Appendix I-E

Draft HSSE Safety Management System

 2021

HSSE Safety Management

System

Risk Level Language Country

[Risk Level] OEMS Standard EN US
 HSSE Safety Management System

CONTENTS
1. INTRODUCTION ................................................................................................................................................................................................... 5

1.1 Regulatory Framework ................................................................................................................................................................................. 5

1.2 Industry and international standards...................................................................................................................................................... 6

2. ABBREVIATIONS AND ACRONYMS .............................................................................................................................................................. 6

3. MANAGEMENT COMMITMENT ..................................................................................................................................................................... 7

3.1 Roles .................................................................................................................................................................................................................... 7

3.2 Training Requirements ................................................................................................................................................................................. 8

3.3 Competence Assessment and Records .................................................................................................................................................. 8

4. EMPLOYEE INVOLVEMENT .............................................................................................................................................................................. 8

5. SAFETY POLICIES .................................................................................................................................................................................................. 9

5.1 Organizational Reporting Structure ...................................................................................................................................................... 11

5.2 Permit to Work .............................................................................................................................................................................................. 13

5.3 Job Hazard / Safety Analysis .................................................................................................................................................................... 14

5.4 Driving Safety / Journey Management ................................................................................................................................................ 15

5.5 Working at Heights / Fall Protection .................................................................................................................................................... 15

5.6 Lock Out Tag Out (LOTO) .......................................................................................................................................................................... 16

5.7 Access and Egress ........................................................................................................................................................................................ 18

5.8 Electrical Safety .............................................................................................................................................................................................. 18

5.9 Hot Work.......................................................................................................................................................................................................... 19

5.10 Lifting and Hoisting Safety .................................................................................................................................................................. 19

5.11 Housekeeping ........................................................................................................................................................................................... 20

6. CONTRACTOR MANAGEMENT .................................................................................................................................................................... 20

6.1 Audits ................................................................................................................................................................................................................ 21

6.2 Training ............................................................................................................................................................................................................. 21

7. MANAGEMENT OF CHANGE......................................................................................................................................................................... 21

7.1 Roles and Responsibilities ......................................................................................................................................................................... 21

7.2 Management of Change Process ........................................................................................................................................................... 21

7.3 Management of Change Communication .......................................................................................................................................... 22

7.4 Training Requirements ............................................................................................................................................................................... 22

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7.5 Management Review................................................................................................................................................................................... 22

7.6 Audits and Assessments ............................................................................................................................................................................ 22

8. UNSAFE WORKING CONDITIONS ............................................................................................................................................................... 22

8.1 Reports of Unsafe Work Conditions ..................................................................................................................................................... 22

8.2 Stop Work Authority ................................................................................................................................................................................... 23

9. SAFETY TRAINING AND FITNESS................................................................................................................................................................. 23

10. Personal Protective Equipment ............................................................................................................................................................... 24

11. DESIGN AND EQUIPMENT ........................................................................................................................................................................ 25

11.1 Lights and warning devices ................................................................................................................................................................. 25

11.2 Fall protection systems.......................................................................................................................................................................... 25

11.3 Lock Out Tag Out .................................................................................................................................................................................... 25

11.4 Confined Space ........................................................................................................................................................................................ 25

11.5 Boat Landings ........................................................................................................................................................................................... 26

11.6 Means of Escape ...................................................................................................................................................................................... 26

11.7 Personnel Landings ................................................................................................................................................................................. 26

11.8 Lifesaving Equipment ............................................................................................................................................................................. 26

11.9 Fire Detection and Suppression......................................................................................................................................................... 26

11.10 Maintenance of Emergency Equipment ......................................................................................................................................... 27

12. Remote Monitoring, Control, and Shutdown Capabilities ........................................................................................................... 27

12.1 SCADA System .......................................................................................................................................................................................... 27

12.2 Fail Safe Systems ...................................................................................................................................................................................... 27

13. EMERGENCY RESPONSE ............................................................................................................................................................................ 27

13.1 Training Requirements for Emergency Response ...................................................................................................................... 28

14. HAZARD IDENTIFICATION AND RISK MANAGEMENT .................................................................................................................. 28

15. IMPLEMENTATION, MONITORING, and REPORTING .................................................................................................................... 29

15.1 Implementation ........................................................................................................................................................................................ 29

15.2 Performance Monitoring ...................................................................................................................................................................... 30

15.3 Incident Reporting .................................................................................................................................................................................. 30

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 HSSE Safety Management System

1. INTRODUCTION
This document provides an overall description of the key elements to be included in the Safety Management System
(SMS) for the Atlantic Shores Offshore Wind project. It describes Atlantic Shores policies with regard to the safety
requirements set forth in BOEM’s Guidelines for Information Requirements for a Renewable Energy Construction and
Operations Plan (v. 4.0; May 27, 2020) (COP).

The SMS is an evergreen document and will be improved and adapted to address the specific needs of each phase of
the Projects. The SMS provides a structure for:
• Identification and vetting of risks and hazards to the health and safety of people and the Environment;
• Risk management and control measures implemented to ensure prevention of personal injury, asset damage,
and adverse environmental impacts;
• Protection of employees, contractors, and the public from foreseeable hazards related to contact with Atlantic
Shores operations or assets; and
• Robust health, safety and environmental monitoring and reporting practices.
The SMS describes the processes and procedures that, when successfully implemented, ensure the safety of personnel
or anyone on or near the facilities. Building upon the SMS foundation of - planning, doing, checking, acting and striving
for continuous improvement - that safety is ensured. Atlantic Shores understands that health, safety and environmental
performance are critical factors during all operations on the OCS. As the Project evolves over the planning and design
process, Atlantic Shores will update this SMS accordingly to reflect a periodic exchange of information with BOEM and
BSEE about matters addressed in this document.

1.1 REGULATORY FRAMEWORK

Commercial Lease of Submerged Lands for Renewable Energy Development on the Outer Continental Shelf, OCS-A
0499 (“Lease”) includes provisions to address federal safety requirements (Section 14 of the Lease). These requirements
are summarized below:

a. Maintain all places of employment for activities authorized under the lease in compliance with occupational safety
and health standards and free from recognized hazards to employees of Atlantic Shores or any contractor or
subcontractor operating under this lease;
b. Maintain all operations within the leased area in compliance with the regulations in 30 CFR Part 585 and orders from
BOEM and other federal agencies with jurisdiction, intended to protect persons, property and the environment on the
OCS; and,
c. Provide any requested documents and records, which are pertinent to occupational or public health, safety, or
environmental protection, and allow prompt access, at the site of any operation or activity conducted under this
lease, to any inspector authorized by the BOEM or other federal agency with jurisdiction.
An SMS must address the requirements set forth in 30 CFR §585.810 (and referenced in 30 CFR § 585.627(d),
§585.614(b) and §585.651), including with respect to the COP a description of:

1. How you will ensure the safety of personnel or anyone on or near your facilities.;
2. Remote monitoring, control, and shut down capabilities.;
3. Emergency response procedures.;
4. Fire suppression equipment, if needed.;
5. How and when you will test your Safety Management System.; and
6. How you will ensure personnel who operate your facilities are properly trained.

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1.2 INDUSTRY AND INTERNATIONAL STANDARDS

The Atlantic Shores SMS draws from decades of industry-leading offshore wind and other energy infrastructure
experience of its parent companies, Shell New Energies and EDF Renewables. Both companies have long-standing,
successful records developing, implementing and managing SMS for global and domestic operations. Atlantic Shores
considers industry standards, such as ISO 45001 and API RP 75, to be important guidelines for the U.S. offshore wind
industry 1 As this SMS evolves, Atlantic Shores will look to these and analogous standards to enhance its SMS program.

2. ABBREVIATIONS AND ACRONYMS

AED: Automated External Defibrillator
ALARP: As Low as Reasonably Practicable
ASOW: Atlantic Shores Offshore Wind
BOEM: Bureau of Ocean Energy Management
BSEE: Bureau of Safety and Environmental Enforcement
CFR: Code of Federal Regulation
COP: Construction and Operations Plan
CPR: Cardiopulmonary Resuscitation
CSMP: Contractor Safety Management Plan
EMP: Environmental Management Program
HAZID: Hazard Identification
HSSE: Health, Safety, Security, and Environment
JSA: Job Safety Analysis
LOTO: Lock Out / Tag Out
MOC: Management of Change
NFPA: National Fire Protection Association
NM: Nautical Mile
OCS: Outer Continental Shelf
OSHA: Occupational, Health, and Safety Administration
PFD: Personal Flotation Device
PIC: Person in Charge
PPE: Personal Protective Equipment
SMS: Safety Management System
SPCC: Spill, Prevention, Control, and Countermeasure
USCG: United States Coast Guard

1
ISO 45001:2018 Occupational Health and Safety Management Systems (see https://www.iso.org/iso-45001-occupational-
health-and-safety.html) and American Petroleum Institute (API) Recommended Practice 75, Recommended Practice for a
Safety and Environmental Management System for Offshore Operations and Assets, 4th Ed. (see
https://www.api.org/products-and-services/standards/important-standards-announcements/recommended-practice-75)

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3. MANAGEMENT COMMITMENT
The commitment of the Atlantic Shores Management Team to safety is paramount to the implementation of the SMS,
and the team has established a goal of eliminating safety-related incidents (referred to as “Goal Zero”). Atlantic Shores
management will lead by example, set clear policy, allocate necessary resources, and designate parties to provide
subject matter expertise.

To achieve the safety culture of Goal Zero, Atlantic Shores will:

• Ensure a systematic approach to the management of HSSE and implement a safety management system
designed to ensure compliance with regulations as a minimum and to achieve continuous performance
improvement.
• Take responsibility and provide clear leadership.
• Be a leader in developing and promoting best practices in the offshore wind energy industry.
• Respect our neighbors and contribute to the societies in which we operate.
• Set targets for HSSE audits, improvement metrics and performance reporting.
• Require all contractors and subcontractors to manage HSSE in line with Atlantic Shores policy
• Ensure that HSSE compliance is the responsibility of all managers, teams, and individuals.
• Empower everyone to stop any work, or prevent work from starting, without retribution where adequate
controls of HSSE risks are not found to be in place or an individual is not certain of the task at hand.
• Include HSSE performance in all staff evaluations.
• Encourage and promote involvement by all employees regardless of position or title.
• Strive for zero safety-related incidents in our operations.

Atlantic Shores is committed to the safety of all employees, contractors, visitors and vendors at all of its facilities. To
guide Atlantic Shores in executing their commitment to safety, and building on lessons learned from the offshore wind, oil
and gas, and other industries, a combination of regulatory sources has been assessed to support the development of
comprehensive and robust safety management program.

The SMS draws on regulations from 33 CFR Parts 140-145 and incorporates information based on certain elements of
30 CFR Part 250, Subpart S, Safety and Environmental Management Systems (SEMS) and OSHA regulations.

3.1 ROLES
The following roles are tasked with fostering and implementing the SMS:

Management Team: The Management Team provides overall leadership to the Project team with regards to HSSE;
ensures the safe management of all work associated with the Project; ensures that the project is fully and competently
staffed for managing HSSE and that objectives are clearly defined for all team members; ensures that all levels of staff
receive adequate and appropriate training; ensures that a means is in place to provide the appropriate level of response
to HSSE protocol that is not followed.

Managers and Leads: Managers and leads provide direct support to help individual contributors manage HSSE
compliance in their role; ensure the safe management of work under their direction; ensure that HSSE objectives are
followed; ensure that staff under their direction receive adequate and appropriate training.

Individual Contributor: All employees, contractors, and subcontractors contribute to keeping Atlantic Shores incident

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and injury free; ensure the safe performance of their work; follow HSSE policies; attend all required training.

3.2 TRAINING REQUIREMENTS

Atlantic Shores team members will receive ongoing training in implementing the SMS and supporting policies. Team
members will receive training to develop and maintain the following capabilities:

• Where to find Atlantic Shores HSSE policies;

• How to perform their work safely;
• The importance of and how to support and improve the Atlantic Shores safety culture of Goal Zero; and
• How to report accidents, near misses, or injuries.
In addition, managers and leads will receive training to ensure they have the necessary skills and knowledge to fulfill
their safety leadership responsibilities including:

• Cultivate and model the safety culture.

• Communicate Atlantic Shores HSSE policies, expectations, and goals.
• Implement and manage the SMS.
• Ensure that the project is fully and competently staffed for managing HSSE.
• Implement the training program and HSSE recordkeeping, performance tracking, and reporting.
• Ensure that procedures are in place to provide an appropriate response to incidents or to
noncompliance.
Further training requirements are addressed in section 9.

3.3 COMPETENCE ASSESSMENT AND RECORDS

Atlantic Shores will use a competence assessment process to assist the development and maintenance of highly and
appropriately trained staff. Contractors working for or on behalf of Atlantic Shores will be required to meet these same
training and recordkeeping standards.

Atlantic Shores and its contractors/subcontractors will maintain records for HSSE training of project personnel, situational
exercises (e.g., tabletop and mock incident exercises), and relevant safety certifications. The Management Team will
direct Managers to maintain a recordkeeping system that allows for regular review and reporting of all necessary training
records and certifications.

4. EMPLOYEE INVOLVEMENT
Atlantic Shores values a high level of employee engagement in its safety program. Employee involvement in the SMS
program will be maximized through initial safety orientation, frequent and repeated safety awareness training, and
management programs that include:

• Safety Meetings;
• Safety Training Program; and
• Safety Recognition Program.

Atlantic Shores will establish a corrective action policy that clearly defines the process employees should follow to correct
issues that may occur. The policy encourages trained employees to exercise appropriate judgement when undertaking
work and to follow established safety policies and procedures. The disciplinary policy clearly defines consequences and

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disciplinary actions when safety policies are violated.

5. SAFETY POLICIES
Specific safety policies and associated training will be developed in accordance with applicable provisions of 29 CFR
Part 1910 (Occupational Safety and Health Standards), 29 CFR Part 1926 (Safety and Health Regulations for
Construction), and 30 CFR Part 585 (Renewable Energy and Alternate Uses of Existing Facilities on the Outer
Continental Shelf).

Atlantic Shores HSSE policies will be maintained through training, regular safety meetings, documentation and audits.
The SMS addresses the following safety topics:

Safety Topic Purpose

Contractor Safety Management Process To confirm that contracts consistently and effectively cover the
(CSMP) management of HSSE risks, and to deliver effective management of
HSSE risks during contracted activities
Emergency Preparedness and Response To plan and prepare for Emergency Responses to Incidents that
Plan + Contact Form mitigate the consequences and enable resumption of normal
operations/business activities
Crisis Management Plan Managing crisis situations that can arise with little or no warning,
cause a high level of concern in the minds of many stakeholders -
external and internal, and puts the Atlantic Shores license to operate
at risk
Oil Spill Response Plan To prepare for fuel or other liquid hydrocarbon and chemical spills
offshore and to develop plans to mitigate their consequences
Office and Work from Home Safety Plan To improve and maintain worker welfare for employees, contractors,
and subcontractors with a goal of driving performance through
demonstrating care for people
Environmental Management Program (EMP) To define detailed plans for ensuring compliance
with all environmental laws and regulations during construction,
installation, and operation.
Incident Management and Investigation Plan To manage, log, investigate, and learn from incidents.
Drug and Alcohol Policy To manage the risk caused by the use of alcohol and drugs
Personal Protective Equipment (PPE) To manage the risk to people where personal protective equipment is
Procedure used
Aviation Incident Prevention Plan Controls to manage air safety are established for aircraft, operators,
facilities and operations for aircraft that are owned, operated,
managed or contracted by Atlantic Shores
Incident Communication Plan To direct internal and external notifications and communications for
response and learning.
Life Saving Rules and Goal Zero Principle To state guiding safety principles for project.
Management of Change Process To manage the HSSE and Social Performance risks resulting from
unforeseen consequences of changes
Crane and Material Handling Requirements To manage the risks of lifting and hoisting operations
(Lifting and Hoisting)
Working at Heights/Dropped Object To prevent falls and drops and to reduce the consequences if a fall or
Prevention Policy drop occurs when working at heights

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Permit to Work System To manage the risks of hazardous work and work that could interfere
with other hazardous operations
Vehicle Safety Plan Controls to manage road safety are established for drivers, vehicles
and journeys.
Extra controls are established for professional drivers and in areas
with high road safety risks.
Waste Management Plan To minimize the generation and optimize the reuse, recycling and
disposal of wastes
Facility Security Plan for Shore Base and To manage security risks by assessing security threats and providing
Substation controls to safeguard people, assets including information, and
reputation.
Spill Prevention, Control, and Details proper containment and cleanup procedures for unintentional
Countermeasure Plan (SPCC) spill or release of substances at onshore facilities.
Bypassing of Safety Systems To manage the risk of using override of process safeguarding
systems and process safety alarms.
HSSE Disciplinary Action Policy To provide appropriate consequences for intentional or unintentional
failure to follow safety rules
Personnel Transfer at Sea Procedure To ensure safety of all project personnel during transfers at sea
between vessels and helicopter if needed.
Fitness for Duty To reduce the risk of injury, illness, or incidents by evaluation of
personnel’s fitness for work
Stop Work Authority Any individual has the right and obligation to declare a “Stop Work” if
an unsafe situation is observed that could potentially result in an
incident or would potentially cause harm to the environment or
damage to equipment and/or property.
Lock Out / Tag Out Procedure To manage the risk from exposure of people to energy and
hazardous substances by isolating equipment and placing locks and
tags.
Marine Incident Prevention Plan Controls to manage Maritime Safety Risks are established for owned,
operated or contracted vessels.
Establish and maintain positive vetting to ensure a vessel is
confirmed to be suitable for the intended usage
First Aid, CPR, and AED Procedure Training and procedure for first responders
Bloodborne Pathogen Procedure To establish a standard way of safely handling incidents where
personnel have the potential to come in contact with blood or bodily
fluids
Hearing Conservation Policy To establish safe practices to address work environments with high
decibel sound
Heat Stress Prevention Establish safe work practices to address and prevent heat stress
Vessel and site-specific induction training Establish what needs to be included in on-site induction training
materials.
Hot Work To manage the risk of igniting flammable materials during hot work
Confined Space Entry To prevent or reduce the consequences of incidents related to
planning, preparing, executing and supporting confined space work
(CSW)

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Diver Safety To prevent or reduce the consequences of incidents related to

planning, preparing, executing, and supporting underwater work
performed by certified, commercial divers.
Wind Turbine Rescue from Height Procedure Establish procedure for rescuing personnel from heights during
various project phases
Electrical Work Requirements (Shock and Arc To manage the risk to people from electrical hazards
Flash Safety)
Fire Safety Awareness Verify that all personnel are trained in basic fire prevention and
suppression protocol

5.1 ORGANIZATIONAL REPORTING STRUCTURE

Atlantic Shores’ organizational structure ensures responsibilities are delineated and accountability is described for all
levels of the organization. As needed, positions and duties will be added to the structure, consistent with the Project
safety needs and in coordination with project contractors.

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Board of Directors

Atlantic Shores Management Team

Managing Director - Development Director - Commercial Director - Finance Director - Technical Director

Project Director

Environmental Installation and

HSSE Manager Project Controls Manager Asset Manager
Coordinator Commissioning Manager

Permitting &
Environmental Risk Lead Marine Coordinator O&M Manager
Compliance

Document Controller Harbor & Logistics Lead

Figure 5-1 Atlantic Shores HSSE Management Organization

5.1.1 KEY ROLES AND DESCRIPTION OF RESPONSIBILITIES

This section lists the responsibilities of Project personnel for administering the SMS, though such personnel may have
additional responsibilities that are beyond the scope of the SMS and are addressed elsewhere.

5.1.1.1 PROJECT DIRECTOR

The Project Director will manage all aspects of the Project and will ensure that the Project is constructed safely, in
accordance with the environmental permits and applicable quality standards. The Project Director will be Atlantic Shores’
authorized representative during the engineering and construction period for all matters related to the SMS including
coordination with government authorities, first-responder emergency agencies, and coordination between contractors.

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5.1.1.2 HSSE MANAGER

The HSSE Manager will report to the Project Director and will be responsible for monitoring compliance with the
approved Construction and Operations Plan, the SMS, all safety-related regulatory requirements, and overall health and
safety conditions for the Project. The HSSE Manager will review all contractor’s safety management plans for compliance
with the COP SMS, regulatory, and contract requirements. The HSSE Manager will establish a “safety first” working
mentality at the project sites and on vessels involved in transport and construction. This will be done through direct
personal involvement from the manager and a team of site safety representatives to create a positive safety culture at all
working sites, remind all personnel that they have stop work authority, and that they are supported by all managers in
taking the time to work safely.

5.1.1.3 ENVIRONMENTAL COORDINATOR

The Environmental Coordinator will report to the Project Director and will ensure that all local, state, and federal permit
requirements and laws relating to environmental protection and reporting are implemented. The Environmental
Coordinator will monitor contractors for compliance with Project specific environmental requirements and shall be
responsible for verifying compliance with environmental protection programs and protocols for environmental incident
response. The Environmental Coordinator will coordinate deployment of certified marine mammal observers and other
environmental resource observers on the vessels as required by the conditions of the Project permits and approvals. The
Environmental Coordinator will ensure contractors have compliant oil spill response plans, hazardous waste plans, and
waste management plans in place.

5.1.1.4 INSTALLATION & COMMISSIONING MANAGER

The Installation and Commissioning Manager will report to the Project Director and will ensure compliance with permit
requirements and applicable laws relating to the Project vessel activities (including installation vessels, transport vessels,
service vessels, tugs, rescue boats, etc.). The Installation and Commissioning Manager will be kept informed of all
planned vessel deployment each day.

5.1.1.5 MARINE COORDINATOR

The Marine Coordinator will conduct regular meetings with contractors to discuss vessel operation and deployments as
appropriate for the level of marine activities scheduled. The Marine Coordinator will be the primary liaison with the
USCG, port authorities, state and local law enforcement, marine patrol, and commercial operators (including ferry,
tourist, and fishing boat operators). The Marine Coordinator will be responsible for all marine updates such as
coordination with USCG regarding any required Notices to Mariners.

It will be the Marine Coordinator’s responsibility to be knowledgeable of weather forecasts and have a communications
plan in place with all contractors and vessels involved in the project. The Marine Coordinator will coordinate with the
USCG and local law enforcement authorities for planning in the event of trespassing vessels within any safety zone
established for the offshore Project construction activity.

5.2 PERMIT TO WORK

Atlantic Shores requires a safe system of work by incorporating a Permit to Work (PTW) process on routine and non-
routine work activities. The PTW process is a comprehensive process for analysing, planning, authorizing, and executing
work in a manner to prevent incidents. The Permit to Work System should support personnel in safely managing hazards
associated with the work activity and the work location or equipment, such that:
• The hazards and controls are understood by the workers.
• The work area is isolated from process hazards.
• Work/activity conflicts are understood and are mitigated for.
• Anyone affected by the work understands the hazard that they could be exposed to

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The Permit to Work 8 Step Process

2. Identify
1. Define work 3. Authorize work
hazards and
scope plan
agree to controls

6. Pre-job 4. Verify controls

5. Issue permit
discussion in the field

8. Verify job
7. Execute and
completed and
supervise
hand back

Activities which will require a written safe system of work controlled through Permit to Work will include:
• Access to and work within Confined Spaces
• Access to and work on electrical systems
• Access to and work on mechanical systems
• Lifting and Hoisting operations
• Vessel Permits
• Pressurized pipe systems
• Instrumentation & Control
• Hot work (such as welding or grinding)
• Radiological processes (e.g., NDT)
• Significant Lifting Operations
• Work at Heights
• Work over water
• Transfer of personnel

5.3 JOB HAZARD / SAFETY ANALYSIS

Another key tool to the process, besides the Work Permit, is the Job Safety/Hazard Analysis (JSA/JHA).

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The JSA/JHA also helps ensure appropriate precautions and procedures are employed to eliminate or minimize identified
hazards and risks of conducted activities. The JSA/JHA is a process for discussing and documenting each step of a job,
identifying the existing or potential hazards, and then determining the best way to perform the job to reduce or eliminate
the hazards.
JSA/JHA are effective tools to be used for jobs that will take place even when a Work Permit is not required. Atlantic
Shores views the JSA/JHA process as an ongoing, continual process that will evolve with the progression of the project
from construction, through operations & maintenance, to decommissioning.

5.4 DRIVING SAFETY / JOURNEY MANAGEMENT

Atlantic Shores employees, contractors, and subcontractors driving a vehicle in the course of their work will comply
with Atlantic Shores’ driving standards and requirements. These requirements include:

• Have a current driving license that is valid for the location, type of vehicle and, where applicable, the cargo
• Be physically and mentally capable of operating the vehicle.
• Use three-point seatbelts at all times and make sure passengers do so throughout the trip.
• Do not use a mobile phone, pager or similar mobile device (whether hands free or not) while driving.
• Do not allow unauthorized passengers in the vehicle.
• Visually inspect the vehicle for roadworthiness every day before use, including the tires and windshield
• Drive with lights on during daytime, except where prohibited by law.
• Use vehicles equipped with 3-point seatbelts, head restraints, anti-lock braking systems, vehicle side-
impact protection, and airbags for both driver and front seat passenger.
• Periodically question and review the number of journeys with the intent to eliminate journeys and lower your
travel risk.
• Attend an accredited Defensive Driving Course at a frequency based on the annual miles driven.
• Non-professional drivers shall conduct a Journey Management Assessment (JMA), which is a mental risk
assessment, prior to every road trip. The JMA will cover fitness to drive, vehicle condition, the route and
road conditions.
• Do not allow driving for more than 10 hours or a combination of work-related activities and driving for more
than 14 hours.
• The use of motorbikes, other motorized devices with two or three wheels, All Terrain Vehicles or Quads are
not allowed for company business.

5.5 WORKING AT HEIGHTS / FALL PROTECTION

All work at height should be properly planned and appropriately supervised. This includes planning for an emergency
rescue. A risk assessment will be completed for a potential fall from ANY HEGHT deemed a risk to determine the
appropriate level of risk mitigation. All work should be risk based, well organized, and planned in advance. There is a
requirement to complete a risk assessment for work at height. The Atlantic Shores Fall Protection Program is intended
to provide general procedures for protecting workers working from heights. Activities that expose workers to any
potential fall, regardless of height, shall employ suitable fall hazard control measures. Whenever possible, tasks
should be planned so that elevated work will not occur.

When fall hazards cannot be eliminated or prevented, personal fall arrest systems shall be used. Personal fall arrest
systems (“PFAS”) consist of an anchoring point capable of supporting at least 5,000 pounds, double latching snap hooks,
a full-body harness with a shock absorbing lanyard and lifeline, or a suitable combination of these. PFAS shall conform to

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the ANSI Z359.2 Standard. PFAS components shall be configured so workers can neither free-fall more than six feet, nor
contact any lower level.

Those working at height should be experienced in working and height and have an understanding of the associated
risks and appropriate safety measures required to do so safely. It is the responsibility of the employing company to
verify the competence of people who:

• Inspect, maintain or repair Fall Protection Equipment

• Inspect, maintain or repair ladders.
• Use Fall Protection Equipment
• Construct or inspect temporary work platforms.
• Perform work using Rope Access techniques and equipment.

Other measures to prevent injury will include:

• Where there is a Risk of a fall, apply the following Hierarchy of Control:

o First: Eliminate the work at height via design change or scope modification, etc.
o Second: Work from a permanent work platform with guardrails and toe boards
o Third: Work from a temporary work platform (scaffold), or mobile work platform, with guardrails. Assess
the hazards of installing, operating, or maintaining the work platform when deciding whether it is
Reasonably Practicable.
o Fourth: Use personal Fall Protection Equipment
• Periodically inspect Fall Protection Equipment and ladders in line with manufacturers’ recommendations. Verify
that Fall Protection Equipment and ladders that fail inspection are not used.
• Visually inspect Fall Protection Equipment and ladders before each use.
• Tie off 100% of the time when wearing personal Fall Protection Equipment, including while:
o moving to and from the work at height
o moving at height; and within 6 feet of a platform edge without a guardrail
• Verify that anchor points meet relevant parts of ANSI/ASSE Z359 before starting work.
• Use a fit-for-purpose harness and lanyard to tie off personal Fall Protection Equipment to an acceptable anchor
point.
• Use three points of contact at all times when climbing up and down ladders.
• Use a ladder climbing safety device when climbing up or down uncaged ladders when these are 20 ft or longer.
• Determine the method(s) used to rescue people who have fallen, are suspended in a harness and could develop
suspension trauma. Verify the competence of people who are to perform rescues.
• Stop operations if safe conditions cannot be maintained.

5.6 LOCK OUT TAG OUT (LOTO)

5.6.1 GENERAL LOTO DESCRIPTION

The intent of the isolation and lock out tag out system is to manage the risk to people, the environment, and assets,
resulting from exposure to energy (e.g., pressure, electrical, kinetic, temperature) and hazardous substances, during
invasive maintenance, through effective isolation of equipment and the placement of locks and tags. Lock out tag out
(LOTO) is a procedure required to isolate personnel from all potential energy sources when performing maintenance or
service on equipment; especially when that maintenance or service requires the disabling or removal of normal guards
and safety devices.

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The OSHA standard for The Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147) for general industry,
outlines specific action and procedures for addressing and controlling hazardous energy during servicing and
maintenance of machines and equipment. The control of hazardous energy is also addressed in a number of other
OSHA standards, including marine terminals (1917 Subpart C), longshoring (1918 Subpart G), construction (1926
Subparts K and Q), electrical (1910 Subpart S), and electric power generation, transmission, and distribution (1910
Subpart R and 1926 Subpart V).

Atlantic Shores will have written LOTO program in effect for execution and documentation. The 9-step isolation process
is mapped below.

3. Verify no
1. Define 2. Develop
conflicts with
Isolation Scope Isolation Plan
other activities

5. Execute 4. Authorize
6. Verify Isolation
Isolation Isolation

7. Maintain 9. Execute De-

8. Authorize De-
Isolation, perform Isolation and
Isolation
work scope hand back

5.6.2 LOTO PROCEDURE

• All personnel associated with the scope will share information prior to the start of the work requiring LOTO
and agree to make all LOTO procedures uniform for the duration of the project.
• Repairs, maintenance, or other work scopes shall not be carried out on equipment in operation. All
equipment shall be shut down and a LOTO device used in such a manner that the equipment cannot be
accidentally started while being worked on. The power switch of the equipment to be worked on shall be
locked out / tagged out.
• Keys for safety locks shall be stored in a secure location accessible only to those authorized.
• Once locked out and proven to be deenergized, the equipment shall be released for work using a PTW
issued by an appropriately authorized person and explained clearly to the recipient working party.
• The current status of work ongoing under a LOTO and PTW shall be recorded in a log and kept up to date
with every shift change. The log shall be available to all in control of supervision of works at the site.
• To ensure the equipment has been properly locked out of service prior to starting any work, a qualified
person shall attempt to turn on the power source to ensure the equipment does not become energized.

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• Tower/Nacelle Specific – Before equipment is unplugged or plugged into any power system, the power
source shall be locked out / tagged out. This includes all equipment that is unplugged or plugged into
portable generators, transformers, controllers, control panels, etc.
• Examples of equipment repairs or maintenance that require LOTO procedures include, but are not limited to
the following:
 Nacelle hub entry;
 Repairs to electrical systems;
 Generator repairs; and
 Cabling inspection/repairs.

5.7 ACCESS AND EGRESS

All access to the Offshore Project Area is controlled by the Site Manager or designated subordinate and will be
performed to the procedure outlined in the access/egress document. All personnel intending to transfer to the offshore
site require up-to-date sea survival training, medical fitness for duty verification, specific training documents for the work
they are to undertake, and site-specific induction training. The vessel master keeps a log of all persons that board their
vessel and of all the persons transferring onto the differing wind turbines, offshore substations, or other vessels. These
log sheets are maintained for audit purposes.

Access/Egress conditions and risks will be assessed prior to transfer activities via NOAA’s Operational Risk Assessment
or a comparable plan designed by the transfer vessel operator.

5.8 ELECTRICAL SAFETY

Atlantic Shores shall address and minimize personnel exposure to electrical hazards through effective equipment
operation, design, specification, installation, and maintenance. All electrical work shall be done in accordance with the
latest codes, standards, and regulations including NFPA 70E. Electrical hazards include:

• Electric shock/electrocution;
• Electric arc flash;
• Trips and falls;
• Ignition by static electricity in flammable atmospheres; and
• Ignition by electrical equipment in flammable atmospheres.
A subject matter expert for electrical safety will develop Electrical Safety Rules consistent with internationally recognized
standards. These Rules will establish work practices and procedure that minimize the exposure to electrical hazards for
persons working on or near electrical equipment. These will include:
• Defining which people can work on electrical equipment. Only use property trained and authorized
personnel to carry out work on electrical equipment.
• Specify when to require a permit to work.
• Manage work on or near electrical equipment to provide safe isolation.
• De-energize and isolate equipment as required in the Lock Out Tag Out process. Verify there is no voltage.
• Use physical barriers, protective equipment, special tools, or other controls to prevent harm to people when
it is not possible to de-energize equipment.
• Verify electrical drawings are provided and maintained.
• Use equipment and work practices that manage static electricity.

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5.9 HOT WORK

Hot work is defined as welding, flame cutting, burning, grinding, or using a torch. When possible, hot work should be
performed in a shop, outside the facility, or in a Safe Welding Area (“SWA”). A SWA shall be established on all
locations where substantial welding or flame cutting is anticipated. All welding and flame cutting operations shall be
conducted in the established SWA unless otherwise authorized. The location of the SWA will be based on a specific
risk assessment.

If hot work needs to be performed outside of the SWA, especially inside a nacelle, all movable fire hazards in the
vicinity shall be removed to a safe distance or guards used to confine the heat, sparks, and slag, and to protect the
immovable fire hazards. A Work Permit shall be issued for all hot work done outside of the SWA and approved by the
contractor and supervisor. Hazards and recommended special precautions should be documented in the Work Permit.

The hot work equipment and work area shall be inspected prior to beginning any hot work operations to ensure safe
working conditions. This includes checking for explosive atmospheric conditions in all vessels, piping and confined
spaces and documenting the results on the Work Permit. Oxygen and acetylene cylinders shall be stored valve end up
and properly secured. Only certified personnel/welders shall be permitted to perform hot work.

5.10 LIFTING AND HOISTING SAFETY

Only trained and qualified personnel shall operate cranes and other such lifting equipment. All cranes and lifting
equipment shall be strictly maintained in accordance with the manufacturer’s recommendations and regulatory
requirements.
The following requirements will minimize the possibility of an HSSE incident during lifting and hoisting operations:
• Verify Competence Assurance for people in HSSE Critical Positions who supervise or perform Lifting and
Hoisting operations and who inspect and maintain lifting equipment.
• Apply procedures that are approved by a Subject Matter Expert for Lifting and Hoisting
• For Routine Lifts, develop general lifting procedures that identify and control the hazards.
• For all Non-Routine Lifts:
 Assign the Authorized Person for the Lifting and Hoisting operation, and the Person in Charge of The
Lift
 For Non-Routine Simple Lifts:
• conduct a specific Job Hazard Analysis to define the lift plan.
• assess Site Factors to define logistics, crane stability, and radius of operation.
• assess Load Factors to define load integrity and stability.
 For Non-Routine Complex Lifts:
• use a Subject Matter Expert for Lifting and Hoisting to establish the lifting plan.
• assess Site Factors to define logistics, crane stability, and radius of operation.
• assess Load Factors to define load integrity and stability.
• provide the requirements for lifting of personnel.
• provide the requirements for performing Blind Lifts.
• Equipment to be used for Lifting and Hoisting must be inspected, maintained, and certified.
 Use equipment only for its intended purpose and within its designed operating limits.
 Maintain and inspect equipment in line with the manufacturer’s recommendations.
• Manage Non-Routine Lifting and Hoisting in line with the Permit to Work process
• Check the Lifting and Hoisting equipment before all lifts and confirm that.

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 equipment is suitable for its intended purpose.

 safety devices are installed and operational
• Confirm that required Controls are in place and the lift is carried out as per the applicable lift Procedure
• Keep people clear of overhead loads and areas of potential impact
• Assign a flagman when moving cranes near overhead electrical lines, reversing, or manoeuvring in an area
with plant, machinery, or personnel

5.11 HOUSEKEEPING
Good housekeeping is essential so work may proceed in a safe and orderly manner. All walking areas, work areas,
handrails, equipment, tools, firefighting, and life-saving equipment, etc. shall be kept clean and free of obstructions. Tools
should be placed appropriately so as not to cause a hazard to the job at hand while in use, and promptly put away after
use. Hand and power tools shall be kept in good condition with guards in place without modification. Defective tools shall
be repaired by qualified repairpersons or replaced.

6. CONTRACTOR MANAGEMENT
Third party contractors and support services will be integrated into the SMS. Specific requirements will be developed for
contracting, including:

• Minimum requirements for bridging documents

• Contractor safety audits
• Minimum contractor safety training
• Contractor roles in an emergency
Contractors are required to follow the same policies and procedures that Atlantic Shores employees follow for
maintaining safety unless the use of the contractors’ own company safety policies and procedures is approved by
Atlantic Shores prior to starting work. Atlantic Shores will manage all contractors to ensure consistent safety policies and
practices are implemented. Contractor HSSE representative shall be well versed in the project SMS and be responsible
for the following:
• Day-to-day site HSSE supervision (onshore/offshore)
• HSSE monitoring, inspection, and auditing
• Support the HSSE Manager in establishing and fulfilling project training needs.
• Participate in planning and coordination of all marine operations relating to the Project.
• Assist with preparation and maintenance of all HSSE documentation.
• Management of PPE inventory, inspection, and testing
• Participation in HSSE meetings, risk reviews and workshops
• Set an exceptional example of safe work for all others involved with the Project.
Contractor operations should not expose Atlantic Shores employees, contractors, subcontractors, or the public to
hazards in violation of governmental regulations and Atlantic Shores policy. Contractors will submit proof of training and
copies of certificates to the Site HSSE Representative before the start of any work activity. The competencies and
training records of all employees will be requested and examined by the Site HSSE Representative before commencing
work activities.

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6.1 AUDITS
Safety programs for all contractors will be subject to audit by Atlantic Shores. Audits may include review of safety
policies, procedures, training records, etc. and may be performed prior to contracting and during the course of the
contract.

6.2 TRAINING
All contractors will be fully qualified to perform the roles for which they are contracted, including any prescribed safety
standards and training. Atlantic Shores will provide safety orientation to familiarize contractors with any site-specific
safety issues. Contractors may be required to demonstrate, through documentation or practical application, their
knowledge and understanding of safety requirements for offshore wind farm construction.

7. MANAGEMENT OF CHANGE
Atlantic Shores will maintain a procedure for Management of Change (MOC), which helps to identify the potential risks
associated with the change and receive any required approvals prior to the introduction of such changes.

The MOC process provides a coherent, systematic, and simple mechanism for identifying and controlling hazards
through the change process with emphasis on the transition phase. When well implemented, MOC ensures that the
safety of the Project and its personnel are safeguarded by the evaluation of hazards, threats, and other potential
undesired events related to a significant change, and the intended benefits of the change are fully realized as planned.

7.1 ROLES AND RESPONSIBILITIES

The Project Director will be responsible for the implementation of the MOC program. All MOC documentation will be
maintained by the HSSE Manager. Any Atlantic Shores employee can initiate the MOC process.

7.2 MANAGEMENT OF CHANGE PROCESS

The Management of Change policy shall be utilized for at least the following changes whether they are temporary or
permanent:

• Physical Changes: including work site changes such as changes in construction vessels, working platforms,
access and egress locations, etc.
• Organizational Changes: including changes in personnel, individual responsibilities, contractor or sub-
contractor changes, etc.
• Technological Changes: including changes in equipment, equipment design, software controls or the
technology used on the work site, etc.
• Procedural Changes, including changes to processes (i.e., work schedules, materials, equipment
unavailability, new equipment, or operating conditions.
Atlantic Shores will develop a form to facilitate the processing of changes. The change form will, at a minimum, include a
description and the purpose of the change, the technical basis for the change, safety and health considerations,
documentation of changes for the operating procedures, maintenance procedures, inspection and testing, P&IDs,
electrical classification, training and communications, pre-startup inspection, duration of applicability, approvals, and
authorization.

For a more complex or significant design change, a hazard and risk evaluation procedure will be used, such as a Hazard
Identification (HAZID) workshop. HAZID is further described in Section 11. Risk assessments should demonstrate that
the risks with controls are “As Low as Reasonably Practicable.” Contractors also have a responsibility to carry out risk
assessments based on the risks associated with their scope of work.

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Documentation of changes will be kept in an accessible location to ensure that design changes are available to any
member of Atlantic Shores who may require them.

7.3 MANAGEMENT OF CHANGE COMMUNICATION

The communication of changes to appropriate personnel is essential to safety and preventing incidents. The following
lists activities that fulfil those requirements:

• A meeting of all involved parties will be held for major changes in Project organization, procedure, or
technology; and
• An e-mail notification will be sent out to all team members for each implemented change agreed in the
meeting.
When appropriate, additional measures (such as trainings or awareness sessions) will be employed to ensure the
change is appropriately communicated and understood by all relevant parties.

7.4 TRAINING REQUIREMENTS

All individuals will receive initial training on the MOC program and will also receive refresher training as required.

7.5 MANAGEMENT REVIEW

On an annual basis, management will review the MOC process and advise improvements or areas to refocus. The
management team and the HSSE Manager will ensure that the MOC policy has been properly implemented and all
elements have been completed and documented.

7.6 AUDITS AND ASSESSMENTS

Audits of the MOC program shall validate that the exercise of the MOC policy includes the following:

• Reason for change

• Authority for approving changes
• Analysis of implications
• Acquisition of required work permits.
• Documentation of change process
• Communication of change to affected stakeholders inside and outside the organization.
• Time limitations
• Qualification and training of personnel affected by the change (including Contractors)

8. UNSAFE WORKING CONDITIONS

All employees, contractors, and subcontractors have the personal responsibility and work-place authority to report any
unsafe work practice or to immediately stop any unsafe work practice during operations.

Unsafe work conditions may be reported anonymously. Emergent safety issues shall be addressed immediately.

8.1 REPORTS OF UNSAFE WORK CONDITIONS

All employees, contractors, and subcontractors shall report to the appropriate supervisor any violation of a safety
regulation or any other hazardous or unsafe working condition on any Atlantic Shores owned or leased property, facility,
structure, or equipment. They may also report any unsafe practice or condition occurring while engaged in Atlantic

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Shores business.

8.2 STOP WORK AUTHORITY

All employees, contractors, and subcontractors have the responsibility and authority to intervene in an effort to stop any
unsafe task or operation where the risk to people, the environment, or equipment cannot be managed in accordance with
Atlantic Shores’ established safety policies, procedures, or safe work practices.

No employee or contractor will be retaliated against for stopping work that is based on a good faith belief that it is unsafe.

9. SAFETY TRAINING AND FITNESS

As part of the safety culture, safety training is on ongoing component of the Atlantic Shores safety program. Safety
training and awareness will include the following topics, as well as any emergent safety issues that may arise. The
training topics listed in this section are the minimum required training for all employees, contractors, and subcontractors.

Orientation Training Visitors

• Site safety rules for moving around on the site.

• Safety equipment for moving around on the site.
• Restricted areas
• Emergency protocol and muster points
• Who to contact in an emergency or with a safety related need.

Site workers

• All visitor topics

• Driving rules (on site and off site)
• Hazardous substances
• Waste, dust emission and noise on site
• Permit to work systems.
• Accommodations for workers
• PPE requirements
• Employee and Contractor general roles and responsibilities
• Incident reporting procedure
• Site security

Example of Minimum HSSE training requirements depending on job function.

• Working at heights
• Electrical safety
• Water survival
• Confined space entry
• First aid and CPR
• Fire fighting

*Example of Specialized and Task Specific Training

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• Use of specialized equipment

• Scaffolding and personnel platform equipment
• Diving operations
• High voltage and switching

Medical Audits and Fitness for Duty: Pre-employment screening completed by an occupational doctor may consist of the
following:

• Medical history
• Occupational history
• Physical Examination
• Determination of fitness to work wearing PPE
• Baseline monitoring for specific exposures
• Respirator fit test

Periodic Medical Examination completed by an occupational doctor may include:

• Yearly update of medical and occupational history

• Yearly physical examination
• More frequent testing based on specific exposures

10. PERSONAL PROTECTIVE EQUIPMENT

All Atlantic Shores employees, contractors, and subcontractors will receive training or shall be able to demonstrate that
they have received training on Personal Protective Equipment (PPE) and its requirements for use, maintenance, and
care for all specific safety related equipment, as appropriate.

At a minimum, the following PPE will be included:

• Eye and face protection

• Head protection
• Foot protection
• Hearing protection
• Protective clothing
• Respiratory protection
• Safety belts and lifelines
• Personal flotation devices (PFDs)
• Eyewash equipment

In addition to care and maintenance of PPE, training will also address:

• Housekeeping
• Guarding of deck openings when required

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11. DESIGN AND EQUIPMENT

11.1 LIGHTS AND WARNING DEVICES

Appropriate lights and warning signals will be deployed during construction and when the Project is operational.
Requirements for lights, markings, and warning devices for structures are codified in 33 CFR Part 67. Structure lights
and warning devices will comply with relevant guidelines and regulations including the following:

• General
o BOEM Draft Proposed Guidelines for Providing Information on Lighting and Marking of Structures
Supporting Renewable Energy Development
• Aids to Navigation
o USCG District 5 Local Notice to Mariner (LNM) 45/20
o USCG COMDTINST M16500.7A Aids to Navigation Manual - Administration, Chapter 4 section G,
Offshore Renewable Energy Installation – 02 March 2005
o NVIC 01-19 Guidance on the Coast Guard’s roles and responsibilities for offshore renewable energy
installations (OREI)
o Navigation Regulations 33 CFR Part 67: Aids to navigation on artificial islands and fixed structures
o IALA Recommendation 0-139: The Marking of Man-Made Offshore Structures
• Obstruction Lighting
o FAA Advisory Circular 70/7460- 1M Obstruction Marking and Lighting
o FAA Advisory Circular 150-5345-43J Specification for Obstruction Lighting Equipment

11.2 FALL PROTECTION SYSTEMS

Design of fall protection systems and anchor points will comply with all relevant parts of ANSI/ASSE Z359. Guardrails
and other permanent forms of fall protection will be designed in accordance with generally accepted industry standards
and applicable regulations, including:
• 33 CFR §142.87 -- Guarding of deck openings, which provides requirements for guarding decks of offshore
structures.
• 29 CFR §1910.29 -- Fall protection systems and falling object protection—criteria and practices, which provides
requirements for handrails of elevated platforms and walkways.
• ISO 14122 series Safety of machinery – Permanent means of access to machinery, which provides requirements
for guardrails and other permanent forms of fall protection

11.3 LOCK OUT TAG OUT

Equipment will be designed so that Lock Out Tag Out (LOTO) procedures compliant with 29 CFR Part 1910, Subpart J,
Section 147 can be used during operation. Design of machinery, electrical, and hydraulic fluid power systems for safe
isolation will comply with ISO 14118, IEC 60204-1, and ISO 4413, respectively.

11.4 CONFINED SPACE

Equipment will be designed to support the use of confined space procedures compliant with 29 CFR Part 1910, Subpart
J, Section 146 during operation.

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11.5 BOAT LANDINGS

Boat landings will meet requirements provided under 33 CFR §143.105 (Personnel Landings).

11.6 MEANS OF ESCAPE

All structures shall be equipped with escape means, as appropriate for unmanned structures and in accordance with the
requirements of 30 CFR §143.101.

11.7 PERSONNEL LANDINGS

Personnel landings will be provided on all structures and will consist of boat landings and access ladders. Guards and
rails will be installed for the unprotected perimeter of all floor or deck areas and openings, catwalks, and stairways.
Training will ensure all workers are aware of the requirements and have sufficient knowledge to report any deficiencies.

11.8 LIFESAVING EQUIPMENT

Lifesaving equipment will be provided in compliance with SOLAS Chapter III – Life-Saving Appliances and Arrangements
and 46 CFR Part 160 as far as practically possible. This includes:

• Survival (transfer) suits will be worn for marine transfer to/from vessels when a risk assessment considering air
and water temperatures, other PPE interactions, expected duration of exposure, tidal strength, expected vessel
reaction times, etc. warrant.
o These survival suits will conform to USCG – UL1197 and/or be SOLAS approved.
o Survival suits will always be coupled with a suitable USCG compliant industrial life jacket.
• Personal Floatation Devices / Work Vests are required for all personnel who require transport and access to the
wind farm.
o Atlantic Shores will provide awareness training on the type(s) of approved PFDs and their uses,
stowage, care, and inspection, including additional requirements for hybrid work vests, if used.
o These PFDs will be USCG approved and fitted with an integrated Personal Locator Beacon.

11.9 FIRE DETECTION AND SUPPRESSION

The fire and safety design are dependent on the selected operational philosophy (e.g., manned versus unmanned
platform and the resulting design risk assessment). A fire hazard analysis will be performed to identify the critical
scenarios and the actual mitigation for each scenario, utilizing applicable NFPA codes where possible.

A SOLAS approved fire, smoke and heat detection system based on the self-monitoring principle should be installed in
accommodation, machinery spaces and other areas deemed high risk. The fire detection system should be designed to
rapidly detect the onset of fire in areas covered by the detectors and should include both audible and visual alarms
where appropriate. Appropriate fire extinguishing equipment shall be provided, each clearly labeled as to the type of fire
that each is suitable for. Locations of such equipment must be strategically placed and clearly marked in accordance with
SOLAS requirements.

Project design and firefighting systems will be consistent with the following standards, at a minimum:

• 46 CFR 108 Subpart D, Fire extinguishing systems

• 29 CFR 1910 Subparts E, Exit Routes and Emergency Planning
• 29 CFR 1926 Subpart F, Fire Protection and Prevention
• 29 CFR 1910 Subpart L, Fire Protection

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• 33 CFR Part 145 Firefighting Equipment

• Applicable NFPA standards

11.10 MAINTENANCE OF EMERGENCY EQUIPMENT

Each piece of emergency equipment will be part of the Atlantic Shores maintenance program. All emergency equipment
in use will be listed and include a description of the maintenance requirements or technical references for maintaining
each piece of equipment.

12. REMOTE MONITORING, CONTROL, AND SHUTDOWN CAPABILITIES

12.1 SCADA SYSTEM

The Project’s Supervisory Control and Data Acquisition (SCADA) system will provide the operator with the capability to
remotely monitor and control the project assets, including the ability to shut down the equipment remotely if necessary.

The SCADA system will continuously assess the status of the wind turbines and subsystems. Control room operators will
observe how the plant is functioning and can make modifications or interventions remotely as required.

The system will incorporate redundancies, such as multiple network connections (e.g., a combination of radio, fiber optic
cables, satellite, LTE) to ensure constant control of project assets. Primary communication will be the fiber optic cables
connecting each wind turbine, the offshore substations, and the onshore substations.

12.2 FAIL SAFE SYSTEMS

In addition to the capabilities of the SCADA system, the wind turbines will utilize standard fail safe mechanisms (e.g.,
mechanical brakes, pitch systems to feather blades) and protocols. In the event that the wind turbines lose power or are
communications with the operations facility; these systems will ensure that the turbines initiate a safe shutdown until the
connection is restored and system integrity is verified.

13. EMERGENCY RESPONSE

The SMS is primarily focused on preventing incidents. However, it is also critically important to be prepared if
emergencies do occur. For this reason, Emergency Preparedness and Response plans are essential for responding
effectively to an incident. Proper planning, training, and drilling will ensure that any impact of an incident will be kept to a
minimum for the public and the environment.

Emergency response plans will be developed for a range of emergency situations. Plan development will include
procedures for testing emergency plans through drills and exercises. Plans will be developed, at a minimum, for the
following scenarios:

• Collision between vessel and structure

• Fire on structure and/or service vessel
• Evacuation
• Pollution incidents
• Adverse weather
• Vessel in distress, man overboard, and Search & Rescue
• Remote monitoring, Control and Shut Down procedures

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13.1 TRAINING REQUIREMENTS FOR EMERGENCY RESPONSE

Individuals who will lead emergency responses, as well as those who will participate as emergency response team
members, will receive initial training prior to their first involvement in an emergency response. These individuals shall
also receive refresher training on an annual basis.

Data and other observational information from past drill and actual events shall be incorporated into training. Learning
from external events not related to Atlantic Shores shall also be incorporated as applicable.

14. HAZARD IDENTIFICATION AND RISK MANAGEMENT

Managing risk effectively is critical to achieving the HSSE objectives under this management system. Atlantic Shores will
review HSSE risks associated with planned operations, assess the impact and likelihood of the risks materializing, and
implement effective actions designed to safeguard assets to enable safe operations.
Comprehensive risk management will reduce risks and mitigate consequences associated with safety, health,
environmental and security incidents by providing essential information for decision-making and planning of work
activities. The goal will always be to reduce the hazard to a level as low as reasonably practicable.
• A process including risk analysis methodology will be established that involves hazard identification, risk
assessment, selection of controls and mitigation (recovery) measures to reduce risk to the Lowest
Practicable Level.
• HSSE hazards will be identified and documented including their effects on people, assets, community and
the environment in a Hazard and Effects Register, including methods for managing the risks.
• Instruction, training, and supervision will be provided so that employees, contractors, and subcontractors
(as applicable) are competent to apply the HSSE & SP risk analysis methodology in their area of
responsibility.
• Security risk management will be conducted in accordance with national legal requirements and
Internationally Recognized Standards, including the Voluntary Principles on Security and Human Rights
• Environmental risks will be identified and assessed together with consultation from a Subject Matter Expert
to determine impacts to the environment.
• Health risks will be identified and assessed together with consultation from a competent person to
determine potential impacts to people.
• Risk assessments will be conducted for ongoing Atlantic Shores projects and operations to identify and
address potential hazards to people, assets, the community and the environment.
• Assessed risks will be addressed and documented by specified levels of management appropriate to the
nature and magnitude of the risk.
• The Hazard and Effects Register will be reviewed and updated when existing operations/activities are
changed in a way that would change the hazards or reduce the effectiveness of controls and mitigation
measures, and when learning is established as an outcome from incident investigations.
• A follow-up process will be established to ensure that risk management decisions are implemented into
plans, procedures, training programs and as part of the Management Review process.

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Risk Assessment Matrix

Likelihood
10-1 10-1-10-2 10-2-10-3 10-3-10-6 <10-6
Known to have Almost
Happens often Known to have Conceivable
occurred impossible.
Consequences and might be
within
occurred within but unusual in
Rare or absent
expected industry industry
Company in industry.
A B C D E
#
Frequent Occasional Possible Unlikely Improbable
-More than 3 fatalities or multiple life- 5
threatening injuries.
-Total loss of asset
Massive
-Massive Environmental/Community Effects Effect
-Up to 3 fatalities or 1 life-threatening injury 4
-Major Environmental/Community Effects Major Effect
3
-Major injury or health effect
-Moderate Environmental/Community Impact
Moderate
Impact
-Minor injury or health effect 2
-Minor Environmental/Community Impact Minor Effect
1
-Slight injury or health effect
-Slight or no Environmental/Community Impact
Slight or No
Effect

15. IMPLEMENTATION, MONITORING, AND REPORTING

15.1 IMPLEMENTATION
The HSSE Manager ensures that the SMS is implemented and monitors the program’s effectiveness using both proactive
and reactive measures. The preparation of an SMS process is only the first step in the implementation of a safety
management system. Execution of plans and implementation of procedures means putting them into practice. This is
most easily achieved if specific individuals are given responsibility for the implementation of plans and procedures
(sometimes key procedures may have a ‘process owner’ [e.g., Management of Change, Permit to Work]). The HSSE
Manager will work with Project Director to assign the appropriate individuals with specific SMS implementation tasks.
While the Project Director has the highest authority for all project personnel, the HSSE Manager has the authority to
intervene on matters related to SMS implementation and will report back to the Project Director, as needed.
These individuals should have roles that cover:
• Identifying people to lead aspects of the plan execution and identify process owners for key procedures to
drive implementation, monitor effectiveness and manage improvement.
• Communicating plans and procedures to those affected.
 Clearly communicating who plans and procedures are for and who is expected to follow them.
 Clearly defining who is responsible for actions that need to be taken.
• Acting as leaders to set expectations and to follow up on progress.
 Measure progress against clear milestones and/or KPIs and take action to adjust where it is clear that
events are not going as per plan.
• Demonstrating commitment at all levels to execute the plans and to implement procedures.

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• Providing training in procedures so that those who need to follow them know what is expected.

15.2 PERFORMANCE MONITORING

Plans and Procedures put in place to meet SMS requirements need to be monitored regularly to ensure they are in place
and working effectively. Monitoring can be either pro-active (e.g., inspections and audits) or reactive (e.g., incident
reporting). In both cases the results should be used to understand any weaknesses in plans and procedures and to
identify corrective actions. Monitoring activities should be prioritized based on risk. Activities that check that controls are
in place and effective range from:
• Field Inspections
• Management Safety Walks
• Formal Behavioral Safety Observation Programs
• Self-Assessment checks
• Checks on logs e.g., shift handover logs,
• Procedure Checks and Audits
Atlantic Shores will establish and maintain effective systems of monitoring HSSE performance and SMS compliance.
Data will be recorded and reported, including:

• Providing input for the HSSE targets and KPIs

• Reporting and communicating the key messages obtained from HSSE statistics gathered
• Reportable incidents
• Exposure hours
• Environmental data (waste generated/disposed, spills, releases, etc.)
• Fines and settlements
• Annual management review of the SMS to assess its suitability and effectiveness, to propose amendments,
and to report status to the Board of Directors

15.3 INCIDENT REPORTING

15.3.1 SAFETY OBSERVATION AND NEAR MISS REPORTING

• Safety observations should be either immediately corrected or reported so that an appropriate action can be
completed.
• All near misses must be formally reported by employees, contractors, and subcontractors as soon as
practical after the event. Every near miss will be investigated by the Site EHS Manager or the appropriate
designee.
• Where appropriate, drills will be carried out to maintain a robust emergency process and competence to
ensure measures adopted from near misses are appropriate.

15.3.2 NOTICE OF INCIDENTS

Atlantic Shores will maintain and follow an evergreen Project-specific Incident Communication Plan that includes internal

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 HSSE Safety Management System

and external reporting. Atlantic Shores will report to BOEM all incidents in the manner described in 30 CFR §585.832
and 30 CFR §585.833.

This includes immediate verbal reporting and written notifications within 15 days for:

• Fatalities, which also include a written report of casualty in accordance with 33 CFR §146.30.
• Incidents that require the evacuation of person(s) from the facility to shore or to another offshore facility.
• Fires and explosions
• Collisions that result in property or equipment damage greater than $25,000.
• Incidents involving structural damage to an OCS facility that is severe enough so that activities on the
facility cannot continue until repairs are made.
• Incidents involving crane or personnel / material handling activities, if they result in a fatality, injury,
structural damage, or significant environmental damage.
• Incidents that damage or disable safety systems or equipment (including firefighting systems)
• Damage affecting the usefulness of primary lifesaving or firefighting equipment.
• Other incidents resulting in property or equipment damage greater than $25,000.
• Any other incidents involving significant environmental damage or harm.

A written report must be provided within 15 days for:

• Any injuries that result in the injured person not being able to return to work or to all of their normal duties
the day after the injury occurred.
• All incidents that require personnel on the facility to muster for evacuation for reasons other than weather or
drills.

In addition:
• The USCG shall be notified immediately of any HSSE incident requiring their assistance offshore.
• The USCG and USACE must be notified for all operations and incidents impacting the seabed.

15.3.3 POLLUTION INCIDENTS

Pollution incidents will be reported in accordance with 33 CFR §146.45. The approved Atlantic Shores Oil Spill Response
Plan (per 30 CFR Part 254) will be followed for specific pollution response actions.

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