Emergency Evacuation Plan

2. Introduction

Mahavir Bullion & Refinery Private Limited (“MBRPL” or the “Company”) acknowledges its responsibility to protect employees, contractors, visitors, assets and the environment during emergency situations. The refinery operations include hazards such as high-temperature furnaces, chemical processes including Aqua Regia, acid vapours, gas cylinders, electrical panels and valuable inventories.

This Emergency Evacuation Plan establishes structured procedures for responding to foreseeable emergencies quickly, safely and effectively. It is based on the Company’s existing Emergency Evacuation Plan and has been structured for RJC COP 2024 audit readiness.

3. Purpose

• Establish clear, step-by-step evacuation procedures for foreseeable emergencies.
• Ensure prompt communication and coordination during critical events.
• Protect life, health, property and the environment.
• Provide clear responsibilities for emergency response personnel.
• Ensure employees and other relevant persons are trained to respond calmly and appropriately.
• Provide a basis for emergency drills, incident review and continual improvement.

4. Scope

This Plan applies to all employees, temporary and contractual workers, contractors, job-workers, visitors, suppliers and transporters present within Company-controlled areas, including:

• Refinery areas including melting, Aqua Regia and assay operations.
• Acid handling and chemical storage areas.
• Furnace areas.
• Electrical and DG rooms.
• Security cabin.
• Offices, administration areas and staircases.
• Storage vaults and production floors.

6. Types of Emergencies Covered

• Fire or explosion, including electrical, chemical, furnace, paper/waste and gas-cylinder ignition events.
• Chemical emergencies, including HCl, HNO3 and Aqua Regia spills, toxic vapour release, scrubber malfunction and chemical reaction outburst.
• Medical emergencies, including burns, acid exposure, respiratory distress, cardiac arrest and injury.
• Security-related incidents, including lockdown situations, unauthorised entry, theft attempts during evacuation and bomb threats.
• Natural disasters, including earthquake, flooding and severe storms.

7. Emergency Response Committee (ERC)

The Emergency Response Committee shall coordinate emergency response and evacuation activities.

• Chief Emergency Controller (CEC) – Plant Head / Senior Manager: makes high-level evacuation decisions, coordinates external emergency services, declares “All Clear” and leads the post-incident review.
• Deputy Emergency Controller (DEC) – EHS / Safety Officer: supports the CEC, activates alarms and announcements, ensures evacuation routes are clear and oversees emergency equipment readiness.
• Floor Wardens: guide employees to exits, check designated areas, ensure no one is left behind and report evacuation/headcount status.
• First-Aid Team: provides medical support, assists injured persons and coordinates transport to hospitals.
• Fire Response Team: responds to fire emergencies within its training and safe operating limits.
• Communication & Security Team: manages communications, gates, assembly areas, emergency vehicle access and crowd control.
• Evacuation Guides: support orderly movement and provide assistance to persons requiring additional support.

8. Emergency Equipment & Infrastructure

• Fire extinguishers appropriate to identified hazards, including CO2, dry powder, foam and water types as applicable.
• Fire alarm system and smoke detectors.
• Fire hydrant/sprinkler system, where applicable.
• Emergency exit signage and displayed evacuation route maps.
• First-aid kits.
• Chemical spill kits.
• Eye-wash stations and emergency showers.
• PPE for trained emergency responders.
• Public address (PA) system and emergency communication arrangements.

Emergency equipment shall be inspected and maintained at defined intervals and in accordance with applicable statutory requirements.

9.1 Raising the Alarm

1. Any person discovering an emergency shall immediately raise the alarm by shouting the appropriate warning or announcing the hazard.
2. Activate the nearest manual alarm switch, where provided.
3. Inform the Safety Officer or Supervisor.
4. The Safety Officer shall activate the fire/emergency alarm, inform the Chief Emergency Controller and notify affected areas using the PA system or other available communication method.

9.2 During Evacuation

5. Stop work immediately.
6. Switch off equipment only where it is safe to do so.
7. Do not collect personal belongings.
8. Move calmly to the nearest safe exit.
9. Walk; do not run or push.
10. Assist injured, physically weak or otherwise vulnerable persons in accordance with the emergency plan.
11. Follow the displayed evacuation route maps and instructions of wardens.

Wardens shall guide employees, check designated areas such as washrooms, acid rooms and utility rooms where safe to do so, close doors without locking them where appropriate, and report evacuation status.

9.3 Assembly Area and Accountability

All evacuees shall gather at the designated external assembly point identified on the site emergency map.
Designated Assembly Point: Inside Main Entrance Gate, Adjacent to Security Office

• Conduct headcount using department attendance registers or another controlled personnel list.
• Identify and report missing persons to the Emergency Response Committee.
• Provide or coordinate first aid for injured persons.
• Await the “All Clear” from the authorised emergency controller.
• No person shall re-enter the affected area unless authorised.

10.1 Fire in Furnace / Melting Area

• Cut power supply where this can be done safely.
• Use the appropriate fire extinguisher for the identified fire type and only by trained personnel.
• Evacuate the furnace aisle/affected area.
• Maintain a safe distance and await emergency response instructions.

10.2 Acid Spill – HCl, HNO3 or Aqua Regia

• Move employees away from the spill and isolate the affected area.
• Activate emergency ventilation where safe and appropriate.
• Use acid-resistant PPE and spill-response equipment as trained.
• Use appropriate neutralising/spill-control material where available and authorised by the emergency procedure.
• Do not apply water directly to an acid spill unless the approved chemical emergency procedure specifically requires it.
• Evacuate the affected area if vapours spread or conditions become unsafe.

10.3 Toxic Vapour Release

• Trigger the alarm and notify the Emergency Response Committee.
• Move away from the affected area and, where practicable, move upwind or to the designated safe location.
• Shut down or isolate relevant systems only where safe to do so.
• Contact external emergency responders where required.

10.4 Gas Cylinder Leak

• Do not operate electrical switches or equipment where this could create an ignition risk.
• Close the cylinder valve only if it is safe to do so.
• Remove ignition sources where safe.
• Raise the alarm and evacuate/isolated the affected area as instructed.

11. Emergency Communication

• Emergency alarms
• Phone/message systems
• Radio/walkie-talkie communication

External communication shall be made by the responsible officer, as applicable, with:
• Local Fire Brigade
• Police Department
• Ambulance / hospital services
• Pollution Control Board for relevant chemical/environmental incidents
• Corporate Management

Emergency contact numbers shall be displayed prominently and kept current.

12. Training, Testing and Mock Drills

The Company shall communicate this Plan to relevant workers and conduct emergency preparedness activities. The existing Plan provides for:
• Fire drill – every 6 months.
• Chemical spill drill – annually.
• Evacuation drill – every 6 months.
• First-aid training – annually.
• PPE usage training – during induction and quarterly.

RJC COP 24.7 guidance states that evacuation drills should be conducted every six months and records should include the time taken to evacuate.
Records of drills shall include date, scenario, participants/attendance, evacuation time where applicable, findings, lessons learned and corrective/improvement actions.

13. Disability-Inclusive Evacuation

• Assign evacuation buddies or other appropriate assistance arrangements where required.
• Provide suitable evacuation assistance/equipment where needed.
• Ensure ramps, handrails and accessible routes are maintained.
• Prioritise appropriate support for persons with disabilities or other evacuation needs.

14. Post-Evacuation and Incident Review

1. Confirm headcount and identify missing persons.
2. Assist injured persons and coordinate medical response.
3. Control secondary hazards where safe to do so.
4. Evaluate damage and operational impacts.
5. Prepare an incident investigation report where required.
6. Identify contributing/root causes and lessons learned.
7. Implement corrective and preventive actions and track them to closure.

Health and safety incidents and near-misses shall be reviewed so that relevant hazard controls can be improved and recurrence prevented.

15. Documentation and Record Keeping

• Emergency drill reports and evacuation drill records.
• Training attendance and training records.
• Incident and near-miss records.
• Fire/emergency equipment inspection and maintenance records.
• Relevant Safety Data Sheets (SDS/MSDS).
• Current emergency response and evacuation plans.
• Headcount/attendance records for drills.
• Corrective action and improvement records.

Records shall be retained in accordance with the Company’s document-control and legal retention requirements. The original Plan specified a minimum eight-year retention period; this requirement is retained unless a longer applicable legal or Company requirement applies.

16. Policy Review and Continual Improvement

This Plan shall be reviewed at least once every 12 months and additionally:

• After any major incident or significant near-miss.
• Following significant changes to processes, plant, equipment, chemicals or site layout.
• Upon changes in applicable legal or regulatory requirements.
• Following emergency drills where findings indicate that changes are required.
• Following RJC audit recommendations or significant changes to RJC requirements.

Changes shall be documented through the Company’s document-control process and approved by the authorised approving authority.

17. Related Controlled Documents

• Staff Safety & Training Policy.
• Security Risk Assessment Policy.
• Natural Resource Use Policy.
• Hazardous Substance / Chemical Safety procedures, where applicable.
• Incident Investigation / Corrective Action records.
• Emergency Contact Register.
• Site Emergency Maps and Fire Safety Records.