In order to avoid damage to the safety and health of plant personnel or company finances due to hazards such as operations, activities or services and facilities, CSRC uses continuous safety and health hazard identification, risk and opportunity assessments to take appropriate preventive measures, implement necessary control methods, and eliminate hazards. By doing so, we control risks to an acceptable level and improve occupational safety and health performance. This risk management process includes risk identification, risk assessment, risk monitoring, risk reporting and disclosure, and risk response. The process follows ISO/CNS 45001:2018 management system specifications and guidelines for handling; and through regular internal and external inspections, we ensure the execution quality of the process (including the abilities of implementation personnel).
CSRC has implemented a comprehensive "Hazard Identification and Risk and Opportunity Assessment Operation." This initiative encompasses various aspects such as risk management policies, risk management organization, risk management processes, and risk management categories and mechanisms. The objective is to effectively control the risks arising from business activities. To prevent any potential harm to personnel safety and health caused by operations, activities, services, or facilities, and to avoid financial losses for the company, CSRC is taking proactive measures. These measures aim to ensure the safety and health of on-site personnel and to address opportunities for improving occupational safety and health performance at an early stage.
CSRC has established the "Safety and Health Hazard Identification and Risk Assessment Procedure" in accordance with ISO 45001 standards. This procedure actively identifies and assesses the hazard factors involved in various operations or services. All assessment personnel have participated in risk assessment training courses to ensure their competence and awareness. The assessment methods can be proposed by internal colleagues (including contractors) or external stakeholders to their unit supervisors. These proposals are then consolidated, reviewed, and tracked by the execution team for relevant improvement plans.
Furthermore, by establishing internal and external communication procedures, employees are involved in incident investigations and the determination of hazard risk assessments and control methods. This ensures that all employees, contractors, suppliers, and stakeholders are timely informed about the company's occupational safety and health and environmental policies, as well as the operational status of the management system requirements.
We have established processes for routine and non-routine occupational hazard identification and risk assessment based on the safety and health management system. This helps identify potential hazards and safety and health risks in each operational plant. Through hierarchical control, we clarify management strategies.
At the Linyuan Advanced Plant in the Greater China region, risks are categorized from 1 to 5, with level 1 being the most significant and unacceptable, requiring stringent control. The control methods determined after risk assessment include (a) elimination, (b) substitution, (c) engineering controls and work reorganization, (d) administrative controls including training/signage/warnings/ management controls, and (e) personal protective equipment. The control methods are considered in the priority order from (a) to (e) to determine the best control method, reducing the risk to an acceptable level.
In the China area, risks are categorized into three levels using a color-coding system. Every year, the main person in charge of the Company organizes a leadership team to conduct a comprehensive and systematic safety risk identification and assessment of production systems, equipment, facilities, and workplaces according to their respective duties. For significant potential hazards, assessments and evaluations are conducted with external experts. For daily risk assessments, the Safety Risk Control Leadership Team identifies new risk points arising from environmental changes or production process changes based on findings from comprehensive and routine inspections. The safety and environmental unit then update the risk point list accordingly. Employees who identify potentially dangerous tasks can refuse to perform such tasks under Article 32 of the Labor Contract Law and the internal "Three Violations Management System" without it being considered a breach of the labor contract. Employees are also encouraged to report violations and are rewarded for doing so.
In the India region, risk assessments and hazard identifications are conducted for all routine and non-routine operations, with control measures implemented to reduce or eliminate risks. At the CCET plant, incidents are classified into four levels: minor, moderate, major, and natural disasters, each with corresponding handling mechanisms. The plant also conducts regular internal and external audits to ensure personnel follow processes or SOPs for risk assessment and hazard identification, ensuring no deficiencies in these processes. Workers have the right to refuse or stop work if it is deemed dangerous, ensuring their safety.
In the US region, workplace hazard assessments are conducted and Job Safety Analysis (JSA) is developed as a preventive guideline. The occupational safety unit is responsible for comprehensive development and maintenance, with reviews at least every three years and updates as needed. Employees or contractors are authorized to exercise Stop Work Authority (SWA) and immediately report unsafe conditions.
Regarding risk management with contractors, CSRC aims to collaborate with them, emphasizing quality and scheduling. We require external contractors to sign agreements ensuring their understanding and cooperation with the company's risk notifications. The implementation focuses primarily on labor health, hygiene and safety, environmental and ethical standards, labor rights, and other aspects. This is to prevent and mitigate significant occupational health and safety impacts related to the Company's operations. This ensures that excellent suppliers can provide high-quality and stable raw materials, while engineering contractors can offer professional construction or supplement factory construction manpower shortages.
Process Safety Management (PSM)
To mitigate the impact on safety and the environment, and to effectively reduce process-related hazards, CSRC has implemented Process Safety Management (PSM) at the Linyuan Advanced Plant in the Greater China region. By 2024, the establishment of relevant systems, operational procedures, and training programs has been completed, including: Safety Critical Equipment (SCE) determination, standard operations, corrosion loop confirmation, MI procedure document discussion, process safety information training, key equipment maintenance planning MI - (Non-Destructive Testing (NDT) operation methods, ultrasonic testing operation procedures, radiographic testing operation procedures, liquid penetrant inspection operation procedures, distributed control system maintenance, electrical room equipment maintenance work, control valve maintenance work instructions, transformer maintenance work instructions, and will execute business and tracking mechanisms under the PSM (Process Safety Management) framework.
Key risk items and response measures at each operational site are as follows:
| Risk item | Description | Countermeasures |
|---|---|---|
| Oil spill | A pipeline instrument falls off and causes oil leakage, resulting in a risk of fire and explosion. | The instrument is inspected regularly to ensure its stability and normal functioning. |
| Hypoxia poisoning | Personnel inhaling harmful gas in the workplace and causing injury or death. Entering a confined space to perform hypoxic work, causing injury or death. |
The working environment is equipped with a carbon monoxide detection system for environmental monitoring, and personal protective equipment is provided and required. |
| Falling | There is a risk of workers falling if there is no proper protective enclosure for high-altitude operations. | We set up appropriate guardrails in accordance with relevant facility regulations, and require personnel to wear appropriate protective equipment. |
| Material collapse | The warehouse shelves for storing materials do not have relevant strength structural calculations. | We ask the structural technician to calculate and set up the relevant shelves according to the structural plan. |
| Mechanical operation accidents, such as Caught/in / Entanglement | Power equipment is not equipped with proper protection, and there is a risk of being caught and entangled. | Power equipment shall be equipped with relevant protective measures such as appropriate guards, gratings, two-handed operation, and interlocking devices. |
| Boiler explosions | Boiler operation abnormalities, pipeline ruptures, and failure to meet operating qualifications. | Establish boiler station safety operating procedures, install flammable gas leak detection alarms and image monitoring systems, and require certified personnel for operations. |
| Electric shock | Risks of electric shock, flash fire, ignition, or explosion when operating electronic equipment. | The power distribution room is to have a dedicated person responsible for management and regular inspections |
| High-temperature operations | There is a risk of fire if flammable materials are scattered in the area when high-temperature operations are carried out. | Before conducting high-temperature operations, remove all combustible materials from the area, and place fire extinguishing equipment. |
To protect employee health and prevent industrial safety accidents, all operational plants of CSRC comply with regulations to establish chemical management guidelines to reduce occupational safety risks posed by hazardous chemicals.
The Linyuan Advanced Plant in the Greater China region adheres to Article 10 of the Occupational Safety and Health Act and Article 17 of the Hazardous Chemical Labeling and General Knowledge Rules. The Safety and Environmental Protection Office is responsible for drafting and periodically updating the "Hazard Communication Plan.". All China-based facilities comply with the regulations set forth in the Law of the People's Republic of China on the Prevention and Control of Environmental Pollution by Solid Waste. This includes controlling and managing pollution from the use of oils and chemicals. Each plant has established "Chemical Management Measures" in accordance with the law to ensure that the workplace meets occupational safety requirements. This initiative aims to enhance employees' awareness of the potential hazards of hazardous chemicals and prevent accidents. All plants are equipped with fixed and portable alarm systems to monitor the presence of toxic gases and provide immediate alerts to ensure personal safety. Additionally, we conduct regular third-party monitoring of the working environment, focusing on both chemical and physical factors to ensure a safe working environment for all employees.
In India, chemical names are labeled in accordance with local regulations, and Material Safety Data Sheets (MSDS) are provided in both English and the local language to ensure the safe handling of chemicals and the safety of employees. The management of hazardous substances is conducted in compliance with the Factories Act of 1948, and internal guidelines are established. Additionally, relevant training is provided to employees and contractors.
In the United States, the Chemical Hygiene Plan and the Spill Prevention, Control, and Countermeasure (SPCC) Plan are developed based on OSHA procedures to ensure chemical safety.
Each production site manages chemicals according to the following key points:
| Items to be managed | Implementation content |
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| Hazardous chemical inventory management |
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| Safety Data Sheet management |
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| Hazardous chemical labeling |
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| Priority management of chemicals |
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| Management of precursor chemicals |
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| Management of dangerous factory materials |
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| Hazardous chemicals assessment and hierarchical management |
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| Hazard general education training |
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| Information management of types of chemicals in factories and warehouses and quantity configuration |
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Each operational site formulates key management items for chemical management as follows:
| Items to be managed | Implementation content |
|---|---|
| Purchase management |
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| Use management |
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| Storage safety |
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| Safety controls of inflammable and explosive chemical hazardous materials |
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