To establish, implement and maintain a procedure for:-
- Handling and Investigating the Non-Conformances.
- Taking actions to mitigate any Impacts/Risks caused and initiating, completing Corrective Action.
- Defining responsibility and authority for handling and investigating non-conformances.
It encompasses all the Activities, Processes Products & Services covered under EHS Management System.
Dept. Heads concerned are responsible for Monitoring, Investigating Non-Conformance, and taking Corrective & Preventive actions in their particular area.
4.0 PROCEDURE :
4.1 The non-conformance shall be identified as –
- Deviations from the documented procedure/instructions not followed.
- Unsafe practices / unsafe conditions.
- Accidental emissions / discharges.
- Deviation from the norms / specified limits.
- Spillage / Leakage / Emission / Accident / Incident due to improper handling / improper maintenance / deviation from operational control procedures and documented procedures.
- Any incident /accident having a significant impact/risk on the environment, or health or safety of persons.
- Noncompliance to applicable legal requirements
- Improper handling of hazardous materials/waste
- Deviation from following the specified OCP’s /ERP
- Deviation from the specification mentioned in the operation control procedure
4.2 Respective Team Members shall identify, record non-conformances, incidents and shall take appropriate actions through investigation & analysis.
4.3 Respective Team Members shall identify non-conformances; incidents periodically in the Environmental Incident Register (EHS-RG-05) and Incidents such as Near Misses/ Accidents are recorded in the Incident report (EHS-F-08) accordingly and shall inform the concerned Dept Head to take appropriate actions.
4.4 Concerned HOD / his designated officer shall review/investigate the non-conformances, incidents and decide about the action to be initiated to mitigate the immediate impact.
4.5 Initiating corrective and preventive actions as detailed in the subsequent steps shall control the non-conformance identified.
4.6 Respective Dept Heads shall investigate the non-conformance by involving concerned workers/employees and details of the investigation are analyzed & recorded.
4.7 The Procedure for Corrective & Preventive Action is designed to ensure that appropriate Corrective & Preventive Actions are initiated based on the inputs from the following as appropriate:
- Identified Non-Conformance, incidents
- Internal / External EOHS Audit Results.
- Emergency Situations
4.8 The concerned Dept Heads shall analyze the cause of the Non-Conformance and decide the Corrective & Preventive action required to eliminate the cause of actual and potential Non-Conformities.
4.9 The steps involved in initiating Corrective Action shall be –
- Investigate the cause of Non-Conformance
- Recording results of the investigation
- Determination of Corrective Actions needed to eliminate the cause of Non-Conformance.
- Ensure that the Corrective Actions are effective.
4.10 The Steps involved in Preventive action shall be –
- Analyze all Processes to eliminate potential causes of Non-Conformances
- Initiate Preventive Actions
- Ensure that the Preventive Actions are effective.
4.11 The corrective and preventive actions shall be taken appropriate to the magnitude of the problem and commensurate with the Environmental impact / OH&S risk encountered.
4.12 The respective Dept Heads along with the concerned worker/employee shall investigate the Non- Conformance.
4.13 EHS MR / Dept. HOD’s shall verify the Corrective Action and shall also decide and update the change in any Operational Control Procedure / Work Instruction if necessary, as per the procedure for Document Control.
5.0 DOCUMENT / RECORD REFERENCE:
|S.No.||Document /Record Description||Reference No.|
|1||Environmental Incident register||EOHS-RG-05|