Health & Safety Risk Assessment Policy

2. Introduction

Mahavir Bullion & Refinery Private Limited (“MBRPL” or the “Company”) is committed to providing safe and healthy working conditions for workers and visitors. This Policy establishes a structured approach for identifying hazards, evaluating health and safety risks, implementing controls, documenting assessments and reviewing their effectiveness.

This revised Policy is based on the Company’s existing Health and Safety Risk Assessment Policy. The original policy covers all work areas, processes, equipment and personnel and requires proactive, documented risk assessments, annual review, and additional review following significant changes, incidents, near misses or safety audits.

3. Objective

• Identify workplace hazards before they result in injury, ill-health, damage or unsafe conditions.
• Evaluate the likelihood and potential consequence of identified hazards.
• Implement effective controls using the hierarchy of controls.
• Assign responsibility and target dates for additional controls.
• Verify that controls remain suitable and effective.
• Promote continuous improvement in occupational health and safety performance.

4. Scope

This Policy applies to all work areas, processes, equipment and personnel at MBRPL, including:
• Permanent, temporary, contractual and outsourced employees.
• Supervisors, managers and department heads.
• Contractors, job-workers and service providers.
• Visitors entering operational areas.
• All shifts, refinery processes and support functions.
• Routine and non-routine activities.

6. Policy Statement

• MBRPL is committed to maintaining a safe and healthy working environment by identifying hazards and implementing effective risk control measures.
• Risk assessments shall be carried out proactively, documented and reviewed periodically and whenever significant changes occur.
• Employees and other relevant persons are expected to cooperate with risk-control measures, report hazards and follow safe work procedures.
• Health and safety considerations shall take priority over production or operational convenience where a material safety risk is identified.

7. Key Definitions

• Hazard: Anything with the potential to cause harm, including chemicals, machinery, energy sources, unsafe conditions or work activities.
• Risk: The combination of the likelihood of harm occurring and the severity/consequence of that harm.
• Risk Assessment: The process of identifying hazards, evaluating associated risks and determining appropriate control measures.
• JSA / Job Safety Assessment: A task-level assessment used to identify hazards and controls before high-risk or non-routine work.

8. Refinery-Specific Hazard Identification

Risk assessments shall consider hazards relevant to the Company’s actual operations. The existing Company assessment specifically identifies the following areas for consideration:

• Hydrochloric acid, nitric acid and Aqua Regia exposure.
• Toxic fumes and vapors.
• Furnaces, high temperatures and molten metal.
• Electrical systems.
• Machinery and moving equipment.
• Compressed gases.
• Chemical storage and chemical incompatibility.
• Material handling and lifting.
• Fire and explosion.
• Heat stress.
• Work at height.
• Confined spaces.
• Other significant operational hazards identified through site assessment.

10.1 Step 1 – Hazard Identification

1. Inspect work areas, equipment, materials and tasks.
2. Consider routine and non-routine activities.
3. Consider foreseeable abnormal and emergency situations where relevant.
4. Consult workers and supervisors who understand the task and work conditions.
5. Consider previous incidents, near misses, audit findings and reported unsafe conditions.

10.2 Step 2 – Risk Evaluation

The Company’s existing policy uses likelihood and consequence of harm and a Low / Medium / High risk approach. Site-specific risk criteria and scoring shall be defined in the approved Risk Assessment Form / Risk Matrix before assessments are conducted.

• Likelihood – how probable the hazardous event or exposure is.
• Severity / Consequence – the potential seriousness of injury, ill-health or other harm.
• Overall risk level – determined using the approved Company risk matrix.

10.3 Step 3 – Control Measures

Controls shall be selected using the hierarchy of controls:
• Elimination – remove the hazard where reasonably practicable.
• Substitution – replace the hazard with a less hazardous alternative.
• Engineering Controls – isolate people from the hazard through physical or technical measures.
• Administrative Controls – procedures, training, supervision, permits, signage and scheduling.
• Personal Protective Equipment (PPE) – use appropriate PPE where residual risk remains.

PPE shall not be treated as the preferred control where a higher-level control is reasonably practicable.

10.4 Step 4 – Documentation

6. Record findings in the approved Risk Assessment Form / Risk Assessment Register.
7. Record existing controls and the assessed risk level.
8. Identify additional controls required.
9. Assign a responsible person for each action.
10. Set a target completion date.
11. Record the status and evidence of completion.

10.5 Step 5 – Verification and Review

12. Verify that implemented controls are actually in place and functioning.
13. Review residual risk after additional controls are implemented.
14. Document findings and outstanding actions.
15. Escalate overdue or significant unresolved risks to appropriate management.

11. Risk Assessment Register

The following minimum fields shall be used for site-specific or department-wise risk registers, based on the Company’s existing format:

12. Frequency of Risk Assessments

• At least annually for all operations.
• Before introducing new processes, equipment, chemicals, materials or significant changes.
• Following any incident or significant near miss.
• Following significant safety audit findings.
• Following changes that could alter existing hazards or risk levels.
• Pre-task Job Safety Assessments for high-risk or non-routine work.

These requirements preserve the frequency specified in the Company’s existing policy while expanding the documented triggers needed for effective COP 24 implementation.

13. High-Risk / Non-Routine Work

• High-risk or non-routine activities shall undergo task-level assessment before work begins.
• Where required, work shall be controlled through appropriate permits, isolation/lockout arrangements, competent supervision and specified PPE.
• Workers shall be briefed on identified hazards and controls before commencing the task.
• Changes in task conditions shall trigger reassessment.

14. Worker Consultation and Hazard Reporting

• Workers shall be encouraged to report hazards, unsafe conditions and near misses without fear of retaliation.
• Workers performing the task should be involved or consulted where appropriate during risk assessment.
• Reported hazards shall be assessed and controlled according to their risk.
• Corrective actions shall be communicated to relevant workers.

15. Incident and Near-Miss Learning

• Health and safety incidents shall be investigated to identify contributing and root causes.
• Near misses shall be reviewed where their potential consequences could have been serious.
• Relevant risk assessments shall be revised following significant findings.
• Corrective and preventive actions shall be assigned, tracked and verified.

RJC COP 24.8 requires members to investigate health and safety incidents and feed the results into reviews of relevant hazard controls to prevent recurrence.

16. Training and Awareness

• Employees shall receive training on hazard identification techniques.
• Employees shall understand the purpose and importance of control measures.
• Employees shall be trained on reporting unsafe conditions and incidents.
• Assessors and supervisors shall receive appropriate role-specific training on conducting and documenting risk assessments.
• Training and attendance records shall be maintained.

17. Monitoring and Effectiveness

• EHS / Safety personnel shall periodically monitor implementation of identified controls.
• Open corrective actions shall be tracked to closure.
• Risk assessments shall be sampled to verify quality, completeness and control effectiveness.
• Trends in incidents, near misses, hazard reports and risk assessment findings shall be reviewed.
• Management shall take corrective action where the risk assessment process or controls are not effective.

18. Records and Document Retention

• Risk Assessment Register.
• Area / department risk assessments.
• Job Safety Assessments (JSA).
• Corrective action records.
• Incident and near-miss investigation records.
• Training and competency records.
• Risk assessment review and approval records.
• Evidence of implementation and verification of controls.

Records shall be retained in accordance with the Company’s document-control system and applicable legal requirements. RJC COP 2.5 requires records covering applicable COP requirements to be retained for at least five years or longer where national legislation requires.

19. Policy Review and Approval

This Policy shall be reviewed at least once every 12 months and additionally when there are significant changes in processes, equipment, chemicals, workplace conditions, applicable law or RJC requirements, or following incidents, near misses, audits or identified weaknesses in the risk-control system.

RJC COP 24.2(e) requires documented reviews at least annually to assess the ongoing suitability and adequacy of the occupational health and safety management system, verify control effectiveness and implement improvements.

Changes shall be documented through the Company’s document-control process and approved by the Board or other authorised approving body.

20. Related Controlled Documents

• Emergency Evacuation Plan.
• Staff Safety & Training Policy.
• Security Risk Assessment Policy.
• Natural Resource Use Policy.
• Grievance Redressal Policy.
• Incident Investigation / Corrective Action records.
• Emergency Response procedures.
• Chemical Safety / SDS records, where applicable.