Health & Safety Policy

1. Policy Statement

2. Legal & Regulatory Framework

• Occupational Safety and Health Act (OSHA), 2007 — the primary legislation governing workplace health and safety in Kenya.
• Work Injury Benefits Act (WIBA), 2007 — governing compensation for workers injured in the course of employment.
• National Construction Authority (NCA) Act, 2011 — regulating the construction industry and contractor standards.
• Environmental Management and Coordination Act (EMCA), 1999 (revised 2015) — governing environmental protection on construction sites.
• National Environment Management Authority (NEMA) Regulations — including Environmental Impact Assessment (EIA) requirements.
• The Building Code and County Government Construction Regulations — applicable to all building works.
• Kenya Bureau of Standards (KEBS) — standards for materials, equipment, and PPE used on site.

We hold valid NCA registration and ensure all subcontractors engaged on our projects are registered and compliant with applicable regulations.

3. Our Commitments

• Conducting thorough risk assessments before commencement of any project or significant work activity.
• Implementing method statements and safe work procedures for all high-risk activities.
• Providing all workers with appropriate, certified PPE at no cost to the worker.
• Ensuring all plant, machinery, scaffolding, and equipment is regularly inspected, certified, and maintained.
• Providing site-specific health and safety inductions to all workers, subcontractors, and site visitors before they commence activities.
• Appointing a competent Health & Safety Officer or site supervisor on all active project sites.
• Maintaining accurate records of all incidents, near-misses, and safety inspections.
• Conducting regular toolbox talks and safety briefings with site teams.
• Ensuring adequate welfare facilities including clean water, sanitation, and first aid are available on all sites.
• Reviewing and continuously improving our health and safety performance.

4. Employee & Worker Responsibilities

• Comply with all health and safety instructions, site rules, and safe work procedures.
• Wear and correctly use all PPE provided for their specific task and site conditions.
• Report all accidents, near-misses, unsafe conditions, and hazards immediately to their supervisor.
• Not operate any plant, machinery, or equipment without the required training, certification, and authorisation.
• Refrain from working under the influence of alcohol, drugs, or any substance that impairs judgement.
• Participate in all safety inductions, toolbox talks, and training sessions.
• Take reasonable care of their own health and safety and that of others who may be affected by their actions.
• Not interfere with or misuse anything provided for health and safety purposes.

Workers who fail to comply with health and safety requirements may be removed from site. Serious or repeat violations may result in disciplinary action or termination of engagement.

5. Subcontractor & Supplier Responsibilities

• Hold valid NCA registration and all relevant licences for the works they are engaged to perform.
• Submit their own Health & Safety policy, method statements, and risk assessments before commencing work.
• Ensure their workers are adequately trained, supervised, and equipped with appropriate PPE.
• Comply with Creekohme's site-specific safety rules and the principal contractor's Health & Safety Plan.
• Report all accidents, incidents, and near-misses to the Creekohme site manager immediately.
• Maintain valid WIBA coverage for all workers engaged on Creekohme project sites.

6. Personal Protective Equipment (PPE)

• Safety helmets (hard hats) — mandatory for all personnel on active construction sites.
• High-visibility vests — required in all areas where vehicles or moving plant operate.
• Safety footwear (steel-toed boots) — mandatory for all site workers.
• Gloves — required for any manual handling, concrete work, or tasks involving sharp or hazardous materials.
• Eye protection — required during cutting, grinding, welding, or use of chemicals.
• Hearing protection — required in high-noise environments above 85 dB.
• Fall protection harnesses — mandatory for any work at height above 2 metres.
• Respiratory protection — required where dust, fumes, or hazardous substances are present.

Task-specific PPE requirements are identified in the Risk Assessment and Method Statement (RAMS) for each activity. Site supervisors are responsible for enforcing PPE use.

7. Incident Reporting & Investigation

• Immediate response — first aid or emergency services to be called as required. The site supervisor is to be notified immediately.
• Preservation of scene — the incident scene is to be preserved until an investigation can be conducted.
• Incident report — a written incident report is to be completed within 24 hours of the incident.
• Investigation — a root cause analysis is to be conducted within 48 hours for all Lost Time Injuries (LTIs) and dangerous occurrences.
• Statutory reporting — fatalities, serious injuries, and dangerous occurrences are to be reported to the Director of Occupational Safety and Health Services (DOSHS) as required under OSHA 2007.
• Corrective action — preventive measures are to be implemented and documented.

8. Emergency Preparedness

• Fire emergency procedures and fire assembly points.
• Medical emergency response including locations of first aid kits and nearest medical facilities.
• Evacuation procedures and emergency exit routes.
• Contact details for emergency services: Police (999/112), Ambulance (999/0800 720 999), Fire Brigade (999), and DOSHS.
• Procedures for environmental incidents including chemical spills.
• Communication protocols for notifying management, clients, and authorities.

All site workers are briefed on the ERP as part of their site induction. Emergency drills are conducted at least once per project.

9. Environmental Responsibility

• Obtaining all required Environmental Impact Assessment (EIA) licences and permits before project commencement.
• Minimising waste generation and ensuring proper segregation, storage, and disposal of construction waste.
• Preventing soil erosion, sedimentation, and water pollution on and around project sites.
• Avoiding unnecessary disturbance to vegetation, protected trees, and wildlife habitats.
• Controlling dust, noise, and vibration to minimise impact on neighbouring communities.
• Promoting the use of locally sourced, sustainable materials where practicable.

10. Training & Competence

• OSHA-compliant site safety inductions for all new workers.
• First Aid training for all site supervisors and designated first aiders.
• Specialised training for operators of plant, machinery, and equipment.
• Working at height and scaffolding safety training.
• Fire safety and emergency response training.
• Environmental awareness training.
• PPE selection, use, and maintenance training.

Training records are maintained for all employees and made available for inspection by DOSHS or other regulatory authorities on request.

11. Policy Review

12. Contact & Reporting

For statutory reporting of serious incidents, contact the Directorate of Occupational Safety and Health Services (DOSHS): doshs.go.ke