Pensar Environmental & Waste Management Plan

                                                           Environmental Management Procedure



       •   Monthly Project Compliance Audit (Q-FRM-004)
       •   Minutes of meetings, correspondence with client, authority and/or community representatives
           and/or diary notes as necessary.

  6.        Identify Environmental Aspects of Company Operations
  The General Manager/Director is responsible for review of the operations of the company as well as any
  relevant regulatory requirements and for identifying any environmental aspects that have potential to
  cause environmental harm.
  The Construction Manager or Project Manager is responsible for all project operations and for ensuring
  that any environmental aspects that have potential to cause environmental harm in accordance with
  clause 7 below are identified. Employees, suppliers and sub-contractors are included in these
  assessments as necessary.
  The Director / General Manager and HSEQ Manager are responsible for identification of any
  environmental aspects pertaining to all non-project operations of the company and for definition and
  implementation of control measures for minimising the potential for environmental harm from these
  operations.

  7.        Assessment of Risk & Potential Environmental Impacts –
            Projects
  The Construction Manager / Project Manager is responsible for ensuring that any employee given the
  task of identifying environmental aspects and their potential for causing environmental harm is competent
  and experienced in identifying them. The list of environmental aspects while prepared prior to the
  commencement of works can be added to at any time during the works following suggestions from staff or
  employees (e.g. following toolbox meetings, as a result of a regular site inspection, client/representative
  instructions). These assessments also consider any relevant regulatory requirements.
  If the project or site circumstances warrant, the Project Manager / Engineer shall engage e xpert
  assistance in identifying environmental aspects and assessment of their potential for causing
  environmental harm.
  Initial identification of environmental aspects and potential for causing environmental harm on projects
  sites is the responsibility of the Estimator – determination of environmentally responsible working
  methods is a key requirement in the process used to determine the tender price (for individual work items
  and for the overall project); this includes approval as warranted by the General Manager/Director or the
  Construction Manager.
  The Project Manager and/or the Project Engineer are responsible for ensuring that all projects are
  reviewed for possible environmental issues prior to commencement. This review forms part of project
  planning and is recorded in the Pre-start Checklist (WHS-FRM-004). This task may be delegated to an
  outside consultant if necessary.
  Risk Management Procedure (WHS-PRO-003) defines the approach taken for risk management in
  planning and execution of all projects. In particular, the Project Manager and/or the project engineer is
  responsible for identification of environmental aspects and potential for causing environmental harm, and
  for determination of control measures for minimising environmental harms well as activities for ensuring
  their effective implementation.
  The Hazard Identification Form (WHS-FRM-015) & Risk Assessment – Projects Form (WHS-RA-004) are
  used to assist with identification of all work activities that warrant implementation of control measures
  including the list of WMS and WPs to be applied. This form facilitates a planned approach to
  determination of the applicable WMS and WPs for all relevant work activities in a project, and is utilised in
  a manner that progressively shows the status of “sign-off” for each, including –
       •   Applicable Pensar and/or subcontractor WMS/WPs
       •   Any project specific WMS/WPs to be prepared
       •   Additional controls that are to be applied (usually forms/checklists in the Pensar IMS) – e.g. Sub-
           Contractor SWMS Compliance Review (WHS-FRM-040), Sub-contractor SWMS checklist (WHS-
           FRM-012), Permit to Excavate (WHS-FRM-010)



Document Number: ENV-PRO-001              Date: September 2018, REV: 4                             Page 5 of 11