1.0 EMERGENCY

An emergency is a situation, which may lead to or cause large-scale damage or destruction to life or property or environment within or outside the factory. Sometimes the Emergency results in uncontrollable situations and leads to disaster. Such an unexpected severe situation may be too great for the normal workforce in the area within the plant. In any industry, an emergency can arise at any moment and this depends on the type of

• Structure
• Raw Materials
• Machines / Plant
• Nearby Industries etc.

2.0  NATURE OF EMERGENCY

The emergency has been identified and can be specified in one or more of the followings with source and effect:

Sr. No.	Emergency	Source	Effect
1	Fire / Explosion	Electrical Panels, Flammable oil storage tanks, Compressors, coolants,  paints, etc.	Small fires, complete equipment loss, complete Area burn out. Air pollution Soil pollution. Dangers to Human beings
2	Spillage of flammable / Hazardous Oils & coolants etc	Hydraulic oil, Furnace Oil, Coolant etc.	Fire Burns Soil pollution. Injury by slippage
3	Electric Shock	Electrical panels, Power Distribution Board, DG Set, Overhead Crane, Voltage stabilizer, Electric Transformer & Machine Operated by electricity, etc.	Burns, suffocation, Death. Toxic chemical ingestion into the bloodstream
4	Accidents – Factory (Major)	Fall from height & Falling of Heavy Materials, Dies, Bins or other Heavy objects.	Fracture
5	Accidents-Transport	Accident due to the transportation of man & material	Death or Injury to Body
6	Personal confinement	Toilets, offices, Basement	Suffocation
7	Natural calamities such as storm,  earthquakes, etc.	Nature	Structural collapse, Death
8	Structure collapse	Office building, & Any Wall or a part Of Factory building.	Serious injury, Major Fracture, Death
9	Riots, Arson, Sabotation	Anti-Social elements.	Serious injury, major Fracture, Death.
10	LPG leakage	Fire Hazard	Serious injury, Death
11	TANK DYKE Fire	Fire Hazard	Serious injury, Death
12	Electric fire	Fire Hazard	Serious injury, Death
13	Office fire	Fire Hazard	Serious injury, Death
14	Person on flames	Fire Hazard	Serious injury, Death
15	Food/Water Poisoning	Health Hazard	Poisoning, Death
16	Bomb hoax	Bomb Threat	Explosion, Death, fear
17	Burn-Minor	Health Hazard	Burn injury
18	Electric shock casualties	Health Hazard	Injury, Death
19	Non Functioning of STP and ETP	Spillage of untreated water on the ground	Land Contamination

3.0 OBJECTIVES:

The objective of the major emergency procedure should be to make maximum use of the combined resources of the works and the outside services to

• Effect the rescue and treatment of casualties;
• Safeguard other people;
• Minimize damage to property and the environment;
• Initially, contain and ultimately bring the incident under control;
• Identify any deed and provide for the needs of relatives;
• Provide authoritative information to news media;
• Secure the safe rehabilitation of affected areas;
• Preserve relevant records of equipment by the subsequent inquiry into the cause and circumstances of emergency;

4.0  EMERGENCY MANAGEMENT & KEY PERSONS                                        

During an emergency situation, it is generally seen that chaos and confusion rules leading to more damage. In Emergency Management, just like in normal operations where there are managers, engineers, supervisors, operators, etc., who are assigned specific tasks to run the business, similarly during an emergency also there are persons with specific duties. These persons are known as ‘Key Personnel’.

Following are the persons who are responsible to face the emergencies.

NAME	DESIGNATION	CONTACT NO

If required external help in case of an Emergency will be sought from appropriate sources. The required assistance from the probable sources has already been informed and consent obtained for the same.

5.0  ROLES & RESPONSIBILITIES:

5.1 Name & Address of the persons furnishing the information:

XXXXXX

XXXXXX

5.2 Any Individuals  

When an emergency occurs, the person who observes it must evaluate the gravity of the emergency and he should alert all the factory personnel by activating the Emergency Siren.  The emergency siren is activated just by pressing the Emergency Siren push button located at the main gate & other different locations. Then he immediately reports to the Emergency Control Centre (Main Security gate) and informs about the Emergency location.

5.3 Site Controller:

The Site Controller will assume overall responsibility for the factory/storage site and its personnel. His duties are to:

i) Assess the magnitude of the situation and decide if staff needs to be evacuated from their assembly points to identified safer areas

ii) Exercise direct operational control over areas other than those affected.

iii) Undertake a continuous review of possible developments and areas in consultation with key personnel as to whether shutting down of the plant or any section of the plant and evacuation of personnel are required.

iv) Liaise with senior officials of Police, Fire Brigade, Medical, and Factories Inspectorate and provide advice on possible effects on areas outside the factory premises.

v) Look after rehabilitation of affected persons on discontinuation of emergency.

vi) Issue authorized statements to news media and ensures that evidence is preserved for inquiries to be conducted by the statutory authorities.

5.4 Incident Controller:

The Head of the unit will act as an incident controller for that unit. Immediately on knowing about an emergency, he will rush to the incident site and take overall charge and report to the Site Controller. On arrival, he will assess the extent of emergency that exists and inform the Communication Officer accordingly. His duties will be to:

i) Direct all operations to stop within the affected area taking into consideration priorities for the safety of personnel, minimize damage to the plant, property and environment and minimize loss of materials

ii) Provide advice and information to the Fire/Security Officers and local fire service;

iii) Ensure that non-essential workers/staff of the areas affected are evacuated to the appropriate assembly point and the areas are searched for causalities

iv) Set up communication points and establish contact with the Emergency Control Centre in the event of failure of electric supply and internal telephones

v) Report on all significant developments to the communication officer and

vi) Have regard to the need to preserve the evidence so as to facilitate an enquiry into the cause and circumstances which caused or escalated the emergency.

5.5 Communication Officer:

He will also work as Liaison Officer and will be stationed at the main entrance (GateHouse) during the emergency. He will handle police, Press, and other inquiries, receive reports from roll-call leaders from assembly points, and pass on the absentee information to the Incident Controller. He shall maintain regular communication with the Incident Controller. He will:

1. Ensure that casualties receive adequate attention/ to arrange additional help if required and inform relatives;
2. Control traffic movements into the factory and ensure that alternative transport is available when the need arises; and
3. When an emergency is prolonged, arrange for the relief of personnel and organize refreshments/food.
4. Advise the Site controller of the situation, recommending evacuation of staff from assembly points if necessary.
5. Maintain proper agreed inventory in the control room.
6. Maintain a log of the incident on tape
7. In case of a prolonged emergency involving risk to outside areas by wind-blown materials, he shall contact the local meteorological office to receive early notification of changes in weather conditions.

5.6 Security Officer-

Security Officer will be responsible for fire fighting. On hearing the fire alarm, he shall reach the fire station immediately and advise fire and security staff in the factory of the incident zone. He will convey the message to the communication officer, Incident Controller and Site Controller about the incident zone. He will direct emergency services. He shall

1) Announce over the PAS in which zone the incident has occurred and on the advice of the Shift Executive In-charge inform the staff to evacuate the assembly service.

2) Inform the Shift Executive In-charge

3) Call Incident Controller, Engineering/ Production Manager, Personnel and Administrative Manager, Departmental Head in whose plant the incident occurred.

4) Security Supervisor for each unit will act as the Security officer for that unit.

5.7 Receptionist:

On hearing the emergency alarm, the receptionist shall immediately contact the Site Controller and on his advice will call the local Fire-brigade and or Police station and safety committee members. In case the PAS and telephone system becomes inoperative, she shall inform the communication officer through the messenger. In case the fire is detected and the alarm is not in operation, she shall receive information about the location from the person who detected the fire and immediately consults the Incident Controller. On his advice, she shall contact the Security Guard and advised him to make an announcement on PAS about the incident and the location of the incident and to evacuate to their assembly point. She will continue to operate the switchboard advising the callers and pass all calls connected with the incident to the Communication Officer.

5,8 Departmental Heads:

The HODs will report to the Incident Controller and provide assistance as required. They will decide the staff they require at the incident site.

5.9 Maintenance In-Charge and Electricians: 

They will report the scene of the incident and close down the services as directed by the Incident Controller

  5.10 Shift Executive In-charge:

As soon as he becomes aware of the emergency and its location, he will proceed to the scene. He shall assess the scale of the incident and direct operations within the affected areas with the following priorities:

1. Secure the safety of persons, which may require evacuation to the assembly points in the event of an escape of materials if the wind is from an adverse direction.
2. Minimize damage to plant, property and the environment.
3. Prevent spreading and damage to outside the premises.
4. Minimize loss of materials;
5. Have regard to the need for preserving evidence that may facilitate subsequent enquiry.
6. Inform shift engineer-in-charge as to what services are needed or not needed.
7. Hand over the charge of the operation to the Incident Controller when he arrives at the site.
8. Advice the Security Officer at Gate whether to make an announcement on PAS or not to call the Senior Staff to the factory, if necessary.

5.11 First-Aid Teams:

The Personnel Manager shall keep the roll call lists for the fire and First Aid team on duty. The First Aid team is appointed by each Departmental Head for his shift team. Roll call leaders shall check their roles as a member of the services and report for emergency duty. The name of unaccounted persons or absentees will be informed to the Security Officer. Members of First Aid teams will report to the shift Executive In-Charge or Incident Controller on hearing the alarm and follow his directions.

3.12 Factory Fire Fighting Personnel:

The duty of the Fire Fighting personnel under the command of the Security Officer shall be responsible for fire fighting and rescue. On hearing the alarm they shall proceed to the place of the incident if know, or otherwise, they shall report to the Security Gate. The men at the security Gate shall find the location of the emergency, the equipment and proceed to the site or occurrence. At the site, the team will respond to the directions given by the Incident Controller

6.0  Roles  & Responsibilities for Safety Teams:                                                                         

After confirmation of the emergency location from the Emergency Control Centre, concerned teams will start functioning. The team leaders will coordinate and communicate with the management. The team member fights the emergency under the instructions of the leader. The team will ensure that:

• The emergency does not spread.
• The head count is taken in consultation with Liaison Manager and if necessary search operation for missing person/s. is undertaken.
• Every member of the team uses the required Personal Protective Equipment while the operation is going on.
• First aid is arranged.
• Additional fire fighting equipment for the fire fighting team is arranged.
• The smooth rescue operation is facilitated.
• The emergency will be informed to fire brigade, neighbouring industries.
• Medicines are provided.
• Send injured to the hospital if necessary.
• Records of first aid and hospitalization are maintained.
• The help of other people is taken to control the emergency.
• Remaining part of the plant is safe.
• The area is cordoned off.
• Necessary tools, equipment to handle any repair work are mobilized.
• The main power supply line is cut – off if necessary.
• Maintenance and repair are undertaken.
• Conduct safety committee meetings every 3 months or in case of an emergency.

Team members of the safety committee:

NAME	DESIGNATION	CONTACT NO

7.0 EMERGENCY CONTROL CENTRE                                         

For the purpose of handling the emergency, Emergency Control Centre is very much essential. In the factory, Security Office at the Main Entrance is declared as Emergency Control Centre. All activities pertaining to the emergency will be carried out from this centre. The emergency Control Centre will be equipped with

• Plant Layout indicating storages of hazardous material and fire fighting equipment and first aid box locations.
• Material Safety Data Sheet of all chemicals handled in the premises.
• List of all employees with addresses, tel. No., contact person and if possible blood group.
• List of important telephone numbers such as police, fire brigade, hospitals, Directorate of Industrial Safety and Health, Pollution Control Board, etc.
• A separate list of team members with their addresses and telephone numbers.
• The facility of Direct Telephone Line.
• Equipment such as Torch, Rope, and necessary Personal Protective Equipment, whistle, etc.
• Note pads and pen/pencils to record the messages and record of activities pertaining to emergency
• First aid box with proper medicines.

8.0 ASSEMBLY POINT      

Assembly point is displayed in front of the main gate and known to everyone which is ensured at the time of safety audit. The area of the assembly point has been set farther from the location of likely hazardous events, where employees, contractors, and visitors must assemble in case of emergency. Up- to date list of pre-designated employees must be available with the Site in charge at the assembly point in case of assembly of the employees.  The site in charge shall then do the roll call of the people present so that their presence can be marked.

9.0 ALARM RAISING SYSTEM

The factory Main “Emergency Siren” is located at the main gate. This will be used for raising the alarm and also for “All Clear” signals in case of emergency.

10.0 EMERGENCY RESPONDING PROCEDURE

In case of Fire / Explosion / natural calamity etc., any person noticing it must evaluate the severity of the emergency and he should alert all the factory personnel by activating the Emergency Siren.  The emergency siren is activated just by pressing the Emergency Siren push button located at the main gate. Then he immediately reports to the Emergency Control Centre and informs about the Emergency location. As soon as the alarm is heard, the safety team members will contact the Security office at the Main Entrance and the safety team will rush to the Emergency location. The safety Team & other team members will assemble at the assembly point.

11.0 Communication System:

Alarms should be followed by an announcement over the Public Address System or verbally by shouting. In case of failure of alarm system communication should be by the security guard who will make an announcement through the Public Address system. Mobile Phones, landlines, etc could be used as a mode of communication for an emergency. If everything fails a messenger could be used for sending the information.

12.0 Action Plan For Various Emergencies.

A) Fire

Actions to mitigate the emergency	Responsibility to Respond
Raising emergency alarm	One who observes Fire  or explosion
Shut down machines and Main power supply	One who observes Fire  or explosion / Prod incharge
Evacuation, Assembly at Assembly Point.	All employees
Fire fighting	All employees
Rescue Operation	All employees
First aid or Hospitalization	All employees
Final Declaration of  “All Clear” Situation	MR / CEO

B) Major Spillage of flammable/ hazardous oils

Actions to mitigate the emergency	Responsibility to Respond
Raising emergency alarm	One who observes the major spill
Switch Off Power Supply of the equipment	Concerned supervisor, Maintenance engineers
Evacuation, Assembly at Assembly Point.	All employees
Isolate & Barricade the area of spill	Security
Control the spillage to avoid spread	DH – PRD
Stop all the work of welding, electrical etc	DH – PRD
Fire fighting	Fire fighting team
Final Declaration of  “All Clear” Situation	MR

C) Electric Shock

Actions to mitigate the emergency	Responsibility to Respond
Switch Off Power Supply of the equipment	Concerned supervisor, Maintenance engineers
Rescue the person.	Concerned supervisor, Maintenance engineers
Call the ambulance, provide first aid	Departmental Head

D) Accidents – Factory (Major)

Actions to mitigate the emergency	Responsibility to Respond
Contact company doctor/hospital	Departmental Head
Rescue Operation	Safety  team

E) Accidents-Transport

Actions to mitigate the emergency	Responsibility to Respond
Contact Ambulance/ Hospital, provide first aid Inform HR Dept Inform Police	Concerned Person     HR dept

F) Personal confinement

Actions to mitigate the emergency	Responsibility to Respond
Call fire brigade	Departmental Head
Raising emergency alarm	One who observes the calamity such as storm, earthquake

G) Natural calamities Such as storm, earthquakes, etc.

Actions to mitigate the emergency	Responsibility to Respond
Evacuation, Assembly at Assembly Point.	All employees
Raising emergency alarm	One who observes the sabotage, terrorism or civil commotion
Isolate & Barricade if necessary	Security
Fire fighting	All Employees
Rescue Operation	All Employees
Hospitalization	All Employees
Evacuation, Assembly at Assembly Point.	All Employees
Final Declaration of  “All Clear” Situation	Chief controller

H) Structure collapse

Actions to mitigate the emergency	Responsibility to Respond
Raising emergency alarm	One who observes the calamity such as storm, earthquake
Evacuation, Assembly at Assembly Point.	All employees
Isolate & Barricade if necessary,	Security
Rescue Operation,	Rescue team
Hospitalization,	First aid team
Final Declaration of  “All Clear” Situation	Chief controller

I) Riots, Arson, Sabotaging (Inside the premises of the organization)

Actions to mitigate the emergency	Responsibility to Respond
Inform HR Head, Plant Head, MD, Security, Immediately.	Concern Person.
Inform the Police immediately.	HR Head
The Security shall isolate the area of Rioting with its total force.	Security In charge
All work should stop immediately. The employees from rest of the premises shall be evacuated  immediately. The ambulance should be kept in Stand by to meet any eventually. Inform Hospital immediately to prepare for any emergencies. As soon as police arrives the area of rioting should be handed over to police.	Admin In charge.

J) Riots, Arson, Sabotaging(Outside the premise)

Actions to mitigate the emergency	Responsibility to Respond
Inform HR Head, Plant Head, MD, Security, Immediately.	Concerned person
Inform the Police immediately.	HR Head
The ambulance should be kept in Stand by to meet any eventually. Inform Hospital immediately to prepare for any emergencies.	HR dept
The gates should be closed and no person and vehicle should be allowed to leave the company premises. Security should man the gates with full force and should prevent entry of any unauthorized person in side the company premises.	Security In charge
In case of more than 8 hours of riot situation the Admin should ensure adequate food and water is available for the employees.	Admin In charge
Once all clear signal is received from the police, normal operation shall resume in the organization	Dept HOD

K) LPG leakage

Actions to mitigate the emergency

Responsibility to Respond

1. Take immediate steps to stop LPG leakage 2. Stop all operations 3. All out effort should be made to contain the spread of leakage/fire 4. Saving the human shall get priority in comparison to stock/assets. 5. Plant personnel without specific duties should assemble at the nominated place. 6. All vehicles except those required for emergency use should be moved away from the operating area, in orderly manner at pressure –nominated route 7. Depending upon severity, electrical system except for control supplies, utilities, lighting and fire fighting system, should be isolated 8. If the feed to the fire cannot be cut off, the fire must be controlled and not extinguished. 9. Start water at areas involved in or exposed to fire risks. 10. In case of leakage of LPG without fire and inability to stop the flow, take all precautions to avoid source of ignition. 11. Block all roads in the adjacent area and render internal/external support for the purpose if warranted.

Fire Fighting Team

L) Tank Dyke Fire

Actions to mitigate the emergency

Responsibility to Respond

1. In case fire occurs in the dyke area due to flange leak in manifold area, the fire is to be extinguished with the help of foam. 2. Use of DCP if the fire is small, otherwise use water spray or foam. 3. Cooling of lines /flanges is to continued till incident/site controller gives the instructions to stop. 4. If tank collapses and product is spread in the dyke area with fire. 5. Withdraw manpower in and around the tank dyke area. 6. Use foam monitors of vehicles to spray and spread foam in the affected dyke area If tank dyke area is on fire and full product is in the dyke then water to be used judiciously otherwise flooding of dyke area may cause overflow of oil from the dyke area to open drains.

Fire fighting team

M) Electrical Fire

Actions to mitigate the emergency	Responsibility to Respond
Disconnection of the electric supply of the affected area.Attempt to extinguish the fire with the help of DCP/CO2 fire extinguishersIf the fire still persists, ensure complete isolation of electric supply of that area and use of water.	Maintenance and fire fighting team

N) Office Fire

Actions to mitigate the emergency	Responsibility to Respond
Disconnection the electric supply of the affected area.Attempt to extinguish the fire with the help of DCP/CO2 fire extinguishersSave all records from fire.	Office staff and fire fighting team

O) Person on Flames

Actions to mitigate the emergency	Responsibility to Respond
1) Bring the water gel blanket 2) Open the bag inside the container to remove blanket. If the bag is already open such blanket should not be used for burn victims 3) The blanket can be held as a screen between the victim and the fire 4) If possible lay down the victim and wrap the blanket around the victim. Leave the victim wrapped in blanket and seek medical help	Fire fighting team

P) Food/Water Poisoning

Actions to mitigate the emergency

Responsibility to Respond

1) Persons observing the symptom should inform the location in charge for assessing the situation 2) Shift in charge should call the doctor and ambulances and also alert all hospitals to meet any exigencies 3) To render first aid and induce vomiting to the affected persons 4) The ambulances and vehicles available should be mobilized to be in readiness to transport large number of people if required Assistant Manager-SHE to report to location in charge for required sanitation and medical assistance.

First Aid team

Q) Bomb Hoax

Actions to mitigate the emergency	Responsibility to Respond
1) Person noticing on object like bomb, should bring it to the notice of the nearest available officer. 2) The officer should carefully observe the same from a distance and raise alarm 3) The area should cordon off. 4) Police control and fire control to be informed for their arrival and inspection of the area. After the bomb is diffused, all clear siren should be sounded by the watchmen.	Concerned person/ Admin dept

R) Burn –Minor

Actions to mitigate the emergency	Responsibility to Respond
Pour cool water on the burn area till the burning sensation is reduced.Cover it lightly with a clean cotton cloth.Do not apply butter, oil, ointments or any home remediesGet Medical help	First aid team

S) For Electric shock casualties

Actions to mitigate the emergency

Responsibility to Respond

Electric shock results in irreversible damage to brain cells followed by deterioration of the other organsRescue and first aidDo first thing first, quickly and without fuss or panic. Switch off the supply if this can be done at once. If not possible, use a dry stick, dry cloth or other non conductor to separate the victim of electrical contact. The rescuer must avoid receiving shock himself be wearing gloves or using a jacket to pull the victim.

First aid team

T) Non Functioning of STP and ETP

Actions to mitigate the emergency

Responsibility to Respond

In case STP or ETP is not working properly, the abnormality of so should be informed to maintenance department. In case the maintenance department closes the ETP or STP plant, the untreated water should be stored in Sock pit in case of STP and Septic tank in case of ETP.  After the STP and ETP starts functioning normally the water from the sock pit and septic tank should be treated before discharge.

ETP/STP operator and Maintenance Dept

12.0 DO’S AND DON’T’S

12.1 All Company Employees

Do’s	Don’t’s
 Stop work on getting information or hearing the alarm.  Switch off the machines and main power supply.  Gather at assembly point.  Contact Management  Take visitors to safer place.	 Do not panic & cause stampede.  Do not run and prevent others from doing so.  Do not go anywhere else.  Do not wait to collect personal belongings.

12.2 VISITORS & CONTRACTORS

After hearing the alarm they will follow the following steps:

1. Give attention to all instructions.
2. Stop work. Do not panic.
3. Do not wait for personal belongings.
4. Assemble at the assembly point.
5. Do not go to the emergency site.
6. Do not spread rumours.
7. Do not engage in communication systems.

13.0 TRAINING

The employees will be informed about the ‘On–Site Emergency Plan’ in detail, with the help of training programs. For the success of this plan not only training will be organized but mock drills also will be organized a minimum of once a year. Mock drills will help to understand the role to be played by everyone during the emergency. The Core members of the Disaster / Emergency control will be given refresher training at the interval of every One Year.

14.0 MOCK DRILL PROCEDURE

The success of the “On-site emergency plan” is very much dependent on planned and unplanned mock drills. Mock drills help employees to be familiar with their roles and ensure accuracy of the onsite Emergency Plan. Following is the procedure for conducting a Mock drill.

• Inform all the employees about mock drill procedures.
• Fix the date and time for mock drill.
• The mock drill will be monitored by the observer/s not involved in the exercise.
• The emergency alarm will be raised.
• After hearing the alarm, the Emergency Procedure will be followed. All clear signals will be given after the emergency is over.
• Observer/s will note down the activities with respect to the time.
• Lacunae observed in the system will be studied carefully.
• Records of drills will be maintained.

After each drill, the plan will be thoroughly reviewed to take into account the omissions or shortcomings for improvement.

15.0 Details of liaison arrangement between the Organization:

All the organizations involved in assisting during the emergency were contacted and apprised of the details of the plant, like process; hazardous material handled; likely emergency incidents; steps taken to avoid/reduce risk mitigation methods, resource availability, etc. The details are as follows:

 15.1 POLICE

Sr.No	Name of Police Station	Tel.No

15.2  FIRE BRIGADE STATION

SR. no	Fire Station	Tel no

15.3 HOSPITALS AND DOCTORS

Sr.No	Name of Hospital	Tel No

16.0  UPDATING THE PLAN

As and when required, this ‘On–Site Emergency Plan’ will be updated and informed to all. If necessary, after each drill the plan will be thoroughly reviewed to take account of shortcomings.

1.0 PURPOSE:

 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.

2.0 SCOPE:

 It encompasses all the Activities, Processes Products & Services covered under EHS Management System.

3.0 RESPONSIBILITY:

 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
2	Incident report	EOHS-F-08
3	Work Permit	EOHS-F-09

1.0 PURPOSE:

 To establish, implement & maintain a procedure to evaluate and update applicable Environmental, its Compliance obligation including legal and other requirements applicable to EMS Management System of XXX.

 2.0 SCOPE:

 Evaluation of its compliance obligations including its legal & other requirements applicable to all the activities, products & services covered under the scope of the EMS Management System.

3.0 RESPONSIBILITY:  Legal Team Members

4.0 PROCEDURE:

4.1 The Legal team of XXX periodically carries out the evaluation of its Compliance obligation including all legal & other requirements once in Six months. Periodicity of evaluation of compliance will vary for different legal & other requirements. The associated records are maintained.

4.2 The method adopted in evaluating its Compliance obligations is briefed below. Each of the identified legislation such as act/rule/ consent / other requirement is studied for every condition in the format specified for evaluating the compliance. Each of the conditions is rated for compliance using the following grades.

1. Fulfilled – Fully complied.
2. Not relevant – any condition in the legal consents, which is not applicable to KFL.
3. Still Open – but can be rectified by taking corrective action.
4. Not fulfilled – This requires an action plan to achieve compliance through the Management Program.

4.3 The evaluation of requirements to be carried out once in Six Months or whenever any new legal requirement is introduced by the Pollution Control Board / any other regulatory authority and is applicable to the firm. The evaluation covers

• License, consents, authorization
• Notifications, publications by government authorities and reply
• Compliance with other requirements
• Updating on legal requirements and other requirements

4.4      The application for renewal of consents/authorization under government statutory requirements will be given in advance as specified in the Act / Rule. The renewal frequency mentioned in the table may be altered as per the notification/intimation from the government authorities from time to time.

4.5     Corrective Action: This includes the steps taken to rectify the non-compliance observed against any of the applicable legal/other requirements. When the applicable condition is rated as 3 or 4 it is reviewed for the appropriate corrective action and action plan or if necessary EOHS management program is initiated with the responsibility and target date.

5.0 Document / record reference:

S. No	Document /Record Description	Reference No.
1	Legal Register	EMS-RG-01

1.0 PURPOSE:

 To promote Industrial Safety by identifying actual & potential emergency situations, respond to emergency situations, and preventing and mitigating the Environmental Impacts & OH&S Risks that are associated with them

2.0 SCOPE:

 Applicable for all the Activities, Processes, and Products & Services covered under the EHS Management System.

3.0 RESPONSIBILITY:

Safety Officer

4.0 PROCEDURE:

4.1 INDUSTRIAL SAFETY: Safety Officer imparts Safety awareness to all employees through in‑house training as per the need identified by concerned department Heads.

4.2 EHS Policy of the Company has been documented and displayed at salient points in the premises.

4.3 Safety Committees have been formed comprising of Operators & CFT to review / initiate actions on the following:

• The accidents that occurred during immediate past and the safety measures that are taken to avoid recurrence of such accidents.
• The requirement of any new personnel protective aids for the safety of the workmen.
• Preventive measures to be taken to eliminate unsafe conditions and unsafe acts.
• Organizing national safety day and initiating safety training classes if required etc.,

5.4 Safety Officer prepares an On-site emergency manual to meet the Emergency situation including a contingency measures Plan that briefly demonstrates the immediate reaction to be initiated by the ERT members & employees during the identified actual & potential emergency.

5.5 Onsite emergency manual is the guideline for declaring/deciding

• Emergency Situations
• The authorized person
• Duties of Emergency Response Team, individuals, and Departments.

5.6 Safety Officer conduct Mock Drills once in six months by involving relevant interested parties to evaluate the effectiveness of mock drills & respond to the identified emergency situation & shall keep the mock drill records ( EHS-F-01).

5.7 Corrective and Preventive actions in respect of industrial safety are taken on the recommendations of the department of Factory Inspectorate.

5.8 Apart from the above, trained internal EHS auditors shall carry internal audit once in six months. The recommendations from these shall be reviewed and implemented as appropriate.

5.9 Inspection of Lifting Tools & Tackles, Pressure vessels, Cranes, Electrical Installation, FO storage under the Explosives rules are organized as per the statutory requirements and the records maintained.

5.10 ERT Members shall Review the Onsite Emergency plan, particularly after the occurrence of Emergency Situation and after periodical conduct mock drill. ERT shall decide the possible changes needed to the Emergency Plan. Safety Officer shall arrange to modify the documents, in view of the above.

6.0 Document/Record reference

S. No.	Document /Record Description	Reference No.
1.	List of Emergency Response Team Members	EHS-ML-18
2.	List of Personnel Protective Equipment	EHS-ML-20
3.	Mock Drill Format	EHS-F-01
4.	List of Emergencies	EHS-ML-19

1.0 PURPOSE:

To provide a documented methodology for identifying operational controls for the identified significant Aspects/ Hazards to improve and/or control where their absence could lead to deviation from the EHS Management system.

2.0 SCOPE:

 Applicable for all the significant processes, activities covered under the scope of EHS Management System at XXX.

3.0 RESPONSIBILITY:

 Concerned Department Head

4.0 DEFINITIONS:

4.1 Operational Controls – The planning and carrying out of operations and activities should be in such a way that they are conducted under specified operating conditions. Operational controls may be documented through the use of work instructions, operational procedures, or manual codes. Examples of operational controls for handling, storage & disposal of Hazardous waste.

5.0 PROCEDURE:

5.1 The list of Significant Impacts / Risks becomes the major input for the setting of operational control procedures. All significant impacts / Risks are considered for conducting a study on the establishment of objectives and operational control procedures. CFT members carry out this study.

5.2  For all those activities calling for an operational control procedure, the respective operational team members ensure that the operational control procedures are prepared and followed in the area of significant impact/risk.

5.3  Operational control procedures are also made for activities significantly interacting with the environment/safety eg:  D.G sets, Hazardous waste handling & disposal, etc.

5.4  These procedures include instructions for controlling Environmental Aspects / OH&S Hazards relating to the operations carried out at XXX.

5.5  These procedures are also applicable to sub-contractors/suppliers at XXX where their absence could lead to deviation from EHS objectives and targets.

5.6  These operational control procedures are prepared to carry out the operations associated with the Significant Impact/ Risk in a controlled manner.

5.7  The Dept HODs approve operational controls. The details of operation Control Instructions / Work Instructions are available with respective departments. A Master List of Operation Control procedure is available with EHS MR.

5.8  Operational controls are also established wherever hazards & risks associated with changes.

5.9 Controls related to purchased goods, types of equipment & services including contractors & visitors related to the workplace. Environmental aspects & OH&S Hazards will be identified by CFT for the purchase of goods & services. For significant, control methods will be established and the same will be communicated to concerned suppliers.  At security Information on the EOH&S system will be given for the visitors and the supplier visiting XXX for the compliance with EHS management system.

5.10 Communication of Operational Controls to Employees:

The respective Implementation team members shall identify the employees who undertake the activities and operations associated with the operational controls and ensure that the requirements and operating criteria are communicated to and understood by them. For employees, this may be undertaken by including the operational controls in the training needs analysis or communication programs.

5.11 Communication of Operational Controls to Suppliers:

The respective team members shall identify the contractors, suppliers, members of the regulated community, and other members of the public who undertake activities associated with the operational controls.  Requirements for these suppliers shall be communicated. For suppliers who are members of the regulated community, requirements may be communicated through letters / verbal mode wherever required.

6.0 Document / Record reference: 

S.No	Document /Record Description	Reference No.
01.	Master List of Operational Control Procedures	EHS-ML-17

1.0 PURPOSE:

To establish, implement & maintain a Procedure for Communication, participation, and consultation with regard to EHS Aspects / Hazards and Environmental, Occupational Health & Safety Management System.

2.0 SCOPE:

This procedure is applicable to the Internal and External Communication and consultation with interested parties for the Activities, Processes, Products & Services of XXX covered under Environmental, Occupational Health & Safety Management System.

3.0 RESPONSIBILITY: As defined in the table below.

4.0 DEFINITION:

4.1 Communication: It is the process of meaningful interaction among persons of an organization & external interested parties related to the EHS Management System.

5.0 PROCEDURE:

5.1 The Communication with Internal and External Agencies shall be done in order to ensure that:

1. Internal functions at various levels are aware of the EHS Management System including the Significant Aspects / Hazards in their working area.
2. The Communication from Interested Parties is received, documented and responded to the concerned.
3. Processes for Communication with External Interested Parties on Significant Environmental Aspects/ hazards are considered.

5.2 The decisions taken regarding the concerned EHS Issues raised by any of the Interested Parties shall be routed through EHS MR.

5.3 The following table shows the various methods by which Internal and external communication is established and the responsibility for the same.

5.3.1 INTERNAL COMMUNICATION

S.No.	Topic For   Communication	Personnel To Be   Communicated	Resp. For Communication	Mode Of   Communication
1.	Awareness on the purpose of EHS Management System	All Employees	EHS MR & CFT	Notice Board & Training Programme
2.	EHS Policy	All Employees	EHS MR,  Dept Head	Poster, Cards, Display boards & Training
3.	Role & Responsibility	Concerned Employees	Respective Head of the Departments & HR	Work Instruction / Procedures
4.	Objectives And Targets	All employees	Respective Head of  the Departments	Group Discussion,   Management Review Meeting, Posters
5.	EHS Issues	Concerned Div. Heads	EHS MR	Emails, Minutes of Meetings,  Notes   Presentation.
6.	Legal and other regulatory requirements.	Concerned Employees	Legal Team	Mail mentioning legal requirement, Minute of Meeting.
7.	EHS Performance	Management Review Committee	EHS MR	Management Review Meeting

5.3.2 EXTERNAL COMMUNICATION

S.No.	Interested Party	Topic For   Communication	Mode Of Communication	Resp. of Receiving, Recording and Communicating
1.	Customer	Any relevant Information as required by the Customer	Verbal/ Letter/ emails	Marketing
2.	Local Community	Any EHS Concerns raised	Verbal / Letter/ emails	HR
3.	Supplier	Request for improving Environmental & Safety Protection.   Any Other Issues  raised Significant Impacts / Risks from their operations.	Letter/ emails	Purchase
4.	Visitors / Contractor’s	Request for improving Environmental Protection   Any Other Issues raised. Significant Impacts / Risks from their operations.	Verbal/ Letter / Notice board/emails	Concern HOD’s
5.	Banks & Insurers	Relevant Information as required	Letter/emails	Finance
6.	Media	Initiatives taken by Organization & Subsequent Development	Press-Release, Interviews, Presentation at Seminar/websites	Director
7.	Regulators (Govt. Authorities, Ministries)	a) Response to Show-Cause   b) Consents	Letter/emails	HR

5.4 Management shall decide for external communication on following points through Management Review meeting if asked for.

• Significant Environmental Aspects / Risks
• EHS Performance.

EHS MR shall record the decision taken in the minutes of the meeting. Management of XXX has decided not to communicate its Significant Environmental aspects to external interested parties.

5.5 EHS Policy shall be circulated to all suppliers to generate awareness about Environment & Safety. The key suppliers shall be included in EHS Awareness training to make them aware of Significant Impacts / Risks from their operations and to exercise control over them.

5.6 Internal Communication effectively established between the various levels of the Organization (i.e., Top-down, bottom-up, and Horizontal communication channels) concerned department heads to their employees and to express their concerns/suggestions of employees, the suggestion box is made available at the factory.

5.7 EHS Policy is made available at main the gate for Visitors / Security. Any Concerns from Interested Parties shall be recorded in the Concerns/suggestions from interested party feedback form (EHS-F-03).

5.8 Concerns if any, raised by external interested parties are communicated through the proper channel through HR. Details of External communication with External parties are recorded by HR/Security. Details shall be recorded in the External Communication register (EHS-RG-04).

5.9 Awareness shall be given to the Security about the importance and purpose of the EHS Management System, including Awareness on Environmental Policy and communication.

5.10 Participation and Consultation

5.10.1 Participation:

 Employees / Workers are involved in Aspect and Impact analysis, hazard risk identification & risk assessment also the identification of necessary control measures. Employees are also involved in the development of EHS objectives. During risk assessment & determination of control measures due consideration is given to identify EHS objectives. Workers are involved in incident investigation & details of investigations are recorded in the incident register.

5.10.2 Consultation on Health and Safety matters:

Safety Officer conducts quarterly safety committee meetings with employee representatives, EHS MR & CFT members. The agenda for the meeting includes –

1. Development and review of systems to manage OH & S risks.
2. Any change that affects workplace safety and health.
3. Any other health and safety matters

Input for the meeting also includes feedback on concerns from interested parties. The decisions and further actions are recorded by HR and circulated to the concerned personnel for action. HR Maintains minutes of safety committees in QSA-FR-05

6.0 Document / Record reference:

S. No.	Document /Record Description	Reference No.
01.	Concerns/suggestions from interested parties	EHS-F-03
02.	External communication register	EHS-RG-04
03.	Internal Feedback form	EHS-F-05
03.	Minutes of  Meeting (Safety Committee)	QSA-FR-05

1.0 PURPOSE:

To establish, implement & maintain a procedure to ensure that all the personnel is trained appropriately to the requirements of Environmental, Occupational Health & Safety Management System including those whose work may create a significant impact / Risk on the environment and safety.

2.0 SCOPE:

 This procedure also applies to all permanent, contract employees & personnel working under the control of XXX, whose job may affect the functioning of the Environmental, Occupational Health & Safety Management System.

3.0 RESPONSIBILITY:

 HR Manager

4.0 DEFINITIONS:  

 4.1 Training – Includes all forms of training such as on-job experience and background education, programmed training, or EHS training.

4.2 Awareness – This refers to awareness on Environment & Safety Management System.

4.3 Competence – All employees or personnel working for or on behalf & under the control of XXX whose jobs can affect the Environmental, Health & Safety should be competent. This means that the education, experience, and training requirements for that job must be defined and the employee must meet the requirement.

5.0 PROCEDURE:

5.1 At XXX, training is conducted across the organization for various topics as covered in the training plan. This is to ensure that the employees are made aware of:

• The importance of conformance with the Environment & Safety policy and organizational objectives derived to meet the policy.
• The control methods derived to reduce the significance of the significant environmental aspects & OH&S Hazards identified in the area.
• The preparedness for potential emergency situations.
• Environmental Impacts / OH&S consequences actuals or potentials of their work in case of deviations and appropriate corrective actions for the same.

5.2   Competency, Training & Awareness:

Employees working or working on behalf & under the control of XXX in the areas where significant Aspects/Hazards has been identified are trained to build competency for handling the significant Aspects / Hazards. MR / HR retains the records of competency. Core Team members of the department within the scope of EHS shall be responsible for assuring that the appropriate training, awareness, and competence requirements have been defined and met. The associated records of competency are retained by the HR / MR as relevant for fulfilling the requirement of competency (PER-FR-06)

5.3 Identification of Training Needs and Training Calender:

The training needs (PER-FR-01) pertaining to the Environmental, Health & Safety Management system are identified:

1. At the start of the implementation of the EHS Management System – a training plan is derived for all departments where the common topics of training are identified. The Core Team must make sure that adequate resources are available to allow the employee to receive all appropriate training. If adequate resources are not available, the Core team members must develop a plan for completion within a reasonable time frame.
2. Activities with Significant Impacts / Hazards
3. Operation control procedures
4. Incidents that have discrepancies
5. Emergency Situations
6. After Audit from its observations
7. Change in the management system, Introduction of new product/process/ services, which has significant aspects / Hazards.
8. Induction of new employees based on the skill/competency requirements of the person.
9. Change in responsibility is based on the skill evaluation, which is kept as the base to analyze his functional competency against the requirement for the relevant function or position.
10. Based on the competence defined for specific significant process/activity.

Annual Training Calendar (PER/FR-02) will be prepared based on the above-mentioned points. After the conduct of training, attendance records are maintained. Training programs are conducted based on the responsibility and ability of the personnel, language & literacy. Competent personnel/ Agency / qualified trainer will conduct the training on the EHS Management system. The effectiveness of training will be evaluated by the concerned dept HOD. If found not effective re-training will be planned & associate records will be maintained by concerned dept Head.

6. 0 Document / Record reference

S. No.	Document /Record Description	Reference No.
1.	Skill  Matrix	PER-FR-06
2.	Training Calendar	PER-FR-02
3.	Training Need	PER-FR-01
4	Training Attendance Sheet	PER-FR-03
5	Training Feedback & Evaluation	PER-FR-04

1.0 PURPOSE:

To define, document, and communicate the roles, responsibilities, authorities, and accountability necessary to facilitate effective Environmental, Occupational Health & Safety Management through EHS implementation.

2.0 SCOPE:

 Applicable for the activities, products, services, policies carried out within the organization and included within the scope of the EHS Management System at XXX.

3.0 RESPONSIBILITY:

C.E.O

4.0 DEFINITIONS:  

• EHS MR –Environmental Occupational Health and Safety Management Representative. The EHS MR is the head of the CFT and has overall responsibility for the Department’s EHSMS.
• HOD – The Head of the department.
• Role – The position title.
• Responsibility – The duties associated with the title.
• Authority – Defined decision-making level.
• Accountable – Overall responsible
• Resources – Includes staff, time, money, and tools.
• CFT –Cross-Functional Team.

5.0 PROCEDURE:

The implementation of the EHSMS is structured as indicated in the manual. The following Teams are identified for effective implementation of the EHS Management system.

1. Cross-Functional Team
2. Legal Team
3. Audit Team
4. Emergency Response Team
5. First Aid Team
6. Safety Committee

Roles, responsibility, authority, and accountability

1.Managing Director:

• Overall responsibility for the performance of the Organization
• Overall responsibility & accountability for the EHS System, directly or through a nominated executive
• Chair and Management Review Meeting
• Define the EHS Policy
• Review and approve the EHS System manual and its amendments
• Ensures adequate resources are available for effective implementation
• Appoint Management Representative
• Approval of Purchase Orders for capital items
• Overall accountable for continual improvement of EHS Management system

2. Cross-Functional Team:

• Preparation of objectives and targets in consultation with Top Management
• Conducting departmental reviews
• Coordinate in providing resources for departmental elements of EHS.
• Providing direction to the department on the design, implementation, and maintenance of EHS
• Resolving corrective action issues
• EHS MR is accountable for the effective implementation of EHS MS
• Identify training needs for personnel directly reporting.

3. Legal Team:

• Identify applicable legislation and other requirements.
• Evaluate Legal compliance
• Communicate the legal noncompliances
• Hold review meetings on a legal requirement.
• Update with latest legislations / amendments.
• DGM-HR is accountable for compliance with EHS legal & other requirements.

4. Audit Team:

• Conduct Internal audits as per the audit schedule
• Generate audit reports
• Verify the audit closure
• EHS MR is accountable for conducting audit & NC closure

5. Emergency Response Team:

• Review emergency response & preparedness manual
• Train the people for emergency response
• Conduct the role during the mock drill
• To see the entry of unauthorized persons is restricted to areas.
• To check whether Fire Extinguishers are provided at appropriate places and are tested periodically.
• To check persons working are using proper PPE’s
• To train the personnel over the safety & to identify key areas where safety is necessary
• To identify safe assembly area
• Impart safety awareness to all employees through in-house training as per the needs identified.
• To check whether safety instructions have been prepared and displayed at relevant places through Operation control Instruction for use of Safety Personal Protective Equipment.
• To see all the effectiveness of the emergency preparedness
• An emergency response team has been constituted with Personnel from all departments to review / initiate actions for identified potential Emergency situations identify through the significant Study.
• To co-ordinate with respective Functions head for identifying different types of emergency situations and prepares an “onsite emergency plan” which briefly describes the action to be taken by the employees during identified emergency situation internally.
• To prepare an evacuation plan & to describe the plan for evacuation from the emergency area and to identify gathering point
• To prepare mitigation actions after the emergency
• To organize Mock drills or Mock exercise, to test the Onsite emergency plan for the different identified emergency situations.
• To make sure the Mock Drill records are maintained by the Safety Officer. To decide the possible changes needed in the emergency plans.
• The safety officer is accountable for compliance with Emergency preparedness and response

6. First Aid Team

• The team should regularly monitor medicines availability in the box.
• The First Aid personnel shall take care of the injured persons and in case of an emergency condition.
• The First Aid persons should take care that the injured persons are shifted to the hospital in time.
• Admin Officer is accountable for maintaining adequate first aid medicines, providing first aid to injured personnel.

7. Safety Committee:

Safety Committee shall meet as often as necessary but at least once in three months. The minutes of the meeting shall be recorded. Safety Committee shall have the right to be adequately and suitably informed. Functions and duties of the safety committee shall include-

• Dealing with all matters concerning health, safety, and environment, and to arrive at practical solutions to problems encountered.
• Creating safety awareness among all the workers.
• Undertaking educational, training and promotional activities.
• Discussing reports on safety, environmental and occupational health surveys, safety audits, risk assessments, emergency and disaster management plans and implementation of the recommendations made in the reports.
• Carrying out health and safety surveys and identifying the cause of accidents.
• Looking into any complaint made on the likelihood of imminent danger to the safety and health of the workers and suggesting corrective measures and
• Reviewing the implementation of the recommendations made by it.
• Incident investigation results & review of the effectiveness of the action taken.
• Safety Officer is accountable for conducting safety committee meeting.

The activity wise responsibilities are as shown below

S. No	Activity	Responsibility
1	Appointing a Management Representative	Managing Director
2	Selection of CFT Members	EHS MR
3	Review and approval of Policy	Prepared by EHS MR, Reviewed &  approved MD
4	Conducting Initial Review & Significant Impact / Risk Assessment	CFT
5	Setting up objectives and targets	EHS MR & CFT
6	Establishing Management Program	EHS MR & CFT
7	Approval of Management Program	Managing Director
8	Identification of Legal and Other Requirements	Legal Team
9	Providing resources for Implementation	Managing Director
10	Identifying training needs	CFT
11	Organizing Training	HR Department
12	Internal Communication	As per defined Procedure
13	External Communication
14	Document Control	EHS MR
15	Operational Control Measurement & Monitoring	CFT
16	Emergency preparedness and response	Safety Officer & ERT Members
17	Review of Procedures after emergency	ERT
18	Calibration of Instruments	QA Deputy Manager
19	Handling and Investigating NC’s	EHS MR & CFT
20	Initiating Corrective and Preventive action	EHS MR & Resp Dept HOD’s
21	Maintaining Records	CFT
22	Conducting Audit	Trained Internal Auditors
23	Conducting Management Review	Managing Director

1.0 PURPOSE:

 To establish, implement & maintain a procedure for setting EHS objectives and targets and developing the EHS Management Programme for achieving Environmental, OH&S objectives and targets.

2.0 SCOPE:

Applicable to the activities, processes, products, and services of XXX covered under the scope of EHS Management Systems.

3.0 RESPONSIBILITY:

Respective Dept Heads.

4.0 DEFINITION:

 4.1 Objective – Overall EHS goal arising from the EHS Policy that an organization sets itself to achieve, and which is quantified where practicable.

4.2 Targets – Detailed performance requirement, quantified where practicable applicable to the organization or part thereof, that arises from the EHS objectives and that needs to be set and met in order to achieve those objectives.

4.3 EHS performance – measurable results of the EHS Management System, related to an organization’s control of its environmental aspects / OH&S Hazards, based on its EHS policy, objectives, and targets.

5.0 PROCEDURE :

5.1 List of significant aspects (EHS-ML-07), List of Significant Risks & unacceptable Hazards (EHS-ML-13) is prepared based on the significant Impact / Risk assessment.

5.2 EHS MR, Dept heads shall review the significant aspects/Hazards and consider for setting as objectives.

5.3 Also whenever an Aspect/Hazard is leading to a Business concern, management can decide on taking it as an objective as policy decision along with the other set objectives.

5.4 EHS objectives and targets are established within the context of XXX and are decided based on:

1. EHS Policy – Objectives to be in line with the stated EHS Policy
2. Legal and other requirements- whether the aspect/Hazard is a legal Requirement and present status with respect to the consent /legal Requirement.
3. Technological options – whether it is technically possible to reduce the Scale of the Aspect/Hazard
4. Financial requirements- whether a financial budget is available for Implementing the necessary change
5. Operational requirement – what will be the operational control to reduce the impact/ risk
6. Business requirement – whether the objective will be important from the business point of view.
7. Views of interested parties – Views/concerns of interested parties and what should be the control and whether it will be beneficial for them.

5.5 The reviews of the above considerations are recorded in the establishment of EHS objectives (EHS-ML-15). CFT shall be involved in setting the EHS objectives.

5.6 Wherever financial sanctions are required, EHS MR shall discuss with Managing Director for obtaining necessary approvals/sanctions.

5.7 CFT shall maintain Establishment of EHS Objectives, Targets & Programme(s).

5.8 EHS objectives and targets shall be established for each relevant function by CFT. An up-to-date list of objectives and targets shall be maintained by EHS MR.

5.9 The list of EHS objectives and targets (EHS-ML-15) shall be communicated to all the relevant personnel for effective implementation of action plans and achievement of targets.

5.10 EHS objectives and targets shall be reviewed every year, if applicable, in light of new regulations, new projects and commitments, and changes in operations and updated.

5.11 The CFT shall develop a detailed EHS Management programme for achieving the objective. The programme shall detail the responsibility, time frame and the action plan by which the EHS objectives can be achieved. The Management Director shall approve the EHS Management programme. (EHS-F-02)

5.12 EHS MR shall review periodically, the progress of activities detailed in the programme for implementation and its effectiveness. In case of any deviations or changes required in the programme, CFT shall amend the programme in consultation with MR & it shall be discussed during Management Review Meeting for final approval and updating the documented programme accordingly. Progress of Management Programme shall be recorded in the Management Programme monitoring report every quarterly based on the target of Management Programme. (EHS-ML-08)

5.13 The status of the EHS objectives and Management program shall be reviewed by CFT whenever there is a project related to new or modified activities, processes, products, or services.

5.14 The progress of the Management Programme is monitored activity-wise and details are recorded. Once the EMP is completed, the status of completion is recorded in the MP closure report (EHS-F-04) and operational control / Work Instructions shall be established if required for monitoring.

5.15 The status of the EHS objectives and Management programme shall be reviewed in Management review meetings.

5.16 The EHS policy and objectives shall be reviewed and revised based on the progress, changing circumstances and as a commitment for continual improvement.

6.0    Document / Record reference:

S. No.	Document /Record Description	Reference No.
1	List of significant Aspects and Impacts	EHS-ML-07
2	List of Significant Risks & Unacceptable Hazard	EHS-ML-13
3	List of EHS Management Programme	EHS-ML-08
4	List of EHS Objectives.	EHS-ML-15
5	Management Programme closure report	EHS-F-04
6	EHS Management Program	EHS-F-02

1.0 PURPOSE:

To establish, implement and maintain a procedure for identification of legal and other requirements to which XXX subscribes & to identify how legal & other requirements are applicable to identified environmental aspects & OH&S hazards covered under the scope of the EHS Management system.

2.0 SCOPE: 

This procedure covers the method to identify and have access to applicable Legal and other requirements related to activities, processes, products, and services of XXX.

3.0 RESPONSIBILITY:

Legal Team Members (LTM). (EHS-ML-14) The legal Team Members consists of EHS MR, DGM –HR, AM-Safety, Officer Admin

4.0   DEFINITION:

4.1 Legal Requirements: These are regulatory requirements as defined by the Central or State regulatory authorities to which the XXX is liable to identify and comply.

4.2 Other Requirements: Any customer-specific requirements, statutory requirements by financial bodies, corporate-specific requirements & any other agreements with public authorities. (Ex: Customer requirements)

5.0 PROCEDURE:

5.1 The details of the List of Applicable legal requirement & other requirements to be compiled by LTM, along with the frequency of retrieval and personnel responsible for maintaining the records are defined in the Legal Register

5.2 Head responsible for compliance to legal requirement shall obtain information on the legal requirement, by referring to any of the following agency.

• Notification from Kuwait Ministries
• Information in Newspapers.
• Communication with the National Safety Council and Confederation of Kuwait Industry & Authorized Publishers.
• Subscription/contact with Bureau of Indian Standard, Book Supply Bureau, etc.
• By referring to various Factories Acts & Rules Book
• Through visiting the website to get information on the latest updates and also through member

5.3 The application for renewal of Consents / License /Authorization under Government statutory requirements shall be submitted in advance as specified in the Acts / Rules. Renewal frequency mentioned in the list of legal & other requirements may subject to change/alter as per Notification / Intimation from the government authorities from time to time. Responsible persons shall communicate relevant information on legal and other requirements to all concerned.

5.4 The following are the other requirements pertaining to the Environmental aspects / OH&S Hazards of the activities, processes, products & services, which are to be complied with:

• Customer Specific Requirements – Marketing & Quality Departments are responsible for receiving the requirement from the Customer and forwarding it to the concerned department to ensure fulfillment.
• The statutory requirement by Financial Institutions – Some of the financial institutions, Banks, Insurance companies may require the organization to comply with certain statutory norms. The finance dept shall identify and comply with those requirements and they are responsible for receiving and responding to the fulfillment of the above.
• Corporate specific Requirements – MR shall identify any corporate-specific requirements and incorporate the same and periodically check for compliance.
• Agreement with public Authorities – Public authorities like social bodies OR Industrial development authorities may require the organization to comply with their requirements. HR is responsible for receiving and responding to ensure fulfillment of such requirements.

5.5 Legal & other requirements applicable to environmental aspects & OH&S Hazards are determined during significant impact/risk study. Description of legal requirements & how legal & other requirements applicable to environmental aspects & OH&S hazards are also described in the significant impact/risk study.

6.0 Document / Record reference: 

S. No.	Document /Record Description	Reference No.
1.	Legal Register	EHS-RG-01
2.	List of Legal Team Members	EHS-ML-14