Example of Emergency Preparedness Plan-HSE MS

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.EmergencySourceEffect
1Fire / ExplosionElectrical 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
2Spillage of flammable / Hazardous Oils & coolants etc Hydraulic oil, Furnace Oil, Coolant etc.Fire
Burns
Soil pollution.
Injury by slippage
3Electric ShockElectrical 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
4Accidents – Factory (Major)Fall from height & Falling of Heavy Materials, Dies, Bins or other Heavy objects.Fracture
5Accidents-TransportAccident due to the transportation of man & materialDeath or Injury to Body
6Personal confinementToilets, offices, BasementSuffocation
7Natural calamities such as storm,  earthquakes, etc.NatureStructural collapse, Death
8Structure collapseOffice building, & Any Wall or a part Of Factory building.Serious injury, Major Fracture, Death
9Riots, Arson, SabotationAnti-Social elements.Serious injury, major Fracture, Death.
10LPG leakageFire HazardSerious injury, Death
11TANK DYKE FireFire HazardSerious injury, Death
12Electric fireFire HazardSerious injury, Death
13Office fireFire HazardSerious injury, Death
14Person on flamesFire HazardSerious injury, Death
15Food/Water PoisoningHealth HazardPoisoning, Death
16Bomb hoaxBomb ThreatExplosion, Death, fear
17Burn-MinorHealth HazardBurn injury
18Electric shock casualtiesHealth HazardInjury, Death
19Non Functioning of STP and ETPSpillage of untreated water on the groundLand 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.

NAMEDESIGNATIONCONTACT 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:

NAMEDESIGNATIONCONTACT 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 emergencyResponsibility to Respond
Raising emergency alarmOne who observes Fire  or explosion
Shut down machines and Main power supplyOne who observes Fire  or explosion / Prod incharge
Evacuation, Assembly at Assembly Point.All employees
Fire fightingAll employees
Rescue OperationAll employees
First aid or HospitalizationAll employees
Final Declaration of  “All Clear” SituationMR / CEO

B) Major Spillage of flammable/ hazardous oils

Actions to mitigate the emergencyResponsibility to Respond
Raising emergency alarmOne who observes the major spill
Switch Off Power Supply of the equipmentConcerned supervisor, Maintenance engineers
Evacuation, Assembly at Assembly Point.All employees
Isolate & Barricade the area of spillSecurity
Control the spillage to avoid spreadDH – PRD
Stop all the work of welding, electrical etcDH – PRD
Fire fightingFire fighting team
Final Declaration of  “All Clear” SituationMR

C) Electric Shock

Actions to mitigate the emergencyResponsibility to Respond
Switch Off Power Supply of the equipmentConcerned supervisor, Maintenance engineers
Rescue the person.Concerned supervisor, Maintenance engineers
Call the ambulance, provide first aidDepartmental Head

D) Accidents – Factory (Major)

Actions to mitigate the emergencyResponsibility to Respond
Contact company doctor/hospitalDepartmental Head
Rescue OperationSafety  team

E) Accidents-Transport

Actions to mitigate the emergencyResponsibility to Respond
Contact Ambulance/ Hospital,
provide first aid
Inform HR Dept

Inform Police
Concerned Person    



HR dept

F) Personal confinement

Actions to mitigate the emergencyResponsibility to Respond
Call fire brigadeDepartmental Head
Raising emergency alarmOne who observes the calamity such as storm, earthquake

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

Actions to mitigate the emergencyResponsibility to Respond
Evacuation, Assembly at Assembly Point.All employees
Raising emergency alarmOne who observes the sabotage, terrorism or civil commotion
Isolate & Barricade if necessarySecurity
Fire fightingAll Employees
Rescue OperationAll Employees
HospitalizationAll Employees
Evacuation, Assembly at Assembly Point.All Employees
Final Declaration of  “All Clear” SituationChief controller

H) Structure collapse

Actions to mitigate the emergencyResponsibility to Respond
Raising emergency alarmOne 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” SituationChief controller

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

Actions to mitigate the emergencyResponsibility 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 emergencyResponsibility 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 emergencyResponsibility 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 emergencyResponsibility 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 emergencyResponsibility 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 emergencyResponsibility 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 emergencyResponsibility 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 emergencyResponsibility 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 emergencyResponsibility 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 emergencyResponsibility 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 emergencyResponsibility 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 emergencyResponsibility 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’sDon’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.NoName of Police StationTel.No
   
   
   
   
   
   
   

15.2  FIRE BRIGADE STATION

SR. noFire StationTel no
   
   
   

15.3 HOSPITALS AND DOCTORS

Sr.NoName of HospitalTel 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.

EHS Guidelines For Contractors / Sub-Contractors & Service Providers

0.0       INTRODUCTION:

This is a summary of safety rules and working procedures, which we suggest are the minimum standard practices applicable to all contractor personnel working on XXX facilities. These are the XXX rules and are intended to supplement applicable laws and regulations of the XXX Safety Manual.

0.1 ENVIRONMENT, HEALTH & SAFETY POLICY

 XXX intends that its activities will, comply with all relevant statutory and other provisions and all measures will be taken to minimize injury and ill health to its employees and other & stakeholders, who may be affected by its operations. We are committed to the integration of safety and environmental considerations in all areas of corporate activity, including the design and operation of all facilities, and implement a process of continual improvement in this regard. We are also committed to prevent pollution and continuously improve our processes and system to conserve natural resources.

 0.2 Responsibility:

  1. Management and supervisory staff have the responsibility for implementing the policy throughout the company, to see that environmental, health and safety considerations are always given priority in the planning and execution of all work.
  2. All employees and contractors are expected to strictly adhere to the above policy.

In their areas, so that work is carried out with minimum risk to themselves, other and environment. 

0.3 Approach:

  1. To maintain high technical standards by employing skilled and qualified technical staff and train them for effective performance.
  2. To design, construct and operate all plant, equipment, storage areas, etc. taking into consideration safety and environmental aspects.
  3. To identify and communicate all hazard-related information about our process and raw materials to all employees, neighboring communities, and contractors.
  4. To train employees in firefighting, first aid, use of PPE’s, safe handling of hazardous chemicals and effectively implement ‘on-site’ emergency plan.
  5. To periodically audit safety preparedness, do a risk analysis.
  6. Asst. Manager, EHS shall be available to assist in the implementation of the policy and provide information, advice, and support to employees.
  7. To make adequate financial and technical resources available to allow the policy to be carried out..

 1.0      IMPLEMENTATION OF EHS AT XXX.

1.1 Following focal areas are addressed by our Environmental Occupation Health and Safety Management system:

  • Conservation of resources especially Energy, Water, Fuel and Petroleum Products used in processes.
  • Optimum utilization of energy.
  • Minimum wastage & optimum utilization of diesel, lubricants, hydraulic oils, water by minimizing its leakage, spillage during storage, recycling and periodic maintenance of machinery.
  • Upkeep of equipment machinery in good working condition for maintaining their efficiency levels by periodic servicing and checking as per maintenance schedule.
  • Reduce waste generation in the manufacturing of moldings & sleeves.

Fire, Spillage of chemicals & oil in large quantities, Gas leakage in large quantities are identified as potential foreseeable emergencies in our nature of operations. A separate procedure is in place to address these environmental emergencies. Management Programs are formed in order to make permanent changes in the existing systems. Operating Control Procedures in different departments are implemented to maintain the processes under controlled conditions. These programs & procedures are implemented on the departmental level; any deviations are recorded & taken up in Management Review (Core group) meeting by Management Representative. All employees are aware of the EHS systems and their roles & responsibilities for implementing the same through rigorous training.

Ultimately our system aims at continual improvement. Once the Objectives / Targets are achieved/implemented through Management Programs, new Objectives & targets demanding a higher level of environmental performance will be set & achieved. This journey for continual improvement is ongoing & endless. We have just made the beginning. We are sure that our perseverance, patience, untiring efforts & inner urge shall help us achieve this noble cause of protecting our environment.

2.0       ACTIVITY

These activities are applicable to visitors / contractors / vendors / their employees / associates.

2.1 THE RULES ARE OBLIGATORY TO ALL CONTRACTORS:- 

  1. These Safety rules have been circulated for the performance of EHS practices regarding day to day work of the concerned contractor.
  2. These rules in no way relieve / to help a contractor from his obligation under various statutory rules and regulations.
  3. All regulations, codes, and ordinances of the Ministries and local Authority regarding EHS shall be obligatory to the contractors.
  4. The contractor should have a valid License with WC Policy as per Govt. rule & regulations amended time to time before mobilization/starting job at the site.
  5. The contractor will be solely responsible for the safety of his employee.

3.0       GENERAL REQUIREMENTS: 

  1. No Supervisor/worker below 18 years (verbal clarification will not acceptable).
  2. Smoking, carrying matchbox, lighter, mobile and other types of electronic types of equipment capable to generate the ignition source is strictly prohibited.
  3. Chewing tobacco, Supari, Gutka, other habitual material, and spitting is strictly prohibited inside the premises.
  4. The contractor will provide proper drinking water & sanitation facilities to the worker.
  5. Emergency exit should be used only in the events of the emergency.
  6. Smoking is strictly prohibited in the XXX Premises.
  7. Material, types of equipment, tools, the debris of contractors should not be stored overhead and near doors/emergency exists. No loose material should be left in the work area. These must be stored at the place provided by the concerned XXX representative.
  8. All types of waste generated in the XXX premises must be segregated & disposed of as per the directives of concerned XXX representative.
  9. Diesel / Petrol / any type of chemical / chemically contaminated waste should not be disposed of in water drain/washbasin/ any other place in XXX premises.
  10. Housekeeping should be maintained.
  11. Welding/gas cutting work should not be done without a proper permit on XXX premises.

 4.0       EHS MANAGEMENT:- 

  1. The contractor shall demonstrate a strong commitment to XXX’s EHS Policy.
  2. Be responsible for all aspects of contractor EHS performance & ensuring that his site supervisory person is competent and has the authority to implement the EHS system properly & to follow EHS practices and procedures.
  3. The contractor should have the obligation to minimize the injuries & abate pollution, minimize loss of material. For that, he should take maximum precautions and utilize his own past experience at the time of execution.
  4. The Machineries at the site are maintained in such a manner that it does not pollute the air/water and soil of the site.
  5. Attain in-house / outside training program, those arranged by EHS Dept.
  6. The contractor shall immediately report any oil, chemical, etc. spill to the company.
  7. The contractor shall periodically assess noise levels from operation & install sound absorption and mitigation devices.
  8. Tank/fuel vessels should have secondary containment with a retention capacity equal to 110% of the largest tank.
  9. The contractors should always keep our concern worksite/area neat, clean & free from physical hazards.
  10. Waste materials always keep aside to avoid interference for working & chances of the accident at site and segregation as per standard practices.
  11. The contractor shall be responsible for disposing of waste at their own cost. If not disposed of in a proper manner, XXX will be disposing of & deducting disposal cost from the contractor bill.
  12. The contractor shall make his own arrangement of an emergency vehicle at the site.
  13. In case of an accident, the person should be immediately sent to dispensary / OHC / nearest Hospital for medical help & accident report in the proper format, duly signed by an authorized representative to Safety Officer / HR Dept. without fails. Also, take care of medical treatment/compensation whatsoever as per industrial rule.
  14. The work area shall be maintained in a neat and orderly manner. Aisles, emergency Exits & controls must be kept free from obstruction at all times.

5.0 PPE:- 

  1. Approved Safety helmet & Safety shoes are mandatory in premises to employees & supervisors of the contractors depending on their work.
  2. Contractors should ensure that all the employees are equipped with proper protective equipment for the work and they are entrusted with.
  3. PPE should always be meeting the appropriate standards, is to be provided by the contractor (BS / ANSI – American National Institute)
  4. Proper training for the use and care of such Personal Protective Equipment to be given by the contractor to all workforces.
  • Head protection: Safety Helmet
  • Eye & Face protection: Safety Goggle with side shield & face shield
  • Foot protection: Safety Shoes/gumboot
  • Hand protection: Hand gloves (work related compatible material).
  • Fall protection: Full body harness
  • Hearing protection: Earplug / Earmuff
  • Dust mask: Approved for protection from Dust inhalation (DGMS/CE/NIOSH)

 6.0       CLOTHING & OTHER APPAREL:- 

Clothing suitable for the job shall be worn.

  1. Long pants and shirts or coveralls should be worn at all times during perform the work.
  2. Ragged or loose clothing and jewelry (ring, watch, necklaces, etc.) are not to be worn when operating equipment.
  3. Any clothing that becomes saturated with petroleum / hazardous chemicals should be promptly removed or changed.
  4. Wearing loose clothes are not allowed near rotating parts /equipment.

7.0 WORK PERMIT:- 

  1. The contractor should take work Permit from the concerned Dept. for any activity.
  2. At every time contractor should have a valid permit for work at the site, which is also signed by standby Supervisor, concern HOD & concerned Plant Head.
  3. Safety Officer Sign is required on Hot, Height, Vessel entry & civil permit.
  4. Dept. supervisor/engineer should be responsible for monitoring job & site till completion & strictly follow the precautions of related permit.
  5. The electrical permit under control of Electrical HOD / Unit Head.
  6. Contractor shall provide proper illumination in their respective work area after sunset, also ensured safe working when natural daylight may not be adequate for clear visibility.
  7. After completion of job Supervisor should close permit, file the record copy.
  8. XXX reserves its right to suspend the work in the event of the contractor not complying with the rules or instructions with regard to Safety practices for which no claim of any kind will be entertained.

8.0 Vehicles: 

  1. The vehicle should be parked in the parking area or as per the instruction of the security officer.
  2. U.C. Of vehicle & driving license of the driver should be valid & should be shown to security officer during entry of XXX,  otherwise, entry of the vehicle will be refused.
  3. The vehicle should not have diesel/petrol/ water leakage.
  4. Loading dock should be used during loading or unloading only. Afterward, the vehicle should be removed from loading dock & should be parked at the parking area or as per the instruction of the security officer.
  5. Maintenance work for the vehicle is not allowed inside the XXX Premises.
  6. Washing of the vehicle is not allowed inside the XXX Premises.
  7. Contractors should not park their vehicle in such a way that it will be a hindrance to the smooth flow of traffic in the premises.
  8. Jumping on or off trucks, automobiles or another moving vehicle is prohibited. Men should wait until the vehicle stops before attempting to enter or leave.

 9.0 Accident & Emergencies: 

 In case of an emergency stop the work, keep equipment in a safe location and gather near assembly point. These instructions should be followed in case of accidents/emergencies. 

9.1       Personnel Protection: 

  1. The person should wear goggles giving complete protection to the eyes.
  2. The person should wear hand gloves to handle the material.

9.2       Actions by the Driver In Case of Accidents:

  1. Stop the engine.
  2. No naked lights, no smoking.
  3. Mark roads and warn other users or passers-by
  4. Absorb leaking liquid with earth or similar material

 9.3 Actions By The Driver In Case of fire:

  Use a fire extinguisher only for smaller fire in connection with the vehicle. Do not fight a fire:

  • Which can increase with loaded material?
  • Which cannot be controlled with the fire extinguisher?

Inform immediately to the local fire department immediately.

9.4       First Aid: 

  1. If the substance has gone into eyes, immediately wash the eyes with plenty of water for several minutes & take help of the nearest doctor.
  2. Remove contaminated clothes immediately & wash affected skin with soap & water.
  3. In case of burns immediately cool affected the skin as long as possible with cold water.
  4. Seek medical attention when anyone has symptoms apparently due to inhalation, swallowing or contact with skin or eyes or following inhalation of fumes produced by the fire.
  5. Contractors should arrange own First Aid box at the work site & they should maintain the required material in it & take proper care of injured persons.

 9.5 Laisioning with XXX:

 All fires, serious injury-accidents and any chemical spillage in large quantities should be reported immediately to intercom telephone numbers: 000,000,000,000,000,000 Representative of XXX will provide you required help & will contact emergency services for you (if required) & direct them on site/location during an emergency.

10.0     Guide to Disposal of waste

 There are two types of waste generated in the factory. Solid waste and hazardous waste.

 10.1     Solid Waste: 

Waste, which is not contaminated by oil, paint, powder, ink, and any chemical, is considered solid waste. Examples of solid waste are paper waste, polybag/polythene sheet, plastic waste, metal waste, wooden waste, empty drums, etc.

10.2     Hazardous Waste:

Waste, which is contaminated with oil, paint, and any chemical, is considered hazardous waste. Examples of hazardous waste are contaminated cotton/paper/plastic/polybag, sheet / wooden waste, hand gloves, mask, containers.  Empty drums of oil, paint, chemicals, paint, ink, etc.

10.3      Trade Effluent:

Any water, pretreatment soln. bath, plating chemical, used in process when disposed of, it becomes trade effluent. MPCB has given norms for trade effluent prior to disposal. The examples of trade effluent are water used in bath for pre-treatment, water, pretreatment soln. bath, plating chemical, water used to clean the components, etc. This trade effluent to be treated in a comprehensive treatment system consisting of primary/secondary and/or tertiary treatment as is warranted (if required) so as to achieve the quality of the treated effluent to the following standards:

1)   PH                                          Between                                             5.5 to 9.0

2)   Suspended Solids                Not to exceed                                    100 mg/l

3)   BOD 3days 27 Deg. C.         Not to exceed                                    100 mg/l

4)   COD                                       Not to exceed                                    250 mg/l

5)   Oil & Grease                         Not to exceed                                    10 mg/l

The water can be tested at an authorized lab. If the effluent treatment system is not available in the house then these effluents can be treated at the common hazardous waste disposal facility. For further details and guidance for effluent testing, treatment (if required) & disposal you can contact the concerned purchase executive or management representative of XXX.

10.4     Storage & collection waste:

Solid waste and hazardous waste should be collected & stored in separate bins. The main reason for storing this waste separately is if mixed all solid waste will also become hazardous waste.

10.5     Disposal method:

Solid waste should be given to off-site recycler for recycling.

10.5.1  Disposal method of oil:

Oil should be given to Ministries authorized recycler who can recycle the oil.

10.5.2  Disposal method of hazardous / contaminated waste:

Hazardous waste to be incinerated at the Ministries authorized site. For further details and guidance for waste disposal, you can contact the concerned purchase executive or management representative of XXX.

10.5.3  Operational criteria: 

  • Avoid spillage of paint, powder, water, oil, chemicals, etc.
  • Keep containers of paint, powder, oil, chemicals closed and the lid secured when not in use.
  • Store paint, powder, oil, and chemicals at the designated place as per respective material safety data sheet. (MSDS)
  • In case of spillage, arrest spill immediately by soaking contents with rags, cotton waste or sawdust. Clean and keep the contaminated material at the designated place.
  • Do not allow paint, powder, oil, and chemicals to spill or drain in water or stormwater drain.
  • Use bare minimum quantity (avoid excessive use) of oil for lubrication, cotton waste.
  • Study MSDS for use of PPE, ensure the use of Personnel protective equipment (PPE) such as hand gloves, mask, etc. as mentioned in MSDS.
  • While painting/powder coating ensures that proper process parameters are set as recommended by the manufacturer or as per process validation to avoid defects.
  • Ensure appropriately skilled operators are employed for respective operations.
  • Ensure that paints/chemicals are used before the expiry date. If it is expired do not use & sent it back to the manufacturer.
  • Store hazardous waste and solid waste in different bins at respective places. Ensure hazardous waste & solid wastes are not mixed.
  • Dispose of solid and hazardous waste as per the guidelines are given above.
  • Ensure following while handling & storage of hazardous waste.
  • Do not store hazardous waste for more than 90 days.
  • Store all hazardous waste in the designated place in closed container/drum & Keep the container closed with a lid during storage.
  • Use properly cleaned container only for the storage of hazardous waste.
  • Mark the container holding hazardous waste as “HAZARDOUS WASTE” in both English & local language & put danger sign on it.
  • Ensure following while disposal of hazardous waste.
  • For disposal of hazardous waste use transporter who is authorized to handle hazardous waste. Generally, waste management vendors send their transporter to collect hazardous waste.
  • During disposal of hazardous waste prepare hazardous waste manifest. Explain the use of TREM card & give its copy to the transporter
  • Verify containers/boxes/cartons offered for transportation for its suitability & mark / label them with type & category of waste in it.
  • Instruct transporter to deliver hazardous waste without any delay to the designated facility.

 11.0 SCAFFOLDING:- 

  1. While working at heights adequate scaffolding & staging should be used.
  2. Scaffoldings should be of sound material, securely fastened and should be capable of supporting 4 times the combined weight of men and material who will be working on them.
  3. Wooden planks used in scaffoldings should not be less than 10” wide, 2” thick and should not extend beyond the outer supports by more than 12” nor less than 6”.
  4. Railing, guarding and toe boards should be provided in all scaffoldings, which are 2 meters or more in height.

12.0     OVERHEAD WORK / WORKING AT HEIGHT:- 

  1. Always uses, to protect from serious injuries due to fall from a height, if the concerned worker will be performing work at height – above 1.8 meter. From zero level or more is mandatory (If there is no Permanent platform and railing available). No half body safety belts are allowed.
  2. In critical situation use, two lifelines / generate the firm supports / necessary arrangement for hook up the lifeline at elevated levels. In the absence of such a structure, seek assistance from the Plant / Building.
  3. Common life-line shall be used wherever linear movement at height is required. 

13.0 ERECTION: 

  1. This is prerequisites – workman engaged for working at height activities must not be suffering from Hypertension, Diabetes, Vertigo, and Epilepsy.
  2. Erecting/lifting machinery should have a valid test certificate.
  3. Only qualified and authorized employees should be allowed to operate mobile cranes and other hoisting equipment.
  4. Before operating cranes or hoisting equipment, the operator should sound a warning and he should accept signals only from one person for starting the work of raising, lowering and swinging loads.
  5. The only authorized supervisor should instruct to the crane operator.
  6. Workmen in charge of the working squad should be responsible for the safe loading and use of ropes, chains, slings, jacks, skids, and other hoisting and lifting apparatus according to their Safe Working Load (SWL), use of defective tool & tackles not allowed.
  7. No persons shall be allowed to stand, walk or work beneath/under any suspended load or erecting equipment.
  8. The operator should stop crane immediately if STOP signal from anyone.
  9. Guide rope must be used for guiding & at time of lifting any loads.
  10. Don’t release the load on chain block, crane and hydra for a long time.
  11. Hanging equipment around operating units is prohibited at all times.

 14.0     LIFTING MACHINE / LIFTING TOOLS & TACKLE:-

  1. Valid test certificate of tool & tackles submits to concern Dept. / or shall be thoroughly examined & tested before taking in to use at least once in a year by a competent person.
  2. Lifting Machine: Crane, crab, winch, teagle, pulley block, gin wheel, etc.
  3. Lifting tackle: Chain sling, rope sling, hook, shackle, swivel, coupling, socket, clamp, tray or similar appliances using for lifting load or loads by use of lifting machine.
  4. Defective or worn out tools & tackles ropes should never be used even if the loads appear small. Always used standard & certified tool & tackles.
  5. New links should be inserted by competent persons.
  6. Check thoroughly all lifting tools, tackles, ropes & slings before putting them to use.
  7. When applying U Bolts and clips, to be checked adequate number.

15.0     NATURAL / SYNTHETIC / FIBER ROPES:

  1. The rope should have properly cared and the following precautions should be taken. (Cotton, Jute, Nylon rope not allowed)
  2. The rope should not pass over sharp edges; kinked ropes should not be used.
  3. The rope should not drag on the ground unnecessarily. Using too small sheaves should be avoided.
  4. The rope should not be permitted to slip on winch drum or moving drums.
  5. Do not tie knots where splices should be used.
  6. Ropes should not be allowed to soak in the oil and exposed to acid or other

Corrosive substances. They should be washed and dried.

16.0     MATERIAL AT HEIGHT:- 

  1. Not to throw any material from any height. In the event, to be followed standard procedure. (Instruct to all other concerned; the particular area must be barricaded to keep other persons in the clear distance, also to be kept supervisor for monitoring till completion of the job.)
  2. Open machinery is not allowed at the work site, proper guarding is required.
  3. Keep all your hand tools such as chisels hammers. Files punch spanners wrenches etc. in good condition at all time.
  4. Keep wrenches spanners & other tools securely so that they will not slip at the time of execution of the job. Also do not leave Tools and materials on an elevated position, if there is a possibility of falling from a height.
  5. Do not use tools for another purpose, for which they were designed.

17.0     ELECTRICAL CONNECTIONS:- 

  1. XXX giving single point connection to every contractor. He should generate an extension board for further distribution.
  2. Only qualified persons of the contractor should undertake electrical works/repairs. If required take help of XXX electrical team.
  3. The contractors should take precautions to prevent tripping hazards caused by defective equipment and welding lines etc.
  4. The contractors should arrange required fire extinguisher at the site for emergency uses.
  5. Bare wire for connection/extension not allowed on premises.
  6. Provide ELCB for main extension board to protect others.
  7. Be careful about the loose connection.
  8. Take approval from electrical HOD for temporary electrical connections, he should ensure cables quality /earthing/grounding arrangement, etc. 

18.0 ELECTRICAL WORK:- 

  1. Treat all circuits as LIVE unless ensured to be DEAD.
  2. XXX system to be followed for better communication.
  3. All electric hand lamp/bulbs should have a protective wire mesh guard.
  4. A clear indication of ON-OFF switches will must on related equipment & use appropriate Amp switch. Also, use approved PPE for electrical work.
  5. Make sure the cord will be protected against abuses and possible damage, from welding sparks, hot surfaces, and sharp edges.
  6. Ladder used for electric equipment should be of non-metallic construction so as not to be a conductor of electricity.
  7. If any cables passing through an aisle or passage make sure it is raised to at least 2 meters above the ground, to avoid damage.
  8. Immediately change damaged cables, don’t wait for an accident/incident.
  9. Regularly check test lamp, working condition of electrical tools by a competent / authorized supervisor.
  10. Identify electrical hazards, repair or report immediately to concerned or XXX electrical Dept. for help or rectification.
  11. In flameproof area always use flameproof tools.
  12. Electrical tools provide with ground wire, top pins, and sockets and should have proper gland packing.
  13. Ensure, the extension cord is free from the cut, damage insulation links or joints. Cable marker to be provided for underground cables.
  14. Ensure easy access to put OFF the supply in case of emergency. In case of short circuit /fire/equipment caught fire.
  15. Extinguished electrical fire with the CO2 extinguisher, in absence of CO2 to be used DCP extinguisher (aim is to extinguish the fire).
  16. Use warning instruction boards while working on Feeder / Panel.

 MEN ARE WORKING

 DO NOT PUT ON

 19.0     GRINDING / SHEARING MACHINE:- 

  1. The grinding/ Shearing machine always maintain in good condition.
  2. Grinding / Shearing machine should have protective wheel guard.
  3. Top pin required for connection & extension purpose from extension board, avoid joints for cable & chances of a short circuit in premises.
  4. Grinder operator should have safety goggle, leather hand gloves, and safety shoes. Use proper ISI / approved grinding wheels all the time.
  5. The skilled employee should operate grinder / Shearing & barricade the front area to restrict sparks. Shifted flammable material from the site.
  6. All portable power tools such as drills & grinders etc., which are operated electrically, should be thoroughly inspected before making use of them. 

20.0     CIVIL WORK:-

  1. Before starting excavation, Civil Dept. should take clearance of Electrical, Mechanical & Safety Dept. for the absence of underground cable & lines.
  2. Use MS pipe scaffolding with necessary clamping. Bamboo-jute scaffolding & use of empty drums for workbenches is strictly prohibited.
  3. Barricade the area before excavation/shifting of material / shuttering / deshuttering & work at height.
  4. Concerned Dept. should give maximum & enough precautions at the time of working to avoid accident/incident.

21.0     WELDING WORK:- 

  1. Adequate precautions should be taken during welding (arc/argon) or gas cutting against hazards such as electric shocks, burns, fumes, fires, explosion and arc eyes, etc.
  2. Welding machine shall be in good condition (should have an ON-OFF switch, Amp meter, Voltmeter, proper connector, copper cable for earthing & welding holder, lugs for fitting cables, Amp adjustable in good condition (remotely operated is also acceptable), holder for connecting earthing).
  3. Use armored cable up to welding machine with the top pin.
  4. Always use safety shoes, Leather hand gloves, welding shield / proper tint goggle, safety harness depending on work situation (always be careful).
  5. To carry out gas cutting or welding work beyond 15 Mtr. from the place where any hazardous/flammable material is kept.
  6. During welding, the earth should be given directly at the job, no short-cut allowed.
  7. The welder should be qualified/skilled & perform his work independently, not depend on another employee for adjusting current and so on.
  8. To be provided with adequate ventilation, if work performs in confined spaces.
  9. When welding or gas cutting in elevated positions, precautions should be taken to prevent sparks or hot metal slag falling below, where the other employees are working / flammable material stacked below.
  10. Make a practice to collect the burnt welding rod pieces in drum & handover to dept. for further disposal.
  11. Workshop: Before welding or cutting a pipe, tank or container, which contain flammable material, it should be thoroughly cleaned and gas free and if necessary ‘Hot Work Permit’ should be obtained.
  12. Welding booth should be located at downwind direction to avoid exposure of toxic gas to others.
  13. Use required PPE’s & warned cloth should be free from oil and grease.
  14. Goggles should be worn while chipping the welding slag. 

22.0     LADDER:- 

  1. Safety goggle, welding shield, hand gloves (Leather– Hot work, Cotton– Material handling, Rubber– acid & alkali, Cryogenic – LPG / IB) to be used whenever necessary.
  2. The contractor should have a proper ladder. Wooden / bamboo / torr-steel ladder not allowed on premises.

 23.0     PAINTING WORK:-

  1. The painting contractor should follow all due precautions of painting standards / working at height/cleaning/ protecting equipment/disposal of waste.
  2. In confined spaces, workers shall be protected with approved mask/airline respirators / tight fitting rubber mask (especially for spray painting).
  3. The contractor can use approved Botwin chair / Zoola at time of painting at an elevated level, with required accessories.
  4. Don’t do painting below the permitted hot work, or above the other work.
  5. Generate pipe scaffolding wherever required.
  6. Compressed gas shall not be used for cleaning of clothing / or part of the body. If used for another cleaning, the discharge shall not exceed thirty-30 psi and eye protection shall be warned.

24.0     COMPRESSED GAS CYLINDERS / GAS CUTTING:-

  1.  We shall be allowed only Acetylene /  Metal Cutting Gas cylinder in our premises for cutting purpose & issuing a permit for the same.
  2. Cylinders should have protective valve cap if it is in use / when being transported / empty & spares kept in the shed.
  3. Cylinders identification on the basis of the standard color code of GC Rules.
  4. Use XXX approved cutting torch, Regulator & hoses for cutting set & must be inspecting frequently (Hoses: Red–Flammable gas & Blue –Oxygen)
  5. Provide nRV and flashback arrester cylinders for to protect the cylinder from flashback & backfire.
  6. Hosepipe and another accessory to be connected with proper clamps.
  7. Acetylene or Liquid compressed Gas cylinder shall never be used in the horizontal position, as the liquid may be forced out through hose causing a Fire hazard/ explosion.
  8. Use proper trolley for shifting/carrying cylinder, rolling and carrying on the shoulder to be avoided.
  9. Compressed gas cylinder shall be stored in the upright position & secured with chain in a shed. Flammable & non-flammable keep separately.
  10. Compressed gas cylinder shall be returned immediately to a suitable storage area after use. They shall not be permitted to lie around the work site
  11. The only qualified/skilled worker should do the cutting work.
  12. The gas cutting torch must be lighted by means of friction lighter.
  13. The gas cylinder should be placed in locations where sparks or flames from
  14. Leather hand gloves & goggle mandatory at the time of performing work.
  15. If the cylinder is in use, cylinders valve-key must be placed on valve spindle.

 25.0     OTHER WORKS:-

 Material handling contractor should take utmost care of our employees, avoid exposure, skin contact & working in the chemical exposed area,

  1. To minimize risk to employees and others,
  2. Not creating new hazards at the site, for that, he should take maximum care,
  3. Abate pollution.

26.0     PENALTIES:- 

  1. In case of damage to property due to lapses by the contractor, XXX Management has reserved the right of necessary actions.
  2. A penalty of Rs. 10, 00,000 shall be levied for every fatal accident and Rs.2, 00,000 for every loss time injury occurring during the course of the execution of the said contract.
  3. Penalties for the non-compliance of safety regulations will be levied as under: If any person found violating the safety rules he will be issued a warning, mentioning the name of workmen name of the contractor, dept. / location. Any workmen found violating 3 times will not be allowed to enter the premises/site in the future.
  4. Hiding of disability/accident will result in a penalty of 25% of the contract value.
  5. To threaten / bullying to XXX / other contractor employees said workmen will not be allowed to enter the premises/site in the future. 
TYPE OF OFFENSEPENAL CLAUSE

Not wearing helmets / safety shoes / welding goggles / shield / apron / safety goggles / hand gloves / non standard practices.

First Offence- Warning Note with a fine of KWD. 200/-

 

Second offense- Fine of KWD. 1000/- & action for termination of the job of concerned supervisor/contractor/ workmen.

Nonuse of full body harness / other life-saving safety gear / unguarded tools & machinery / Electrical gloves / Electrical safety shoes / No cordon off the area at the time throwing material from height / no use of safety net / unsafe working which may tend to fatal events / violating the permit conditions.First Offence- Warning Note with a fine of KWD. 100/-

 

Second offense- Action for the concerned supervisor/workmen for termination of his job and a fine of KWD. 1000/-.

 

Contractor / Vendor / Their Employee’s Acknowledgement:

I have read, understood and agreed to abide by Environmental, Health And Safety Requirement and Do’s & Dont’s of XXX.

Name:

Signature:

Name of Company:                                           Date:

Trainer’s Acknowledgement:

The above-named employee was trained to understand and abide by the Environmental Policy and Dos & Dont’s of XXX.

Name:

Signature:

Name of Company:                                          Date:

Note: XXX representative will train Vendors & Contractors whereas Contractors & Vendors will be responsible to train their employees prior to arriving at XXX.

Contact XXX

XXX,

Procedure for Incidents Investigation, Non-Conformity, and Corrective Action

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 DescriptionReference No.
1Environmental Incident registerEOHS-RG-05
2Incident reportEOHS-F-08
3Work PermitEOHS-F-09

Example of Procedure for Evaluation of Compliance

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. NoDocument /Record DescriptionReference No.
1Legal RegisterEMS-RG-01

Procedure for Emergency Preparedness And Response-HSEMS

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 DescriptionReference No.
1.List of Emergency Response Team MembersEHS-ML-18
2.List of Personnel Protective EquipmentEHS-ML-20
3.Mock Drill FormatEHS-F-01
4.List of EmergenciesEHS-ML-19

Procedure for establishing Operational Control

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.NoDocument /Record DescriptionReference No.
01.Master List of Operational Control ProceduresEHS-ML-17

Procedure for Communication, Participation and Consultation

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 CommunicationMode Of

 

Communication

1.Awareness on the purpose of EHS Management System

All Employees

EHS MR & CFTNotice Board & Training Programme
2.EHS PolicyAll EmployeesEHS MR,  Dept HeadPoster, Cards, Display boards & Training
3.

Role & Responsibility

Concerned EmployeesRespective Head of the Departments & HRWork Instruction / Procedures
4.Objectives And TargetsAll employeesRespective Head of  the DepartmentsGroup Discussion,

 

Management

Review Meeting, Posters

5.

 

 

EHS Issues

Concerned Div. HeadsEHS MREmails, Minutes of Meetings,  Notes

 

Presentation.

6.Legal and other regulatory requirements.Concerned Employees

Legal Team

Mail mentioning legal requirement, Minute of Meeting.
7.EHS PerformanceManagement Review CommitteeEHS MRManagement Review Meeting

5.3.2 EXTERNAL COMMUNICATION

S.No.Interested PartyTopic For

 

Communication

Mode Of CommunicationResp. of Receiving, Recording and Communicating
1.CustomerAny relevant Information as required by the CustomerVerbal/ Letter/ emailsMarketing
2.Local CommunityAny EHS Concerns raisedVerbal / Letter/ emailsHR
3.SupplierRequest for improving Environmental & Safety Protection.

 

Any Other Issues  raised

Significant Impacts / Risks from their operations.

Letter/ emailsPurchase
4.Visitors / Contractor’sRequest for improving Environmental Protection

 

Any Other Issues raised.

Significant Impacts / Risks from their operations.

Verbal/ Letter / Notice board/emailsConcern HOD’s
5.Banks & InsurersRelevant Information as requiredLetter/emails 

 

Finance

 

6.MediaInitiatives taken by Organization & Subsequent DevelopmentPress-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 DescriptionReference No.
01.Concerns/suggestions from interested partiesEHS-F-03
02.External communication registerEHS-RG-04
03.Internal Feedback formEHS-F-05
03.Minutes of  Meeting (Safety Committee)QSA-FR-05

Procedure for Competence, Training, and Awareness.

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.

  1. 0 Document / Record reference
S. No.Document /Record DescriptionReference No.
1.Skill  MatrixPER-FR-06
2.Training CalendarPER-FR-02
3.Training NeedPER-FR-01
4Training Attendance SheetPER-FR-03
5Training Feedback & EvaluationPER-FR-04

Procedure for Resources, Roles, Responsibility, Accountability, and Authority.

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. NoActivityResponsibility
1Appointing a Management RepresentativeManaging Director
2Selection of CFT MembersEHS MR
3Review and approval of PolicyPrepared by EHS MR, Reviewed &  approved MD
4Conducting Initial Review & Significant Impact / Risk AssessmentCFT
5Setting up objectives and targetsEHS MR & CFT
6Establishing Management ProgramEHS MR & CFT
7Approval of Management ProgramManaging Director
8Identification of Legal and Other RequirementsLegal Team
9Providing resources for Implementation  Managing Director
10Identifying training needsCFT
11Organizing Training HR Department
12Internal CommunicationAs per defined Procedure
13External Communication
14Document ControlEHS MR
15Operational Control Measurement & MonitoringCFT
16Emergency preparedness and responseSafety Officer & ERT Members
17Review of Procedures after emergencyERT
18Calibration of InstrumentsQA Deputy Manager
19Handling and Investigating NC’sEHS MR & CFT
20Initiating Corrective and Preventive actionEHS MR & Resp Dept HOD’s
21Maintaining RecordsCFT
22Conducting AuditTrained Internal Auditors
23Conducting Management ReviewManaging Director

Procedure for Identification Of EHS Objectives, Targets, and Programs

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 DescriptionReference No.
1List of significant Aspects and ImpactsEHS-ML-07
2List of Significant Risks & Unacceptable HazardEHS-ML-13
3List of EHS Management ProgrammeEHS-ML-08
4List of EHS Objectives.EHS-ML-15
5Management Programme closure reportEHS-F-04
6EHS Management ProgramEHS-F-02