Health & Safety Policy

Spiral Renewables designs, procures and delivers electrical infrastructure for electric vehicle charging. We work principally on operating petrol filling stations — sites where fuel is stored and dispensed while the public are present, and where the consequences of getting safety wrong are severe.

Our commitment

The board accepts that health and safety is a duty we own, not one we can pass down the contract chain. So far as is reasonably practicable, we provide and maintain safe systems of work, a safe working environment, safe plant and equipment, and the information, instruction, training and supervision our people need to work without harm to themselves or to anyone else affected by what we do.

We commit to:

• Complying with the Health and Safety at Work etc. Act 1974 and all subordinate legislation applying to our operations, treating legal compliance as a floor and not a target
• Assessing the risks arising from our work and eliminating them at source wherever we can, and controlling them where we cannot
• Discharging in full the duties that fall to us under the Construction (Design and Management) Regulations 2015, in whichever dutyholder role we occupy on a given project
• Appointing competent people, and giving them the training, equipment and authority to work safely
• Consulting our workforce on matters affecting their health and safety, and acting on what they tell us
• Selecting subcontractors on competence as well as price, and managing them as though their people were our own
• Investigating every accident, incident and near miss, and acting on what we learn

Every person who works for Spiral Renewables, or on our behalf, has the authority to stop work they believe to be unsafe. Nobody will be criticised or disadvantaged for exercising it.

How we work

We take the CDM roles we actually perform

On our own projects we prepare and control the electrical design, appoint and coordinate our subcontractors, and plan, manage and monitor the construction phase. We therefore act as Principal Designer and Principal Contractor, and we accept the duties attached to those roles.

Our role is determined by the functions we carry out — not by the title on a purchase order. We assess and record it at tender stage and confirm it in writing with the client. Where another party is properly appointed as Principal Contractor, we work under their construction phase plan as a Contractor, and remain fully responsible for our own work and that of our subcontractors.

Live forecourts are treated as the hazardous environments they are

Petrol filling stations are places where explosive atmospheres may occur. We do not attend site without the written authorisation of the site operator, we work to the site's hazardous area classification, and all work in or adjacent to a classified zone proceeds under the operator's permit-to-work system. We do not self-authorise work on a live forecourt.

Hot work is designed out wherever possible. Where unavoidable, it proceeds only under permit, with gas testing, fire watch and agreed isolations. Only equipment suitable for the zone enters it.

We work to the APEA and Energy Institute Blue Book, fifth edition.

Dead working is the default

All electrical work is carried out under the Electricity at Work Regulations 1989 and BS 7671 by people competent for the voltage and the task. Live working is not permitted on our sites without the written authorisation of the Managing Director. Isolation is locked, tagged, and proved dead with GS38-compliant equipment and an approved proving unit. HV switching is carried out only by formally appointed Authorised Persons under permit.

We assume there is a fuel line where we are about to dig

A service strike on a forecourt is not just a damage event — it is a potential release and ignition event. Records from the site operator are treated as indicative, never definitive. Services are located with CAT and genny by a trained operator, and trial holes are hand-dug or vacuum-excavated to confirm position and depth before any mechanical excavation nearby. We work to HSG47.

The public are still driving through

Most of our sites keep trading while we work. A traffic management plan is agreed in writing with the site operator before work begins, working areas are segregated with rigid barriers rather than tape, and reversing is designed out or banksman-controlled.

Responsibility

The Managing Director holds ultimate and non-delegable responsibility for health and safety. Competent assistance under Regulation 7 of the Management of Health and Safety at Work Regulations 1999 is provided in-house by our NEBOSH-qualified health and safety lead, who reports directly to the Managing Director and has authority to stop any work on any site, without reference to commercial consequence.

Phil Nelson
Managing Director

The full policy, including our detailed arrangements, is available on request.