(Name of company)
EH&S Manual
Environment, Health & Safety
ISO 14001: 1996 & OHSAS 18001:1999
Document No. EHSM 01
Issue No.
01
Date of issue 01.01.2005
Approved by
Copy No.
Issued to
MANAGEMENT SYSTEM MANUAL
Environment, Health & Safety
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AMMENDMENT SHEET
Document(s) reference –
Amendment details
Document &
Issue No.
Section/
Issue No.
Page
No.
Reasons for change
New Issue
No.
& date
Senior Management representative___________________
Date __________________
Issued to Concerned Personnel / User Departments - You are advised to return the copies of pre-amended/revised
issues of above document(s) to the undersigned. Implementation date is as given in column 5 of above table (date of
revised document).
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CONTENTS
(Section 1, Issue 1, Page 1 of 1)
Section/
Annex
Title
Page No.
-
Title page
-
-
1
1
Amendment sheet (whenever any amendment to the
manual is issued)
Contents
2
Introduction
3
3
Scope of EH&S Management System
4
4
EH&S Management System Requirements
5
4.1
General Requirements
5
4.2
E&HS Policy
6
2
7-8
4.3.2
4.3.3
4.3.4
Planning –
Environmental Aspects;
Hazard Identification, risk Assessment and Risk
Control;
Legal and Other Requirements;
Objectives & Targets;
Environmental and EH&S Management Programme
4.4
4.4.1
4.4.2
4.4.3
4.4.4
4.4.5
4.4.6
4.4.7
Implementation and Operation –
Structure and Responsibility,
Training, Awareness & Competence:
Consultation and Communication;
Documentation;
Document and Data Control;
Operational Control;
Emergency Preparedness and Response
9 - 11
4.5
4.5.1
4.5.2
Checking and Corrective Action –
Monitoring and Measurement;
Accidents, Incidents, Nonconformances, Corrective
& Preventive Actions;
Records;
Internal Audit
Management Review
12 - 13
4.3
4.3.1
4.3.1.1
4.5.3
4.5.4
4.6
14
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INTRODUCTION
(Section 2, Issue 1, Page 1 of 1)
1.1, 1.2, 1.3 )Give introduction of the company)
I.4 The company is a forward looking, technology oriented company committed to regular up-gradation of
manufacturing and testing techniques to produce improved quality products.
I.5 The company uses environment friendly materials and technologies in production of footwear. Other activities
and processes are also managed in a manner to ensure that environment is not adversely affected.
I.6 Company also ensures that appropriate health and safety measures are employed to reduce or eliminate
occupational and process/material associated risks.
I.7 For further underscoring its commitment, company ensures that footwear are manufactured under socially
acceptable conditions not only in and around production area but in and around entire factory site.
I.8 The company is also committed to ongoing dialogue with the users of its products so as to optimize the advantage
of company’s products in international market.
I.9 The company is committed to comply with national and other applicable laws, other requirements to which the
company subscribes, and requirements of both ISO 14001 and OHSAS 18001 standards.
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SCOPE OF EH&S MANAGEMENT SYSTEM
(Section 3, Issue 1)
3.1 SCOPE OF MANAGEMENT SYSTEMS
3.1.1 Scope of environmental, health and safety management system as per ISO 14001:2004 and OHSAS 18001 is as
follows:
“Environmental, health and safety management system associated with design & development,
manufacture, supply and export of footwear and footwear components”
3.2 TERMS & DEFINITIONS
3.2.1 Terms and definitions as given in ISO 14001: 2004 and OHSASW 18001: 1999 shall apply.
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EH&S MANAGEMENT SYSTEM REQUIREMENTS
(Section 4, Issue 1, Page 1 of 2)
SECTION 4.1
4.1 GENERAL REQUIREMENTS
(Reference 4.1 of ISO 14001:2004 and OHSAS 18001:1999)
4.1.1 (Name of the company) has established, documented, implemented and is maintaining an Environmental,
Health & Safety (EH&S) Management System according to ISO 14001:2004 and OHSAS 18001:1999.
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4.2 ENVIRONMENTAL, HEALTH & SAFETY POLICY
(Clause 4.2 of ISO 14001:2004 and OHSAS 18001:1999)
4.2.1 Company has documented, implemented and is maintaining following environmental and OH&S policy:
" (Name of the company) is in the business of manufacturing and exporting
footwear and footwear components.
(Name of the company) is committed to continual improvement in its
performance related to environmental management, prevention of pollution,
occupational health & safety.
(Name of the company) shall comply with all applicable environmental,
health & safety legislation and regulations, and any other requirements,
(Name of the company) shall strive for improving efficiency of processes,
elimination of and/or reduction in hazards & associated risks, waste
generation and conservation of natural resources.
(Name of the company) shall subscribe to concepts and principles of UN
Global compact.”
Following points have been given full consideration while formulating these policies:
a) be appropriate to the nature and scale of environmental impacts of organization’s activities, products or
services and associated OH&S risks,
b) commitment to continual improvement & prevention of pollution and reduction of OH&S risks,
c) commitment to comply with relevant environmental/OH&S legislation and regulations, as applicable
from time to time, including concern for public interests,
d) policies are available to interested parties.
The environmental/OH&S policies are reviewed during planned management review by Managing Partner. In case
of any changes in the environment/OH&S legislation, availability of better and environment friendly materials,
technologies and improved OH&S risk controls, any change in neibhourhood scenerio existing environment /OH&S
policies are reviewed for any changes and if considered necessary such changes are carried out.
Environmental/OH&S policies have been communicated to all concerned within the organization to ensure that all
are aware of the relevance and importance of their activities and how they contribute to the achievement of the
environmental/OH&S objectives of their respective functions and the organization. MR initiates steps to verify the
level of environmental/OH&S awareness amongst company’s employees.
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4.3 PLANNING
(Clause 4.3 of ISO 14001:2004 and OHSAS 18001:1999)
4.3.1 Environmental aspects
(Clause 4.3.1 of ISO 14001:2004)
Company has established and is maintaining a procedure to identify environmental aspects of its activities, products
or services that it can control and over which it can be expected to have an influence, in order to determine those
which have or can have significant impacts on the environment (EP-4.3.1).
Environmental aspects of company’s activities, products & services and their respective impacts are identified with
the help of an Initial Environmental Review conducted with assistance of concerned personnel. While listing the
environmental aspects, care has been taken to include those areas also with which the public at large is likely to be
adversely affected.
Based on the above review, significant environmental aspects have been identified and their associated impact on the
environment has been determined. While setting environmental objectives, these aspects have been taken in to
consideration. These significant environmental aspects and associated impacts are reviewed during planned
management reviews and the relevant information is kept up-to-date.
4.3.1.1 Planning for hazard identification, risk assessment and risk control
(Clause 4.3.1 of OHSAS 18001:1999)
Company has established and is maintaining a documented procedure for ongoing identification of hazards, the
assessment of risks, and implementation of necessaery control measures covering routine and non-routine activities,
activities of all personnel having access to the workplace (including subcontractors and visiters), and facilities at the
workplace provided by the company or other organizations. It is ensured that results of these assessments and the
effects of these controls are considered when setting health and safety objectves. This information is suitably
documented and kept up to date.
4.3.2 Legal and other requirements
(Clause 4.3.2 of ISO 14001:2004 and OHSAS 18001:1999)
Legal and other requirements as applicable to environmental aspects of activities, products and services; and OH&S
requirements have been identified. Company has established and in maintaining a procedure for this purpose
(EH&S/P-4.3.2). These legislative requirements are regularly reviewed (at least once a year) based on the inputs
from pollution control board, information in newspapers, environment journals and circulars from other regulatory
bodies, employees and other interested parties.
Company has arranged copies of legal requirements, statutory pollution norms set by UP State Pollution Control
Board (UPPCB). Company has systems to arrange, as required, industry codes of practice, agreement with any
public authority or non-regulatory guidelines, to which it subscribes or may subscribe.
Compliance to UPPCB pollution norms is demonstrated on annual basis, and Board gives its yearly consent if the
compliance is considered satisfactory.
4.3.3 Objectives and targets
(Clause 4.3.3 of ISO 14001:2004 and OHSAS 18001:1999)
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------------------------------------------------------------------------------------------------------------------------------------------Based on the company’s environmental policy and selected significant environmental aspects, environmental
objectives and targets are established for relevant activities and processes (Annex F). Following factors are
considered while establishing or reviewing these objectives and targets:
a) Legal and other regulatory requirements
b) Significant environmental aspects
c) Technological options
d) Operational requirements
e) Business & financial requirements
f) Views of interested parties.
Objectives at prcess/functional level are defined by Process Heads, monitored by Process Heads/MR and reviewed
by Managing Partner.
4. 3.4 Environmental/OH&S management programmes
(Clause 4.3.4 of ISO 14001:2004 and OHSAS 18001:1999)
Environmental management programmes are established for accomplishing objectives & targets. These programmes
include details of all objectives & targets, activities to be accomplished, the person responsible and also the time
frame.. As and when there are any complaints received from neighborhood industries/public, or there happen to be
some changes in company’s activities, its products and services, the environmental programmes are appropriately
modified. The environmental management programmes are reviewed during planned management reviews or
whenever there is a change in product, activities, process etc.
A programme (action plan) is prepared, if required, for achieving defined objectives. Functional heads select an
activity/process/operation for achieving objectives and targets in the defined time frame, and by using specified
means. In case of new developments and new or modified activities and products, plan is amended to cover them
under its scope.
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4.4 Implementation and operation
4.4.1 Structure and responsibility
(Clause 4.4.1 of ISO 14001:2004 and OHSAS 18001:1999)
Roles, responsibility and authority of working personnel for carrying out various activities/processes of EH&S
management system have been defined in respective documents, such as, procedures, forms, work instructions etc.
These have been communicated within the organization to all personnel through group training and personal
interactions. In case of any change in responsibility & authority of any person, the same is communicated to all
concerned personnel.
Mr. Agrawal has been appointed Management Representative by top management of the company. He will look after
the duties of MR, in addition to his designated duties. As MR, he will be responsible for ensuring that processes and
programmes needed for the E&HS Management System are established, implemented and maintained. He will report
to Managing Partner on the performance of the system and any need for improvement. He will also ensure the
promotion of awareness of importance of meeting customer requirements throughout the organization. He will
maintain any liaison with external agencies on matters relating to E&HS Management System.
Factory, workshop and other offices are housed in a well-constructed and planned building. Required workspace and
associated utilities have been provided. Suitable machinery, monitoring & measuring devices have been provided,
and are maintained to achieve conformity to product requirements. Supporting services, such as computers, couriers
and communication facilities have been provided for performing and monitoring various processes to achieve desired
results.
No special work environment is required for manufacture and testing of company’s products. Suitable arrangements
have been made in identified work areas where working personnel are required to take precautions and observe
safety measures.
4.4.2 Training, awareness and competence
(Clause 4.4.2 of ISO 14001:2004 and OHSAS 18001:1999)
Personnel performing work-affecting quality and tasks, which can cause significant environmental impacts, are
qualified as competent based on appropriate education, training, experience and skill. Company identifies their
training needs and appropriate training is given to them for enhancing their skill and competence and to create
awareness about environmental aspects of their activities, associated impacts and control.
Company has established a procedure for determining necessary competence, providing training or taking any other
action to satisfy determined competence needs, and evaluating effectiveness of training or actions taken (QP-6.2). It
is ensured that personnel are aware of:
a) relevance and importance of their activities and how they contribute to the achievement of quality
objectives,
b) importance of conformance with the environmental policy and procedures and with the requirements of
environmental management system, and their roles and responsibilities in achieving such conformance,
including emergency preparedness and response requirements,
c) significant environmental impacts, actual or potential, of their work activities and the environmental
benefits of improved personal performance,
d) potential consequences of departures from specified operating procedures.
Appropriate records of education, training, skills and experience of the personnel are maintained.
4.4.3 Consultation and communication
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Company has established and is maintaining a documented procedure (QEP-5.5.3) for internal communication
between various levels and functions of the organization; and for receiving, documenting and responding to relevant
communication from customers and other external interested parties about its products, environmental aspects and
QEMS. Communications received are considered while identifying significant environmental aspects and quality
characteristics of the products. Records of these communications are maintained.
4.4.4 Documentation
(Clause 4.4.3 of ISO 14001:2004 and OHSAS 18001:1999)
Company has established and is maintaining information in paper and/or electronic form to describe the core
elements of the management system and their interaction, and to provide direction to relevant documentation.
4.4.5 Document and data control
(Clause 4.4.5 of ISO 14001:2004 and OHSAS 18001:1999)
A documented procedure has been established and is being maintained for control of documents (QEP-4.2.3) to
ensure that
a) documents can be located,
b) documents are reviewed annually, revised as necessary and approved for adequacy by authorized personnel,
c) the current versions of relevant documents are available at all locations where operations essential to the
effective functioning of EMS are performed,
d) obsolete documents are promptly removed from all points of issue and points of use, or otherwise assured
against unintended use,
e) any obsolete documents retained for legal and/or knowledge preservation purposes are suitably identified.
It is also ensured that documents are legible, dated (with dates of revision/issue) and identifiable, maintained in an
orderly manner and retained for a specific period (till amended/revised/withdrawn). Responsibility and authority for
creation and modification of documents have been specified.
4.4.6 Operational control
(Clause 4.4.6 of ISO 14001:2004 and OHSAS 18001:1999)
Company has identified its operations and activities that are associated with the identified significant environmental
aspects in line with its policy, objectives and targets (see F-4.3.1). All activities and operations requiring compliance
to legal requirements have been identified as significant. Cleaning and plating operations; running of manufacturing
machines and DG sets; storage, handling and disposal of oil/lubricants and other chemicals; packing; generation of
metal dust; use of vehicles for transportation of incoming and finished products are some identified operations and
activities having significant impact on environment.
These operations and activities are carried out under specified conditions to control their impact on the environment
within acceptable limits of relevant legal requirements, and also to minimize any deviations from the environmental
policy and the objectives and targets. For this purpose a procedure has been documented (EP-4.4.6), and wherever
considered necessary, suitable work instructions have also been prepared for reference and use by concerned
personnel including contractors while carrying out their assigned jobs.
Company has also identified significant environmental aspects of goods and services and wherever required these
have been communicated to suppliers. These may include precautions to be taken in transporting goods to the
factory, packing and any MSDS prepared by the supplier organization for proper storage, handling, use including
any precautions to be taken by personnel and treatment in case any person has been exposed to their harmful effects.
4.4.7 Emergency preparedness and response
(Clause 4.4.7 of ISO 14001:2004 and OHSAS 18001: 1999)
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------------------------------------------------------------------------------------------------------------------------------------------Company has established and documented a procedure for identifying potential for and response to accidents and
emergency situations, and for preventing and mitigating the environmental impacts that may be associated with them
(EP-4.4.7). These procedures are reviewed and revised wherever necessary, in particular, after the occurrence of any
accident or emergency situation. Plans made under these procedures are periodically tested to evaluate their
effectiveness.
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4.5 Checking and preventive action
(Clause 4.5 of ISO 14001:2004 and OHSAS18001: 1999)
4.5.1 Performance monitoring and measurement
(Clause 4.5.1 of ISO 14001:2004 and OHSAS 18001:1999)
The organization has established systems needed for monitoring, measurement, analysis and improvement, to
demonstrate conformity of the product, to monitor and measure key characteristics of operations and activities
having significant impact on the environment, to ensure conformity of QEMS, and to continually improve its
effectiveness. Applicable methods have been determined including any statistical techniques.
Company has established suitable methods and criteria to monitor and, where applicable, measure QMS processes to
demonstrate their ability to achieve planned results. Managing Director reviews their effectiveness by evaluating
achievements during his planned reviews. Wherever performance is judged ‘needs improvement’ or specified targets
are not achieved, suitable actions are taken for improvement of concerned processes.
Characteristics of products are monitored and measured to verify that product requirements have been met (see
procedure QP-8.2.4). Such monitoring and measurement are carried out at appropriate stages of product realization
process, such as, incoming, in-process and final stages. Test and inspection records are maintained demonstrating
conformity to specified criteria including details of authorization of product release. In case any product is
authorized for release before satisfactory completion of planned arrangements, records of approval by relevant
authority and/or customer are maintained.
8.2.5 Monitoring and measurement of environmental impact
(Clause 4.5.1 of ISO 14001:2004)
Company has established and is maintaining documented procedure to monitor and measure, on a regular basis, the
key characteristics of its operations and activities that can have a significant impact on the environment (EP-4.5.1).
Procedure includes recording of information to track performance, relevant operational controls and conformance
with the company’s environmental objectives and targets.
Company has also established and is maintaining a documented procedure for periodically evaluating compliance
with relevant environmental legislation and regulations (EP-4.3.2).
Regular monitoring and analysis of ambient air and effluent water (after treatment) is done. Company utilizes
services of specialized laboratories for this purpose. In addition to this, UPPCB personnel also regularly visit the site
to collect samples for testing them in their own regional/central laboratories. Based on the results of this analysis,
company evaluates compliance with relevant environmental legislation and regulations.
4.5.2 Accidents, incidents, non-conformances and corrective and preventive actions
(Clause 4.5.2 of ISO 14001:2004 and OHSAS 18001:1999)
Company, under an established procedure (QP-8.5.2) takes appropriate action(s) to eliminate the cause of
nonconformities to prevent recurrence. The procedure defines responsibility and authority for handling and
investigation of accidents, incidents and non-conformances; taking action to mitigate any adverse effects/impacts
caused on environment, health & safety of personnel; for initiating and completing corrective and preventive actions;
and confirmation of the effectiveness of these actions. Any corrective and preventive action taken to eliminate the
cause of actual and potential non-conformances are appropriate to the magnitude of problems and commensurate
with the environmental impact and OH&S risk encountered. All these actions are reviewed through the risk
assessment process prior to implementation. Any changes in the documented procedures resulting from corrective
actions are implemented and recorded.
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------------------------------------------------------------------------------------------------------------------------------------------4.5.3 Records and records management
(Clause 4.5.3 of ISO 14001:2004 and OHSAS 18001:1999)
A documented procedure has been established for identification, maintenance and disposition of environmental and
health & safety records (QP-4.2.4). Records are appropriate to the system and to the organization, to demonstrate
conformance to the requirements of ISO 14001:2004 and OHSAS 18001:1999. Minimum retention time of records
has been specified.
4.5.4 Management system audit
(Clause 4.5.4 of ISO 14001:2004 and ISO OHSAS: 1999)
Company has established and is maintaining a documented procedure (QP-8.2.2) for conducting internal audits to
determine whether the E&HS Management System is effectively implemented and maintained, and confirms to ISO
14001:2004 and OHSAS 18001: 1999 requirements and to company’s established management system requirements.
The audit procedure covers audit scope, frequency and methodologies, as well as the responsibilities and
requirements for conducting audits and reporting results. Internal audit programme, including any schedule, is based
on the importance of the activity concerned and the results of previous audits relating to environmental, health &
safety. Presently company has outsourced internal audit process to QMS Management Services Pvt. Ltd., New Delhi.
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4.6 Management review
(Clause 4.6 of ISO 14001:2004 and OHSAS 18001:1999)
Company has established and is maintaining a procedure for management review (QP-5.6) of various management
systems implemented by the company. Authority and responsibility for review is with the Managing Partner. MR
assists him in the process of review. For this purpose, MR coordinates with all Process/Departmental Heads for
collection and analysis of data needed for an objective review to ensure continuing suitability, adequacy and
effectiveness of the system. This review includes assessing opportunities for improvement and the need for changes
to the system, including the environmental/health & safety policy & objectives and performance of system and its
processes. MR maintains records of these reviews.
Top management of the company has decided to align the review of all its Management Systems with preparation of
yearly performance reports based on ‘financial accounting year’ system. As per this decision, a detailed management
review of these systems will be carried out in April and October every year.
Inputs to this review necessarily include information on possible needs for changes to policies, objectives and other
requirements of management systems, internal/external audit results, feedback from customers and other interested
parties, status of C&PA, follow-up actions on previous reviews, changes that could affect the systems in view of
changing circumstances, and recommendations & commitment to continual improvement.
Output of this review results in any decisions and actions related to improvement of effectiveness of management
systems and its activities/processes, improvements related to environmental, health and safety performance.
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