Policies and procedures for Emirates Group Management
When serious accidents occur in our workplace / operations, these are often due to particular problems associated with the activities of Contractor personnel. Identified problems are mostly; inadequate training, insufficient instruction, unfamiliar work environment, unauthorized operation of equipment, working in hazardous/ high risk areas without following safety instructions / procedures, high turnover rates and poor communication.
The requirements of Emirates Group Document – Integrated Safety Management System (ISMS) include that Emirates Group Companies conduct their activities in such a way as to take account of the health and safety of their employees and of other persons. In compliance with the operation of Core elements of safety policy – Item 12 of ISMS document Page 30, the concerned department and the contract custodian of the company must ensure that contractors working for the Emirates Group Company apply health, safety and environmental standards and best practices.
The contractors are required to comply with all relevant standards and legislations in force in the country. If there are no state regulations for safety, health and environment in the country of operation, then the contractors must adopt the best practices established in the industry.
Emirates Group companies must consider the consequences of their contractor’s acts and omissions in terms of both legal liability and social responsibility in the fields of health, safety and environment protection. Being in the airline industry, the Emirates Group is seen as a responsible professional organization and the reputation of Emirates Group can suffer when associated with non-standard operations by Contractors.
It is very well established that the benefit from improved contractor safety performance is improved overall effectiveness and efficiency in the execution of the contractor’s work.
In general, the contractor has an independent responsibility for his own safety performance.
The objective of this guideline is to assist Emirates Group Companies / Departments by highlighting factors and suggesting standards and best practices, while selecting contractors, awarding contracts and during execution of work.
Although the contractual obligation for the safety of contractor’s work activity rests with the contractor himself, the Emirates Group Company Department – custodian of contract must ensure the contractor’s compliance with the standards and best practices.
This guideline does not cover the technical aspects of safety required for the job.
Types of Contractor
A contractor is any party, or company, or individual to whom the performance of certain work is contracted. The wide diversity of types of Contractors and contract arrangements implies that judgment will need to be used to assess the relevance and applicability of the factors highlighted in this guideline.
While considering the relevance and applicability, the following criteria should be considered.
The agreements to be entered into with the contractor.
The agreements fall into main groups such as
Project agreements, where the result of the Contractor’s work is a “finished product”
E.g., Construction work, refurbishing work, Electrical work, Fire Alarm system installation work, Installation of Company signage etc.,
Operational agreements whereby services are provided to any of the Emirates Group companies on an ongoing basis or one off, such as maintenance of facility or equipment e.g. elevators, escalators or other machinery, equipment / machinery leasing, cleaning, including exterior window - cleaning, transport – bussing services, manpower supply for baggage handling, cargo handling, loading and unloading services, driving, security services, transportation of personnel and material, outsourcing man-power supply for any activity etc.,
The principles of this guideline extend to sub-contractors, in the sense that the Emirates Group Contract custodian department monitors the contractor’s performance.
The size of the Contractor’s organization.
In some cases certain points in this guideline may not be applicable.
Selection of Contractors
When selecting a Contractor and awarding a contract three stages can be distinguished:
Tendering and Contract award
During Pre-selection, a contractors’ suitability for a specific type of work is assessed in a preliminary way. Safety should be one of the prime considerations in such assessment.
Pre-selection involves establishing a list of approved contractors. The contractors who are placed on this list can be invited to tender for a Contract, should meet a number of requirements, which can be checked by obtaining information on general, organizational and financial matters. The questions relating to safety must be included in any request for information.
Once the project is defined, the pre-qualification process takes place as part of initial tender process.
The safety requirements to be verified as part of this pre-qualification are detailed in a generic format in Appendix 1.
The information on safety requirements specific to the project should be requested.
Tendering and Contract award
The tenders submitted by the Contractor will have to include in the cost estimate of all items necessary for it to comply with safety, health and environment aspects. When one contractor specifies costs relating to safety and another does not, the Emirates Group Company custodian department can estimate additional cost to achieve the same standard and arrive at a comparable basis for both bids. Emirates Group companies should be cautious while awarding work to a bidder without regard to its safety performance and occupational health and environmental protection records. Short term apparent benefits of having the job done cheaply are liable to be offset by long term adverse effects.
The contract should have a separate clause dealing with the Contractor’s compliance with health, safety and environment requirements. A specimen of safety requirements applicable to work is given in the Appendix 2. This would apply to work on Emirates Group Company premises as well as to other places where the Emirates Group company interests are there.
For example, a transport contractor will need to comply with appropriate guides and best practices on road safety including driver training, defensive driving and emergency situation procedures.
The degree of training and supervision will depend on the type of work the contractor personnel will be involved in, type of work agreement, the location and duration of the job.
Where a new contractor is brought onto a work site / operational area, induction training should be held for its personnel, including supervisors, before starting work. They should be conversant with the activities being carried out in the vicinity and given a clear indication of the potential hazards.
It is essential that the training is given in the language of the Contractor personnel.
In the case of a transport contractor, drivers should be qualified to drive the vehicle prescribed and must have undergone defensive driver training by a suitable agency before they are placed on the job.
To emphasize the commitment of the Emirates Group Company management, it is recommended that the management team of the new contractor be given an oversight of safety requirements by Emirates Group Company line management. This briefing should include the Emirates Group Company’s policy on health, safety and environmental protection. Emirates Group Safety Department can assist in this regard.
On the Job Control
The contract should place the responsibility for supervision of safety of Contractor personnel on the contractor. Continuity of the Contractor’s supervision is essential in order to maintain the required safety standards.
Where contractors are engaged on a short term basis, or for a specific job, or for man-power supply, the requisite amount of department supervision / checking should be determined by local circumstances and the nature of the work.
Inspection and auditing are important means for monitoring Contractor safety.
Reporting and Performance Evaluation
For Emirates Group Company to assess its overall performance and to monitor the full effect of accident prevention measures, it is essential that the Contractor safety performance statistics are included.
It should be made clear to the Contractor that his safety record in terms of injuries and damage, as well as the efficiency of his reporting system, will be factors taken into account when new contracts are under consideration.
Contractor HSE Pre-qualification
The questionnaire should provide the information required to assess the extent to which HSE and its management is organized by the contractor.
The Contractor should cover all relevant activities not only of the EK Group Company works / site but also all other support activities.
The questionnaire should be revalidated by a responsible Contractor Project Manager prior to submission.
Complete answers must be provided and substantiated by supporting documents.
Submissions should be assessed by Group Safety with representatives of Custodian of contract work.
If necessary, discussion with the Contractors may be required.
The Contractor should identify where he exceeds company requirements or Local laws and this should be recogonised.
The Contractor HSE Pre-qualification is required for all types of contract whether it is a project agreement or operational service agreement.
Use additional sheets wherever required.
Questionnaire for Contractor HSE pre-qualification
Leadership and Commitments
Commitment to HSE through leadership
Describe the personal involvement of Senior Management in HSE management.
Provide evidence of commitment by all levels of the organization.
Demonstrate promotion of positive culture towards HSE matters.
Policy and Objectives
HSE Policy Documents
Does your company have a HSE policy Document? If yes, Please provide a copy?
Who has the overall and final responsibility for HSE in your organization?
Who is the senior most responsible person for the policy being carried out at the premises and on site or any other premises, where the employees are working / or supplied to EK Group Company?
Availability of HS&E policy statements to employees
Describe how policy statements are brought to the attention of all employees?
Describe arrangements made to advise employees of changes in the policy?
Organisation, Responsibilities, Resources,
Standards and Documentation
Organisation – commitment and communication
How are management and supervisor involved in HSE activities?
Describe how they manage and communicate HSE issues effectively?
Are HSE communication meetings held, if yes, how often?
Are there nominated HSE Advisers or representatives?
Competence and HSE Training – Managers / Supervisors; HSE Advisers
Do the HSE Managers and Supervisors possess HSE qualification?
Have the HSE Managers and Supervisors received formal training?
Have the managers, supervisors received formal HSE training?
If yes, is the training is in-house or outside - Provide course content and duration
Competence and HSE Training – Employees
What arrangements does your company have to ensure that new employees have knowledge of basic industrial HSE and up to date?
What arrangements does your company have to ensure that new employees have knowledge of your HSE Policies and Practices?
What arrangements does your company have to ensure that new employees have been instructed and have received information on specific hazards arising out of nature of activities? What training do you provide to ensure that the employees are aware of company requirements?
How have you identified areas of operations requiring specialized training to deal with potential hazards? List the areas / operations and training provided
If the specialised work involves Radioactive, Asbestos, Chemical, and Scaffolding,Working at height, long hours of driving or other occupational Health hazards to employees/passengers/ public, how are the hazards identified, assessed and controlled?
Does your company have established Hazard identification and Risk assessment procedure? If so, furnish details.
Assessment of suitability of sub-contractors / other companies
How do you assess HSE competence of sub-contractors?
How do you assess HSE record of the sub-contractor / companies with whom you place contracts?
Where do you specify your HSE standards to be met by your sub-contractors?
Describe how these standards are met and verified?
Standards and Procedures
Where does your company spell out HSE performance standards that are required?
How do you ensure that the standards are met and verified?
How do you identify the regulatory standards or the best practices applicable to your activities?
Describe the organisational structure for producing, updating and disseminating standards and procedures?
Hazards and Effects Management
Hazard and Effects Management
What are the techniques used within your company for the identification, assessment, control and mitigation of hazards and effects?
Exposure of workforce to chemical and physical agents
What systems are in place to monitor the exposure of your workforce to chemical or physical agents?
Storage, Handling, Transportation and Use of Chemicals, Noise, Vibration, Radiation etc.
Describe the arrangements made to advise workforce on potential hazards from sources encountered during the work?
Personal Protection Equipment
What arrangements does your company have for provision and issue of Personal Protective Equipment for regular activity and specialised work activity?
Drugs and Alcohol
Does your company have drugs and alcohol policy?
If so, does it include testing procedures?
Environment and waste pollution
Does your company have an environment and waste policy?
What are the arrangements for identification, classification, minimization and management of waste?
Planning and Procedures
Manuals – HSE or Operation Manuals
Does your company have HSE Manual or Operations Manual covering HSE working practices relating to work activities?
How do you ensure compliance with HSE Manual or Operations Manual?
Equipment Control and Maintenance
Describe the arrangements made for:
Control on use of equipment
Maintenance of Equipment in safe working condition
What arrangements does your company have for control of road and vehicle accidents?
Does your company have a Driver Training program that includes defensive driving?
If so, do they have pre-placement and refresher training?
Implementation and Performance monitoring
Management and Performance Monitoring
What arrangements does your company have for supervision and monitoring of performance?
What are the types of performance criteria used in your company?
What are the arrangements made for communication to management and other employees?
HSE Performance Awards
Has your company received any awards for HSE performance?
Has any of your employee received award for HSE issues?
Notifiable accidents/ incidents / dangerous occurrences
Has your company had statutory notifiable accidents/incidents/ dangerous occurrences in the last Five years?
What are the follow-up preventive measures taken?
Records of incidents
Does your company maintain records of accidents with details of lost time
Does your company identify any occupational disease among your workforce? If so, please furnish details
How are environmental issues / performance recorded?
HSE Legislation Compliance
Has your company been issued with notices by regulatory authorities or been prosecuted under any Safety, Health and Environmental issues?
Incident investigation and reporting
Who conducts incident investigations?
How are findings of investigation communicated to Department and employees?
Are Near-miss incidents reported?
Auditing and Review
Does your company have HSE Auditing in practice?
What are the criteria adopted for auditing and competence / qualifications of auditors?
Does your company have audit schedule?
How is the effectiveness of audit verified?
Who does management reporting and follow-up audits?
Describe your Company’s participation on HSE matters in industry level or government agencies?
Additional information of your HSE management
Safety Requirements Applicable to the Work
1. The Contractor shall in the execution of the work be fully responsible for compliance with:
i. relevant local, national and international laws and regulations;
ii. local, national and international standards or codes of practices and best practices on relevant subjects
Emirates Group’s safety requirements.
2. The Contractor shall be fully responsible of its personnel to ensure that they strictly adhere to all applicable safety requirements.
The Emirates Group Company Department may, if it so wishes, advise and monitor specific contractor personnel, such as forklift or any other equipment or machinery operator, driver for cabin crew / passenger bus etc. under manpower supply contract. The Contractor personnel shall demonstrate their ability and skills relative to their qualifications, experience and training in the field.
The Contractor and its Sub-contractor shall at his own expense ensure that all his personnel have been given the necessary safety and job related training required by law, as well as Emirates Group company requirements.
The Contractor shall inform the Emirates Group Company custodian department, of the names of Sub-contractors and their acknowledgement to comply with the safety requirements.
The Contractor shall ensure that Sub-contractors be informed of, and have opportunity to participate in, the safety activities required by the Emirates Group company department.
The Contractor shall regularly check Sub-contractor’s compliance with safety requirements.
Safety Awareness /Safety Meetings
1. The Contractor shall be responsible for maintaining and enhancing the safety awareness of his personnel and sub-contractor’s personnel, including arranging safety meetings.
Reporting and investigation of Accidents
The Contractor shall have an accident reporting system acceptable to Emirates Group.
2. The Contractor shall investigate all accidents and dangerous occurrences and advise the measures taken to prevent reoccurrence of similar accidents in the Emirates Group company work site or operational area.
Occupational Health and Hygiene
The Contractor shall be responsible for the work-related medical welfare of his own and
Sub-contractor personnel and shall provide for:
first aid facilities in work sites
periodical medical examination where required
arrangements for professional medical treatment
Personal Protective Equipment
The Contractor shall ensure his personnel and Sub-contractor’s personnel are equipped with adequate clothing and equipment, as required in connection with the safe performance of the work. The personal protective clothing and equipment shall be maintained in good condition, and shall be worn as indicated in instructions, notices, safety regulations and best practices.
The Contractor shall pay due regard to the environment to protect it from adverse effects of the contractor’s activities. The waste disposal procedures prescribed by local laws shall be followed.
Alcohol and Drugs
When required, the contractor shall establish an Alcohol and Drug Policy and implement the same.
Technical / Safety Audit by Emirates Group Company
The Contractor shall allow the Emirates Group Company’s representative or any other person nominated by the company access at any time to premises, plant, and equipment, personnel records when requested, to enable Emirates Group Company to inspect or audit any aspect of contractor’s / sub-contractor’s operations relevant to safety, health and environment.
The contractor shall conduct Risk Assessment of all operations including sub-contractor’s work and establish the control measures required to mange the risks. The Contractor shall establish a system of checks and audits to ensure that the work is being performed in accordance with the safety requirements applicable to the work.