CONTRACTOR COMPLIANCE

1.0 DISTRIBUTION
All Departments
1.0 APPLICABLE DOCUMENTS
INA-03-001 Environment, Health and Safety Policy
INA-03-003 General Plant Safety
3.0 APPLICABLE FORMS
INA-03-003-01 Avoid Verbal Instruction Slip
INA-03-007-01 Hot Work Permit
INA-03-007-02 General Work Permit
INA-03-017-01 Confined Space Entry Permit
INA-03-008-01 Accident / Injury Report
INA-03-008-02 Learning Incident Report
4.0 APPLICABILITY
This procedure applicable to Xxx India Pvt Ltd, Xxx Plant
5.0 PURPOSE
To establish procedures to be complied by contractors.
6.0 SCOPE
To ensure that outside contractors follow all the statutes of the Indian Government and Xxx’s Environment, Health and Safety requirements when executing work on company premises.
7.0 RESPONSIBLE DEPARTMENTS
QA, Production and Engineering
8.0 RESPONSIBILITY
EHS Coordinator
9.0 DEFINITION
A contractor is defined as any person or firm who performs work or provides services and does not receive direct supervision by an employee of Xxx India. A person or persons visiting the facility to view the operations is not considered to be a contractor. Examples of contractors are building contractors, service contractors, electrical contractors, etc. The definition will cover both short term and long-term contractors.
7.0 PROCEDURE
7.1 Duties and Responsibilities of Xxx's Staff Engaging Contact Services
7.1.1 The department and or individuals engaging the service of outside contractors are responsible for strict compliance of this policy and ensuring comprehensive communication to the contractors.
10.1.2 The department and or the individual engaging the services of the contractor shall make available to the contractor the set of rules to be followed in Xxx's premises. The set of rules is attached in Appendix 1.
10.1.3 All contractors' activities on Xxx's premises shall be performed under the supervision of the hiring Xxx person. The department engaging the services of the contractor will ensure that he/she understands and follows the EHS regulation of Xxx (India), Xxx Plant and same shall be documented in HR Training form(INA-56-005-03,as attachment). The Xxx personnel responsible for the contractor shall submit a copy of Contractor entry request through AVI (Form #INA-03-003-01) to the Security Department upon arrival or prior to the contractor’s arrival.
10.1.4 The Xxx staff responsible for hiring the contractor shall ensure that the contractor signs the Non-Disclosure Agreement. The signed Non-Disclosure Agreement shall be submitted to the manager of the department concerned.
10.1.5 Follow Xxx requirements outlined in section 10.3 of this procedure.
10.2 Duties and Responsibilities of the Contractor
10.2.1 The contractor shall ensure that there will be an onsite supervision while the work is being conducted on site. The contractor supervisor shall supervise the contractor employees and enforce all Xxx requirements along with country, state and local regulation.
10.2.2 The contractor has the responsibility and obligation to know and comply with all Indian regulations and Xxx's rules. The contractor shall make safety and environmental considerations an integral part of the daily work habits within the facility.
10.2.1 The contractor is responsible for protecting the health and safety of his/her employees, Xxx employees and property and maintaining a clean environment.
10.2.2 The contractor shall provide the workers with the required personal protective equipment (PPE) and shall ensure that workers use PPE properly. Personal protective equipment may include, but not limited to: helmets, safety shoes, goggles/safety glasses, gloves, shields, aprons, respirators, and earplugs and safety harness.
10.2.3 Contractors can be terminated immediately if they do not follow the applicable rules and regulations.
10.2.4 The contractor shall remove any worker violating any Environment, Health and Safety regulations immediately and inform the EHS Coordinator, Security and the concerned department.
10.2.5 Contractors are responsible for disposing of any hazardous & non hazardous waste that they generate when executing their work.
10.2.6 The contractor shall obtain the necessary instructions in AVI Slip (INA-03-003-01) for disposing off any waste that they may generate when executing the work.
10.2.7 The contractor will bring and submit to the Xxx EHS Coordinator, the MSDS of the material used by him / his company at least 02 days prior to the job starting.
10.3 Procedures for Establishing Contracts
10.3.1 Written contracts between Xxx and any outside contractor shall contain the following statement or equivalent thereof, owning environment, health and safety responsibility:
- Contractors and their representatives shall observe all the Statutes of Indian Government and Xxx Environment, Health and Safety requirements, when executing work on Xxx premises.
10.3.2 Contract agreement shall also include all the points mentioned in section 10.2. Examples of such contracts are building contracts, monthly, yearly service contracts, etc.
10.3.3 The department/individual engaging the services of the contractor shall communicate the Environment, Health and Safety rules to the contractor and his representatives.
10.2.1 The department/individual engaging the services of the contractor should see that the contractor or his companion following various procedures but not limited to the following:
- Safe handling use and storage of compressed air/gas (INA-03-006)
- Lock Out and Tag Out Procedures (INA-03-019)
- Confined space entry(INA-03-017)
- Welding and cutting Safety- Hot work permit requirements (INA-03-007)
- Hazardous Communication (INA-03-010)
- Personal protective equipment (INA-03-012)
- Fall protection (INA-03-014)
- GMP requirements.
10.2.2 The department and or the individual engaging the services of the contractor
must ensure that contractor obtains a hot work permit approved from the EHS Coordinator, before the commencement of any hot works. The hot works permit must be displayed prominently at the locations of the works.
10.2.3 The department and or the individual engaging the services of the contractor
must ensure that contractors legally dispose off any waste arising from his operation. Contractors are not allowed to dispose their waste in Xxx's waste stream.
10.2.4 The department and or the individual engaging the services of the contractor
must ensure that contractors comply with Xxx's GMP requirements when executing their work.
7.0 ATTACHMENTS
Appendix 1: EHS Guidelines for Contractors

Appendix 1
SET OF RULES FOR CONTRACTORS
1.0 Duties and Responsibilities of the Contractor
A. The contractor shall ensure that there will be an onsite supervisor while work is being conducted on site. The contractor supervisor shall supervise contractor employees and enforce all the applicable regulations and Xxx's requirements.
B. The contractor has the responsibility and obligation to know and comply with the country, state & local regulations of India and Xxx's rules. The contractor shall make safety and environment an integral part of the daily work habits within the facility.
C. The contractor is responsible for protecting the health and safety of his/her employees, Xxx employees and properties and maintaining a clean environment.
D. The contractor shall provide the workers with the required personal protective equipment and shall ensure that workers use them properly. Personal protective equipment may include, but not limited to: helmets, safety shoes, goggles/safety glasses, gloves, shields, aprons, respirators, and earplugs, safetyharness.
E. Contractors shall maintain good housekeeping standards always:
i. The contractor shall remove any worker violating any Environment, Health and Safety regulations immediately and inform the EHS Coordinator, Security and the concerned department.
ii. Contractors are responsible for disposing off any waste that they may generate when executing their work.
iii. The contractor shall obtain the necessary instructions in AVI Slip (INA-03-003-01) for disposing off any waste that they may generate when executing the work.
iv. The contractor will bring and submit to the Xxx EHS Coordinator, the MSDS of the material used by him / his company at least 02 days prior to the job starting.
Note: The contracters can be terminated immediately if they do not follow the applicable rules and regulations
2.0 Rules and Regulations for Contractors
A. Access
- Employees of contractors and their nominated sub-contractors who need to enter Xxx premises must first obtain a Visitor Pass from the Security.
- Visitors or relatives of contractor’s employees, who are not employed by the contractor, will not be allowed on Xxx’s premises.
- The Visitor Pass must be visibly worn above the waistline at all times.
- Term passes for contractors and his representatives must be returned to Security, when expired or when the contract is completed.
- No one is allowed to enter Xxx plant without prior approval by authorized Xxx representative.
- Xxx staff must escort contractor’s personnel who have been granted permission to enter the plant.
- Contractor’s personnel who have been issued a term Contractor Pass is allowed to enter the Plant unescorted, e.g. cleaners, shipping contractors, suppliers, etc.
- Entry to and exit from Xxx plant is allowed only through the employee entrance guard lobby. All the contractor’s personnel will have to sign the logbook both while entering the plant and while exiting from the plant.
B. Parking
Vehicles may be temporarily parked near the building to unload tools and materials. Once this is completed, the vehicles must be removed. The vehicles must be parked at the designated area.
C. Restrictions
- Contractor personnel are not allowed to use Xxx's staff canteen without prior approval or bring food into any part of the premises.
- All keys issued to contractors must be returned prior to leaving the premises.
- Smoking - Xxx (India) is a designated non-smoking site. However, smoking is permitted outside the building.
D. Conduct
- All contractor personnel are expected to conduct themselves in a business like manner while on site.
- All contractors shall wear appropriate attire and footwear at all times.
- No loud or abusive language is allowed.
- No unauthorized radios, cameras are permitted in Xxx plant premises.
- The possession of intoxicants or illegal drugs on Xxx grounds is not permitted.
E Material Safety Data Sheets
- On site Material Safety Data Sheets for Xxx materials are available in the Environment, Health and Safety Department. These must be given to the contractor supervisor during training.
- The Xxx contact person or department responsible for the contractor must provide the Environmental, Health and Safety Department with the Material Safety Data Sheets for hazardous materials which will be brought into the premises, such as cleaning solvents, paints, adhesives, etc. This is required prior to commencement of any operation.
F. Safety
- The contractor or his personnel shall comply with all current regulations/codes while working at Xxx premises. Xxx will reserve the right to halt any work where good safety habits are not observed. Any delay incurred as a consequence of non-compliance will be the contractor's liability.
- The contractor will be responsible for the following:
o Report immediately any unsafe conditions.
o All tools and equipment must be maintained in good condition and used only as intended.
o Safety glasses must be worn when needed for eye protection.
o Hearing protection is required in posted areas.
o Protective equipment (goggles/face shields, glove) must be worn when working around or handling dangerous chemicals.
o Respiratory and/or hearing protection must be used as needed or where required.
o Hard hats are required once he/she is present in the plant / working area.
o Suitable signs or barricades must be set up to clearly identify hazards caused by the contractors when applicable.
o All construction areas will be barricaded so that persons cannot walk into the worksite.
- No horseplay or practical jokes are permitted.
- All machines, equipment, electrical circuits, pipelines, etc., which will be repaired must first be tagged out of service with a 'Danger, Do Not Operate' tag. This tag shall have the date and contractor's name. In addition, the disconnect or supply valve must be physically locked to prevent the inadvertent operation, which could expose any person to possible injury. For electrical equipments its current or rpm and other capacities that may cause risk should be displayed properly.
- Fire exits and passageways must not be blocked at all times.
- All the activities at Xxx (India), Xxx are performed in such a fashion to achieve world class levels of least environmental impact. Keeping the above in mind, misuse or mismanagement of hazardous chemicals by contractor personnel while conducting work on site will not be tolerated. If the need arises, contractor personnel may request assistance from the Environment, Health and Safety Department, when dealing with chemicals or materials that are likely to have Environmental Impact.
G. Emergencies
- Chemical Spills:
Should a chemical spill occur which involves release of hazardous material to a drain, threatens life or property, immediately call EHS Coordinator and notify with the following information:
o Your name
o Specific location
o Materials and/or areas involved
- Fire Emergency:
Should a fire emergency occur, immediately activate the fire alarm and immediately call EHS Coordinator and notify with the following information:
o Your name
o Specific location
o The nature of emergency such as burning/smoldering electrical equipment, etc.
H. Waste Disposal
- The contractor is responsible for disposing off any waste that is generated when executing their work. The necessary permits for disposing off the wastes shall also be obtained by the contractor INA-03-003-01 ( on Avoid verbal instruction Slip).
- If at any time during the contractual work, should the need to impact building materials arise, please contact Environment, Health and Safety Department, prior to any work.
I. Cutting and Welding
- The contractor shall inspect the work site before beginning work and shall perform all works in a safe manner. A Xxx hot works permit, issued by the EHS Department is required for all operations involving cutting and welding.
J. Company Equipment
- All site tools and equipment, including pallet jacks, pallet stackers, fork lifts and trained operators should only use carts.
- Contractors must provide all tools, equipment, and materials necessary to complete their contracted work.
- The contractor at his or her own risk will use any Xxx tools, equipment and material that are loaned to the contractor.
K. Good Manufacturing Practices
- Nature of operations in some areas requires the use of hair and/or mustache covers. All contractor personnel must wear these covers while working in these designated areas.
- Additionally, other areas may require special gowning. Also wrist watches, jewellery and make-up may not be allowed in certain areas. All contractor personnel must review procedures for any area that they plan to enter or work in with the Xxx contact person responsible for them being on site.
L. Housekeeping
- Good housekeeping is a major concern to Xxx in the daily operation. Contractors and their employees shall leave their work areas clean and in an orderly condition on a daily basis. This shall also include a general clean up of trash. Materials, tools and/or equipment shall be arranged in an orderly manner. At the completion of work, materials, tools and equipment must be promptly removed from the work site.
- Special care must be taken not to block walkways, roadways or fire extinguishing and safety equipment (safety showers, eye wash stations and spill kits).
- In certain areas, dust blocking enclosures or walls may be required to limit the amount of disruption to adjacent areas.
M. Clean Rooms
- Entry to clean rooms is restricted. Prior permission is required for entrance. Departmental management will provide specific instructions on environmental requirements while working in these areas and obtain necessary clearances.
N. Confidentiality
- All manufacturing processes and company operations are considered confidential.The contractor will have to sign a Non-Disclosure Agreement
- Contractors and their employees are expected not to discuss anything observed in our facilities with anyone outside of Xxx.
- Additionally, no video, photographic or reproduction equipment of any kind may be used within the facility unless prior approval has been granted.