HSQE System Manual - 01 Sep 2015

System Policies & Procedures o The fully equipped rescue team that will be on standby at the tank entrance for the duration of the restricted entry must be briefed o In all cases, the HSQE Department shall be contacted in advance to review the prepared risk assessment and provide concurrence regarding the adequacy of controls6.4.2.9 PaintingThe company considers spray painting and the use of two (2)component paints, such as Epoxy, in enclosed spaces to be extremelydangerous. Any painting in an enclosed space may lead to anatmosphere that is explosive, flammable, and, or toxic. Painting inenclosed spaces may only be carried out after risk analysis has beencarried out.The following safety guidelines apply when painting in enclosedspaces:• A Restricted Entry Addendum to the confined Space Entry Permit has been completed and all safety checks are satisfactorily complied with• Adequate forced ventilation to ensure the atmosphere does not become explosive or flammable must be provided• The crew assigned to the space has been specifically instructed with regard to hazards expected• Air line masks must be worn by personnel painting in the tank• Filter masks are prohibited• Lights and power tools must be pneumatic air driven type• Electric lights are prohibited when painting in confined spaces6.4.2.10 Personal Gas DetectorsThe use of personal type gas detectors is intended for monitoring ofambient conditions in the work place. The detectors are designed tobe carried in gas free spaces where unsafe conditions may occurControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 32 of 60

System Policies & Proceduresrapidly (e.g. petroleum cargo leak in a pump-room) and to give thewearer some notice and alarm of an oncoming danger. The use ofpersonal type gas detectors in enclosed spaces is for a person enteringthe space after it has been previously checked by remote sensingdevices and found safe for entry. The personal gas detectors are tobe set to alarm when atmospheric conditions deteriorate to unsafelevels warning the wearer to leave the space. The detectors are to becalibrated according to the manufacturer's instruction and prior toentry, the alarm is to be tested. Whenever pump-rooms or confinedspaces are entered, at least one person must wear a personal gasdetector that will alarm if low levels of Oxygen (less than 19% byvolume) or high levels of hydrocarbons (more than 10% of lowerexplosive limits) are encountered.When wearing personal gas detectors:• Keep away from the effects of own exhaled air• Carry so the sensor is not covered or blocked• Keep away from UHF radio as this may cause a false alarm• Refer to manufacturers instructions when in doubt6.4.2.11 Marking of Entry or Access HatchesAll vessels must assume that confined spaces, including cargo tanksand holds, ballast tanks and similar spaces are unsafe until provenotherwise.• All access points are to be marked with the following warnings on a yellow background with black writing o DANGER - LACK OF OXYGEN o DANGER – FLAMMABLE/TOXIC GAS (cargo tanks) o DO NOT ENTER WITHOUT PERMISSION OF CHIEF OFFICER• Access to holds and hatches are to be pad locked at all times and the keys are to be held by the Chief Mate. Therefore, the holds and hatches can only be entered with the Chief Mate's consent and knowledgeControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 33 of 60

System Policies & Procedures• Prior to entry into cargo holds, the atmosphere is to be checked for Oxygen, unless forced ventilation is permanently fitted• Prior to arrival, hold atmospheres should be checked and ventilated a short time before berthing6.5 Hydrogen Sulfide (H2S)To ensure safety in tanker and terminal operations, all personnelinvolved should be familiar with the following precautions whenhandling all cargoes and bunker fuels likely to contain hazardousconcentrations of Hydrogen Sulphide. Precautions are also beobserved during ballasting of cargo tanks, tank cleaning and gasfreeing operations associated with the carriage of previous cargoeshaving a Hydrogen Sulphide content.• Exposure levels in all work locations should be monitored by using suitable instrumentation for detecting and measuring the concentration of the gas. Detector tubes should be used if it becomes necessary to monitor a known high concentration. High concentrations and the corrosive nature of the gas can have a damaging effect on many electronic instruments.• Bunker fuel tanks should be monitored prior to, during and after bunkering. If H2S has been detected, the bunker tank should be periodically tested. Although the concentration in the vapour space can be successfully lowered by forced air ventilation, it often increases again when the bunker fuel is heated, transferred or agitated by other means. Bridge, control room, accommodation and engine spaces should be monitored if H2S may be present. Ventilation systems should be operated as far as possible to prevent H2S vapours entering the accommodation and engine spaces. A low concentration of H2S over time can cause discomfort to personnel.• The use of personal H2S gas monitoring instruments for personnel engaged in cargo operations is required. Warning alarm which should be set at a value not exceeding 5 ppm or the latest TLV which ever is less. Personnel should always carry personal monitors when working in enclosed spaces, gauging, sampling, entering a pump room, connecting and disconnecting loading lines, cleaning filters, draining to open containments and mopping up spills.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 34 of 60

System Policies & Procedures• In addition to being a health hazard, the H2S odour is also considered a public nuisance. Most local environmental regulations limit or ban the release of H2S concentrations to the atmosphere and this is, in any case, good practice. It is therefore necessary to maintain cargo tank pressures within acceptably low limits. The tank vapour pressure will rapidly increase if vapour space is exposed to heat or the product is agitated. Crude oil washing may rapidly increase the vapour pressure and should begin at a relatively low pressure and, preferably, while maintaining a relatively high discharge rate. • Respiratory Protective Equipment o Whenever high concentrations of H2S are likely to be present, Emergency Escape Breathing Devices (EEBD) should be made available to all personnel working in hazardous areas. They should be used in conjunction with a personal H2S gas monitoring/alarm instrument. o Personnel should be instructed to don their EEBD should their alarm activate and immediately leave the area to an upwind location. They should advise the central control location of the presence of a high gas concentration in order that appropriate procedures can be initiated. o Self-contained breathing apparatus should always be worn if it is considered necessary to breach the integrity of the cargo system and a vapour free atmosphere cannot be guaranteed. This would include the following activities:  Open gauging and sampling;  Removing blanks for connecting the cargo hose or loading arm;  Cleaning filters;  Draining lines to open containment; and  Mopping up spills. o Chemical cartridge respirators should not be used for protection against H2S vapours, as the vapour concentrations in theControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 35 of 60

System Policies & Procedures atmosphere may exceed the operational capability of the respirator being used.• Training is to be periodically conducted for crewmembers to highlight the hazards associated with H2S and the precautions to be taken to reduce the risks to an acceptable level. Daily Tool Box talks and MSDS sheets should be utilized to convey: o Safe operating procedures for all operations; o Gas testing/atmosphere monitoring procedures; o Maintenance procedures for cargo related systems; o PPE requirements; o Contingency planning; o Emergency response measures; o Measures to protect visitors from exposure.6.6 Winning with Safety Incentive ProgramIncentives are provided by the company as a means of encouragingand rewarding safe practices.• To provide crew with an incentive for safe operation and behavior based safety, SeaTeam has established a \"Winning with Safety\" Incentive Program to reward those who promote safety and maintain superior safety records.• The company will provide each vessel with a quantity of Safety Winner \"scratch and win\" type incentive cards to reward safe practices.• Each Safety Winner \"scratch card\" provides two chances to win cash prizes. Each card has an \"Instant Winner\" scratch box and a \"2nd Chance for Safety\" scratch box. The \"Instant Win\" scratch box provides opportunities for recipients to win CASH awards of $10, $20, $50, $100, $300, or $500 as an incentive for safe behavior. Winners are to be paid in cash by the Master after reporting the winning numbers to the HSQE Department.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 36 of 60

System Policies & Procedures• The \"2nd Chance for Safety\" scratch box which provides a second opportunity for recipients to earn $500 for the ship's welfare fund. Each 2nd Chance block when scratched will reveal one letter in the company name, S.E.A.T.E.A.M. Working together, the crew onboard may collect and compare cards with the objective to correctly spell SEATEAM. Each ship who manages to spell the company name will be awarded a $500 contribution to the welfare fund as a collective safety incentive.• Game cards will be distributed in bulk to all vessels in the fleet and periodically topped up as need be to maintain availability onboard. The HSQE Department is responsible to monitor game play and as onboard inventories of game cards are depleted over a 3-6 month period.• Each Vessel will be provided an inventory of scratch cards to be maintained and controlled by the Master. Cards are randomly shuffled and distributed by the company so that awards are completely random. Cash award distribution is controlled so that each vessel will have an equitable mix of winning cards.• Earning Incentive Cards - Cards will be awarded to crew members on the basis of both vessel and individual performance. o Vessel Performance - If the vessel has not experienced any LTI's in the previous 2 months every crew member serving onboard is awarded 1 Card o For Tankers, If the vessel has undergone a vetting inspection in the previous month with 4 or less observations and no high risk, every crew member serving onboard is awarded 1 card o For Bulk Carriers, If the vessel has completed a PSC with inspection in the previous month with 2 or less observations, and no detention, every crew member serving onboard is awarded 1 card o Individual Performance - Each Safety Committee, as chaired and guided by the Master, will select two (2) crew members, who have, in the previous month demonstrated superior commitment to safe working practices and has exhibited Behavior Based Safety on the job. Each \"Safest Crew\" nominee will be awarded 2 cards each as Safety Incentive. No winner may be a repeat winner in consecutive month and the two winners can not come from the same department.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 37 of 60

System Policies & Procedures o Each Safety Committee, as chaired and guided by the Master, will select the best \"CARE Card\" and the best “Non-Conformity Report” submitted for the month. The crew members who raised the selected reports will be awarded 2 cards each as Safety Incentive. No winner may be a repeat winner in consecutive month. • Issuance and Control of Incentive Cards - The Master shall issue cards to winners during monthly safety meetings. All winning cards and corresponding serial numbers are then to be reported to the company HSQE Department for control verification prior paying out the award values from cash onboard. o Incentive cards are to be publicly drawn during safety meetings o All cards in stock are placed in a plain cardboard box and the box shaken to mix the cards so that winning cards are randomly distributed throughout the box o Crew select cards one at a time while the box is held overhead by a senior officer o Winning values are individual awards and are not to shared among the crew6.7 HSQE / Quality Safety Campaigns• Safety Posters o Produced by the company to motivate achievement of the goals and targets established in the 5 year HSQE Plan.• Quality / Safety Campaign o Produced by owners to instill culture of safety awareness and understanding of “human factor” and its role in safety culture.6.7.1 Organizational Improvement IncentiveThe company will an annual basis, review and consider suggestions forimprovement submitted by staff, at sea or ashore, for awards of up toUSD 1000 monetary incentive, for practical suggestions that result in:• Improved efficiency in operations or cost reduction;Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 38 of 60

System Policies & Procedures• A measurable decrease in trends in incidents, break-downs, or non- conformances, or;• Significant improvement in customer satisfactionAt the end of each calendar year, management will review suggestionssubmitted for award eligibility. The best suggestions will be short-listed based upon the above criteria, and awards granted, dependingupon the benefit of the suggestions as judged by the managementteam. The resulting incentive awards (if any) will be mentioned in thefirst management review and news letter of each new calendar year. 6.8 Safety SignageThe company provides a standard set of safety signs and posters fordisplay aboard ship to highlight common hazards and promote safepractices. Safety sign inventory is specified on Master List 011. It is acompany requirement for safety signs to be posted in locations andquantities listed.6.9 House KeepingCleanliness and organization are essential elements in promotingsafety and health must be maintained in all spaces onboard. Thisincludes: • Laundry must never be hung out to dry on hand rails or on makeshift lines rigged in the passages. If sufficient dryers are not available, designated drying rooms are to be established until additional dryers can be supplied • Toilet areas must be kept clean, sanitized, and well stocked • The bridge, engine control, cargo control rooms must be kept well organized with systematic labeling and filing. Instruction manuals and publications should be inventoried and indexed • Galley and work-shop waste cans should be fitted with lids at all times o Waste paper bins in the accommodation bins must either have self closing lids or be of the self extinguishing type.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 39 of 60

System Policies & Procedures o All waste bins must be constructed of non-combustible materials• Infestations of roaches and rats must be prevented through good hygienic practices o Use of poisons for infestation control must be in accordance with manufacturers instructions and safety data o No poison may be kept in food or medicine storage areas• Store rooms and workshops must be kept clean and well organized• Cabins and common spaces must be maintained in a sanitary condition, clean and tidy o Masters must ensure a weekly cabin inspection is carried out to ensure that cabins are clean and well maintained o Showers shall have nozzles and kept operational o Toilets shall always be fitted with seats; broken seats are to be replaced as soon as possible o For safety reasons, squatting with feet on toilet seats is prohibited6.10 Identification & Sharing of Best PracticesMany times our crews may develop a new approach to a particulartask that results in the development of best practices in the way workis accomplished, either with a higher degree of safety or with greaterefficiency. Sources of best practices include employee ideas, and thehard lessons learned from painful and costly incidents.• The sharing of ‘best practices’ is the interchange of ideas between companies and individuals who may jointly benefit from smarter strategies. Ideas may be generated by clever crewmen who develop a better way of doing things or from incidents where the need to control hazards are highlighted to prevent recurrence. Industry forums provide a platform for sharing lessons learned as do safety alerts and bulletins distributed by the company or received from other sources outside the Company. The HSQE Department is responsible to filter information so that content isControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 40 of 60

System Policies & Procedures appropriate for dissemination within the company and/or for distribution externally to industry partners.• The intent of the company is to share information as far as possible, to progress safety, health and environmental protection throughout the maritime industry.• Sharing will be accomplished via Safety Alerts, Fleet Circulars, Seminars, and News Letters.6.11 Incident Reporting, Investigation and AnalysisAn Incident is defined as an uncontrolled or unplanned event, orsequence of events, that results in fatality or injury to Seafarersonboard, damage to property, loss of process or damage to theenvironment. Incidents involve People, Property, Process or Pollution.Response actions required for a particular incident depend upon itssignificance.• The Master is responsible to ensure all incidents are reported to the company in a timely manner with accurate details entered in ShipNet• The Master and Safety Officer are responsible to ensure all incidents are investigated by appropriate staff, and that adequate evidence is collected• The Master and Safety Officer are responsible to recommend recurrence preventive measures• The HSQE Department is responsible to accept or recommend additional recurrence preventive measures, track progress, and close reports when complete• Anonymous Reports may be submitted to the DPA by via private email: [email protected] Classification of IncidentsIncidents are classified by severity so that appropriate managerialfocus is placed on mitigating events with the greatest impact.Severity of consequence is rated on a scale from zero to five (0 – 5)with zero meaning no consequence (a near miss) and five meaningmassive effect with cost more than USD 10 MillionControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 41 of 60

System Policies & Procedures• Minor Incidents o Minor incidents are defined as those small injuries that may require first-aid but do not result in more that 24 hours of lost time, non-polluting environmental incidents such as leaks, material failures or break-downs that do not result in operational stoppage, and routine near miss incidents such as stopping unsafe acts o Except for navigational incidents, minor incidents are typically investigated by trained personnel serving onboard  Minor incidents are to be investigated by the ship's Safety Officer, with the supervision, oversight and concurrence of the Master.  Minor navigational incidents are to be investigated by shore based office investigators as if significant and will be subject to oversight by the management office and shore based investigators o Minor Incidents are those Rated 0 – 2 on the consequence scale, with zero being a no consequence near miss• Significant Incidents o A Significant incident is one that may not be classified as minor and requires a more extensive investigation. o A Significant incident is one where there is actual physical damage to in excess of US$100,000, or those incidents where material damage affects the seaworthiness or efficiency of a vessel, fire, grounding, collision with fixed or floating object, loss of life, Injury hospitalized or repatriated include environmental incident resulting in pollution o Significant incidents merit the direct involvement and will be subject to oversight by the management office and shore based investigators o Significant Incidents are those Rated 3 – 5 on the consequence scaleControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 42 of 60

System Policies & Procedures• Sub-Classification of Personnel Incidents o The company subscribes to the Oil Company Marine International Forum's (OCIMF) Marine Injury Reporting Guidelines, and sub-classifies all work related injuries accordingly o The OCIMF Marine Injury Reporting Guidelines are incorporated by reference and included in the ShipNet Incident Reporting Module for easy classification o Shipboard Management Teams are required to know and understand the sub-classification of work injuries, lost work cases, restricted work cases, medical treatment cases, first aid cases and ensure incident reports are properly classed o Incident statistics are monitored in line with the OCIMF guidelines so that safety awareness and training program can be evaluated by comparison of data to others in the shipping industry• Near Miss Occurrences o A Near Miss is an event, or sequence of events, which did not lead to an injury or any lost time but which, under slightly different circumstances, could have done so. A near miss is an incident, or occurrence that has no consequence.  On the Severity Scale Zero (0) and designated “Minor Near Miss” o A \"High Potential\" Near Miss is an event where only by extremely good luck was a serious accident avoided. High potential near miss incidents are treated and investigated the same as a significant incident with consequences  On the Severity Scale Zero (0) but designated “High Potential Near Miss”  High Potential Near Miss Occurrences are investigated as if a Significant IncidentControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 43 of 60

System Policies & Procedures o Statistically, there are supposed be 600 near miss incidents for every actual accident, but over reporting of insignificant matters can dilute important trends and is therefore not encourage. o A near miss report should detail an occurrence that is worthy of sharing of the lessons learned. o The company promotes the reporting of near misses as a means accident prevention and process improvement. o It is expected that each main department, deck and engine, should document a minimum of one near miss per month in line with industry averages o Near miss occurrences should be a standard discussion point during departmental and all hands meetings6.11.2 ReportingThe assigned Technical Superintendent is the first point of contact forall incident notifications and should be made verbally by telephoneimmediately or otherwise as soon as possible. Written follow-upnotification must follow within 24 hours of any significant accident,lost time injury, or high-potential near miss• Within 24 hours, or as soon as crisis response in under control, the HSQE Department will evaluated and determine if any urgent safety-related information should be transmitted and disseminated to the fleet.• It is important that all necessary information is passed on and thus an IMO Format written report should follow as soon as possible. o All Officers are required to know how to report incidents in accordance with the company' Emergency Contingency Plan o The written report should be submitted with details of the incident and any remedial action taken up to that point. o In all cases, Vessels' assigned office email is primary addressee of all Incident Reports.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 44 of 60

System Policies & Procedures6.11.3 InvestigationIncident investigation reports should be completed by responsibleofficers with no direct involvement in the incident and submitted tothe Master for review, corrections where/if needed, and forwarded tothe HSQE Department via the ShipNet Database.• The investigation report should include a detailed narrative and chronology of the incident. All relevant supporting evidence should be attached, including, where applicable: o Statement(s) of Fact (SOF) - are statutory requirements in the event of a significant accident and should include all details with relevant times, position, consequences, names of witnesses, etc. SOF’s should contain verifiable facts and no speculation. o Note(s) of Protest (NOP) - A ‘Note of Protest’ should normally be made to a third party to protect the interests of Principals. Notes of Protest should not apportion any blame but simply identify a point of concern. The NOP should mention that it is made “without prejudice” and that it is possible that there will be a reference back to this issue at a future date. o Copies of Log Book entries related to the incident o Copies of the following are required for all significant incidents as applicable to the events prior to and during the incident data event:  Deck Log book  ER log book  Movement books (Deck and ER)  Standing Orders (Bridge and ER)  Course Recorder  Echo Sounder (if appropriate)  Port Log (cargo operations)  Weather forecasts – Navtex or other as appropriate.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 45 of 60

System Policies & Procedures  Daily ‘log abstracts’  ER log printout from central logging system.  Photographs  Voyage Data Recorder (VDR) / Simplified Voyage Data recorder (SVDR) inclusive of the incident o Individual Statements. Statements from all involved personnel shall be taken as soon as practicable after the event. Ideally these statements should be made in isolation so that they represent the actual thoughts of the individual concerned as these statements are of great importance when trying to establish / verify ‘time lines’ after an incident occurs. o Individual statements should be handwritten and signed by the author.• Only trained investigators may conduct an investigation; the company will schedule other appropriate staff, where possible, to assist, so that practical experience in incident investigation is obtained• Investigations of minor incidents should be completed by the Safety Officer (if not involved) within 72 hours of occurrence• Investigations of significant incidents and high potential near miss occurrences should normally be completed within 2 weeks, although severe incidents may require more time for evidence gathering and analysis  The Senior Manager HSQE is responsible to monitor completion of investigations and may authorize more time if and when circumstances dictate• The investigation must determine: o What happened? o Who was involved either directly or indirectly? o What equipment, tools, materials were involved? o Who should provide witness statements?Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 46 of 60

System Policies & Procedures o Has anything been moved since the accident took place? o Damage and the injuries o Substandard acts or conditions o Job and personal factors o Immediate, basic, and root causes o If there was any violation of procedures and requirements o Any immediate action necessary to re-establish safe condition o Propose recurrence preventive measures to prevent the accident from happening again• Investigation reports should be reviewed by members of the Shipboard Management Team who are not directly in the incident o The SMT should verify the facts are correctly reported, causes fully identified, and that adequate preventive measures air proposed. o The ShipNet System is configured to require specific causation input for each incident• In the event of a significant incident, an HSEQ Department Investigator will take responsibility to verify findings, complete the investigation and submit the final report to senior management. o The company maintains at least two externally trained investigators on staff at all times so that appropriate personnel may be assigned o The shore investigation team will evaluate:  Fundamental operating practices  Adherence to the HSQE procedures  Compliance with international standards  The level of supervision and control providedControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 47 of 60

System Policies & Procedures  Adequacy of training and familiarisation  The suitability and reliability of any equipment involvedo Near Miss Incidents  Are investigated of the safety officer or master and, with the exception of high potential near miss incident, may be closed by the Master once the near miss incident has been discussed with the crew in a safety meeting  High Potential near miss incidents are to be reviewed by the HSQE department to determine is a further more detailed investigation is required  All CARE Cards submitted by the crew are to be recorded in the ShipNet database as a near missControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 48 of 60

System Policies & ProceduresFigure 6-11-1 Incident Response and Investigation Process IncidentSignificant Minor Near Miss Severity 3-5 Severity 1-2 Severity 0 Emergency Immediate Action Investigated byResponse Actions to Correct Unsafe Safety Officer High Potential NM Conditions closed only byAttend Priorities Conduct HSQE Investigation Safety of Life Provide What Happened Documentation Safety of Ship Persons Involved, Investigation Protection of the Report Environment Equipment / Area Statements of Request Environmental Witnesses Emergency Conditions Assistance Supporting Compliance with Documents / Complete Procedures & Notifications Requirements Photos Continuously Determine HSQE Department Update Office Immediate & Basic Review Crisis Team at Agreed Intervals Causes Additional Action or InvestigationConfirmation when Recommend Emergency is Preventative Confirm Under Control Preventive Measures Measures Close ReportControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 49 of 60

System Policies & Procedures6.11.4 AnalysisWhen the report to senior management has been completed, detailsof the incident shall be circulated to the fleet so that personnel maylearn from the incident so that lessons learned may help preventrecurrence.• Analysis of immediate, basic and root causes is a function carried out by the investigator during the investigation process; assignment of causes is verified by HSQE staff with approval authority.• All incident reports are entered into the company ShipNet database for statistical monitoring• Analysis of trends is undertaken on quarterly basis in conjunction with the quarterly management review.• Spikes in incident statistics will be monitored by the HSQE Department• Amendments to safety campaigns, audit focal points, or training programs may be highlighted when appropriate and needed to counter the impact of identified trends• The minutes or the management review and the incident trend analysis will be circulated to the fleet for review and action where appropriate.6.11.5 Close-outThe HSQE Department is responsible to ensure incident investigationsare completed properly, corrective and preventive actions completed,and the incident report closed out• Incidents will have closure indicated in the ShipNet database after approval of findings and actions6.11.6 Post Incident Drug & Alcohol TestingThe Master is responsible to conduct post incident testing of involvedcrew whenever a significant incident has occurred. If the Master isinvolved, a non-involved officer, preferably the Chief Engineer, is toControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 50 of 60

System Policies & Proceduresserve as a witness to the test. Testing should be conducted wheneverthere is:• Serious injuries to crew resulting in death or disability• Collision or Grounding• Assault with bodily harm• An incident where behavior indicates possible substance abuseVessels are to maintain post incident test equipment for both alcoholand drugs for use in such circumstances. If a positive reading isnoted, the affected crew should be the scheduled for confirmationtesting by a shore based laboratory.6.12 Emergency Drills and TrainingIt is the responsibility of the Shipboard Management Team to ensurethe crew is properly familiar with basic emergency procedures andhave the ability to operate emergency equipment as follows:• Emergency stations when the emergency alarms are sounded• Individual assigned duties• The procedures for raising the alarm• The action to be taken upon discovery of a fire or other emergency• The function of the emergency organization• Pollution prevention/mitigation equipment• The use of safety equipment (e.g. preparation and lowering of lifeboats, use of emergency fire pump and generator, etc.)• Closing down procedures (e.g. ventilation, fuel, etc.)• Rescue procedures (e.g. from enclosed spaces)• Ensure that officers are familiar with and can operate: o The emergency generatorControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 51 of 60

System Policies & Procedures o Emergency steering o The emergency fire pump o The lifeboat engines o Emergency Communications o Line throwing apparatus o Emergency towing arrangements6.12.1 Conduct & RecordingRegular emergency training and drills are designed to ensure that:• The crew is ready to react to contingencies and emergencies should they occur, to preserve their own lives and the safety of the vessel, environment and cargo• Emergency or contingency equipment that is ineffective or faulty is identified• The crew are able to demonstrate to PSC, Flag or company inspectors: o That all statutory training has been undertaken o Satisfactory response to emergency situationsHSQE Booklet 021 - Record of Drills, Training, Life Saving Appliances& Fire Fighting Appliances Maintenance, provides an annual schedulefor required drills and trainings. This record is to be maintained andkept up-to-date by the 3rd Officer and should be periodically reviewedby the Safety Officer and Master to ensure drills & Trainings areplanned and carried out as required. It is the Masters responsibility toensure any additional Flag or other statutory requirements notindicated therein, are carried out and recorded• The HSQE 021 LSA/FFA Maintenance Log has a Drill Schedule which should be used for planning purposes• It is the responsibility of the Safety Officer to ensure that the vessel is in compliance and conducts all required drills.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 52 of 60

System Policies & Procedures• The planning and conduct of emergency drills and training should be a topic of each monthly safety committee meeting.• Fire & Boat Drills should be photographed for objective evidence, and uploaded with month Safety Minutes in ShipNet6.12.2 Types of Training and DrillsAs long as specific drills fulfill statutory requirements, training anddrills may include:• Video training followed by discussion• Table Top Discussion with review of contingency plans and procedures• Demonstration of emergency equipment operation• Physical deployment of equipment• Full scale drills with simulated response o Equipment should be activated as far as possible o Crew should respond as if the emergency were real6.12.3 PlanningWhen planning drills and exercises the senior onboard managementteams are to ensure the requirements of the following are alwaysconsidered and incorporated where needed:• Flag State requirements• SOLAS Training Manual• SOPEP / SMPEP• Fire Training Manual• Ship Security PlanControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 53 of 60

System Policies & Procedures• OPA 90 Vessel Response Plan• Individual U.S. State Vessel Response Plans• Drills are to alternate between exercising the emergency organization procedures in simulated emergency conditions and training in the use and operation of Systems and equipment. Training is to be comprehensive, for those who carry out key contingency tasks and the use of substitutes and reserves.• Any equipment or machinery used during drills shall immediately be brought back to a fully operational condition with any faults and defects discovered rectified as soon as possible• After the completion of each training session or drill, a de-brief review should be conducted with all participating officers and crew to evaluate the effectiveness of the training and assess if crew are properly trained o Any resulting suggestions should be forwarded to the company in conjunction with the Master’s Review and marked as a Suggestion for Improvement• Every training session is to be recorded with all participants listed by name on the Training Record o The form should be signed by the Safety Officer or Instructor6.12.4 Life Boat Drills• Safety of Life is the first and foremost overriding consideration during boat drills• Each abandon ship / lifeboat drill is to include: o Summoning of passengers and crew to muster stations with the ships alarms and by drill announcement on the public address or other communication System o Reporting to stations and preparing for the duties described in the muster list o Checking that passengers and crew are suitably dressed and that lifejackets are correctly donnedControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 54 of 60

System Policies & Procedures o Lowering of at least one lifeboat after any necessary preparation for launching o Different lifeboats are to be lowered at successive drills if practicable o For the purpose of drills, the vessel must be stopped in water, anchored, moored, etc. before lifeboats and rescue boats are swung out over the water o Starting and operating the lifeboat engine o Operation of davits used for launching life rafts (if fitted) o Instruction and the use of radio life-saving appliances o Testing of the emergency lighting used for mustering and abandonment• Rescue boat crews must train to be able to prepare, launch and operate the rescue craft in an efficient and timely manner to effect retrieval of survivors• No dedicated seating positions are to be allocated onboard a lifeboat o During an operational life boat drill:  The Master must personally supervise boat dills to ensure safe conduct  The life boat must first be swung-out and lowered without any crew onboard  The lifeboat is then to be raised to the embarkation deck for boarding by a minimum operating crew and lowered to the water to demonstrate engine and sprinkler operation  In the interest of safety, manning during swing out should be avoided by all possible means  If the ship design is such that it is not possible to embark crew from other than the cradled position, the safety committee must devise alternate methods and procedures that allow the crew to embark the boat at a point where minimum stresses on lifting tackle will be incurredControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 55 of 60

System Policies & Procedures  If the embarkation deck is at a level where the boat will swing out and place maximum stress on the rigging, the operating crew should attempt to board either while waterborne via the embarkation ladder or if the curvature of the hull is too great, a boarding platform or other arrangement should be made to allow the crew to board from the davit deck after swing-out  The ‘assigned operating crew’ are to use suitable safety harnesses secured to a safe external location on the lifeboat (if practicable)  The use of \"fall preventer\" device is compulsory during lowering and hoisting with the crew on board.6.12.4.1 Davit Launched Life BoatsJSA Builder on-line risk assessment tool is to be used to account forspecific hazards and applicable controls required for each drill. Thefollowing sequence is suggested safe practice:• Step 1 o Boat is prepared with locks and harbour pins removed, gripes removed, painter run, etc. Fall Preventers fitted• Step 2 o Boat is lowered full speed (brake “wide” open) from stowed position until waterborne – NO CREW ONBOARD• Step 3 o Boat is heaved back to stowed position (or until limit switch is engaged)• Step 4 o Boat is lowered again full speed (brake “wide” open) from stowed position until about 3 metres above the water and brake closed “fast” to place as much force on the equipment as is possible – THIS IS A “CRASH” STOP TEST WITH NO CREW ONBOARDControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 56 of 60

System Policies & Procedures• Step 5 o Boat is heaved to boat deck where crew board• Step 6 o Boat is lowered from inside the boat using the lowering wire until waterborne• Step 7 o Once the boat is waterborne with crew inside then “weight” is taken on the falls and the boat heaved approximately 150mm (6 inches) so it is “just” suspended from the falls and not completely floating• Step 8 o On-load quick release is activated o If only one end lets go then the boat will come to rest floating at one end and suspended at the other and no crew will be injured• Step 9 o Boat is then tested waterborne o All officers, engineers and petty officers are aware if the cam setting for the quick release and one who is experienced is given the task of resetting the cam• Step 10 o Boat is re-attached to falls and lifted 1 metre where cam setting is re-checked and boat with crew are then lifted back onboard6.12.5 Fire DrillsFire drills are to be planned in such a way that due consideration isgiven to practice in various emergencies that may occur depending onthe type of ships and the cargo. Each fire drill is to include:• Reporting to stations and preparing for the duties described in the muster listControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 57 of 60

System Policies & Procedures• Starting of a fire pump and using at least the two required jets of water to show that the System is in proper working order o Different fire pumps are to be exercised at successive drills• Checking of fireman’s outfit and other personal rescue equipment• Checking of relevant communication equipment• Checking the operation of watertight doors, fire doors, fire dampers and main inlets and outlets of the ventilation Systems in the drill area o Chief Engineers are to personally inspect all fire dampers and confirm proper operation, the results of which, is to be recorded in the engine log o Junior Engineers are to be closely monitored in the weekly testing of fire dampers which should always be supervised6.13 LSA & FFA MaintenanceThe Third Officer is responsible for LSA/FFA Maintenance and mustensure that the intervals and maintenance routines specified in HSQEBooklet 021 - Record of Drills, Training, Life Saving Appliances & FireFighting Appliances Maintenance, are properly completed.• Maintenance should be performed according to manufacturers instructions, the SOLAS Training Manual, and the Fire Safety Operations & Training Manual6.13.1 Lifeboat MaintenanceFor safety reasons, the following recommendations for lifeboatmaintenance and drills are to be complied with:• The maintenance of lifeboat Systems is to be carried out by documented qualified personnel at dry-docks (or more frequently as prescribed by flag authorities)• During maintenance, the lifeboat is to be secured by Fall Preventers in accordance with flag requirementsControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 58 of 60

System Policies & Procedures• Painting of moving parts on LSA Systems should never be done• Corroding parts should be replaced as necessary and, or at specified lifetime intervals• Limit switches to be verified to be operating properly• Fuel tanks to be kept in a topped up condition• After any maintenance, life boat rigging must be tested• Testing or launching of the lifeboat should be performed always without personnel• The difference between mustering (no embarkation) and launching of lifeboat must be recognized and adhered to• To prevent parting of lifeboat falls or tackle, Chief Officers are instructed to personally verify the operation of all limit switches and to add checking to the weekly routine. Crews must be constantly reminded to use care when painting so as not to seize the roller or other moving partsControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 59 of 60

System Policies & Procedures Documentation & Filing o ShipNet Database o MSDS Sheets o SeaTeam Form No. HSQE 007 - \"Enclosed Space Entry Permit\" o HSQE Booklet 021 - Record of Drills, Training, Life Saving Appliances & Fire Fighting Appliances Maintenance o HSQE 030 - CARE Card o HSQE 008 - Hot Work Permit o HSQE 004 - Dangerous Work Permit o SOLAS Training Manual o Fire Safety Operations & Training Manual Distribution o All Offices o All Vessels References o OCIMF ISGOTT o Tanker Safety Guide (Chemicals) o MCA Code of Safe Working Practices for Merchant Seamen o OHSAS 18001 Health and Safety Standards o OCIMF TMSA o Flag State RegulationsControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 60 of 60

System Policies & Procedures7.0 Risk Management  Purpose o To detail standard operating procedures to ensure risks on board are correctly evaluated and properly managed throughout the organization  Application o Chennai Office o Singapore Office o All Vessels  Responsibility o Shore Management Team o Shipboard Management Team o Individual Staff & Crew 7.1 Management of Change Change management is a planning process to ensure intended changes do not result in unforeseen harmful consequences. When changes are properly planned, negative outcomes are considered in advance, so that controls may be established to mitigate the risk. • Change requests are to be entered in the ShipNet database in the Feedback Module for consideration and approval • Risk Assessments are used to review, pre-plan, assess, and manage changes when needed, and should be attached to the change request if applicable • Change Management applies to equipment, personnel, operations, procedures, materials or design whether the change is temporary, with a specific duration of effect, or permanent in natureControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 1 of 17

System Policies & Procedures• Changes are evaluated using Risk Assessment so that changes may be reviewed and managed by assignment of controls to ensure that risks remain at an acceptable level.• The following key considerations are to be evaluated and acted upon when and where needed and are encoded in the ShipNet MOC Module: o If documents or drawings require modification o If the change required by law or regulation o If approval from an outside authority required o If there are safety implications o If there are security implications o If there are Permit to work implications o If there are occupational health implications o If there are environmental implications o If statutory approval is required o If a HSEQ System amendment required o If there are training implications• Key considerations are to be addressed in the ShipNet Database where Change Requests are entered via the Feedback tab: o Identified training needs must be resolved in conjunction with the change as a basic condition for approval o MOC process is required for employment of key office staff o MOC process is required for promotion and hire of management level staffControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 2 of 17

System Policies & Procedures• It is the responsibility of the Shipboard Management Team to determine if a particular change should be the subject of a formal Risk Assessment• Temporary changes, such as taking critical equipment out of service, must have a specific time line indicating the duration of the effect. Should critical systems, alarms or equipment become defective, or require planned or unplanned maintenance, the temporary change, (such as taking critical equipment out of service), must supported by a Risk Assessment, and reported to the company together with the estimated time line indicating the duration of the planned effect o The Fleet Manager is responsible for review or Risk Assessments and approval any planned shut-downs of critical systems, alarms or equipment o For Bridge Equipment the Marine Manager must review the Risk Assessment and concur prior to any planned shut- downs of critical systems, alarms or equipment• A Risk Assessment is required for all changes that are not covered by existing approved procedures o Evaluation and procurement of fleet software systems• Approval to proceed is subject to the approval authorities given in the company Chart of Authority and/or in ShipNet user rights o Any change where a likely consequence is estimated to be intolerable, must be brought to the attention of the Technical Director and the Senior Manager HSQE o Any temporary change that exceeds the initial authorization for scope or time is required to be reviewed for re-approval by the appropriate level of management. o Requests for Change (MOC) may not approved by a person directly involved in the change.• Changes to HSQE procedures are not normally subject to a risk AssessmentControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 3 of 17

System Policies & Procedures o The need for permanent changes to procedures and instructions is to be communicated to the HSQE Department via email or through the ShipNet System as appropriate, and o All identified weak-points in HSQE procedures should be included in Master's Hand-Over notes7.1.1 Recurring ChangesThe company HSQE System has established procedures to ensureroutine operational changes are accomplished safely and inaccordance with established good practice. Anticipated changes aremanaged by HSQE System procedures (e.g. Change of NavigationalWatch, Bridge Checklist).• Recurring changes are controlled through the establishment of approved procedures, hand-over forms, checklists or systems to ensure expected hazards are adequately controlled7.1.2 Requesting Change• Change Requests should be submitted via ShipNet in the Feedback Module under the Suggestions and Complaints Tab, and ticked as a Change Request. The Technical Superintendent is responsible to monitor requests and should be given an indication of the planned time-frame and whether urgent or routine in nature o The Master is responsible to ensure the intended change has been adequately assessed and to ensure necessary supporting documentation is attached. o The Superintendent is responsible to ensure changes are approved in accordance with the Chart of Authority before the change is initiated.• For vessel design or equipment modifications, a risk assessment along with drawings of the proposed design is first submitted to the vessels superintendent for review and concurrence. If accepted, the proposed new design should then be forwarded to the Senior Technical Manager for “design” Approval. Once design is accepted from an engineering standpoint, the Change Request is forwardedControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 4 of 17

System Policies & Procedures to the HSEQ Department to verify that hazards are adequately controlled.• It is the Technical Superintendent's responsibility to monitor intended Changes before they are implemented and ensure the intended change has been correctly analyzed and all required controls are in place prior to commencement• If controls are not considered adequate at any level, the change request will be denied until adequately addressed.• All changes are to be documented in the ShipNet database for tracking and close out.7.1.3 Communication of Change• Changes to HSQE System procedures are communicated to Shipboard Management Teams through issuance of HSQE Circulars• It is the Shipboard Management Team's responsibility to ensure that any change affecting the operational integrity of the ship is communicated to the affected staff through the following means as may be appropriate: o Meetings o Announcement on the Public Address System o Log entries o Entries in the Standing Orders and Night Orders o Posted notices and warnings• Changes to regulatory requirements, codes or industry practices are tracked and evaluated at least annually during management review meetings to determine if any processes, procedures, equipment, or training need to be modified. Such changes will be communicated in the Minutes of the Meetings, which are disseminated throughout the organizationControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 5 of 17

System Policies & Procedures7.2 Risk Assessment & ControlThe Master and Shipboard Management Teams will constantly assessrisks, and take action as needed to control unacceptable risks. Inorder to ensure Risk Assessments are carried out in accordance withestablished best practices, the following main points are broadlyaccepted as an adequate means to assess risk and analyze jobhazards:• Identify a job or activity where a risk assessment is required• Separate the steps into sequential order as far as possible• Identify the hazards associated with each step• Using a standard scale, estimate the frequency and consequence of accidents caused the hazards• Calculate the Risk (Frequency X Consequence)• Refer to \"Action Codes\" on the standard risk matrix• Establish Hazard Controls where risks are not acceptable• Re-calculate Risk after all possible controls are considered• Establish contingency controls in case planned controls fail or if something should go wrong• If the final risk estimate exceeds tolerable limits, Stop.7.2.1 Hazard IdentificationThe Shipboard Management Team identifies hazards and possibleconsequences by using the collective experience of the crew involvedby employing a Hazard Identification process where the experience ofthose on board, can be questioned as to “what if” something goeswrong.• If the person carrying out hazard identification is confident that the task is relatively straight forward then they alone may carry out hazard identification. Where the hazards become moreControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 6 of 17

System Policies & Procedures complicated, the Shipboard Management Team (SMT) may need to contact the office for assistance o Identify if there may be death, injury or illness to people (e.g. crew, terminal reps, etc.); o Identify if there may be damage caused (e.g. ship, machinery, terminal equipment, tugs, etc.); o Identify if there may be environmental damage or pollution (e.g. ocean, land, fish, animals, birds, plants, etc.); o Identify if those carrying out the operations or who the task may fall to are experienced; o In the case of equipment identify if any manufacturers guidance is available; o In the case of hazardous material identify pertinent MSDS information (e.g. IMDG Code, etc.); o Identify if regulatory, company or industry standard procedures are already available.7.2.2 Risk EstimationRisk is estimated by those performing the Risk Assessment basedupon the probability and potential impact of accidents that they haveseen or are aware of through industry contacts and forums.• By approximating values based upon the experience of the individuals involved, risk may be estimated by referencing a standardized risk matrix• The standard risk matrix provided in Figure 7.2-1 below is derived from an ISO standard model as included in Det Norske Veritas guidelines.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 7 of 17

System Policies & Procedures• Figure 7.2-1 Standard Risk Matrix CONSEQUENCE INCREASING PROBABILITYSeverity People Property Environment Reputation 1 2 3 45 Rating Rarely Happened Has Happened Happened occurred several occurred several times several in times per in per year in times per Shipping year in operating operating year on the industry industry company company vessel0 No Zero Zero Zero Zero ACTION CODE \"A\" Cost injury damage effect impact ACTION CODE \"B\"1 <10K Slight Slight Slight Slight ACTION CODE \"C\" USD injury damage effect impact2 >10K Minor Minor Minor Limited USD injury damage effect impact3 >100K Major Local Local Considerable USD injury damage effect impact4 >1M Single Major Major Major USD fatality damage effect national impact5 >10M Multiples Extensive Massive USD fatalities damage effect Major international impact• Severity of Consequence x Probability of an Event = Actual Risk• To assess the risk of a given hazard, potential consequences to People, Property, Environment and/or company Reputation must be considered.• The assessed risk should be evaluated for possible application of additional risk control measures to render the risk as “As Low As Reasonably Practicable” (ALARP)• Risk Level Action Codes: o A = Acceptable Risk - Go Ahead o B = Moderate Risk - Additional Controls & Continuous Monitoring Required to render the risk ALARP o C = Severe Risk - STOPControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 8 of 17

System Policies & Procedures• If risk control measures can bring the risk to the ALARP condition, the job can be performed with a greater measure of safety, but the crew must continuously monitor and review during the activity to ensure the risk level remains within acceptable limits.7.2.3 Risk ControlUnless the initial evaluation reveals the task or activity in question isan acceptable risk, additional controls may need to be established toremove or reduce the risk, through: • Elimination or Avoidance of the hazard • Substitution of the dangerous aspect with something less hazardous • Modification of the activity so that the hazard is handled in a different manner • Isolation the hazards through Lock-Out Tag-Out Techniques • Provision of Engineering Controls (e.g. machine guards, nets, safety barriers) • Requirement for Back-up controls (e.g. Personnel Protective Equipment, and contingency plan is something goes wrong)7.2.4 Close-Out TargetsFor some tasks and activities (such as Hot Work or Confined SpaceEntry) the specific validity of controls put in place must be specified byindicating a definitive close out target. Close out targets shouldindicate:• The expected duration of the activity• Estimated date and time when all affected systems will have been restored and all personnel may resume normal operations• Close-Out Targets are to be estimated based upon the aggregate of all controls and remain in effect till the last control is liftedControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 9 of 17

System Policies & Procedures• For Planned Shutdown of Critical Equipment, any extension of time or alternate action requires review and approval of the Technical Superintendent• Changes not carried out within the proposed time scale are to be reviewed and revalidated• Risk assessments are to be discussed with the team involved in the task prior to commencement• Electronic copies of Risk Assessments are maintained in the JSA Builder On-line Risk Assessment Tool where the common E-Library is provided for experience transfer7.2.5 Risk MonitoringFor every job or activity, someone must supervise it's conduct.Normally prime responsibility falls to the department head, but as jobsare delegated to be carried out, responsibility to monitor the riskassociated with a particular job cascades down to the senior manparticipating. A Risk Assessment must include:• Assignment of a responsible supervisor o Responsible to monitor the situation to watch for risks occurring, new risks emerging, or changes in the assessment of existing risks o Responsible to confirm restoration of all effected systems, account for all involved personnel, and give the go ahead to resume normal operations o Responsible to report completion of the task and close-out to the Master7.2.6 When to Conduct a Risk Assessment• Risk assessments should be conducted or reviewed for all of the following: o All new or non-routine tasks and changesControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 10 of 17

System Policies & Procedures o Shutdowns of critical equipment o Changed environmental or operational circumstances o Permanent and temporary changes to equipment, personnel, operational environment or procedures o Abnormal Mooring Operations o Port Entry, Navigation in Restricted Waters, Transits of Panama or Suez Canals o Under Keel Clearance evaluations o Hot Work outside of Engine Room work shop o Confined Space Entry o Painting in confined spaces o Routine tasks that are frequently repeated o Other dangerous work• Risk assessments are to be documented and entered in the JSA Builder database as far as possible• Previously conducted Risk Assessments of a similar nature may be reviewed in lieu of conducting a new, redundant risk assessment, as long as the review is conducted with those assigned responsibilities participate in the activity, there is no significant difference in controls, and the review is logged in an official log book.• The JSA Builder Electronic library of Risk Assessments is designed and collated for routine situational use and reference. Specimen examples are available for a variety of activities and tasks. The JSA Builder library is periodically collated and reviewed for relevance by the HSQE Department• HSQE Department concurrence is required prior to commencement of any activity whose risk, when estimated after application of available controls, has been estimated to be “severe”.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 11 of 17

System Policies & Procedures• Under no circumstance is the job or task to be attempted until the risk is adequately controlled. o Figure 7.2-2 Simple Risk Assessment / JSA Flow Chart  The follow chart on the following page provides a simple overview of the Risk Assessment / JHA Process o Figure 7.2-3 Navigational Risk Assessment / JSA Flow Chart  The follow chart provides go / no-go guidance and overview for Bridge TeamsControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 12 of 17

System Policies & Procedures Figure 7.2-2 Simple Risk Assessment / JHA Flow Chart Identify the Task orchange to be undertaken Identify the HazardsAssociated with the Task or change Is there an Yes Review JHA/RA in a Existing Risk Yes Tool Box Meeting. Assessment or Are there any JHA? Unaccounted-for Significant Risks? No No Conduct JHA / Risk Assessment using“What If” Method” toDetermine what can Go Wrong IdentifiedHazards are controlledUndertake task of Monitor and Input Secure Job and change Improvements if Confirm Safe needed to Control Close-Out RisksControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 13 of 17

System Policies & Procedures Figure 7.2-3 Navigational Risk Assessment / JSA Flow ChartPort Entry, Departureor Critical Navigational MovementIs there a record of Yes Review Form OPS 047previous port call or to determine if transit in ShipNet? problems by other company vessels in same location Conduct JSA Risk Are There AnyAssessment to Control High Risk Situations Identified Hazards Evident? Identified Yes Yes Hazards Rendered Marine Tolerable Superintendent Yes Concurs with EstablishedPassage Plan Updated& JSA Discussed with Controls Bridge Team No STOP Contact DPA for AdviceUndertake Passage Monitor and Input Debrief and Improvements if populate Form OPS needed to Control 047 in ShipNet RisksControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 14 of 17

System Policies & Procedures• SeaTeam has contracted JSA Builder to provide a web-based JHA/Risk Assessment Tool that allows for easy creation, recording and sharing of a common JHA Risk Assessment Library. o All vessels and training offices should have received an e-mail with their log-in information and password which should be maintained by the master. o Use is of the JSA Builder web based JHA/Risk Assessment Tool is considered simple and self explanatory, though Shipboard Management Teams are to ensure every officer serving onboard is familiar. o Familiarization training is provided on-line by clicking the “Help” tab. Written instructions, a JSA Demo, and a Power Point Training Presentation are available and should be referred too when needed o Every existing JSA in the common library may be opened and edited by any user, making the common library a very useful foundation for anyone who must create a JHA / Risk Assessment. o Records may be exported as Adobe .pdf or MS Word Docs, to allow printing, posting, and sharing during tool box meeting. o JSA Builder offer two (2) formats for Risk Assessment that may be employed, depending upon the circumstances and user familiarity o Job Safety Analysis (JSA) – May be used as a convenient tool to assess and control risks for day to day tasks o Activity Hazard Analysis (AHA) – May be used when a more detailed Risk Assessment is deemed required, or for particularly dangerous, non-routine tasks. AHA provides additional information in way of:  Equipment, Training & Inspection Intervals  Identification of the Risk Action Codes for each stepControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 15 of 17

System Policies & Procedures o JSAs & AHA’s may be converted interchangeably within the JSA Builder Tool• JSA Builder may be used to create JHA/Risk Assessments for power tools and equipment (lathes, grinders, drill press, etc.), hand-tools, chemicals, painting, dangerous work, and work activities (mooring, cargo operations, bunkering, etc.)• The JSA Builder Tool may be used in-lieu of HSQE Form 033 as the Risk estimation scale has been harmonized to provide the same risk calculation. Users should refer to the scores and action codes listed on the log-in page which mirror HSQE Form 033. o For vessels without internet connection, HSQE Form 033 may still be used to accomplish completion of JHA / Risk Assessments. o All vessels with Internet connection are to use the JSA Builder Tool as the preferred method of conducting Risk Assessments as it allows experience transferControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 16 of 17

System Policies & Procedures Documentation & Filing o HSQE Form 033 Job Hazard Analysis Risk Assessment  E-File o JSA Builder – JHA/Risk Assessment  On-line E-File Common Library o Change Request  ShipNet Database Distribution o All Offices o All Vessels References o OCIMF TMSA o DNV Marine Risk Assessment o JSA Builder Web SiteControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 007RISK MANAGEMENT Approval: WBF Page: 17 of 17

System Policies & Procedures8.0 Health & Hygiene  Purpose o To detail standard operating procedures to promote healthy life styles and ensure a healthy working environment is maintained throughout the organization  Application o All Offices o All Vessels  Responsibility o Shipboard Management Team o Individual Staff & Crew 8.1 Individual responsibilities The company values the health of its staff and wants everyone to be able to live and work in a healthy and sanitary environment. It is the responsibility of the individual to attend to personal hygiene and look after their own health. Guidance and promotional materials are provided to all offices and vessels to encourage staff to recognize their individual needs and take personal responsibility for their health.  Personal cleanliness o Staff are expected to maintain good bodily hygiene  Sensible diet o The company will provide provisions for establishment of healthy menu on board o Appropriate portions of protein and carbohydrates for body sizeControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 1 of 28

System Policies & Procedures o Regular intake of fruits and vegetables Adequate sleep during rest periods o At least 6-7 hours daily is recommended for most individuals Regular exercise o Recreational programs should be encouraged on board o The company will provide recreation equipment to promote use Use of Alcohol and/or Tobacco o Consumption of alcohol onboard is prohibited o Smoking is restricted to authorized areas only o Smokers should be aware of possible adverse health consequences of passive smoke and restrict use in confined areas in consideration of any presence of non-smokers o Excess consumption of Tobacco is discouraged o Shore Contractors and Visitors must comply with Smoking Restrictions during their stay on board the vessel; Ship staff shall inform shore workers and visitors of the smoking restrictions verbally or by directing their attention to signage o The company will support any employee who wishes to cease smoking by providing a once-only sponsorship to a company approved program o The company will provide safety matches and suitable self extinguishing ashtrays. These are the only matches to be used on board; the use and possession of other cigarette lighters, and matches (other than the company supplied safety matches), is prohibited o Any cigarette lighters and matches brought on board, in ignorance of this requirement, are to be collected by theControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 2 of 28

System Policies & Procedures Master and held in a safe place until the owner departs from the vessel. o Carrying safety matches outside of the accommodation space is prohibited o Smoking is strictly prohibited in bed, alleyways, corridors, all storerooms including linen lockers and laundry rooms. o In the interest of safety and to promote hygiene, Master has the discretion to prohibit smoking in any other additional areas on board. o All of the above smoking restrictions are also applicable to any form of “E-Cigarettes” in case carried on board by individuals. Prompt attention to wounds o All small cuts and abrasions should be treated with antiseptic and bandaged where appropriate o Galley staff should not handle food if wounds become infectious o Any sign of infection should be brought to the immediate attention of the medical officer Prevention of Toxic Vapour Exposure o Containment is the first objective of handling Toxic cargo by making sure that they remain contained at all times. o Full chemical suit should be worn while attending operational activities such as manifold connections, ullaging, sampling, attending to accidental spills etc. o Use of breathing apparatus is essential if there is any suspicion of toxic gas in the area.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 3 of 28

System Policies & Procedures Prompt attention to Chemical Burns o Specific guidelines are given in IMGS and MFAG should be followed. In addition to risks from fire and electrical burns, Chemical may be absorbed through the damaged skin and cause further poisoning. o Use decontamination showers and wash off the corrosive substance with very large quantity of water. Remove contaminated clothing and shoes while taking shower. Use eye wash for at least 15 minutes. o First aider must wash and sterile their own hands and use only sterilized materials. o Cotton wool or other linty materials should not be used to clean the wound as it may likely to leave bits in the burn. o Do not puncture blisters o Small size Vaseline Gauge should be used with great care so that the dressing does not stick to the damaged flesh. Prevention of infectious diseases o Staff with cough and phlegm should report to the medical officer o Pandemic contingency plans are provided for vessels trading in areas where outbreaks have occurred Maintenance of protective equipment in good condition o Safety Helmets should be replaced after three (3) years of service life or earlier if damaged o Safety shoes should be worn as designed and never modified o Protective clothing should be discarded if degraded by chemical or other adverse exposuresControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 4 of 28