Environmental Management System Environmental Management System (“EMS”) Table of Contents Environmental Management System (EMS) 2007 Edition A Guide for Environmental Management & Compliance -1- Environmental Management System ENVIRONMENTAL MANAGEMENT SYSTEM (“EMS”) TABLE OF CONTENTS PART I GENERAL 1. Company Profile 2. EMS Manual 3. Access to the EMS PART II ENVIRONMENTAL POLICY 1. Policy Statement 2. Goals (a) Procedures & Guidelines (b) Communication and Education (c) Waste Management (d) Chemical Control and Emergency Procedures (e) Environmental Initiatives (f) Environmental Audits PART III 1. 2. 3. 4. ELEMENTS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM Planning Implementation (a) Legal and Other Requirements of Environmental Best Practices (b) Structure and Responsibility (i) Board of Directors (ii) Executive and Senior Management (iii) Employees (c) Environmental Compliance and Management Training (d) Environmental Targets and Objectives (e) Implementation of Sustainable Practices (i) Conservation (ii) Recycling Checking and Correction/Internal Environmental Reporting Requirements (a) Annual Environmental Management & Compliance Review (b) Monthly Reports (c) Annual Green Report (d) Incident Reports (e) Document Control Management Review and Environmental Review (a) Environmental Advisory Committee (b) Environmental Review Team PART IV APPLICABLE ENVIRONMENTAL LAW PART V CONCLUSION APPENDIX A EMERGENCY PROCEDURES -2- Environmental Management System PART I 1. GENERAL COMPANY PROFILE MTS Allstream Inc. (“MTS Allstream”) is one of Canada’s leading national communication solutions providers, delivering innovative products and services through its Consumer Markets and Enterprise Solutions divisions. The Consumer Markets division serves residential and business customers in Manitoba with a full suite of wireline voice, high-speed Internet and data, next generation wireless, digital television, security and alarm monitoring services. Our Enterprise Solutions division provides national business customers with a world-class portfolio of IP-based connectivity, managed network services, and professional services. MTS Allstream's extensive national broadband fibre optic network spans more than 24,300 kilometres, and provides international connections through strategic partnerships and interconnection agreements with other international service providers. MTS Allstream is a subsidiary of Manitoba Telecom Service Inc. (“MTS”). While the Environmental Management System (“EMS”) is most relevant to MTS Allstream as the largest operating subsidiary of MTS, it also applies to other MTS subsidiaries including AAA Alarm Systems Ltd. and Delphi Solutions Corp. Collectively throughout this manual, the MTS group of companies will be referred to as MTS Allstream. MTS Allstream’s facilities are located throughout Canada, in both densely populated urban centres as well as in remote rural locations. MTS Allstream has an obligation to protect and preserve the environment wherever MTS Allstream carries on its business. Environmental Management is part of MTS Allstream’s approach to management, providing the framework to balance and integrate the economic interests of the company with the requirements of environmental protection. MTS Allstream’s Environmental Management System (“EMS”) reflects the vital importance that MTS Allstream places on the protection and preservation of the environment and conservation of natural resources. The objectives of the EMS are formulated based on international standards for environmental management systems as articulated by the International Standards Organization (“ISO”) and the Canadian Standards Association (“CSA”). This EMS Manual functions as both an operational manual and as a reference guide for environmental compliance and management for all employees of MTS Allstream. It is comprised of several components which specify the organizational structure, responsibilities, practices, procedures and resources used in implementing MTS Allstream’s Environmental Policy (the “Environmental Policy”) and complying with environmental law. The EMS emphasizes prevention, rather than detection and remediation of environmental problems by: • • • Identifying and ensuring compliance with applicable laws, regulations and industry standards; Identifying the significant environmental effects arising from the organization’s existing or proposed activities, products or services; Identifying the environmental effects which could arise from incidents, accidents and potential emergency situations; -3- Environmental Management System • • • Facilitating corrective action, process improvement, systems auditing, communication, training and review activities to ensure that the Environmental Policy is complied with and that it remains relevant; and Monitoring new and emerging environmental laws, regulations and standards; and Establishing and updating operational processes and procedures. This EMS Manual contains: • • • 2. The MTS Allstream Environmental Policy; The key elements of the MTS Allstream Environmental Management System; and References to the separate operational guides used by the relevant business owners to effectively manage the aspects of MTS Allstream’s operations which raise identified environmental issues. These are: the Environmental Matrix; Emergency Response Procedures; and, the Environmental Compliance Procedures. EMS MANUAL The predecessor to MTS Allstream’s current environmental management system, MTS’s Environmental Code of Practice, was developed in 1992. It contained a mission statement that expressed concern for the environment and supported the principles of sustainable development. MTS Allstream’s current Environmental Policy, which evolved from the Environmental Code of Practice, was officially approved by the Board of Commissioners (as it then was) in June,1995. The existing Environmental Policy was reviewed by the MTS Allstream Board of Directors in August, 2005 at which time the Board of Directors confirmed that the Environmental Policy would be applied to both the Enterprise Solutions and Consumer Markets divisions of MTS Allstream. The EMS requires the MTS Allstream Board of Directors to review the Environmental Policy once per year as part of their responsibility to ensure the Environmental Policy is up to date and that it reflects principles consistent with effective management of environmental issues. In addition to adopting and regularly reviewing the Environmental Policy, MTS Allstream has developed the EMS, as more fully described below, and has undertaken an environmental risk assessment to identify each of the environmental issues raised by its operations. This regular review process ensures that the EMS remains current and is responsive to change, as circumstances dictate. For each issue, MTS Allstream has developed specific operational procedures, which: • • • • • • Specify the means to achieve the goals of environmental protection and conservation of resources; Provide for ongoing assessment and re-assessment of environmental risks; Identify the applicable environmental law; Identify the persons responsible for compliance supervision and support of MTS Allstream Environment Programs; Identify operational practices and procedures of employees in managing the issue; Specify relevant employee training requirements; -4- Environmental Management System • • • • • Set the requirements for waste reduction, disposal, re-use and recycling; Set out emergency response procedures; Specify the internal reporting and documentation requirements; State the external regulatory reporting obligations; and State MTS Allstream’s audit and review requirements. The environmental aspects of MTS Allstream’s operations are set out in detail in MTS Allstream’s Environmental Matrix. The specific operational procedures to be used are set out in the Environmental Compliance Procedures. Procedures applicable to emergency situations are set out in the Emergency Response Procedures. The Environmental Policy, the statement of goals for and the elements of the EMS and the Environmental Matrix and Procedures, come together to make up the EMS. MTS Allstream’s “Environment Officer” holds the position of Manager, Environmental Programs, and is responsible for implementation of the EMS. This position is a full time position and reports to designated Executive/Senior Managers (Chief Human Resources Officer, Vice President Corporate Services) as to the status and adequacy of the EMS. As well, the Environment Officer coordinates and conducts the annual Environmental Management & Compliance Review. The incumbent in this position also makes recommendations regarding staff training on matters pertaining to the environment. -5- Environmental Management System 3. ACCESS TO THE EMS The EMS, including the Environmental Matrix, Emergency Response Procedures and Environmental Compliance Procedures, can be accessed through a number of internal, online tools available to employees. The EMS manual is available in hard copy upon request. Relevant business units, Executive/Senior Managers and employees are made aware of, familiarized with and kept up-to-date on the content of the EMS and associated requirements applicable to their individual business units and jobs in the company through various methods, including: • • • • • • • • New employee orientations New hire training Pre-determined and job specific training modules covering environmental management, health and safety Sign-off of job specific training modules by employees Recording completed training in MTS Allstream’s learning management system(s) A continuous cycle of revisiting and reviewing training modules Communication of environmental issues, incidents and/or requirements by the Environment Officer and Environmental Review Team New communication or training programs created to respond to new environmental laws, regulations and standards -6- Environmental Management System PART II 1. ENVIRONMENTAL POLICY POLICY STATEMENT MTS Allstream is committed to conducting its business in a manner, which reflects concern for the environment and supports the principles of sustainable development1. 2. GOALS Procedures & Guidelines • To develop and implement procedures and guidelines which will give effect to the Environmental Policy. • To comply with applicable laws and regulations regarding the environment and sustainable development. Communication and Education • To encourage and foster environmentally sensitive attitudes, knowledge and skills of employees through communication, education and community involvement. • To provide an annual report to the Executive and to the Board of Directors on environmental matters affecting MTS Allstream. • To provide reports to the Executive and to the Board of Directors on environmental matters affecting MTS Allstream whenever the Board has to make decisions. Waste Management • To set objectives and seek out measures within all operational groups which demonstrate commitment to sound environmental practices, which minimize the creation of waste and which maximize the principles of reduce, re-use and recycle within MTS Allstream. • To dispose of waste in an environmentally sound manner. Chemical Control and Emergency Procedures • To identify and inventory substances used in MTS Allstream and substitute, wherever practical and reasonable, environmentally friendly substances. • To develop and monitor environmental emergency procedures and train appropriate staff for emergency situations. Environmental Initiatives • To encourage innovative technology, products and services that contribute to the preservation of the environment or minimize negative environmental impacts. Environmental Audits • To monitor procedures for compliance with applicable environmental laws, regulations and the EMS. 1 For the purposes of the Environmental Policy, sustainable development is generally defined as “meeting the needs of the present without compromising the ability of future generations to meet their own needs” -7- Environmental Management System PART III ELEMENTS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM The EMS begins with the Environmental Policy. It employs the elements of planning, implementation, checking/correction and management review which may in turn result in changes to the Environmental Policy. The elements flow as follows: Environmental Policy Management Review FIGURE 1 MTS Allstream’s EMS Checking and Correction 3. Planning Implementation PLANNING MTS Allstream undertook a risk assessment process to identify and plan for key environmental aspects of the activities, products and services of MTS Allstream. This risk assessment resulted in the creation of MTS Allstream’s Environmental Matrix, Emergency Response Procedures and Environmental Compliance Procedures. The Environmental Matrix, Emergency Response Procedures and Environmental Compliance Procedures are maintained as separate operational guides associated with the EMS Manual and are maintained by the Environment Officer. They are reviewed and updated on a regular basis as part of the annual Environmental Management & Compliance Review or as required due to changes in environmental laws, regulations and standards or changes to MTS Allstream operations. 4. IMPLEMENTATION (a) Legal and Other Requirements of Environmental Best Practice Part IV of this EMS manual identifies the type of environmental laws which are generally applicable to MTS Allstream operations. The separate Environmental Procedures serve as a guide to specific legal and other environmental best practice requirements. However, each Executive and Senior Manager of MTS Allstream is required to be aware of new legal requirements, industry standards and changes in legal requirements and industry standards which are directly applicable to the -8- Environmental Management System environmental aspects of that Executive or Senior Manager’s group’s functions. Executive and Senior Managers are responsible to implement and monitor compliance with those changes. Each Executive and Senior Manager is required to assess the legal and other requirements associated with any new process or new product/service which is being planned. Non-compliance is not permitted and is to be reported to the Environment Officer immediately for corrective action. (b) Structure and Responsibility All employees are required to be familiar with the Environmental Policy, the elements of the EMS and those parts of the Environmental Matrix and Procedures which involve their particular job functions or groups. To effectively implement the EMS, MTS Allstream’s Board and Executive: • • • Provide resources essential to the implementation and control of the EMS; Appoint specific management representatives who have defined roles, responsibilities and authority for ensuring that the EMS requirements are established, implemented and maintained; and Require regular feedback on the performance of the EMS for review and as a basis for improvement of the EMS and for taking corrective measures as appropriate. Responsibilities of each level of authority within MTS Allstream are allocated as follows: (i) MTS Allstream Board of Directors The MTS Allstream Board of Directors is responsible for: • • • • Ensuring the development of the Environmental Policy and the EMS by the MTS Executive and ensuring the allocation of appropriate resources for their implementation; Monitoring corporate compliance with the Environmental Policy and EMS, as reported by the Executive, ensuring accountability by the Executive and ensuring that corrective action is taken when necessary; Ensuring that material environmental matters brought to the attention of the Board of Directors are addressed by the Executive in a satisfactory manner; and Ensuring that the Executive keeps the Board of Directors apprised of applicable and pending legal requirements and the standards of the telecommunications industry and those of other industries that deal with similar environmental risks. The annual Environmental Management & Compliance Review and individual reports of material incidents enable the Board to monitor the implementation of the Environmental Policy and compliance with the Policy and the EMS. -9- Environmental Management System (ii) Executive/Senior Management MTS Allstream’s Executive and Senior Management are responsible to be aware of MTS Allstream’s Environmental Policy and to ensure that it is properly implemented and communicated to all MTS Allstream employees. Designated Executive/Senior Managers are held accountable for operational compliance with the Environmental Policy and to ensure that applicable procedures and training are properly implemented. Delegation of responsibility for the implementation of the EMS is appropriate, provided that the designated Executive/Senior Managers are held accountable for the operational compliance with the EMS. Executive/Senior Managers will in turn delegate the responsibility for communication of the EMS within each MTS Allstream group of employees to operational managers. Executive/Senior Managers will direct operational managers to identify those areas where there are recognized environmental risks to ensure that employees are especially familiar with the contents of the EMS and the need for compliance. (iii) Other Employees It is the responsibility of all employees at MTS Allstream to be aware of and comply with the Environmental Policy and the EMS, and to comply with all instructions and training with respect to environmental management procedures. The EMS is implemented through MTS Allstream’s Environment Officer. The Environment Officer is responsible and accountable for organizational implementation of the EMS. This position is a full time position and reports to the designated Executive or Senior Manager on a regular basis as to the status and adequacy of the EMS, coordinates and conducts the annual Environmental Management & Compliance Review and reports material environmental incidents or issues to Executive and Senior Managers. This position also makes recommendations regarding training. (c) Environmental Compliance and Management Training MTS Allstream’s compliance and management training is the responsibility of MTS Allstream’s Environment Officer. Employees whose work may create an impact upon the environment or who perform work governed by environmental legislation are provided with appropriate training, as recommended by MTS Allstream’s Environment Officer. Training modules are developed by or through MTS Allstream’s Environment Officer for all environmental procedures. These training - 10 - Environmental Management System modules make employees aware of their roles and responsibilities in achieving conformance with the environmental policies and procedures, including emergency preparedness. Documentation of training is consistent with other documented health and safety training. Three levels of training are implemented to educate and track employee awareness of environmental issues. • • • (d) General awareness Knowledge of the EMS manual, including spill and reporting procedures. Operational Knowledge of the EMS manual, spill and reporting procedures, forms and procedures specific to operations. Critical Knowledge of the EMS manual, spill and reporting procedures, forms and procedures specific to operations, including spill clean-up operations, repair procedures and government reporting. Environmental Targets and Objectives Consistent with effective environmental management and the Environmental Policy, MTS Allstream sets environmental targets which are consistent with the principles of sustainable development, the Environmental Policy and this EMS. These targets lead to the development of objectives for environmental performance, including: • • • • • • Regulatory compliance; Environmental protection and impact reduction; Pollution prevention and waste reduction; Emergency preparedness; Work procedures and practices updates; and Continuous improvement The setting and ultimate achievement of environmental targets and objectives ensures regulatory compliance and effective environmental management as MTS Allstream responds to new environmental legislation and standards. The Environment Officer assists in setting and reviewing environmental targets and objectives. Environmental targets and objectives are reported in an annual report (called the MTS Allstream Green Report) available to the public and shareholders. - 11 - Environmental Management System (e) Implementation of Sustainable Practices (i) Conservation Conservation is a key element of the EMS. Conservation strategies and successes are reported in the annual MTS Allstream Green Report. Initiatives for environmental conservation within MTS Allstream include: • • • • • (ii) Energy consumption; Water usage; Vehicle and fuel dependence; Appropriate purchasing practices; and Waste reduction Recycling Many initiatives for recycling are active within MTS Allstream. These initiatives are tracked, evaluated and reported in the annual MTS Allstream Green Report. Initiatives for environmental recycling within MTS Allstream include: • • • • • • • Paper; Cardboard; Wire; Nickel cadmium batteries; Automotive fluids Metal; and Printer cartridges - 12 - Environmental Management System 3. CHECKING AND CORRECTION – INTERNAL ENVIRONMENTAL REPORTING REQUIREMENTS Communication within MTS Allstream is required in order to make senior managers of MTS Allstream, its Executive and Board of Directors aware of environmental performance. MTS Allstream’s internal environmental reporting is required to include: • • • • • • • Environmental achievements; Specific examples of non-compliance and deficiencies and corrective actions taken; Strategies or situations for corrective actions; Monitoring and measurement of the corrective actions; Special reports to the Executive and to the Board of Directors on environmental matters/issues affecting MTS Allstream whenever a decision is required from those management levels; Special reports to the Executive and to the Board of Directors on material environmental incidents and corrective actions taken, as well as recommendations and communication processes to eliminate repeat incidents; and Dissemination of environmental reports and recommendations to all affected managers and employees. a) Annual Environmental Management & Compliance Review Once per year, MTS Allstream’s Environment Officer oversees the Environmental Management & Compliance Review of MTS Allstream sites, premises, procedures, communication, training and the EMS itself. The resulting Annual Environmental Management & Compliance Review Report is prepared and forwarded to the Executive Committee, Audit Committee and Board of Directors during the first quarter of the next ensuing year. This report documents the findings and recommendations of the Annual Environmental Management & Compliance Review including the results of the annual audit against mandatory compliance items as set out in MTS Allstream’s Environmental Matrix. This report provides a structured and prioritized snapshot of compliance with environmental legislation, regulations and applicable standards, and sets out the associated corrective actions taken by MTS Allstream. It establishes whether MTS Allstream is complying with the Environmental Policy and the requirements of the EMS. b) Quarterly and Monthly Environmental Reports Quarterly reports on environmental matters and performance are provided to the Executive and Audit Committee. A similar monthly report is provided to divisional senior management on a monthly basis. These reports address: • • • • Government reporting; Environmental success stories; Incidents and spill releases; and Environmental initiatives, targets and objectives. - 13 - Environmental Management System (c) MTS Allstream Green Report A Green Report will be prepared annually. This report is prepared to highlight MTS Allstream’s initiatives and achievements in a format suitable for distribution to the public, customers and shareholders. This public document covers discretionary sustainable development or “green” efforts by MTS Allstream. This report demonstrates MTS Allstream’s commitment to the environment and the principles of sustainable development including: • • • • • • Balance and integration of environmental and economic decisions; Shared responsibility; Prevention; Conservation; Waste minimization; and Technological innovation The Green Report is distributed to the Executive Committee for information before it is made available to the public, customers or shareholders. (d) Incident Reporting All environmental incidents which require reporting to federal or provincial regulatory bodies are reported to impacted divisional Senior and Executive Management as detailed in the Emergency Response Procedures. (d) Document Control Municipal By-law Permits • Land drainage discharge or other required permits are applied for and retained by the Environment Officer Internal Environment Reports • The Environment Officer retains all internal environment reports addressed to divisional senior management, the Executive, the Audit Committee and the Board of Directors. External Reports • The MTS Allstream Green Report is posted on the corporate web site available to the public, customers and shareholders. Environment Permits - 14 - Environmental Management System • • • • For new construction, modification, decommissioning and upgrades of fuel storage tanks, the MTS Allstream Property Services group is responsible for application and retention of permits and construction records. For new service installations on crown property, the regional engineering groups are responsible to make applications for appropriate permits and retain those permits for the duration of the project. For installations in National Parks, the regional engineering group is responsible for completing the procedures for environmental assessment required and documented in the Environmental Compliance Procedures. The Environment Officer is responsible for the application, maintenance and retention of pesticide records and preparation of an annual report to provincial conservation agencies where required. Licenses • • • • The Environment Officer is responsible for monthly inspection reports for the PCB storage facilities maintained by MTS Allstream. As required by federal and provincial environment regulations, reports are forwarded to Environment Canada and provincial regulatory bodies. The Environment Officer retains all related records and reports. Consistent with transportation of dangerous goods regulations, sites where hazardous materials are generated require a disposal option. The Environment Officer classifies and makes application to provincial environment agencies for the appropriate Hazardous Material Generator License where required. Required licenses, transportation manifests and disposal documentation are retained with the Environment Officer. Consistent with transportation of dangerous goods regulations, automotive waste oils and lubricants generated at MTS Allstream’s facilities are the responsibility of the Corporate Services’ automotive group. Where required, the automotive group is responsible for contracting a certified waste handler to remove and dispose of such oils and lubricants and to maintain the transfer manifests for the period of time required by regulations . Consistent with transportation of dangerous goods regulations, waste oils, lubricants and hazardous materials generated from operations by MTS Allstream’s Corporate Services (Investment Recovery, Property Services), Network Services, Network Operations, Customer Operations and Service Delivery are coordinated by the Environment Officer. The Environment Officer classifies and makes application to provincial conservation agencies for hazardous material generator licenses where required. The licenses, transportation manifests and disposal documentation are retained by the Environment Officer. - 15 - Environmental Management System Emergency Reporting • • MTS Allstream’s Emergency Response Procedures stipulate that the quantity of the chemical released to the environment, which constitutes a reportable spill or release, is to be documented. When quantities of the product exceed the reportable quantity, a report to environment agencies may be required and is submitted by MTS Allstream’s Environment Officer. The Environment Officer is responsible for providing internal reports and advising environment agencies on the clean-up progress if required. The Environment Officer retains such reports. For chemical releases of freon and halon, MTS Allstream’s Corporate Services (Property Services) is responsible for documentation and reporting to ozone protection agencies where required. All records, licenses and documentation are retained by Corporate Services and records of releases are forwarded to the Environment Officer for inclusion in the quarterly and monthly reports to divisional senior management, the Executive or the Audit Committee. - 16 - Environmental Management System 4. MANAGEMENT REVIEW AND ENVIRONMENTAL REVIEWS The annual Environmental Management & Compliance Review is intended to determine compliance with applicable environmental laws, regulations, licences, approvals and registrations, applicable non-regulatory standards and with the EMS. Information on the results of the review is provided to relevant divisional senior management, the Executive, Audit Committee and Board of Directors through the Annual Environmental Management & Compliance Review Report. (a) Environmental Advisory Committee This committee is comprised of senior or middle managers representing appropriate operational groups within MTS Allstream, including: • • • • • • • Law Human Resources Corporate Services Network Operations Network Planning and Engineering or Network Assurance Corporate Insurance Audit The responsibilities of this committee include: • • • • (b) Maintaining accountability for operational compliance to the MTS Allstream Environmental Policy and procedures relating to applicable environmental law; Acting in an advisory role to the Environmental Review Team (see below) for the development and maintenance of the Environmental Procedures; Assisting in the identification of areas of environmental risk that have not previously been identified; and Reviewing and endorsing the recommendations and findings of the Environmental Review Team Environmental Review Team MTS Allstream’s Environmental Review Team is comprised of representatives from diverse operations within MTS Allstream who are directly involved in environmental matters. This typically includes: • • • Corporate Services Network Planning and Engineering, Network Assurance, Network Operations, Customer Operations and/or Service Delivery Human Resources Led by the Environment Officer, the team determines the scope of the annual Environmental Management and Compliance Review as well as incident specific reviews, based on the environmental importance of the - 17 - Environmental Management System activity or operation concerned. The team reports on the scope of the annual Environmental Management and Compliance Review to the Environmental Advisory Committee, which then approves or modifies the scope as it sees necessary. Overall, the Environmental Advisory Committee approves the scope of the annual review and the Environmental Review Team completes the review. Following the completion of the annual review, the Environmental Review Team then reports the results to the Environmental Advisory Committee in the form of the annual Environmental Management & Compliance Review Report. The Environmental Management & Compliance Review Report is approved by the Environmental Advisory Committee. The Environmental Review Team monitors procedures for compliance with environmental laws, regulations, standards, licences, approvals and registrations and with the EMS. The Environmental Review Team evaluates on an ongoing basis the effectiveness of steps taken by MTS Allstream to achieve the goals set out in the Environmental Policy. In addition, the duties of Environmental Review Team include: • • • • Monitoring the EMS and procedures; Identifying environmental risks and collaborating with operational groups to minimize risk; Updating the EMS and procedures to respond to new laws, regulations and standards as well as new processes, products or services in MTS operational groups; and, Corporate reporting The following illustrates the flow of the elements of MTS’s EMS, in the context of these committees/teams. Environmental Policy Environmental Review Team Management Review Environmental Advisory Committee Environmental Review Team Planning Environmental Advisory Committee Environmental Review Team Checking and Correction Environmental Review Team Implementation Environmental Advisory Committee - 18 - Environmental Management System PART IV APPLICABLE ENVIRONMENTAL LAW There are numerous federal, provincial and municipal environmental laws and regulations which are applicable to MTS Allstream, and with which compliance is mandatory as the company carries out its day-to-day business. The most relevant laws and regulations address the following: • • • • • • • • • • • Environmental protection including control of toxic substances Fisheries protection Hazardous products Handling and transportation of dangerous good Above ground and underground fuel storage systems Ozone depleting substances Public health Waste reduction and prevention Contaminated sites remediation Land drainage discharge Unnecessary and harmful noise On behalf of MTS Allstream, the Environmental Officer and Environmental Review Team monitor and identify new and emerging laws, regulations and standards. This ensures that the EMS and associated operational guides remain current, and that impacted business units/employees receive required communication and training. This continuous identification of laws, regulations and standards is achieved through established practices, including: • • • • Relationships and regular dialogue with environmental regulators Participating in industry and environmental associations Monitoring government legislative registries and communication vehicles Participating in government advisory groups and roundtables - 19 - Environmental Management System PART V CONCLUSION As a guide for environmental compliance and management, the EMS helps MTS Allstream meet or exceed environmental regulatory requirements. The EMS also plays an important role in creating a culture of environmental innovation and responsibility. The MTS Allstream EMS needs to continually evolve in order to remain aligned with the corporate structure, the fast-paced changes in the telecommunications industry, and evolving environmental requirements and challenges. This continues to be well served by regular reviews of the EMS and implementation of the recommendations flowing from the reviews. - 20 - Environmental Management System APPENDIX “A” EMERGENCY PROCEDURES MTS Allstream needs to establish, implement and maintain procedures to identify potential emergency situations and how to attend to them as part of the EMS. Consistent with this standard, emergency procedures are included as part of the EMS. Environment Spills and Emergency Incidents Any release of a regulated chemical to the air, onto the soil, or into water must be reported. Chemical products must be handled in a manner to reduce or eliminate the chance of an accidental release to the environment. The primary objective is to ensure personal safety and minimize the spread of the chemical. Applicable Laws • Dangerous Goods Handling and Transportation Act • Environmental Accident Reporting Regulation MTS Allstream References Environmental Procedures: 1. ENP 101, ENP 102, ENP 103, ENP 104, ENP 105, ENP 106, ENP 110, ENP 111, ENP 114, ENP 118, ENP 120, ENP 121, ENP 122. Responsibilities It is the responsibility of supervisory or people managers to ensure that employees handle all chemicals in a safe manner. Through WHMIS training, the manager can identify employees who require additional training in environmental response. It is the responsibility of the employee to report any activity or problem with equipment which may contaminate the environment to their immediate supervisor. Drums, tanks and containers containing chemicals must be labeled and stored in an area where the condition of the drums can be inspected regularly. The MTS Allstream Environment Officer and Environmental Health and Safety Specialist is responsible for providing chemical awareness training (WHMIS) for all employees. It is the responsibility of supervisory managers to identify training needs. Emergency Response The following immediate action should be taken: • Ensure personal safety • Contain spill to as small an area as possible • Block sewers and drains • Eliminate sources of ignition • If a fire is present evacuate and call the local Fire Department. - 21 - Environmental Management System Relevant Chemicals Listed below are the chemicals used at MTS Allstream which are most likely to cause an environment incident. Releases greater then the listed quantities must be reported to the appropriate government body. Class/Division Product Name Class 2 Non Flammable Gas Including: • Freon • Halon • Nitrogen • Carbon Dioxide Including • Propane • Acetylene Class 2 Flammable Gas Class 3 Flammable Liquids Class 8 Corrosive materials Class 9 Environmental Classification Including • Gasoline • Diesel Fuel • Hydraulic Oil Including • Battery Acids and gel cells Asbestos/PCB Transportation of Dangerous Goods Any quantity that could pose a danger to public safety or any sustained release of 10 minutes or more Manitoba Limit Any quantity that could pose a danger to public safety or any sustained release of 10 minutes or more Greater than 200L Any release from a container with a capacity of more than 100L Greater than 100L Greater than 5kg or 5L Greater than 5kg or 5L Greater then 5kg or 5L Greater than 500g of PCB Any release from a container with a capacity of more than 100L Note: Manitoba Conservation has implemented slightly different reporting quantities for some classes of Dangerous Goods. If in doubt, call your MTS Allstream Environmental Department for reporting procedures. Canadian Emergency Response Reporting Requirements When dangerous goods are spilled in the environment or leaked in a company vehicle or pose a health and safety risk to the public, the driver must immediately notify: • • • The local police and/or other local authority first (see Emergency Contact Numbers) and then; His/her employer The consignor of the dangerous goods and the owner or lessee of the vehicle if applicable - 22 - Environmental Management System Environmental Reporting information Requirements • The location and time of the incident; • The name and telephone number of the person reporting the incident; • A brief description of the circumstances and status at the time of the report; • The identity and quantity of the contaminants; • The name of the owner of the contaminants; • The action that the person making the report has taken or intends to take with respect to the incident; and • Other relevant information required by the person to whom the report is made. Emergency Contacts ALBERTA BRITISH COLUMBIA 800-272-9600 and local police 800-663-3546 and local police MANITOBA NEW BRUNSWICK NEWFOUNDLAND AND LABRADOR NORTH WEST TERRITORIES NOVA SCOTIA ONTARIO NUNAVUT PRINCE EDWARD ISLAND QUEBEC SASKATCHEWAN YUKON 204-945-4888 and local police 800-565-1633 or local police 709-772-2083 and local police 867-920-8130 800-565-1633 or 902-426-6030 or local police Local police 867-920-8130 and local police 800-565-1633 or local police Local police 800-667-7525 or local police 867-667-7244 The Transport Dangerous Goods Directorate of Transport Canada operates CANUTEC (Canadian Transport Emergency Centre). CANUTEC provides a national bilingual advisory service and is staffed by professional chemists experienced and trained in interpreting technical information and providing emergency response advise. In an emergency, CANUTEC may be called collect at 613-996-6666 (24 hours). In a nonemergency situation, the 24 hour information line is 613-992-4624. - 23 - Environmental Management System MTS Allstream Reporting Requirements Enterprise Solutions Reporting Procedure: 1. Immediate supervisor/field operations manager to report the incident to: 2. Provincial Environment Contact 3. Property Services/Access Management 4. Environmental Health and Safety 5. Human Resources Sr. Manager Consumer Markets Reporting Procedure: 1. Immediate Supervisor 2. Environment Officer 3. Manitoba Conservation 4. Property Services 5. WOC 941-6521 944-4888 941-4440 257-2511 In the case of a spill or leak, where quantities require Provincial or Federal reporting, The Environment Officer or delegate will prepare a “Fact Sheet” on the spill, clean up, and actions taken. Enterprise Solutions Internal Reporting Procedure: A report must be prepared on the spill, clean up and actions taken. This report is to be compiled and updated within 48 hours and distributed by internal electronic mail to the following people or departments. The departments below will also be notified upon clean up and closure of the spill / leak report. • • • • • • • • Immediate supervisor of the employee reporting the spill Environmental H&S Specialist Finance / Risk Management/ Corporate Communications Legal Department Human Resources Property Services Network Engineering Customer Operations (Director & VP) Consumer Markets Internal Reporting Procedure: The Fact Sheet is to be compiled and updated within 48 hours and distributed by internal electronic mail to: • • • • • • • • • - 24 - Immediate supervisor of the employee reporting the spill Chief Financial Officer Chief Human Resources Officer Director Property Services Corporate Emergency Planning Manager Law Department Corporate Communications VP Operations Consumer Markets Manager Corporate Insurance Environmental Management System Material Safety Data Sheets (MSDS) Material Safety Data Sheets are retained for all identified chemicals used at MTS Allstream. In the case of a spill or release, relevantl information can be obtained directly from the OPS web site. Enterprise Solutions The latest version of the MSDS can be found on mysource at • http://mysource/content/1,,15812656-10424,00.html • National Reporting Centre (NOC) 257-2507 or you can email any questions to Environment, Health & Safety/Environnement, Santé et Sécurité. Consumer Markets The latest version of the MSDS can be found on the OBSWEb at • http://opsweb/safety/ Or • iNFOZONE> Inside MTS> Wellness> Workplace Hazardous Material Information System • Manitoba Reporting Centre (WOC) 257-2511 or you can email any questions to the Manager Environment Programs - 25 -