The company is committed to achieving high standards of safety and environmental performance and, as such, will ensure that all necessary resources are made available to achieve these goals.

We recognise that the nature of our activities may give rise to major accident hazards for employees, contractors, visitors, members of the public and the natural and built environment. We therefore have obligations to all these stakeholders to reduce the risks associated with such hazards to levels as low as is reasonably practicable.

In order to meet our obligations to our staff, customers, neighbours and other stakeholders, the company will provide and maintain a Safety Health & Environmental (SHE) Management System. This includes arrangements for the prevention of major accidents in accordance with the Control of Major Accident Hazards Regulations 2000.

The Company's aim in implementing this system is to reduce the risks associated with a major accident hazard to as low as reasonably practicable.

The SHE Management System (SMS):

• Identifies the roles and responsibilities of those involved in the management of major hazards, identifies and provides for their training needs and involves both staff and contractors.
• Systematically identifies and evaluates the likelihood and severity of major hazards which may arise at our sites.
• Implements procedures and instructions for safe operation.
• Implements procedures for the management of change to our operations.
• Identifies foreseeable emergencies and tests and reviews emergency plans.
• Monitors our performance in meeting these objectives.
• Provide for systematic audit, review and updating of the MAPP and SMS.

These criteria constitute a declaration of the Company's commitment to maintaining a safety management system.

The company's MAPP is based on the following legal requirements.

1. Factories Act 1955
2. Safety in Industry Act 1980
3. Seveso Directive 1986
4. Safety Health & Welfare at Work Act 1989
5. Dangerous Substances (Storage of LPG) Regulations, 1990
6. Safety Health and Welfare at Work (General Application Regulations, 1993)
7. Council Directive 96/82/EC on the control of major-accident hazards involving dangerous substances

2. Organisation, Personnel & Training

The company will ensure that:

• The organisational structure is appropriate to minimise the risk of a major accident and to minimise the consequences should one occur.
• All employees are made aware of the potential for major accidents and are trained, where relevant, in procedures needed to ensure that policy objectives are met.

In addition, all contractors' employees are made aware of the potential for major accidents and their responsibilities in relation to them. They are trained, where relevant, in procedures needed to ensure that policy objectives are met.

• All employees are aware of their responsibilities in the management of major accidents and are selected and trained to ensure that they have the necessary skills and experience to perform their duties. The responsibilities of management and employees for major accident prevention are set out in written procedures.
• All the company's employees have access to safety information. Employees and their designated safety representative have access to relevant safety information and to data on Material Safety Data Sheets.
• Feedback from employees is encouraged on major accident issues in the course of training and safety inspections. The company employees are also encouraged to make suggestions and raise specific major accident concerns, which they may identify during operational activities.
• The necessary resources are made available for training of management and employees in the prevention of accidents, including major accidents.
• Systems are in place to co-ordinate the SMS and ensure its effectiveness.

Responsibility for setting training schedules for employees and contractors lies with the Safety Director or his nominee and is responsible for ensuring that training is carried out in accordance to the training schedule.

Refer to SMS procedure on Organisation.

3. Identification & Evaluation of Major Hazards

The company's policy objectives are to ensure that:

• The levels of risk are reduced to 'as low as reasonably practicable' (ALARP).
• Major hazards arising from normal and abnormal operations are identified and their likelihood and severity assessed
• The identification and evaluation of hazards covers all phases of our operations including storage, product transfer and control of emissions to the environment.
• Hazard identification extends to evaluating the effects of events originating outside the site, including risks from abnormal meteorological conditions, flooding, power failure, seismic activity and from aircraft impact.
• Identification of major hazards, their possible consequences and prevention and control measures are detailed in the SMS.
• The results of such risk assessments are analysed and areas for improvement identified, prioritised and scheduled.

The responsibility for managing the process of hazard identification and risk assessment lies with the Safety Director.

Refer to SMS procedure on Hazard Identification and Risk Assessment.

4. Operational Control

The company's policy is to ensure that:

• The risk of incidents with the potential for accidental damage to people or the environment is minimised, by exercising control over all aspects of the company's operations.
• Operating Procedures including maintenance are adopted and implemented.
• Operating Procedures and Works Instructions are reviewed on a regular basis.
• Operating Procedures and Works Instructions are developed in co-operation with the people who are required to follow them. Responsibility for implementation of these systems on site lies with the Safety Director.

Refer to SMS procedure on Key Risk Control Systems – Operational Control.

5. Management of Change

The company's policy objectives are to ensure that:

• Procedures are adopted to achieve the Management of change objectives in respect of changes capable of affecting the control, of major accidents.
• Appropriate post change review procedures are defined and implemented
• Management of change covers both permanent and temporary changes and also includes urgent operational changes.
• Any new installations or storage facilities shall be installed in accordance with specific procedures.

Refer to SMS procedures on Key Risk Control Systems – Management of Change.

6. Planning for Emergencies

The company's policy is that:

• Operations are carried out in a manner, which serves to protect the community and the company employees from injury or illness and which avoids damage to the environment. This policy extends to protection from major hazards.
• An on-site emergency plan has been prepared and maintained, which details the required response of the company personnel in the event of a major accident.
• The emergency plan includes arrangements for contacting the emergency services and those people in the surrounding environment that might be affected.
• The relevant personnel are trained in their emergency response duties under the on-site plan, together with first aid fire fighting.
• The emergency plan is tested by means of regular exercises and other appropriate means.
• The company's co-operates fully with the local Fire Authority and other emergency services for emergency planning.
• The on-site emergency plan is reviewed periodically to ensure its continued effectiveness.

The Safety Director is responsible for ensuring that the testing and training schedule involving site personnel is completed.

Refer to SMS procedure on Planning for Emergencies.

7. Monitoring Performance

The company's policy objectives are to ensure that:

• Procedures are developed, implemented and maintained which actively monitor adherence to all safety procedures adopted in order to minimise the risk from major accident hazards. Active monitoring includes inspections of safety critical plant, equipment and instrumentation as well as checking compliance with training, instructions and safe working practices.
• All accidents and incidents capable of leading to a major accident are systematically reported and investigated. Investigations examine both the immediate cause of an incident and any underlying causes such as failure of procedures to protect against the occurrence.
• Corrective/preventative action determined by such investigations are recorded and implemented to a set deadline.
• The relevant manager holds responsibility for the completion of plant and vehicle checks and for the reporting of all incidents or "near misses". It is the responsibility of the manager to complete incident report forms, establish the causes of incidents and decide on possible actions.

Refer to SMS procedure on Measuring Performance.

8. Audit & Review

The company's policy objectives are to ensure that:

• The MAPP and SMS are systematically reviewed for effectiveness and suitability.
• Regular internal audits are conducted.
• Procedures are developed, adopted and maintained to audit the achievement of MAPP objectives.
• In particular, all relevant procedures are reviewed following any major accident or incident with the potential to escalate into a major accident.