Prepared by Umberto Frixione March 2010 - Foster Wheeler Italiana

HEALTH, SAFETY AND ENVIRONMENTAL POLICYWe demand a fully integrated approach to health, safety and environmentalmanagement in our offices, on site and at our clients' locations, in every countrywhere we provide our expertise, to ensure successful delivery of each project.We are committed to:• To ensure the highest attention and priority to health and safety of all FWIpersonnel and of persons who are involved in our activities.• To design, construct, commission plants in compliance with highest safetystandards and taking care of the environment.• Implementing and maintaining a Health and Safety Management Systemthat complies with relevant international standards.• Implementing and maintaining an Environmental Management System.• Complying with applicable legislation, together with relevant internationalstandards, codes of practice and client requirements in respect ofoccupational health, safety and the environment.• Supporting our employees by providing training and development of HSEknowledge and skills.• Promoting the benefits of a healthy lifestyle amongst our employees.• Reporting accidents, incidents and near misses and investigating fully toidentify lessons learned and prevent similar events from occurring again.• Defining for each activity/project the objectives to achieve regarding health,safety and environmental matter.• Minimizing in our activities the environmental impact and thepotentialpollution sources.• Qualifying suppliers and contractors making them aware ontheirresponsibilities regarding health, safety and environmental.No job task or service is so urgent that health, safety or environmentalrequirements should be compromised.Through the Prevention, ‘zero incident and zero occupational disease’ shouldbe the goal for all projects and operations.Authority for the implementation and effectiveness of the HSE Policy,Procedures and Work Instructions and for the HSE targets assignement and theirachievement verification is vested in the HSE & Q Committee.We shall continue to foster an atmosphere that supports these commitmentsand welcomes ideas that contribute to a safer workplace, protect the environment,and improve efficiency through an integrated system of continuous improvement.The success of this Policy is dependent upon the participation and cooperationof all employees.2

OBJECTIVES AND KEY ELEMENTSFWI has an HSE Management System to pursue the following objectives:• To safeguard the health and safety of all personnel whether Foster Wheeleremployees or employees of other's, or members of the general public.• To design plant that can be constructed, commissioned, operated and maintainedsafely, as well as demolished, without significant risk to any person involved andtaking care of the environment.• To carry out construction, commissioning, operating, decommissioning anddemolition activities safely and to minimise accidents, zero accidents being the goal.The FWI HSE Management System takes care of the following key elements:- FWI personnel- Design (in Engineering and Process activities)- Site (Construction, commissioning and start-up)FWI personnel Health & SafetyConcern all FWI personnel Health & Safety, wherever they are working.Specifically, the compliance with the laws which acknowledge the European Directive89/391/EEC (Risk Assessment, Prevention and protection measures plan, informationand training, fire prevention and first-aid, etc..) and with all the applicable regulationsconcerning FWI personnel safety.Design Safety and Environmental (in Engineering and Process Design activities)Control of the compliance with National Laws, International codes, Clients and FWIStandards, in order to integrate all the safety aspects during the design phase withreference to plant construction, operation, routine and extraordinary maintenance. Amongthe others, this will imply the study of likely incidental sequences and their consequencesthrough methodologies like HAZOP, Fault or Event Trees, Quantitative Risk Analysis, etc.Site (Construction, commissioning and start-up) Safety and EnvironmentalMainly, activities of Subcontractors co-ordination. In the European Countries specificcare should be paid to the laws which acknowledge the European Directive 92/57/EEC.Risk Assessment, Prevention and Protective measures plan for commissioning andstart-up phases. Organisation of a temporary safety system to guarantee theresponsibilities peculiar to these working phases.3

HSE SYSTEM MANAGEMENT CERTIFICATIONFWI has achieved the Certification both for Occupational Health and Safety ManagementSystem, in compliance with B.S. OHSAS 18001:2007 and for EnvironmentalManagement System, in compliance with ISO 14001:2004.Both certificates are included in the attachment D, that also includes Quality Certificate,in compliance with ISO 9001:2000.For each Management System a Coordinator has been appointed and a Manual hasbeen issued to describe the criteria and to indicate the procedures utilized by FWI toachieve and demonstrate HSE performance by controlling the impacts of the activities,products and services, consistent with the HSE Policy and objectives.4

RESPONSIBILITIESThe authority, responsibility and accountability for Health, Safety and Environment isviewed in the same manner as FWI business standards regarding quality,productivity, costs and schedules.IN FWI ALL RESPONSIBILITIES FOR HEALTH, SAFETY AND ENVIRONMENTALARE VESTED IN THE ‘LINE MANAGEMENT’.The Chief Executive Officer is primarily responsible for implementing, reviewing andauditing the Health, Safety and Environmental policy consistent with foregoingguidelines.A HEALTH, SAFETY, ENVIRONMENTAL & QUALITY COMMITTEE reviews theorganization’s management system, to ensure their continuing suitability, adequacyand effectiveness.Management at all levels of the organisation is responsible for ensuring that theHealth, Safety and Environmental Policy is implemented throughout their area ofresponsibility.For each project a specific HSSE Plan is prepared and implemented, under theProject Management and HSE Focal Point responsibility.During project operations, the assigned Project Manager is responsible for ensuringthat the HSE issues relative to the scope of work are effectively addressed in theProject Execution Plan (PEP).5

SPCIALISED FUNCTIONSThe “LINE Management” make use HSE specialised Staff functions that have thefollowing duties:HSE&Q DIRECTOR (General Co-ordination)1. Establish general guidelines for Health, Safety and Environmental and their coordinationin the various fields (FW personnel, construction, design,commissioning) - interpretation of the new laws and their enforcement.2. Define the principal HSE functioning rules of the System and verify the goodfunctioning of it.3. Be consultant for what concerns the health and safety of FWI personnel, whereverthey are working, i.e. carrying out the activities foreseen by the EEC Directive89/391 for the Protective and Preventive Service (Risk Assessment, Preventionand Protection measures plan, training and information, Emergency procedures,etc).4. Prepare and issue the HSE System Documentation.5. Help Commercial Department, particular in the proposal phase, in the definition ofthe Design Safety Project Scope of Work.6. Verify the implementation of new European Directive requirements.7. Verify that the Machinery Directive Dossier is executed and sign the declaration ofconformity.8. Guarantee that the HSE Design and Process Engineer’s activities, relevant todesign safety, will be performed.9. He is also the HSE&Q Management representative, with the followingresponsibilities and authorities:a) ensuring that processes needed for the HSE&Q management system areestablished, implemented and maintained,b) reporting to top management on the performance of the HSE&Q managementsystem and any need for improvement, and.6

HSE DESIGN & PROCESS MANAGERS1. Collaborate with Project Managers in drawing up and follow up the HSE Plansconcerning specific projects.2. Follow up the development of laws and regulations and assist Engineering &Process Department Managers, who are the ultimate responsible, in updatinginternal Work Instructions.3. Consulting and co-ordinating in writing, developing and updating safety proceduresduring design phase, in particular in compliance with new European Directivesrequirements.4. Interface with Client (both actual and prospective) for responding to its requests /concerns on HSE design matter relevant to FWI projects and proposals.5. Co-operate with the Project Teams for the permitting activities.6. Take part and / or provide the participation, when requested, in:Hazop; Risk Assessment; Plot Plan review; Internal or Client Model Review;Packages Review; Other Safety Design Reviews like: hazardous areaclassification, Fire fighting Systems, Fireproofing, PED classification, etc. asspecified in the HSE section of the Project Execution Plan.7. Visit the sites for a review during the construct phase and verify the Safety inDesign and the exhaustive and timing application of the European Directives.8. Take care over the documentation required by the law which acknowledges theMachinery Directive, cooperate during the preparation of relevant check list,according to the specific regulations, either when expressly required by the Clientor under Company’s decision.9. Assist Project Engineers and the specialities departments of activities related toEuropean Directive 97/23/EC (PED) and perform Hazard Analysis for PEDDirective.10. Receive the feed back from field of the completed projects concerning safety.11. Co-operate with the Commissioning Department and the Site Safety Offices forHSE activities in Commissioning and Start-up phase.7

HSE CONSTRUCTION MANAGER (also for Commissioning and Start- Up phases)1) Supervision of the Subcontractors’ performance concerning Health and Safety.2) Writing of general procedures relevant to the health and safety in field.3) Verification of the general trend of site injuries.4) In the European Countries specific care should be paid to the laws whichacknowledge the European Directive 92/57/EEC.5) In collaboration with the Commissioning Manager, planning of Health, Safety andEnvironmental matter during pre-commissioning, commissioning and start-upphases and verifying the activities on the following items:a) Risk Assessment and definition of a protection and prevention measures planduring pre-commissioning, commissioning and start-up.b) Definition of an emergency plan.c) Drawing up of the main safety procedures.d) Organisation of a temporary safety system to guarantee the responsibilitiespeculiar to these working phases.See in the ATTACHMENT A the organisation chart concerning the above-describedHSE Staff Functions.8

A General Procedure of the FWI Quality Management Manual describes the HSEManagement System.HSE detailed procedures, in compliance with Italian Laws and applicable EuropeanDirectives, in particular with “D. Lgs. 81/2008”, have been issued in order to cover thefollowing subjects:• Health and Safety of FWI personnel wherever they are working;• HSE Design (in particular with regards to the European Directives - Machinery,PED, etc - implementation);• HSE on site (subcontractors co-ordination).The detailed arrangements necessary to carry out the Company's policy, throughoutits multi-disciplinary activities are contained in the HSE Plans and Work Practices ofthe individual Divisions and Branch Offices.In FWI HSE System, every employee is accountable for their role in achieving theHealth, Safety, and Environmental objectives by proper implementation of FWIprocedures and Work Practices throughout the execution of their activities.For this reason, recruitment and selection focuses on obtaining personnel with therequired level of qualifications and experience which provides the required level ofcompetency.A qualified training plan is prepared.Personnel who start work in Foster Wheeler Italiana offices are provided with HSEInduction Training on arrival.Personnel who go to work on Foster Wheeler Construction Sites are provided withSite Induction Training.Foster Wheeler will pre-qualify sub-contractors to ensure that they are competent too,have sufficient resources, experience and a satisfactory safety record.9

HSE SITE MANAGEMENT ORGANIZATIONFWI HSE System takes particular care of the Site Safety Management (FWI has a greatexperience on this matter, supported with very interesting statistic results - see theATTACHMENT B).The principal specialist on this matter is the HSE CONSTRUCTION MANAGER (seeabove for his duties). Furthermore FWI Site Safety System provides for SAFETYSUPERINTENDENTS assigned to every sites: they are the local consultants of ourConstruction Managers and Supervisors.Daily inspections are performed by the Safety Superintendents who report to theConstruction Manager; periodically audits are performed by the HSE ConstructionManager, who reports to the HSE & Q DIRECTOR.The HSE Safety System is based on general and specific procedures and has acompany wide continuous improvement programme (also for these reasons thefollowing reactive measures of performance are taken: incidents and ‘near-misses’, losttime accidents, work days lost due to occupational health and injury).10

ATTACHMENT AHSE STAFF FUNCTIONS ORGANISATION CHART

ATTACHMENT BINJURIES STATISTICAL REPORT

ATTACHMENT CAWARDS

ATTACHMENT DFWI CERTIFICATES