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HIGHER CORPORATION FOR
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CODE OF PRACTICE ON
COMPLIANCE ENFORCEMENT
ZonesCorp CoP - EHS12
APPROVED BY:
DATE: 21 SEP2008
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CODE OF PRACTICE
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REVISION HISTORY

Rev. No. Issue Date Revised Section Revision Description
0 New document





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



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TABLE OF CONTENTS

1 PURPOSE 4
2 SCOPE 5
3 DEFINITIONS 6
4 EXISTING APPLICABLE LAWS 8
5 RESPONSIBILITIES 10
6 PRINCIPLES OF ENFORCEMENT 12
7 THE ENFORCEMENT PROCESS 16
8 REFERENCES 22
9 ANNEXURE 1: LIST OF EHS CODES OF PRACTICE 23
10 ANNEXURE 2: LIST OF PENALTIES FOR NON-COMPLIANCE 25
11 ANNEXURE 3: TEMPLATE FOR ENFORCEMENT NOTICE 34




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1 PURPOSE
Based on the power vested by the Executive Council of Emirates of Abu Dhabi
on the EHS Higher Committee, it has designated Higher Corporation for
Specialized Economic Zones ZonesCorp as the EHS Regulatory Authority
for the Industrial Sector within Abu Dhabi Emirate. Also the Executive Council
has designated the Environment Agency Abu Dhabi (EAD) as the Competent
Authority of EHS Management within Abu Dhabi Emirate. ZonesCorp in its
Regulatory Role is the enforcement agency for the Entities within Industrial
Sector while interacting with the concerned Govt. Agencies (EAD, Civil
Defense etc.) for fulfilling the applicable regulatory requirements like EHS
Permitting etc.
The provisions of the Federal Law No. 24 and Abu Dhabi Emirate EHS Law
have outlined the mechanism of Protection & improvement of the Environment.
The EHS law also has clearly established the principle of self regulation by
entities.
A legal instrument to establish the enforcement mechanism and to define the
policy and approach has lead to the development of this ZonesCorp EHS
Code of Practice. The purpose of this Code of Practice is to outline the
Environmental Health & Safety requirements Enforcement Policy. The
objectives of the Enforcement Policy are:
a. To ensure that those on whom the laws places duties (duty holders)
take action to deal immediately with serious risks;
b. To promote and achieve sustained compliance with the laws;
c. To ensure that duty holders who breach environment, health and safety
requirements, and owner or the management of the entity who fail in
their responsibilities can be held accountable which may include
bringing alleged offenders before the courts.
The purpose of this document is to set out the Enforcement Policy by which
ZonesCorp on behalf of the EHSMS Higher Committee for the Emirate of Abu
Dhabi ensures compliance with Environment, Health & Safety legislation. The
purpose of the policy is to ensure that enforcement decisions are always
consistent, balanced, fair, targeted, accountable, transparent, proportional and
relates to common standards to ensure no harm to people, environment,
property and the public at large is adequately protected.
The ultimate aim of ZonesCorp is to ensure that duty holders manage and act
to control risks effectively, thus preventing any harm to people, environment,
property and the public at large.


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2 SCOPE
These requirements are applicable to the Entities including but not limited to
industrial units / facilities / commercial operations / workshops / warehouse /
residential cities/ labour camps / construction work sites within the Industrial
Sector in the Abu Dhabi Emirate. These include Industrial Cities but not limited
to Abu Dhabi Industrial Cities (ICADs), Al-Ain Industrial Cities (AAICs) and
other Entities (Industries / residential cities / commercial operations etc.) within
Industrial Sector in the Abu Dhabi Emirates.
The enforcement action would be enforced by ZonesCorp EHS Specialist /
Inspectors based on their best professional judgement and shall be final.
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.



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3 DEFINITIONS
3.1 ACGIH : American Conference of Government Industrial Hygienists
3.2 BEIs : Biological Exposure Indices
3.3 CEMP: Construction Environment Management Plan
3.4 CHSMP: Construction Health & Safety Management Plan
3.5 CoP: Code of Practice
3.6 Construction and Demolition Waste: Waste arising from construction,
repair, maintenance and demolition of buildings and structures. Can
sometimes contain hazardous wastes such as asbestos.
3.7 Duty Owner: Those on whom the law places duties e.g. the Owner / Chief
Executive Offices / Chief Operation Offices / Plant or Factory Manager of the
entity.
3.8 Duty Of Care: A policy which requires all persons who have responsibility for
waste to ensure that it is managed properly and recovered or disposed of
safely.
3.9 EAD: Environment Agency Abu Dhabi
3.10 ECAP: Environmental Compliance Action Plan
3.11 Entity: Facilities within Industrial Sector including Industrial, Commercial
Residential and Welfare
3.12 EHS: Environment Health & Safety
3.13 EHS Construction Permit: Issued after review and approval of CEMP,
CHSMP, FSP & TMP and valid for a period of 1 Year
3.14 EHSMS Environment Health & Safety Management System
3.15 EHS Operation Permit: Issued after review and approval of OEMP, EHSMS,
WMP, ERP & ECAP and valid for a fixed duration to be renewed thereafter
subject to compliance conditions.
3.16 ESP: Environment Service Provider approved by EAD
3.17 Fixed Penalty Notices : A written notice served to an entity identifying the
EHS noncompliance and the financial penalty to be paid within the stipulated
time frame
3.18 Flora: Any vegetation including plants, trees, etc.
3.19 Fauna: Includes flora & faunas, insects, reptiles, marine life etc.
3.20 FRMP: Fire Risk Management Plan
3.21 Hazardous Waste: Wastes may be defined as hazardous on the basis of
waste characteristics (e.g. Flammable, Ignitable, Toxic, Mutagenic, Reactive,
Corrosive, etc.) or waste may be defined as hazardous on the basis of 'Listing'

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(i.e. are any components of the waste stream listed as hazardous; in
Hazardous Waste Regulation).
3.22 IETP: Industrial Effluent treatment Plant
3.23 Improvement Notices: A written notice served to an entity identifying the EHS
noncompliance and suggesting the required improvement within prescribed
time frame
3.24 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
Facilities (Labour Camps) for Industrial Sector
3.25 IOSH: Institute of Occupational Safety & Health
3.26 KPI: Key Performance Indicators are a measure (or benchmark) of
performance of a particularly activity with reference to applicable standards
and timescales for frequency of measurement.
3.27 LEV : Local Exhaust Ventilation
3.28 NIOSH: National Institute Occupational Safety & Health
3.29 OEMP: Operation Environment Management Plan
3.30 OHSMP: Operation Health & Safety Management Plan
3.31 OSHA: U. S. Occupational Safety & Health Administration
3.32 OSS: ZonesCorp One Stop Shop
3.33 PELs : Permissible Exposure Limits
3.34 Prohibition Notices: A written notice served to an entity identifying the EHS
noncompliance and requiring offender to cease contravening activities, giving
offender reasonable time to rectify a contravention
3.35 RELs : Recommended Exposure Limits
3.36 Tenant: Project Proponent / Lease Holder / Concession Agreement Holder /
Owner / Operator of an entity within the Industrial Sector in Abu Dhabi Emirate
3.37 TMP: Transport Management Plan
3.38 TLVs : Threshold Limit Values
3.39 WMP: Waste Management Plan
3.40 Worker: Personnel primarily working in Industrial Sector within Abu Dhabi
Emirate, including but not limited to Abu Dhabi Industrial Cities (ICADs), Al-Ain
Industrial Cities (AAICs) and Mussafah Industrial Area, Worker Residential
Cities, Labour Camp, as well as contractor personnel etc.
3.41 ZonesCorp: Higher Corporation for Specialized Economic Zones
Development

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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

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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.

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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 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.
5.3.2 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.

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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.

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6 PRINCIPLES OF ENFORCEMENT
6.1 General
Enforcement of environmental, health and safety requirements should only be
undertaken for the purposes of:
a. Better protecting the environment and its economic and social uses;
b. Ensuring that no commercial advantage is obtained by any person who fails to
comply with environmental and/or health and safety requirements; and
c. Influencing the attitude and behaviour of persons whose actions may have
adverse environmental, and/or health and safety impacts, or who develop,
invest in, purchase or use goods and services which may have adverse
environmental and/or health and safety impacts.
ZonesCorp as the Industrial Sector EHS Regulatory Authority is committed to
the principles of self regulation and good enforcement of all Federal as well as
Local EHS Laws and regulations including the requirements of the ZonesCorp
EHS Code of Practices. ZonesCorp believes in strong, fair and effective
enforcement of Environment, Health and Safety regulations.
In line with the policy of self regulation as per the EHS law, entities having
established an EHSMS are required to demonstrate self regulation, failing
which if the regulatory authority (ZonesCorp) may find an EHS non
conformance will take enforcement action against the entity.
ZonesCorp has a range of tools at their disposal in seeking to secure
compliance with the regulations. ZonesCorp EHS Specialists / Inspectors may
provide duty holders information, both face to face and in writing. This may
include warning a duty holder that in the opinion of the inspector, they are
failing to comply with the regulations. Where appropriate, ZonesCorp EHS
Specialists / Inspectors may also serve improvement and prohibition notices,
issue formal cautions or revoke EHS Permit / Licence
Giving information, issuing improvement or prohibition notices are the main
means which inspectors use to achieve the broad aim of dealing with serious
risks, securing compliance with environment, health and safety regulations and
preventing accidents. A prohibition notice stops work in order to prevent
serious personal injury or anything that may be cause immediate danger to life
or health. Information on improvement and prohibition notices shall be made
publicity available.
Every improvement notice / prohibition notice / fixed penalty notice contains a
statement that in the best professional judgement of the ZonesCorp EHS
Specialists / Inspectors a non-compliance has been committed.
Investigating the circumstances in presence of the entity representative
encountered during audits, inspections or following incidents or complaints is
essential before taking any enforcement action.

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ZonesCorp EHS enforcement will follow the following principles:
6.1.1 Proportionality
Proportionality means relating enforcement action to the risks.
In practice, applying the principle of proportionality means that ZonesCorp as
the Industrial Sector EHS Regulatory Authority shall take particular account of
how far the duty holder has fallen short of what the regulations requires and
the extent of harm to the environment or the extent of the risks to the people
arising from the breach.
Where duty holders must control risks so far as is reasonably practicable,
ZonesCorp consider protective measures taken by duty holders, shall take
account of the degree of risk on the one hand, and on the other the reasonable
practicability, whether the money, time or trouble, involved in the measures is
necessary to avert the risk. Unless it can be shown that there is gross
disproportion between these factors and that the risk is insignificant in relation
to the cost, the duty holder must take measures and incur costs to reduce the
risk. The ZonesCorp specialist's decision on the extent of risk or potential
harm to people asset and environment shall be the final.
ZonesCorp will expect relevant good practice to be followed. Where relevant
good practice in particular causes is not clearly established, health and safety
regulations effectively requires duty holders to establish explicitly the
significance of the risks to determine what action needs to be taken.
Some irreducible risks may be so serious that they cannot be permitted
irrespective of the consequences or any kind of rational being put forward by
the duty holder.
6.1.2 Consistency
Consistency of approach does not mean uniformity. It means taking a similar
approach in similar circumstances to achieve similar ends.
Duty holders managing similar risks expect a consistent approach from
ZonesCorp in the use of enforcement notices, penalties and in the response to
incidents.
ZonesCorp as the Industrial Sector EHS Regulatory Authority recognizes that
in practice consistency is not simple matter. ZonesCorp EHS Specialists /
Inspectors may face with many variables including the degree of risk, the
attitude and competence of management, EHS audit / inspection findings,
EHS performance reports, any history of incidents or breaches involving the
duty holders, previous enforcement action, and the seriousness of any breach,
which includes any potential or actual harm arising from a breach of
regulations. Decisions on enforcement action are discretionary by the enforcer
(ZonesCorp EHS Specialists / Inspectors).
ZonesCorp as the Industrial Sector EHS Regulatory Authority shall have
arrangements in place to promote consistency in the exercise of discretion,

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including effective arrangements for liaison with other enforcing authorities
(EAD, Civil Defence, Municipality etc.).
6.1.3 Transparency
Transparency means helping duty holders to understand what is expected of
the entities and what they should expect from the ZonesCorp as the Industrial
Sector EHS Regulatory Authority. It also means making clear to duty holders
not only what they have to do but, where this is relevant, what they dont. That
means distinguishing between statutory requirements and advice or guidance
about what is desirable but not compulsory.
When ZonesCorp EHS Specialists / Inspectors offer duty holders information,
face to face or in writing, including any warning, ZonesCorp EHS Specialists /
Inspectors will explain the duty holder what needs to be done to ensure
compliance to the EHS Laws and regulations, and why.
6.2 Enforcement Actions
An enforcement action would be preceded by a routine audit / inspection
finding of EHS non-compliance or a poor EHS performance report or a follow-
up investigation of an EHS incident including accidental release or
environmental discharge.
The possible outcomes of an inspection or investigation are: -
Take no action only verbal warning
Take informal action issuing written warning / improvement notice
Use prohibition notices, equipment seized, premises closed etc.
Refusal / revocation of EHS licence / permit
Fixed penalty
Recommend legal action
These actions are discussed in further detail in Section 7 of this Code of
Practice. It may be that one or more of these outcomes would be appropriate
in any given case.
In the case of improvement notices the ZonesCorp EHS Specialists /
Inspectors will discuss the notice and, if possible serving it. The improvement
notice will explain that in the ZonesCorp EHS Specialists / Inspectors have
observed a breach of the difference has been committed, what needs to be
done to comply with the regulations and by when.
In the case of a prohibition notice the ZonesCorp EHS Specialists /
Inspectors will explain the description of violation and why prohibition is
necessary.
Each case is unique and must be considered on its own merits. There are
however general principles that apply in the way each situation must be
approached. This document sets out the factors to be taken into account when

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considering the type of enforcement action to be taken. The policy must be
followed except in exceptional circumstances.
The ZonesCorp EHS Specialists/Inspectors are authorised to take action, and
are required to follow the policy and the lines of responsibility in terms of
decision-making, as laid down in this documents. The decision and judgement
of ZonesCorp EHS Specialists/Inspectors shall be considered final.
6.3 Baseline Environmental Incidents
In case of environmental the entity shall be required to undertake
environmental remediation as per the Emirate Environmental Protection Policy
(EEPP) or the legal baseline. The legal baseline for the industrial cities shall
be the data submitted as a part of the Environmental Impact Assessment
Report.
All Incidents shall be reported to ZonesCorp in line with ZonesCorp Code of
Practice on Accident / Incident Reporting & Investigation (CoP-EHS05)
6.4 Penalties
Penalty or Citation or Fine shall be charged to an Entity for any non-
compliance of EHS Laws / Regulations / EEPPs / Standards / Requirements of
ZonesCorp Code of Practices etc. A list of ZonesCorp Code of Practices is
given in Appendix 1 which is subject to change as deemed necessary by
ZonesCorp.
Penalty shall be payable over and above the cost of environmental
remediation or repair of damaged property or any legal compensation payable
to affected parties / governmental agencies. Also the entity shall bear the cost
of investigation (not included in the penalty) like sampling, testing, analysis etc.
A base guideline for penalties, not including and over & above any legal
compensation payable is provided in Appendix 2. These are subjected to
change as and when deemed necessary by ZonesCorp.
Based on the Severity of Consequences the penalty value could increase from
the minimum base guidelines as given in Appendix 2.The penalty would be
fixed by ZonesCorp EHS Specialist / Inspectors based on their professional
judgement and shall be final.
6.5 Owners Responsibility
The EHS Specialist / Inspector's functions all relate to events in a place of
work. In case of a transfer of facility ownership the new owner shall ensure
that the facility is totally EHS compliant and or may get himself indemnified
from the non-compliant actions of the previous owner. However, all
enforcement actions or legal proceedings shall be instituted against the current
owner and as per the prevalent UAE law and requirements of the concerned
Competent Authority.


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7 THE ENFORCEMENT PROCESS
The requirements of the EHS Law, regulations, ZonesCorp EHS Code of
Practices shall be taken into account during an EHS non-compliance
investigation. The ZonesCorp EHS Manager is referred as the Industrial
Sector EHS Regulatory Authority and shall ensure that fair and consistent
decisions are made about enforcement.
7.1 Enforcement Policy
7.1.1 Self Regulation by Entity No Action by Regulatory Authority
Self-regulation is a concept designed to enhance protection of human health
and the environment by encouraging the regulated community to voluntarily
discover, disclose, correct, and prevent violations of relevant laws.
To participate in self-regulation the entity must be able to demonstrate that
they:
a. Have identified, and know the implications to the entity of, all relevant
environmental, health and safety legislation;
b. Provide for legal compliance with relevant legislation; and
c. Have procedures in place that enable the entity to meet these
requirements on an ongoing basis.
Entities having established an EHSMS and are able to demonstrate self
regulation identifying EHS non-conformance themselves and reporting to the
Industrial Sector EHS Regulatory Authority along with a Corrective Action
Plan and Commitment Statement to ensure compliance at the shortest
possible practicable timeframe.
The Corrective Action Plan shall clearly identify the root cause for the non-
compliance. The Corrective Action Plan and Commitment Statement shall be
subject to acceptance as discussed in Section 7.2
However since the entity has identified and declared the EHS non-conformity
in line with the principles of self regulation, enforcement of penalties shall be
reviewed in accordance to the requirements of this CoP..
Also in the circumstance where compliance with legislation has been achieved
or the expectation can be achieved by issuing a verbal warning, no action
would be taken. However in case of verbal warning the entity shall submit
compliance report to ZonesCorp within the stipulated time. ZonesCorp EHS
Specialists / Inspectors shall physically verify the compliance based on the
entity's report.

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7.1.2 Informal Action
Informal action to secure compliance with the legislation includes providing
Information issuing Warnings and Improvement Notice (format given in
Appendix 1).
In the following circumstances it may be appropriate to use informal action.
This is not an exhaustive list and each case must be looked at on its merits:
a. The activity or omission is not serious enough to warrant formal action.
b. From the Entitys past history it can be reasonably expected that
informal action will achieve compliance.
c. Where the original approach is from person(s) seeking advice or
assistance (however, if serious breaches are found then formal action
will be necessary).
When an informal approach is used to secure compliance, this may be verbal
or written. However it is important that any written documentation issued or
sent to individuals / businesses:-
a. Contains all the information necessary to understand what work is
required and why it is necessary.
b. Indicates the statute or laws or regulations contravened and measures
which will enable compliance to be achieved.
c. Clearly differentiates between legal requirements and recommendations
of good practice.
d. The stipulated time frame for the compliance of the contravened law or
regulations.
7.1.3 Prohibition Notices, Equipment Seized or Closure of an Operation /
Construction
Prohibition Notices shall be served to require offenders to cease contravening
activities or seize the subject equipment, give offenders reasonable time to
rectify a contravention, or require entity owner/manager to provide information.
Prohibition Notices may require contravening activities to cease immediately
where circumstances relating to health, safety, environmental damage or
nuisance demands and serious EHS Risks (format given in Appendix 1).
In other circumstances, the time allowed must be reasonable, but must also
take into account the health, safety, environmental damage or nuisance
implications of the contravention.
The circumstances under which Statutory notices shall be considered and
served, equipment seized or closure of a construction / operation would be
such that require immediate action otherwise could lead to serious
consequences to Health & Safety of People or damage to Environment.

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7.1.4 Fixed Penalty for EHS Non-Compliance
Fixed Penalty Notices will be issued under specified legislation. If a fixed
penalty is not paid within the prescribed period, legal proceedings shall be
instituted. Even if the entity pays the fixed penalty but fails to comply with the
legal requirements, legal proceedings shall be instituted.
In case of environmental incidents over and above the fixed penalty, the entity
shall bear the cost of environmental remediation as per the EEPP or the legal
baseline.
The structure of fixed penalties is given in Annexure -2.
7.1.5 Refusal / Revocation of EHS Licence / Permit
Licences, Approvals and Permits are issued under specific legislation and the
requirements of the circumstances that allow refusal / revocation of licence
etc. shall be taken into account in accordance with the legislation.
In order to warrant refusal / revocation of an EHS Licence or Permit, the Entity
must meet one or more of the following criteria:
a. Engage in fraudulent activity (hiding an activity / undertaking an
unauthorised activity / providing wrong or fabricated information)
b. Deliberately or persistently breach legal obligations (including the
requirements of ZonesCorp EHS Code of Practice)
c. Deliberately or persistently ignore written warnings or formal notices
d. Endanger to a serious degree the health, safety or well being of people,
flora & faunas or the environment
e. Failure to pay fixed penalty in case the entity fails to pay the fixed
penalty within the stipulated time frame
f. In cases of wider public interest, or if there is significant expenditure
involved in compliance which jeopardises the financial viability of a
business, reference may be made to the Licensing Authority.
7.1.6 Recommend Legal Action
In case an Entity that blatantly disregard the law, refuse to achieve even the
basic legal standards and / or who put the public at risk even after repeated
warnings / disregard other enforcement actions like fixed penalty etc.
ZonesCorp EHS Manager may recommend to the Concerned Competent
Authority for legal action, which may include filing a legal case against the
entity in the court of law. A recommendation for legal action would be made if
the Entity falls under one of the following criteria:
a. Flagrant Breach of Law For example, where there is an apparent
blatant breach of law such that public health, safety or well being, flora
& fauna health or welfare is put at serious risk, it would be appropriate
to recommend legal action.

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b. Failure to Comply with a Prohibition Notice legal action may be
recommended in cases of failure to comply with improvement notices or
other notices requiring actions to ensure compliance.
c. Failure to Pay Fixed Penalty legal action may be recommended in
cases of failure to pay fixed penalty and also fulfil required improvement
actions to ensure compliance.
d. Failure to Comply with Lawful Requirements If the operator of an
Entity fails to comply with lawful requirements, having been advised on
previous occasion(s), legal action shall be recommended.
e. History of Non-compliance If there is a history of non-compliance
with law by the operator of a business or by an individual then legal
action shall be recommended even if the matters identified are not
flagrant breaches of law.
f. Community Benefit Legal action shall be recommended on the first
occasion that certain events are witnessed because of the extreme
improbability that the person once seen committing an offence would be
seen on a subsequent occasion. Community benefit of a legal action
would also be indicated by the importance of the case, for example,
whether it might establish a legal precedent.
g. Obstruction Legal action shall be recommended in cases of
deliberate obstruction of a ZonesCorp EHS Specialist/Inspector.
7.2 Corrective Action Plan
In case an EHS non-conformity is identified whether by the entity themselves
or by the Industrial Sector EHS Regulatory Authority or a third party external
auditor, the entity shall be required to develop within 15 calendar days, a
Corrective Action Plan and Commitment Statement to ensure compliance at
the shortest possible practicable timeframe and submit the same to Industrial
Sector EHS Regulatory Authority. The Corrective Action Plan shall clearly
identify the root cause for the non-compliance, immediate action taken and the
time frame for closing the non-compliance.
The Corrective Action Plan and Commitment Statement shall be reviewed by
the Industrial Sector EHS Regulatory Authority and depending upon the
severity of the consequences, the same may be accepted or may advice the
entity to cease contravening activities or seize the subject equipment until the
corrective action has been implemented and compliance has been achieved.
On receipt of the conformity report submitted by the entity, the Industrial
Sector EHS Regulatory Authority shall physically verify the compliance on site
if the need be through a process of environmental assessment and close out
the non-conformity.

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7.3 Shared Enforcement Role
Before proceeding with any action ZonesCorp EHS Specialists / inspectors
shall consider if there is a shared or complementary enforcement role with
other agencies e.g. Civil Defence, Environment Agency Municipality, ADWEA
etc. and liaise with such agency.
7.4 Power of EHS Specialist / Inspectors
EHS Specialists / Inspectors may enter a place of work / Entity's premises for
the purpose of carrying out any of the functions
A visiting EHS Specialist / Inspector is not required to give advance notice,
except where the visiting time or circumstances may be other than what is
"reasonable" in the circumstances.
Access shall therefore be available to any place of work during its regular
working hours (including all shifts), and where there are not other
circumstances which would make the timing of the visit unreasonable.
The EHS Specialist / Inspector may:
a. Conduct investigation including examinations, tests, inquiries interview
an employee and inspections or direct others to conduct them; and/or
b. Seek information, data, records, procedures to satisfy themselves that
the activities are in compliance with the EHS Laws and regulations;
and/or
c. Record statement, take photographs or measurements, or make
sketches or recordings
The EHS Specialist / Inspector may also require the employer or other person
who controls the place of work:
a. Not to disturb the place of work for a reasonable period while any
examination, test, inquiry or inspection is carried out; and/or
b. To produce documents or information relating to the place of work or
the employees who work there, and permit the inspector to make copies
of or extracts from them; and/or
c. To make or provide statements in a specified form or manner about
conditions, material, or equipment that affects the safety or health of
employees who work there or harm to environment.
To carry out these functions, the EHS Specialist / Inspector may be
accompanied and assisted by other people, or bring any necessary equipment
into the place of work.
7.4.1 An EHS Specialist / Inspector is authorised to require a duty holder or any
other person that controls a place of work to make or provide statements
about:

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a. Conditions;
b. Material; or
c. Equipment,
That affects the environment, health or safety of employees.
Such statements may be made in the course of routine inspections, or while
the EHS Specialist / Inspector is investigating an accident or incident.
The statements may be written, oral, or in any other form or manner specified
by the EHS Specialist / Inspector. The inspector's requirement of statements is
in addition to the powers to require documents or other information as set out
above.
A statement provided to an EHS Specialist / Inspector under the provision of
this Code of Practice, or documents or other information provided to the EHS
Specialist / Inspector, may form the basis of enforcement notices issued by the
EHS Specialist / Inspector, or may be used in evidence in any subsequent
court proceedings.
7.5 Authorisation Of Documents
Individuals authorised to sign various documents (Improvement Notice /
Prohibition Notice / Fixed Penalty / Revocation of EHS Permit etc.) on behalf
of the Industrial Sector Regulatory Authority shall, in general, have the level of
experience and responsibility of the post as referred to in their job descriptions
and specifications and outlined in the scheme of delegations and associated
documents.
EHS Specialist / Inspector shall sign and issue Improvement Notice /
Prohibition Notice / Fixed Penalty and shall obtain approval of ZonesCorp EHS
Manager for Refusal / Revocation of EHS Licence / Permit.


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COMPLIANCE ENFORCEMENT

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8 REFERENCES
8.1 ZonesCorp Code of Practice on EHS Management Framework (CoP-EHS01)
8.2 ZonesCorp Code of Practice on EHS Management System (CoP-EHS02)
8.3 ZonesCorp EHS CoP on EHS Impact Assessment (CoP-EHS04)
8.4 ZonesCorp EHS CoP on EHS Incident Reporting & Investigation (CoP-EHS05)
8.5 ZonesCorp EHS CoP on EHS Performance Monitoring & Reporting (CoP-
EHS06)
8.6 ZonesCorp EHS CoP on EHS Compliance Assurance (CoP-EHS11)
8.7 ZonesCorp Code of Practice on Waste Management (CoP-E03)
8.8 ZonesCorp Code of Practice on Crisis Management Plan (CoP-FE05)
8.9 ZonesCorp Building Control Unit Technical Handbook
8.10 EAD EHSMS Volume 2 Section 2 Quality Indicators And Standards

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APPENDIX 1
EHS REGULATORY FRAMEWORK CODES OF PRACTICE &
GUIDELINES FOR INDUSTRIAL SECTOR (Partial List)
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 Industrial Cities 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 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 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 Standards CoP-H03
Safety
1 Construction EHS Management Plan (CEHSMP) CoP-S01
2 Operation Health & Safety Management Plan (OHSMP) CoP-S02
3 Transport Management Plan (TMP) CoP-S03

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Sr. No. Code of Practice & Guidelines Document No.
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
5 EHS Manual for Workers Residential Cities CoP-GL05

Note: This list of CoPs and Guidelines is not final, additional Code of Practices will be
developed as deemed necessary by ZonesCorp and communicated to all concerned.

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COMPLIANCE ENFORCEMENT

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APPENDIX 2
PENALTIES FOR EHS VIOLATION
Note: These are base guidelines for penalties not including and over & above any legal compensation
payable. These are subjected to change as and when deemed necessary by ZonesCorp
NO. TYPE OF VIOLATION PENALTY
ZC COP
REFERENCE
1
Failure to establish or non-
compliance to Substance Abuse
Policy
A minimum fine of AED 5,000
EHS01
EHS02
2.
Failure to establish, maintain and
implement the Training Program
including both the Craft and EHS
A minimum fine of AED 5,000
EHS01
EHS02
3
Start Construction or Operation
prior to obtaining the appropriate
EHS Permits
Stop activity, obtain the desired
permit and a minimum fine of
AED 25,000
EHS07,
EHS08, E01,
E02, S01, S02
4
Failure to have the
environmental analysis
performed by an approved
environmental laboratory at the
time environmental study being
undertaken.
Rejection of the analysis results,
requiring that the analysis be
redone by an approved
environmental laboratory and a
fine ranging between AED 3,000
to 5,000
EHS04
5
Incorrect analysis results or
components of environmental
study
Resubmit the study and
imposition of a fine of AED 5,000
to AED 10,000 on the violator
EHS04
6.
Failure to comply with the
undertakings, conditions and
specifications listed in the EHS
studies to obtain the EHS Permit
A fine of AED 10,000 to 50,000
EHS04,
EHS07,
EHS08, E01,
E02
7
Failure to submit the Monthly /
Periodic Reports in accordance
with the EHS Performance
Reports / Construction EHS
Management Plan / Operation
EHS Management Plan and
EHS Permit conditions within the
stipulated time frame (within 7
working days of the last date)
Submit the appropriate Report
within 7 Working days
Suspension or refusal of renewal
of the EHS Permit granted and
imposition of a fine up to AED
5,000
EHS04,
EHS05,
EHS06,
EHS11,
EHS07,
EHS08, E01,
E02, E03, E04,
S01, S02
8
Failure to conserve biodiversity
including killing of a rare species
or cutting of tree
Recommendation for legal action
(proceedings)
EHS04, E01

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PENALTIES FOR EHS VIOLATION
Note: These are base guidelines for penalties not including and over & above any legal compensation
payable. These are subjected to change as and when deemed necessary by ZonesCorp
NO. TYPE OF VIOLATION PENALTY
ZC COP
REFERENCE
9
Failure to apply for renewal of
the EHS Permits one months
ahead of its expiration date
Denial of renewal and or a fine of
minimum AED 5,000 pending
renewal of the EHS Permit
EHS07,
EHS08, E01,
E02, S01, S02
10
Failure to produce, maintain or
implement Waste Management
Plan
A minimum fine of AED 10,000 E03, E04
11
Disposal of untreated / partially
treated sanitary wastewater in
marine environment
A minimum fine of AED 10,000 E03, E04
12
Disposal of untreated/ partially
treated sanitary wastewater on
land
A minimum fine of AED 10,000 E03, E04
13
Discharge (injection) of
untreated/ partially treated
sanitary wastewater into ground
water bodies
A minimum fine of AED 10,000 E03, E04
14
Discharge of treated sanitary /
trade wastewater that does not
confirm to environmental
standards and criteria
A minimum fine of AED 10,000 E03, E04
15
Discharge (injection) of treated
sanitary / trade wastewater that
does not confirm to
environmental standards and
contaminate ground water
A minimum fine of AED 10,000 E03, E04
16 Disposal of sludge in the sea A minimum fine of AED 7,000 E03, E04
17
Disposal of sludge into water
bodies other than marine
environment
A minimum fine of AED 10,000 E03, E04
18
Disposal of sludge in areas that
are not designated for it
A minimum fine of AED 5,000 E03, E04
19
Unauthorized Storage of Material
(outside entitys premises).
A minimum fine of AED 5,000
E01, E02, E03,
E04

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COMPLIANCE ENFORCEMENT

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PENALTIES FOR EHS VIOLATION
Note: These are base guidelines for penalties not including and over & above any legal compensation
payable. These are subjected to change as and when deemed necessary by ZonesCorp
NO. TYPE OF VIOLATION PENALTY
ZC COP
REFERENCE
20
Violations involving sample
collection procedures that are
inconsistent with the criteria.
A minimum fine of AED 3,000 EHS04
21
Violations involving measurement
and analysis procedures that are
inconsistent with the criteria
A minimum fine of AED 3,000 EHS04
22
Pollution/contamination of ground
or surface water with hazardous
or toxic (harmful) substances
Remediation and a fine up to
AED 500,000 (1/2 Million
Dirhams)
E01, E02, E04
23
Pollution / contamination of
underground or surface water
with high concentrations of non-
hazardous pollutants
Remediation and a fine up to
AED 250,000 (1/4 Million
Dirhams)
E01, E02, E04
24
Failure to comply with the
emission monitoring program
A minimum fine of AED 10,000 E01, E02, E04
25
Tampering with monitoring and
observation devices
A minimum fine of AED 15,000 E01, E02, E04
26
Release of pollutants without
advance notice
A minimum fine of AED 10,000 E01, E02, E04
27
Failure to report facility
shutdowns resulting in pollutants
gas emissions
A minimum fine of AED 10,000 E01, E02, E04
28
Neglect the maintenance of pollution
abatement and surveillance &
monitoring equipment
A fine of AED 10,000 to 30,000 E01, E02, E04
29
Failure to operate pollution
abatement, monitoring and
surveillance equipment to the
required efficiency
A fine of AED 25,000 to 100,000 E01, E02, E04
30
Failure to comply with the
procedures related to the
handling of emissions and leaks
in cases of emergency
A fine of AED 10,000 to 25,000 E01, E02, E04

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COMPLIANCE ENFORCEMENT

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PENALTIES FOR EHS VIOLATION
Note: These are base guidelines for penalties not including and over & above any legal compensation
payable. These are subjected to change as and when deemed necessary by ZonesCorp
NO. TYPE OF VIOLATION PENALTY
ZC COP
REFERENCE
31
Open burning of domestic
construction wastes
A minimum fine of AED 10,000 E03
32
Failure to establish or Non-
compliance to Environment
Compliance Assurance Plan
(ECAP)
A minimum fine of AED 10,000 E04
33
Non-compliance to Pollution
Prevention and Control Plan
A minimum fine of AED 10,000 E04
34
Failure to segregate and
properly store Hazardous Waste
A minimum fine of AED 10,000 E03
35
Failure to manage waste as per
the Waste Management Plan
including failure to maintain /
produce proper manifestations
A fine ranging from AED 5,000 to
10,000
E03
36
Unauthorised waste / liquid
waste disposal on land or in
marine environment
A minimum fine of AED 10,000 E03
37
Unauthorised waste / liquid
waste disposal within the
premises of industrial cities of
Abu Dhabi Emirate
A minimum fine of AED 10,000 E03
38
Unauthorised use of scrap or
waste as raw material for
manufacturing packaging or any
other purpose
A fine of AED 10,000 to 30,000
EHS07, E02,
E03, S02
39
Violations by the licensee of the
hazardous waste storage
conditions and specifications
Fine from AED10,000 to 25,000
and EHS Permit cancellation
E03
40
Failure to pack hazardous wastes
in appropriate shockproof and anti
spill and anti-evaporation/
sublimation containers
Fine from AED 5,000 to 10,000
and EHS Permit cancellation
E03
41
Failure to place conspicuous
labels on storage vessels,
Fine from AED 5,000 to AED
10,000, requiring the violator to
E01, E02, E03,
E04, S01, S02

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PENALTIES FOR EHS VIOLATION
Note: These are base guidelines for penalties not including and over & above any legal compensation
payable. These are subjected to change as and when deemed necessary by ZonesCorp
NO. TYPE OF VIOLATION PENALTY
ZC COP
REFERENCE
including the type and hazard
rating, characteristics and UN
number of the stored material
repack the material in
accordance with the
specifications and license
cancellation warning
42
Transportation of hazardous
wastes to the waste collection
facility using a means of
transportation not authorized by
the Competent (EAD) / Regulatory
Authority (ZonesCorp)
Fine from AED 10,000 to AED
20,000 and EHS Permit
cancellation
E03, S03
43
Transportation of hazardous
wastes with incompatible
characteristics and qualities to
the hazardous waste
management facility in one or
the same means of
transportation
Fine from AED 10,000 to AED
20,000 and EHS Permit
cancellation
E03, S03
44
Transport of hazardous wastes
to an agency or facility not
authorized by the Competent /
Regulatory Authority
Fine from AED 2,000 to AED
10,000 and EHS Permit
cancellation
E03
45
Failure to carry the manifest of
the wastes being transported
Fine from AED 10,000 to AED
20,000 & EHS Permit cancellation
E03
46
Excessive noise pollution from
vehicles or Plant / Machinery or
Construction/Operation activity
A minimum fine of AED 5,000
E01, E02, E04,
S01, S02
47
Excavations and construction
works outside designated hours
A minimum fine of AED 5,000
EHS09, E01,
S01, S02
48
Failure to fence off excavations
resulting from construction
activities or failure to maintain
them regularly, thereby exposing
passers by to hazards
Rectify the maintenance of the
fence and excavations.
Imposition of a fine of AED 5000
to 10000
EHS09, E01,
S01, S02
49
Use of un-inspected or faulty
scaffolding
A minimum fine of AED 10,000
EHS09, S01,
S02

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PENALTIES FOR EHS VIOLATION
Note: These are base guidelines for penalties not including and over & above any legal compensation
payable. These are subjected to change as and when deemed necessary by ZonesCorp
NO. TYPE OF VIOLATION PENALTY
ZC COP
REFERENCE
50
Failure to provide safe work
environment including poor
housekeeping
A fine ranging from AED 5,000 to
20,000
S01, S02
51 Failure to display/provide MSDS A minimum fine of AED 2,000
E02, E04, S01,
S02, H01
52
Personal Protective Equipment
(PPE) non-compliance by
personnel
A minimum fine of AED 1,000 H01, S01, S02
53
Failure to provide PPE as per job
requirement
A minimum fine of AED 5,000 H01, S01, S02
54
Failure to undertake risk
assessment and comply to safe
working procedures including
Permit To Work etc.
A minimum fine of AED 5,000
EHS03,
EHS04,
EHS09, S01,
S02
55
Failure to store Gas cylinders
properly including proximity
distances & compatibility issues
A minimum fine of AED 5,000
EHS09, S01,
S02
56
Storage of incompatible
hazardous substances
A minimum fine of AED 5,000
E01, E02, S01,
S02
57
Failure to provide adequate First
Aid & Emergency Equipment like
Eye Wash, Emergency Shower,
Spill Response Kit etc.
A minimum fine of AED 5,000
EHS09, E01,
E02, E04, S01,
S02, H01, H02
58
Failure to undertake regular
workplace monitoring
A minimum fine of AED 5,000 EHS06, H01
59
Failure to conduct and maintain
occupation health monitoring
records
A minimum fine of AED 10,000 EHS06, H01
60
Failure to get lifting equipments
& tools inspected by approved
3
rd
Party
A minimum fine of AED 5,000
S01, S02,
EHS09,
EHS10
61
Use of plants, machines, lifting
equipments & tools NOT
A minimum fine of AED 10,000
S01, S02,
EHS09,

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PENALTIES FOR EHS VIOLATION
Note: These are base guidelines for penalties not including and over & above any legal compensation
payable. These are subjected to change as and when deemed necessary by ZonesCorp
NO. TYPE OF VIOLATION PENALTY
ZC COP
REFERENCE
inspected by approved 3
rd
Party EHS10
62
Failure to get pressure vessels
etc. inspected by approved 3
rd

Party
A minimum fine of AED 5,000
S01, S02,
EHS09,
EHS10
63
Conducting heavy lifting
operation without the presence
of a Competent Rigger
A minimum fine of AED 5,000
S01, S02,
EHS09,
EHS10
64
Failure to establish ERP or display
emergency contact numbers,
mark emergency exits etc.
Submit the ERP approved by
Civil Defence within 15 working
days and a minimum fine of AED
10,000
EHS07, FE03
65
Failure to train all concerned on
ERP and undertake drills as per
plan
A minimum fine of AED 5,000 EHS07, FE03
66
Failure to report incidents to
Industrial Sector Regulatory
Authority
A minimum fine of AED 5,000
EHS05,
EHS06
67
Endangering human life by
engaging personnel without
proper craft training or experience
to hazardous activities
A minimum fine of AED 10,000
EHS01,
EHS02,
EHS03
68
Sheared Enforcement:
Unauthorized Operation of a
facility that the concerned
agency has ordered to shut
down or eliminate and without
approval of the Industrial Sector
Regulatory Authority
A fine from AED 30,000 to
50,000 and closure of the facility.
Also recommend legal
proceedings.
EHS04,
EHS07,
EHS12, E01,
E02, S01, S02
69
Failure to comply to and provide
Welfare facilities as per the
requirements of ZC CoP H02
in the industrial and worker
residential facilities
A fine ranging from AED 5,000 to
10,000
H02, EHS08
70
Failure to comply with
(exceeding) the maximum
A minimum fine of AED 5,000 H02

CODE OF PRACTICE
COMPLIANCE ENFORCEMENT

Document No ZC-COP-EHS12 Rev. No. 0 Date of Issue 21 Sept. 2008
Page 32 of 34 Industrial Sector Environment Health & Safety Regulatory Framework

PENALTIES FOR EHS VIOLATION
Note: These are base guidelines for penalties not including and over & above any legal compensation
payable. These are subjected to change as and when deemed necessary by ZonesCorp
NO. TYPE OF VIOLATION PENALTY
ZC COP
REFERENCE
occupancy number in a room in
worker residential cities / labour
camps as per the ZonesCorp
requirements
71
Failure to submit 3
rd
Party Audit
report
Submit 3
rd
Party Audit Report
within 15 calendar days and a
minimum fine of AED 5,000
EHS06,
EHS11, E01,
E02, S01, S02
72
Failure to comply to Prohibition
Notice
EHS Permit cancellation, closure
of the total operation /
construction and a fine of AED
50,000
EHS12
73
Failure to submit Corrective
Action Plan within 15 calendar
days
A fine ranging from AED 5,000 to
10,000
EHS12
74
Failure to develop, maintain or
implement the Transport
Management Plan (TMP)
Submit the TMP within 15
working days and a minimum
fine of AED 5,000
S03
75
Failure to develop, maintain or
implement Fire Risk
Management Plan (FRSP)
Submit the FRSP approved by
Civil Defence within 15 working
days and a minimum fine of AED
20,000
FE01, FE02
76
For Construction Worksites:
Failure to develop and maintain
the EHS Manual
Develop EHS Manual within 7
days and a minimum fine of AED
10,000
S01
77
For Operating Worksites:
Failure to develop and maintain
the O&M Manual or EHS Manual
Develop O&M and EHS Manual
within 15 days and a minimum
fine of AED 10,000
S02
78
Failure to establish or implement
Contractor EHS Management
Plan
Develop and Implement
Contractor EHS Management
Plan within 7 days and a
minimum fine of AED 10,000
EHS09, S01
79
Failure to provide the
appropriate Safety/Hazard
Warning Signs and Instructions
Install the appropriate signs /
instructions and a minimum fine
of AED 5000
EHS09, S01,
S02, S04

CODE OF PRACTICE
COMPLIANCE ENFORCEMENT

Document No ZC-COP-EHS12 Rev. No. 0 Date of Issue 21 Sept. 2008
Page 33 of 34 Industrial Sector Environment Health & Safety Regulatory Framework

PENALTIES FOR EHS VIOLATION
Note: These are base guidelines for penalties not including and over & above any legal compensation
payable. These are subjected to change as and when deemed necessary by ZonesCorp
NO. TYPE OF VIOLATION PENALTY
ZC COP
REFERENCE
80
Workplace violations leading to
Injuries and/or other EHS
Incidents including Property
Damage
A minimum fine of AED 10,000
EHS03,
EHS05, H02,
S02
81
Barring EHS Specialist /
Inspector from inspection of
premises / operations (1
st

occasion)
A minimum fine of AED 5,000 EHS12
82
Barring EHS Specialist /
Inspector from inspection of
premises / operations (2
nd

occasion)
A minimum fine of AED 10,000 EHS12
83 Security Breaches
As listed in ZonesCorp CoP on
Security Access Control
SEC01

CODE OF PRACTICE
COMPLIANCE ENFORCEMENT

Document No ZC-COP-EHS12 Rev. No. 0 Date of Issue 21 Sept. 2008
Page 34 of 34 Industrial Sector Environment Health & Safety Regulatory Framework

APPENDIX 3
EHS ENFORCEMENT NOTICE
INDUSTRIAL SECTOR REGULATORY AUTHORITY
IN THE EMIRATE OF ABU DHABI

Date of Inspection:
IMPROVEMENT NOTICE PROHIBITION NOTICE PENALTY NOTICE
NOTICE ISSUED TO:
Company Name
Address
Location(Specific details of
construction / operation area)

ISSUES REQUIRING ACTION:
Regulations, COP Description of Contravention / Non-Compliance Penalty

ACTION: May Include but not limited to:
Closure of Operation / Prohibition for Use of / Seizure of Equipment / /.
Develop / Obtain & Submit OEHSMP / CEHSMP / WMP / ECAP / PP&CP / FRMP /
ERP / TMP / Inspection Certificates / EHS Permit / O&M Manual / EHS Manual etc.
Others:.
Submit: Action Plan / Enforcement Statement by (date).
The notice is to be complied with on or before
NOTICE ISSUED BY: The enforcement notice is being enforced by ZonesCorp EHS
Specialist / Inspectors based on their best professional judgement and shall be final.
Name:
Designation:
Signature:
Date : Time: