Procedure for Identification and Evaluation of Environmental Aspects.

1.0 PURPOSE:

To establish, implement & maintain a procedure for identification of environmental aspects of activities, products, and services covered under the scope of EHS Management system and to evaluate the environmental aspects and further determine significant impacts on the environment.

2.0 SCOPE:

 Applicable for the activities, process, products & services covered under the scope of EHS Management System.

3.0 RESPONSIBILITY:

EHS MR & Cross-Functional Team

4.0 DEFINITION

4.1 Aspect: Element of an organization’s activities, process, products, and services that can interact with the environment.

4.2 Impact: Any change to the environment, whether adverse or beneficial, wholly or partially resulting from the organization’s activities, process, products, and services.

5.0 PROCEDURE – DETAILS:

5.1 EHS MR shall identify the CFT Members (EHS-ML-12) from all departments for effective implementation of EOHS Management System. List of CFT members shall be approved by CEO.

5.2 CFT conducts the overall process of identifying environmental aspects & impacts.

5.3 CFT conduct an Initial Environmental review  considering the following:

• Identification of legal requirements
• Emission to air
• Discharge to water
• Waste management practices.
• Use of natural resources such as water, electricity, Furnace Oil and diesel are considered as a business concern.
• Existing procedure dealing with contractual activities etc.,

5.4 During the study, all the areas/departments under XXX premises are covered and due consideration given to emergency situations.

5.5 CFT shall identify the environmental aspects & impacts associated with the activities, processes, products, and services of XXX including planned / new developments / new or modified activities, process, products, and services. The Environmental Aspects shall be identified such that over which KFL can exercise direct control or it can have influence.

5.5.1 Identifying activities, processes, products and services:

1.) Activities: The first step is to categorize activities, processes, products & services of XXX. The activities, processes, product & services at XXX premises are identified in each dept. There can be more than one aspect for each activity and an aspect can have as its source more than one activity.

2.) Products: The product is the outcome of the processes and or operations which may or may not have an impact on the Environment. Thus the processes/operations directly related to the manufacturing will be considered to identify the related environmental aspects & impacts.

3.) Services: Services have been classified into the categories listed below:

1. Services provided by XXX such as Maintenance – Air compressors, DG, water supply, Fuel handling, Canteen, and communication, etc.,
2. Services obtained from the outside agency: AC Maintenance & DG Maintenance etc.,

5.5.2 Identifying Environmental Aspects & Impacts: The second step is to identify the aspects associated with the identified activities, process, product & services. Aspects/ Impacts associated with activities, process, product & services shall be identified considering impacts and output associated with operations giving due consideration to normal, abnormal operating conditions, startup & shutdown as well as foreseeable emergency situations. Aspects are also identified where KFL established direct control & over which they can have an influence. The aspects are identified in the following classes:

1. Discharge to water
2. Emissions to air (including noise)
3. Spillage of all types of oils
4. Waste management practices
5. Noise pollution from DG sets and Forging Presses
6. Hazardous waste management.
7. Energy consumption
8. Material use/consumption
9. Recycling and re-use
10. The emergency situation during all activities etc.,

SCORE	SCALE(IMPACT AREA)	SEVERITY (Quantum )	DURATION (HEALTH IMPACT)	DETECTION    ( PERIOD )	PROBABILITY ( OF OCCURANCE)
1	The immediate person	Negligible	Momentary	Immediate	Accidental
2	Concern department	Minor	One day	Daily	Occasional
3	Factory / unit	Moderate	One week	Weekly	Periodically
4	Neighborhood	Major	Month/ year	Periodically	Regular
5	Beyond neighborhood	Excessive	Life long	Not detectable	Continuous

The total score for any aspects shall be the multiplication of individual score of scale, severity, duration, detection, and probability of the same aspect. Significant aspects are those activities that will score above average of the total score or any overriding criteria.

Consumption of natural resources such as oil, water, energy has been considered as overriding criteria. (Note: – Natural resource will be considered small when the volume is less than or equal to 20 %( approximately) of total volume consumption. If Consumption of natural resources is small volume & probability is accidental or occasional such aspects considered as nonsignificant.)

Also, legal concerns interested party concern & emergency situation have been considered as overriding criteria.

Guidelines for considering overriding criteria are as follows:

a) Legal Concern: All legal concerns as identified in Legal Register (EOHS-RG-01).

b) Interested Party Concern: All other requirements

c) Natural Resources: Volume of activity is small, medium & large.

d) Emergency: As per situations defined in the emergency plan

Non Significant aspects are those activities that will score below the average of the total score. Overriding criteria for determining significant aspects shall be any one of the following criteria’s like legal concern, interested party concern, emergency situation, and Natural resources used in large quantity. Operational control (i.e. work instruction) shall be implemented for all significant aspects

1. Scale: – An Impact area in the neighborhood or beyond neighborhood is as per assumption,
2. Severity: – These are the Quantum of adverse impact on the environment by the activity, processes of the organization.
3. Duration: – Time period for which the impact will be active on the human being, animal, flora, fauna, etc.
4. Detection: – It’s the Time required for the aspect to be detected.
5. Probability: – It’s the chances of Occurrence of the aspect –

• Accidental    = by accidentally.
• Occasional   = Once per year.
• Periodically = Once per month.
• Regular        = Once per week.
• Continues    = At least Once per day or daily.

Assumptions:-

1. The scale of impacts is in the neighborhood or beyond the neighborhood.
2. Health impacts may sustain for the year or life long.
3. The time period of detecting the aspects may be periodical or may not be detectable at all.
4. Probability of occurrences may be accidental.
5. Glass bowls may burst / brake.
6. Components may fall down on shop floor during handling.
7. Components / material may get rejected during inspection / production.
8.  Oils may spill on the floor during handling.
9. Residual oils may spill or contaminate water/land during disposal of empty drums.
10.  Drinking waters may not be pure or safe for drinking.
11.  The smoke of tempering furnace or press may pollute workplace environment
12.  Incoming vehicles may create air pollution.
13.  The volume of aspect should be considered based on experience.

5.6     Review of Significant Impact Study:

Any new aspects identified are rated for finding significant impact. In the significant impact study, the rating allocated may be re-rated annually to know the effectiveness of Implementation of the system. In case of any change in rating guideline the rating of all aspects is conducted for the revised criteria in the guideline. The latest list of significant impacts is maintained in each department. The change to documents is made as per document control procedure.

6.0 Document/ Record Ref:

S. No.	Document /Record Description	Reference No.
1.	List of CFT Members	EHS-ML-12
2.	List of General Waste and Hazardous Waste	EHS-ML-11
3.	Aspect & Impact Register	EHS-RG-02
4.	Master list of Significant Aspects	EHS-ML-07
5.	Legal Register	EHS-RG-01