To define responsibility and authority for handling and investigating incidents and non-conformance, taking corrective action or preventive actions to mitigate or deal with any actual or potential nonconformity.
Follow-up and confirmation of the effectiveness of corrective actions and preventive actions are taken.
SCOPE
Applicable to all EHSMS non-conformances, incidents across all departments of XYZ Ltd. are covered under the FrameWork Standards for EC and OH&S.
RESPONSIBILITY
The overall responsibility for establishing, documenting, implementing, and updating this system lies with the SHE Coordinator.
The key responsibility for implementing the requirement of the system in the Department lies with the Dept Heads in the respective departments.
SYSTEM REQUIREMENT
GENERAL
Deviation from key requirements of the EHSMS & Operation Control Procedures, which can have a consequence on the EH&S is non-conformance. Non-conformance could be:
Legal non-compliance
EH&S-related complaints from interested parties such as the public, employees, neighbors, statutory bodies, investors, etc.
Lack of or ineffective implementation of any of the EHSMS requirements/procedures.
Incidents including near misses and injuries and illness cases “Procedure for control and investigation of EHS incidents and non-conformance” and “Corrective and Preventive Action” is as follows:
INCIDENT INVESTIGATION (NEAR-MISSS AND ACCIDENTS)
All acci
This is
then investigate
Employees that have been witnesses to the incident are involved in the investigation process.
The remedial actions are listed in the SHE action checklist with responsibility and the time frame for completion. This checklist is reviewed weekly as part of the weekly production meeting by the FM and all managers to ensure compliance within the time frames allotted.
All LTA’s are reported to Corporate Safety and Environment Head within 4 hours of occurrence. Serious incidents are also reported and a detailed investigation report follows in 24 hours.
Fatalities and serious incidents (accidents) are reported by the Corporate Safety and Environment Head to the Director, of Human Resources, Corporate Affairs, and Technology who then reports these to Unilever as per the Unilever standards of reporting such occurrences.
DENSIFICATION & REPORTING OF NON-CONFORMITY
Non–conformances &/OR Observations are identified through one or more of the following events
Regulatory agency inspection leading to the issuance of notice of violation or similar document
Occurrences such as sudden leakage/ spillage/ accidental or abnormal release of products/ wastes/ episodic emissions/ deviations from established norms of operation & practice causing significant EHS impacts observed during routine operations.
Incidents include near misses and accidents. Analysis of root cause, preventive & corrective actions
Complaints/ notices related to EHSMS issues received from interested parties
Note: Interested parties include affected individuals, voluntary environmental protection organizations, courts, MPCB, Factory Inspector, other statutory bodies, employees, investors, insurers, financial institutions, customers, sub-contractors, Corporate EHSMS, and associations concerned about EHSMS.
Natural calamities such as cyclones, earthquakes, floods, and major fires, impacting regular operations and leading to environmental disturbances or OH&S injuries or illnesses are also considered as a non-conformance.
Routine day-to-day inspections/observations
Reporting of OBSERVATIONS & Nonconformance
Under any of the occurrences as described above the nonconformance is reported in the specified Incident investigation form or thru mail for near misses.
The operation in charge of an area raises the investigation form.
The Form is routed to the Departmental Head by the initiator
CORRECTIVE AND PREVENTIVE ACTIONS
Immediate corrective actions/s are taken to control or minimize the impact caused by identified observations or nonconformance
Non-conformances / observations are investigated to find out root cause/s and appropriate corrective action or preventive actions identified
The identified corrective action and/or Preventive actions are written on the CPAR.
In case inputs are required from other departments for identifying/ verifying the corrective/ preventive actions, they are coordinated accordingly through internal communication and are obtained.
Corrective action and/or preventive action is accordingly finalized
IMPLEMENTATION OF CORRECTIVE AND PREVENTIVE ACTIONS
Depending on the type and nature of the corrective and preventive action, coordination for its implementation is taken.
Based on the severity of the observation or nonconformance corrective action may be taken immediately and then the CPAR may be raised.
Implementation of the corrective action is done according to the systems and procedures of XYZ Ltd.
CLOSURE OF CPAR
The Corrective and preventive action is implemented and verified and then CPAR is closed. Records are maintained for a specified time period.
MANAGEMENT REVIEW
A synopsis of the Pending corrective actions and preventive actions, Preventive actions planned and taken are provided to the SHE Coordinator from the “Register of non-conformance and disposition, corrective and preventive actions with respect to EC and OH&S FWS requirements” at least two weeks before the Management Review Meeting
If corrective or preventive action requires any change in the documentation, the same will be recorded and implemented as per the Procedure for Document Control EHS Manual.
