 HSE Engineer(s)

• Assist in the identification, assessment and development of control mechanisms for

6.7 HSE Inspector(s)

HSE Organization Chart

6.8 Medical Personnel

6.9 Line Supervisors (includes Supervisors, Foremen and Team Leaders)

6.10 All Project Personnel / Employees

6.11 Low Tier Construction Sub-Contractors

The Low Tier Construction Sub-Contractors has the responsibility to:

7 HAZARDS AND EFFECTS MANAGEMENT PROCESS

7.2 Hazard Identification

7.3 Construction and Completions

The process of hazard and effects management:

7.4 Initial Hazard Identification

7.5 Risk Assessments

7.6 Method Statements

7.7 Hazards & Effects Register

8 TRAINING & COMPETENCY