A review of the organization is conducted by the Core EHS Team at the beginning of the system & a subsequent review has been conducted a frequency of once every three years to determine the environmental aspects of health & Safety Hazards.
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IDENTIFICATION OF ENVIRONMENTAL ASPECTS & HEALTH & SAFETY HAZARDS
PROCESS
OWNER: M.R (for Co-ordination)
PROCESS
INPUTS: All Company’s
products, processes, and services
PROCESS DESCRIPTION:
A
review of the organization is conducted by the Core EHS Team at the beginning
of the system & a subsequent review has been conducted a frequency of once every three
years to determine the environmental aspects of health & Safety Hazards.
Core
EHS Team consisting of M.R. and all other H.O.D’s
conduct a brainstorming session to list down the various operations
of the company and prepare an “
INVENTORY OF OPERATIONS”. For this purpose documented
guidelines (I-E10-01 & 02) are followed by the team and the information
generated is recorded in the aspect identification & analysis record (AIA)
(R-E10-01) and hazard identification & risk analysis record (HIRA)
(R-E10-02).
For
each of the operations identified above, an analysis is carried out for inputs
to the operation and outputs/releases from the operation, and all
possible environmental aspects and health & Safety Hazards are
identified. While identifying the aspects & hazards of operation in each
department, the team makes use of documented guidelines for the identification of
environmental aspects and health & Safety hazards (I-E10-01 & 02). The
results of aspects & hazards are recorded and maintained in the (R-E10-01
& 02)
The
team then debates and discusses the impact/ risk rating as per the criteria
(I-E10-03 & 04) to determine the total ratings of all identified aspects
& hazards. The significant/unacceptable aspects & hazards are selected
on the basis of criteria defined in the above instruction
Individual
Heads of Deptt. keep track of any changes w.r.t. organization, equipment
/machine, process, material including temporary change or incident/accident
taking place and their impacts on operations, processes, and activities. In case
of any such instances taking place, they get the operation
inventory modified through the MR,
who then initiates the process of identifying changes in
relevant aspects & hazards and their impacts/ risks, as per the process
above. This may require revisions of aspects & hazards, regulatory
requirements, and impact/risk rating.
PROCESS OUTPUTS: Aspect identification & analysis record (AIA) (R-E10-01) and hazard identification & risk analysis record (HIRA) (R-E10-02).
MANAGEMENT OF LEGAL & OTHER REQUIREMENTS
PROCESS
OWNER: HOS (Personnel
& Admn.)
PROCESS
INPUTS: a)
Identify hazards & aspects
b)
Environmental, safety, and health acts and rules
PROCESS DESCRIPTION:
The
company maintains a subscription to Environmental, safety, and health acts and rules, consents/permits, and any other documents as a
database. The track is also kept of any changes/ amendments to the above through
circulars, subscriptions, Liaoning, etc. for keeping the information updated. In
view of any changes as above, required changes are made in the documents.
Based
on regulatory requirements & other requirements like company’s production
& internal requirements, hazard identification & control, best
practices codes, Industry associations/ regional standards/ interested parties/
customer requirements are determined through Regulation
Register (R-E20-01) and for applicable requirements Regulation &
Other Requirements Monitoring and Compliance Program (P-E020-01) has been
prepared for compliance & monitoring. Where more than one requirement on
the same issue is identified to be applicable, the most stringent requirement
is listed in the program. Apart from compliance with the program all
reports/ statements are sent to the regulatory bodies, any other information
with respect to applicable regulatory requirements is provided by MR.
At
least once a year, all regulatory and other requirements are evaluated and
compliance is ensured through a checklist (F-E020-01)
PROCESS OUTPUTS: Compliance with regulatory requirements
E-030 OPERATIONAL CONTROL
PROCESS
OWNER: All Heads
PROCESS
INPUTS: a)
All significant hazards and aspects
b)
Contractors working on site
c)
Regulatory requirements
PROCESS DESCRIPTION:
Based
on the above inputs operational Control has been defined as aspect
identification & analysis record (AIA) (R-E10-01) and hazard identification
& risk analysis record (HIRA) (R-E10-02) . These records specify,
among other things, the operation related to the control of
significant/unacceptable aspects & hazards
including instructions for control of process sequence &
parameters to be monitored and any precaution to be taken. While defining
controls following hierarchy has been considered:
The
Hindi/ English version of these operating instructions are displayed at the
relevant location for use by the operators, wherever required, as per the
process for document control. The equipment associated with
significant/unacceptable aspects & hazards requiring preventive maintenance
has been identified and executed as per the process for maintenance.
PROCESS
OUTPUT: Control of processes to meet the defined requirements.
E-040 CONTROL OF CONTRACTED SERVICES
PROCESS
OWNER: All HODs
PROCESS
INPUTS: Activities of all contractors, can be influenced by
the company
PROCESS DESCRIPTION:
A list of all contractors working on site is maintained (L-E040-01).
Based on the performance of existing contractors who had been delivering
satisfactory services to the company for the past one year and above have been
listed. Any new contractor to be hired for services is selected by the HOS
& approved & V.P. (O) by comparing the contractor’s skill with the job
requirement. For this purpose, he may consult the other user HODs. The records
of contractors’ assessments are maintained in the contractors' file by the HOD
(Personnel).
All
approved contractors are issued a copy of relevant instructions along with the
issue of the contract. All existing approved contractors have also been supplied
with a copy of such instructions. Any changes/amendments made in
instructions of contractors are requiring a fresh copy to be issued to the
contractor by MR.
For
contractors working at the site, the copy of such instructions is displayed at
relevant places for reference by them during use and the respective HOD monitors
their performance on a day-to-day basis. Contractors or their employees working on
site are provided training as per the process of HRD and records are kept.
All
HOD’s ensure conveying complete requirements to contractors and suppliers
through contract agreement/ indent/purchase order affecting quality,
environment & safety to the contractors and suppliers of a new plant,
equipment, materials, chemicals, technologies, process, procedures, work
pattern, etc. On receipt of deliveries, compliance is verified as per receipt
inspection plan (P-E040-01), in case of any non-compliance matter is taken up
with the supplier suitably and records are kept. All
visitors have informed the environment, health, safety & emergency related
issues by the security & respective head
PROCESS
OUTPUTS: Control of activities of contractors formatting the requirements
of EHS management system
E-050 EMERGENCY PREPAREDNESS
PROCESS
OWNER: Head (P&A)
PROCESS
INPUTS: All potential emergencies situations and accidents
PROCESS DESCRIPTION:
During the identification of aspects & hazards, potential emergency situations and
accidents have been identified and recorded in the aspect identification &
analysis record (AIA) (R-E10-01) and hazard identification & risk analysis
record (HIRA) (R-E10-02). Considering emergencies and accidents and taking
into account the needs of relevant interested parties, e.g. emergency
services and neighbors an on Site emergency plan has been prepared
(P-E50-01). The plan gives the details of the Command structure to handle the
emergency, responsibilities of various functionaries, preventive measures to
avoid emergencies, maintenance of personal protective equipment, fire fighting
equipment, and first aid boxes. The plan also defines the ways to mitigate the
impact of emergencies on the environment and personnel. The above plan is reviewed
periodically in view of lessons learned from emergencies and accidents and wherever
felt necessary the plan is revised.
PROCESS OUTPUTS: Structured handling of emergencies & accidents.
E-060 MONITORING & MEASUREMENT
PROCESS OWNER: All HODs
PROCESS
INPUTS: a)
Processes as per operational control.
b)
Regulatory requirements
c) Objectives &
targets
PROCESS DESCRIPTION:
Based
on the Operational Control Program, Regulation Compliance Program, and
Management Programs monitoring & Measurement is carried out. Various
programs specify, among other things, the followings:
i) The
key process parameters of different operations/stages related to the
significant hazards & aspects and their specification limits.
ii) The
parameters related to the release/discharge related with the significant
aspect and their specification limits.
iii) The frequency of the check to be carried out on each parameter, the method of test, and actions to be taken in case of deviation.
While
defining the specification limits of various parameters, the reference has been
made to the regulatory requirements, if any. Where ever it is necessary, the
specification limits have been defined as per the company’s standards. The
departmental head ensures that the required monitoring and measurement as given
in the plan is carried out by the designated personnel at the defined
frequency. The record of such monitoring and measurement is kept in the forms
specified in the plan. In case of non-conformity in meeting the standards
(specification limit) with respect to releases or discharge from the operation,
the procedures for non-conformance and corrective and preventive actions are
followed.
The equipment related to monitoring and measurement and requiring periodic
calibration has also been identified by the respective
HOD/HOS and controlled as per the process for calibration.
PROCESS
OUTPUTS: Monitoring and measurement records
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