Environment, Health &
Safety Management Plan

§Document control

Revision history

Approval

§Contents

1Purpose & alignment with SBR

This project-specific Environment, Health & Safety (EH&S) Management Plan sets out how DTL (WA) Pty Ltd will manage EH&S for the Bitterns Recycling Field Piping Installation at the Useless Loop operation. It is submitted under SOW 7.1 for SBR review and approval prior to site mobilisation, and supplements DTL’s corporate Health, Safety & Environment Management Plan (DTL-HSE-PLN-0001).

1.1 Project-specific EH&S requirements (SOW 7.1)

In addition to SBR-PRO-0082, DTL will deliver each of the following, addressed in this Plan at the section shown:

1.2 EH&S objective

DTL is committed to a zero-harm outcome: no injury to people, no damage to SBR infrastructure, and no contamination of the sensitive crystalliser-pond environment. Higher-order controls (eliminate, substitute, isolate, engineer) are preferred over administrative controls and PPE.

2Scope & battery limits

This Plan applies to all DTL personnel, subcontractors, plant and visitors engaged on the Works — the supply and installation of the Bitterns recycling and seawater flush field piping, including HDPE butt-fusion, road crossings, tie-ins, standpipes and associated civil works.

It applies from mobilisation to demobilisation, on all areas of the SBR site to which DTL is granted access, and to all interfacing activities described in Section 9.

3Roles, responsibilities & supervision

4Pre-mobilisation personnel requirements (SOW 7.5)

Before any person mobilises to site, DTL will hold current evidence of each of the following for that person. No person mobilises without a complete record; the personnel matrix is maintained by DTL and made available to SBR on request.

5Inductions & site access (SOW 7.2)

• All DTL and subcontractor personnel complete the SBR induction (computer-based, ~2.5 hrs, completed off site) before mobilising and commencing work.
• Anyone driving a light vehicle on site completes the light-vehicle VOC (allow ~1 hr per person).
• Delivery drivers may be escorted to the worksite without induction but remain subject to Fitness for Work (Section 6).
• Site access and attendance are recorded (DTL-HSE-REG-0002 Site Access Register; DTL-HSE-FRM-0007 Sign-On).

6Fitness for work — drug & alcohol (SOW 7.4)

DTL applies its Fatigue Management (DTL-HSE-POL-0003) and Fitness for Work (DTL-HSE-POL-0007) policies, and adopts the SBR 0.00% standard as the governing requirement on site. Work hours are managed to control fatigue; supervisors monitor for signs of impairment and fatigue and stand personnel down where necessary.

7Risk management & the CRAW (SOW 7.6)

All site works and tasks are risk-assessed using JSA/JHA, Safe Work Instructions and Take 5s, following DTL’s Risk Management Procedure (DTL-HSE-PRO-0003) and the risk matrix and hierarchy of control in the corporate Plan. Controls are identified and implemented to eliminate or mitigate each hazard; task risk assessments are signed by the crew and held on the job file.

7.1 Construction Risk Assessment Workshop (CRAW)

8Hydrocarbon, contamination & waste control (SOW 7.8)

Because of the sensitive environment and the proximity to the SBR crystalliser ponds, strict controls prevent and contain hydrocarbon spills and other contamination. DTL’s hydrocarbon and contamination control procedures are provided to SBR for approval prior to mobilisation and describe managing, storage, handling, controls, prevention and clean-up.

• Spill kits maintained on site; refuelling in designated bunded areas only.
• Plant checked daily for leaks; drip trays under static plant.
• All spills and contamination, no matter how small, reported to the SBR site representative immediately.
• Chemicals registered with SDS (DTL-HSE-REG-0001); handling per DTL-HSE-PRO-0018.

8.1 Waste & wind-blown contamination

• Rubbish and waste managed so there is no risk of wind-blown contamination of the crystalliser ponds; DTL provides its own bins where necessary (DTL-HSE-PRO-0023 Waste Management).
• No glass is taken into the ponds area (per the SBR induction).

9Permits, traffic & interface management (SOW 7.1, 7.7)

9.1 Permits

DTL prepares and submits the necessary SBR permits before the relevant work begins, and applies its own permit-to-work system (DTL-HSE-PRO-0024) for high-risk activities — excavation / ground disturbance, hot works, working at heights, confined space, crane & lifting, and electrical / energised services.

9.2 Traffic management

A project Traffic Management Plan (DTL-HSE-PRO-0016) provides temporary barricading, safety signs and notices for the work areas, segregation of plant and personnel, spotters and UHF comms, and compliance with site speed limits and exclusion zones.

9.3 Interface areas (SOW 7.7)

DTL understands and manages the following interfaces, with planned traffic movements past the pipeline installation area:

• SBR electricians — isolation, instrumentation and control works.
• Project civil construction works.
• SBR and other contractors accessing the flume / pond areas via shared access and haul roads adjacent to the construction site.

10Emergency & environmental management

Site emergency arrangements, assembly points and wardens are established before work starts; first aid and emergency equipment are provided and maintained; drills are conducted and reviewed. DTL follows its Emergency Response Plan (DTL-HSE-PRO-0006) and Emergency Management Procedure (DTL-HSE-PRO-0020), aligned to SBR’s site emergency arrangements.

• Emergency contacts and nearest medical facility confirmed at induction and displayed on site.
• Environmental controls: spill response, dust suppression as required, and protection of client infrastructure (e.g. pond liners).
• Waste segregated and disposed of lawfully; records kept in 2iB.

11Consultation, communication & reporting (SOW 7.9)

• Kick-off meeting with SBR before works commence.
• Daily pre-starts documented and forwarded to the SBR representative (DTL-HSE-FRM-0006).
• Daily site meetings and discussions with SBR as required.
• Weekly progress meetings with SBR stakeholders once site works commence — actual vs planned progress, next-week plan, HSE concerns and any other issues.
• Toolbox talks and worker consultation recorded (DTL-HSE-FRM-0004, FRM-0008); H&S consultation per DTL-HSE-PRO-0009.

12Monitoring, audit & review

• Site safety inspections and plant pre-starts conducted and recorded (DTL-HSE-CHK-0001, CHK-0002).
• Incidents and near-misses reported and investigated (DTL-HSE-PRO-0005; FRM-0001, FRM-0002); corrective actions tracked to closure (DTL-HSE-REG-0009).
• HSE objectives and targets set and reviewed; this Plan reviewed at planned intervals and on change (DTL-HSE-PRO-0017 Quarterly Self-Evaluation).

13Supporting DTL system documents

This Plan draws on DTL’s controlled EH&S management system. Key supporting documents: