The audit report summarizes the initial review of the Nylex Water Solutions site in Ingleburn, NSW, Australia. It finds that while the site has a can-do attitude towards safety, more systematic approaches are needed to comply with health and safety requirements. Areas for improvement include site induction protocols, emergency management systems, compliance with company standards, and machine guarding. The report provides specific actions needed across several areas to improve safety and compliance.

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SH&E INTERNAL AUDIT
Pilot Programme – Intital Review
NYLEX WATER SOLUTIONS
Nylex Water Solutions – Ingleburn NSW
3B Williamson Road, Ingleburn 2565
GREG LAZZARO
31th
March 2005

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Activity No SE-001
Date 31/3/05
Surveillance Audit
Site: Nylex Water Solutions, Ingleburn
Site Address: 3B Williamson Rd, Ingleburn
New South Wales, Australia
Standards: Safety, Health & Environment Initial Review
Scope of Audit: Occupational Health and Safety Management System & Environment
Management system “initial compliance review” for the manufacturing
site and processes employed in the manufacture of a range of moulded
tanks and accessories. The audit will also focus on functional
compliance areas requiring improvement.
Prepared By: Greg Lazzaro
COMMERCIAL- IN – CONFIDENCE
The contents of this report must not be disclosed to a third party without the agreement of Nylex Limited

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Introduction
Nylex Head Office conducted an audit of Nylex Water Solutions, 31th March 2005.
The purpose of this audit report is to summarise the degree of compliance with relevant criteria, as
defined on the cover page of this report, based on the evidence obtained during the review of Nylex
Water Solutions.
Audits are carried out within the requirements of Occupational Health and Safety Management
Systems requirements appropriate to a business and also observations related to site inspections.
Executive Overview
The Ingleburn Water Solutions Facility is located in a well established light industrial area about 44km SW of
Sydney. The factory was established in late 2004 and the site was previously tenanted by a company that
recycled copper from the electrical industry (Resource Recycling Technologies).
The site at Ingleburn is made up of two factory areas which has been spilt into production and fit out areas.
The site has currently 5 employees and all employees have a can do attitude and very conscious of safe
working practices. It is however, a site that requires a systematic approach towards complying with
occupational, Health & Safety requirements from a basic perspective at least for the short term. Areas of
improvement are with site induction protocols, emergency management and evacuation systems, compliance
with Nylex Limited standards and a general blending in towards the way in which we expect to eventually run.
It must be said that the site leadership has taken the initial safety issues as a priority and whilst much work
can be done, the ingredients exist for quite a practical and safety focused operation.
The site has a number of machines that will require a more focused risk assessment process and the ability
for the site to improve its machine and operator interface. Task based duties will also be required to be
examined to ensure that there is a consistency in good practices within all the Water Solutions business. The
involvement with Pakenham site is also a very beneficial in the initial setup of systems but again there needs
to be more attention focused in this area before the standard operating practices are set.
The machine guarding issue will be rolled out across the business with Pakenham being the lead as its focus
is more prominent on these areas of Safety. It has been discussed that these methods will then be passed
over to the other water businesses.
The site has scope for improvements but, at this early stage, the site manager has a can do focus and
demonstrates that the requirements for implementing the safe and practical and complaint operation whilst
extracting information from the other Nylex Water Solutions businesses.
The Audit Team Comprised:
• Leader: Greg Lazzaro
Nylex Water Solutions Site Representative : Barry Lewis

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Many aspects of the original lease requirements have not been done.
The concrete pad to the rear of the premises is one of these and
requires to be done as the uneven ground will cause difficulty in the
stability of the forklifts on site.
The tank storage areas are organised so that there is minimal isle ways
and also obscured vision. It would be recommended that all persons
including truck and delivery drivers, wear fluorescent jackets whilst on
site. Although this is done there are no visible indicators or signage to
reflect this.
Some of the machines are in various stages of serviceability with the
rotational rock & roll open flame machine located in the annexure of the
main building. This was found to have faulty bearing arrangement and
other units will be retrofitted in order to ensure that the coupling is
suitable for ongoing operation.

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Access platform for the “Rotoline”
oven has no fall protection gate or
chain making the platform
vulnerable to persons falling if
they were to lose footing. This
platform should be retrofitted to
ensure that a gate or restraint
chain is present.
Utilities pipe rack should be painted or taped yellow to ensure that there
is no striking the rack with a ladder or other equipment. It ensure that
the walkway has this more highlighted
Machine segregation is most effective around the enclosed oven at the
site. This was seen to be a very good safety initiative and should be
duplicated around other machinery.
Gas trains should have appropriate certification and ongoing
maintenance checks as per the requirements of the appropriate codes.
Systems should be in place to ensure that the PM program is
established and put into practice.
Plant lighting is adequate in most areas. Improvements in housekeeping
would be an opportunity for improvement within the business. The way
in which the site deals with this will roll out once there is more of a
system based approach introduced. At the moment, this will be
controlled by site leadership. Segregation could also be done with an
extensive line marking system. This will ensure a traffic management
program exists.

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Protection of gas pipelines should be considered where the risk of
striking or impact is likely. In areas where forklift or pallets will be used,
the gas trains should be protected from mechanical damage.
The forklift gas bottle storage is currently not compliant. Bottles should
be stored in an appropriate area, which is segregated form trafficable
areas and chained. This will ensure that the minor storage requirements
for DG regulations are met.
Warehouse area where product fit out is done has dusty environment.
Housekeeping could be more effective in this area.
The installed pallet racking has no foot protection, which could lead to
striking, and potentially racking could become unstable. It is
recommended that the racking have footing protection installed.
There is a rather large mould stored alongside the racking limiting the
access to the restrooms located behind where the mould is stored. It
seems that this is not the appropriate place for this mould given that the
congestion in the area.

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The general gardening around the site is not satisfactory and will impinge
on various aspects of the site systems. Air conditioning systems currently
run the risk of becoming in effective unless garden growth is controlled.
Natural Gas supply installed by Nylex Limited. Awareness of gas isolation
and emergency scenario’s should be made aware to all personnel in the
gas of a major gas leak or fire. Inclusion in the site induction programs is
required.
The systems are lacking, as the operation is fairly new. Emergency
planning and evacuation programs should be set up and also
management systems for the operation including what is expected from
employees in terms of PPE, SH&E reporting, process of managing
Occupational Health issues and a variety of systemic programs that
would need to be rolled out. Operational based systems such as work
order and permits for various types of work and contractor induction
process would also be required.
An overall transition to the Safety Framework would also be
recommended so that there is consistency with the Nylex Limited
business standards and systems.
Environmental bunding is used well but as inventory increases, a focus
on proper storage of DG should be implemented. DG cupboard should be
used if storing flammable liquids. The site would need to follow the
Environmental Minimum standards to get an appreciation of would be
required as the site expands its workload.

8. SUMMARY OF AUDIT
ACTIONS LISTING PAGE 0 OF 2
ACTION NUMBER ACTION Person Responsible Due Date
1 NWI-1/S 001 The concrete pad to the rear of the premises has uneven ground will cause
difficulty in the stability of the forklifts on site. This should be addressed by the
landlord.
2 NWI-1/S 002 All persons including truck and delivery drivers should wear fluorescent
jackets whilst on site. There are no visible indicators or signage to reflect this.
3 NWI-1/S 003 Examine the serviceability with the rotational rock & roll open flame machine
as one was found to have faulty bearing arrangement and other units to be
retrofitted in order to ensure that the coupling is suitable for ongoing
operation.
4 NWI-1/S 004 Access platform for the “Rotoline” oven has no fall protection gate or chain
making the platform vulnerable to persons falling if they were to lose footing.
This platform should be retrofitted to ensure that a gate or restraint chain is
present.
5 NWI-1/S 005 Utilities pipe rack should be painted or taped yellow to ensure that there is no
striking the rack with a ladder or other equipment.
7 NWI-1/S 006 Gas trains should have appropriate certification and ongoing maintenance
checks as per the requirements of the appropriate codes. Systems should be
in place to ensure that the PM program is established and put into practice.
8 NWI-1/S 007 Protection of gas pipelines should be considered where the risk of striking or
impact is likely. In areas where forklift or pallets will be used, the gas trains
should be protected from mechanical damage.
9 NWI-1/S 008 The forklift gas bottle storage is currently not compliant. Bottles should be
stored in an appropriate area, which is segregated form trafficable areas and
chained. This will ensure that the minor storage requirements for DG
regulations are met.
10 NWI-1/S 009 Warehouse area where product fit out is done has dusty environment.
Housekeeping could be more effective in this area.
11 NWI-1/S 010 The installed pallet racking has no footing protection, which could lead to
striking, and potentially racking could become unstable. It is recommended
that the racking have footing protection installed.

9. SUMMARY OF AUDIT
ACTIONS LISTING PAGE 0 OF 2
12 NWI-1/S 011 There is a rather large mould stored alongside the racking limiting the access
to the restrooms located behind where the mould is stored. It seems that this
is not the appropriate place for this mould given that the congestion in the
area.
13 NWI-1/S 012 The general gardening around the site is not satisfactory and will impinge on
various aspects of the site systems. This should be addressed in a timely
fashion.
14 NWI-1/S 013 Personnel should be made aware of Natural Gas supply control valve set at
the front of the premises in the event of a major gas leak or fire. Inclusion in
the site induction programs is required for gas isolation and emergency
scenario’s.
15 NWI-1/S 014 Suggested implementation of a site safety manual which has key criteria for
dealing with SH&E basics, eg induction, PPE, scope of work safety and
contractor management. This should be followed by more formal systems of
SOP‘s.
16 NWI-1/S 015 An overall transition to the Safety Framework would also be recommended so
that there is consistency with the Nylex Limited business standards and
systems.
NWI Nylex Water Ingleburn 001 Rec./ Obs. Number
1 Audit Number S Safety Item
E Environmental Item