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:

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:

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

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: 

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

5.3.2 EXTERNAL COMMUNICATION

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:

1.0 PURPOSE:

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

2.0 SCOPE:

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

3.0 RESPONSIBILITY:

 HR Manager

4.0 DEFINITIONS:  

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

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

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

5.0 PROCEDURE:

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

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

5.2   Competency, Training & Awareness:

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

5.3 Identification of Training Needs and Training Calender:

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

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

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

6. 0 Document / Record reference

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

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:

1.0 PURPOSE:

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

2.0 SCOPE: 

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

3.0 RESPONSIBILITY:

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

4.0   DEFINITION:

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

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

5.0 PROCEDURE:

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

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

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

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

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

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

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

6.0 Document / Record reference: