Guideline / Manual23 .

Document number: IN-AH/A-IN-27647 Version: 1

Document status: Approved Valid from: 2016-05-23

LIPL Guidelines on disciplinary action for safety violation

and appreciation for good safety performance

Scope: India

page 1/11
Informative copy - no subject to the change management service - the valid and up to date version
is available in eMAX
Guideline / Manual

LANXESS IndiaDokumentennummer:

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Purpose of the procedure:

This procedure applies to ensure consistent implementation of the Life

Saving rules (LSR) and consistent application of appreciation for
excellent safety performance, disciplinary actions against LSR breaches
or any other safety violations within LANXESS India. The procedure
should be followed whenever a LSR Violation or LSR Breach is
discovered involving LANXESS employee, supervised contractor or
independent contractor employee.

LANXESS Life Saving Rules (LSR):

Rule:1

Work with a valid work permit

when required.

Rule:2

Use fall Protection while working

at height (more than 2 mtr).

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Rule:3

Obtain authorization before

entering a confined space.

Rule:4

Make sure moving machinery is

adequately guarded all the times
except during maintenance.

Rule:5

Check equipment is isolated

before work begins (LOTO).

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Rule:6

Obtain authorization before

disabling safety equipment /
interlock or safety system.

Rule :7

Follow the management of change

(MOC) for Process change,
Infrastructure and People.

Rule :8

Do the hazard assessment and

control the hazards (JSA) for
routine jobs and high risk non-
Risk routine Jobs.

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Rule :9

Conduct safe lifting operations.

Do not bypass interlocks.
Do not walk under suspended
loads.

Rule:10

Wear a seatbelt in motor vehicles

including material handling
equipment e.g. Forklifts etc.

Rule:11

Use proper PPE as per SOP (Area

mandatory and task mandatory).

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Rule:12
Do not use drugs and alcohol at
work.
Do not Smoke at Non-designated
places in the plant areas.
Do not use mobile at Non-
designated places in the plant
areas.

Rule :13

Follow the
Xact Follow the released X-act site
Standards standards.

1.

Rule :14

Maintain housekeeping in the work

area to avoid unsafe condition.

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Rule :15

Report all Incidents including near-

misses in LANXESS Incident
Incident Reporting System (IRS)
Reporting

Employee engagement and recognition:

While conducting safety dialogue if own or contractor’s employee is

found to be demonstrating good safety behaviors, no unsafe act or LSR
violations are found, then the concerned employee will be given safety
score on a scale of 1, 3 and 5 (1 being “needing improvements”, 3 being
“meeting expectations” and 5 being “exemplary”) and same to be
mentioned on the safety dialogue form. The safety dialogue data will be
tracked in the e-Byte including the safety scores. Safety scores thus
tracked, will be recognized at the end of every month by displaying a
photo of the safety champions both from the categories of own or
contractor’s employee having maximum score for the month on all Site
communication boards and inviting them to attend the site safety
committee meetings for explaining the good safety performance for
which they have been appreciated.

At the end of the year the employees from both the categories of own or
contractor’s having maximum safety score for the year or having won
maximum number of monthly safety championship will be awarded with
“Safety champion of the year” certificate and a reward of 10000 INR at
both the manufacturing sites.

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Definitions of a LSR Violation, LSR Breach and

Applicability of Zero Tolerance Disciplinary Action

A LSR Violation is the failure by an employee, supervised contractor, or

independent contractor to follow or comply with any LSR procedures.

A “LSR Breach” is a LSR Violation that results in a OSHA recordable

injury. Is intentional or repeated, e.g., where an employee, supervised
contractor or independent contractor is advised that a LSR Rule is being
broken but continues the activity or continues to disregard the rule
despite the rule being called to his or her attention. Subsequent non-
conformance with any LSR by a person whose behavior has already
been corrected, is also considered an intentional or repeat violation and
a LSR Violation is the failure by an employee, supervised contractor, or
independent contractor to follow or comply with any LSR procedures set.

Actions to be taken in the event of a LSR Violation:

If there is a LSR Violation at a site that is discovered after it has been
committed, the following procedure is used. These violations need to be
documented since the third time is considered as safety breach;

1. The line manager informs his or her manager, the HSE manager
and the site head
2. For first and second LSR violations, counselling will be done by site
HSE manager
3. For third time, violation will be considered as LSR or safety breach
4. If LSR violation has resulted in an incident or injury, the same will
be considered as LSR breach.

Confirmation of a LSR Breach:

If a LSR breach is confirmed, the site LSR team completes the LSR
breach documentation and site HSE Manager notifies the LSR country
team within 24 hours with a copy of the LSR breach documentation.
Preliminary investigation will be conducted by the site LSR team,
consisting of;

1. Site HSEQ head

2. PTSE representative
3. BU production / SIS head as the case may be
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4. Site HR head

A report will be submitted to the country LSR team for further decision.
The Country LSR team consists of;

 Corporate PTSE Head

 Corporate HR Head
 Corporate legal Head
 BU Head as the case may be
 Site Head

The Country LSR team will review the report and if LSR breach is
confirmed according to this definition, “Zero Tolerance” action will be
decided by the Country LSR team commensurate with the committed
breach taking in to consideration local legislation, where ever applicable.
Consequently, warning letter will be issued to the employee seeking the
reason for not adhering to the LSR rules. The disciplinary action may
extend to termination in case of the company employee by following
necessary legal process.

Based on the disciplinary action decided by the LSR country team, the
site Head Manager and site HR manager will formally notify the
employee in a face to face meeting and by written letter of the
disciplinary action and implement the same.

In the event that the LSR breach is caused by an independent

contractor, the site HSEQ Manager and the SIS Head along with GPL
representative should meet the representative/s of the contractor to
communicate the breach of Zero tolerance in writing which is to be kept
in the contractor’s safety performance records, and shall issue a notice
to the contractor demanding the appropriate action against the
concerned contractor employee.

For continuing business with LANXESS India, the contractor company

must (1) continue to maintain a good safe work history at the site (2)
continue to meet site safety standards, LSR guidelines and X-act
standards and (3) strive to meet targets like MAQ, OSHA recordable
incidents.

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Document information
Author: Harshada Bhade Date:
Reviewer: Neelanjan Banerjee 2016-05-20
Dr. Dattaprasad Talekar 2016-04-28
Namitesh Roy Chaudhary 2016-04-27
Approver: Jacques Perez 2016-05-23

Category in GML: Manual 00.01

Process references: -
Parent Documents: RL-0078 LANXESS - Compliance Management System

Other applicable documents: -

Superseded documents: -

Attachments: -
Changes to previous version: New Version

Version Template: 03

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Dokument number: IN-AH/A-IN-27647 Version: 1