SHUI ON BUILDING CONTRACTORS LIMITED SHUI ON CONSTRUCTION COMPANY LIMITED

Transcription

1 Title : Environmental Management System Manual Issue No. : 3 Revision No. : 0 This Manual and the information therein is the property of Shui On Building Contractors Limited and Shui On Construction Company Limited. All rights are reserved. No part of this Manual may be reproduced in any form, transmitted by any means or otherwise disclosed without the prior permission of the above companies

2 Table of Contents 1.0 Summary of Amendments 2.0 General (Title Only) 2.1 Introduction 2.2 Manual Control 2.3 List of Abbreviations 3.0 Cross Reference with ISO Environmental Management System (Title Only) 4.1 Scope of the Environmental Management System 4.2 Environmental Policy 4.3 Planning (Title Only) Environmental Aspects Legal and Other Requirements Objectives, Targets and Programmes 4.4 Implementation and Operation (Title Only) Resources, Roles, Responsibility and Authority Competence, Training and Awareness Communication Documentation Control of Documents Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 2 of 49

3 4.4.6 Operational Control Emergency Preparedness and Response 4.5 Checking (Title Only) Monitoring and Measurement Evaluation of Compliance Nonconformity, Corrective Action and Preventive Action Control of Records Internal Audit 4.6 Management Review 5.0 Company Environmental Procedures Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 3 of 49

4 1.0 Summary of Amendments Rev. No. Issue Date Amendments /7/31 NA Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 4 of 49

5 2.0 General 2.1 Introduction 1. Shui On Building Contractors Limited or Shui On Construction Company Limited is one of the leading building contractors in Hong Kong and holds a Government approved building works licence that allows the Company to tender for projects of all sizes. The Company is a subsidiary of the Shui On Construction and Materials Limited in the Shui On group of companies. 2. The Company has established and implement an Environmental Management System (EMS) in accordance with the requirements and interpretation of ISO This Manual is a document describing the Company s approach to fulfilling the system elements of ISO According to ISO requirements, the EMS consists of a 5-step management cycle which are environmental policy, planning, implementation and operation, checking and management review to achieve continuous improvement. 4. This manual is written in a concise manner with the pragmatic objective that it can be easily understood by the users. Users of the manual should therefore refer to the complete set of EMS documents including but not limited to Company Environmental Procedures, Site Environmental Management Plans as well as detailed work instructions. 5. The purpose of the EMS is to ensure that significant risk(s) identified in the Company s activities and services are being controlled. These significant risk(s) will be managed through operational controls and will be improved by objectives and targets from time to time. This Manual also addresses the documentation requirements of ISO and provides a road map to the system for employees and third parties. 6. To facilitate implementation of the EMS, system procedures are developed and referred as Company Environmental Procedures (CEPs) listed in Section 5.0 of this Manual. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 5 of 49

6 2.2 Manual Control 1. HSE Senior Manager is responsible for the preparation, maintenance, issue and control of this Manual. 2. HSE Steering Committee is responsible for reviewing this Manual and approving any changes. 3. The Executive Director is responsible for endorsement and authorization of this Manual by signing the front page of this Manual. 4. The issue status of this Manual is indicated on the front sheet and on every sheet of this Manual. Authorization by the Executive Director is provided on the front page of the master copy of this Manual. 5. This Manual Revision Number allows this Manual to be updated for the amendment of any section or sub-section. 6. This Manual is re-issued with a new Manual Issue Number when more than half of the sections or sub-sections need to be changed. 7. This Manual will be issued in electronic form by uploading to the Company s intranet where all staff can gain access. HSE Senior Manager is responsible for keeping the master copy of the signed Manual and arranging to keep the intranet version up-to-date. 8. Usually all printed copies are uncontrolled copies and are for reference only. Always refer to intranet for updated version of this Manual. 9. Uncontrolled copies may be distributed outside the Company with the approval of HSE Senior Manager. They will be printed on normal paper without orange company logo and will not be kept up-to-date. HSE Senior Manager will record to whom copies have been sent. 10. Controlled copies are only distributed outside the Company when approved by the Executive Director. In these circumstances, formal transmittal letters will be used. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 6 of 49

7 11. Controlled copies, if necessary, will be printed on paper with an orange company logo and distribution is controlled by HSE Senior Manager. 12. Anyone desiring a change to this Manual must address a request to HSE Senior Manager in writing. 13. HSE Senior Manager evaluates the request and prepares a draft of the proposed change for review by HSE Steering Committee. 14. When the change is agreed, HSE Senior Manager advances this Manual Revision Number and/or this Manual Issue Number accordingly and produces a master for authorization by the Executive Director. 15. For ease of reference, recent changes made will be given in italics. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 7 of 49

8 2.3 List of Abbreviations CEP(s) Company ED EMS ER HSE HSEP HSEMC HSEMP HSESC ISO ISO ISO19011 OC(s) Site EMP Site HSEC WI(s) Company Environmental Procedure(s) Shui On Building Contractors Limited or Shui On Construction Company Limited as appropriate Executive Director Environmental Management System Environmental Resolution Health Safety and Environment Health Safety and Environment Policy Health Safety and Environment Management Committee Health Safety and Environmental Management Programme Health Safety and Environment Steering Committee ISO 14001:2004 Environmental Management Systems Requirements with guidance for use ISO 14004:2004 Environmental Management Systems General guidelines on principles, systems and support techniques ISO 19011:2002 Guidelines for quality and / or environmental management systems auditing Operational Control Procedure(s) Site Environmental Management Plan Site HSE Committee Work Instruction(s) Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 8 of 49

9 3.0 Cross Reference with ISO The cross reference between sections and subsections in this Manual and the elements of ISO standard are given below. Section Description ISO Ref. 4.1 Scope of the Environmental Management System Environmental Policy Planning (Title Only) Environmental Aspects Legal and Other Requirements Objectives, Targets and Programmes Implementation and Operation (Title Only) Resources, Roles, Responsibility and Authority Competence, Training and Awareness Communication Documentation Control of Documents Operational Control Emergency Preparedness and Response Checking (Title Only) Monitoring and Measurement Evaluation of Compliance Nonconformity, Corrective Action and Preventive Action Control of Records Internal Audit Management Review 4.6 Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 9 of 49

10 4.0 Environmental Management System 4.1 Scope of the Environmental Management System 1. This Manual is applicable to the Company with respect to site operations of building construction. 2. During the building construction phase, environmental management becomes the prime responsibility of the main contractor since the environmental aspects in construction phase have direct impacts on the employees and the surrounding neighbourhood. Aiming at minimizing or better still eliminating the environmental risks arising from building construction, the Company put in place a structured EMS that complies with the requirements of ISO Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 10 of 49

11 4.2 Environmental Policy 1. The Environmental Policy is incorporated into the Health Safety and Environment Policy (HSEP) statement of the Company. The HSEP states that the concern for the health, safety and environment is the responsibility of every employee and subcontractor. All operations shall comply with the relevant statutory requirements. All employees and subcontractors shall at all time adhere to the related responsibilities, work procedures which are clearly laid out in this Manual. 2. The HSEP states that continuous improvement is the strategic goals of the EMS. The current HSEP and associated measures shall be reviewed regularly to allow continuous upgrading of environmental standards. 3. The HSEP is stated in English and Chinese versions, and is communicated to all relevant levels through a variety of means described in CEP 4 (Environmental Training) and CEP 5 (Communication). 4. Management of the HSEP is addressed in CEP 1 (Environmental Policy). Supporting Procedure(s) CEP 1 CEP 4 CEP 5 Environmental Policy Environmental Training Communication Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 11 of 49

12 4.3 Planning Environmental Aspects 1. Environmental aspects arising from construction operations and services are identified, evaluated and reviewed in accordance with CEP 2 (Environmental Aspects) with consideration to normal, abnormal and emergency operations. 2. To each individual operation and service, its environmental aspects are identified and their corresponding levels of significance are also evaluated with a pre-defined criteria. Such evaluation is important for defining objectives, setting targets and prioritizing programmes and actions. 3. The environmental aspects shall address the environmental impacts arising at all stages of the service or process, so as to allow the identified aspects be monitored according to CEP 8 (Monitoring and Measurement) and controlled. 4. In the event that new activities are introduced to the sites or existing activities modified, the related environmental aspects shall be identified. Once the aspects have been amended with respect to internal or external changing circumstances, all related documents shall be updated accordingly. Supporting Procedure(s) CEP 2 CEP 8 Environmental Aspects Monitoring and Measurement Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 12 of 49

13 4.3.2 Legal and Other Requirements 1. HSE Senior Manager is responsible for identifying, maintaining, reviewing and updating all relevant legal and other requirements (including consideration on applicable international standards) according to CEP 3 (Legal and Other Requirements). These requirements also include the ERs developed internally. 2. The Company shall ensure the key responsible staff understand and strictly follow these requirements by establishing appropriate work instructions, implementing monitoring programmes and conducting periodic internal inspection and auditing respectively according to CEP 8 (Monitoring and Measurement), CEP 9 (Inspection and Maintenance) and CEP 12 (Audit). 3. In case of any nonconformity, CEP 10 (Nonconformity, Corrective Action and Preventive Action) shall be followed accordingly. Supporting Procedure(s) CEP 3 CEP 8 CEP 9 CEP10 CEP12 Legal and Other Requirements Monitoring and Measurement Inspection and Maintenance Nonconformity, Corrective Action and Preventive Action Audit Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 13 of 49

14 4.3.3 Objectives, Targets and Programmes 1. HSE Steering Committee (HSESC) shall set objectives and targets in line with the HSEP and communicate to all relevant functions and appropriate levels for implementation and review. The agreed targets shall be specific, measurable where practicable, and achievable within specifiable time frame. 2. HSE Senior Manager is responsible for gathering information for establishing objectives and targets in HSESC. Objectives and targets shall be identified through the following steps: (i) (ii) Identify new and review the existing significant environmental aspects, legal and other requirements Review existing operational controls/practices to determine whether the significant environmental aspects are effectively controlled. (iii) If no controls are in place, identify and implement necessary controls. Under certain circumstances objectives and targets may be set to address the control of significant aspects. (iv) If controls are in place but not satisfactory, the following will be implemented: amend the relevant control mechanism. develop a new operational control/practice. (v) Alternatively the HSE Senior Manager shall improve control beyond the satisfactory level already being achieved, and in these circumstances the HSE Department shall establish new control(s) with reference to available technology, financial, operational and business requirements and views of interested parties. 3. Complaints from external interested parties and internal suggestions shall be discussed, reviewed and taken into the account for the establishment of objectives and targets. 4. Based on the agreed objectives and targets, measurable indicators and a Health Safety and Environmental Management Programme (HSEMP) shall be developed and used as the basis for environmental performance evaluation which can provide information about the effectiveness of the EMS at both the management and the operational levels. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 14 of 49

15 5. The prime aim of the HSEMP is to achieve the objectives and targets and to achieve compliance with a recognised standard. 6. The HSEMP shall address clearly the objectives and targets, detailing the method of achievement and necessary action, responsibility for implementation and time scale over which the targets are to be achieved. 7. HSE Management Committee shall monitor, review and update the HSEMP as necessary in accordance with CEP 13 (Management Review). The progress of achieving objectives and targets can be traced through the minutes of committee meetings. 8. Staff assigned to assist in the implementation of HSEMP, along with the objectives and targets they seek to achieve, shall be mutually agreed between themselves and management. 9. In this EMS, objectives and targets are addressed alongside with the management review process in accordance with CEP 13 (Management Review). Monitoring and review of target achievement shall therefore be included in part of the management review cycle. 10. If appropriate, EMP shall be modified with reference to any changes to objectives and targets to ensure the actions and targets are fully in line with each other. Supporting Procedure(s) CEP 13 Management Review Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 15 of 49

16 4.4 Implementation and Operation Resources, Roles, Responsibility and Authority 1. To effectively maintain the EMS, the Company develops and maintains a crossfunctional structure as shown below. Appendix 4.4.1A also shows the organisation structure of the Company. 2. Within this structure, roles, responsibilities and authorities are defined, documented and communicated in order to facilitate effective environmental management. 3. Management shall ensure resources essential to support the implementation and control of the EMS are provided whenever required. Resources cover competent/trained personnel with specialized skills, appropriate technology and financial resources. HSE STEERING COMMITTEE 安全健康及環保主導委員會 HSE MANAGEMENT COMMITTEE 安全健康及環保管理委員會 SITE HSE COM. 地盤安全健康及環保委員會 SITE HSE COM. 地盤安全健康及環保委員會 SITE HSE COM. 地盤安全健康及環保委員會 SITE HSE COM. 地盤安全健康及環保委員會 SITE HSE COM. 地盤安全健康及環保委員會 SITE HSE COM. 地盤安全健康及環保委員會 Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 16 of 49

17 4. Health Safety and Environment Steering Committee (HSESC) Executive Director (Chair-person) General Manager Assistant General Manager Senior HSE Manager HSE Managers / Assistant Managers Its main responsibilities are to: Formulate and review HSEP for approval by ED. Ensure the EMS meets the ISO requirements. Assess and anticipate the impact of existing and forthcoming legislation. Set objectives and targets as part of HSE planning which are compatible with the Company goals and objectives for continuous improvement. Review and ensure the effectiveness of the EMS. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 17 of 49

18 5. Health Safety and Environment Management Committee (HSEMC) General Manager (Chairperson) Assistant General Manager Project Managers Procurement Senior Manager Plant Manager HSE Senior Manager and Managers Its main responsibilities are to: Review on implementation and effectiveness of HSEMP. Formulate Environmental Resolutions. Discuss on budgeting HSE program and training need in the planning stage. Set up an accountability system to motivate all levels to achieve good HSE performance. Implement policy and procedures made by the HSESC, and give feed back, if any, to the said committee for continuous improvement. Coordinate and designate work of management and establish responsibilities and authorities. Conduct in-house EMS audit to check over the effectiveness of implementation and review operational control measures for environmental issues with site staff. Work and maintain on pre-determined standard. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 18 of 49

19 6. Site HSE Committees (Site HSEC) HSE Officer Project Manager (Chair-person) Mechanics Foremen Engineer Site Agent Project Supervisor Site Administrator Subcontractors' Worker Rep. The main responsibilities of each Site HSEC are to: Ensure proper implementation of EMS. Develop, introduce and monitor working environmental rules. Enforce standards for pollution prevention at all times. Give all trades foremen and gangers precise instruction on their responsibilities. Inspect the site to ensure all environmental measures are observed. Maintain on the adequacy of communication and publicity in the workplace. Provide interaction between management and employees on environmental problems where both have vital interests. Monitor all subcontractors activities regularly to ensure their continuous commitment to the prescribed EMS requirements. Consider and implement on recommendations provided by Government bodies and appointed HSE officer. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 19 of 49

20 7. The HSE Senior Manager is appointed with specific responsibility for environmental management of the Company while the Project Manager of a project site is responsible for environmental management of that particular site. Their roles and authority include: ensuring that the EMS is established, implemented and maintained in accordance with ISO 14001; ensuring that reports on the performance of the EMS are presented to top management for review and used as a basis for improvement of the EMS. 8. The responsibilities and authorities of the employees who perform and verify work affecting the environment are described in their job descriptions or the related procedures. For easy reference, the responsibilities and authorities of the key members or departments are outlined in this section. 8.1 Executive Director Appoint senior management to HSESC. Endorse Environmental Policy. Chair HSESC meetings. Set objectives and formulates Health Safety and Environmental Management Plan (HSEMP) to improve the environmental performance of operations. Approve and endorse relevant controlled documents such as EMS manual and procedures. 8.2 General Manager Chair HSEMC meetings. Take the lead to support the implementation of HSEMP. Decide on the provision of training, equipment and facilities to assist the implementation of EMS. Keep abreast in complying with all relevant statutory and contractual environmental requirements. Oversee and facilitate the sites for the implementation of EMS. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 20 of 49

21 Communicate and collect feedback on the overall implementation. 8.3 HSE Senior Manager / Managers Assist the HSEMC to implement EMS for improving the environmental performance of the Company and communicating of all relevant information to HSESC for Management Review. Ensure the Company is complying at all times with relevant statutory and contractual environmental requirements and ISO requirements. Draft EMS Procedures / documentation. Approve OCs and WIs Maintain EMS records. Identify training needs for all relevant staff and promote environmental training program for all supervisory levels. Forecast the legislation impact on the Company. Liaise with government authorities such as Environmental Protection Department, and other professional bodies, etc. Conduct and revise environmental audit to check over working methods and environmental precautions. Oversee HSE Officers for effective implementation of EMS. Participate in management meetings for HSE issues. 8.4 Procurement Senior Manager / Managers Communicate and collect feedback from subcontractors and / or suppliers. Consider all subcontractors invited for tendering are environmentally oriented. 8.5 Plant Manager Oversee the mechanics and provide technical advice on pollution control facilities. Communicate and collect feedback from mechanics. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 21 of 49

22 8.6 Senior Project Manager / Project Manager Chair Site HSEC meetings. Ensure overall implementation of EMS at site level through participating in regular inspections. Be familiar with the requirements of the EMS. Ensure that all site management levels are conversant with and fully comply with EMS, Company, statutory as well as contractual environmental requirements. Be responsible for ensuring that the HSEMP is reviewed half yearly, kept up to date and implemented. Ensure that all senior site staff are assigned appropriate duties and responsibilities of the EMS. Ensure that subcontractors are aware of and implement the EMS. Take appropriate actions against subcontractors with poor environmental performance. Act as the Employee Representative for the site to maintain the communication between HSEMC and site HSEC. Maintain a direct line of communication with the HSE Officer. Support and uphold rectifications and recommendations from HSE Officer on environmental deficiencies. Supervise the implementation of corrective action plans. 8.7 Site Agent Be familiar with the requirements of the EMS. Be accountable to the Project Manager and responsible for implementing the EMS. Ensure that all subcontractors are conversant with, receive a copy and fully comply with EMS. Monitor the site operations to ensure they are conducted in accordance with Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 22 of 49

23 the EMS and take urgent and appropriate action to prevent improper working practices or other infringements of statutory or EMS requirements. Coordinate incident investigations. Lead monthly site safety inspections. Attend and participate in site HSE committee meeting. 8.8 Engineer Ensure works are carried out according to the required standard with minimum risk to workers, public, equipment and materials. Understand and enforce the statutory and contractual environmental requirements. Co-ordinate activities between main contractor and sub-contractors and any other individual contractors who may be working at the same time. Check environmental condition of hired plant and that, where appropriate, copies of valid test certificates are readily available for inspection. Ensure that all work carried out at workplace, all plant, machinery and equipment therein, confirm to the prevailing statutory requirement. 8.9 Project Superintendent / Project Supervisor Know and understand the requirements of EMS and other relevant legislation and ensure that they are being observed. Advise foremen and engineers on the correct working practices to avoid pollution. Liaise with subcontractors and other contractors to ensure that their sections of work are executed and conformed with the environmental standards. Assess the environmental performance of foremen and subcontractors. Conduct regular environmental inspections. Enforce environmental disciplinary system. Participate in risk assessments and risk process control measures. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 23 of 49

24 Implement operational control. Take actions to rectify unsafe conditions and practices and to implement the environmental control measures as recommended by the HSE officer. Coordinate and enact housekeeping measures to keep the site clean and tidy. Attend and participate in site HSEC meeting. Participate in incident investigations HSE Officer Advise site management to: Supervise and monitor the implementation of HSEMP. Address implementation and updating of the HSEMP and all relevant aspects of environment. Verify the EMS are implemented through regular inspection. Implement the recommendations in the EMS audit report. Keep aware of changes in legislation and environmental requirement and keep legal requirements affecting the environment up-to-date. Organize environmental training and keep relevant training records. Carry out training for all levels of employees on protecting the environment. Keep up-to-date with recommended environmental requirements; circulate information applicable to each level of employee. Conduct environmental risk assessment before high risk operations. Recommend environmental control measures and compile control procedures for high risk operations. Carry out site inspections, in association with appropriate site staff to see that environmentally friendly methods of working are in operation; that all regulations are being observed. Implement environmental disciplinary system. Suspend operations with significant environmental risk. Report on accidents and dangerous occurrences for statistical analysis. Investigate incidents and compile investigation reports. Assess environmental performance of foremen. Organize and facilitate site HSEC meetings. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 24 of 49

25 Prepare and organize internal and external EMS audits Foremen Be familiar with statutory regulations and the client s specific environmental rules applicable to the work on which their gangs are engaged; insist that the regulations are observed. Ensure that new employees learn to be environmental aware. Ensure that plant / equipment are operated by competent person only and any defects are reported immediately to site agent / project supervisor. Ensure the right tools is used for the specific purpose of work. Ensure that appropriate clothing are worn and appropriate devices/equipment are used at work where required. Carry out inspection on the execution of operational control based on an approved checklist. Enforce environmental disciplinary system. Maintain good housekeeping of supervising area. Attend site HSEC meetings Operators / Mechanics Know the statutory and contractual environmental requirement in respect of the plant. Familiar with the characteristic of the plant to be operated. Ensure the plant is in good working condition prior to use and operate the plant in environmentally acceptable working method. Ensure regular maintenance has been carried out. Report defects in plant or equipment. Supervise and guide their subordinates to carry out work in accordance with statutory and Company safety requirement. Maintain good housekeeping of work area after work. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 25 of 49

26 8.13 Site Administration Officer Support site in monitoring, documentation, record-keeping and inspection. Handle logistic arrangement of equipment calibration, document storage and coordination of site workers General Staff Be familiar with the HSEP, statutory regulations and environmental rules applicable to the work on which their gangs are engaged; insist that the regulations are observed and all nonconformity events are reported immediately. Hold accountable for the performance of environment, which is generally reflected by inspection reports. Take reasonable care for the working & surrounding environment and others who may be affected by their actions. Attend and/or release the workers for environment training upon requested. Inform and report the site office immediately on the occurrence of any nonconforming event. Be familiar with the nature of work and the equipment or tools to be operated. Check relevant equipment regularly to ensure they are in good condition. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 26 of 49

27 Appendix 4.4.1A Organisation Structure of the Company Board of Directors Executive Director HSE - Steering Committee General Manager Quantity Estimating/ E & M Project Plant Human HSE Administration Finance/ Quality Surveying Procurement Engineering Engineering Department & Resources & Accounting Assurance Machinery Training Department Department Department Department Project Department Department Department Department Department Department Head Head Head Head Managers Head Head Head Head Head Head Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 27 of 49

28 4.4.2 Competence, Training and Awareness 1. All employees shall receive environmental awareness training which includes but is not limited to issues relating to conformity with the environmental policy general environmental awareness including the understanding of the EMS. 2. HSE Senior Manager shall identify training needs for their staff whose work may create a significant environmental impact on the environmental performance of the Company. HSE Officer shall identify training needs of subcontractor s workers on site. 3. Training will be provided in order to Maintain levels of competence Comply with existing new legislation and regulations, and Environmental Resolutions Introduce new technology and Encourage two-way communication 4. Environmental training are provided internally or by external bodies, or by a combination of both. 5. Project Managers and HSE Senior Manager shall establish and maintain procedures to make its employees or members at each relevant function and level aware of The importance of compliance with the organisation s HSEP and objectives, and with the requirements of the relevant EMS standard specifications The importance of conformity with the HSEP and procedures and with the requirements of the EMS The significant environmental impacts, actual or potential, of their work activities and the environmental benefits of improved personal performance Their roles and responsibilities in achieving conformity with the HSEP and procedures and with the requirements of the EMS, including emergency preparedness and response requirements Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 28 of 49

29 6. Personnel performing the tasks with significant environmental risks should be competent on the basic of appropriate education, training and/or experience. 7. Management shall determine the level of experience, competence and training necessary to ensure the capability of personnel, especially those carrying out specialized environmental management functions. 8. Procedure CEP 4 (Environmental Training) has been established to ensure that where appropriate all employees are trained with respect to the above environmental issues, and that this training is reviewed and updated as necessary. Supporting Procedure(s) CEP 4 Environmental Training Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 29 of 49

30 4.4.3 Communication 1. Communication is an important part of our EMS; we need to communicate internally with employees and contractors and externally, with outside parties. 2. Our communication is a two-way process; that the management communicate make the employees aware of its aims and its progress on environmental management. Management also listen and take heed of the opinions and inputs from staff and from outside organisation and individuals. 3. Procedure CEP 5 (Communication) has been established and in place for receiving, documenting and responding to internal and external communications. 4. Internal communication aims to: Raise awareness of environmental issues Achieve commitment to the HSEMP Communicate changes and progresses that are made in environmental management Gather information from staff ideas, attitudes and suggestions 5. Receiving, documenting and responding to relevant communication from external interested parties is important in implementing the EMS. Changes on the environmental management and the activities description will be reported and provided to the interested parties, related departments and employees. Supporting Procedure(s) CEP 5 Communication Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 30 of 49

31 4.4.4 Documentation 1. Documentation is necessary to provide direction to the System and to facilitate audits. The EMS is established in accordance with the environmental management system requirements of ISO The system comprises of the following key documents which is controlled and maintained according to CEP 6 (Document Control) and CEP 11 (Records): Health Safety and Environment Policy (HSEP) A signed policy statement by top management stating its strategy for environmental management which provides the basis for the EMS and objectives. Health Safety and Environmental Management Programme (HSEMP) Programme that is compiled by HSE Department to detail the actions and time frame necessary to achieve the established objectives and targets. Environmental Management System Manual Comprehensive guide to all elements of the EMS; also refers to other related documents. Company Environmental Procedure (CEP) System procedure for effective implementation of the EMS. Register of Environmental Aspects Summary of environmental aspects of the company s activities, products or services in which it can control or expected to have an influence. Site Specific Register of Environmental Aspects Similar to the Central Register of Environmental Aspects except it only accounts for the environmental aspects specific to individual project site. Environmental Legislation and Regulations Legislation and regulations can be accessed through internet to relevant websites. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 31 of 49

32 Register of Legal and Other Requirements Details all environmental legislation and other requirements to which the Company may subscribe. Environmental Resolution (ER) Written resolution passed by HSEMC specifying the measure(s) that will be implemented for every site. Alternatives shall be undertaken if site environment does not allow the specified measure(s). Objectives and Targets Actions planned by HSESC to implement satisfactory environmental measures and controls if they are not already in place and to improve control beyond the satisfactory level already achieved. Operational Control Procedure (OC) General guidance including implementation of legal and other requirements developed to control the environment impact arising from work activities. Work Instruction (WI) Activity-specific instruction developed with reference to the OC for supervisory to maintain their work in an environmental acceptable manner. Environmental Records Records which demonstrate achievement of the required environmental standards and the effective operation of the EMS. Supporting Procedure(s) CEP 6 CEP 11 Document Control Records Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 32 of 49

33 4.4.5 Control of Documents 1. This part ensures that documents are reviewed and approved prior to issue and that the pertinent issues of appropriate documents are made available for the due performance of the environmental management and control. 2. Master list or equivalent document control procedures are used to identify the revision status of documents. Amendment sheets are used to identify changes in documents, which are reviewed and approved by the functions that performed the original review and approval. Obsolete documents are removed or clearly identified as such to prevent inadvertent use. 3. HSE Senior Manager is responsible for control and maintenance of the Manual as well as its associated procedures. Executive Director is responsible for approving the Environmental Management System Manual and CEPs. 4. Obsolete documents retained for legal and/or knowledge preservation purpose are suitably identified by the respective holders. 5. HSE Senior Manager holds master for the Environmental Management System Manual and CEPs and ensure the updating of the copy placed on intranet. 6. Amendments to the Manual are drafted by HSE Senior Manager and authorized by Executive Director; while changes to CEPs are drafted by the employee who proposes the changes, approved by HSE Senior Manager and authorized by Executive Director. Details of the changes are recorded in the amendment section of these documents. 7. Upon receipt of revised documents, HSE Senior Manager will arrange uploading of the updated version of documents to the intranet for every staff s reference. 8. All staff shall always refer to the intranet for the updated version when necessary. 9. Department Heads or Project Managers or their nominees shall file, distribute and control the incoming and outgoing project documents in accordance with CEP 6 (Document Control). 10. Details of control of EMS records shall be referred to CEP 11 (Records). Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 33 of 49

34 Supporting Procedure(s) CEP 6 CEP 11 Document Control Records Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 34 of 49

35 4.4.6 Operational Control 1. HSE Senior Manager identifies those operations and activities that are associated with the identified significant environmental aspects in line with its policy, objectives and targets. Also, these activities are planned and maintained in order to ensure that they are carried out under specified conditions by: establishing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy and the objectives and targets; stipulating operation criteria in the procedures; establishing and maintaining procedures related to the significant environmental aspects and communicating relevant procedures and requirements to subcontractors. 2. Operational control is addressed through the implementation of documented ERs, Operational Control Procedures (OCs) for the relevant activities and operations. In addition, subcontractor s activities will be controlled through provisions in the contracts 3. OCs aim at providing a general guidance for controlling significant environmental aspects in project operations so as to meet the requirements of ISO OCs are divided into the following major categories: Energy / Material Consumption Hazardous Materials Air Noise / Vibration Waste Management Wastewater Discharge Spillage / Leakage 4. WIs can be developed with reference to OCs if necessary, it is for supervisory to check the detailed instructions for controlling the environmental impacts arising from individual operations. Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 35 of 49

36 5. In the event of a change to the Index of Environmental related Activities (see CEP 2), OC(s) will be updated and reviewed; and modification and/or addition of WI(s) will be followed. Supporting Procedure(s) CEP 2 OCs Environmental Aspects Operational Control Procedures Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 36 of 49

37 4.4.7 Emergency Preparedness and Response 1. Procedures are maintained to solve the problems in case of emergency, providing that the particular actions will minimize the environmental impacts. 2. Training on dealing with accident and emergency situation are provided, and HSE Officer is responsible for organizing the training programs. Procedures mentioned in the emergency preparedness and responses will be reviewed and tested periodically (at least once a year) to ensure the procedures are applicable, and details related to the testing shall be recorded. 3. In case of emergency happened, Emergency Team is responsible for preparing the incident record, and reviewing the efficiency and effectiveness of the procedures. Also, by considering the impacts generated from the accident and emergency situations, HSE Senior Manager is responsible for judging the need of reporting the case to the HSESC. 4. Procedures are established to identify the potential for, and the response to, accidents and emergency situations (to minimise environmental impacts). These include Fire and Explosion Spillage and Leakage Landslide / Flooding Underground Contamination Harsh Weather 5. Procedure CEP 7 (Emergency Preparedness and Response) addresses the implementation of an effective and appropriate emergency response to dealing with potential incidents and accidents. CEP 7 ensures that the effectiveness of this response is tested and staff has received the appropriate training. Supporting Procedure(s) CEP 7 Emergency Preparedness and Response Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 37 of 49

38 4.5 Checking Monitoring and Measurement 1. Procedures are established and maintained to monitor and measure, on a regular basis, the key characteristics of its operations and activities that can have a significant impact to the environment. This shall include the recording of information to track performance, relevant operational controls and conformance with the organization s environmental objectives and targets. 2. Monitoring equipment shall be calibrated and maintained and records of this process shall be retained according to the approved procedures. 3. A procedure is established and maintained for periodically evaluating compliance with relevant environmental legislation and regulations, and the controls include Reviewing the adequacy of the equipment for applications involved. Initiation of corrective actions on the validity of previous measurement when an equipment is found to be out of calibration or overdue. Maintaining suitable equipment having a known valid relationship with nationally/internationally recognized standards for calibration where no such standard exists, the basis used for calibration shall be documented. Subcontracting of calibration and repair work. Retaining suitable records on calibration. Calibration status is identified by label fixed to the equipment. 4. CEP 8 (Monitoring and Measurement) outlines the requirements and responsibilities for carrying out this environmental monitoring and measurement of sites activities in accordance with the requirements of ISO CEP 9 (Inspection and Maintenance) provides details of inspection and maintenance. Supporting Procedure(s) CEP 8 Monitoring and Measurement Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 38 of 49

39 CEP 9 Inspection and Maintenance Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 39 of 49

40 4.5.2 Evaluation of Compliance 1. Legal and other requirements that are applicable to environmental aspects shall be identified and periodically evaluated for its compliance according to CEP 9 (Inspection and Maintenance). The records of the results of the evaluations shall be kept according to the CEP 11 (Records). 2. HSE Senior Manager is responsible for identifying, maintaining, reviewing and updating all relevant legal and other requirements according to CEP 3 (Legal and Other Requirements). 3. Project Managers shall inform HSE Senior Manager on environmental compliance of their projects. HSE Senior Manager is responsible for collecting the information and submits to senior management for review if necessary. 4. HSESC will conduct the legal compliance evaluation, such as prosecution and complaint records, in management review of the EMS to improve / revise the HSEP and / or Management Programmes and check that the EMS is effective in achieving its purpose. 5. Other methods which can be used to assess compliance, including: internal audits; inspections; document and / or records review; meeting; routine monitoring and measurement results. 6. The compliance evaluation can be integrated with other assessment activities such as health and safety inspections and assessments. For any nonconformity events related to legal compliance, it should refer to CEP 10 (Nonconformity, corrective action and preventive action). Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 40 of 49

41 Supporting Procedure(s) CEP 3 CEP 8 CEP 9 CEP 10 CEP 11 CEP 13 Legal and Other Requirements Monitoring and Measurement Inspection and Maintenance Nonconformity, Corrective Action and Preventive Action Records Management Review Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 41 of 49

42 4.5.3 Nonconformity, Corrective Action and Preventive Action 1. Root-cause analysis is used for a great range of situations where non-compliance occurs. Procedures are established and maintained for defining responsibilities and authorities for handling and investigating nonconformity, taking action to mitigate any impacts caused and for initiating and completing corrective and preventive action through CEP 10 (Nonconformity, Corrective Action and Preventive Action). 1.1 Any changes in the procedures resulting from corrective and preventive action are implemented and recorded. 1.2 Non-conforming materials and works are properly identified and controlled to prevent unauthorized use or installation. 1.3 Project Manager and Site Agent are responsible for the identification, documentation, evaluation, segregation and rectification of nonconformity in materials and equipment. In case of significant nonconformity, they are responsible for initiating Environmental Non-conformance Report and implementing remedial action decided by HSE Management Committee. 1.4 Nonconformity discovered during inspection, document / record review, and audit are identified, documented and segregated where practical and reviewed. Decision of appropriate disposition and rectification are made by the respective Project Managers or their nominees. Non-conforming materials are returned to the supplier, if necessary. 1.5 Non-conforming equipment, materials and/or works are re-inspected in accordance with applicable procedures after rectification. 1.6 When a nonconformity is significant, an Environmental Non-conformance Report is initiated for remedial action by the relevant party. 2. Corrective Actions aims to Restore compliance as quickly as possible Prevent recurrence of the problem Evaluate and mitigate any adverse environmental effects Ensure that interaction with other components of the management system, such as Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 42 of 49

43 safety and health, are satisfactory Assess the effectiveness of the action taken 3. The corrective action procedure incorporates the following elements: Formal investigation of the causes of the nonconformity. Comprehensive analysis of possible contributory factors. Recommendations to solve the problems. Implementing or modifying controls necessary to avoid repetition of the nonconformity. Formal review of corrective actions to verify implementation and analyze their effectiveness Recording and implementing changes resulting from corrective actions. 4. Revised procedures and processes following from any corrective action will be circulated as soon as possible and the obsolete documentation removed. 5. Preventive Action procedure incorporates the following elements: Information collected from appropriate sources to detect, analyze, rectify and/or eliminate potential causes of nonconformity. Recommended measures needed to prevent potential nonconformity. Formal review of preventive actions to verify implementation and analyze their effectiveness. Recording and implementing changes resulting from preventive actions Supporting Procedure(s) CEP 10 Nonconformity, Corrective Action and Preventive Action Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 43 of 49

44 4.5.4 Control of Records 1. Records are maintained to demonstrate conformance to specified requirements and effective operation of the EMS. 2. Department Heads and Project Managers or their nominees are responsible for collecting relevant records and keeping good filing so that the records can be retrieved easily. 3. HSE Department is responsible for the control and storage of EMS documents. 4. Administration Department is responsible for the disposal of EMS records stored in company godown that have passed the approved retention period. 5. Evidences of target achievement and effectiveness for the required action/operation of environmental protection activities are recorded. These records must be legible and identifiable to the materials, works or activities involved. 6. Care is taken to ensure that EMS records are accessible to authorized personnel and that they are properly filed, stored and controlled to prevent from loss, damage or deterioration. 7. The general procedure pertaining to all records is detailed in CEP 11 (Records). Supporting Procedure(s) CEP 11 Records Issue No. 3 Revision No. 0 Issue / Revision Date: 2009/7/31 Page No. 44 of 49