I SPECIALIZED ECONOMIC ZONES CODE OF PRACTICE GUIDELINES ON EHS AUDIT AND INSPECTION Zones Corp COP-EHS11 APPROVED BY: DATE: CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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REVISION HISTORY
Rev. No. Issue Date Revised Section Revision Description 0 New Documents
Copyright
The copyright and all other rights of a like nature in this document are vested in Higher Corporation for Specialized Economic Zones (ZonesCorp), Abu Dhabi, United Arab Emirates. This document is issued as part of the Industrial Sector EHS Regulatory Framework and as guidance to Industrial Sector within the Abu Dhabi Emirates. Any party within Industrial Sector may give copies of the entire EHS Documents or selected parts thereof to their contractors/consultants for implementation of EHS Management Standards. Such copies should carry a statement that they are reproduced by permission of ZonesCorp and an explanatory note on the manner in which the document is to be used.
Disclaimer
No liability whatsoever in contract, tort or otherwise is accepted by ZonesCorp or any party whether or not involved in the preparation of the EHS Management System Documents for any consequences whatsoever resulting directly or indirectly from reliance on or from the use of the ZonesCorp EHS Documents or for any error or omission therein even if such error or omission is caused by a failure to exercise reasonable care.
All administrative queries should be directed to the ZonesCorp EHSMS Administrator HSE Division
Higher Corporation for Specialized Economic Zones P.O. Box: 36000, Abu Dhabi, United Arab Emirates. Telephone: (9712) 5073358 Fax: (9712) 5073564 Internet site: www.zonescorp.com E-mail: hse@zonescorp.com
CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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TABLE OF CONTENTS 1. PURPOSE 4 2. SCOPE 5 3. DEFINITIONS 6 4. EXISTING APPLICABLE LAWS 9 5 RESPONSIBILITIES 11 6. EHS AUDITS 13 7 AUDIT CATEGORIES 14 8 EHS MANAGEMENT SYSTEM AUDITING 15 9 EHS AUDIT TEAM 16 10 KEY STEPS FOR EHS AUDIT 18 11 SCOPE OF EHS AUDITING 19 12 EHS AUDIT PLANNING 21 13 MANAGING THE AUDIT PROGRAM 22 14 CONDUCTING THE AUDIT 24 15 EHS MANAGEMENT SYSTEM AUDIT COMPLIANCE SCORE 26 16 DOCUMENTING THE AUDIT FINDINGS 27 17 AUDIT REPORTS 29 18 EHS INSPECTIONS 30 19 EHS INSPECTION PROGRAM 31 20 REFERENCES 35 21 APPENDIX 1 INDUSTRIAL SECTOR EHS COMMITMENT & POLICY 36 22 APPENDIX 2 LIST OF EHS CODES OF PRACTICE 37 23 APPENDIX 3 EHS MS AUDIT BASIC REQUIREMENTS 39 24 APPENDIX 4: EHS AUDIT CONCERNS 58 25 EHS AUDIT CHECKLIST RECOMMENDED FORMAT 62 26 BUILDING EHS AUDIT CHECKLIST RECOMMENDED FORMAT 64 27 EHS INSPECTION CHECKLIST RECOMMENDED FORMAT 70 CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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1. PURPOSE This document establishes the ZonesCorp Regulatory Requirements and provides guidelines to establish the basic framework and general requirements for conducting EHS Audits & Inspections. Industrial Sector Entities may develop their own procedure appropriate to their organisations activities to meet or exceed the requirements stipulated in this Code of Practice. Environment Agency Abu Dhabi (EAD) being the Competent Authority of EHS Management within Abu Dhabi Emirate has designated Higher Corporation for Specialized Economic Zones ZonesCorp as the EHS Regulatory Authority for the Industrial Sector within Abu Dhabi Emirate. ZonesCorp in its Regulatory Role is the nodal agency for the Entities within Industrial Sector while interacting with concerned Govt. Agencies (EAD, Civil Defense etc.) for fulfilling the applicable regulatory requirements like EHS Permitting etc. The Higher Corporation for Specialized Economic Zones ZonesCorp being the EHS Regulatory Authority for the Industrial Sector in the Emirate of Abu Dhabi, has established the Environmental, Health & Safety Regulatory Framework Codes of Practice to communicate the requirements of EHS management as a key factor in successful business development to all industries within the Emirate of Abu Dhabi. ZonesCorp considers the establishment of priorities, programmes and practices as vital for integrating good environmental, health & safety management into all entities business. The Industrial Sector EHS Regulatory Framework has been established in line with the requirements of UAE EHS Laws, Regulations and the Abu Dhabi (EAD) EHS Management System Framework Documents for the Industrial Sector. The system is also aligned with other international standards like ISO14001, OHSAS18001 and BS8800 for Occupational Health. The document is not addressing the requirements for monitoring for Integrity Assurance of Equipment / Systems / Structures which are separately covered in ZonesCorp Code of Practice on Integrity Assurance & Management (ZC- CoP-EHS10). Any section / clause of this document shall therefore not substitute any requirement of the above referred CoP. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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2. SCOPE The requirements outlined in this document are applicable to EHS Management System Audit, EHS Audit & Inspection activities carried out in all Operating Facilities, Buildings and Construction Worksites. This document is applicable to all Entities within Industrial Sector in Abu Dhabi Emirate. The Industrial Sector includes but is not limited to Entities in Abu Dhabi Industrial Cities (ICADs), Al-Ain Industrial Cities (AAICs), Western Region Industrial Complex, Mussafah Industrial Area and Workers Facilities (Labour Camps) for Industrial Sector within Abu Dhabi Emirate. Wherever possible, and rather than providing detail within this document, reference is made to other, more detailed documents that have been provided in the ZonesCorp EHS Management System. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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3. DEFINITIONS 3.1 Asset: Any person, environment, facility, material, information, business reputation or activity that has a positive value to an owner. 3.2 Audit: An audit is a systematic, independent, and documented process for obtaining evidence and evaluating it objectively to determine the extent to which the audit criteria are fulfilled (ISO 19011:2003). Qualified professionals with relevant auditing experience can conduct most audits and where possible, independent external auditors should also be used. 3.3 EAD: Environmental Agency Abu Dhabi. Competent Authority for EHS Management System in Emirate of Abu Dhabi 3.4 EEPP: Abu Dhabi Emirate Environment Protection Policy 3.5 EHS: Environment Health & Safety 3.6 EHS MS: EHS Management System. 3.7 EHS Audit 3.7.1 EHS audit is a systematic review of operations and practices to ensure that relevant requirements are met. These are planned evaluations on performance and compliance. 3.7.2 It is a structured, methodical assessment and evaluation of how workplace activities affect Safety Health, and Environment. It reveals how an organization is doing in maintaining a safe and healthy environment. 3.7.3 The basic goal of EHS audit is to verify that EHS activities comply with organization policies and regulations. 3.7.4 This also covers the EHS-Management System Audit - An audit to verify compliance with ZonesCorp and/or Tenant(s) EHS Management System requirements and expectations 3.7.5 An independent, systematic and documented process of objectively obtaining and evaluating verifiable evidence to determine that business controls: a. Are complete and consistent. b. Are (cost) effective and efficient. c. Safeguard organizations resources and promote their effective use. d. Provide, and protect the integrity of, required records and information. e. Allow for compliance with policies, chosen standards, laws and regulations 3.8 EHS Audit Team 3.8.1 Team structure shall be linked with the location/facility to be audited. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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3.8.2 Facility / Location specific Audit Team shall be nominated by concerned Management in consultation with HSE Manager or equivalent. 3.8.3 In general audit shall comprise of members at least one each from HSE, Operations, Maintenance, Engineering & Projects, Divisions/Departments in Buildings, Contractors Representatives (for construction sites) 3.8.4 HSE representative shall be audit coordinator. 3.8.5 Team leader shall at least be Department Manger / Section Head nominated on rotation basis. Team leader shall not be responsible for the area to be audited 3.9 EHS Audit Reports: Report based upon the audit findings (checklist) normally presented in a format indicating the salient observations, actions required, responsibilities, recommendation and target dates. 3.10 EHS Inspections 3.10.1 EHS Inspections are the walk-through of the physical areas of the facility, with the goal of identifying EHS hazards & concerns. 3.10.2 A scheduled, structured examination of a worksite with a specific focus on physical conditions & working practices in addition to normal supervisory duties 3.10.3 The surveys shall be conducted on a regular frequency by the inspection team including the representative from the area to be inspected. 3.10.4 Inspection team members are to note problem areas, write reports, present the report to concerned, offer recommendations, set completion dates and follow-up to ensure action has taken place. 3.10.5 Inspections should concentrate on working conditions, working practices, housekeeping, process controls, hazard exposure, and other similar concerns. 3.11 Emergency: A sudden and usually unforeseen event that requires immediate action to minimize its consequence 3.12 Entity: Facilities within Industrial Sector including Industrial, Commercial, Residential and Welfare 3.13 Hazard: Any substance, physical effect, or condition with potential to harm people, property or the environment or affect on the company reputation 3.14 Incident: An uncontrolled / unplanned/undesired / uncontrolled event that results in undesirable consequences to the personnel (injuries/illness) and / or to the assets (damage/loss) or to the neighbouring community and/or to the environment. The term Incident is synonymous with Accident wherever used in ZonesCorp EHS Management Framework 3.15 Industrial Sector: Industrial Sector within Abu Dhabi Emirate includes but not limited to Entities (Industrial Units etc.) in Industrial Cities developed by ZonesCorp, Industrial Areas like Mussafah, Mafraq, etc. and Workers CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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Facilities (Labour Camps) for Industrial Sector 3.16 Non-Compliance: Failure to meet the EHS Management System requirements. Non-compliance may be identified by monitoring activities, adverse trends in performance indicators, non-completion of EHS plans, failure to meet ZonesCorp/EAD requirements and expectations, meet targets, incident investigations and audits. 3.17 Shall: Signifies mandatory requirements 3.18 Should: Signifies recommended/optional requirements 3.19 SOP: Safe Operating Procedure 3.20 Tenant: The Project Proponent/Lease Holder/Concession Agreement Holder/ Owner/Operator of an Entity within the Industrial Sector in Abu Dhabi Emirate CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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4. EXISTING APPLICABLE LAWS All Tenants shall ensure that their operations comply with all relevant UAE and Abu Dhabi Environmental, Health and Safety laws and regulations. Environmental, Health and Safety regulations in the UAE are gradually being implemented. This Code of Practice has been developed to ensure compliance to or exceed the requirements of all relevant legislative statutes and regulations, specifically including but not limited to: 4.1 Federal EHS Laws and Codes including UAE Standards Industrial Safety & Health Regulations (Emirates Authority for Standardization & Metrology) 4.2 Local Law No. ( ) of 2008 concerning Environment Health & Safety Management System in Abu Dhabi Emirate 4.3 Local Law No. 16 of 2005; Article 14 Establishment or Individual is prohibited to carry out any activity that could adversely affect the lives of human beings and the safety of the environment before obtaining a license from the Agency. 4.4 Local Law No. 21 of 2005 on the Waste Management in Emirate of Abu Dhabi 4.5 Local Law No. 23 of 2005 and the Executive Regulations Regarding the Health Insurance Scheme for the Emirate of Abu Dhabi 4.6 Federal Law No. 1 of 2002 Regarding Organisation & Monitoring the Use of Radiation Resources and Protection 4.7 Federal Law No. 8 of 1980. The Labor Law (as amended 1986) 4.8 Federal Law No. 23 of 1999 Marine Bio-Resources in the UAE 4.9 Federal Law No. 24 of 1999 for the Protection & Development of the Environment 4.10 Regulations / Executive Orders made under the Federal Environment Law a. Federal Bylaw; Protection of Air from Pollution (Ministerial Order # 12 of 2006) b. Federal Bylaw; System for Protected Area Ministerial Decree No. 37 of 2001 concerning the approval of the Executive Orders for Law No. 24. It includes the following Regulations: a. Environmental Impact assessment of Projects 2001 b. Assessment of Environmental Effects of Installations 2001 c. Protection of the Marine Environment 2001 d. Handling Hazardous Materials, Hazardous Wastes & Medical Wastes 2001 e. Pesticides, Agricultural Additives and Fertilizers 2001 CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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4.11 Ministerial Decrees & Decisions: a. Decree No. 50/2003 Basic Regulating Rules for Ionizing Radiation Protection b. Decree No. 55/2004 Basic Regulations for Protection against Ionizing Radiation. c. Decree No. 56/2004 Basic Regulations for Safe Transport of Radioactive Materials d. Decree No. 57/2004 Basic Regulations for Radioactive Waste Management e. Decree No. 214/2004 on Use of Sludge on Land f. Ministerial Order No.32/1982 on the Determination of Preventative Methods and Measures for the Protection of Labor from Risks at Work 4.12 Abu Dhabi Emirate Environment Protection Policies (EEPPs) a. Part 1 Air Quality b. Part 2 Water Quality c. Part 3 Land Quality d. Part 4 Noise e. Part 5 Waste f. Part 6 Hazardous Substances g. Part 7 Occupational and Environmental Health & Safety h. Part 8 Biodiversity and Conservation 4.13 Abu Dhabi Emirate Environment Protection Policies Standards a. Part 1 Air Quality Standard b. Part 2 Water Quality Standard c. Part 3 Land Quality Standard d. Part 4 Noise Quality Standard 4.14 Abu Dhabi Emirate EHS Management System Codes of Practices a. Self Regulation b. Roles & Responsibilities c. Risk Management d. Audits & Inspection e. Emergency Management f. Monitoring and Reporting g. Management Reviews 4.15 EAD Regulations on Hazardous Material & Waste Permit 4.16 Industrial Safety and Health Regulations Occupational Health and Environmental Control SSUAE No. 209 / 1995. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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5. RESPONSIBILITIES 5.1 Competent Authority The Competent Authority (EAD) in cooperation with the Regulatory Authority (ZonesCorp) shall approve the types of entities (targeted entities) that should develop & implement an EHSMS in accordance with the Abu Dhabi Emirate EHS Law. The Competent Authority (EAD) shall set mechanisms for: Reviewing and approving EHSMS developed by Entities to ensure compliance with the requirements of the EHSMS at Abu Dhabi Emirate level. Auditing the EHSMS implemented by different entities. The Competent Authority (EAD) shall promote the importance of implementing the EHSMS. The Competent Authority (EAD) shall be responsible for reporting to the Executive Council the performance of the EHSMS at Abu Dhabi Emirate level. 5.2 Regulatory Authority The Regulatory Authority (ZonesCorp) in cooperation with the Competent Authority (EAD) shall identify the types of entities that should develop & implement an EHSMS in accordance with the Abu Dhabi Emirate EHS Law. The Regulatory Authority (ZonesCorp) in cooperation with the Competent Authority (EAD) shall implement mechanisms for: Reviewing and approving EHSMS developed by entities in compliance to the requirements of the Abu Dhabi Emirate EHSMS. Auditing the EHSMS implemented by different entities. Receiving EHSMS Performance from Industrial Sector Entities Compilation and reporting EHSMS Performance of Industrial Sector to the Competent Authority (EAD) The Regulatory Authority (ZonesCorp) in cooperation with the Competent Authority (EAD) shall promote the importance of implementing the EHSMS. 5.3 Entities 5.3.1 Entities shall provide and maintain a safe environment for workers, avoid any risk to human health, avoid adverse impact to environment and prevent environmental pollution. 5.3.2 Entities shall develop and implement an EHSMS within their areas of jurisdiction to protect their employees, the community and the environment from any adverse impacts arising from their activities. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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5.3.3 Entities having an EHSMS are required to audit their System in order to ensure conformance with ZonesCorp EHSMS Requirements. 5.3.4 Entities having established an EHSMS are required to demonstrate self regulation 5.3.5 Entities having an EHSMS are required to submit an annual report to the ZonesCorp / EAD on the performance of their System as per the mechanism set by ZonesCorp. 5.4 Employers Duties 5.4.1 Employers have the ultimate responsibility to ensure the health and safety of their employees. 5.4.2 Employers have a general Duty of Care to take all practicable steps to ensure the safety of their employees while at work, visitors and contractors. In particular, they are required to take all practicable steps to: Provide and maintain a Safe Working Environment; Provide and maintain facilities for the Safety and Health of employees at work; Ensure that machinery and equipment are safe; Ensure that working arrangements are not hazardous to employees; and Ensure a Safe System of Work comprising at least of Procedure, Training, Communication & Supervision is in place Ensure procedures are available to deal with emergencies that may arise while employees are at work. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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6. EHS AUDIT 6.1 The purpose of EHS Audit is to ensure compliance to EHS Management System, Procedures and a safe and healthy workplace by striving to eliminate unsafe practices and hazards that lead to injuries and accidents. 6.2 EHS Audits are report cards on the success of EHS programs. Like financial audits, EHS audits are structured evaluations on performance & compliance. 6.3 EHS Audit is a structured, methodical assessment and evaluation of how workplace activities affect safety, environment and health. It reveals how an organization is doing in maintaining a safe and healthy environment. Its goal is to ensure a safe and healthy workplace by striving to eliminate unsafe practices and hazards that lead to injuries and accidents. 6.4 An audit consists of two parts: gathering data about a program and evaluating the data. The audited program must comply with a variety of regulations and guidelines: federal environmental, safety, and health regulations; local and state requirements; and internal institutional performance requirements. 6.5 An audit should identify the strengths as well as the weaknesses of a program. It should reveal to management and the employees where and how they could and should make improvements. 6.6 On-site Audits require three main actions. 6.6.1 First, arrange interviews with facility personnel who have key roles in developing or implementing safety management systems. 6.6.2 Next, review documentation that defines safety system records or verifies completion of critical tasks. These tasks may include emergency preparedness; hazard identification, control, and monitoring; and safety education and training. 6.6.3 Last, conduct field assessment of the facility or equipment. Here, the assessment might include verification of implementation of safety practices. For example, are only certified welders performing hot work (welding)? Does he have hot work permits? 6.7 Audit data, obtained by reviewing written records and procedures, interviewing personnel, and personal observation, are collected from both an administrative area and a management or operational area, which controls the physical environment. 6.8 Audit of the administrative area includes a review of how well or how poorly management has implemented the program. Audit of the operational areas, whereby management controls the physical environment, includes assessing the surroundings and external conditions that influence the daily operation of the organization. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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7 AUDIT CATEGORIES 7.1 Level 1 Audit: To be conducted at Corporate level (for the whole organization) by Internal or External Auditors. 7.2 Level 2 Audit: To be conducted at Divisions Level within the Organization by Internal Auditors. 7.3 Level 3 Audit: or Inspections. to assess at the Sections/Department level, the physical conditions of the workplace and to physically verify that operations are conducted in accordance with EHS Policy, Standards and Procedures. Note 1: Depending upon the organizational structure and size the appropriate category of audit (Level 2 or 3) should be selected. Note 2: Where applicable Contractors Worksites shall be covered in all the Audits 7.4 External Audits 7.4.1 External audits can be carried out for all audit levels. These audits shall be in addition to Internal Audits 7.4.2 Entities shall ensure external audits being conducted by EAD/ZonesCorp approved auditors on annual basis. The report shall be submitted to ZonesCorp as a part of EHS Performance monitoring. Refer to ZonesCorp Code of Practice on EHS Performance Monitoring & Reporting ZC-CoP- EHS06 7.4.3 ZonesCorp shall conduct an audit of Entitys EHS Management System at approximately three yearly intervals. 7.4.4 The ZonesCorp EHSMS audit aims to verify Entitys implementation of, and compliance with the ZonesCorp EHS MS requirements and expectations. 7.4.5 Consultants, ISO 14001 certification bodies, etc., may also perform external EHS audits. 7.4.6 External audits shall be tracked and followed up similarly to internal audits, with same responsibilities. 7.5 Self Assessments 7.5.1 Entities shall perform an EHS MS self assessment on an annual basis or a frequency set by the concerned Management. This shall be performed according to the requirements as outlined in this document 7.5.2 Entitys Management shall co-ordinate and support the EHS MS self assessment process in order to ensure objectivity and consistency of approach. 7.5.3 The EHS MS self assessment may be submitted as part of the EHS Performance Reporting. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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8 EHS MANAGEMENT SYSTEM AUDITING 8.1 The EHSMS auditing, for the purposes of implementing the objectives, principles and intent of the EHSMS Framework, should include (where relevant), but not be limited to the following areas: a. EHS Management Systems; b. Discharges to air, water and land; c. Management of water (wastewater, groundwater, drinking water); d. Minimization and management of waste including resource recovery, reuse and recycling; e. Hazardous waste management and responding accordingly to hazardous releases; f. Managing hazardous substances such as asbestos, pesticides & oil pollution; g. Noise management; h. Occupational and public health and safety (includes workers and visitors, customers and neighbors) including personal protective equipment and training and supervision; i. Adequacy of monitoring and measurement practices (including calibration); j. Aboveground and underground storage tank management; k. Risk assessment and management including hazard identification and communication; and l. Emergency management planning and response. 8.2 This document is however limited to the EHS Management System Audit, the auditing requirements for other above listed items are addressed in the relevant Code of Practices 8.3 EHS Management System Audits aims to verify compliance with EHS Management Systems Elements and associated Expectations. Refer to ZonesCorp Code of Practice on EHS Management System ZC-COP-EHS02 8.4 The EHS MS Audit program should be designed, developed and implemented in accordance with, ZonesCorp EHS MS requirements and the applicable international standards like ISO: CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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9 EHS AUDIT TEAM 9.1 EHS Audit team should comprise a lead auditor, an engineer (or equivalent) familiar with the area/plant/equipment and/or process, and a person with experience in the relevant field, e.g. EHS. 9.2 During operations, each Manager is responsible for controlling the regular frequency of audits for its facility or area of management. Line Managers must be satisfied that appropriate due diligence is being achieved. 9.3 EHS Audit Team shall be nominated by concerned Management in consultation with HSE Manager or equivalent. 9.4 The recommended members of the team shall be as defined in section 3. In general audit shall comprise of members at least one each from HSE, Operations, Maintenance, Engineering & Projects, Divisions/Departments in Buildings, Contractors Representatives (for construction sites). 9.5 EHS Audit Team leader shall at least be a Department Manager / Section Head or equivalent nominated on rotation basis. Team leader shall not be responsible for the area to be audited. 9.6 HSE representative shall be the EHS Audit coordinator and an essential member of the audit team. 9.7 EHS Auditors must be suitably knowledgeable, experienced and qualified to undertake EHS audits. Refer to the preceding sub-sections. 9.8 Audit Team Responsibilities 9.8.1 EHS Auditors, and their Audit Team, have a primary duty of care to the Environment, Health and Safety and above all to the organization. They have ethical as well as technical obligations in the fulfillment of their duties. 9.8.2 Ethically, EHS Auditors are obliged to: a. Provide true and accurate information concerning their investigations; b. Not issue inaccurate EHS audit reports, or conceal relevant information from the concerned management, ZonesCorp, EAD etc.; and c. Notify ZonesCorp / EAD of any imminent hazard to workers, the community or the environment, or fraudulent activity, as soon as practicably possible during the course of conducting the EHS audit 9.8.3 Technically, EHS Auditors are obliged to: a. Refer to documents (CoP, Guidelines etc.) developed by the ZonesCorp, EAD and updated international standards in the course of conducting the audit; b. Utilise best practice methods while conducting assessments; CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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c. Exercise due care, diligence, and professional judgement while conducting their activities to a standard expected of a qualified environmental, health and safety auditor; d. Conduct audit only in areas within their competence; and e. Ensure that EHS audit statements or reports are based on sound observations and logical deductions and analysis. 9.9 Types of EHSMS Auditors a. The following types of EHSMS auditors are required for the implementation of the objectives, principles and intent of the EHSMS Framework: b. EHS Management System Auditors; c. EHS Industrial Facilities Auditors; d. EHS Contaminated Land Auditors; e. EHS Hazardous Materials Auditors; f. EHS Occupational Hygiene Auditors; g. EHS Monitoring Measurement Auditors; and h. EHS Air Quality Modelling Auditors; 9.10 Qualifications for EHSMS Auditing Personnel a. Internal EHSMS auditors must be suitably knowledgeable, experienced and qualified to undertake EHS audits. b. External EHSMS auditors must be suitably knowledgeable, experienced and qualified to undertake EHSMS audits. c. The training undertaken by external EHSMS Auditors must be recognized and sufficient to be certified to undertake EHSMS audits of management systems in accordance with the standards prescribed in Section 13, or recognized equivalent. d. Only ISO certified auditors, or an equivalent recognized by the ZonesCorp / EAD, should conduct external EHSMS audits in accordance with this policy. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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10 KEY STEPS FOR AUDITING 10.1 The figure presented below contains guidelines on planning and conducting audit activities as part of the audit program. The extent to which the provisions of these guidelines are applicable depends on the scope and complexity of the specific audit and the intended use of the audit conclusions.
Initiating the audit 1. Appointing the Audit Team Leader 2. Defining audit objective, scope, and criteria 3. Determining the feasibility of the audit 4. Selecting the audit team 5. Establishing initial contact with the auditee
Conducting document review 6. Reviewing relevant EHS Management System documents including records and determining their adequacy with respect to audit criteria
Preparing for on-site audit activities 7. Preparing the audit plan 8. Assigning work to the audit team 9. Preparing work documents
Conducting on-site audit activities 10. Conducting opening meeting 11. Communication during the audit 12. Roles and responsibilities of guides and observers 13. Collecting and verifying information 14. Generating audit findings 15. Preparing audit conclusions 16. Conducting closing meeting CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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11 SCOPE OF EHS AUDITING 11.1 The scope of EHS auditing, for the purposes of implementing the objectives, principles and intent of the organizations EHS objectives, should include (where relevant), but not be limited to the following areas: a. EHS Management System including EHS Control Procedures b. All existing written EHS programs c. Compliance to Safe Work Procedures and Practices 11.2 Appendix 3 & 4 presents a set of basic requirements recommended for use in EHS MS and EHS Audits and Self Assessments. This is based upon the Eight Elements of ZonesCorp EHS MS and the associated expectations 11.3 In addition to the EHS Policy Statement and Commitment (Appendix 1), there are EHS expectations that are contained within 8 Elements of ZonesCorp EHS Management System (CoPEHS02). Together, these 8 Elements provide a framework for managing EHS. List of existing Code of Practices included in ZonesCorp EHS Management System is provided in Appendix 2 The 8 EHS Elements are listed below and EHSMS Audit should consider the associated expectations. The Elements are: a. Element 1 Leadership and Commitment b. Element 2 Policy and Strategic Objectives c. Element 3 Organization, Resources & Competency d. Element 4 Risk Evaluation & Management e. Element 5 Planning, Standards and Procedures f. Element 6 Implementation and Performance Monitoring g. Element 7 Compliance Assurance (Audits/Inspections) h. Element 8 Management Review In addition, the following environmental principles are to be upheld: a. Full compliance with all EAD standards as a minimum b. Full compliance to Abu Dhabi Emirate Environmental Protection Policies (EEPPs) and Standards c. Minimization of power requirements. d. No unplanned venting of gases from process facilities. e. Utilization of best available technology to minimize fugitive emissions. f. No utilization of ozone depleting substances. g. No discharge of off-spec water to land or sea. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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h. No discharges of oil or chemicals to land or sea i. Minimization of waste generation. j. Optimization of facilities footprint to reduce environmental impacts. k. Minimization of visible impacts, noise and odour 11.4 Areas of consideration shall at least include: a. EHS MS Expectations b. EHS Control Procedures c. Engineering Controls d. Administrative Controls (Procedure, Work Instructions etc.). e. Personal Protective and Safety equipment. f. Periodic Inspections Records and status of action items. g. Employee Training Records and needs h. Site Compliance Deficiencies. i. Unsafe Conditions / Unsafe Acts j. Spills / Leaks k. Adequacy of monitoring & measurement practices (including calibration); l. Managing hazardous substances such as asbestos, pesticides and oil pollution; 11.5 Appendix 3 presents the EHS MS Audit Basic Requirements and Appendix 4 presents EHS Audit concerns 11.6 Environment maters like hazardous material & waste separation, storage & handling, containment, placards, chemical inventory, emergency equipment and procedures, sampling & monitoring needs etc. 11.7 All Operating Facilities, Buildings including Control Rooms, Offices, Workshops, Warehouses, Construction Sites, etc. shall be audited as per agreed frequency. 11.8 The buildings (etc.) may be grouped depending upon the area, size, usage and/or location. 11.9 For Multi-storey Buildings, audit should be carried out floor wise and concerned Managers (located on the floor to be audited) or equivalent shall assign the representative to accompany the auditors. 11.10 For New/Expansion Projects / Construction Worksites: Project Owner in consultation with Project Executing Division/Department and HSE Department shall coordinate for the Audit as deemed necessary. Construction Contractor shall be involved. Refer to ZonesCorp CoP on Construction H & S Management Plan (CoPS01) CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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12 EHS AUDIT PLANNING 12.1 The personnel responsible for conducting EHS audits within the organization should: a. Establish the audit objectives, criteria, extent, and scope; b. Define responsibilities of the audit team, allocating adequate resources, and developing suitable procedures; c. Implement the audit plan or program; d. Maintain records to demonstrate implementation of the audit programme; and e. Monitor the implementation of the audit plan or program and review the audit plan or program at various stages to determine whether the objectives have been met and to identify areas requiring improvement, or that can be improved. 12.2 To make the EHS audit an effective tool that produces reliable information for an organization to improve on its environmental health and safety performance, EHS auditors must uphold the following principles of auditing: a. Ethical conduct b. Fairness when presenting audit findings; c. Exercising due care and professionalism when conducting the audit; d. Freedom from bias and partiality; and e. Utilising the logical, scientific, evidence-based approach for arriving at reliable audit conclusions. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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13 MANAGING THE AUDIT PROGRAM 13.1 The audit program should be designed, developed and implemented in accordance with, but not limited to, the following series of standards: a. ZonesCorp / Tenant(s) EHS MS Targets & Objectives b. ISO 14000 series for Environmental Management Systems; c. ISO 18000 series for Occupational Health & Safety Management Systems; d. OHSAS 18001 series for Occupational Health & Safety Assessment Series; e. ISO 19011 - Guidelines on quality and/or environmental management systems auditing; f. ISO 9000 series for Quality Management Systems (optional); and g. Relevant standards for Risk Management Systems (optional). 13.2 Authority for conducting random or targeted EHS audits must be granted by Entitys senior management. 13.3 An audit program may include one or more audits depending upon the size, nature, and complexity of the organization to be audited. 13.4 An audit program also includes all activities necessary for planning and organizing the type and number of audits and for supplying adequate resources to conduct the program effectively and efficiently within the specified timeframe. 13.5 In addition to their internal audit program, organizations should also arrange external audits of their EHS MS. External audits may be useful in providing a more independent assessment of performance and may employ expertise not available in-house. 13.6 Figure 13.1 illustrates the process-flow for the management of an audit program based on the plan-do-check-act methodology described in ISO 19011:2003 (Guidelines for Quality and/or Environmental Management Systems auditing). 13.7 Appendix 3 presents a set of requirements recommended for use in EHS MS Audits and Self Assessments. This is based upon the Eight Elements of ZonesCorp EHS MS and the associated expectations CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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Figure 13.1: Process Flow for the Management of The Audit Program
Authority for the audit program Establishing the audit program 1. Objectives and extent 2. Responsibilities 3. Resources 4. Procedures Implementing the audit program 1. Scheduling the audits 2. Evaluating auditors 3. Selecting audit teams 4. Directing audit activities 5. Maintaining records Monitoring & reviewing the audit program 1. Monitoring and reviewing 2. Identifying needs for corrective and preventive action 3. Identifying opportunities for improvement
Improving the audit program Audit activities Act Plan Do Check CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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14 CONDUCTING THE AUDIT 14.1 EHS Management System Audits 14.1.1 EHS MS Internal Audit (Self Assessments) EHSMS Internal Audits should be carried out by the Entitys EHS Audit Team at least on annual basis or at the frequency approved by senior management in consultation with facility HSE staff 14.1.2 EHS MS External Audit (3 rd Party) Entities shall get their EHS MS audited by external 3 rd Party EHS Auditors approved by ZonesCorp/EAD on at least annual basis. The report of such Audits shall be submitted to ZonesCorp as a part of EHS Performance. Refer to ZonesCorp Code of Practice on EHS Performance Monitoring & Reporting (CoP-EHS06) 14.1.3 EHS MS External Audit (ZonesCorp) ZonesCorp Audit Team as a normal course shall undertake an Independent Audit of Entitys EHS Management System at least once in three years. However ZonesCorp reserves the rights to increase the frequency as and when required on a case to case basis. 14.1.4 Minimum requirements that need to be verified during the EHS MS Audit are provided as guidelines in Appendix 3 14.1.5 EHSMS Internal & External Audit schedules indicating time, location, area, suggested team leader etc. shall be prepared by Entities and communicated to all concerned including ZonesCorp, Internal Audit Team Leaders and Members etc. 14.1.6 ZonesCorp may like to nominate an observer during any of such Audits. 14.1.7 All EHSMS Audit Reports including Self Assessment and External shall be submitted to ZonesCorp EHS. 14.2 EHS Audits (Safety Audits) EHS Audits commonly known as Safety Audits should be carried out by Entitys Internal EHS Audit Team at least on monthly basis or at the frequency approved by Senior Management in consultation with facility HSE staff Minimum requirements that need to be verified during the EHS Audits are provided as guidelines in Appendix 4 14.2.1 Audit schedule for the year indicating time, area and suggested team leader shall be prepared and communicated to Auditee(s) (Area/Facility Owners), Audit Team Leaders, Members, etc. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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14.2.2 If audit of a particular area is not possible due to unavoidable circumstances like shut down, maintenance etc. then this shall be rescheduled by the team leader in consultation with the Auditee. 14.2.3 EHS Audit checklist should be used by each member of the audit team during the audit. 14.2.4 FM-ZCEHSCOP11-01 and FM-ZCEHSCOP11-02 presents the recommended checklists for facilities and buildings respectively 14.2.5 ZonesCorp may ask Entities to submit or present the EHS Audit Reports 14.3 Audits Key Requirements a. Auditee (Area / Facility Owner etc.) shall be informed about Audit timings and Scope in advance by Audit coordinator (HSE representative etc.) and shall be required to accompany the audit team. b. Audit team should comply with the applicable personal protective equipment requirement and operating facilities basic safety rules. c. Auditee shall provide all the information / evidence as required during the audit. d. Auditee shall take notes during the audit for all concerns raised by the audit team. e. Previous audit reports shall be provided to the audit team and reviewed by the audit team before the audit. f. Audit team may take these reports along with them during the audit for confirming the previous recommendation compliance etc. g. Audit team members may carry out a joint audit of all fields within audit scope or each / some members may assign to audit separate fields as per requirement and decision prior to start the audit. h. If audit team is performing audit on separate field bases then the Auditee shall ensure all required arrangements like availability of concern representative etc. i. An important aspect of the EHS Audit is onsite conversation with the employees. j. The auditor shall talk with employees about EHS aspects, hazards, practices, safety knowledge and any other concerns related to the job. k. Auditors should also inquire about what actions the employee thinks should be taken to safeguard the job. l. A closeout meeting of Audit Team shall be held after conducting the audit for discussing / consolidating the observations CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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15 EHS MANAGEMENT SYSTEM AUDIT COMPLIANCE SCORE 15.1 The table provided below is recommended for use in assigning the Compliance Scores to each of the EHS Management System Elements and Requirements 15.2 When reviewing the implementation extent for each of the requirement / expectation, a score (as per Table below) should be given, which reflects the stage of implementation. 15.3 While assigning the scores, auditors shall perform a careful review of audit findings and implementation status in consultation with the Auditee(s): 15.4 There are 5 distinct levels: Score Definition 0 There is no evidence that the Expectation is recognised to be an EHS MS requirement. There is no implementation action ongoing or planned. 1 The Expectation is recognised to be an EHS MS requirement but is only partially being complied with and shows significant gaps and weaknesses. There is no adequate plan to implement this Expectation beyond the current level of compliance. 2 The Expectation is already partially implemented and there is an adequate plan in place to fully implement it. Implementation progress is less than originally planned. 3 The Expectation is being implemented and there is an adequate plan in place to fully implement it. Implementation progress is in accordance with or better than the plan. 4 The Expectation is currently fully met with negligible non- compliance. There are adequate systems in place to ensure continuous compliance and improvement. 15.5 The Score should be assigned to each of the requirements agreed to be part of the audit scope. This shall be reflected clearly in the Audit Report. . 15.6 To arrive at the appropriate Score, auditors should use the information obtained from site visits, interviews and documentation reviews. Also, information may be obtained from other Audit Team members as appropriate. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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16 DOCUMENTING THE EHS MS AUDIT FINDINGS 16.1 The audit findings may be considered as Gap or Weakness in the management system. 16.2 The documented audit findings must relate to the gaps/weaknesses which have been identified for the EHS MS Expectations / Requirements. 16.3 Audit findings should provide the detail as required by the Auditee to arrive at a rectification action plan. 16.4 Efforts should be made to ensure that the manner in which the Gaps are reported is stand-alone i.e. the Auditee should be able to interpret the Gap without having to relate to the body of the audit report, the audit checklists or any other working papers. 16.5 No reference should be made to the way how the finding is to be corrected or the time-frame in which this correction is to be implemented. Both of these shall strictly Auditee responsibilities. 16.6 All audit Findings shall be risk classified in accordance with the definitions as per Table 16.1 below, which has been derived from the Risk Potential Matrix provided in Fig 16.1. For detail refer to ZonesCorp COP on Risk Management CoP-EHS06 16.7 The margins between the risk areas in the matrix are relatively large and as such should not cause substantive arguments regarding the extent of probability or severity. Table 16.1: Risk Weighting Factors for EHS MS Items Risk Definition E Extreme An item with an unacceptably high risk potential. It may expose the Entity to intolerable losses to people, Assets, environment or reputation. The gaps or weaknesses must be brought to the attention of management. Immediate action should be taken to rectify it, i.e. reduce the risk to a tolerable and ALARP level. H/M High/Moderate An item with a risk potential which falls in the highest part of the ALARP risk management area. The gaps or weaknesses, although not resulting in unacceptably high risk levels, must be brought to the attention of management. High priority action must be planned and documented to satisfy ALARP risk management criteria. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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Table 16.1: Risk Weighting Factors for EHS MS Items M Moderate An item with a risk potential which falls in the lower part of the ALARP risk management area. The gap or weakness must be rectified as a medium priority as to satisfy ALARP risk management criteria. L Low An item with a low risk potential. The gap or weakness is tolerable without further action. Correction may improve process, system or organisation effectiveness/efficiency. FIG 16.1: RISK ASSESSMENT MATRIX (RAM) Consequence 2
Probability 2
Insignificant (1) Minor (2) Moderate (3) Major (4) Catastrophic (5) Rare (1) 1 2 3 4 5 Possible (2) 2 4 6 8 10 Likely (3) 3 6 9 12 15 Often (4) 4 8 12 16 20 Frequent (5) Almost Certain 5 10 15 20 25 15 25 Extreme Risk 1
Activity or industry should not proceed in current form 8 12 High Risk Activity or industry should be modified to include remedial planning and action and be subject to detailed EHS Assessment 4 6 Moderate Risk Activity or industry can operate subject to management and / or modification 1 3 Low Risk No action required, unless escalation of risk is possible
1: Risk is the multiple of Probability & Severity of Consequence 2: Probability: Refer to Table 8.1 above for getting definition of Probability of Occurrence 3: Consequence: Refer to Table 8.3 for Potential EHS Impact & Potential Incident Consequence Rating
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17 .AUDIT REPORT 17.1 Audit results must be documented to identify existing deficiencies and required corrective actions. 17.2 Before being closed out, corrective action requests should be followed up to ensure that non-conformance has been corrected. Similarly, the quality system should also be corrected, if necessary, to prevent recurrence. 17.3 Based upon the working documents, check lists, audit observations and meetings discussion, an audit report shall be prepared by Audit Team and approved by the Team Leader. 17.4 Audit findings shall be communicated to Auditees at the end of the audit in the close out meeting 17.5 Audit report shall reflect the points of concern, action required for rectification, recommendations, responsibility and the target date. 17.6 Audit team shall make efforts to record the actual facts during the audit and the same may or may not be agreed by the Auditee(s); however the observations and findings of the Audit Team can not be challenged. 17.7 EHS MS Audit Reports (Internal & External) Copies shall be forwarded to ZonesCorp 17.8 One copy of the audit report should be forwarded to the Auditee. 17.9 Auditee(s) should follow up for rectification of audit observation and submit status report to Team Leader / concerned Management. 17.10 Original report along with the checklist shall be maintained by designated department like HSE for recordkeeping and follow up for recommendation. 17.11 HSE Manager or equivalent shall share the audit results with organization senior management, if deemed necessary. 17.12 Quarterly report indicating the status of audit conducted, salient observations, recommendations and the status of actions should be prepared and shared with concerned management. 17.13 Audit Reports shall be kept for presentation to external auditors (ZonesCorp, EAD, etc.) as and when required.
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18 EHS INSPECTIONS 18.1 EHS inspections are a basic tool for establishing and maintaining safe conditions and discovering unsafe practices in the workplace. 18.2 Systematic inspections are practical ways to identify and correct unsafe equipment, conditions, processes, and work practices. If unsafe conditions and practices are found to exist, prompt corrective actions are initiated. They are an excellent way to prevent accidents from occurring and to safeguard employees. 18.3 An additional benefit occurring from inspections is that they give employees an opportunity to point out deficiencies in their area that may otherwise go unnoticed and uncorrected. 18.4 EHS inspections are conducted primarily not to find out how many things are wrong, but rather, to determine if things are satisfactory. Their secondary purpose is to discover conditions that, when corrected, will bring the facility up to accepted and approved standards and/or regulations. As a consequence, the inspected facilities should become safer and more healthful places to work. 18.5 First-line supervisors, individual employees, maintenance employees, as well as inspection teams, all function as workplace inspectors. The first-line supervisor is one of the most important inspectors in the entire organization. He or she is more important to EHS than is the EHS inspection team. 18.6 The supervisor is the key person because he or she is in constant contact with employees and is thoroughly familiar with all the safety risks that may develop in the department. 18.7 Supervisors should be on the alert at all times to discover and correct unsafe conditions and practices. 18.8 Employees, if they are on the alert, also can be of great value in preventing accidents. Employees should be encouraged to inspect the workplace every day and to report any hazardous conditions to their supervisor. Employees who are safety conscious will look continuously for conditions that may cause injury to themselves or others. 18.9 Maintenance employees, in particular, should be safety conscious. When maintenance employees are working in various departments and observe safety risks that should be corrected, they can avert hazards by reporting risks to the supervisor of the department. Management should alert its employees that maintenance people are a great help in locating and correcting hazardous conditions. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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19 EHS INSPECTIONS PROGRAM 19.1 EHS Inspections mainly differs from EHS Audits in areas like Scope, Frequency, Team Structure, Depth or Detail however the sections outlined under EHS Audit shall be considered for necessary guidance as applicable to various activities of EHS Inspections, Inspections refer to a physical walk-through of an area conducted by either the internal team of an organisation or by an external agency to determine compliance with regulations and/or industry policies. A simple checklist can be used for the purpose. FM-ZCEHSCOP11-03 presents the recommended format for EHS Inspections) 19.2 Organizations should establish, implement, and maintain documented procedures for planning and conducting ongoing inspection, testing, and monitoring related to EHS goals and targets set earlier. The frequency of such inspection and testing should be appropriate to each item inspected, tested or monitored. 19.3 In order for the EHS strategy to be effective, it is essential that inspections be planned and systematic. This does not remove responsibility from organizations to be vigilant in recognizing and correcting issues that they believe may cause harm or damage. 19.4 At the completion of each inspection, any deficiencies identified must be noted on a summary sheet for action. 19.5 The supervisor (or equivalent) should then be de-briefed on ways to address the key issues identified, the personnel recommended to undertake specific actions and those responsible for notifying the person(s) responsible for EHS. Any issues that are identified as continuing must be reported to the area manager and to the person(s) responsible for EHS. 19.6 It is the responsibility of each organization to develop, with their work teams, the most efficient manner in which such inspections will be performed. The minimum requirement is that a written procedure for inspections is developed. 19.7 Figure 19.1 illustrates the process flow for coordinating workplace safety inspections schedules. 19.8 To have a program for EHS inspection for reviewing work practices / workplace hazards throughout the organization and addressing the unsafe condition/act through the reports which shall be monitored and tracked for rectification. 19.9 The objective of Safety Inspection / Walk Thru is to maintain a Safe Working Environment (by identifying, controlling & removing hazards) and ensuring the implementation of Safe Work Practices. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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Figure 19.1: Coordinating A Workplace Safety Inspection Schedule
Step 1: Develop register of activities occurring in the organisations area of responsibility in consultation with the EHS committee or Equivalent. Step 2: Identify inspection, testing, and monitoring required and frequency and competency by checking industry policies, legislation, and standards.
Step 3: Appoint a staff member to assist in developing plans and schedules of inspections, testing, and monitoring that determine whether certificates of competency are needed.
Step 4: Coordinate the implementation of the inspection, testing, and monitoring schedule and ensure results are documented, reviewed, and acted upon and records are filed in a systematic manner. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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19.10 Entities shall perform Level 3 EHS inspections to supplement the formal EHS audit process. There are two types of EHS inspection: 19.10.1 Supervisory Inspections a. Supervisory inspections are an essential part of the routine supervisory work scope. Gaps and issues detected during these inspections shall be invariably rectified on-the-spot or within a short time frame. There is no requirement to formally document supervisory inspection findings. b. The responsibility for supervisory inspections shall be the Section Head or equivalent. Supervisory inspections shall be conducted by First Line Supervisors. 19.10.2 Management Inspections a. Management inspections are an essential part of the management process. The term management refers to Senior Managers and above. b. Management inspections are a key component of the HSE assurance process in which senior management physically verify that operations are conducted in accordance with policy, standards and procedures. c. The results of management inspections shall be formally documented and effective follow-up shall be verified. d. Management EHS inspections provide excellent opportunities to: Convey management EHS commitment and leadership messages to the workforce. Physically verify the correctness of formal progress and achievement reports. Create awareness of general attitudes and concerns of the workforce. e. Management inspections, if conducted properly, enhance EHS team work, workforce culture and willingness to change and improve. 19.11 EHS INSPECTIONS SCHEDULE Each Area (facility) owner in consultation with HSE Staff shall prepare Safety Inspection Schedule for the whole year. This shall at least include scope, proposed Dates, Time and Locations/Areas 19.12 CONDUCTING EHS INSPECTIONS: a. EHS Inspections shall at least be carried out jointly by HSE, Area/Facility Owner and Maintenance Representatives. b. For Building Safety Inspection each Division/Department located at respective floor shall nominate a representative for participating in Inspections c. Buildings Fire Wardens or equivalent shall also be the team members. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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d. For Projects (New or Expansion)/ Construction Sites: Contractor representatives shall be part of the facility inspection team. However the contractors shall conduct independent inspections as well and maintain record. This shall be in accordance to ZonesCorp Code of Practice on EHS Management of Contractors ZC-CoP-EHS09 19.13 EHS INSPECTION REPORTS 19.13.1 EHS Inspection Report shall be filled-up by the appointed representative indicating the inspection finding, action required and the responsible department / section. FM-ZCEHSCOP11-03 presents the recommended format for EHS Inspections) Area owner / Fire Wardens shall distribute the copies of the EHS Inspection report to the responsible section / group for execution of marked actions. A copy of each inspection report should be kept with HSE Department. 19.13.2 EHS Inspection Status Report All the EHS inspection reports shall be consolidated in Monthly Safety Inspection Report The actions marked in corrective action column shall be tracked to ensure that the recommendations are acted upon and accomplished. The remarks column shall be filled with DONE, IN PROGRESS or any applicable remarks - this column shall serve as the Action Taken status indicator. 19.13.3 Monthly / Cumulative EHS Inspections Statistics Report The Monthly / Cumulative Safety Inspections Statistics report shall be prepared for sharing with Senior Management and keeping track of action items. This report shall reflect the no. of Inspections planned in the month, actual no. of inspections that has been carried out, no. of recommendations made and the status of recommendations (in progress or closed). Both the monthly and year to date status of all these information shall be presented in the report. In each report the status of previous months In Progress Actions should be updated. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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20 REFERENCES 20.1 Abu Dhabi Emirates EHS Management System Manual 20.2 ZonesCorp Code of Practice on EHS Management System Framework 20.3 ZonesCorp Code of Practice on EHS Incident Reporting & Investigation 20.4 ZonesCorp Code of Practice on Operation Environment Management Plan 20.5 ZonesCorp Code of Practice on Pollution Prevention & Environmental Compliance Assurance 20.6 ZonesCorp Code of Practice on EHS Compliance Enforcement 20.7 ZonesCorp Code of Practice on EHS Impact Assessment (EHSIA) 20.8 ZonesCorp Code of Practice on EHS Risk Management 20.9 ZonesCorp Code of Practice on Integrity Assurance & Management 20.10 ZonesCorp Code of Practice on EHS Management of Contractors 20.11 ZonesCorp Code of Practice on EHS Performance Monitoring & Reporting 20.12 ZonesCorp Code of Practice on Waste Management 20.13 ZonesCorp Code of Practice on Health Surveillance & Monitoring 20.14 ZonesCorp Code of Practice on Operation Health & Safety Management Plan
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APPENDIX 1 EHS COMMITMENT & POLICY
Industrial Sector within Abu Dhabi Emirate shall: 1. Strive to protect the Environment and the Health and Safety (EHS) of Employees, Contractors and the Community by sharing responsibility at all levels within Industrial Sector in the Emirate of Abu Dhabi 2. Develop an Institutional Framework for effective enforcement of National EHS Policies & Regulations across the Industrial Sector within Emirate of Abu Dhabi 3. Ensure that the Health, Diversity and Productivity of the Environment is maintained or enhanced for the benefit of future generations in order to achieve sustainable development. 4. Achieve sustainable development by promoting the concept of Cleaner Production, Energy Conservation and Industrial Ecology. 5. Integrate EHS Risk Assessment & Management in Planning, Development & Operation of all Projects 6. Integrate Economic, Social, Environmental, Health and Safety considerations including conservation of Biological Diversity and Ecological Integrity into decisions making process for Industrial Development 7. Ensure responsible care and management of Environment Health and Safety concerns including the ultimate disposal of any Wastes throughout the life cycle of the Project. 8. Ensure that the cost of abatement of Pollution and Health Risk is borne by the Polluter and Risk Generator. 9. Ensure commitment of reducing EHS Liabilities and Improving Efficiency or Resource use. 10. Promote awareness across Industrial Sector within Abu Dhabi Emirate about their responsibility in protecting the Environment and the Health and Safety of the Community. 11. Ensure an effective Emergency Response Preparedness for the Industrial Sector is in place and maintained at all times. ZonesCorp and Industrial Sector Entities shall implement this Policy through a documented Environment, Health and Safety Management System (EHSMS) and conduct periodic audits for compliance assurance. CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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APPENDIX - 2 ABU DHABI EMIRATE INDUSTRIAL SECTOR EHS REGULATORY FRAMEWORK This appendix presents a partial list of EHS Regulatory Framework Codes of Practice and Guidelines for Industrial Sector within Abu Dhabi Emirate. The list will continue to be subject to considerable change during the next few years, to match the requirements of Industrial Sector Sr. No. Code of Practice & Guidelines Document No. Environment Health & Safety (EHS) 1 EHS Management System (EHSMS) Framework CoP-EHS01 2 EHS Management System CoP-EHS02 3 EHS Risk Management CoP-EHS03 4 EHS Impact Assessment (EHSIA) CoP-EHS04 5 EHS Accident/Incident Reporting & Investigation CoP-EHS05 6 EHS Performance Monitoring & Reporting CoP-EHS06 7 EHS Management of Industries CoP-EHS07 8 EHS Management of Workers Residential Cities CoP-EHS08 9 EHS Management of Projects CoP-EHS09 10 Integrity Assurance & Management CoP-EHS10 11 EHS Audits & Inspections CoP-EHS11 12 EHS Compliances Assurance & Enforcement CoP-EHS12 13 EHS Training & Awareness CoP-EHS13 Environment 1 Construction Environment Management Plan (CEMP) CoP-E01 2 Operations Environment Management Plan (OEMP) CoP-E02 3 Waste Management Plan CoP-E03 4 Pollution Prevention & Environmental Compliance Assurance CoP-E04 Health 1 Occupational Health Surveillance and Monitoring CoP-H01 2 Occupational Health Welfare Management CoP-H02 3 Food Safety Management CoP-H03 CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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Sr. No. Code of Practice & Guidelines Document No. Safety 1 Construction Health & Safety Management Plan (CHSMP) CoP-S01 2 Operation Health & Safety Management Plan (OHSMP) CoP-S02 3 Transport Management Plan (TMP) CoP-S03 4 Contractors Safety Requirements CoP-S04 Fire & Emergency 1 Fire Risk Management (FRM) CoP-FE01 2 Fire Protection System Design Criteria CoP-FE02 3 Emergency Response Plan (ERP) CoP-FE03 4 Emergency Communication CoP-FE04 5 Crisis Management Plan (CMP) CoP-FE05 6 Incident Command System (ICS) CoP-FE06 Code of Practices Guidelines 1 EHS Manual for Workers Residential Cities CoP-GL05
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APPENDIX 3 EHS MANAGEMENT SYSTEM AUDIT BASIC REQUIREMENTS Section 1: Leadership and Commitment
ESSENTIAL ITEMS TO BE CHECKED Leadership and Commitment Commitment to EHS aspects through leadership Senior management should engender commitment to EHS issues at all levels through their personal style of leadership and management. Key elements include: Visible expressions of commitment by senior people EHS matters should be placed high on personal and collective agenda All senior managers should set a personal example to others. They should be, and seen to be actively involved in EHS matters, e.g. attendance at EHS meetings, personal instigation of EHS audits and reviews, etc. A feedback system should be established to encourage and facilitate employee feedback on EHS matters A positive culture should be promoted at all levels Section 2: Policy and Strategic Objectives EHS Policy Statement General Written EHS policy Dated and signed by Chief Executive Policy statements: specific to individual parts of the contract (e.g. locations/sites/plants) cover specialised aspects (e.g. alcohol and drugs) consistent with Tenants standards and guidelines clear, concise and motivating Content Importance of EHS as a contract objective Incidents and injuries are unacceptable EHS established as a line management responsibility Everyone is responsible for their own and their colleagues' EHS at work CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Distribution/ availability EHS policy distributed to all concerned, i.e. handed to each employee by their line manager when issued All new employees handed a copy by their line manager displayed on notice boards at each work location(worksites and offices) copies provided for each entity on the contract(including subcontractors, suppliers and agents) available to Tenant and contractor employees in their working language(s) Discussion Policy and its implementation when issued discussed by line managers with each employee Section 3: Organization, Resources and Competence EHS Organization Key personnel Personnel responsible for the implementation of EHS objectives clearly identified in an organisation chart Responsibility adequately covered during all phases of contract Job descriptions in place showing each team member's EHS competencies, responsibilities and function Organisation clearly shows position of EHS professionals EHS objectives/ accountability Defined to meet health, safety and environmental objectives as well as those of time, cost and quality Accountability for EHS success and equally of any failure clearly stated Focal point within the team structure ensuring that all EHS matters have been identified Designated team leader to produce EHS objectives, tasks and targets for the organization Targets, etc to be realistic and consistent EHS issues Manning/ Communication Manpower philosophy Manpower level to be defined correctly so as not to compromise EHS Effective means to communicate EHS issues between the Tenant, contractor and subcontractors Organisation staffed by competent personnel with sufficient appreciation of EHS where necessary with specific training in the issues involved CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Corporate Structure/ Responsibility Entity's expectations on EHS Management shall be communicated in depth within the organization Access of line management to their corporate management structure on EHS issues to be defined Level of handling EHS issues by the Entity corporate structure (middle or senior management or board level) In the Tenants corporate organisation, individuals charged with responsibility for EHS at middle senior manager or board member level Access to specialist EHS advice for line management, e.g. Provision of EHS documentation Employment of EHS specialist EHS Professionals Job definition Role of the EHS advisers / specialists well defined Job description drafted Reporting/ follow-up Reporting relationship with line management Direct access to the Chief Executive Does line management follow advice offered EHS Communication within organization CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED EHS Department or Equivalent Entity's EHS department involved in: Preparing and monitoring departmental action plans Formulation and suitability of EHS rules Planned inspections and audits together with line management Promotional material EHS training Subcontractor assessment Training and auditing Health risk assessment, health performance monitoring and health surveillance Environmental monitoring Supporting incident investigation by line management Guidance given by the EHS Professional in preparing and implementing: Operating and emergency manuals Emergency plans Training for fire fighting teams, first-aiders, etc Emergency drills and exercises Protective equipment and rescue Contact and liaison with relevant Government departments maintained Contractors Control Management Verify availability and compliance to ZonesCorp EHS Code of Practice on EHS Management of Projects CoP-EHS09 Contractor Safety Requirements CoP-S04 Construction Health & safety Management Plan CoP-S01 To be well integrated and identified in Contract EHS Plans Contractor(s) EHS Plans to be vetted for suitability by concerned Management Vetting of past contractors / subcontractor records Maintenance of approved contractors lists where EHS has been considered CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Coverage/ Awareness Set up appropriate lines of communication to handle EHS issues, e.g. such items as: Direct access to emergency services Nearest hospital Ambulance Services First Aid Facilities, etc Emergency Services: those organisations that would be expected to provide support in a major incident aware of requirements Briefed as to their likely role Construction Projects Verify availability and compliance to Construction EHS Management Plan Construction Environment Permit Construction EHS Manual Refer to ZonesCorp Code of Practice on Construction Environment Management Plan (CoP-E01) and Construction Health & Safety Management Plan (CoP-S01) EHS Communications Coverage/ Awareness Set up appropriate lines of communication to handle EHS issues, e.g. such items as: Direct access to emergency services Nearest hospital Ambulance First aid Centre, etc Authorisation and implementation procedures fully understood Emergency services: those organisations that would be expected to provide support in a major incident aware of requirements Briefed as to their likely role External links Lines established to communicate externally incidents that may endanger those on a site Government agency reporting procedures and the associated responsibilities of Employees & Contractors Ability of base to mobilise in an emergency, e.g. doctors, hospital facilities Emergency communication Appropriate for incidents envisaged Strengthened, duplicated or backed up by other means Able to communicate with all the workforce in an emergency Communications take into account the diversity of languages amongst the workforce CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED EHS Meeting Programme Scheduling Entity(s) to establish a regular schedule for EHS meetings Procedure to maintain records of personnel attendance Management participation Managers / Supervisors seen to be involved by employees in: EHS activities, objective setting and monitoring Taking action and providing resources to support their stated policies and objectives Meeting structure EHS meeting structure Effective to manage and communicate on EHS Allow employees full involvement and their own ideas to be heard Typical agenda and meeting formats Follow-up actions Meeting actions Where action is agreed, is it seen to be carried out? Where action is not agreed, is it explained why? Communication Results of EHS activities, both successful and less successful, openly communicated to all employees Meeting programme consistent with the rest of the management structure to communicate effectively EHS issues Meetings recorded clearly and consistently Structured to differentiate between health, safety and environment EHS Promotion and Awareness Techniques Appropriate communications techniques used to make the personnel aware of EHS issues How this is to be implemented, e.g. Personal contact Interactive video Notice-boards Newsletters (suitable for large sites) Bulletins Posters Performance EHS Performance Boards at designated locations EHS Performance Recordkeeping Performance Improvement Possibilities include: Small 'give-aways' with the EHS message Competitions CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Suggestion schemes Part of business EHS activities seen as an integral part of running an efficient business rather than a costly and time-consuming 'extra' EHS Competence Requirements Fitness of personnel Confirmation of medical fitness from recognised / approved medical facility of all employees proposed for contract Employee Orientation Programme Approach Provision of a comprehensive EHS handbook for all new employees On-the-job orientation for supervisory staff Established procedure in relation to follow-up of all new employees at the worksite New employees Adequately trained and confident of their own abilities Coached to improve their work practices rather than blamed for mistakes Accountability Employees know they are accountable for EHS performance Aware that their EHS performance is part of the organization's appraisal and reward system Know that flagrant or frequent breaks of published EHS rules will result in disciplinary action Procedures Required for new employee orientation consistent with Tenants existing standards and guidelines Reappraisal Programme subject to appraisal and review EHS Training (General) Entity Standards Statement on the current standard of workforce and training requirements to meet Entitys standard Established Training Program Including: EHS management Work (Job) related procedures Road safety Health (first-aid, health hazards, medical services, alcohol and drugs, health promotion, use of PPE) Auditing Incident investigation and reporting EHS adviser skills Supervisory development CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Environmental protection Supervisory Training Supervisory development training promotes man-management skills and communication skills Formalised programme Formal EHS orientation programme for employees working on- site Records kept of employees who have been through the programme Employees trained before starting work Training covers those joining as a contract is being implemented Coverage EHS training of employees coverage (including): Safety Fire and explosion Road transport/driving First-aid Work Procedures EHS Procedures including / Permit to Work Hazard awareness and reporting Occupational health Security Basic EHS Rules Legislative requirements Environmental Protection Supervisors' participation Supervisors required to brief and debrief staff before and after training courses Course content Effective system for establishing the need for and the content of training courses Determining course effectiveness and relevance of training assessed Specialised training Relevant training given to personnel prior to the execution of hazardous operations Training gained through course attendance supplemented by on- the- job training as necessary Records kept of attendees of the training courses and qualifications gained by employees Emergency Training Training covers the actions to be implemented and the employees' responsibilities in an emergency EHS content in other courses EHS included in: Induction courses Craft training CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Supervisory training Line management training Auditing techniques EHS Training (Professionals) Selection Procedure in place for introducing competent EHS personnel on to the organization Criteria set to select the EHS & Other supervisory staff(e.g. career development, professional status) Training Verify availability and compliance to ZonesCorp CoP on EHS Training & Awareness CoP-EHS13 Training is received by EHS professional Required specialisation (e.g. drilling, radiation, chemicals) Appropriate levels of: Institute training EHS Management Qualifications Knowledge and experience of the EHS professional: Suits to competence for the job being carried out Suits to the advice required Section 4: Risk Evaluation and Management Methods and Procedures for Hazards and Effects Management Coverage Verify availability and compliance to ZonesCorp CoP on EHS Risk Management CoP-EHS03 ZonesCorp CoP on EHS Impact Assessment CoP-EHS04 Risk assessment carried out in accordance with the formal methods and procedures as set in EHS MS Analysis techniques used in preliminary form where appropriate Assessment covers all parts of the operation / activities with assessments for the specific scope and locations of the business. Experience and Awareness Workforce able to use material from previous similar assignments and demonstrate awareness from past experience
CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Assessment of Exposure of Workforce to Hazards and Effects Coverage To develop assessment of the scope and degree of exposure of workforce to hazards from the hazards and effects management process Hazard & Effect Register shall be developed & maintained Refer to ZonesCorp CoP on EHS Risk Management CoP-EHS03 Handling of Chemicals Coverage Demonstrate availability and distribution of guidance/information (MSDS) on the safe handling of chemicals, likely to be encountered in operation, and proposals for confirming adherence to guidance Material Safety Data Sheets MSDS to be provided for all hazardous chemicals Hazards and Effects Management and the Assessment of PPE Requirements Hazard assessment/ PPE requirements Hazard & Effect Management Plan shall be developed & maintained All processes identified that require use of PPE Statutory requirements similarly identified Procedure in place for recording issue to personnel together with follow-up inspection and replacement/re-certification Storage of PPE adequate and secure with procedure for ensuring adequacy of stock PPE instruction/ training Requirements identified for all personnel Instruction and training in its use provided where needed Procedure for checking its use been specified Renewal/ replacement Schedule and criteria for renewing PPE Schedule for re-certification Responsibility for payment Section 5 Planning, Standards and Procedures Process Safety Availability/ Control Verify availability and compliance to Operation Environment Permit Operation EHS Management Plan Operation & Maintenance Manual Refer to ZonesCorp CoP on Operation Environment Management Plan (CoP-E02) and Operation Health & Safety Management Plan (CoP-S02) CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED EHS Standards Availability Employee in possession of EHS Manual / set of standards Available in writing to all users in consistent, concise and clear form Users involved in the development Standards in line with Tenant(s) requirements Refer to Operation Health & Safety Management Plan (CoP-S02) Control/ Authorisation Controlled documents Updated regularly Approval level indicated Procedure for obtaining deviations from standards Responsibility for authorisation Mechanism for recording approved deviations Coverage Clear reference to national and international standards Setting minimum requirements on EHS issues EHS Procedures Availability/ Control Operation EHS Manual comprising of Written procedures available to cover hazardous operations on EHS (Refer to ZonesCorp CoP on Operation Health & Safety Management Plan (CoP-S02)) Include EHS precautions to be taken Consistent with Entity EHS MS standards and guidelines Controlled documents Appropriate level Coverage: include health safety and environment Written procedures: Familiar to all employees including contractors Available in their working language Contents related to individual job descriptions Deviations Procedure for obtaining Responsibility and level Recording of authorised deviations Omissions Identify whether there are any areas where procedures for hazardous operations are not drafted Commitment to prepare Permit to Work (PTW) System in place together with full set of applicable EHS procedures If the contractor's system is utilised, it shall be consistent with industry CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED norms and in line with Tenants standards and guidelines? Training/ Qualification Training standards and qualifications set for personnel allowed to implement procedures Basic EHS Rules Availability Set of rules available and distributed to all employees Users acknowledge receipt New employees given a copy before starting work Method of discussion and verifying understanding Coverage Covers health and environment as well as safety Set of rules provided tailored to specific contracts Identify hazards likely to be encountered Address basic housekeeping and hygiene Cover signals that will be encountered on site Production/ updating Structure for producing updating & disseminating rules Frequency Personnel participation Involvement of users Coverage Identification of potential major emergency scenarios, and procedures to use in such scenarios, e.g. Fire and explosions Evacuation and abandon location(s) Storm / Natural Disaster Oil / chemical spill Vehicles incident Emergency communications Medical Emergencies & Rescue Confined Space Activities & Rescue Loan workers and search and rescue (SAR) Toxic Gases Security breaches Emergency Preparedness and Response Awareness System shall ensure for the concerned workforce Orientation Program Schedule of drills and testing CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Medical contingency plan included Review frequency Employees responsibility for own & colleagues' EHS Monitoring mechanism Drills to be carried out without warning Plans Verify availability and compliance to Fire Risk Management Plan (ZC-CoP-FE01) Fire Protection Facilities (ZC-CoP-FE02) Emergency Response Plans (ZC-CoP-FE03) Emergency Communication (ZC-CoP-FE04) Contingency plans allowed for in emergency situations Recovery procedures in place to be activated in event of emergency scenarios Drills to be held to demonstrate preparedness for response Communication Procedure EHS Equipment and Equipment EHS inspection Integrity Assurance Verify availability and compliance to Entitys Integrity Assurance and Management Program (ZC-COP-EHS11) EHS equipment List drawn up of all EHS equipment to be used in the facility Identified by type, capacity and reference to standards Integrity Assurance & Management Program Established Requirements identified for each item of EHS equipment, including: Registry Classification Licensing Survey Test certification Schedule EHS equipment regular inspection schedule established Inspection frequency clearly identified for critical items of plant Occupational Health & Welfare Health & Welfare Management Verify availability and compliance to: Occupational Health Surveillance & Monitoring (CoP-H01) Occupational Health Welfare Management (CoP-H02) Food Safety Standards (CoP-H03) CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Facilities available Facilities defined as required by Workplace Hazards Occupational health programme established to: Identify hazards Assess hazards Control hazards, e.g. engineering controls, procedural controls, vaccinations, etc Maintain emergency procedures Appropriate for the site conditions Welfare programme meets the needs of workplace Local medical facilities evaluated in detail to assess: Range and quality of equipment and supplies Hygiene standards Administration procedures and standards Transportation and communication Sufficient for day-to-day needs and consistent with relevant health programmes Adequate provision for supply of drugs, antidotes, etc Staffing Availability of adequately trained, experienced staff Access to medical treatment facilities (if external) Contingency Plans Defined for possible incidents beyond capability of site facilities Accommodation & Catering Facilities Where provided, facilities to meet normally accepted standards of hygiene at site location Facilities to be operated in line with government hygiene Regulations and to meet Tenants standards and guidelines Rules in force to maintain cleanliness of site and other facilities Promotion Promotional material available to assist in maintaining standards Appropriate for the contractor's workforce in terms of: language clarity, etc Hygiene and housekeeping Procedure on on-site cleanliness and maintenance Environmental Environment Management Verify availability and compliance to: EHS Impact Assessment (CoP-EHS04) CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Operation Environment Management Plan (OEMP) (CoP-S02) Construction Environment Permit (where applicable) (CoP-E01) Waste Management Plan (CoP-E03) Pollution Prevention & Control and Environment Compliance Assurance (CoP-E04) Awareness Of the workforce to protect the environment whilst executing contract Control Operation Environment Permit Identify potential environmental hazards Develop procedures for handling materials and performing operations that may damage the environment Contingency plans Aims Focus for the environmental protection team At what level Line management responsibility for environmental protection been defined as well as other job objectives Development and enhancement of environmental impact statements for the contract Monitoring/ restoration Environmental monitoring to gauge the impact of operations Plans appropriate and sufficiently detailed Recovery and restoration of site after contract completion Audits To be set as committed in EHS Management Plans Regular Environmental audits of Operations / Activities Carried out by experienced individuals or companies Road Transport Coverage Verify availability and compliance to ZonesCorp CoP on Transport Management Plan CoP-S03 Drivers : competence and selection Assess physical, mental and psychological capability Character and background Qualities and experience, medical examination, document checks, driving tests Special skills such as terrain and climatic experience and first- aid knowledge Driving Permits Should record personal and employment details, types of vehicle licensed to drive and types of cargo licensed to carry Driver induction Local area characteristics and regulations CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Driver training This should test vehicle operation and use, operating conditions(terrain, climate), off-loading and positioning, emergency situations, and vehicle inspection Driver improvement Techniques should identify deficiencies, analyse causes and select appropriate retraining Vehicle selection Ensure correct type, capacity and size for facilities Good manoeuvrability and serviceability Vehicle specification The job description should be clearly defined before the vehicle is chosen, to ensure work operations do not exceed the manufacturer's specifications Safety equipment and communications on board the vehicle need to be checked Passengers Is the vehicle designed to carry passengers? Freight Design of vehicle and load limits Segregation, positioning and securing of freight Vehicle maintenance Conducted on a regular basis Operations management - need and approval Define the journey and justify the need Awareness of hazards involved Allocation of vehicles, written authorisation, verification of employees' driving standards Operations management - journey routing and scheduling Full awareness of route (hazards, conditions) Realistic schedules Journey management Logging of actions Roles and responsibilities Roles and responsibilities defined for management, supervisors, drivers, passengers Contracting Prequalification of contractors and contractor EHS management treating road transport with equal importance to main activity Standards for scope of operations included in tender operation Control and review mechanisms included in contracts Policy of no subcontracting without written authority Procedures Ensure procedures are in place for all transport operations Monitor and review mechanisms in place CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Emergency Services In place and tested Section 6 Implementation and Monitoring EHS Performance General Monitoring & Reporting Verify availability and compliance to ZonesCorp EHS Code of Practice on EHS Performance Monitoring & Reporting CoP-EHS06 Measurement Proposed plan to measure performance, i.e. Performance indicators Progress against targets EHS initiatives/incentive schemes Achievement of milestones Numbers and types of training courses Numbers and status of audits action items Status / Closure of action items Use will be made of reactive statistical indicators, e.g. Lost Time Injury (LTI) Frequency / Severity Rate Numbers of first-aid and minor injuries Property Damage / Material Loss Vehicle incidents Spillages Occupational illnesses Sickness absenteeism Feedback/ analysis Performance Improvement Plan Availability and use of performance records Feedback/review/discussion at EHS meetings Presentation and distribution to employees Comparison of performance Comparison of performance With other similar contract work Frequency Involvement of Tenant personnel Incident Reporting & Investigation Coverage Verify availability and compliance to ZonesCorp CoP on EHS Accident/Incident Reporting and CoP-EHS03 Reporting procedure covering not only injuries to and time lost by personnel but also: CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Health incidents (diseases, exposures to hazardous substances, near misses, etc) Environmental incidents (spillages, releases, contamination, etc) Other safety incidents (safety equipment failures, loss of capital equipment) Property Damage / Material Loss Methods Incident investigation method established to determine and correct causes Incidents first reported to the direct supervisor Incident investigation teams led by the relevant managers Differentiation made between numbers of first-aid treatments and other minor injuries Procedure in place on vehicle incidents Methods to be used for collecting incident statistics Availability Established EHS procedure outlining responsibilities, frequency, methods and follow-up Section 7 Audit and Review EHS Auditing Verify availability and compliance to ZonesCorp CoP on EHS Audits & Inspections CoP-EHS11 Scope Compliance with the EHS Plan including: EHS Management System Workers / Staff EHS Technical Personnel EHS Contractor Occupational Health Unsafe acts / Conditions Audit Training Environmental Emergency Response CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ESSENTIAL ITEMS TO BE CHECKED Coverage Consistent with Tenant standards and guidelines Construction EHS Management Plans Scope & Requirements Operation EHS Management Plans Scope & Requirements Waste Management Plan Pollution Prevention & Control Plan Inspections and Audits Involvement of personnel in audit teams from outside the location Carried out by a wide cross-section of the workforce including Tenant and subcontractor personnel Effectiveness How verified Involvement of the contractor's corporate management in review of findings Intention to publish findings Discussion with personnel on contract and at EHS meetings Lessons used to improve operations across the contract Follow-up Any numerical treatment made of findings Frequency of review of implementation progress Rejections of audit findings properly authorised and documented CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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Annexure 4 EHS AUDIT CONCERN
EHS audit concern can be divided into two main categories: 1. Administrative Controls
Like assignment of responsibilities, emergency preparedness, employee awareness, acceptance of responsibility and participation, identification, control and monitoring of potential hazards, management leader ship, Safety & Environment rules, regulation and procedure, Safety training, Record keeping etc.
Following list is intended only as a guide in reviewing administrative control items. 1.1 Safe Operating Procedure (SOP) / Regulations Safe Operating Procedure (SOP) / Regulations
HSE Procedures Awareness Incident Reporting Safety Talk Procedure Implementation Work Permit Procedure Awareness Lockout /Tag out Safety Inspection Reports / Follow-up Material Safety Data Sheets available / accessible 1.2 Training
Safety and Environment Training Emergency Response Awareness First Aid Training / Awareness Other: 1.3 Records
Incidents Safety Equipment Services / Inspection Logs Training Other:
1.4 Other:
HSE Posters Emergency phone listings CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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2. Physical Controls To provide a safe workplace requires control of the physical environment the surrounding and external conditions that influence the daily operation of the establishment, including the possibility of injury to employees. Physical concepts may include compliance to regulations and laws, identification of exposures, safeguarding exposures, hazard protection & guarding, environment control etc. 2.1 Machinery and Equipment
Equipment in good condition Equipment is clean and labelled General safeguarding provided and in place Operators properly attired (no loose clothing,) No unnecessary leakage Regularly inspected Others 2.2 Materials Handling and Storage
Manual materials handling equipment in good condition Powered material handling equipment in good condition Hazardous Materials handled, stored and transported in accordance to HSE procedures and regulatory requirements Housekeeping good Storage areas properly illuminated & ventilated Cylinders transported, stored in upright position AND properly secured Shipping/receiving areas in good condition Racking and other storage procedures followed Wheel chocks and restraint devices available / functioning properly Others: 2.3 Hand and Portable Power Tools
Correct tools provided Hand tools and power equipment in good condition Guards are in place, adjusted properly Grinding wheel tools in good condition Regular inspection of tools conducted Stored tools are locked and /or secured Other: CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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2.4 Fire Protection
Portable fire extinguishers / Fire Monitors / Fire Water Hoses: Provided as required Inspected as marked Labelled properly Location identified Locations are readily accessible Fixed Fire System In good condition & inspected/tested regularly Fire Alarm System Tested (as required) Emergency exit doors in good operating condition Exits marked and accessible Fire detectors working Other: 2.5 Electrical
Outlet boxes covered and intact Electric cords properly routed Office electrical equipment in good condition & right connected No connection / circuit overloaded Outlet circuit properly grounded Portable electric tools: Good condition Protected against shock Grounded as required Electric tools and receptacles grounded Switches properly identified and in clean, closed boxes Circuit fuses, circuit breakers identified Extension cords in good condition & approved Motors are clean, free of oil grease 2.6 Housekeeping
Work areas maintained in clean and properly Floors, aisles, work area free of abstraction, slipping and tripping hazards Washrooms and change facilities are clean and well maintained No spill around the equipment or in walkway Tools, equipment and material properly stored and not in use Waste material stored in appropriate containers and disposed of in a safe manner Workplace well ventilated and illuminated Safety & other area sign boards in good condition Drain channels covered and clean CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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2.7 Personal Protective / Safety Equipment
Awareness about the use of Personal Protective Equipment (PPE) Compliance to use of PPE PPE are in place and well maintained Breathing Apparatus are inspected regularly and intact PPE Provided as Required (determined by exposure) Head protection Eye protection Ear protection Foot protection Hand protection Exposure proof Clothing Respiratory protection Safety Shower / Eye Washer Provided as required In good condition Located visibly Accessible Inspected regularly 2.8 Health & Environmental Controls Odours that may indicate unhealthy conditions Noise level while work is under way Clean and free of debris, spilled materials, dirt, etc. Lighting and illumination satisfactory in all areas Hygienic conditions Spill Control / Secondary Containment CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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FM-ZCEHSCOP11-01 EHS AUDIT CHECKLIST FOR FACILITIES RECOMMENDED FORMAT Location/Area: Date:
Physical Control Machinery & Equipment Electrical Condition Condition
Safeguarding Protection
Labeling Housekeeping Hand & Power Tools Slip/Trip/Fall
Condition Drain Channels
Use Waste Disposal
Storage Any Spill / Leak
Safe Storage of Items
Personal Protective Equipment (PPE) Emergency Exit
Availability Material Handling & Storage Condition Equipment Condition
Compliance SOP Followed
Fire Protection Equipment Storage Condition
Identification Health & Environment Controls Availability Ventilation Condition Illumination
Accessibility Noise Level Inspected Spill Control / Sec. Containment
Knowledge to Use Hygiene Conditions
CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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ITEM CHECKED REMARKS ITEM CHECKED REMARKS Safety Shower / Eye Washer / First Aid Box (as applicable) Other Unsafe Conditions Availability Accessibility Condition Inspection
Audit Team Members Signature:
Name / Designation
CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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FM-ZCEHSCOP11-02 EHS AUDIT CHECKLIST FOR BUILDING RECOMMENDED FORMAT
Area / Building / Floor No. Inspection Date: Inspected By: Location: = Satisfactory X = Needs improvement N/A = Not applicable
No. AREA / ACTIVITY FINDING WORK ENVIRONMENT 1. Office well Illuminated. 2. Ergonomic hazards, e.g. awkward posture, prolonged repetitive motion, etc. 3. Work area is clean, orderly and dont present any hazard 4. Area Ventilation and Humidity Level 5. Clean Environment (free of cigarettes smoke, fumes or bad smell etc.) 6. Smoking habits & provisions 7. Computer monitors are positioned or guarded to avoid glare. 8. AC thermostats are working properly. 9. Unobstructed air movement and vents 10. Chairs and chairs caster are in good condition 11. Noise Pollution 12. Paper shredder guarded 13. Common use office items within easy reach of employee while seated 14. Sharp edge office items stored with sharp side down 15. Dustbins available and cleaned up regularly 16. Rubber or plastic floor mats are provided to prevent the chair from rolling off? 17. Employees tea/coffee habits while working on Personal Computer 18. Others: CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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No. AREA / ACTIVITY FINDING REMARKS
OFFICE LAYOUT 1. Furniture is arranged to avoid any potential hitting hazard 2. Furniture posing no obstruction during emergency evacuation 3. Furniture with no potential hitting hazard (sharp edges or corners) 4. Furniture layout facilitates employees for easy movement 5. Others: REMARKS
WALKING SURFACES (SLIPS/TRIPS/FALLS) 1. Aisles correctly established and clear 2. Are passageways and work areas clear of obstructions? No tripping hazards. 3. Floors dry - not slippery 4. Cords (Electrical, Telephone etc.) not stretched across aisles or under carpets 5. Entrance mats available and used in wet weather 6. Carpet is secure and free of tears, lumps or loose pieces 7. Trash bins are not posing any tripping hazard 8. Floor level posing no tripping hazard 9. Others:
CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
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No. AREA / ACTIVITY FINDING REMARKS
ELECTRICAL SAFETY 1. Electrical outlets not overloaded 2. Equipment properly grounded (3 pronged plugs) 3. Electrical cords and plugs are in good condition 4. Extension cords are not substituted for permanent wiring 5. Electrical sockets/switch are visible & accessible 6. The multiple outlet strips have a circuit breaker 7. Cord guards are provided across an aisle or other pathways 8. 3 way switches are safe and of good quality 9. All extension cords connected directly to wall socket, no multiple extensions 10. Others: REMARKS
STAIRWAYS, AISLES, STORAGE ROOMS, HALLS, 1. Adequate lighting in stairways, aisles and storage rooms 2. Stairways clear - not cluttered 3. Stair treads in good condition 4. Handrails installed and in good condition 5. Halls kept clear of equipment and supplies CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
Document No ZC-COP-EHS11 Rev. No. 0 Date of Issue 21 Sept. 2008 Industrial Sector Environment Health & Safety Regulatory Framework Page 67 of 70
No. AREA / ACTIVITY FINDING 6. Housekeeping good in storage rooms 7. Others: REMARKS
EMERGENCY PROTECTION 1. Emergency exit doors clearly marked and accessible 2. Emergency exits doors closed securely all the times 3. Emergency contact number clearly posted 4. Fire extinguishers available and fully charged 5. Fire extinguishers are visible and accessible 6. Fire extinguishers inspected regularly 7. Fire alarm call points visible & accessible 8. Smoke detectors & sprinklers clear from any obstruction 9. Smoke detectors & sprinklers test program 10. Accident/Incident reporting Form available? 11. Others: REMARKS
COOKING AREA 1. General hygiene conditions 2. Electric Appliances Condition CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
Document No ZC-COP-EHS11 Rev. No. 0 Date of Issue 21 Sept. 2008 Industrial Sector Environment Health & Safety Regulatory Framework Page 68 of 70
No. AREA / ACTIVITY FINDING 3. Electric Connections & Fittings 4. Grounding Provided as Required 5. Potential contact with electrical/hot equipment 6. Potential hazard of water contact leading to electric shock 7. Drinking Water Filter condition and change frequency 8. Waste disposal 9. Others: REMARKS
MATERIAL STORAGE & HANDLING 1. Bookcases, cabinets and shelves are not overloaded 2. Heavy storage shelves are properly secured to wall 3. Only one drawer in a file cabinet is opened at any one time to prevent tipping 4. File drawers closed when not in use 5. Bookcases and cabinets secured against tipping 6. File cabinets positioned to avoid being caught in between to objects when opened. 7. File cabinets, drawers, doors positioned to avoid opening into an aisle or walkway. 8. Safe step stools and ladders properly used when needed 9. Items are stored on shelves properly stacked & weight distributed evenly 10. Tables & drawers are in good condition 11. Waste combustible material (papers, files etc.) not pileup in office/cabinets 12. Cabinets are positioned to avoid any accidental fall of stored material on employee 13. Files/folders are stored properly in cabinets to avoid any accidental fall while handling
CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
Document No ZC-COP-EHS11 Rev. No. 0 Date of Issue 21 Sept. 2008 Industrial Sector Environment Health & Safety Regulatory Framework Page 69 of 70
No. AREA / ACTIVITY FINDING 14. Portable machines & temporary devices are positioned for not to be knocked over 15. Employees are aware about safe lifting techniques 16. Material storage is not obstructing light or ventilation 17. No unsafe practice e.g. using chairs as step stools, improper storage, etc 18. Chemicals (toilet cleaners, detergent etc.) are stored separate & secured 19. Others: REMARKS:
AUDIT TEAM NAME SIGNATURE DESIGNATION DATE
CODE OF PRACTICE GUIDELINES EHS AUDIT AND INSPECTION
Document No ZC-COP-EHS11 Rev. No. 0 Date of Issue 21 Sept. 2008 Industrial Sector Environment Health & Safety Regulatory Framework Page 70 of 70
FM-ZCEHSCOP11-03 EHS INSPECTION CHECKLIST RECOMMENDED FORMAT LOCATION / AREA: Date / Time of Visit: TYPE OF REPORT: INITIAL [ ] FOLLOW-UP [ ] ITEMS TO BE CHECKED (UNSAFE CONDITIONS / UNSAFE ACTS) PPE COMPLIANCE (As Applicable) Safety Glasses, Safety Helmet, Ear Plugs, Goggles/face shields, Safety Shoes, Gloves, Fall Protective, Face Masks, Protective Clothing, Uniform FIRE PROTECTION Fire Extinguishing Equipment condition, availability & accessibility, Info signs. TOOLS (As Applicable) (Condition & Storage) Power Tools (Hydraulic, Pneumatic, Electrical, Grinders, Jack Hammers, etc.), Hand Tools HOUSEKEEPING Aisles, Stairs, Floors, Walkways, Material Storage, Exits, Egress, Offices, Dining Facilities, Wash Room, Waste Disposal, Parking Area, Workshops, Trenches, Drains, Tripping Hazards, Spills VEHICLES & EQUIPT. Tankers, Trucks, Forklift, Elevators, Cranes, Hoists, Cables, Ropes, Chains, Slings, Compressors, Electricity Generators, Gas Cylinders (storage, proximity distance), Safety Shower MACHINERY Belts, Conveyers, Pulleys, Gears, Machine Guarding, shafts, Cleaning, Oil spills, leakages etc. MISCELLANEOUS Materials Storage including Flammables and Hazardous Chemicals (compatibility issue), Material Labelling, Protection for Dusts, Vapour, Fumes, Excavations, MSDS, Ladders, Scaffolds, First Aid Kit, Light and Ventilation, Warning / Safety Signs, etc. FINDINGS RECOMMENDATIONS ACTION BY
Use Separate Sheets if Required
PREPARED BY (Inspection Team)
Name / Position / Sign.
Copy: Responsible Department / Section (as mentioned in column 3) / HSE Department