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McKeil Marine Limited Health and Safety Manual

Supplement to the Quality and Safety Management System

Edition 2, Revision 3

Issued: June 1, 2013

McKeil Marine Limited

Health and Safety Manual

Supplement to the QSMS Edition 2, Revision 3

Date: June 1, 2013

Record of Amendments

Record of Amendments

Revision Date Section and Title Description of Change VP Compliance Manager

Ed 2, Rev 1

Jan 2, 2013

QSMS Edition 2, Revision 1 Issued

Ed 2, Rev 2

Feb 10, 2013

11.0 - Violence in the Workplace Policy

“Violence in the Workplace Policy” to become “Harassment and Violence in the Workplace”

Ed 2, Rev 3

June 1, 2013

2.1 - General Safety Policies Clothing Policy Modified

Ed 2, Rev 3

June 1, 2013

3.5 - Eye Protection Eye Protection Policy Modified to include more tasks

Ed 2, Rev 3

June 1, 2013

3.11 – Personal Floatation Devices

Vessel Equipment Policy Requirements Modified for iPFD implementation

Ed 2, Rev 3

June 1, 2013

4.2 – Shore Based Health and Safety Committee

Shore Based Health and Safety Committee & Safety Representative added

Ed 2, Rev 3

June 1, 2013

15.0 – Job Safety Analysis Job Safety Analysis Section Added

Ed 2, Rev 3

June 1, 2013

16.0 – Tool Box Meeting Tool Box Meeting Section Added




Date: June 1, 2013

Table of Contents

Table of Contents Title Page

1.0 Objective..................................................................................................................... 1

2.0 Safety Rules................................................................................................................ 2 2.1 General safety Rules 2 2.2 Deck Safety Rules 3 2.3 Engine Room Safety Rules 4 2.4 Galley Safety Rules 4 2.5 Safety Rule Familiarization 4

3.0 Personal Protective Equipment................................................................................ 5 3.1 Personal Protective Equipment Policy 5 3.2 Project Personal Protective Equipment Requirements 5 3.3 Footwear 5 3.4 Head Protection 5 3.5 Eye Protection 5 3.6 Face Protection 6 3.7 Ear Protection 6 3.8 Hand Protection 6 3.9 Respirators 6 3.10 Safety Belts and Harnesses 6 3.11 Personal Floatation Devices 7 3.12 Reflective Vests 7

4.0 Health and Safety Committee.................................................................................... 8 4.1 Shipboard Health and Safety Committee 8 4.2 Shore Based Health and Safety Committee & Safety Representative 8

5.0 Drug and Alcohol Policy............................................................................................ 9 5.1 Drug and Alcohol Policy 9 5.2 Posting and Notification 9 5.3 Drug and Alcohol Policy Violations 10

6.0 No Smoking Policy..................................................................................................... 11

7.0 Hours of Work/Rest.................................................................................................... 12 7.1 Hours of Work and Rest Policy 12 7.2 Daily Hours of Work Record 12

8.0 Hazardous Material Handling.................................................................................... 13 8.1 The Workplace Hazardous Material Information System (WHMIS) 13 8.2 Material Safety Data Sheet 14 8.3 Responsibilities 15

9.0 First Aid Supplies and Equipment............................................................................ 17 9.1 Minimum First Aid Supplies 17 9.2 Eyewash Stations 17




Date: June 1, 2013

Table of Contents

10.0 Galley, Housekeeping and Sanitation...................................................................... 18

11.0 Violence in the Workplace......................................................................................... 20 14.1 Violence in the Workplace Policy Statement 20

12.0 Landing Booms, Gangways and Ladders................................................................ 24 12.1 Landing Booms 24 12.2 Portable Ladders 24 12.3 Stages 25 12.4 Gangways 25

13.0 Hazard Analysis.......................................................................................................... 26 13.1 What is Hazard Analysis? 26 13.2 Hazard Analysis Checklist 27 13.3 Risk Assessment for Tug and Barge Fleet 27

14.0 Work Permit System.................................................................................................. 31 14.1 General 31 14.2 Confined Space Policy 31 14.3 Hot Work Policy 33 14.4 Lock Out Tag Out 35

15.0 Job Safety Analysis 37 15.1 Introduction to Job Safety Analysis 37 15.2 What is a Job Safety Analysis 37 15.3 Use of Job Safety Analysis 37 15.4 How to Complete a Job Safety Analysis 37 15.5 Tips for Selcting the Job to be Analyzed 37 15.6 Tips for Breaking the Job into Basic Steps 37 15.7 Tips for Identifying Potential Hazards 38 15.8 Tips for Identifying Preventive Measures 38 15.9 McKeil Marine Limited’s Job Safety Analysis Program 38 15.10 Job Safety Analysis Documentation 38

16.0 Tool Box Meeting 39 16.1 Tool Box Meeting Description 39 16.2 Tool Box Meeting Requirements 39 16.3 Tool Box Meeting Documentation 39

15.0 Contractors Working Onboard.................................................................................. 40 15.1 Definitions 40 15.2 Governing Laws and Regulations 40 15.3 Duties and Responsibilities 41 15.4 Safety Practices 42 15.5 Permit System 45 15.6 Contractor Incident Reporting 45 15.7 Smoking, Alcohol and Controlled Substances 45




Date: June 1, 2013

Section 1: Objective Page 1 of 46

1.0 Objective

1.0 Purpose The objective of this manual is to provide McKeil Marine Limited Seafarer’s with a set of policies and procedures regarding health and safety to be carried out onboard company vessels. These policies and procedures are designed to meet and exceed the regulations that apply to the marine transportation industry. McKeil Marine Limited is committed to adhering to and exceeding the requirements of all health and safety regulations. The majorities of health and safety regulations governing the marine transportation industry are found in the Maritime Occupational Health and Safety Regulations (MOHS). Considering the scope and depth of the topics covered in the MOSH regulations, McKeil Marine Limited has made an effort not to simply recreate the MOHS regulations in this manual. In fact, many topics addressed by the MOHS are quite specific in their requirements. This manual addresses the topics covered in the MOHS that require company’s to develop policies and procedures. A copy of the Maritime Occupational Health and Safety Act shall be made available to all crew members. When new revisions are released, new editions shall be sent to the vessels. A copy of McKeil Marine Limited’s Health and Safety manual shall be made available to all crew members.




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Section 2: Safety Rules Page 2 of 46

2.0 Safety Rules

2.0 Purpose The purpose of this section is to define and document McKeil Marine Limited’s Safety Rules. The following are safety rules, designed to help mitigate the numerous hazards associated with operating vessels. It should be noted that safety rules listed in other sections of the Health and Safety Manual (ie PPE requirements) are not included in the list below. 2.1 General Safety Policies Employees shall only use equipment they have been properly trained on. Follow instructions on all warning signs. All injuries, accidents or illnesses, no matter how minor should be reported immediately to the ship’s officer on watch (refer to incident reporting section). Report immediately any unsafe condition(s) to ship’s officer on watch. Portholes are to be secured at sea and dead lights are to be secured in bad weather. Secure all equipment and loose gear in heavy weather. Know the potential dangers of your job. Be aware of what is happening around you, at all times. Immediately after joining the ship, learn the location of the emergency exits, life saving and fire fighting equipment, fire alarm pulls, muster points and other emergency equipment of your ship. Do not sit on railing or bulwarks. Do not stand under loads being lowered or raised - stand clear. When lifting, always bend your knees, keep your back straight and let the leg muscles do the work. Avoid running on deck or in the accommodation, jumping over door sills or down stairways. Potential hazards such as beams and corners can cause serious head, knee or shin injuries. Loose clothing shall not be worn around machinery. Wearing shorts while working is prohibited Rings and loose necklaces are potential hazards and it is recommended that they not be worn while on duty. Long hair shall be tied back and secured when in all working conditions. Access to fixed ladders, electrical switches, fire fighting, life saving equipment shall be kept clear at all times; Use only those cleaning solvents authorized for the job.

Always work within the safe working load of cranes, block, tackles, ropes, wires etc.




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2.2 Deck Safety Rules

Only crewmembers trained and authorized by the officer on watch, in the operation of deck equipment (winches, deck crane, windlass etc.) shall operate such equipment.

Never step over a line or cable under tension or that could come suddenly under tension.

When handling mooring lines never place your arm through the eye of the cable.

Stand-by at a safe distance from all running wires.

Operators of the equipment shall ensure warning devices, if fitted, are functioning as designed. Under no circumstances shall a person be made or allowed to work over the ship’s side while vessel is underway.

Mooring Winches

While using the winch, employees shall wear the appropriate protective equipment (i.e. leather palm

gloves, safety shoes, hard hats, safety glasses). The wearing of shorts while working with a winch or

its wire is prohibited.

The person in charge of operating the winch shall pay close attention to the safety of personnel handling the wires, and shall operate the winch and its wire such that the operation is safe. Stepping into the eye of the wire, stepping on running wire or stepping over a wire under tension shall be avoided, at all times.

The person operating the winch while docking, undocking or canalling shall pay particular attention to the safety of personnel handling the mooring wires on shore.

Windlass

Only persons trained in the use of the windlass shall operate the same. The deck officers shall train their

respective ordinary seamen on watch and wheelsman, in the operation of the windlass.

When operating the windlass, hard hats, work gloves, foot protection and eye protection shall be worn.

Heavy Equipment (Fork lifts, Front end loaders etc.) Most heavy equipment is designed to be operated by one person at a time. Only persons that are trained in their use shall operate such equipment. A person shall be designated to signal directions to the operator. Each piece of heavy equipment shall have a minimum if one 5 lbs. ABC rated fire extinguisher. The following care shall be taken when operating such equipment:

a) Put on the seat belt (if equipped). b) The operator shall ensure the path is clear before backing the equipment. c) The bucket, blade or fork shall be left in the lowered position, when not in use. d) When refuelling equipment, ensure the equipment has been switched off. e) Compressed gas cylinders shall not be carried in the bucket of forks. f) Employees are not to jump on and off the equipment. Instead they shall face the equipment

and use the hand and foot holds provided.




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2.3 Engine Room Safety Rules

Do not secure blocks or hoists to pipes or gratings. Secure them to solid structure.

When not in use, chains shall be secured.

Damaged or broken tools shall be appropriately tagged and taken out of service. These shall either be repaired if possible or got rid of. Safety guards, hand rails, gratings if removed for work, shall have the area roped off with an appropriate sign(s) attached to it.

Floor plates, ladders and gratings shall be kept clean and free from oil and grease.

2.4 Galley Safety Rules

Galley personnel shall maintain a high level of personal hygiene. Hands shall be washed frequently during the day and each time before handling food. The chief cook shall ensure that all areas under his/her responsibility are kept clean and tidy. Galley personnel shall ensure they have been trained in the equipment they are to use in the galley. Repairs to galley equipment shall be carried out by authorized persons only. The chief cook shall test all refrigerator alarms (audio and visual), at least once every two weeks and record the same. Any defects shall be brought to the attention of the chief engineer as soon as possible to rectify. Store knives in the knife rack provided. Store supplies properly to prevent shifting in heavy seas. Wipe up spilled grease, oils and water within your area of responsibility, immediately.

2.5 Safety Rule Familiarization

Familiarization with safety rules is facilitated through crew familiarization training. Crew members should

be familiar with all company safety rules and policies, regardless of their department.




Date: June 1, 2013

Section 3: Personal Protective Equipment Page 5 of 46

3.0 Personal Protective Equipment

3.0 Purpose The purpose of this section is to define and document McKeil Marine Limited’s Personal Protective Equipment requirements. Every activity on board warrants some protection for the employee. This section shall attempt to spell out which protective equipment is required and when, bearing in mind that this list is not exhaustive as it is not possible to cover unforeseen circumstances. 3.1 Personal Protective Equipment Policy Personal protective equipment shall be worn when working or as required. Proper care of safety equipment is the responsibility of each individual. Defective Personal Protective Equipment must be reported immediately and removed from service 3.2 Project Requirements McKeil Marine Limited is often engaged in projects where PPE requirements are set that exceed our standards, in such cases, the overall site PPE requirements shall be adhered to. 3.3 Footwear All safety footwear shall be CSA approved.

Location Foot Wear Protection Required

Wheel house Non-skid shoes (could be casual or dress style)

Deck Work boots, steel toe, puncture resistant soles with metatarsal protection (ankle high). Rubber boots: steel toes.

Galley Steel toes and non-skid shoes (could be casual style)

Engine room Work boots, steel toes, slip resistant soles

3.4 Head Protection Hard hats shall be worn at all times when overhead work is being carried out or when there is a possibility of being struck by falling objects. They shall be worn with the beak over the face (not backwards). Damaged hard hats shall be taken out of service and destroyed. Head protection shall be worn under the following designated situations:

During all loading and unloading operations;

Working in cargo areas;

Hoisting or lowering stores and materials;

Canalling

Handling mooring lines and winches;

At all dry docks.

The engine room is a designated area requiring the use of hard hats or bump caps during fit-out, lay-up and at all times when overhead work is being carried out; 3.5 Eye Protection Eye protection shall be worn whenever a risk of eye injury exists from physical, chemical or radioactive material. Eye protection includes CSA approved goggles, shields, safety glasses or other suitable eye protection equipment. Operations that require the wearing of eye protection include but not limited to:

When using portable or fixed tools (e.g. grinder, lathe, drill etc.).

When using needle guns, scraping, chipping, wire brushing.

When operating rope capstans




Date: June 1, 2013


When operating the tow winch

When operating the tugger winch

When working dusty cargoes.

When operating anchor windlass.

When welding, cutting, burning or using any spark producing equipment.

When using chemicals..

When handling chemicals.

Whenever deemed necessary. 3.6 Face Protection Certain operations require the use of a face shield to be used by itself or in conjunction with safety glasses. Face shields shall be worn when full-face protection is required from sparks from welding and grinding 3.7 Ear Protection Hearing protection shall be worn when employees are exposed to detrimental noise levels, over a period of time. All personnel entering or working in the engine room shall wear approved hearing protection. Hearing protection may be in the form of earmuffs or earplugs, as appropriate. 3.8 Hand Protection It is essential that work gloves be considered as an important part of a seaman’s working gear and shall be used under the following circumstances but not be restricted to:

Handling wires and ropes;

Welding and burning;

Handling chemicals. 3.9 Respirators Where concentrations of dust or vapour exist, appropriate types of respirators shall be used. Personnel using respirators shall be test fitted by a qualified individual. Respirators shall be used but not limited to, the following circumstances:

Spray painting;

Spray cleaning with solvents;

Working in boilers;

Loading or discharging dusty cargoes. 3.10 Safety Belts and Harnesses Safety harnesses shall be worn every time when entering or leaving a cargo hold; Safety harnesses/belts shall be worn when working at heights exceeding 5 feet and where a danger of falling exists. The lanyard used shall be no more than 4 feet. The lanyard shall be securely attached to a fixed support, capable of withstanding the individual’s weight, in case of a fall. Safety belts/harnesses and lanyards shall be inspected every time before being used. If found defective (cuts, broken buckle etc.), it shall be taken out of service and replaced.




Date: June 1, 2013


3.11 Personal Floatation Devices (PFD) PFDs shall be worn every time under the following circumstances:

When involved in mooring operations (aboard and on dock);

When being lowered on a landing boom.

When working from a punt/scow/raft etc.

On an unmanned barge at all times and when going between tug & barge.

Notching up or going on a towline. Vessels shall be equipped with enough traditional PFD for the deck crew’s complement in addition to the iPFD’s issued to individuals in order to be used by new employees, visiting shore personnel and in the event of an iPFD not being available. 3.12 Reflective Vests Reflective vests shall be worn when working around material handling equipment (fork lifts, loaders etc.)




Date: June 1, 2013

Section 4: Health and Safety Committee Page 8 of 46

4.0 Health and Safety Committee

4.0 Purpose The purpose of this section is to define and document McKeil Marine Limited’s requirements for on board health and safety committees. 4.1 Shipboard Health and Safety Committee

The Captain will ensure that the vessel “Health & Safety Committee” meets on a monthly basis. All

personnel (less personnel on watch) onboard will attend this meeting and a copy of the minutes will be

sent to the Vessel’s Manager

The “Agenda” topics that must be discussed are:

Discuss Minutes of the last meeting and Company’s reply.

Review the Health & Safety Representatives’ records.

Discuss accidents occurring on-board since the last meeting.

Discuss “Incidents”, “Hazardous Occurrences” occurring on-board since the last meeting.

Safety and pollution prevention.

Discuss environmental hazards, if any.

Discuss safety equipment and its status. Any defects found shall be rectified as soon as possible.

Review the “Quality and Safety Management System” and submit constructive comments for improvement, if any.

Review of the Company’s Health and Safety Policies.

Review and record training carried out on-board.

Any other business related to Safety.

Minutes will be taken of the Meeting following the using Form S004 Health and Safety Meeting Report

and sent to Vessel’s Manager. The Vessel Manager shall review and forward the same to the

Compliance Manager. The Captain shall retain a copy on the vessel for the duration of the season and

office shall retain on file for 5 years.

4.2 Shore Based Health and Safety Committee & Safety Representative McKeil Marine Limited has developed and implemented a Health and Safety Committee for its 208 Hillyard Street in accordance with the requirements of Canadian Labour Code part II. A Safety Representative has been established for the Hamilton Warehouse.




Date: June 1, 2013

Section 5: Drug and Alcohol Policy Page 9 of 46

5.0 Drug and Alcohol Policy

5.0 Purpose The purpose of this section is to define and document McKeil Marine Limited’s drug and alcohol policy. 5.1 Drug and Alcohol Policy

MCKEIL MARINE LIMITED

DRUG AND ALCOHOL POLICY

McKeil Marine Limited recognizes that the use of alcohol and illegal substances is at-risk behaviour and a detriment to good health. Employees who partake in this behaviour could have a negative impact on the remaining vessel complement and vessel activities. Acknowledging the above the Company maintains zero tolerance to at-risk behaviour related to the abuse of alcohol and/or controlled substances. The Company is obligated to take action to ensure that consumption of any substance does not put the vessel complement and/or operation at risk. Vessel personnel, contractors, guests and persons boarding the vessel must be aware that:

No crewmember, contractor or guest may return to, or be on board the vessel while under the influence of alcohol or drugs.

Possession of alcohol and drugs is prohibited onboard the vessel at any time. For the avoidance of doubt this includes all periods when the vessel is operational or inactive. The definition of inactive includes any period when the vessel is idle awaiting orders or laid-up and specifically includes the entire winter lay-up. The Master or senior most person onboard is to apply company standards with regard to these policies. Officers and crew returning to the vessel from any shore leave must be in a sober condition and free from the influence of drugs and/or alcohol, as part of the Company’s zero tolerance policy. Certain countries insist that seamen be tested for impairment. McKeil Marine Limited is obliged by law to recognize testing and /or impairment performance indicators and will employ the use of each as permitted appropriately by law. The Company will provide assistance for employees who recognize that their activities related to alcohol, legal and /or illegal substances have affected their lives in a negative manner. The vessel’s Master, via the Company, will arrange this assistance once any employee requests it. All the office and shipboard personnel are required to support and contribute to the effective implementation of the Company policies.

Mr. Steve Fletcher

5.2 Posting and Notification The Drug and Alcohol Policy shall be posted on all vessels in a prominent matter. All seafarer’s shall be made aware of the policy during ship board familiarization tours.




Date: June 1, 2013

Section 5: Drug and Alcohol Policy Page 10 of 46

5.3 Drug and Alcohol Policy Violations Seafarer’s found to be in violation of the Drug and Alcohol policy will be disciplined immediately. Disciplinary action may include suspension from work, loss of bonus and or termination. Incidents where the Drug and Alcohol policy is violated shall be examined on a case by case basis by the Operations management team.




Date: June 1, 2013

Section 6: Smoking Policy Page 11 of 46

6.0 No Smoking Policy

6.0 Purpose The purpose of this section is to define and document McKeil Marine Limited’s No Smoking Policy. The Federal government has in place non-smoker’s health regulations. Due to known ill effects of smoking and second hand smoke, McKeil Marine Limited has implemented a companywide non-smoking policy. A copy of the Smoking is not permitted on the interior of McKeil Marine Limited’s vessels. This includes all cabins, the wheelhouse, engine room, personal cabins, the galley and any recreation rooms. Smoking is permitted on the vessels exterior decks. While bunkering, smoking is not permitted on the vessels exterior decks, including the deck of the barge. Copies of the Federal Non-Smoker’s Health Act and Non-Smoker’s Health Regulations can be found on the Reference Document menu.




Date: June 1, 2013

Section 7: Hours of Work and Rest Page 12 of 46

7.0 Hours of Work and Rest

7.0 Purpose The purpose of this section is to define and document McKeil Marine Limited’s policy regarding hours of work and rest. 7.1 Hours of Work and Rest Policy McKeil Marine Limited shall follow the guidelines regarding crew member’s hours of work and rest as set out by the Marine Personnel Regulations. Rest/Fatigue Every Master and Seaman has a personal duty to be properly rested when commencing duty, particularly before watch at sea and in port and to obtain adequate resting during allocated rest periods. Hours of Work Officers and crew members must not work more hours than is safe in relation to the vessel and the performance of duties. This applies to every crew member that has duties involved with the safe operation of the ship and or the safe evacuation of crew in an emergency. Hours of Rest The Canadian Marine Personnel Regulations section 319 to 323 requires that each crew member be provided with a minimum of six consecutive hours of rest in any 24 hour period and at least 16 hours of rest in every 48 hour period A copy of the Marine Personnel Regulations can be found in the reference section of the QSM.

7.2 Daily Hours of Work Record

Every crew member shall record their hours of work and rest on Form: D215. A copy of this form shall be

provided to each crew member upon joining the vessel and at the beginning of each month. Daily Hours

of Work forms shall be kept on board the vessel during the crew member’s engagement and discarded

after their discharged.




Date: June 1, 2013

Section 8: Hazardous Material Handling Page 13 of 46

8.0 Hazardous Material Handling

8.0 Purpose The purpose of this section is to define and document McKeil Marine Limited’s requirements for handling hazardous materials on board. Including the Work Place Hazardous Material Handling System (WHMIS) 8.1 The Workplace Hazardous Materials Information System (WHMIS) The workplace Hazardous Materials Information System is a Canada wide system to provide employers and workers with information about the hazardous materials they work with on the job. WHMIS gives everyone in the workplace the right to know about the hazards they work with and it does this by means of:

Material Safety Data Sheets (MSDS)

Supplier/Workplace labels.

Worker training. WHMIS was set up with three objectives in mind:

To identify hazards in the workplace.

To provide information about hazardous materials.

To ensure consistency of information about hazardous materials in all Canadian workplaces.

To achieve these three goals, WHMIS set up the information delivery system that is comprised of three key elements:

Labels.

Material Safety Data Sheets (MSDS).

Worker education.

Labels Under WHMIS Legislation there are four kinds of labels; supplier label, workplace label, laboratory sample label and the laboratory supply house label. Only products with supplier labels and workplace labels are found on McKeil Marine Limited vessels.

Supplier label This type of label that is found most frequently in the workplace is the full information label that applies to all containers of controlled products in excess of 100 ml. The required contents of the label are as follows:

1. Product Identifier

Common name, trade name, generic name etc. 2. Supplier Identifier

Name of supplier. 3. MSDS Statement

See Material Safety Data Sheet. 4. Hazard Symbol

One or more of the eight hazard symbols and must be exact reproductions except for size and colour.

5. Risk Phrases

Description of effects that may result from exposure. 6. Precautionary Measures

Measures to avoid the risk(s) with the product. 7. First Aid Measures

Treatment to give for the type of exposure to the product. Containers that contain less than 100 ml. of a controlled product, the labelling requirements are slightly different than the full label.

1. Product Identifier.




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2. Supplier Identifier. 3. MSDS Statement. 4. Hazardous symbol.

The supplier label has certain design requirements that must be met and are as follows:

The label must convey the information in both English and French.

The label must have a border with the slant and shape of the marks being the same with only the size and spacing that can be varied.

The required information can be located anywhere within the WHMIS border.

There is no minimum or maximum size for the supplier label as long as the label is easily legible.

The border must be in a colour that contrasts with the container. Workplace label The workplace label is a label that the employer produces for the workplace. The workplace label is used instead of a supplier label under the following circumstances:

Materials that are produced in the workplace for the workplace.

Material that is decanted from the original container into a workplace container.

The original supplier label has been removed or is illegible. Workplace labels requires the following contents:

Product identifier.

Precautionary measures.

Statement that a MSDS is available.

The workplace label has no standard format that must be followed other than the content requirement.

8.2 Material Safety Data Sheets Material Safety Data Sheets are required for all hazardous materials in the workplace except for the following:

If the controlled product is exempt from WHMIS regulation.

Laboratory sample in a quantity of less than 10 kg and has the required label.

Laboratory supply house product used for the laboratory in a quantity less than 10 kg and has the required label.

The Material Safety Data Sheet contains detailed information on the product for which it describes. The exact layout of the Material Safety Data Sheet is not specific, however, there are nine categories of information that must be found on the MSDS:

Hazardous ingredients.

Preparation information.

Product information.

Physical data.

Fire or explosion hazard.

Toxicological properties.

Preventive measures.

First side measures.

From these nine categories there are about 60 specific items of information which must be included, if available and applicable.

Material Safety Data Sheets must be updated every three years or when new information comes available.

They are to be readily available to workers.




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Supplier MSDS must be available in both French and English at the time of sale.

There must be a MSDS for every controlled product before it can be used.

If there is no MSDS, report this to your supervisor.

Employee Education Employee education programs are used to educate employees on how to properly use labels and Material Safety Data Sheets, to protect themselves from hazardous materials. It is the employers’ responsibility to supply the training, and the employees’ responsibility to participate in the training. Ingredient Disclosure List This list was established to be used by suppliers to assist them when preparing Material Safety Data Sheets. If the product containers a listed ingredient in a concentration at or above the level listed, then it must be named on the Material Safety Data Sheet with its percentage of concentration in the product. Excluded Materials The following is a list of hazardous materials that are excluded from the WHMIS regulation with regard to labels and Material Safety Data Sheets because they are regulated by other laws within Canada:

1. An explosive within the meaning of the Explosives Act. 2. A cosmetic device, drug or food within the meaning of the Food and Drug Act. 3. A control product within the meaning of the Pest Control Products Act. 4. A product, material or substance packaged as a consumer product and in quantities normally

used by the consuming public. The following are controlled products that are not covered by WHMIS legislation:

1. Wood or a product made of wood. 2. Tobacco or a product made of tobacco. 3. A manufactured article. 4. A controlled product being transported or handled in accordance with the requirements of the

Transportation of Dangerous Goods Act or the Transportation of Dangerous Goods Act (Canada). 5. Hazardous waste - except to the extent that an employer shall ensure safe storage and handling

of hazardous waste generated at a workplace. This will include identification of the hazardous waste and work training/education for the hazardous waste.

8.3 Responsibilities Under the WHMIS Regulation there are three distinct groups with certain obligations. SUPPLIER shall:

Determine which hazardous materials intended for use in the workplace are controlled products.

Label all controlled products as a condition of sale.

Provide MSDS for controlled products as a condition of sale.

EMPLOYER shall:

Ensure controlled products are appropriately labelled.

Ensure a controlled product received from a supplier has a label.

A proper supplier label is shown.

Ensure labels are not removed or altered.

Ensure decanted controlled products are labelled.

Obtain Material Safety Data Sheets for controlled products.

Ensure that a MSDS is obtained before or on the date of delivery for a controlled product.

Update MSDS every three years or when new information is known.

Provide employee access to MSDS.




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Educate workers.

The employer has a general duty to educate workers who are working with, or around a controlled product.

WORKER shall:

Worker must participate in training programs and apply that knowledge and common sense to their daily jobs.

Hazardous Classification A controlled product is any product that can be included in and of the following six classes: Class A Compressed gases.

Class B Flammable and combustible material. Class C Oxidizing material. Class D Poisonous and infectious material. Class E Corrosive material. Class F Dangerously reactive material.




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Section 9: First Aid Supplies and Equipment Page 17 of 46

9.0 First Aid Supplies and Equipment

9.0 Purpose The purpose of this section is to define and document the first aid supplies carried on board McKeil Marine Limited’s fleet. The Maritime Occupational Health and Safety regulations acts as the guideline for first aid materials carried on board. 9.1 Minimum Supplies McKeil Marine Limited shall supply its vessels with, at least the first aid supplies that meet the requirements of the Maritime Occupational Health and Safety Regulations Section 114.

Item Supplies and Equipment Quantity per Type of First Aid Kit

Vessel Compliment Consists of: 2 – 5 Crew

Members

6 – 19 Crew

Members

1. Antiseptic-wound solution, 60 mL or antiseptic swabs (10-pack) 1 2

2. Applicator-disposable (10-pack) [not needed if antiseptic swabs used]

1 2

3. Bag-disposable, waterproof, emesis 1 2

4. Bandage-adhesive strips 12 100

5. Gauze, Roll 2.5 cm × 10 m 2 6

6. Bandage-triangular-100 cm folded and 2 pins 2 4

7. Container-First Aid Kit 1 1

8. Dressing-compress, sterile 7.5 cm × 12 cm approximately 2 4

9. Dressing-gauze, sterile 10.4 cm × 10.4 cm approximately 4 8

10. Forceps-splinter 1 1

11. Manual-First Aid, English — current edition 1 1

12. Manual-First Aid, French –– current edition 1 1

13. Pad with shield or tape for eye 1 1

14. Record-First Aid (section 119) 1 1

15. Scissors — 10 cm 1 1

16. Tape-adhesive, surgical 1.2 cm × 4.6 m (not needed if ties attached to dressings)

1 1

17. Penlight – –

18. Antipruritic lotion 30 ml or swabs (10 packs) 1 1

19. Bandage-elastic 7.5 cm × 5 m – –

20. Blanket-emergency, pocket size – –

21. Dressing-burn, sterile, 10 cm × 10 cm 1 1

22. Dressing-burn, sterile, 20 cm × 20 cm – –

23. Hand cleanser or cleaning towelettes, 1 pack 1 1

24. Malleable splint set with padding – 1

25. Stretcher – –

26. Gloves, disposable examination non-latex (pr) 5 10

27. Mask, barrier device for mouth to mouth resuscitation 1 1

28. Tongue depressor, disposable 5 5

9.2 Eyewash Stations A portable eye wash station shall be provided on all McKeil tugs in conspicuous locations where there is a risk of eye injury (ie Engine Room, vicinity of tow winch). Eyewash fluid shall be checked regularly by the ships safety officer.




Date: June 1, 2013

Section 10: Galley and Housekeeping Page 18 of 46

10.0 Galley, Housekeeping and Sanitation

10.0 Purpose The purpose of this section is to define and document McKeil Marine Limited’s policies regarding galley standards and housekeeping. Galley Management Management at McKeil Marine expect the galley to be operated efficiently (within budget) in cost and effectively in crew satisfaction. The Chief Cook is responsible to the Master of the vessel (to the Chief Engineer, in the absence of the Master). Personal Health and Hygiene The cleanliness, health and habits of the cook is important because people frequently become carriers for decease organisms that are so readily spread through food. These organisms are frequently present on our hands, face hair and in our mouths, noses and intestinal tracts. Dishes, utensils and food will be easily contaminated by employees' hands and clothing, unless a high standard of personal hygiene is maintained.

It is important that all persons in the galley department are free from communicable disease. To this end, all galley personnel must have a valid medical certificate during the entire time of their stay on board. Any galley personnel who has any infectious disease, or infected cuts or sores, will not be permitted to perform their duties on board.

It is required that, when a person is diagnosed by a physician as suffering from a communicable disease, it be reported to the office right away. The office will contact the health department for further details to assist the employee return to work as soon as it is safe to do so.

Tools such as ladles, spoons, tongs, scoops etc. shall be used instead of hands wherever possible. For complete personal cleanliness, a daily bath or shower, the use of a deodorant or antiperspirant and the avoidance of pungent offensive perfumes are desirable.

Hands and arms shall be washes prior to starting work, and as frequently during the work period as is necessitated by handling objects or surfaces that could contaminate food. Hands shall be washed before returning to work after using the toilet facilities, after a meal break, after a smoking break, after coughing or sneezing, after handling raw food and after handling money. Hair and beards shall be clean and suitably controlled or covered. House Keeping and General Maintenance Chief Cook shall fill out the Form: G002 Galley Inspection Log weekly and maintain a record available to all crew for the duration of the sailing season. It is essential that food service equipment be maintained on a regular basis, not only for sanitary reasons but also to remain efficient. All areas within the galley and storerooms shall be kept neat, visibly clean and free from litter and rubbish. Waste materials shall be stored in sealed containers or garbage bags and disposed off in garbage trucks.

Food products must be stored in designated food storage areas only.

Floors shall be cleaned after every meal, more often if necessary. Mops, brushes and brooms shall be stored separately from food preparation and storage areas in a place that is well ventilated; they should be hung to keep them above floor level.




Date: June 1, 2013

Section 10: Galley and Housekeeping Page 19 of 46

Normal floor and wall cleaning shall not be carried out during food preparation and serving periods. All tables, counter tops and work surfaces should be frequently. Cleaned and sanitized Exhaust hoods, grease filters, ductwork, grills and ranges are fire hazards and should be cleaned regularly. Storage of cleaners, poisonous substances and materials Many products commonly used in a galley are poisonous, if consumed. To prevent accidental consumption of the above:

1) They shall be stored in their designated areas, clearly marked for cleaning and sanitizing. They shall

never be stored with food supplies.

2) All such products shall be in the original containers as purchased. If opened, they shall be tightly capped. Such products shall always be distinctly marked and labeled with their hazardous rating if transferred to another container.

3) Insecticides shall not be removed from their original containers and shall be stored separately from

cleaning materials and products. They shall never be stored in food preparation areas.

4) Containers must be clearly labelled to distinguish them as such. Food Waste and Garbage Since food waste and garbage is a source of food contamination, odors, insects etc., these wastes must be handled, stored and removed from the galley after each meal.

Garbage pails in the galley shall be kept covered with well fitting lids, at all times.

Garbage cans shall be lined with plastic garbage bags, which when full are removed, tied at the top and stored in the designated area, to be appropriately disposed off. Recyclable materials (paper, cardboard, bottles, cans etc.) shall be stored separately for disposal.

Garbage shall be regularly transferred to a designated outside location where it can be safely stored. Means shall be provided to cover the garbage to prevent it from being disturbed. Garbage Disposal No garbage shall be thrown over the side

The Chief Cook in liaison with the Chief Officer shall keep a record of showing the following details: 1) Number of bags 2) Type of garbage 3) Date of landing 4) Where landed (Port and company to whom given)

Maintain garbage receipts on board for at least 1 year (12 months)




Date: June 1, 2013

Section 11: Violence in the Workplace Page 20 of 46

11.0 Violence in the Workplace

11.0 Purpose The purpose of this section is to define and document McKeil Marine Limited’s policy regarding Workplace Violence in accordance to the requirements of the Maritime Occupational Health and Safety regulations. 11.1 Harassment & Violence in the Workplace Policy Statement

Harassment & Violence in the Workplace

McKeil Marine Limited is committed to providing a safe work environment and part of this is preventing harassment and violence in the workplace. If McKeil Marine Limited becomes aware that domestic violence that would likely expose a worker to physical injury may occur in the workplace or harassment may occur, the employer shall take every precaution reasonable in the circumstances for the protection of the worker.

McKeil Marine Limited will meet or exceed the requirements of the Marine Occupational Health and Safety Regulations including but not limited to the prescribed duties of the employer, supervisor and worker.

All employees will not engage in or ignore violent, threatening, intimidating or other disruptive behaviors

All employees will report immediately to their supervisor any incident where the employee is, subjected to, witnesses, or has knowledge of harassment or workplace violence, or has reason to believe that harassment or workplace violence may occur.

When an employee feels that that their mental or physical well-being is at risk because of the actual or attempted application of physical force or verbal abuse it must be reported immediately to their supervisor or the Designated Person. They may remove themselves from the situation but remain must remain at a safe place as close as reasonably possible to the work station, until the investigation is complete.

.

Mr. Steve Fletcher President McKeil Marine Limited

Introduction McKeil Marine Limited is committed to providing a violence-free work place where any act of violence is unacceptable and will not be tolerated. This policy applies in the “work place” which is defined in the Canada Labour Code, Part II to mean “any place where an employee is engaged in work for the employee’s employer.” Acts of violence may occur as a single incident such as a physical attack or as an event resulting from a series of exposures to factors such as teasing and bullying. All factors that may contribute to violence in

http://laws.justice.gc.ca/en/L-2




Date: June 1, 2013


the work place that we are made aware of or that are reported will be investigated and any deliberate acts of violence in the work place will be subject to discipline. Purpose The purpose of this policy is to ensure that:

Employees and management understand that disciplinary action will be taken with those who commit or contribute to work place violence.

Those who are subjected to violence in the work place understand there are procedures for recourse and that assistance/counselling is available.

Employees and management understand that everyone has a responsibility to report any factors that may contribute to violence in the work place and that all incidents of work place violence must be reported.

Commitment McKeil Marine Limited is committed to:

Resolving work place violence situations to the best of our ability and, if they cannot be resolved, having a competent person conduct an investigation to arrive at conclusions and recommendations for corrective action.

Using the necessary amount of resources to prevent and to respond to incidents of work place violence.

Providing support for employees affected by work place violence.

Doing what is reasonably practicable to achieve a violence-free work place.

Prohibited conduct No employee shall subject any other person to work place violence or intentionally use any of the known factors that contribute to violence in the work place. Prohibited conduct includes, but is not limited to:

Intentionally causing physical injury to another person.

Intentionally causing damage to property of another.

Threatening remarks directed at another person (written or oral).

Possessing, during work, a dangerous weapon that is prohibited or not provided by the employer.

Bullying or intentional harmful teasing (written or verbal).

Displaying or exhibiting extreme anger or hostility. An employee who subjects another to violence in the work place will be subject to disciplinary action appropriate to the severity of the incident, up to and including dismissal. Management responsibilities Under this policy managers and supervisors have the following responsibilities:

To treat individuals at the work place with respect.

To develop work place arrangements that minimize work place violence.

Address and resolve incidents involving employees.

To promote a violence-free work place.

To ensure that all employees are aware of the policy and that the policy is posted and available.

To report any incidents of violence in the work place to the employer and, if necessary, to the police. Note: All physical assaults are to be reported to the police.

When applicable, to ensure the privacy and safety of all parties involved in a work place violence incident.

Employee responsibilities Under this policy employees have the following responsibilities:

To treat individuals at the work place with respect.

To report any incidents of work place violence, experienced or observed, to the employer.




Date: June 1, 2013


To report any factor not yet identified that may contribute to work place violence.

To co-operate in the investigation and resolution of matters involving work place violence. Complaint procedure for persons who have experienced work place violence

Inform the person inflicting the behaviour that it is an unwanted/ unwelcome behaviour. Note: A manager, supervisor or employee representative may be asked to assist with this.

Document all events, including time, date, and names.

Fill out a complaint form and report the incident to the manager or supervisor.

Request support/assistance, if required. Intentional false complaints will not be tolerated and will be subject to progressive discipline. Confidentiality/privacy Confidentiality/privacy is needed to properly investigate a work place violence incident and to offer proper support to those adversely affected. Any individual who becomes aware of a work place violence incident should not disclose any information to a third party without consulting the complainant/person directly involved. Those with questions or concerns regarding a work place violence incident should contact the DPA. Non-retaliation Employees will not be penalized or disciplined for making a complaint in good faith. Disciplinary action will be taken against any person who takes any reprisal against a person who reports an incident of work place violence. Investigation Upon receiving a formal complaint, the employer will decide whether to contact the police or will contact the police if requested by the employee involved. The employer will then address and resolve the complaint between the parties involved. If the matter can be resolved, the employer will assess and implement controls to prevent the WPV from happening again. The identities of the people involved will not be disclosed without their consent. If the complaint cannot be resolved internally, the employer will appoint a competent person to investigate the complaint and submit a written report to the employer. The employer can conduct an investigation without using a competent person if these three criteria are met:

The work place violence was caused by a person other than an employee.

It is reasonable to consider that the possibility of intervening in violent situations is a normal condition of employment.

The employer has effective procedures and controls in place to address work place violence, the development of which involved the employees.

Upon receipt of the report, the employer will provide a copy to the health and safety committee (or the health and safety representative) and will implement controls to prevent a recurrence of the work place violence. Disciplinary action The employer may consider the following factors when deciding on disciplinary action based on a WPV incident:

The severity of the incident.

Whether there was intent to injure or harm.

Events leading up to the incident that indicated the WPV was likely going to occur.

The prior history of the employee involved in causing the WPV.

Whether the complaint was made in good faith. The resulting disciplinary action may include:

An apology.

Progressive discipline such as written warning, suspension.

Training.




Date: June 1, 2013


Referral to an assistance program.

Dismissal. Record keeping The written or electronic documents related to the findings of the review of the work place violence prevention measures will be kept by the employer for three years and be readily available for examination by a health and safety officer. The report from an investigation into a work place violence incident conducted by a competent person will be kept by the employer and be readily available for examination by a health and safety officer. Signed records in paper or electronic form on the information, guidelines and training provided to each employee will be kept for two years after the date the employee ceases to perform an activity that has a risk of work place violence associated with it. Assistance If requested, the employer will provide assistance for an employee who was involved in a work place violence incident. This assistance may include:

Employee Assistance Program.

Counseling.

Policy review To ensure this policy remains current and up to date it will be reviewed and updated at least once every three years. The date of the last review will be indicated in the policy.




Date: June 1, 2013

Section 12: Landing Booms, Gangways and Ladders Page 24 of 46

12.0 Gangways, Ladders and Landing Booms

12.0 Purpose The purpose of this section is to define and document McKeil Marine Limited’s requirements for personal transfer apparatus, including landing booms, portable ladders and points of access to the vessel. This section meets the requirements set out in the Maritime Occupational Health and Safety Regulations. 12.1 Landing Booms Only qualified persons shall be permitted to lower personnel on the landing boom. They shall be maintained in good order and be available for use throughout the sailing season. Persons being lowered shall wear hard hats, safety gloves, life vests/life jackets, and safety shoes. Persons lowering personnel shall wear at the minimum, safety gloves and safety shoes to carry out the operation. Under normal circumstances, personnel shall be lowered on shore when the ship is alongside the dock. In unusual circumstances, personnel shall be lowered when the ship is as close to the dock as is possible. 12.2 Portable Ladders Portable ladders shall be used to reach no more than 5 feet above the deck. When working aloft at heights larger than 5 feet, Stages shall be used. Rope ladders shall not be used for height in excess of 9m. Employees shall not use ladders when it is safe and practical to use permanent structures. The use of ladders shall be avoided under adverse weather conditions, unless the use of such is for the rescue of personnel, removing a hazard or protecting the safety of the ship. Ladders shall be maintained in good condition. Defective ladders shall either be repaired or be removed from the ship, as soon as possible. When using step or extension ladders, only one person shall be on the ladder at any given time. Tools, equipment, and materials used on a ladder shall be arranged or secured in such a manner that they cannot be knocked off the ladder accidentally. Employees using portable ladders must:

Use both hands and face ladder to ascend or descend the ladder.

Face the ladder while working.

Perform work within one arms length off the ladder.

Raise and lower material and equipment by means of a rope or bucket, whichever is appropriate. A person shall be assigned to hold the ladder in place, and the ladder can be secured safely on top and the ladder is safely tied off at the bottom. The correct angle for using a ladder safely is one foot horizontal for every four feet vertical. Avoid using ladders in front of doors. If they must be used in such location, the door shall be locked with a sign indicating not to open door.




Date: June 1, 2013

Section 12: Landing Booms, Gangways and Ladders Page 25 of 46

12.3 Stages The erection, use, dismantling and removal of a stage shall be carried out by or under the supervision of a qualified person. Every stage shall a) Have a flat and horizontal working surface capable of supporting any load that is likely to be imposed

on it. b) Be fitted with an effective means for holding the stage away from the working area. c) Where the stage is to be used at a height of more than 3 meters, be fitted with guard lines. The supporting structure and the ropes or tackle supporting the stage shall have a safety factor of not less than six. Employees working on a staging over the ship’s side shall wear life jackets and be secured with a safety belt and line. 12.4 Gangways All McKeil Marine Limited tugs and barges shall follow the requirements of section 12, Means of Access, of the Maritime Occupational Health and Safety Regulations. The Maritime Occupational Health and Safety Regulations can be found on the Reference Document menu. All McKeil Marine Limited tugs shall be provided with an adequate gangway. Where applicable, barges shall be provided with adequate gangways. When secured alongside at least one safe point of access must be established, either between the tug and the dock or the barge and the dock. When the safe access point is from the barge to dock, safe access from the barge to the tug must be established and vice versa. Failing to rig a proper gangway can result in personal fines levied against the vessel’s officers. A safety net shall always be rigged underneath a gangway, do not board unless a secured safety net is in place. Crossing from either the tug or the barge with used of a gangway must be avoided at all times unless required by the tugs operations to secure the vessel. Access to and from the vessel in a lock shall only take place by means of the canal gangway provided. Stepping to and from the vessel over the ship’s bulwark or guardrails is strictly prohibited.




Date: June 1, 2013

Section 13: Hazard Analysis Page 26 of 46

13.0 Hazard Analysis

13.0 Purpose The purpose of this section is to define and document McKeil Marine Limited’s Hazard Analysis procedure. 13.1 What Is Hazard Analysis?

This is the process of pre-planning shipboard operations to identify and remove possible hazards.

It involves:

a) Participation of all employees in the safe planning of an activity, b) Prediction of possible negative outcome scenarios and the provision to safeguard or mitigate. c) Planning and predicting the required equipment, tools, permits, and protective equipment

including the gathering of such before the job is commenced. d) Agreement on the methods of work to be employed, including the form of communication before

commencement of work by all involved employees.

When to Perform a Hazard Analysis?

a) A Hazard Analysis is to be conducted when planning a new activity, an activity that involves new equipment, an activity that has been identified as potentially hazardous or any other work that the outcome cannot be positively predicted.

b) Before starting any such work, personnel must consider the possible hazards involved and institute measures to minimise the risk from these hazards. This process is an integral part of every operation of this type.

c) Hazard Analysis is required for all jobs covered by the Permit-to-Work system. d) A Hazard Analysis shall be conducted for all activities that have resulted in a Hazardous or

Dangerous Occurrence (near miss).

Who Can Require A Hazard Analysis?

a) The Master, Chief Engineer or any workplace supervisor may require the completion of this analysis.

b) Hazard Analysis is required for any jobs identified as potentially hazardous. c) The vessel Safety committee may request a hazard analysis for any work instruction or job to be

performed. d) An employee may request that a Hazard Analysis be conducted for any job, at any time, without

fear of reprisal.

Right of Refusal

Crew members involved in the job have a RIGHT OF REFUSAL to carry out work which they deem to be At Risk (unsafe).

In any instance of disagreement, between a supervisor and a crew member, as to the At Risk implications of a work instruction, the disagreement shall be referred to the Master, Chief Officer or a McKeil Marine shore management representative prior to commencing the work. The Master, or shore management, shall then conduct a formal review of the work planned and/or the work instruction.

No refusal permitted in certain dangerous circumstances

An employee may not refuse to use or operate a machine or thing, to work in a place or to perform an

activity if:

a) The refusal puts the life, health or safety of another person directly in danger; or b) The danger referred to is a normal condition of employment.




Date: June 1, 2013


An employee that is informed that the employee may not discontinue the use or operation of a machine or

thing or cease to work in a place or perform an activity shall not, while the vessel on which the employee

is employed is in operation, refuse to use or operate the machine or thing, work in that place or perform

that activity when vessel is in operation.

A vessel is defined to be in operation from the time it casts off from a wharf in a Canadian or foreign port

until it is next secured alongside a wharf in Canada.

13.2 Hazard Analysis Checklist

Form S010 Hazard Analysis Check List has been implemented to facilitate Hazard Analysis’s done on

board and on shore. When completing form S010 Hazard Analysis Checklist keep in mind:

The completion of this checklist may be used to assist in the process of Hazard Analysis.

Where possible, all personnel who will be involved in the work will contribute to the Hazard Analysis

Any required permits (hot work, confined space, etc.) must be in place before work begins.

A work supervisor shall recognise a request for a hazard analysis by any crew member if the employee is uncomfortable with a work process or is aware that the work instructions may be detrimental to the environment.

Risk is calculated and safeguards provided to guard against negative outcome.

13.3 Risk Assessment for Tug and Barge Fleet The following Risk Assessment has been carried out in relation to the operation of McKeil Marine Limited’s Tug and Barge fleet. Experience gained and documented incidents were referred to when creating this assessment. Safeguards have been established through procedures, training and equipment. This Risk assessment shall be reviewed and revised if deemed necessary on an annual basis. Table 1. Frequency Scale

Assign a rating of if the frequency is

1 REMOTE = Might occur once in a lifetime

2 OCCASIONAL = Might occur every five-ten years

3 LIKELY = Might occur every one to five years

4 PROBABLE = Might occur yearly

5 FREQUENT = Might occur more than once per year

Table 2. Consequence (Impact) Scale

Assign a rating of if the impact could be

1 NEGLIGIBLE = Injury not requiring first aid, no cosmetic vessel

damage, no environmental impact, no missed voyages.

2 MINOR = Injury requiring first aid, cosmetic vessel damage, no

environmental impact, additional work, minor operational




Date: June 1, 2013


disruption, no missed voyages.

3

SIGNIFICANT = Injury requiring more than first aid, vessel

damage, some environmental damage, longer operational

disruption, or financial loss.

4

CRITICAL = Severe injury, major vessel damage, major

environmental impact, major operational disruption missed

voyages (up to and including the entire season).

5 CATASTROPHIC= Loss of life, loss of vessel, extreme

environmental impact.

Figure 3. Risk Priority Matrix

Severity

Fre

qu

en

cy

1 2 3 4 5

5 M H H VH VH

4 M M H VH VH

3 L M M H H

2 L L M M H

1 L L L M M

L – Low M – Medium H – High VH – Very High

A risk priority of “VH” indicates an event or an accident that is very likely to occur and with very high consequences. A risk priority of “L” indicates an inconsequential event that is unlikely to occur. Risk priorities of “H” and “M” lie somewhere in between. When Hazard Assessment result in priorities higher that Medium, extra precautions must be taken to mitigate the risk of an incident. Precautions shall be listed on the Hazard Assessment Checklist. When Hazard Assessments result in priorities High or Very High and precautions cannot be implemented that reduce either the frequency or severity of the outcome, the task should not be attempted without further consultation with McKeil Marine Limited’s operations department.




Date: June 1, 2013


Figure 3. Risk Assessment Table

Hazard Causes Risk Assessment

Safeguards

Describe

Describe

Fre

qu

en

cy

Co

nseq

uen

ce

(Im

pact)

Ris

k P

rio

rity

Safeguards in place and any additional recommendations.

1) Grounding a) Pilotage Error 3 4 H McKeil Has in place a system for vetting and training river pilots. This will be formalised under the GLPA Marine Pilots Certificate Training Program. QSMS 8.0 Emergency Preparedness

b) Weather 2 4 M Hiring experienced trained mariners that can determine risk when weather is a factor. QSMS 8.0 Emergency Preparedness

c) Equipment Failure 2 4 M Preventative maintenance program. QSMS 8.0 Emergency Preparedness

2) Fire on Board

a) Housekeeping 2 5 H Statutory fire fighting training for crew.

b) Equipment (mechanical)

2 5 H Preventative maintenance program. Statutory fire fighting training for crew. QSMS 8.0 Emergency Preparedness

c) Equipment (electrical)

2 5 H Preventative maintenance program. Statutory fire fighting training for crew. QSMS 8.0 Emergency Preparedness

3) Oil Spill a) Human Error 2 4 M SOPEP, oil spill drills Bunkering and Oil Transfer procedures as defined in Engine Room Procedure Manual QSMS 8.0 Emergency Preparedness

b) Mechanical Failure 2 4 M SOPEP, Preventative maintenance program. QSMS 8.0 Emergency Preparedness

4) Collision a) Human Error 2 5 H Hiring experienced trained mariners and providing collision avoidance tools. IE, Arpa Radar, Electronic Charts, AIS, Communications. QSMS 8.0 Emergency Preparedness

5) Man Overboard

a) Notching up / Going on Towline

3 5 H Crew Training, Procedures set out in the Towing Procedure Manual. Life jacket and PFD policies defined in the Health and Safety Manual. Man Overboard Drills

b) mooring 3 5 H Crew Training, Life jacket and PFD policies defined in the Health and Safety Manual. Man Overboard Drills QSMS 8.0 Emergency Preparedness

6) Explosion a) Welding 1 5 M Hot work procedures defined in Health and Safety Manual




Date: June 1, 2013


Hazard Causes Risk Assessment

Safeguards

Describe

Describe

Fre

qu

en

cy

Co

nseq

uen

ce

(Im

pact)

Ris

k P

rio

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Safeguards in place and any additional recommendations.

b) Confined space work

1 5 M Hot work, Confined Space Entry and Lock out-Tag out procedures defined in the Health and Safety Manual QSMM 8.0 Emergency Preparedness

c)Equipment failure 1 5 M Planned Maintenance System QSMM 8.0 Emergency Preparedness

7) Pollution due to Cargo Emissions

a)Loading / Unloading 4 3 H Cargo Procedures defined in the Deck Procedure Manual McKeil Marine Garbage Management Plan and Cargo Residue Log

b)Hold and Deck cleaning

4 3 H Cargo Procedures defined in the Deck Procedure Manual McKeil Marine Garbage Management Plan and Cargo Residue Log

8) New or Inexperienced Crew

a)Lack of Knowledge for Specific Tasks

5 5 VH New Employee Start Up procedure defined in the Human Resources Manual Familiarization training on joining vessel procedure defined in the Human Resources Manual Training Needs defined in the Human Resources Manual

b) Lack of skills and experience

5 5 VH Training Needs defined in the Human Resources Manual




Date: June 1, 2013

Section 14: Work Permit Page 31 of 46

14.0 Work Permit System

14.0 Purpose The purpose of this section is to define and document the policies and procedures associated with McKeil Marine Limited’s Work Permit system. 14.1 General McKeil Marine Limited has developed procedures for a Work Permit system in accordance with the guidelines of the Maritime Occupational Health and Safety Regulations. This section describes the requirements of each task to which the Work Permit system applies 14.2 Confined Space Policy

Before commencing any work that requires entry into a confined space FORM S007 Confined Space

Entry Permit must be filled out and FORM S009 Confined Space Entry Hazard Assessment must be filled

out. If an existing FORM S009 Confined Space Entry Hazard Assessment has be completed for the

space to be entered, and no changes have occurred to that space (ie ballast tanks used for liquids other

than water, or significant changes to the structure have occurred) then the previously completed FORM

S009 is still acceptable and should be reviewed while completing the Confined Space Entry permit

Persons granted access to the confined space shall be given whatever protective equipment deemed

necessary.

A confined space entry log shall be used each time personnel enter and leave a confined space and a

copy shall be stored in the wheelhouse.

Oxygen level metering shall be conducted before entry into a confined space. If the oxygen level is below 20% or above 22% by volume at normal atmospheric pressure, the space shall not be entered without appropriate protection. Qualified competent person

Entry into confined spaces must be authorized by the Master or in his absence, the 1st mate and in his

absence, the Chief Engineer.

Officers trained in the use of the gas monitor and well versed with company procedures on confined

space entry, shall be the qualified competent persons. This person will be responsible for identifying

hazards, filling the entry permit, ensuring safety equipment availability and for conducting a pre-entry

briefing with the employees entering.

Atmosphere monitoring

When a confined space is being tested, sample of air shall be drawn from the top, middle and bottom of

the space. Because gases stratify or layer, air at one level may be safe whereas it may be hazardous at

another level.

During meal breaks and coffee breaks while the space has been left unattended, the atmosphere shall be

tested prior to re-entry. Even in such short periods, the atmosphere could become oxygen or acetylene

enriched from leaking hoses/gaskets.




Date: June 1, 2013


Ventilation

The confined space shall be adequately ventilated and/or flushed and purged or otherwise emptied of any

hazardous atmosphere before each entry. Ventilation may be natural or mechanical. For water ballast

tanks that are frequently filled and emptied, natural ventilation is usually adequate. Water ballast tanks

that are empty for long periods without ventilation shall be tested and entered only when found safe.

Rescue plan

The rescue plan section of the confined space entry permit will be in place before entry. The plan should

consider items such as falls/retrieval blocks for hoisting injured personnel out of the confined space,

appropriate stretchers, breathing units, etc.

Potential Hazards in Confined Spaces:

Oxygen depletion

Hot work such as welding and burning absorbs oxygen and can deplete the safe level of oxygen required to breath. This can be avoided by the use of mechanical ventilation that ensures sufficient exchange of air.

Oxygen enrichment

Oxygen enrichment is said to take place when the oxygen level increases above 23% by volume at normal atmospheric pressure. Excessive oxygen causes burning to occur at an accelerated rate.

Oxygen enrichment is usually caused by leaks from oxygen cylinders or hoses used during burning and welding operations. Therefore, as far as possible, avoid taking oxygen cylinders into a confined space. Also, when work is stopped for any length of time example coffee or meal breaks, all torches and hoses must be removed from the confined space.

Combustible Gases

Fuel oils, acetylene from burning equipment, hydrogen gases from severely rusted tanks etc. create combustible gases. Combustible gases ignite only when they are within their respective concentrations. Example, gasoline will ignite when concentration is between

1.5% to 7.8%. Above or below these levels, gasoline will not ignite. 1.5 is known as the lower explosive level (LEL) and 7.8 the upper explosive level (UEL).

Toxic Gases

The most likely toxic gas on board our ships would be Carbon Monoxide. Its source is generally gas emissions from combustible engines. This gas is odorless, colorless, toxic, flammable and slightly lighter than air. Toxic gas on ships is generally controlled by vigorous mechanical ventilation.

Effects of Carbon Monoxide (CO) levels:

At 35 PPM the permissible exposure level is 8 hours (OSHA).

At 200 PPM the worker may experience a frontal headache in 2 to 3 hours.

At 400 PPM the worker may experience frontal headache and nausea in 1 to 2 hours. Occipital

after 2½ to 3½ hours.

At 800 PPM the worker will experience headaches, dizziness and nausea in 45 minutes. Collapse and possible death in 2 hours.

At 3200 PPM headache and nausea in 5 to 10 minutes. Unconscious and danger of death in 10 to 15 minutes.

At 12,800 PPM the worker will be immediately unconscious. Danger of death in 1 to 2 minutes.




Date: June 1, 2013


Air borne dust

Air borne dust should be considered a hazard when dust obscures visibility at 5 feet or less. Air borne dust could pose a toxicity problem or an explosive hazard. Air borne dust is controlled by ventilation.

Respiratory protection shall be worn when dust is present.

Occupational hazards to consider when entering confined spaces

Slipping, tripping

Falling

Falling objects

Entrapment

Engulfment

Drowning

Other hazards to consider when entering confined spaces:

Electrical shock

Mechanical shock

Hydraulic - liquid inflow/outflow, hydraulic controls

Pneumatic - pressurized air or gasses, pneumatic controls 14.3 Hot Work Policy

No hot work shall be carried out on the tug or barge without the permission of the Chief Engineer.

FORM S006 Hot Work Permit must be completed before commencing any hot work by a licensed crew

member and be signed by the Chief Engineer. A copy of the form shall be posted at the work site. A

continuous log of Hot Work Permits must be kept on board.

Welding can be carried out by ship’s personnel on non-safety items and on safety items on a temporary

basis.

Safety items shall be repaired by companies certified to carry out such repairs.

Appropriate protective equipment shall be worn by all persons involved in the operation, at all times,

whilst hot work is being carried out.

A fire extinguisher shall be available in the welding area.

Fire watch shall be carried out during the entire hot work operation and for at least half an hour after.

Combustible materials shall be removed from the hot work area. If this not possible, such materials shall

be adequately protected.

Hot work shall NOT be carried out under the following conditions:

Where dust or flammable gasses/vapours could be present. The atmosphere shall be tested and hot work shall proceed only when it is deemed safe to do so (i.e. monitored and determined non-explosive). Where such risk of gasses, vapours and dust exist, testing of the atmosphere shall be carried out frequently;

On bulkheads containing fuel oil(s), grain or other flammable cargoes or products.




Date: June 1, 2013


Hot Work Safety Rules

Cordon-off area where hot work is to take place

Protect bystanders and equipment from potentially harmful exposure to arcs and sparks

Operators and assistants shall wear the appropriate safety equipment

Ensure cylinders are upright and well secured before use

Check connections for leaks, using a leak test solution, prior to commencement of work. If leak(s) is

observed, fix it before proceeding with the work

Use friction lighters to light torch. Do not use cigarettes or matches

Do not use slings or electro-magnets to lift or transport cylinders. Use a cradle or a suitable platform

Do not lift cylinders by the valve protection cap

Do not use a hammer, wrench or pliers for opening and closing cylinder valves equipped with hand

wheels

Always attach a pressure-reducing regulator to cylinder valves

Do not open acetylene cylinders more than one and one half turn (1½)

Observe good housekeeping practices; dispose welding rods, pick up excess material, roll up hoses etc.

Hot Work Personal Protective Equipment

Eye protection

Application Lens shade No.

Brazing 3 or 4

Light cutting (up to 1”) 3 or 4

Medium cutting (1” to 6”) 4 or 5

Heavy cutting (over 6”) 5 or 6

Light welding (up to 1/8”) 4 or 5

Medium welding (1/8” to 1/2”) 5 or 6

Heavy welding (over 1/2”) 6 or 8

Note: Filter recommendations adapted from ANSI Safety Standards

Wear welding gloves of leather or other suitable fire resistant material.

Wear an appropriate welding jacket/apron of leather or other suitable fire resistant material.

Wear chaps if leg protection is required;

Wear steel toe safety boots. Ensure pants are not tucked into boots.




Date: June 1, 2013


While welding, a welding helmet shall be worn;

If goggles are worn while cutting or brazing, a hard hat must be worn.

Wear hearing protection where required.

14.4 Lock Out / Tag Out Policy

Before commencing any work on machinery, or in a location, that if energized during the work could injury

the person performing the work a Lock Out Tag Out Permit must be completed and the appropriate items

be physically ‘locked out’.

Lock Out Tag Out is a safety procedure to ensure that dangerous machines are properly shut off and not

started up again prior to the completion of maintenance or servicing work. It requires that hazardous

power sources be "isolated and rendered inoperative" before any repair procedure is started. "Lock and

tag" works in conjunction with a lock usually locking the device and placing it in such a position that no

hazardous power sources can be turned on. The procedure requires that a tag be affixed to the locked

device indicating that it should not be turned on. Lock Out Tag Out does not only apply to electrical

sources, it also includes hydraulic and mechanical systems.

Lockout/Tagout Procedures It is the responsibility of all personnel involved with the work to follow lock out tag out process and permit procedures provided by McKeil Marine Limited Lock out Tag out kits will be made available for this purpose. Before any work requiring energy isolation Form S011 must be completed. This form must be posted at the sight of the work being performed. A continuous log of Work Permits must be kept on board. • All affected personnel are notified which specific piece of equipment will be locked out or tagged out and the reason for it being secured • All actual and potential sources of energy and their hazards are identified. A means of isolating or dissipating each energy source must be identified. Energy source examples: Pneumatic, hydraulic, steam, electric and mechanical • The equipment or system to be locked out must be turned off according to normal shutdown procedures as laid out in the individual instruction manuals. -Pneumatic hydraulic and steam systems may require pressure bleed off or venting to properly isolate and de energize the system. No pressure should remain. -Electrical breakers tripped or racked out if possible and locked. All valves required to isolated pneumatic and hydraulic and steam systems need to be locked. Mechanical breakers require discharging springs prior to racking out and locking out. (Main tie breaker on most vessels) Any spring mechanism associated with the device or equipment being isolated should be de energized. • All of the energy sources to the equipment must be individually isolated. Electrical breakers opened and locked, valves either opened or closed and locked with a restricting bonnet for this purpose or ball valve handles using the provided locking holes. Chains and cables can also be used where necessary to restrict the movement of valves




Date: June 1, 2013


• Stored energy must be dissipated or restrained by methods such as repositioning, blocking, bleeding down/blinding, etc. • If there is a possibility of re-accumulation of stored energy during the work, verification of isolation must be continued until the servicing or maintenance is completed or until the possibility of re-accumulation no longer exists • The switch, valve or other device used to isolate the equipment must be locked and tagged. Locks and tags should be positioned to indicate to everyone proper isolation. Information should be noted on the tag to identify its use. Date, time and the permit holders initials should be noted on each tag. Keys will be held by the permit holder until the permit is lifted and at that time returned to the lock out tag out kit along with the associated lock. • Energy isolation is to be verified by attempting to restart the equipment, reading a pressure Gauge, voltmeter or other instrument. If verification is made by attempting to restart equipment, return the operating controls to the "neutral" or "off' position after the test. Note: verification of isolation is the responsibility of all persons involved with the locked out and tagged out equipment or system. • Check system for hazardous vapors or liquids, if appropriate. Note: If more than one person or group of people is involved with the work multiple locks and tags may be used as required. A new permit is required for each additional group. Any permit issued must accompany a signature on the Lock out Tag out Log. Completion of Work When work is completed, but before any lock out/tag out release, the following actions must be taken: • The work area is to be inspected to ensure that the equipment is intact, that all non-essential tools have been removed and that guards have been replaced. • The work area must then be inspected to ensure that all employees are in a safe location. Each lockout/tag out device must then be removed by whoever originally placed them. In an emergency, and only if the person whose personal locks/tags are in place is not able to unlock them through incapacity, the Chief Engineer or his delegate, may remove those locks/tags. However, this is a potentially hazardous action and before doing so they must complete the following steps: • Verify that personnel are not working on the system or on other work which may be affected by the re- energizing of the system. • Make a reasonable effort to contact the original people involved in the lockout/tag out procedure. • Notify everyone onboard of the impending release of the equipment lockout/tag out. • Cancel the permit and notify the EOW to update the lockout/tag out log. • Ensure that everyone involved with a particular job knows that the lockout/tag out device has been removed before work resumes in the area. • Account for all personnel. • Restore energy to the equipment.




Date: June 1, 2013

Section 15: Job Safety Analysis Page 37 of 46

15.0 Job Safety Analysis (JSA)

15.0 Purpose The purpose of this section is to define and document McKeil Marine Limited’s Job Safety Analysis (JSA) program.

15.1 Introduction to Job Safety Analysis

As part of McKeil Marine Limited’s commitment to continual improvement of safety onboard its fleet,

McKeil Marine Limited has designed and developed a Job Safety Analysis system to help identify and

reduce the risks associated with the operation of our vessels.

15.2 What is a Job Safety Analysis?

A Job Safety Analysis (JSA) is a tool to help analyse the risks that are associated with the ‘jobs’ that are

required to operate our vessels. In a JSA, a job is broken down into individual steps, then the risks

associate with each step is identified and finally, preventative measures for each risk are developed.

15.3 Use of Job Safety Analysis

Benefits of JSA’s include the clear identification of all risks associated with completing a job. Once

completed a JSA can be used for training for new crew members onboard as well as be used during Tool

Box Meetings. When a JSA is reviewed as part of a Tool Box Meeting, it must be printed and signed by

all attendees. Storage of completed JSA is described below in Section 15.10.

15.4 How to complete a Job Safety Analysis?

JSA’s are completed in four steps;

1. Selecting the job to be analyzed

2. Breaking the job down into a basic steps

3. Identifying potential hazards

4. Determining preventive measure to overcome these hazards

15.5 Tips for selecting the job to be analyzed

Ideally, all jobs should be analyzed using the JSA format, practically, critical jobs should be analysed first.

Critical jobs include;

Jobs where accidents occur frequently or where they occur infrequently but result in disabling

injuries

Potential for severe injuries or illnesses; the consequences of an accident, hazardous condition or

exposure to harmful substances are potentially sever

Newly established jobs; due to lack of experience in these jobs, hazards may not be evident or

anticipated

Modified jobs; new hazards may be associated with changes in job procedures

Infrequently performed jobs; workers may be at greater risk when undertaking non-routine jobs

Make sure to identify a ‘job’ and not a ‘step’ in a job. Bunkering would be considered a job, while

hooking up the fuel line would be considered a step.

15.6 Tips for breaking the job into basic steps

A job step is defined as a segment of the operation necessary to advance the work. Ideally, jobs will be

analysed by observation, alternatively they can be analysed by discussion. Care must be taken not to

make the steps too generally, on the other hand, if they are too detailed, there will be too many steps.

Generally, jobs can be described in less than 10 steps. It is important to remember to keep the steps in




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Section 15: Job Safety Analysis Page 38 of 46

their correct sequence. Any step which is out of order may miss serious potential hazards or introduce

hazards which do not actually exist. Always remember, steps are what is done, not how it is done.

15.7 Tips for identifying potential hazards

Potential hazards, no matter how minor must be identified for each step, list everything that could go

wrong at every step. Consider the following questions when analysing each step for hazards;

Can any body parts get caught in or between objects?

Do tools, machines or equipment present any hazards?

Can the worker make harmful contact with moving objects?

Can the worker slip, trip for fall?

Can the worker suffer strain from lifting, pushing or pulling?

Is there danger from falling objects?

Is lighting a problem?

Can weather condition affect safety?

Can contact be made with hot, toxic or caustic substances?

Are there dusts, fumes, mists or vapours in the air?

15.8 Tips for identifying preventive measures

The ultimate goal of JSA’s is to identify preventative measures for every risk identified in the analysis.

Preventive measures, in order of preference should;

1. Eliminate the hazard; by choosing a different process, modify an existing process, substitute

with a less hazardous substance or modify or change equipment or tools

2. Contain the hazard; if hazards cannot be eliminated, contact might be prevented by using

guards

3. Revise work procedures; consider modifying steps which are hazardous, changing the

sequence of steps or adding additional steps

4. Reduces exposure; should only be used if no other solution is possible.

In general, when developing preventive measures, do not use general statements such as ‘be careful’ or

‘use caution’. Specific statements that describe what action is to be taken and how it is to be preformed

is preferred.

15.9 McKeil Marine Limited’s JSA Program

McKeil Marine Limited has evaluated a number of common jobs using the JSA methodology. These JSA

create the frame work for the fleet JSA system. Every vessel is responsible for evaluating the provided

JSA’s against the vessels operation and providing the Health and Safety department with modifications

and feedback. New JSA’s are to be developed for vessel specific jobs not already listed and for any new

jobs onboard going forward using for S013 Job Safety Analysis Blank. Any modifications to existing

JSA’s or new JSA’s should be attached to the monthly Health and Safety Meeting Minutes and sent to the

vessels manager.

15.10 JSA Documentation

Approved JSA’s are available on the reference menu of the QSMS. In addition to the digital document all

McKeil Marine Limited vessels shall be equipped with a JSA binder, this binder shall be kept up to date by

the vessel’s Safety Officer. The binder will be comprised of four sections, one for approved fleet JSA’s,

the second section will contain JSA’s approved for that specific vessel. The third section will contain

JSA’s developed for the vessel that have yet been approved. The final section will contain the JSAs that

have been reviewed and signed by the crew. This binder will be subject to review during the vessel’s

annual safety audit.




Date: June 1, 2013

Section 16: Tool Box Meetings Page 39 of 46

16.0 Tool Box Meeting

16.1 Purpose The purpose of this section is to define and document McKeil Marine Limited’s Tool Box Meeting requirements. 16.1 Tool Box Meeting Description Tool Box Meetings are brief meetings used to ensure all persons involved in the execution of a task are made aware of the proper steps required to complete the task in a safe manner. Tool Box Meetings are held to ensure that all persons have the situational awareness required to safely complete a task. During a Tool Box Meeting a Job Safety Analysis may be developed or reviewed in order to ensure all persons are aware of the steps required to complete a task. Tool Box Meetings are to be chaired by the Officer of the Watch or Engineer of the Watch. 16.2 Tool Box Meeting Requirements A Tool Box Meeting must be held before commencing work where any of the following factors may apply: 1. New or unfamiliar crew are involved with the task 2. New equipment is being used 3. New contractors/suppliers are involved in the task 4. Any circumstance out of normal operating parameters is involved 5. Any crew member has a concern regarding the safe completion of a task 16.3 Tool Box Meeting Documentation Upon completion of a Tool Box Meeting an entry in the Bridge Log Book must be made. A Tool Box Meeting entry should include, at a minimum, the following information: 1. Time of meeting 2. Attendees of meeting 3. Topic discussed 4. Job Safety Analysis reviewed or Work Permits Issued 5. Issues or Concerns raised during the meeting 6. Solutions or mitigating factors developed through the meeting




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Section 17: Contractors Working Onboard Page 40 of 46

17.0 Contractors Working Onboard

17.0 Purpose These Guidelines state the policy of McKeil Marine and shall apply to all contractors, sub-contractors, and workers performing work on board any McKeil Marine vessel. These Guidelines outline the minimum level of safety practices, procedures, and conditions required when performing work on board any vessel. Nothing in these procedures shall be construed to override the applicable legislation of the Port State. These Guidelines establish the level of safety awareness required by all contractors, sub-contractors, and workers authorising and performing work on board any vessel. The requirements of these Guidelines are applicable to work performed on board McKeil Marine vessels either in service, alongside or during lay-up and/or during periods of stationary repair. These Guidelines are to work in compliance with the latest edition of McKeil Marine Safety Standards, Policies and Procedures. 17.1 Definitions The following definitions apply to these guidelines. "Authorised Delegate" shall refer to an individual who has been delegated to undertake the responsibilities of the referred person or position in accordance with these procedures. The term "Confined Space" shall be as defined by the current Marine Occupational Health and Safety Regulations. "Contractor" shall refer to person(s) contracted to perform work or supply services. For the purpose of these Guidelines the term contractor shall include both maintenance contractors and project contractors (marine contractors). "Hotwork" shall refer to any work involving an ignition source of solid materials, combustible gases, vapours or liquids in or adjacent to the area involved. Hotwork includes, but is not limited to: welding, burning, scorching, grinding, metal chipping, explosive fastening to metal hammering and electrical work which might produce an incendive spark. "Personnel" shall refer to McKeil Marine shipboard employees. "Shall" is used to indicate provisions which are mandatory. "Should" or "it is recommended" shall indicate provisions which are not mandatory but which are pointed out as recommended good practices. "Subcontractor" shall refer to person(s) contracted by contractor to perform work or supply services. "Worker" shall refer to a person who performs work or supplies services for monetary compensation; employee of either a contractor or subcontractor. 17.2 Governing Laws and Regulations The following laws and regulations apply to the health and safety of all personnel, contractors, subcontractors and workers on board McKeil Marine Limited vessels.




Date: June 1, 2013


Canada Shipping Act The duties and responsibilities of the owner, contractors, sub-contractors and workers outlined in the Canada Shipping Act shall apply to all persons conducting work on board McKeil Marine vessels. Safe Working Practices All work performed on board McKeil Marine vessels shall be performed in compliance with the Safe Working Practices of the Canada Shipping Act. Contractors shall undertake and comply with all regulations in force on the work site, relating to the safety of persons on the site or the protection of property against loss or damage from any and all causes. Occupational Safety and Health, Canada Labour Code Part II of the Canada Labour Code, "Occupational Safety and Health", defines the specific duties and responsibilities of owners and contractors to provide a safe working environment and to guard the health and safety of all employees. Marine Occupational Health and Safety Regulations, Canada Labour Code All work performed on board McKeil Marine vessels shall be performed in such a manner as to comply with the current “Marine Occupational Health and Safety Regulations"; Part IV of the Canada Labour Code. 17.3 Duties and Responsibilities All McKeil Marine management and personnel, contractors, sub-contractors, and workers shall promptly report, to their immediate supervisor, any incidents of vessel damage or personal injury, resulting from work performed on board McKeil Marine vessels. Vessel Manager The Vessel Manger shall always be the point of contact with regard to these procedures if there is no crew aboard the vessel during times of Lay-up. The Vessel Manager, or authorised delegate (i.e. Chief Engineer), shall be responsible for: ♦ Supplying the contractor with a hazardous substance report for the specific work area and advising the contractor of the requirement to comply with these Guidelines upon issuing a work order; ♦ Ensuring that the Chief Engineer or his delegate is administering the Guidelines aboard vessels in their jurisdiction; ♦ Reviewing incident reports of personal injury or vessel damage on board vessels in their jurisdiction to determine if all requirements were adhered to and what steps are necessary to prevent re-occurrence. Chief Engineer The Chief Engineer, or authorised delegate, shall be responsible for: ♦ ensuring that all reasonable action is taken to protect the health and safety of all persons working on board their vessels and to provide contractors, sub-contractors and workers with safe entry and exit to the work area; ♦ advising contractors of all known hazards associated with the work to be performed; ♦ ensuring that all hazardous substances brought on board a McKeil Marine vessel, are controlled, stored and handled properly, and labelled in accordance with the Hazardous Materials Information Review Act, (WHMIS); ♦ providing access to adequate fire protection and fire fighting equipment and, first aid facility on board; ♦ investigating, recording and reporting to the Vessel Manager, all incidents involving personal injury, loss of life, vessel damage, or activities that pose a threat to the safety of persons working on board the vessel. Contractors The contractor shall be responsible for:




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♦ having full knowledge and comprehension of McKeil Marine’s health and safety policies, procedures and permit systems and the governing laws and regulations cited in Section 3.0 of these Guidelines; ♦ ensuring sub-contractors and workers are fully aware and will comply with these requirements, for the duration of the contract; ♦ ensuring each subcontractor and worker is qualified to perform the prescribed work safely, and is legally able to perform said work; ♦ reporting to the Chief Engineer upon boarding the vessel, ensuring the Chief Engineer is aware of the number of persons boarding; ♦ at lay up or during periods of repair of lengthy duration or upon the request of the Vessel Manager, Chief Engineer, or authorised delegate, participating in a safety orientation session prior to the start of work; ♦ providing Workers' Compensation Board clearance certificates at the request of McKeil Marine; ♦ providing required licenses and/or certificates of workers and/or equipment relating to the work to be performed at the request of McKeil Marine ♦ reviewing the hazardous substance report supplied by McKeil Marine and advising sub-contractors and workers of all known hazards associated with the work to be performed; ♦ supplying sub-contractors and workers with written instructions of work to be performed when necessary; ♦ ensuring sub-contractors and workers have appropriate personal protective clothing and equipment that is properly maintained and are using said equipment in the manner intended; ♦ ensuring that all tools, materials, equipment and personal gear, not being used by workers, are stored in a manner and location as to not jeopardise the safety of personnel or interfere with the proper operation of the vessel; ♦ ensuring the removal, repair or replacement of defective personal protective clothing and equipment as required; ♦ reporting to the Chief Engineer, any incident involving personal injury, loss of life, or vessel damage or activities jeopardising the health and safety of any person on board the vessel; as defined in section 7 - “Incident Reporting” ♦ ensuring appropriate conduct is exhibited at all times by all sub-contractors and workers, and that workers and sub-contractors do not participate in pranks, practical jokes, feats of strength, or rough and boisterous activities that may endanger the safety of workers on board, or result in vessel damage; ♦ advising the Chief Engineer of completion of work and intention to disembark the vessel. 17.4 Safety Practices General To prevent accidents and eliminate adverse health effects, contractors, sub-contractors and workers require a thorough understanding of the vessel's physical structure, the nature of operation and any potential hazards associated with performing work on board. Contractors and their workers shall in no way interfere with the safe operation of the vessel, its machinery and equipment. From time to time, in the performance of their work, contractors may be required to dismantle or partially dismantle machinery, equipment or essential systems on board the vessel. Contractors shall not alter adjust, modify or otherwise tamper with any machinery, equipment, system or component of such system, (such as valves, controls and switches) without prior consultation with the Chief Engineer or authorised delegate. Under no circumstances shall contractors, sub-contractors or workers render inoperative any fire fighting, fire extinguishing equipment or safety device without prior approval of the Chief Engineer, or authorised delegate. Contractors shall notify the Chief Engineer immediately if such systems are inadvertently adjusted, modified or rendered inoperative. All workers performing work on board a McKeil Marine vessel shall take all necessary steps to recognise and protect themselves from the hazards outlined herein. When conflict arises between the guidelines imposed on the contractor by the contractor’s regulating body and these Guidelines, by agreement between the contractor and the Vessel Manager or Chief Engineer, the higher standard will apply.




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Personal Hazards and Safe Practices. Engulfment Engulfment may occur when a compartment being entered contains loose materials, such as grain or fine coal, or when pipes and supply lines pump materials, fluids or products into a compartment. All pipe lines accessing the compartment shall be locked out or fitted with a blank to completely block the flow of material and appropriate valves locked out according to McKeil Marine Lockout/Tag Out procedures. Moving Machinery Often compartments containing mechanical machinery must be entered for inspection or maintenance operations. Unexpected movement from mechanical equipment present hazards that may cause serious physical damage or loss of life. Energy sources (electric, steam, air, hydraulic, etc.) shall be isolated as required by the policies and procedures outlined in McKeil Marine Work Permit Procedures (Lockout/Tag out). Electric Shock Operations performed during maintenance and repair may require the use of power tools, electrical cords, welding cables, etc. Electric shock can result from faulty welding cables, electrical extension cords, and from energised machinery. Persons performing work shall do so in accordance with current Marine Occupational Health and Safety Regulations. Physical Hazards Compartments on board vessels often have narrow entrances / exits, blind accessibility by ladder, poor visibility, unfamiliar bottom and side structures, hot piping, machinery, and contain varying debris. All of these characteristics create an environment susceptible to slips, trips, falls and burns. Each of these events could result in serious injury or loss of life. Persons performing work shall do so in accordance with current Marine Occupational Health and Safety Regulations. Noise Grinding, cutting, and gouging operations, diesel engines and other machinery often produce noise levels above acceptable exposure limits governed by the current Marine Occupational Safety and Health Regulation, Canada Labour Code Part V, "Levels of Sound". Loss of hearing can impede the ability for workers to communicate with other workers and safety attendants or to hear alarms and/or warnings of danger. Appropriate hearing protection, meeting the standards outlined in current CSA Standards, must be used to reduce the level of sound exposure to 85 dB or less. If the sound exposure level in a compartment cannot be reduced below acceptable limits then a visual or non-hearing dependent communication system shall be established. Fatigue Workers may be exposed to extreme temperatures and may be required to maintain an uncomfortable position for extended periods of time. Either condition could cause workers to suffer fatigue. Persons performing work shall do so in accordance with current Marine Occupational Health and Safety Regulations. Heat Stress / Cold Exposure High temperatures and heavy, bulky protective clothing may result in personnel experiencing the effects of heat stress and low temperatures and winds may result in personnel experiencing hypothermia or cold exposure injuries. Persons performing work shall do so in accordance with current Marine Occupational Health and Safety Regulations.




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Materials Handling The lifting and moving of materials is required for most work performed on board vessel. Workers shall only manually lift materials that they are capable of lifting. The worker shall employ practical mechanical means to transport materials when the size, weight, shape, toxicity, or other characteristic of the material may be hazardous to health and safety. Shore Cranes and other lifting devices, where required by law, shall only be operated by persons having the appropriate qualifications and/or certification. Confined Space Entry Hazards Hazards normally associated with work on board a vessel are intensified in a confined space and the risk of accidents causing serious injury, loss of life, or vessel damage is greatly increased. All persons performing work in a confined space shall adhere to McKeil Marine’s Confined Space Safe Entry Practices Standard. No entry shall be permitted without authorisation and a valid Confined Space Entry Permit. Atmospheric Hazards Atmospheric Hazards are the primary cause of deaths in confined spaces. Atmospheric hazards are generally invisible and odourless. All workers shall have had training in safe confined space entry practices and procedures. Atmospheric hazards are categorised in four classes; oxygen deficiency, oxygen enrichment, fires and explosions, and toxic atmospheres. An oxygen deficient atmosphere shall be considered immediately dangerous to life or health (IDLH) when the oxygen content is less than 18%. Air may become oxygen deficient as a result of oxidation of metal (rust formation), fire, and displacement by gases such as nitrogen and carbon dioxide, or aerobic activity of bacteria present in sludge. An oxygen enriched atmosphere shall be considered IDLH when the oxygen content is greater than 23%. The main causes of oxygen enrichment stem from ventilating a confined space with pure oxygen instead of air, or from leaking oxy-fuel gas welding and cutting hoses and / or oxygen lines. Air containing flammable or combustible gases in excess of 10% of the lower explosive limit (LEL) shall be considered flammable or combustible and IDLH. The most common causes of fires and explosions in confined spaces are arcs or sparks from tools, lighting, welding/cutting operations, static electricity, smoking, and explosive gases emitted from sludge. Air containing toxic substances above the Threshold Limit Value (TLV) shall be considered IDLH. The most common sources of toxic substances found in confined spaces result from stored products, release of toxin inherent in a material through a hot work process, use of solvents and degreasers; toxins that may be present in adjacent spaces. McKeil Marine does not permit entry into a confined space unless the oxygen content is between 20% - 22%, the LEL is below 1% at the commencement of work and any toxic substances are below their TLV. Hazards Associated with Hotwork Hotwork operations are often required in the course of ship repairs on board McKeil Marine vessels. The hazards normally associated with hotwork are intensified on board a vessel due to confined spaces and the possible presence of flammable or explosive materials. All persons performing hotwork shall adhere to McKeil Marine’s Safe Hotwork Practices Standard. Hotwork shall not be permitted without authorisation and a valid Hotwork Permit. The following are some of the more relevant hazards and safe practices associated with hotwork. Burns Hotwork processes produce molten metal, sparks, slag, and hot surfaces that may cause severe burns. Persons performing hotwork shall avoid placing themselves in close proximity to these hazards. Contractors shall ensure that other personnel on board are warned of dangers in areas where hotwork has been performed to avoid injuries.




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Compressed Gas Cylinders, Pipes and Appliances High pressure gases and liquids, including steam, compressed air, exhaust gases, fuel and hydraulic oils if released can cause severe injury. Persons using, handling and storing compressed gas systems shall do so in accordance with current Marine Occupational Health and Safety Regulations. Fumes and Gases Hotwork operations generally produce smoke-like fumes and gaseous by-products. Persons performing hotwork shall do so in accordance with current Marine Occupational Health and Safety Regulations. Electric Arc Welding, Radiation and Chemicals Radiant energy consisting of ultraviolet, visible light and infrared radiation may originate from the welding arc or be reflected from other sources. Exposure may result in operator discomfort or skin burns. Persons performing electric arc welding tasks are to cover exposed skin and wear protective head gear. Persons performing hotwork may be exposed to chemical hazards resulting from anti-spatter compounds, fluxes, pickling solutions and gases formed from solvent fume. Hotwork operations shall not be performed in the presence of solvents of any type. Gaseous Fuelled Equipment In order to avoid oxygen enriched fires persons shall not use oxygen for cleaning or dusting off equipment and the cylinders shall not be handled by persons with oily hands or gloves. All equipment shall be checked and tested prior to use with persons following safe set up precautionary techniques. Persons lighting and extinguishing a gaseous fuelled torch shall do so in accordance with standard, accepted or regulated safe practices of the Port State. 17.5 Permit System McKeil Marine’s commitment to safety has led to the development of a permit system that, as a minimum, must be followed by all contractors performing work on board any vessel in the fleet. 17.6 Contractor Incident Reporting All workers shall promptly report incidents involving personal injury, loss of life, or vessel damage to their immediate supervisor. All incident reports required by McKeil Marine and governing laws and regulations are to be completed as soon as possible. Contractors shall report all “Disabling Injuries” to the Chief Engineer or shipboard delegate; this policy has been established to ensure that work place accidents, illnesses and injuries are reported and investigated in accordance with the requirements of the Canada Labour Code Part II, and the Canadian Marine Occupational Safety and Health Regulations. (Marine OSH). Contractors should report any “Minor Injuries” or “First Aid Injuries” that with similar circumstances could affect a vessel employee and/or those circumstances that the Contractor feels would benefit the loss prevention program. 17.7 Smoking, Alcohol, and Controlled Substances Smoking There are many areas on board a vessel where lighting a cigarette may provide the ignition source required to ignite a flammable substance. Smoking is not permitted in most work areas as indicated by no smoking signs. The Master, Chief Engineer, or authorised delegate reserves the right to ban smoking in all compartments and decks of the vessel; as is appropriate for the circumstance or cargo carried. Alcohol Alcohol consumption or possession is strictly prohibited on board every McKeil Marine Limited vessel. Persons on board a vessel shall not consume, nor be in possession of alcohol. Persons shall not board the vessel if deemed to be under the influence of alcohol and shall not carry any quantity of alcohol on




Date: June 1, 2013


board. Persons not complying with this restriction shall be removed from the vessel at the expense of the contractor and may be found guilty of an indictable offence, (Canada Shipping Act, Part III, Section 241). Drugs Use of, or possession of, any controlled substance or illegal drug is strictly prohibited on board every McKeil Marine vessel. Persons on board vessel shall not use, nor be in possession of controlled substances or illegal drugs. Persons shall not board the vessel if under the influence of drugs and shall not carry any quantity of these substances on board. Persons found in possession of or using controlled substances or illegal drugs shall be removed from the vessel at the contractor’s expense and may be found guilty of an indictable offence under the Criminal Code of Canada or that of the Flag State where the offence has occurred. Prescription Medication Persons taking prescription medication should be aware that many medications cause drowsiness or alter judgement. Persons shall not operate machinery or perform tasks requiring alert senses if taking medication that causes drowsiness, impairs or alters judgement.

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