ISO 9001:2008, ISO 14001:2004, OHSAS
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1 Page: 1 of 8 ISSUE STATUS Issue Date: Issued for Use Revision Date: - Revision No.: First Issue Action Position Issued By: Reviewed By: Reviewed By: Approved By: QESH Document Controller Company QESH Management Representative HR and Operations Department Director Chief Executive Officer
2 Page: 2 of 8 1. Scope of the Procedure This Procedure describes all actions performed to identify and efficiently handle all environmental aspects and related impacts, concerning activities in the Offices / Camps / Material Stores / Laydown Areas / Workshops / Plant and Sites. 2. Field of application of the Procedure and responsibilities This Procedure is applied to all activities in Offices / Camps / Material Stores / Laydown Areas / Workshops / Plant and Sites. Those responsible for its application are: The CEO; The COO: HR and Operations Centre Department Director ; Company Representative for Quality, Environmental, Health and Safety (QESH) Management System; Plant and Equipment Manager; Country Managers; Country Representatives for Quality, Environmental, Health and Safety (QESH) Management System; Senior Project Managers; Administration Department Managers; Procurement Department Managers; Workshops Manager; Project Managers; Construction Managers; Site Engineers; Land surveyors; HSE Engineers and Officers; The Country QESH Management Representative is responsible for the overall supervision of handling of the environmental aspects and is responsible to oversee the implementation of this procedure. 3. Description of the Procedure 3.1. Definitions Environmental Aspects are elements of the Branch s activities, products or services that can interact with the environment.
3 Page: 3 of Environmental Impacts are any changes to the environment, whether adverse or beneficial, wholly or partially resulting from the Company s activities, products or services Environmental Risks are classified according to their estimated likelihood and potential severity of harm according to the following table, which gives the means to establish a ranking order for the risks in the workplace: According to the Probability Index as above, the objectives are set for each potential hazard and recorded in Risk Assessment Control with the control measures and documents that will be used listed in the form. Decisions are taken about: The priority of the handling of each health and safety objective and the time schedule; The issue of specific Instructions and monitoring their implementation; The person(s) that will be responsible for the objective; The measuring indicators (if any) that will be used for follow up of the progress of the health and safety objectives and the measurement of the performance (column comments ). Decisions are based on the following consequence and risk factor evaluation tables:
4 Page: 4 of Subsequent to the analysis, impact control measures are taken based on the following table to: - Remove the aspect - Change the aspect to one of less significance or - Reduce the effect of potential impacts Risk Level LOW MEDIUM HIGH Control Measures and time schedule No measures are required and no records need to be kept No additional controls are required. Consideration may be given to a more cost effective solution or improvement that imposes no additional cost burden. Monitor is required to ensure that controls are maintained Efforts should be made to reduce risk within a defined time period, but the associated costs should be carefully measured and limited. Where the moderate risk is associated with extremely harmful consequences, further assessment may be necessary to establish more precisely the likelihood of harm as a basis for determining the need for improved control measures. Work should not be started until risk has been reduced. Considerable resources may have to be allocated to this cause. Where the risk involves work in progress, urgent action should be taken. If risk reduction is not possible even with unlimited resources, work has to remain prohibited.
5 Page: 5 of Environmental Objective is an overall environmental goal arising from the environmental policy, set by the Company itself to achieve, and which is quantified where practicable Environmental Target is a detailed performance requirement, quantified where practicable, applicable to the Company or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve these objectives General The Country Management of the Company provides the resources (human resources, specialised skills, technology, financial resources etc) necessary for the identification and efficient handling and analysis of environmental aspects. For each of the Company s area (Office, Camps, Material Stores, Laydown Areas, Workshops, Plant, Site) a Site HSE Officer is appointed (or a suitable employee is nominated), who is trained for all relevant activities. A Site HSE Officer may cover more than one area according to the Project size and nature. The responsibilities of the Site HSE Officer concerning environmental aspects are, among others, to promote and support the continuing development of a culture of environmental awareness and to evaluate achievements against environmental targets. The Country Management is regularly informed about environmental aspects during the annual QESH System review (Procedure P 830) or on a case by case for important or exceptional events. The Country s employees must be aware of the significant environmental impacts of their work activities and conform to the Company s Environmental Policy, Plans, Procedures, Instructions, and Programs Environmental legislation The Country QESH Management Representative is responsible for collecting and maintaining a library of the respective legislation, regulations and other relevant documents concerning environmental issues applicable to the Country s activities. Environmental aspects can be categorised in the following groups: - Emissions to air; - Releases to water; - Contamination of land; - Depletion of ground water table; - Waste management; - Use of raw materials and natural resources; - Noise observation levels; - Other local environmental and community issues.
6 Page: 6 of 8 The Country QESH Management Representative communicates the legislation concerning their activities to the Site HSE Officers and Department Heads Identification and handling of environmental aspects Based on the legislative, regulatory, client and other requirements the Site HSE Officers (assisted by the Country QESH Management Representative) draw up a table of environmental aspects, as well as of impacts and respective legislative and other requirements for their area of responsibility by using Form F-P 710 The priority of recording of environmental aspects in Form F-P 710 is determined by their importance. All activities of the Office / Camps / Material Stores / Laydown Areas / Workshops / Plant / Site that may have an environmental impact (including purchased materials and activities of suppliers and subcontractors), are considered. Current and scheduled activities (including site / area reinstatements) may also be considered. For each activity the environmental aspect and impact is recorded and a severity rating is given, both for normal (after control measures are applied) and abnormal (before proper control measures are applied) operations (including emergencies). Decisions are taken about: - The objectives and targets for each aspect followed by the appropriate control measures and documents; - The priority of each environmental objective / target and the time schedule taking into account abnormal and potential emergency situations; - The need of drawing up and implementing an Environmental Management Program (see paragraph 3.6 below) or, alternatively, handling by issue of specific Instructions and monitoring their implementation; - The need for drawing up a specific Environmental Plan (see paragraph 3.7 below); - The person(s) responsible for the activity; - The measuring indicators (if any) that will be used for follow up of the progress and the measurement of the environmental performance ( comments ). The analysis and the objectives / targets and relevant measures are approved by the Project Managers Review of the environmental aspects At least every six (6) months or when it is thought that the current analysis is no longer valid or according to Client s requirements (expressed in the respective Environmental Plan, see paragraph 3.7) or if there are significant changes, a review of the environmental aspects takes place by the Site HSE Officer. During the review: - The existing situation is reviewed and the strong and weak points are determined;
7 Page: 7 of 8 - The possibility to meet the requirements that have been set is assessed and corresponding resources are examined (e.g. personnel, equipment, know-how, cost); - Alternative solutions for handling environmental aspects are considered; - Any needs for environmental studies, before taking final decisions, are examined and the studies are assigned to appropriate persons along with time schedules. - These studies shall include any requirements for dealing with emergencies, should they occur; The review of each environmental aspect and all relevant decisions are recorded in Form F-P 710, which is revised and approved as mentioned in paragraph Environmental Management Programs An Environmental Management Program must be implemented for various of the companies areas, e.g. Camps, Laydown Areas, Material Store, Offices and Plant in order to meet the environmental objectives / targets, its contents are as follows: - An introduction, where the title, scope, expected objectives / targets, specifications, regulations, legislation etc applied and the methodology used are mentioned; - A technical description accompanied by any relevant drawings, sketches etc; - Resources (human resources, equipment, financial resources etc); - An organisational chart concerning the people involved in the implementation of the Environmental Management Program and their responsibilities; - Data for the necessary training for the people involved; - Results of aspects and impacts analysis and the effectiveness of the controls as well as provision for new ones if considerable changes from previous situations are present; - A scheduled action plan based on the above aspects and impacts analysis should form part of this program; - The phases, actions and deadlines of the Environmental Management Program; - References to corresponding documents (e.g. drawings, Procedures, Instructions either permanent or specific to the Site etc); - The forms that will be used for recording data; - Any comments or observations. The Environmental Management Programs are prepared by the Site HSE Officer in cooperation with the Department Head of the concerned area. The Country QESH Management Representative may assist in the Environmental Management Program s preparation if necessary. The Environmental Management Programs are approved by those mentioned in paragraph 3.4 and reviewed by the same persons who prepared it (refer to P 810). If this is not absolutely possible, then the Reviewer must have sufficient information regarding the basis for the program in order to carry out an objective review. During the implementation of an Environmental Management Program all actions taken must be recorded. Additionally, the date and effectiveness of such actions must also be recorded.
8 Page: 8 of 8 The Environmental Management Programs are audited by the respective HSE Officer and/or appointed auditors in line with the general requirements of P 830 Internal Audits and System Review Environmental Plans for Projects When there is a Client s requirement, a specific Project Environmental Plan is prepared for each Project either in the phase of bidding or after the Project has been awarded. Based on the environmental aspects analysis of similar projects, the bidding / contract documents, the Client s requirements and the particulars of the specific Project, the Environmental Plan is prepared by the Country QESH Management Representative in co-operation with the Project Manager and the Site HSE Officer. Initially, the Environmental Plan contains all known data concerning the Project. During the Project execution the Site HSE Officer of the Project, in co-operation with the Project Manager and Construction Manager, is responsible to complete and follow-up its implementation, review and revise as necessary. The following items, or references to them, are included in general in an Environmental Plan along with specific Client s requirements: - Environmental Policy; - Organisation; - Human resources and responsibilities; - Suppliers and subcontractors involved (if necessary); - Equipment and tools (measuring, waste handling etc); - Document control and filing system; - Handling of Non-Conformities, corrective and preventive actions; - Audits; - Reviews; - Emergency / Evacuation Plans (see Procedure P 750); - Standards, specifications, legislation, regulations; - Environmental Instructions; - Environmental Management Programs; - Environmental Aspects Analysis Objectives / Targets (Form F-P 710, see clause 3.4). The above may be incorporated with the Health and Safety Plan (ref. P 720) to result in an integrated Health, Safety and Environment Programme. 4. Forms 5. Records F-P 710 Environmental Aspects Analysis Objectives / Targets All records of Environmental Aspects Analysis Objectives / Targets and any accompanying documents, as well as the Environmental Plans where existing, are maintained for five (5) years and they are then scrapped.
9 Page: 9 of 8 6. Revision First issue of Group Wide Procedure.
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