H& Health, Safety & Welfare 2013

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1 H&S Health, Safety & Welfare 2013 Our objective is to develop a positive health and safety culture across the company, involving and engaging our workforce at all times.

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3 Contents 02 Introduction 03 Our objectives 04 Health and Safety Policy Statement 05 Health and safety organogram Responsibilities for health, safety and welfare Arrangements for health and safety 14 Legal requirements Implementation and operation 20 Measuring performance 20 Reviewing performance /01 01

4 Introduction Viridor is a wholly owned subsidiary of Pennon Group Plc and operates in accordance with the group s health and safety policies. The Pennon Group Board periodically reviews the health, safety and welfare policies and arrangements of the whole group and requires each subsidiary board to establish and comply with all relevant statutory provisions and codes of practice relevant to health, safety and welfare issues. The Viridor Board ensures that it is kept informed of and alerted to relevant health and safety risk management issues. The Chief Executive has overall responsibility for the executive management of health and safety and the Operations Director has been appointed as the Health and Safety Director, in accordance with the recommendation of the Health and Safety Executive, to ensure that all relevant health and safety risk management issues are properly addressed, both by the Board and also throughout Viridor. The Chief Executive ensures that the Operations Director has the necessary competence, resources and support of every Board member in carrying out his functions. In addition, every other executive Board member has responsibility for specific areas of health and safety risk management within their own business area. Viridor provides essential waste management, renewables and recycling services to customers across the UK. We provide these services to the highest operational and environmental standards. As with any leading company, we recognise that our greatest asset is our workforce, and the health, safety and welfare of our employees is of the utmost importance. Our aim is to provide a working environment that is free of accidents, ill health and loss to property and equipment. We recognise that health and safety has positive benefits to the organisation and that commitment to a high level of safety makes good business sense. We also recognise that health and safety is a business function and must therefore continually progress and adapt to change. The Board of Directors leads a positive culture on health, safety and welfare issues, which is actively supported by management and is expected to be acted upon by every employee. This policy document provides a summary of Viridor s approach to health, safety and welfare management. Where more specific information is required, this can be provided on request. 02

5 Our objectives To develop a positive health and safety culture across the company, involving and engaging our workforce at all times. n To achieve a level of health and safety performance equal to that of the best performers within the UK waste, renewables and recycling sector and to meet the objectives of the industry s Accident Reduction Charter n To prevent injury and ill health and to continually improve our health and safety performance n To develop a positive health and safety culture across the company, involving and engaging our workforce at all times n To apply best practice across the company, to work with our regulators and industry bodies to demonstrate Viridor s leadership within our industry as a best practice employer n To comply with statutory requirements and strive to exceed these where appropriate. n To ensure, so far as is reasonably practicable: the provision and maintenance of plant and systems of work that are safe and without risks to health; arrangements for ensuring the safety and absence of risks to health in connection with the use, handling, storage and transport of articles and substances; the provision of such information, instruction, training and supervision as is necessary to ensure the health and safety at work of our employees; the maintenance of any place of work under our control in a condition that is safe and without risks to health, and the provision and maintenance of means of access to and egress from it that are safe and without such risks; the provision and maintenance of a working environment that is safe, without risks to health, and adequate as regards facilities and arrangements for welfare at work. 03

6 Health and Safety Policy Statement Performance Viridor is committed to continually improve health and safety standards and performance. To this end we endeavour to ensure that all relevant statutes, regulations and codes of practice are complied with. The minimum standards that are adopted by the company are those required by law, although we will always seek to exceed these where there is a demonstrable benefit. Communication and control The Chief Executive has overall responsibility for the executive management of health and safety. I am the Health and Safety Director appointed by the Viridor Board and have full responsibility for the implementation of this policy. It is the responsibility of all the Directors and management teams to ensure that appropriate systems are developed and maintained for the effective communication of health and safety matters throughout the company, and to liaise and work with all necessary persons to ensure high standards of health and safety. The company also ensures so far as is reasonably practicable that adequate arrangements are in place for ensuring the health, safety and welfare of visitors, members of the public and other businesses that come into contact with our operational activities. Responsibilities The Chief Executive has overall responsibility for the executive management of the Operations Director who has been appointed Health and Safety Director in accordance with the recommendation of the Health and Safety Executive, to ensure that all relevant health and safety risk management issues are properly addressed, both by the board and also throughout Viridor. Health and safety is an integral part of every manager s function and their performance is monitored on a regular basis. Managers have specific duties and responsibilities to comply with company policy. Furthermore, Viridor educates all employees and expects them to recognise that there is a clear duty on them to exercise selfdiscipline and accept responsibility to do everything they can to prevent injury to themselves and others and loss to the company, and to co-operate with management in achieving the standards required. This duty is additional to the employee s legal duty to take reasonable care of their own health and safety and that of others who could be affected by their acts or omissions. Monitoring and review Appropriate monitoring and review of the implementation of the health and safety policy is carried out. An appropriate audit process forms part of the overall management system with the audit results being reviewed by the Board of Directors. The Health and Safety Policy is formally reviewed on an annual basis. However, amendments may be introduced at any time. Mark Burrows-Smith Operations Director Viridor February

7 Organisation and responsibilities for health and safety Pennon Group Board Our approach Line management is primarily responsible for maintaining safe working environments and safe systems of work. However, general health and safety responsibilities are allocated and set out in this section. The organogram illustrates the network for health and safety information and feedback throughout the organisation. Viridor Board Executive Directors Regional Directors and Heads of... Chief Executive Officer Operations Director Corporate Responsibility and Regulatory Director Head of Compliance Regional Area Management Regional Health and Safety Advisors Unit / Site / Department Managers and Supervisors Management Advice Employees Representatives for Employee Safety (RES) 05

8 Responsibilities for health, safety and welfare The Chief Executive has overall responsibility to ensure that the company complies with all appropriate health and safety regulations and standards. Chief Executive and Viridor Board The Chief Executive has overall responsibility for the executive management of health and safety and ensures that the Operations Director, as the designated Health and Safety Director, has the necessary competence, resources and support of the Viridor Board to enable him to ensure that the company complies with all appropriate health and safety regulations and standards. Operations Director In accordance with his responsibilities as the designated Health and Safety Director, the Operations Director determines the requirements of the Health and Safety Policy, ensures that there are sufficient resources (both financial and personnel) available and generally ensures that the required standards of health, safety and welfare are achieved. In fulfilling this role, the Operations Director will be advised and supported by the Corporate Responsibility and Regulatory Director, ensuring that all relevant matters are brought to the attention of and considered by the Board. Executive Directors Executive Directors (including the Operations Director) are accountable to the Chief Executive, and while the Corporate Responsibility and Regulatory Director will lead on assuring the health and safety framework, executive directors must ensure that: n The company has a health, safety and welfare policy and a structure, and that arrangements are in place to ensure the policy is appropriate, implemented, monitored and reviewed n Adequate resources are made available to ensure the company can meet its legal obligations under The Health and Safety at Work etc. Act 1974 and other subordinate health and safety regulations n All Viridor employees are aware of the health and safety responsibilities to themselves, their colleagues, and others who may be affected by their actions and the company s undertakings n Employees receive training appropriate to their work and responsibilities, which enables them to carry out their work in a safe manner n Appropriate recording and reporting mechanisms exist within the company to meet legislative requirements and assist the company in prioritising and targeting resources. This ensures the health, safety and welfare of our employees and those affected by our undertakings n Arrangements are in place to enable full consultation on health and safety issues and that employees representatives can carry out their duties. 06

9 Our Objectives CAN Corporate WE Responsibility ADD FEW and Regulatory Director WORDS HERE?? (reporting to the Chief Executive Officer) The Corporate Responsibility and Regulatory Director oversees the health and safety function and is responsible for ensuring that health and safety policies, procedures and arrangements are in place and kept up to date. The Corporate Responsibility and Regulatory Director shall n Report to the Board on any matters which require a change in the corporate policies for health and safety n Report on a regular basis on relevant aspects of health and safety performance n Ensure that the necessary resources for health and safety are planned into forward budgetary programmes n Ensure that the necessary resources of staff, facilities and finance are provided to implement the Health and Safety Policy Statement and any supplementary policies adopted by the Board n Arrange for the necessary information, instruction and training to be made available to staff to fulfil their roles n Arrange for the provision of up-todate information to employees on health and safety matters and for this to be recorded where required n Make appropriate arrangements for the keeping of statutory records on health and safety and for the reporting, when necessary, of injuries, diseases or dangerous occurrences in accordance with statutory requirements n Ensure that appropriate arrangements are put into effect to consult with employees and to encourage their active participation on matters concerned with their health and safety at work n Ensure that the company reports on our progress with regard to health and safety issues and meeting performance targets in the annual report in accordance with HSE guidance and Government Strategy. General responsibilities of all managers All managers are expected to actively support the Board in the development and proper implementation of the company s Health and Safety Policy and objectives. All managers, regardless of management position, are expected to demonstrate their commitment to health and safety by setting a good example themselves and by ensuring that health and safety is the number one priority when compared to other aspects of management activities within their own areas of control. Certain personnel have designated management responsibilities for implementation of the company s Health and Safety Policy. These responsibilities are summarised in the following sections. 07

10 Viridor Regional, divisional is a wholly and owned departmental directors and subsidiary heads of... of Pennon Group Plc and operates Must in accordance with the group s n Implement health the objectives and of safety this policy policies. n By leadership and personal example, foster positive attitudes towards health and safety throughout their region, division or department. Directors will ensure that health and safety is given the same priority and importance as any other corporate or business line objective n Consider the health and safety implications for employees and non-employees of decisions made at either a strategic or operational level and act accordingly n Ensure that their management team know, understand and are held accountable for their individual responsibilities under the company s Health and Safety Policy n Ensure that their management teams are provided with the appropriate resources in order to fulfil their health and safety responsibilities including the provision of information, instruction and training n Establish appropriate mechanisms to allow the dissemination of information, and communication and consultation on matters which affect the health and safety of employees within their region, division or department n Make the necessary arrangements to ensure that safe systems of work are implemented for all work activities and processes within their division, region or department and that their effectiveness is monitored and reviewed at timely intervals n Where health and safety issues cannot be effectively dealt with at their level, ensure that the matter is drawn to the attention of the Board. Regional and area managers (applies equally to operations managers) Managers falling within this category will also have line management responsibilities for staff and working practices directly under their control. They must n By leadership and personal example, foster positive attitudes towards health and safety and demonstrate commitment not only in words but through visible action within their teams n Consider the health and safety implications for employees and nonemployees of decisions made at either a strategic or operational level and act accordingly n Ensure that all individuals reporting to them know, understand and are held accountable for their responsibilities under the company s Health and Safety Policy and are provided with appropriate resources including training, information and instruction n Make the necessary arrangements to ensure that health and safety risk assessments are carried out for all work activities and processes within their area(s) of control, and ensure that safe systems of working are identified, recorded where appropriate, implemented, and that their effectiveness is monitored and reviewed at timely intervals n Establish mechanisms to ensure that safe working practices are at all times maintained to ensure the health and safety of employees and others who may be affected n Where managers have responsibility for buildings, plant and equipment, ensure that all statutory regulations and codes of practice are adhered to and that such plant and equipment is effectively maintained to a safe standard, including statutory inspections where required n Establish and maintain mechanisms to allow the dissemination of information and communication and consultation on health and safety issues n Where health and safety issues cannot be effectively dealt with at their level, ensure that the matter is drawn to the attention of their respective regional, divisional or departmental director n Make the necessary arrangements to ensure that representatives for employee safety are appointed and can effectively carry out their duties. 08

11 Our Objectives CAN Line managers WE ADD FEW (This applies to unit, site and WORDS HERE?? departmental managers) Line managers are responsible for effective health and safety management in the areas falling within their control and for people that they supervise. They are responsible for the detailed implementation of the company s Health and Safety Policy at a local level. They must n By leadership and personal example, foster positive attitudes towards health and safety and demonstrate commitment not only in words but through visible action within their sections or teams n Consider the health and safety implications for employees and non-employees of decisions made at an operational level and act accordingly n Ensure that all personnel under their control, including temporary and agency workers know and understand their responsibilities under the company s Health and Safety Policy n Ensure that all personnel under their control are adequately trained and competent to perform the task required and are made fully aware of all known hazards associated with their work. This applies particularly to new employees, temporary workers, agency workers and contractors n Ensure that staff are provided with correct personal protective equipment and clothing for the task and work activities that they are expected to undertake n Ensure that new employees, temporary and agency workers are inducted for health and safety immediately upon their commencement and that contractors are fully inducted prior to them commencing a work activity n Ensure that competent persons complete risk assessments for all work activities and processes falling within their areas of control that include employees and non-employees, and that safe operating procedures are put in place which incorporate the significant findings of risk assessment n Ensure that any health and safety measures introduced as a result of the risk assessments are monitored to ensure they are effective and that reviews are undertaken as and when necessary n Ensure that all accidents, incidents and near miss events falling within their areas of responsibility are promptly reported and appropriately investigated n Where managers have responsibility for workplaces, buildings, plant and equipment, ensure that all statutory regulations and codes of practice are adhered to and that such workplaces, buildings, plant and equipment are effectively maintained to a safe standard, including statutory inspections where required n Ensure that any health and safety matter brought to their attention by an employee, representative of employee safety or other person, receives prompt and appropriate attention n Ensure that any health and safety matter which cannot effectively be resolved by them is brought to the attention of senior management. 09

12 Head of Compliance (reporting to the Corporate Responsibility and Regulatory Director) The Head of Compliance has functional responsibility for the health and safety team in addition to advising and supporting Directors and management teams on all aspects of health and safety, in line with the company s health and safety strategy. The Head of Compliance s activities and key responsibilities will include n Interpreting new and existing UK and EC legislation relating to health and safety matters so far as they affect Viridor as an employer n Preparing policies, procedures, codes of practice and guidance on health and safety matters for approval and adoption within Viridor n Monitoring the application of policies, procedures, codes of practice and guidance notes and updating them as and when appropriate n Providing support and advice to the Board on health and safety, in particular assisting senior management teams in their duties to manage health and safety within their areas of responsibility n Maintaining statistical information on work related accidents and ill health and ensuring that statutory duties to report under the Reporting of Industrial Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) (as amended) are complied with n Formulating and publishing the annual Corporate Health and Safety Strategy and identifying SMART objectives for health and safety n As necessary assist in the investigation of accidents and incidents with a view to identifying measures to prevent recurrence and liaise with the enforcement agencies on health and safety n In consultation with the department heads, assist in the identification of training needs and provision of health and safety training n Developing and facilitating information flows relating to health and safety throughout the company, through the production of briefing notes, bulletins and training n Monitoring the effectiveness of arrangements for any external specialist health and safety support used by the company n Ensuring that appropriate arrangements are put into effect to consult with employees and to encourage their participation on matters concerned with health and safety at work n Maintaining liaison with external professional contacts, the Health and Safety Executive, external authorities, and other relevant bodies on health and safety matters and communicating relevant information internally. Health and Safety Advisors (operating in each region reporting to the Head of Compliance) Health and Safety Advisors are responsible for advising and supporting regional management teams on all aspects of health and safety, including risk assessment, accident prevention and the implementation of health and safety legislation, statutory regulations and codes of practice. The Health and Safety Advisors activities and key responsibilities will include n Interpreting new and existing UK and EC legislation relating to health and safety matters so far as they affect Viridor as an employer n Providing support and advice to regional management on health and safety, in particular supporting unit management in their duties to manage health and safety within their areas of responsibility n Participating in the investigation of accidents and incidents with a view to identifying measures to prevent recurrence and liaising with the enforcement agencies on health and safety where necessary 10

13 n Reviewing information on work related accidents, ill health, hazards and near-miss incidents and ensuring that statutory duties to report under the Reporting of Industrial Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) (as amended) are complied with n Conducting periodic inspections of the workplaces and work activities in conjunction with line management with a view to maintaining standards and identifying and advising on the elimination or control of the risks to health and safety n Providing assistance and guidance to line management in the production of risk assessments, safe operating procedures and safe systems of work n Monitoring and appraising safe working practices and making recommendations to regional management for their consideration n Assisting Regional Managers to organise and conduct quarterly representative for employee safety (RES) and safety representative meetings n Maintaining liaison with external professional contacts, the Health and Safety Executive, external authorities and other relevant bodies on health and safety matters, and communicating relevant information internally. All employees Every employee has a legal obligation to take reasonable care of their own health and safety and for that of others who may be affected by what they do or do not do. Viridor recognises the valuable contribution every employee can make through a positive influence on everyone they come into contact with. Specific responsibilities include n Not putting themselves or others at unreasonable risk to their health or safety and to stop work if unsafe, to make safe if possible and to notify people who may immediately be affected and then to report it promptly to their line manager if such circumstances arise n Complying with safe working methods, instructions and training given n Setting an example by their approach to safe and healthy working Viridor s contr n Complying with guidelines on the proper use of tools, machinery, plant, equipment and personal protective equipment n Complying with local health and safety procedures while on premises or sites under the control of someone else n Remaining alert to health, safety and security risks while at work and acting accordingly n Reporting to their supervisor or manager the need for additional health and safety procedures or for the improvement of existing ones n Not interfering with or misusing anything provided in the interest of health and safety n Being fit to work safely and not affected by alcohol, drugs or medicines which could affect the safety of themselves or others. 11

14 Representatives of employee safety (RES) and union appointed safety representatives The company recognises the benefits of communicating with its employees for the benefit of health, safety and to the business as a whole. Representatives of employee safety report to their respective line managers, but are appointed by the workforce to represent them in discussions with management on matters concerned with health and safety. Arrangements for trade union appointed safety representatives are in principle similar to those for representatives for employee safety. Both have a valuable contribution to improve health and safety standards and their active participation is encouraged. However, they act as representatives of the staff and do not have executive responsibilities. Their responsibilities include n Representing their fellow employees on health and safety matters n Communicating regularly with their fellow employees and the manager responsible for health and safety in the area where they work, to bring any concerns to the attention of management n Communicating regularly with their fellow employees and the manager responsible for health and safety in the area where they work, to bring any concerns to the attention of management 12 n Conducting regular inspections (independently or jointly with their manager) to ensure compliance with legislation, policy and procedures and identify risks to the health and safety of fellow employees, contractors and visitors, and to communicate any findings with their manager n Checking that local procedures for evacuation in an emergency are adequate, with appropriate signs, and that their fellow employees understand these n Participation in the investigation of accidents and near misses n Attending and participating in regular meetings with fellow safety representatives, to provide these meetings with information on health and safety matters from their areas of responsibility, and to communicate any content of these meetings to their manager and fellow employees. First aid and appointed persons Viridor s policy provides information to managers to allow them to carry out a first aid needs assessment to decide whether the risks require an appointed person or trained first aider. Suitable first aid resources and equipment e.g. first aid kits, emergency showers, eye wash facilities etc are provided as required on all Viridor premises and work sites, in addition a suitable first aid kit is located in all goods vehicles. n First aiders and appointed persons are responsible for checking that adequate first aid equipment is available, reporting incidents in accordance with the company accident reporting procedures and calling the emergency services. First aiders are also responsible for administering first aid in the event of an accident. n First aiders must hold a valid First Aid Certificate, and are required to undergo refresher training to maintain their competence. Regional Operational Systems Controllers (operating within each region) Regional Operational Systems Controllers (ROSC) are responsible for the administration of appropriate health, safety and environmental compliance control systems. The ROSC s activities and key responsibilities include n By personal example, fostering positive attitudes towards health, safety and environmental compliance, demonstrating commitment not only in words but through visible actions n Ensuring full and relevant control systems as set out in the company s management system are in place and maintained for all units n Assisting unit managers in maintaining accurate and up to date health, safety and environmental compliance documentation n Ensuring that action plans are in place that address areas of system non-compliance as a result of site audits, inspections, incidents and regulatory visits.

15 Temporary and agency workers Viridor has the same responsibilities for the health and safety of temporary and agency workers as for our own employees. The geographic spread of the company makes it impractical to have one agency supplying additional operatives. All agency operatives are provided through a coordinating provider. The coordinating provider is aware of the work the company carries out and the associated risks and our requirement that only suitable people are supplied. This includes screening for health conditions which could increase risk to their employees when working for Viridor and not supplying those individuals for work of a type which significantly increases that risk. Where specific skills or qualifications are required e.g. plant operator, administrative specialist line management has a responsibility to verify that those temporary and agency workers are suitably qualified or skilled. Before temporary employees commence their duties, they are given the same safety and health induction as full time employees and informed of correct working practices and safe operating procedures. They shall be issued with appropriate personal protective equipment, clothing/tools etc as required and instructed in the safe and correct use of such items. Whilst working for Viridor, temporary and agency workers have the same individual responsibilities for health and safety as any permanent employee. 13

16 Arrangements for health and safety All new employees receive health and safety training as part of our induction programme. Legal requirements The company maintains a Register of Legal Requirements that identifies the various health and safety regulations applicable to company activities. Risk assessment Good risk assessment, effective policies and the implementation of appropriate controls will ensure risks are managed and controlled to a reasonable level. Risk assessments are carried out by competent personnel and significant findings recorded and appropriate action taken to eliminate or reduce the risk to an acceptable level. Risk assessments are reviewed and updated periodically or when changes occur, particularly n Where there have been significant staff changes n When an accident/incident has occurred n Where there have been significant changes to the activity or process or working environment n When new or different equipment is being used n The aim is to review risk assessments and associated safe operating procedures every two years or at a frequency appropriate to the risk. Implementation and operation Health and Safety Assistance (Regulation 7 - MHSWR) The company has appointed an internal team of qualified health and safety professionals to assist and advise in applying the provision of health and safety law and, in particular, devising and implementing measures to ensure compliance with relevant health and safety legislation. External specialist support in health and safety The company may, from time to time, appoint competent external specialist support to assist with the adequate discharge of our responsibilities for health and safety. The Head of Compliance shall be provided with details of any such arrangements made by individual departments in order to verify competency. Training Viridor is committed to investing in its people and recognises the importance of an informed, competent and motivated workforce. The skills, knowledge and professionalism of employees are highly valued. Training needs are assessed based on risk assessment and reviews of each type of work that may require a specific qualification. All new employees receive health and safety training as part of our induction programme, including an awareness of the hazards associated with the industry and our operations and arrangements for first aid, fire evacuation and emergencies. 14

17 All permanent employees will hold a sector Safety Passport (where these are applicable to their job role) within three months of starting work. Basic skills and specific on-the-job training and training in health and safety procedures are provided as required. Other role/task specific training requirements include vocational qualifications and specific skills and accreditation. Supervisors will achieve Managing Safely and managers the NEBOSH General Certificate in Occupational Health and Safety. Directors will attend IOSH Directing Safely. Communication and consultation The company recognises the need for effective communications and takes steps to ensure that all personnel are well informed on health and safety matters. In pursuit of continual improvement of health and safety performance, the company has various formal methods of ensuring two way communication reaches employees at all levels in good time. These are held at a frequency not exceeding n Board meetings (monthly) Health and Safety Director and Corporate Responsibility and Regulatory Director n Regional health and safety committee meetings (six monthly) n Health and safety team meetings (quarterly) n Regional health and safety meetings (quarterly) n Area operational meetings (bi-monthly) n Unit/site/department meetings (monthly) n Representative for employee safety (RES) meetings (quarterly) n Quarterly health and safety update in company internal newspaper, and regular updates on the intranet as appropriate n Notice board updates as appropriate n Briefings and toolbox talks as appropriate. Health and safety policy and strategy review On a six monthly basis the Corporate Responsibility and Regulatory Director presents to the Board a formal review of the health and safety policy and an update on the health and safety strategy including a range of key performance indicators. This review highlights any changes needed to the health and safety policy and is the forum for directing the health and safety strategy, bringing forward any amendments and additions. Any deviations from the strategy are also discussed and the action plans for compliance are recorded. The Operations Director plays a key role in this process and together with the rest of the Board act as the central policy making body. Minutes of these reviews form part of the normal Viridor Board minutes. 15

18 Representatives of employee safety (RES) and union appointed safety representatives The value of day-to-day communications with employees and their representatives is recognised by the company. Appropriate training is provided for all representatives. The RES contribute to risk assessment, safety inspections and incident investigations in addition to representing fellow workers at meetings. Contractors All contractors and their subcontractors engaged to work on the company s behalf are given a suitable induction and issued with our Contractors Code of Practice, which sets out the standards expected of them when working for Viridor. In addition, information, guidance, rules and procedures relating to health and safety and any site specific hazards are provided. Visitors All visitors are made aware of safety rules and procedures affecting their health and safety on arrival at a Viridor facility or work site, given an induction as necessary and are restricted from entering hazardous areas. Workplace safety All company premises and work sites are required to meet minimum standards. Workplace inspection/site audit checklists are used by managers to monitor health and safety conditions and performance. In addition, there is a system in place for reporting n Workplace hazards n Defective plant/equipment n Accident/incidents and near misses n Unsafe acts and conditions and n For monitoring and reviewing progress of these reports. Management system The company management system is documented, structured and accredited to the requirements of the Occupational Health and Safety Assessment Series (OHSAS) specification. Accidents, incidents and near-miss reporting The company has implemented procedures to ensure that all accidents, dangerous occurrences and near-misses are reported, reviewed and the results analysed to identify trends and areas for further action to prevent a reoccurrence. Procedures are in place for reporting, recording and investigation of accidents and near-miss incidents, and the reporting of accidents required under RIDDOR. All accident/incident data is collated and reviewed for trends at unit/site, regional and company level. Reducing the risk of accidents and ill heath will be achieved through hazard reporting and behavioural observations to develop a culture which openly challenges unsafe acts and conditions. Health and safety auditing The company has implemented an audit programme and has established auditing procedures that are used to verify that the health and safety management system is operated correctly at all levels. The audit examines the implementation of the health and safety system against established standards. Audit procedures ensure that corrective actions are implemented and recommendations for improvements are made. Personal protective equipment (PPE) Suitable PPE is provided free of charge by the company where risks cannot be controlled by other means. Requirements are identified by risk assessment and, where required, PPE is routinely inspected to ensure that it is suitable for the purpose and in good condition etc to comply with the regulations. 16

19 Work equipment The company has implemented standards and procedures to ensure that work equipment is suitable for the intended purpose, complies with all relevant regulations and is regularly inspected and maintained by a competent person. Where faulty equipment is identified, it is taken out of service if unsafe and then repaired. Maintenance procedures including Planned Preventive Maintenance (PPM) are in place for many items of plant and equipment and across the business the company is implementing a common recording and programming system for PPM. Records of all inspections and repairs are maintained. Only appropriately trained and competent persons may maintain and/or operate work equipment. Lifting equipment, lifting operations and pressure systems The company has implemented procedures that ensure that lifting equipment and pressure systems are safe to use, are used by appropriately trained and competent persons, are suitable for the intended purpose, that lifting equipment is marked with a safe working load (SWL) and is inspected and thoroughly examined and, where necessary, tested by a competent person as required by legislation. Inspection records are maintained. Permit to work and lock-off systems The company has identified certain types of activity that are particularly hazardous, including (but not limited to) hot work, electricity, machinery and maintenance, working near water, work in confined spaces and exposure to dangerous substances and explosive atmospheres, and controls these using a permit to work system and/or an appropriate lock-off and isolation procedure as appropriate. Working in confined spaces The company has identified certain operations that require employees to enter and work in a confined space. Controls and procedures have been implemented to minimise the risks involved. These only allow such activities to be undertaken by employees or contractors who are competent and trained in accordance with the National Occupational Standards (NOS) NC1 4 for working in confined spaces. Electricity at work The company has appointed competent specialists to advise on the management and control of electricity and electrical systems and has implemented procedures to ensure that all fixed, portable and transportable electrical equipment and hard wired installations are correctly inspected, tested and maintained by competent persons at appropriate intervals. Procedures are in place for the isolation, reporting and repair/ replacement of faulty equipment. Workplace transport Transport plays a key role in the company s operations and the hazards from moving vehicles and plant can be significant. The company ensures that risks are effectively controlled by n Segregation of people from mobile equipment and vehicles n Management of transport activities n Training to recognised standards n Selection of equipment. Transport fleet Road going vehicles are highly regulated. Viridor maintains its fleet of vehicles to comply with appropriate legislation and industry standards and ensures drivers are competent. 17

20 Noise at work Where risk assessment has identified areas of excessive noise, appropriate noise monitoring is conducted. Where high noise levels cannot be eliminated using reasonably practicable measures, training and appropriate PPE is provided and ear protection zones are designated with appropriate signage prominently displayed. Musculoskeletal disorders from manual handling and repetitive work Where practicable, the company has eliminated the need for manual handling by using various lifting aids. Manual handling assessments are conducted where practicable. However, the nature of work in the sector is highly variable and employees are trained in safe lifting techniques which includes assessing risk from lifting and handling. Where automation is not practical and repetitive work is a necessary part of processing, workplaces and systems of work (which might include staff rotation) are implemented to control the risk. Slips and trips Slips and trips account for a significant number of injuries and the company recognises that slips and trips can happen for a number of reasons including n Contamination and obstacles n The working environment n Footwear, flooring and n People. The nature of waste handling and collection and the location of work is extremely variable and often on premises not controlled by the company. Risk assessment, information, equipment and training will assist to minimise risks from slips, trips and other hazards. Control of Substances Hazardous to Health (COSHH) The company has implemented procedures to ensure that substances potentially hazardous to health in the workplace have been identified, assessed and that exposure is controlled. Where use of the substance cannot be eliminated, a less harmful substance is substituted along with safe working practices to reduce the risk. A central inventory of all substances potentially hazardous to health is held in addition to the appropriate Material Safety Data Sheet (MSDS) and risk assessment. Control measures are maintained and records kept. Occupational stress Stress is not in itself an illness but can result in psychological illness and may contribute to physical illnesses. It can be considered as the adverse reaction people have to excessive pressure or other types of demand placed on them. The company is committed to protecting the health, safety and welfare of its employees and recognises that workplace stress is a health and safety issue and acknowledges the importance of identifying and reducing workplace stressors. Violence in the work place The company has a duty of care to protect its employees from all forms of harm including that which may occur from persons outside of its control e.g. customers, contractors or members of the public. As such, systems and procedures are in place to ensure the safety of our employees and (for areas where members of the public are on our sites) clear warning signs and information is displayed. The use of CCTV is also in place in many areas and the images are recorded where appropriate. If a verbal or physical attack against one of our employees takes place, the incident will be thoroughly investigated and the police involved. Viridor will press forward charges against persons perpetrating acts of violence whenever there is sufficient evidence to secure a prosecution. Counselling and support is provided to employees who are subject to acts of abuse and violence. 18

21 Display Screen Equipment (DSE) The company has implemented procedures to ensure that DSE workstation assessments are carried out. Where the findings of the assessment identify employees who use DSE as a significant part of their normal work, the company bears the cost of VDU eyesight tests and contributes to the cost of corrective eyewear where required. Health and safety signs and signals Adequate and appropriate warning signs that comply with the Health and Safety (Safety Signs and Signals) Regulations are posted to warn of hazards at all Viridor premises and work sites, and, where appropriate, on work equipment. Working at height The company has implemented standards and procedures to ensure that where work at height cannot be avoided, a suitable and sufficient risk assessment is carried out and a safe operating procedure is written for the task. A permit to work at height is required where risks are significant. In addition, where planned work involves sheeting of loads, maintaining vehicle mounted equipment at height, the use of cradles or cherry pickers or other mechanical means of working at height, appropriate training is given to operators on the correct use of the equipment. Carriage of dangerous goods To ensure compliance with the Carriage of Dangerous Goods and use of Transportable Pressure Equipment Regulations (the Carriage Regulations), the company maintains a number of staff who are fully qualified as Dangerous Goods Safety Advisers (DGSA) and has adopted procedures to ensure that all dangerous goods are documented and transported in compliance with the Regulations. Construction, Design and Management projects (CDM) The company has implemented project management procedures to provide a control framework for all construction work. HSE will be notified when construction projects are notifiable under the regulations. Asbestos regulations duty to manage The company acknowledges the health hazards arising from exposure to asbestos and protects employees and other persons potentially exposed as far as is reasonably practicable. Surveys have been undertaken on all Viridor premises which have identified the locations of asbestos containing materials (ACM) and an asbestos register is maintained and the condition of ACM is monitored and remediated if required. In addition, procedures have been established to prevent work being undertaken unless adequate control measures are in place to prevent fibres being released from ACM. Some Viridor waste sites are licensed to receive and dispose of asbestos. Monitoring and procedures are in place to comply with the legislation. Acquisitions and integration Viridor has been an acquisitive company and continual expansion forms part of its stated business plans. In acquiring businesses and contracts, Viridor is mindful of different standards of health and safety performance within the target organisation. Consequently Viridor has made and will continue to make significant investment in hardware, systems and people to effect the changes required to bring new organisations and their employees to the standards that Viridor require. Viridor will adopt any methods or systems which bring improvement. The focus shall always be on reducing risks and potential harm, both during the transition stage and in the on-going operation of the acquired organisation. This is particularly so when new or complex technologies are employed. 19

22 Fire safety The company takes all reasonable steps to prevent fire on its premises through design and organisation. A programme of inspection and maintenance is undertaken for raising the alarm, fire fighting equipment and means of escape. Employees are given adequate training in the use of fire fighting equipment. Fire evacuation drills are practiced and reviewed at appropriate intervals (according to site operations). Unit Emergency Plans (UEP) are established at each location. Emergency procedures Where risk assessment identifies significant risk, the company has implemented Unit Emergency Plans (UEP) and associated procedures. Employees receive training in the actions to be taken in the event of on-site emergencies. Visitors and contractors receive information and instruction on what to do in the event of an emergency as part of their site induction. Measuring performance Health surveillance programme The company has implemented a health surveillance programme to monitor the health of all employees who might be exposed to hazardous substances, noise or occupational health and disease risk at work as identified by risk assessment. The company has appointed external occupational health professionals to operate the company s health surveillance programme, screening employees who have been identified by their job role as being at risk of exposure and enabling any adverse health effects to be identified at an early stage so that appropriate action can be taken. Culture In addition to the routine opportunities to communicate through RES and other communication channels, at appropriate intervals the company will carry out surveys to gauge the effectiveness of its safety and health programmes, how they are communicated, viewed and applied. The results will be used to further actively engage with all employees to achieve Viridor s objectives of a positive culture and sensible control of risk, to the benefit of employees, the business and its partners. Reviewing performance Management review The health and safety committee formally reviews the Health, Safety and Welfare Management System to ensure its effectiveness, and compliance with current health and safety legislation on an annual basis. However, amendments may be introduced at any time. All line managers have health and safety responsibility as part of their role profiles (job descriptions) and they are regularly reviewed against this as part of the performance appraisal review process. Partnerships The company recognises the benefits of working with other organisations to improve health and safety standards within Viridor and the sector in general. To this end, it is supportive of and contributes to the work of the Health and Safety Executive (HSE), Environmental Services Association (ESA), Chartered Institution of Wastes Management (CIWM), Waste Industry Safety and Health (WISH) forum and Energy and Utility Skills (EU Skills) and other organisations as appropriate. Suggestions The company seeks to set the highest sensible standards of safe and healthy working for its employees and anyone who may be affected by any of its operational activities and welcomes suggestions from stakeholders on ways to further improve standards of health and safety. 20

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